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Nuclear Transparency Watch

Prevent and anticipate through transparency and participation

Transparency and Public participation

Nuclear energy and civil society conference at the European Parliament

🗓 17.10 : Nuclear Transparency Watch (NTW) was invited at the European Parliament in Brussels đŸ‡ȘđŸ‡ș for a conference on nuclear energy ☹ in Europe from a civil society đŸ‘„ perspective.

📄 Based on the Aarhus Convention and on the Environmental Democracy principles, this event co-organised by NTW with the European Environmental Bureau (EEB) and the member of NTW and Italian MEP, Dario Tamburrano (The Left) was introduced with a presentation from Yves Marignac (Institut NĂ©gawatt) on the management of nuclear risks in nuclear energy transition scenarios:

20241017-NTW-NuclearEnergyEurope-YvesMarignac

The roundtable introducing the debate welcome the following speakers: —
☑ Luke Haywood (Policy Manager on Climate and Energy policy at the European Environmental Bureau)
☑ Lorelei Limousin (Campaigner at Greenpeace Brussels)
☑ Dario Tamburrano (Member of the European Parliament)
☑ Nadja Zeleznik (Chair of Nuclear Transparency Watch)

The main safety concerns reported in the presentation from Yves Marignac were related to the following topics:
1ïžâƒŁ Lifetime extensions of nuclear power plants
The oldest operating European reactor is 55 years old and located in Beznau (Switzerland) therefore, there aren’t any experience for programme of lifetime extension to 80 or 60 years.
2ïžâƒŁ New reactors
Sovereignty concerns on Europe’s capacity to provide reactors were reported with questions related to the industrial and financial
capacities to manage many projects.
3ïžâƒŁ Fuel and waste management
New nuclear implies enrichment and fuel fabrication capacities as well as adjusted storage and disposal capacities.
4ïžâƒŁ Evolving concerns
Finally, the impacts of the climate change and of a rising geopolitical instability needs to be considered.

Jean Claude Delalonde, Chair of ANCCLI, recalled that: “… recently in France, civil society via ANCCLI đŸ‘„ was heard by parliamentarians on 2ïžâƒŁ laws related to nuclear issues ☹: one on the acceleration of procedures & the other on the reorganization of safety. This is a major step forward, and it’s vital that political decision-makers are able to hear the voices of civil society before forging their decisions. This is as true in France đŸ‡šđŸ‡” as it is in Europe đŸ‡ȘđŸ‡ș …”

In fact, NTW was established in 2013 following a call of members of the Parliament praising for Transparency and Public Participation in nuclear energy to improve the safety. It has been recognized that an early involvement of civil society can help decision making, this is why this conference will hopefully lead to another ones involving many other MEP and Civil Society Organisations representatives.

 

Transboundary participation and safety concerns

In the frame of the Consultation on the 4th periodic review of France’s 1300 MWe nuclear reactors, NTW provided the following statement:

Insufficient transboundary participation and the risk of French Nuclear Power Plants (NPP) for European countries.

Note: ANCCLI being a founder member of NTW and a member of the HCTISN it didn’t associate to this statement for obvious deontological reasons.

Insufficient transboundary participation and the risk of French Nuclear Power Plants (NPP) for European countries

The safety objectives for the continued operation of 1300 MWe reactors is to move towards the safety levels of the latest reactors (EPR). To date, 1300 MWe reactors have not achieved the highest levels of safety, and concerns persist about corium and the ability to dissipate heat in the event of core meltdown, as well as the safety of fuel pools.

The ASN guidelines regulating protection against flooding are outdated for a possible extension[1]. There are remaining doubts whether the Hardened Safety Core’s design against flooding events considered adequately the effects of climate change. In fact, regarding impacts of climate change in general, Patrick Lejuste (IRSN) said during the consultation that he was “very pessimistic” adding that “there are a lot of unknowns”[2]. Also, design basis earthquakes need to be defined not only on deterministic methods as this is no longer state-of-the-art[3].

Nuclear risk resulting from the French NPP fleet should not be underestimated and could probably impact other country in Europe. Calculations from the project flexRISK show a contamination risk in consequence of a severe accident in the old French NPP fleet for all over Europe.

The extension of reactor operation and, more generally, the arrival of new reactors (EPR) cannot be achieved without a thorough review of waste and fuel management, some links of which are under strain.

The risk to humans and environment resulting from severe accidents and from nuclear waste management has to be assessed and presented to the public, also from other European countries in a transboundary Strategic Environmental Assessment (SEA). The lifetime extension program constitutes a prominent part of the French energy policy and therefore falls in the scope of SEA Directive 2001/42/EC; moreover, as the French Multi-Annual Energy Plan also was not subjected to a transboundary SEA but only to a voluntary consultation.

If transboundary comments are appreciated, an English version of the consultation website and of all documents should be offered, too. Furthermore, NTW is concerned by the absence of consultation guarantors reported several times in order to ensure a real participatory process agreed on[4].

To preserve the trust and fruitful consultations of the participatory process, much greater access to resources must be possible for members of civil society such as local residents, NGO volunteers or young people.

