Opinion Columns

Heated fusion of the nuclear energy governance model in France

25 October 2024

Some background

In 🗓 February 2023, the French government announced its intention to merge IRSN, the nuclear expert body 🔬☢️ with ASN, the regulator authority, foreseeing with this the end of the dual model for the nuclear energy safety governance in France 🇫🇷.

This came as a shock since this model was praised internationally, especially after the Fukushima disaster 🗾🌊☢️, as a better model to be followed. Even more surprising for the barely 3000 employees concerned, this decision came without any previous notice or concertation of the institutional bodies constituting the very core of the safety governance model in France 🇫🇷.

Despite no impact assessment and a trans-partisan opposition coming from many elected official and nuclear experts 👩🏽‍🔬☢️, warning about the possible risks linked to such a disruption, the text was put to the vote at the French National Assembly 🇫🇷. Anyhow, after being ❌rejected a first time in 2023, the proposal, included in the nuclear acceleration law 📄☢️, was then ✅approved when presented a second time on 🗓 Tuesday 19 March 2024, with only 260 votes in favor and 259 votes against…

Enacted the following month in May 2024, this law led to the creation of a new entity called ASNR meant to start operating for 🗓 the 1st of January 2025 leaving only 7 months⏱ for both ASN and IRSN to organize themselves.

Nuclear Transparency Watch (NTW) involvement

In this context, NTW reacted immediately after the decision was made public, raising concerns on the outcomes for the safety of such a decision in an open letter to the then French Minister of Energy Transition co-signed by 11 other NGOs and 22 Members of the European Parliament 🇪🇺.

NTW was also invited to be heard by the for a consultation of the OPECST in June 2023, and by French Deputies, in 2023, and French Senators, in 2024, to give its opinion on the consequences of the foreseen fusion of ASN and IRSN. Its position on this issue revolved around the following four points that underlined the importance of preserving the qualities of the current French system 🇫🇷:

The exemplary nature of the French control system, recognized 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.

Also, the first open letter being left without response, NTW sent another open letter in March 2024 to the new Minister in charge who answered in 🗓 June 2024 with a letter (part 1 and part 2) ensuring that the new entity would be as transparent, as safe and as open to the civil society as what was functioning in the previous dual system.

However, even before the operation of the new ASNR, a major conflict of interest risk is pointed out by several NGOs ⚠️🧐 as the current Director General of the French National Agency for the Management of Radioactive Waste (ANDRA)🛢☢️ is foreseen by Emmanuel Macron to lead the future nuclear safety authority where he will have to give its opinion on the industrial geological repository for high-level and intermediate-level long-lived waste (Cigéo) he developed over ten years…

Transboundary participation and safety concerns

30 September 2024

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

United-Kingdom: pressure over land at Moorside for SMRs

3 September 2024

“A letter signed by more than 100 political, business and union leaders is calling for urgent action to resolve land issues at Moorside so that new nuclear power stations can be built.

Whitehaven and Workington MP Josh MacAlister wrote the letter, which has been signed by fellow Cumbrian MPs Julie Minns and Markus Campbell-Savours, local members of the House of Lords, Cumberland Council leader Mark Fryer, trade union leaders in the nuclear industry and dozens of local business leaders.”

Here is the News & Star journal introduced the letter below (source):

“In my first few weeks as an MP I’ve met with ministers, the NDA, Great British Nuclear and leading nuclear industry figures. It’s become clear that there’s been a conspiracy of silence for years over plans for new nuclear in our area. The last government told our community to wait in line and trust the process. But having looked in detail at the process, we’ve been set up to fail because of competing claims on land at Moorside.

The NDA want to use a large chunk of the land at Moorside for potential future decommissioning activity. If all of the land they want is taken out then there’s not enough land left to build the number of small modular reactors Great British Nuclear wants.

Today, over 100 local leaders are ringing the alarm on this. Our ask is simple – this is land designated for new nuclear use and it should be prioritised for new nuclear use. The NDA should develop contingency plans for their future land needs and buy alternative land for future decommissioning activity if and when the need arises.