We demand a transboundary Environmental Impact Assessment (EIA) for every lifetime extension of an old NPP beyond the originally foreseen lifetime of 40 years, especially in the lights of the new developments in the framework of the Espoo and Aarhus Convention which clarified the EIA obligation for NPP life-time extensions.

[1] https://www.umweltbundesamt.at/fileadmin/site/publikationen/rep0915.pdf 4.4.3, p.39.

[2] https://concertation.suretenucleaire.fr/media/default/0001/01/89713121a30d81cd976bcbca2ed8f218b79cd88f.pdf

[3] Results from the expert statement of the Austrian Government to the consultation.

[4] https://concertation.suretenucleaire.fr/media/default/0001/01/89713121a30d81cd976bcbca2ed8f218b79cd88f.pdf

Synthesis of the NTW’s results in EURAD

As an NGO dedicated to ensure and increase transparency and public participation in nuclear safety and security in all fields of nuclear activities[1], Nuclear Transparency Watch (NTW) found it relevant to be involved in the European Joint Programme on Radioactive Waste Management (EURAD).

When EURAD started in 2019, the programme was foreseen to include activities and Interactions with Civil Society (ICS) in the perspective of the Aarhus Convention[2]. Therefore, it was understood that Civil Society (CS) could contribute to enhancing decisions on safety and security of Radioactive Waste Management (RWM)[3].

ICS activities in EURAD were structured based on a so-called “double wing” model[4] that was established and tested during the previous European projects SITEX II[5] and JOPRAD[6] following a specific vision and development plan[7]. This model allowed regular exchanges in between 13 CS experts involved in various EURAD Work Packages (WPs) and 22 CS larger group members attending yearly ICS workshops as described in the figure here below.

Figure 1 – Structure of ICS activities in EURAD

The yearly ICS workshops organised by the CS experts for the CS larger group were based on the results obtained by the CS experts from their work for the WPs labelled as “strategic studies” (ROUTES[8] and UMAN[9]) and their work for the WP PMO[10] which included:

  • Interactions with R&D technical WPs.
  • Interactions with all stakeholders.
  • Evaluation of the CS contribution to EURAD.
  • CS coordination, organisation, integration, and reporting.

Figure 2 – ICS workshop n°6 in Ljubljana (April 2024)

Between 2019 and 2024, 17 deliverables were published by the CS experts on various topics by stimulating interactions with the CS larger group and with the technical partners of EURAD [11]. Moreover, NTW has organized 17 workshops, participated to 30 EURAD events and contributed in around 40 EURAD documents. This iterative process helped to identify and deepen the knowledge in the main areas of concern for CS towards RWM.

First and foremost, the importance of sharing a culture for safety and security was underlined as a cornerstone for any fruitful pluralistic interaction on RWM. Therefore, based on previous studies such as SITEX II[12] a charter for fruitful interactions was established and used as an evaluation tool for the ICS activities in EURAD[13]. It was also considered relevant to update the existing studies on safety culture with more concrete examples of ways and situations where it can be enhanced[14]. Developing the “double wing” model into a “third wing model” was one of the propositions made[15], another was to continue the diversification of ways for CS to participate  using existing tools such as the Pathway Evaluation Process (PEP)[16] – allowing pluralistic views on various RWM scenarios which had already proven to be very effective considering the feedback – or with new tools such as a visualisation tool designed by CS to be used as an interactive support enabling knowledge sharing and public participation[17].

Finally, to sustain and improve the Aarhus Convention pillars approved by the European Union[18] and the addition proposed by NTW in the BEPPER report[19], the concept of intergenerational stewardship[20] was studied as a means to maintain a safety culture through time until a final safe enough solution is found. This implies a recognition that the problem remains to be solved going against abandonment and amnesia.

Now that EURAD (2019-2024) is finished, a second phase of the programme (EURAD 2) is under final agreement with EC with NTW again foreseen as the coordinator for all CS organisations – which makes it important to share and evaluate the results of the first EURAD programme. This is why NTW has provided the following feedback for the evaluation of Euratom Research and Training Programme (2021-2025) which encompasses EURAD to assess the strengths and weaknesses of the Programme in the eyes of CS:

As an NGO involved in the Joint Programme on RWM EURAD, NTW has benefited from funding to represent civil society in the programme, in accordance with the first 2 pillars of the Aarhus Convention (access to information, access to participation) to help ensure the development of transparency and safety.

Results were obtained (e.g., production of deliverables on Transparency & Public Participation (T&PP) or Interaction with the Civil Society (ICS)) that envision better ways for interaction of different stakeholders involved in decision making procedures and research. Progress (e.g., double wing model of interaction and involvement in strategic studies) was made in understanding how to approach uncertainties through a shared culture for safety and security and what this could mean in the perspective of intra- and intergenerational stewardship.

However, there is still the need of sufficient structural and material support to develop a sustainable citizen engagement in a trustworthy environment independent from nuclear industry’s influence. Therefore, referring to the obligations under the Aarhus Convention art. 3(2), 3(3) and 3(4), it is necessary to include funds to develop civil society engagement structures to enhance civil society participation from a wider perspective and also in future research and training concerning the development of nuclear technology, including management of radioactive waste.