West Cumbria has the land ready to go, the strong community consent, the skills and the nuclear infrastructure which make our area the perfect location for new nuclear. We do not want to miss out on another opportunity.”

In reaction to this letter, Colin Wales, Chair of Cumbria Trust and member of Nuclear Transparency Watch, wrote the published letter below:

“Your article on the Battle for New Nuclear was an interesting read, particularly the part about the “conspiracy of silence” as Mr. Mac Alister described it. Surely part of the truth is that if the Mid Copeland GDF Community Partnership progresses to borehole investigations, then all the “Moorside” land mentioned will be “needed” for GDF access and decommissioning work. That is the NDA’s priority and given the encouraging subsea geology results a Sellafield area the GDF looks the most likely outcome.

Another thing counting against the siting of Small Modular Reactors in that area are the International Atomic Energy Agency guidelines. While not specific, common sense raises some significant safety issues i.e., Would it be wise to site any operational nuclear power plant next door to what Europe’s largest stockpile of nuclear waste for the reason that an accident at one facility might well render the other inoperable. Do either the Office of Nuclear Regulation or CoRWM have a view on this?

A less risky, less expensive, more productive, and safer alternative might be to spend such huge amounts of money on a Morecambe Bay/Duddon Estuary 3GW transport and power generation barrage. For comparison, this would :-

*Connect the 3 nuclear communities of Copeland, Barrow and Heysham.

*Provide easy access for West Cumbrians to the M6 southbound and increase tourism to the Western Lake District.

*Provide a flood defense for local communities against predicted rising sea levels.

*Provide 2 x the power output than 3 SMR’s

*As part of a deal to host the GDF it could provide us with cheaper power, an attraction to business investors and provide west Cumbrian households with discounted electricity bills for decades to come.

*Be built using a local workforce.

* Have a lifetime of 120 years as opposed to 60 years for nuclear power plants.

It is also important to note that Electricite de France (EDF) have abandoned their SMR programme and Rolls Royce are trying to sell their SMR business.

Given the new Chancellor’s ideas on using the Canadian approach to Pension Fund investment for major infrastructure projects, what is proposed above would work well since there would be guaranteed long term returns on investment. Other countries do strategic infrastructure programs, why can’t we?

Colin Wales – Cumbria Trust and Nuclear Transparency Watch”

Evaluation of Euratom Research and Training Programme 2021-2025

22 May 2024

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.

Article on Rosatom-show in COP28 and other issues

30 January 2024

January 6, 2024

Source:Rosatom News

József Kóbor dr.

Pécs City Council, Hungary, European Committee of the Regions, NTW

Undoubtedly, it borders on the absurd that at the largest world environmental congress in 2023, COP28, the biggest appearance was presented by the Russian state nuclear giant ROSATOM. It is even more absurd when you consider that this company is theoretically being boycotted by the so-called “democratic world” due to Russia’s war against Ukraine. Or maybe not .

The Small Modular Reactors (SMR) have become so important for both Rosatom and the entire world that the Russian state-owned company recently dedicated a day to them at the United Nations Climate Change Conference (COP28) in Dubai – an SMR day. In addition, Rosatom conducts negotiations, concludes agreements, develops projects and prepares documentation related to the construction of small power reactors. Nuclear experts from other countries will also be familiarized with small power plants and their operating characteristics.

SMR Day was one of the most important events in Rosatom’s COP28 program. The event began with a vivid multimedia presentation covering the construction of a small, powerful onshore nuclear power plant in Yakutia that will be “carefully” integrated into the Arctic ecosystem.

Guests were able to virtually explore the Lomonosov floating nuclear power plant, which supplies electrical energy and heat to the town of Pevek on the Chukchi Peninsula, Russia’s northernmost city. “I am sure that Rosatom’s small powerful nuclear power plants represent an efficient and environmentally friendly choice for countries that, for various reasons, have not previously thought about their own nuclear energy production,” said Alexey Likhachev, the general director of Rosatom, in his video message to the Participants of the SMR day. The Russian small, powerful nuclear power plants are also interesting for other countries.”