This is key to develop and implement processes, tools, knowledge, and relations that were previously established in the EURAD programme. If this is not continued, engagement towards transparency, public participation but also safety and security will suffer, as recognized by all stakeholders, who emphasized that participation of civil society in these research programmes is indeed indispensable in increasing safety.

List of publications per work packages in which NTW’s has been involved 

PMO

ROUTES

UMAN

MODATS

[1] Nuclear Transparency Watch statutes:
https://www.nuclear-transparency-watch.eu/wp-content/uploads/2024/05/NTW-statutes-2024-ENG.pdf

[2] Adopted on 25 June 1998, the Aarhus Convention is created to empower the role of citizens and civil society organisations in environmental matters and is founded on the principles of participative democracy. See: https://aarhus.osce.org/about/aarhus-convention

[3] EURAD – D1.14 Mid-term evaluation ICS activities and interactions EURAD participants and Civil Society: https://www.ejp-eurad.eu/publications/eurad-d114-mid-term-evaluation-ics-activities-and-experimental-model-interaction

[4] EURAD – D1.13 List of CS group members:
https://www.ejp-eurad.eu/publications/eurad-d113-list-cs-group-members

[5] SITEX-II is the acronym for “Sustainable network for Independent Technical Expertise of Radioactive Waste Disposal – Interactions and Implementation” (2015-2017). Its overall objective was the practical implementation of the sets of activities issued by the previous European research program SITEX (2012-2013). See: http://sitexproject.eu/

[6] JOPRAD is the acronym for « Joint Programming on Radioactive Waste Disposal” (2015-2017). The objective was to prepare a proposal for setting up of a Joint Programming that bring together at the European level, aspects of R&D activities implemented within national research programmes where synergy is identified. See: http://www.joprad.eu/about-joprad/rationaleobjectives.html

[7] The EURAD vision and EURAD deployment plan are two of the founding documents of EURAD.
All the funding documents are available here: https://www.ejp-eurad.eu/publications.

[8] https://www.ejp-eurad.eu/implementation/waste-management-routes-europe-cradle-grave-routes

[9] https://www.ejp-eurad.eu/implementation/wp10-understanding-uncertainty-risk-and-safety-uman

[10] https://www.ejp-eurad.eu/implementation/interaction-civil-society

[11] See the list of deliverables published in the Appendix.

[12] https://igdtp.eu/wp-content/uploads/2019/09/SITEX-II_D4.1-Conditions-and-means-for-developing-SITEX-network_FINAL.pdf

[13] https://docs.google.com/presentation/d/1WJW5URedhv4-Bvj5XeQAZscIYoocOHJ1/edit#slide=id.p1

[14] https://docs.google.com/presentation/d/1IgDUkKpokcO0HIMn6ufBugfthjsXYaJN/edit#slide=id.p1

[15] https://docs.google.com/presentation/d/1TK6e0og1-z-m-xiUOuf0c2_0Qh0gGJ3l/edit#slide=id.p1

[16] https://www.sitex.network/projects/

[17] https://docs.google.com/presentation/d/18kSmg9VybMynwHDRAtL7uKBtW9KrJjxW/edit#slide=id.p1

[18] Access to information, access to public participation and access to justice.

[19] Access to resources. See: https://www.nuclear-transparency-watch.eu/wp-content/uploads/2016/04/NTW_Transparency_in_RWM_BEPPER_report_December_2015.pdf

[20] https://docs.google.com/presentation/d/1hl4Za69yMx60DGuqEJ53qTxew4_OTUmr/edit#slide=id.p14

Evaluation of Euratom Research and Training Programme 2021-2025

The contribution of Nuclear Transparency Watch for the Evaluation of Euratom Research and Training Programme 2021-2025 is available here: https://t.co/1jSf4zGPx2

As an NGO involved in the Joint Programme on RWM EURAD, NTW has benefited from funding to represent civil society in the programme, in accordance with the first 2 pillars of the Aarhus Convention (access to information, access to participation) to help ensure the development of transparency and safety.

Results were obtained (e.g., production of deliverables on Transparency & Public Participation (T&PP) or Interaction with the Civil Society (ICS)) that envision better ways to interact with different stakeholders involved in decision making procedures and research. Progress (e.g., Double wing model of interaction and involvement in strategic studies) was made in understanding how to approach uncertainties through a common shared culture of safety and what this could mean in the perspective of intra- and intergenerational stewardship.

However, there is still insufficient structural and material support to develop sustainable, trustworthy (from industry’s interests) independent citizen engagement. Therefore, referring to the obligations under the Aarhus Convention art. 3(2), 3(3) and 3(4), it is necessary to include funds to develop civil society engagement structures to enhance civil society participation from a wider perspective and also in future research and training concerning the development of nuclear technology, including management of radioactive waste.

This is key to develop and implement processes, tools, knowledge, and relations that were previously established in the EURAD programme. If this is not continued, engagement towards transparency, public participation but also safety will suffer, as recognized by all stakeholders, who emphasized that participation of civil society in these research programmes is indeed indispensable in ensuring safety.

This contribution was developed by the European Environmental Bureau, Jan Haverkamp, Kobor Joseph, Colin Wales and other members of NTW Management Board.

Nuclear safety put to the Common test

In this article named, Nuclear safety and the Common, the authors, Gilles HĂ©riard-Dubreuil and Julien DewoghelaĂ«re have provided a study on the notion of Common in relation of the nuclear safety in the French context. This article has been published with other articles on the notion of Common in the frame of a collective publication named “Dynamiques du Commun” (2021).

The introduction is reported below, while the full article is accessible there.

“Civil nuclear power generation activities are associated with very significant risks for humans and the biosphere. They also give rise to the production of dangerous radioactive materials, the presence of which must be envisaged for very long periods, and even infinite from the perspective of a human life itself.

From the very beginning, these activities have been the subject of strong political opposition from various groups within the populations of the producing countries and at international level. These confrontations involve pro-nuclear and anti-nuclear players, with a relatively indifferent public in the background, with the exception of periods of concern caused by the Chernobyl and Fukushima nuclear accidents. The opposition to these activities is based on the rejection of exposure to nuclear risks and their potential consequences at national and international level. The possibility of safe management of nuclear activity is a central object of controversy.

This contestation also concerns the technical, economic and social relevance of the choice of nuclear power generation, particularly in the current context of energy transition. Nuclear activities are facing a deterioration in their economic model, with a sharp rise in productivity requirements, combined with stricter European regulations restricting state aid and increased financial and economic transparency5, which in Europe is limiting the public support from which this activity has historically benefited.

The European context today is characterised by a wide disparity in energy choices, particularly where nuclear power is concerned. Only some European countries are involved in nuclear production, often in connection with military nuclear activities. Some of these countries have decided to withdraw from nuclear power at different times. They are planning a transition to other forms of energy production. But phasing out nuclear power does not mean phasing out nuclear safety, which remains a long-term or even very long-term issue for these countries. Ultimately, nuclear safety is an issue for all European countries. Indeed, serious nuclear accidents are always of a cross-border nature and the management of radioactive materials, although a national responsibility, remains a common safety issue for Europe’s neighbours.

Nuclear safety requires a wide range of technical, scientific, economic, social and political conditions to be met. As a result, safety is highly vulnerable to changes in the economic climate affecting the industry, in an unstable international context that differs in many respects from that which prevailed in the second half of the last century. A systemic deterioration6 in nuclear safety and security conditions could result from these profound changes in the national and international context. The ability of dyadic governance between State and Market to support nuclear safety requirements in an unfavourable economic climate is questionable. At European level, this situation is a new factor which tends to make nuclear safety a common issue for the peoples of Europe.

A study of the governance of nuclear activities since their inception reveals a profound evolution, the most recent stage of which, in Europe, is based on the societal recognition of nuclear safety as a common problem (with, in particular, an increase in the power of the European institutions on this issue), over and above the diverse positions of the Member States with regard to nuclear energy. Favoured in particular by the Aarhus Convention (1998), this development has the seeds of a gradual recomposition of nuclear safety governance, with the institutional components of safety interacting in a Common dynamic: 1) the operator (the Market), 2) the State and its institutions and 3) civil society. This move towards triadic governance could ultimately bring about a political rebalancing of the negotiation processes that govern the establishment of nuclear safety rules and standards.”

 

 

Bulgaria: NPP Kozloduy and SLAPP case against citizen Natalia Stancheva

NTW is happy to inform about the unprecedented claim of 500,000 BGN (253,837 euro) – a SLAPP case filed by the Kozlody Nuclear Power Plant (NPP) against the nurse Nataliya Stancheva who revealed violations of the law at the Bulgarian nuclear power plant – has been withdrawn (see NTW’s position on the case below).

After Nuclear Transparency Watch, Dr. Petar Kardzilov reached out to the Bulgarian media and organized a protest in front of the Ministry of Energy in defense of Nataliya Stancheva. Publications in leading media and an invitation to Natalya and him on an evening talk show followed. All this contributed to putting pressure on the Kozloduy NPP to withdraw their shameful lawsuit against the woman who exposed the corruption scheme with the polyclinic operating at the NPP site using her right according to the Access to Public Information Act.
 
However, now, according to Natalia’s information, the illegal polyclinic continues to function and no one in the state is checking and taking action to eliminate it. Actions in this direction are also forthcoming with Dr. Petar Kardzilov’s colleagues from Bulgaria at NTW, Albena Simeonova and Borislav Sandov. According to Natalia’s information, a bank, pharmacy, shops and other illegal sites also operate at the site of the Kozloduy NPP. Below are the media publications in Bulgarian.
Publications after the position of NTW and the gathering in support of Natalia Stancheva before the Ministry of Energy:
 
An international organization calls on the Kozloduy NPP to withdraw a case against a citizen
Citizens protest in defense of the nurse fired from Kozloduy NPP
Kozloduy NPP to withdraw the claim against an employee who revealed violations, European organization called
Protest after an unprecedented claim for half a million BGN of Kozloduy NPP against a former employee
Protest in support of the nurse sued by the Kozloduy NPP for BGN 500,000 in a slap case. The case is an embarrassment to the management of the plant. Brutal, unheard of and unprecedented insolence, said the non-governmental organization Nuclear Transparency Watch
On the territory of the “Kozloduy” NPP there is also… a pharmacy, a restaurant, a bank This is what Petar Kardjilov from Nuclear Transparency Watch claims
In support of Natalia Stancheva – citizens protested in front of the Ministry of Energy
UNHEARD OF: “Kozloduy” NPP prosecuted its employee with a lawsuit for half a million BGN! The office of occupational medicine at the headquarters has been turned into an unregistered polyclinic, the woman reveals
A former employee of Kozloduy NPP is being sued for BGN 500,000, they defended her during a protest
Slavi Trifonov’s evening show, January 25, 2024.