The parties will examine the possibilities and study the location of the mainland SMR, the configuration of the power plant and the infrastructure required for construction and operation, and select the optimal implementation model for the project.

Hearing all this, an expert who has worked in the nuclear industry for decades remembers the old joke: For a newborn, every joke is new. Because what ROSATOM has presented here on the subject of SMR is a story from over 60 years ago that could only have been something new for the “newborn” and laypeople. The IAEA had been trying to “sell” this to the public since 1960. It is the civilian application of these small nuclear reactors developed by the nuclear powers to power their strategic nuclear submarines and aircraft carriers. (Also for icebreaking ships of the Soviet Union or Russia, this can be described as civilian use).

In reality, every previous project that has attempted to use SMRs for civilian economic purposes – where profitability, economy and the promised low operating costs mattered – has failed. The nuclear reactor was dismantled from the USA’s only nuclear-powered cargo ship 50 years ago and converted to diesel. Canadian nuclear heating plants were converted to gas and oil. Nothing came of the planned nuclear-powered locomotives, trucks, heavy commercial vehicles, seawater desalination plants, electrolysis plants and industrial heat generation units. Although a nuclear company came forward with such plans at least once every 10 years, they were never accepted by the business community.

So there is currently the lavishly presented Lomonosov floating nuclear power plant, whose towing through the Baltic Sea has sparked international protests – the others only belong to the category of visions, as was the case with the earlier ones.

IAEA also dreams – and unfortunately, EU plays with it

The IAEA published a report ahead of the COP28 conference entitled “Nuclear Technology Review – 2023”, which presents the main events and trends of 2022 and is considered by the agency’s experts as a pathfinder for the future development of the global nuclear industry.

We focus on the most significant and interesting ones.

Increase in nuclear capacity

The IAEA has increased its forecast for the development of the global nuclear industry in the last two years. According to the optimistic forecast, the installed capacity of nuclear power plants worldwide could reach 873 GW by 2050. This would be 10 percent higher than last year’s forecast. This could increase the share of nuclear energy in the global energy basket from the current 9.8 percent to 14 percent. (This was roughly the case before the Chernobyl meltdown .) Realizing this forecast will require a major shift to long-term operation, which means extending the life of existing reactors and building about 600 GW of new nuclear production capacity over the next 30 years.

It is quite shocking that the UN organization, whose main task should be the protection of nuclear safety, supports the systematic extension of the operational life of old, expired nuclear reactors, which obviously means an increase in risk and, incidentally, contradicts the previous principles of the IAEA!

And of course, Rosatom contributes significantly to achieving this goal. The state-owned company is building 22 power plant blocks in seven countries. The project portfolio includes a total of 33 units in 10 countries. The state-owned company has built 18 high-performance units in 18 years, nine of which were outside Russia. This year, fuel was delivered to the Akkuyu nuclear power plant under construction in Turkey and the Ruppur nuclear power plant in Bangladesh.

It is interesting that the IAEA does not say a word about the Belarusian Astravets nuclear power plant, which is also in operation – perhaps not by chance, as there are serious technical problems with the new VVER-2000 reactors. These reactors are also to be taken over by the Hungarian Paks2 project.

Difficulties in financing nuclear projects are hindering the construction of new nuclear capacity, study finds. However, there are “positive” developments, with nuclear energy being included in the sustainable finance taxonomy of the European Union and other countries in 2022.

What is taxonomy? Taxonomy is a tax system, which in this case means that nuclear energy and natural gas are considered “green” to enable the complete phase-out of coal and oil while meeting carbon emissions reduction targets. This would be the basis for the EU program to develop a green economy, the Green Deal. Behind this was a formal nuclear coalition: France under Macron, Hungary under Orbán, the Czech Republic, Poland – but above all Russia under Putin, for which both nuclear energy and gas would have been huge business.