 

… [Read More]

NTW heard by the Senate on reorganising nuclear safety in France.

Project of law on the organisation of the governance of nuclear safety and radiation protection protection to meet the challenge of revitalizing the nuclear industry.

* * *

Hearing by Mr Pascal Martin, Senator, Secretary of the French Committee on Spatial Planning and Sustainable Development

* * *

Round table discussion with representatives of the Réseau Sortir du Nucléaire, France Nature Environnement (FNE)
and Nuclear Transparency Watch (NTW).

The position below was presented at the hearing by Mr Julien Dewoghélaëre, member of the
Management Board of Nuclear Transparency Watch (NTW).

Thursday 11 January 2024 from 10:00 to 11:00, in room 261 (15 rue de Vaugirard)

______________

The European network Nuclear Transparency Watch (NTW) was set up in 2013 following a call “for vigilance on nuclear transparency” by a group of around twenty Members of the European Parliament from different political backgrounds.

The NTW network brings together more than fifty members (individuals and organisations) from twenty European countries. from twenty European countries, and promotes a citizens’ watch on nuclear safety and transparency around nuclear issues.

In the spirit of the Aarhus Convention’s principles of access to information, public participation in decision-making and access to justice in environmental the NTW network seeks to :

  • Increase the contribution of civil society to the governance of nuclear activities activities (including participation in European research projects) with a view to improving safety,
  • Raise awareness among political decision-makers and European society of the need for decision-making processes in nuclear matters at local, national and European levels.

Nuclear Transparency Watch’s activities cover all aspects of the nuclear cycle: issues relating to nuclear safety and security, problems associated with the ageing and life extension of nuclear facilities, new build and the decommissioning of old facilities, radioactive waste management, emergency preparedness and nuclear safety.

In particular, the network is involved in European research projects on the above-mentioned subjects, it is also involved in partnerships with the European Commission on transparency in the nuclear sector in Europe (BEPPER report) and access to information and public participation (Aarhus Convention & Nuclear – ACN multi-stakeholder round table process).

In view of its activities and missions, NTW has closely followed the project to the reform of the French nuclear safety expertise and control system, and more specifically the planned merger of ASN and IRSN. On 16 March 2023, the NTW network wrote, with 12 European associations and 23 MEPs co-signing, an open letter to the French Minister for Energy Transition, AgnĂšs Pannier-Runacher, to express its concern at the urgency with which the reform was being carried out and underlying the fact that the reform was not based on an impact study nor on any dialogue with stakeholders.

NTW also responded favourably to OPECST’s request for a hearing in June 2023 to give the NTW network’s opinion on the consequences of a possible reorganisation of ASN and IRSN. Its position on this issue revolved around four points that underlined the importance of preserving the qualities of the current French system:

  • The exemplary nature of the French control system, recognised as a model at European level and the importance of strictly independent expert assessment institutions,
  • The ability of the French control and expertise system to maintain a link between and expertise, as well as a pluralism of expertise that guarantees the quality of quality,
  • Maintaining a high level of commitment to exchanges and research conducted at European level on the various technical and socio-technical issues related the nuclear sector,
  • Maintaining the development of a shared safety culture and openness to civil society in the spirit of the Aarhus Convention.

Since this hearing, France has passed a law on the acceleration of procedures relating to the construction of new nuclear facilities (22 June 2023) and the OPECST report has been made public. Following on from this, a bill on the organisation of the governance of nuclear safety and radiation protection to meet the challenge of relaunching the nuclear industry was tabled in December 2023 and is currently being examined by the Commission for Spatial Planning and Sustainable Development.

In this context, NTW is today responding to the Committee’s request for a hearing to give the NTW network’s opinion on this bill. Its position on this issue revolves around four points which, in its view, highlight the risks of weakening the nuclear safety nuclear safety system presented by the bill in its current form:

Axis 1 – A decline in transparency, undermining the safety system and public trust public confidence

Contrary to the stated objectives of enhanced safety and transparency, some of the provisions of the bill seem to us to lead to a regression in this area in comparison compared with the current system.

Regulating the publication of expert opinions by means of provisions in the internal regulations of the new entity combining the functions of the ASN and the IRSN does not provide the necessary transparency. of the new entity combining the functions of the ASN and the IRSN does not provide the same the same guarantee as the current legal provision prescribing the publication of IRSN notices.

In the same way, referring the question of the separation of the expert appraisal and the separation of the appraisal and investigation processes is a step backwards in terms of transparency. On the contrary, this crucial issue should be at the heart of parliamentary discussions, because it raises the question of the guarantees of the independence of the from decision-making on nuclear safety. In the current system, which is seen in European research circles as a model to follow, the presence of two separate the presence of two separate institutions guarantees independence from external pressures and an internal requirement for rigour in the production of opinions. In the new system prescribed by the bill, it is to be feared that positive opinions will be published and the unfavourable opinions “forgotten”, reducing the quality of the system’s safety.

This reduction in transparency and weakening of guarantees of independence threaten public confidence in the safety system. At Moreover, the opposition of a large number of IRSN staff reinforces the risk of weakening the safety system at a time when, on the contrary, it needs to be strengthened since the stated objectives are to increase the number of nuclear installations.

Axis 2 – Risks associated with the decline in R&D in safety and radiation protection

The quality of the current system is based in particular on the development of high-quality research to support expert assessments, which has been the fruit of twenty years of effort within IRSN to guarantee the quality of scientific and technical risk assessments. This high-quality is carried out at all levels (local, national, European and international). If the merger goes ahead, it will be essential to ensure that all research activities are transferred to the future ASNR. NTW has seen the driving role played by the IRSN in European research activities (particularly around the issue of radioactive waste management) and a withdrawal of the new authority from these research activities would send a very bad signal to the partners within the EU.

In addition, certain elements, such as the drafting of decrees preparing for the transfer of certain IRSN projects to the CEA, or the provisions of Articles 5 and 7 of the bill, which transfer IRSN’s assets, rights and obligations in the area of research to the CEA, present a significant risk to the autonomy of the expert assessment function (which needs independent research within it) and presage a return to the much-criticized situation that led to the creation of IRSN.

Axis 3 – Keeping expertise open to society

Over the past twenty years, IRSN has also developed initiatives to open up to society, giving citizens access to information and increasing their skills in safety and radiation protection, thereby contributing to the development of a shared safety culture.
For NTW, the bill must not be a step backwards and should include guarantees to preserve the innovative actions developed in this area: technical dialogues, inclusion of civil society in the preparation of opinions (example of the actions carried out as part of the fourth periodic review of the 900 Megawatt reactors in the French nuclear fleet), opening up IRSN research to civil society (Research Steering Committee) in order in particular to ensure that research also responds to society’s questions. In addition to reiterating the importance of this public participation, the bill makes no mention of concrete measures to ensure that these actions are maintained.

Axis 4 – A rushed project that is not compatible with safety issues

In March 2023, NTW, along with others, expressed its concern about the hasty form that this project to reform the governance of the safety system was taking. While the OPESCT report was a first step towards a necessary analysis of the benefits and risks of such a reform, it is clearly no substitute for a complete and contradictory evaluation of the existing system. This report does not that the current system is unsustainable, nor on the consequences of the merger. The current French organisation works well and has won the confidence of the French people, which was not the case in the past. Moreover, it is a model that is seen as positive abroad as positive.

For NTW, while rethinking the organisation of the safety system is understandable, the current project seems to be rushed, with a high risk of undermining the existing system at a time when the challenges ahead require stability and confidence. The date planned for the entry into force, 1 January 2025, leaves little time for the Senate and the National Assembly to consider the consequences of implementing the bill with all the stakeholders concerned.

Nuclear Waste Management in the EU: Joint Project Report

Nuclear Waste Management in the EU: Joint Project Report –

Update 2023

2023-07-31

Nuclear waste from NPPs remains an unsolved and highly dangerous problem, as spent fuel must remain isolated from the environment for a million years.

In an attempt to solve the nuclear waste problem, an EU-wide directive was introduced in 2011, the “Council Directive 2011/70/Euratom establishing a Community framework for the responsible and safe management of spent fuel and radioactive waste”. This directive tried to force EU member states to address the issue seriously, after this had been neglected for decades – thus immediately proving that nuclear waste has never been effectively dealt with.

The Joint Project has been active for years in monitoring the implementation of the Nuclear Waste Directive, especially with regard to transparency and opportunities for public participation.

The 2023 update of our report is available here.

EP&R: Is Bulgaria ready to react in a nuclear crisis?

Analysis by Dr. Petar Kardzhilov on the answer of the Ministry of the Interior to his application according to the Access to Public Information Act.

There is a delegation of responsibilities from the minister of interior to the Main Directorate Fire Safety and Protection of the Population (FSPP), which are not legally justified because, according to the regulations, they are expressly prescribed for the Мinister. On the other hand, there are serious gaps in the regulatory framework, which are a factor in an unnecessary and dangerous division between the structures of FSPP at the Ministry of Interior around the country and the regional and local authorities.

After the strong interest of 46,000 readings on the “Aktualno” website to the publication with questions in my application according to the Access to Public Information Act (APIA) to the Ministry of the Interior (MI), regarding the prevention and preparation in Bulgaria for a crisis with high radioactivity in the environment, I offer a comment and analysis of the answers in the access decision of the ministry , signed not by the minister but by director of the Legal and Normative Activity Directorate, Mr. Hristo Stefanov.