Of course many people protested against it. Greens, professional associations. I – as a Hungarian city council member, member of the European Committee of the Regions and member of Nuclear Transparency Watch (NTW) – presented the case for plenary debate in December 2021. The European Parliament rejected the taxonomy. Nevertheless, the European Commission pushed through the taxonomy on December 31, 2021, on New Year’s Eve (!!). At this point, Russian tanks were already massing on the Ukrainian border. Everyone knows what happened next.

Small nuclear power plants

A current trend identified by the IAEA is interest in small-scale nuclear energy production. “Small nuclear power plants, along with high-performance water-cooled reactors, are expected to account for the majority of capacity additions over the next three decades,” the report says. of course in cooperation with the promotion of Rosatom projects..

Rosatom has commissioned the world’s first floating nuclear power plant, the Lomonosov Academic Floating Power Plant, and has begun implementing three more small floating nuclear power plant projects. The first four floating nuclear power plants provide power to the Baimsky Mining and Processing Complex. The second will be a small mainland nuclear power plant in Yakutia.

In addition, Rosatom is working on the construction of a small-scale nuclear power plant based on the Shelf-M reactor to supply energy to the Sovetskaya Gavan and neighboring areas. In total, Rosatom has about a dozen plans for the development of small nuclear power plants at various stages of development. Rosatom is actively negotiating with various governments, particularly Mongolia and Myanmar, to build small nuclear power plants.

The report states that modernized versions of water-cooled reactors are increasingly being considered, studied and built to gradually become modern, more efficient, semi-closed or “closed” ! Introduce fuel cycles. (A closed fuel cycle without waste production does not exist!)

“In the Russian Federation, conceptual research is underway on innovative water-moderated reactors with supercritical coolant parameters, including fast neutronic applications. The latest developments focus on small modular variants with an emphasis on improved nuclear safety, nuclear protective equipment, economic efficiency and sustainability parameters.” In addition, the development of Rosatom’s spectrally controlled VVER-S reactor is at an advanced stage. Among the promising technologies are also called salt bath reactors.”

Rosatom is also developing in this area, but not for energy purposes. The aim of the research is to test the transmutation of minor actinides in order to produce lower-activity fissile substances. This salt bath reactor is scheduled to be commissioned in 2030.

Note: not lower-activity, but perhaps shorter-lived isotopes (and not fissile material, but waste) can be produced with transmutation, but only with very poor efficiency.

“The report devotes a separate chapter to fast neutronic reactors.”

There are five fast neutron-cooled sodium reactors worldwide. One in China, one in India and three in Russia. Rosatom also plans to build the BN-1200 fast neutron reactor with 1200 MW of electrical power. According to plans, the first concrete for the BN-1200 will be poured into the block body in 2027.

“Technologies that use liquid metal coolants are receiving increasing attention. Rosatom is a leader here and is the first in the world to build the BREST OD-300 experimental demonstration reactor with 300 MW of electrical power.”

The characteristic feature of fast neutron technology is that the reactors operate at high temperatures in the strained operating mode with a high risk. Cooling with liquid metals. Most importantly, they produce plutonium, suitable for both nuclear weapons and nuclear fuel. Precisely for this reason they were not encouraged and even banned from spreading. Previous attempts in Germany, France, Sweden and even Czechoslovakia and Romania (!!) failed. It is truly shocking that this technology, which is extremely dangerous from a safety perspective, is now being promoted again.

The other applications of atomic energy

As mentioned in the report, the greatest interest in the non-electricity applications of reactor technologies is heat generation – alone or in conjunction with electricity (district heating and heat supply for industrial enterprises), seawater desalination and hydrogen production. Rosatom also deals with these areas and carries out developments. The Lomonosov floating nuclear power plant in Chukotka also supplies heat to the town of Pevek.

“A desalination plant designed and installed by Rosatom will be installed at the Akkuyu Nuclear Power Plant to serve the reactors and to meet the needs of drinking and fire-fighting water.”

The commissioning of an experimental plant for hydrogen production through electrolysis is planned at the Kola nuclear power plant. In addition, Rosatom is developing a project for a plant with an annual hydrogen production capacity of about 110,000 tons, using a 200 MW high-temperature gas-cooled reactor and chemical technology. The first unit is expected to be operational in 2032.