Regarding the first question, concerning the need for citizens to have prior knowledge of how to react in situations with high radioactivity, the MI answers that the preventive activity is carried out by the bodies of FSPP under the MI, although in the Disaster Protection Act (DPA) and in the Ordinance for Emergency Planning and Emergency Preparedness in the Event of a Nuclear and Radiation Accident (OEPEPENRA) there are duties and responsibilities assigned specifically to the Minister of the Interior. Neither in the act nor in the ordinance is written that the minister can delegate his duties and responsibilities to FSPP. In particular, no answer is given, for example, whether the Minister agreed together with the Мinister of Education on the requirements for training in disaster protection in the system of preschool and school education, which the latter is obliged to approve, according to Art. 16, par. 3 of the DPA. In the answer, there is also no information that the minister has coordinated educational activities in the system of higher education according to the following par. 4 and 5 of Art. 16. There is no answer to the question of whether the Minister has approved programs for training the population on behavior and actions in an emergency situation and for specialized training of the executive authorities on the implementation of the external emergency plan, for which he is obliged according to Art. 21, para. 7, points 5 and 7 of OEPEPENRA. No information is provided as to whether and how the FSPP fulfilled these duties that the Мinister illegally delegated to them.

Attention deserves the answer from the Ministry of the Interior to the first part of the first question: “In what ways, in which settlements, in what locations and how often do the specialized state bodies work with citizens to create, as well as refresh the necessary prior knowledge with the aim of strict implementation by the citizens of protective measures to limit the harmful consequences for them in case of emergency situations with increased radioactivity in the environment?” The answer is: “In MI-FSPP, systematized information is not processed and stored according to the criteria set in the application for the frequency and number of trainings conducted by FSPP authorities in populated areas specifically on the subject of nuclear and radiation accidents.”; The lack of such information and archive means that the citizens have no way to find out whether and how the statutory duties of the Minister directly delegated to FSPP are fulfilled, both to date and in previous years decades ago. From the overall answer to the first question in the application, according to APIA, it is clear that the MI does not implement the DPA and OEPEPENRA, which necessitates the need for legislative changes, both essentially in the regulatory framework for preparation and radiation protection, as well as for control over the fulfillment of the duties of the institutions liable according to the law.

From the answer to the second cluster of questions: “Are there external emergency plans developed for all regions, coordinated by the Minister of the interior and approved by orders from the regional governors according to Art. 9 of OEPEPENRA? For which regions and municipalities in the country do such plans exist, according to the provision of Art. 16, par.2 of OEPEPENRA and Art. 9 of the DPA? Please indicate where these emergency plans are available to the public? ”, after one page of general information, it is clear that the MI does not know at all whether and which districts and municipalities in Bulgaria have emergency plans. This means that the current or former ministers of the interior have not fulfilled the provisions of Art. 9, par. 17 of DPA (effective from 07.05.2016) – to conclude agreements with regional governors and mayors regarding the implementation of these plans: “(17) In connection with ensuring the implementation of disaster protection plans under para. 4, 8 and 10, agreements are concluded between the Minister of Interior, the regional governor or the mayor of a municipality and the persons under chapter four, section II.” In the answer to the question, there is no information that the Minister has coordinated the development of emergency plans for populated areas, which is his responsibility according to Art. 9, par. 3 and Art. 16 from OEPEPENRA.

From the answer to the third cluster of questions about siren systems for early warning, we understand that for 39.33% of the citizens of Bulgaria, alarming is provided with modern systems. That is, the people living in Sofia, Plovdiv, Varna, Burgas, Ruse, Pleven, Pazardzhik, Montana, Smolyan, Kardzhali, Vratsa, Stara Zagora, Galabovo, Tsarevo, Ahtopol, the village of Lozenets and all settlements in the 30 kilometer zone around Kozloduy NPP may hear various siren signals, accompanied by a message of what type and with what threats the emergency situation is. In other settlements in the country, air raid sirens are used, without a voice message. Regarding the latest
ones, the Ministry of the Interior says that they are checked once every two years, but they do not say when they were checked for the last time and whether they are all in working order. It is also clear from the answer to this question that no serious tests and studies have been conducted, and there are no written reports on the audibility of sirens by all citizens in a given settlement, as well as on the audibility and intelligibility of voice messages and commands. We also understand that for this important part of radiation protection there is no documentation and no archive has been created.

From the answer to the fourth cluster of questions about prophylaxis with potassium iodide tablets, we learn that suitable tablets are available almost all over the country. I write almost all of it because of the expression “(…) as well as partially for the regions of Veliko Tarnovo, Lovech and Pleven”. Although according to the law they are obliged to buy and deliver them to the municipalities, the MI doesn’t answer the exact amount of tablets in municipalities, but they write that there are enough, including for foreign citizens and guests of the country. There is also no answer to the question of where the tablets delivered to the municipalities are physically located and how they are stored.

After another half page of general info, we indirectly get an answer to the most important question in this cluster – there is no centralized and uniform protocol for the time, places and ways of distributing the tablets to citizens: “According to the Ordinance on the Order of Creation, Storage, Renewal , Maintaining, Providing and Accounting for the Stocks of Personal Protective Equipment, the mayors of the municipalities prepare logistical schemes for the provision of individual protective equipment to the population if necessary, which are updated annually. Logistic schemes should be available in the respective municipal administrations.” Since each mayor decides for themselves how to distribute tablets, and the MI has no idea and control over who decided to do what, the result in the event of a crisis will certainly be panic actions and severe consequences in places. This leads us to the conclusion of a very serious gap in the Bulgarian legislation.

The answer to the fifth group of questions concerning evacuation procedures also speaks of a serious gap in the legislation. The MI admits: “The legislation in the Republic of Bulgaria does not contain norms obliging MI to collect and store data on the settlements in the country that have evacuation plans. Calculations for evacuation and dispersion in the event of a disaster/accident are part of the respective regional or municipal disaster protection plans, which are published on the website of the relevant administration.” It is grossly inadequate that the MI, which is responsible for the public order and the security of citizens in the country, does not know who, where and how should evacuate in case of a crisis. This gap is a condition for chaos, incidents, accidents, looting, exposure of citizens to high doses of radiation and other damaging events in a nuclear accident crisis or attack. The ministry doesn’t even know how many and which settlements have evacuation plans.

Even more unacceptable, absurd and in complete contradiction to the law is the answer to the biggest sixth cluster of questions from the application under the APIA, concerning the availability of individual means of protection for citizens in a crisis with high radioactivity. The MI writes: “The Minister of the Interior, respectively the MI, is not obliged by law or by-law to collect statistical data on the individual means of protection available in the country. Because of this, they are not obliged entities within the meaning of Art. 3, par. 1 of the APIA for providing the requests in point 6.2 of the application for public information.” How then, if they think that they are not obliged to collect data, do they fulfill the obligations of the minister, arranged in Art. 21, par. 7, point 13 of the OEPEPENRA: “The Minister of the Interior supervises the maintenance of the readiness of the individual and collective means for the protection of the population” ?! There is no answer to the question of how Bulgarian citizens can get life-saving protective equipment, written in a leaflet by “Kozloduy” NPP, uploaded to the website of the MI – FSPP: civilian gas mask, children's gas mask, respirator, child safety camera. The answer to this group of questions also ends with the admission that the MI don’t store information and don’t have control: “At the Main Directorate FSPP to the MI no information is stored according to the criteria specified in the application – what exactly, how many individual means of protection, where they are located, how many of them are suitable and how they will be distributed in the event of a nuclear accident.” Thus, when a crisis with dangerously high radiation level occurs no one, including the MI, will know how, with what means to protect themselves and, contrary to the more correct decision to stay in the buildings, many people will run in panic, which will most likely lead to far more severe consequences.

The answer to the last seventh cluster of questions about information and communication doesn’t offer other options for activation, except for the siren system, national television and radio, the websites of the municipalities, the FSPP and the Nuclear Regulatory Agency. With the highly developed modern telecommunication and online network capabilities, a much more secure and qualitative structure for information and communication can be developed, but, as can be seen from the response, the MI is not working in such a direction. Even the crisis call center, which is mandatory for every large-scale disaster/accident/attack, is not provided as an opportunity for information, communication and control over the situation by the structures of the FSPP in the country.

In conclusion, from the whole answer of MI it is clear the statement that there are several legal and by-law requirements in the DPA and OEPEPENRA, which are not complied with by the MI, because the institution does not accept them as their obligations. There is a delegation of responsibilities from the Minister to MD FSPP, which are not legally justified because, according to the regulations, they are expressly prescribed for the Minister. On the other hand, there are serious gaps in the regulatory framework, which are a factor in an unnecessary and dangerous division between the structures of MD FSPP in the country and the regional and local authorities. There is a lack of data on a sufficient number of quality activities for the preparation and prevention of crisis with high radioactivity levels, working together with the structures of the MI, local authorities, educational services, private organizations and citizens.

Petar Kardzhilov is a Doctor of Public Communications and Information Sciences at Sofia University “St. Kliment Ohridski”, a specialist in risk and crisis communications, a member of the Union of Scientists in Bulgaria, a qualified expert at the international NGO for transparency in nuclear energy “Nuclear Transparency Watch”.

Abbreviations:
MI – Ministry of Interior
FSPP/MD FSPP – Main Directorate Fire Safety and Protection of Population
DPA – Disaster Protection Act
APIA – Access to Public Information Act
OEPEPENRA – Ordinance for Emergency Planning and Emergency Preparedness in the Event of a Nuclear and Radiation Accident

RWM : interactions with civil society on technical topics

In 2023, a new process of dialogue has started with the goal to experiment a joint work between civil society and IRSN on the basis of a co-constructed scenario (accident scenario in the operational phase of the repository or scenario of changes in the post-closure phase of the repository) with a view to a shared assessment of the associated safety issues.

Different types of participation were foreseen for the civil society from a general and continuous participation to a punctual and specific participation. In fact, three groups were established to consider three different themes during three different period:

  1. Basic data retained for the Cigéo safety assessment: site, inventories of radioactive waste intended for disposal, disposal components, etc. (April 2024).
  2. Evaluation safety in the operating phase (autumn 2024).
  3. Evaluation safety in the post-closure phase (mid-2025).

Find out more about it there in French: DT-DAC-Cigeo_Bilan-perspectives_12_07_23

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