Natural uranium

NAÜ experts – citing global forecasts – estimate that demand for uranium will rise from about 160 million pounds of uranium oxide annually to about 190 million pounds over the next five years. “Due to the expected further increase in spot prices for the uranium market, the procurement departments of nuclear power plants are expected to give preference to the early acquisition of uranium ore concentrate and again enter into long-term contracts with uranium suppliers. This could lead to a further increase in the immediate price of uranium, which is forecast to rise to $65/ton by 2027, compared to the previous price of $52/ton – the report said. Reality is already exceeding expectations: on December 4, 2023, the spot price for uranium was $81.45/pound.

“New uranium mines are expected to open in the next five to 10 years, including in Australia, Brazil, Canada, Mauritania and Namibia. “

And not just there. In Europe we know of at least ten new uranium mining projects. In southwest Hungary, uranium mining near the city of Pécs is to be reopened; in Germany there is the former Wismut project in the Elbe valley.

However, the planned production capacity of these new facilities will not be sufficient to meet the current shortage of supply, which is currently being met from secondary sources. In this regard, uranium exploration is expected to increase in the coming years, including both conventional and non-conventional sites,” state NAÜ experts.

“Rosatom is also developing sites and conducting exploration work in Russia and Kazakhstan and launching projects in Tanzania and Namibia.” (And in Hungary!)

Source:Rosatom News

József Kóbor dr.

Pécs City Council, Hungary, European Committee of the Regions, NTW

Link to the article in other languages: https://www.donauregion-atomkraftfrei.at/beitraege-ungarn/

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

12 December 2023

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

Audition of NTW by the French Assembly regarding absorption of IRSN by ASN

14 June 2023

The French National Assembly heard Julien Dewoghélaëre for Nuclear Transparency Watch, Tuesday 6 June 2023 at 5.30pm on the consequences of a possible re-organisation of the ASN and IRSN on scientific and technological plans nuclear safety and radiation protection.

The transcription of this hearing by Jean-Luc Fugit, Deputy and Stéphane Piednoir, Senator for the Parliamentary Office for the Evaluation of Scientific and Technical Choices (OPECST) can be found here after: Parlementary Audition

On this topic, you can also find out NTW’s press release after that a coalition of NGOs and Members of the European Parliament have sent out an open letter with concerns for nuclear safety system in France:
https://www.nuclear-transparency-watch.eu/media/open-letter-to-the-french-minister-of-energy-transition-on-nuclear-safety.html

Furthermore, you can find ANCCLI’s Director, Yves Lheureux, views given to NTW, Monday 13 March:
https://www.nuclear-transparency-watch.eu/media/update-on-the-irsn-dismantling-project-by-the-french-government.html

WEBINAR – ANCCLI’s position regarding IRSN dismantling project by the French government

13 March 2023

Today, Monday 13 March is an important date in the evolution of the IRSN dismantling project decided by the French government early February, in fact IRSN more united than ever is demonstrating again today against this decision considered rushed and unjustified.

… [Read More]

SITEX.Network concerns about the sustainability of IRSN

13 March 2023

As a member of the SITEX.Network, NTW is sharing this statement from the network involving technical and citizen organisations:

SITEX.Network is concerned about the recent news that IRSN, one of its members, may be dissolved during the reorganization of the French nuclear safety governance currently under discussion.

… [Read More]

UNITED KINGDOM: letter from NTW’s member published in Cumbrian newspaper

7 March 2023

Here is the letter including reference to new UK legislation, published in Cumbrian newspapers by NTW member Tim Knowles the 19 February 2023:

“Sir,

As predicted the investment bonanzas forecast by our politicians over the last decade have failed to materialise. Moorside, the National Grid upgrade, new high quality roads, rail improvements etc etc have proved to be hot air. Yes there are a few “town deals”, but these don’t start to replace the money cut from Cumbrian council budgets during the period. … [Read More]