Belene Nuclear Project: Intolerable Risks and the Importance of EIA

1. August 22, 2017 St. Poelten, Austria nuclear projects in Bulgaria& importance of eiaDr. g. Kastchiev2 conferencecooperation Danube region nuclear-free

2. I am scientist, lecturer, researcher and consultant in the field of safety of nuclear facilities; 44 years experience, 16 in start-up and operation of Kozloduy NPP, the rest in research, lecturing and regulatory activities; 13 years international experience in USA, Japan and Austria; Head of Bulgarian Nuclear Safety Authority, 1997-2001; At this meeting I am speaking on my own. I believe Belene nuclear project poses intolerable risks! It has to be stopped! FRAMEWORK • For contacts: gueorgui.kastchiev@boku.ac.at00359 888 958218

3. Kozloduy - Two WWER-1000 in operation. Program to prolong design life, official position – EIA not needed, court case initiated; - Two storages for spent fuel (wet and dry); - Four WWER-440 in early phase of decommissioning; - National storage for low and middle level radioactive waste. IEA report rejected by the court in 2013, second EIA report appealed, court case not finished. September 2017 construction started; - Talks to construct one or two reactors. Feasibility study done (not publicly available). EIA accomplished, report appealed (2013 Austrian expert statement for unit 7 used), court case not finished; Agreement with Westinghouse not approved. nuclear sites in Bulgaria

4. Beginning of 80-ies: decision to construct two reactors WWER- 1000 at Belene site, preparatory works; 1987: Start of construction activities; 1990-1991: Environmental concerns, public opposition, lack of finances, project scrapped; 2002-2005: Number of decisions to restart the project. Report on EIA approved; Feasibility study based on false energy forecasts. 2005-2012: Manipulated tender - selection of Russian AES-92 reactors, licensing of the site, number of agreements with Rosatom, regulatory review of the technical design, lack of transparence, high corruption. Belene nuclear project - history

5. No contract for construction; • Huge initial investments: projected 4 billion Euro (2004) – real more than 10 billion Euro (2011); • No financial scheme; • No candidate for strategic investor, no private investors, no banks and no neighboring country willing to participate; • Detailed technical design of the plant (still) not approved by Nuclear Safety Authority (BNSA); • Nevertheless the main primary equipment ordered; • Spent more than one billion Euro (like water in the sand); • 28 March 2012: Governmental decision No 250 to abandon the project, supported by the Parliament. All activities stopped. Belene 2005 – 2012 main results

6. June 2016: Decision of Paris arbitration tribunal - the ordered equipment has to be paid (620 mln Euro); • In the following months attempts to negotiate with Russia and speculations concerning possible restart of the project; • September 2016: Almost 600 mln Euro interest-free loan from the state budget given to National Electrical Company to pay the ordered equipment; • May 2017: New government formed. The Energy Minister stated: “To finish Belene NPP in the best way remains in our plans*” • August 15, 2017: The Energy Minister announced the plan to establish Belene project company. In early 2018 to start privatization procedure. The state to have a minority stake. Belene nuclear project: 2016-2017

7. The gross domestic consumption on the plateau and always below the official minimum forecasts; Big export of electricity; New base-load generating capacity not needed; Again manipulated energy forecasts fabricated. Belene NPP not needed

8. Belene site seismic risk Seismic maps show Belene seismic hazard is moderate to high 8

9. Belene site seismic risk The intolerable seismic hazard for Belene proved by the effects of March 4, 1977 earthquake in Vrancea, Romania. In the neighboring town of Svistov: - collapse of two residential buildings; - about 30% of the buildings and houses damaged; - curved railroad rails in the port; - 120 people died. 9

10. Belene site seismic risk After the March 4, 1977 earthquake number of additional seismic studies for Belene site accomplished by Russian scientists; Finalizing the outcomes of the studies, in 1983 Russian site concluded that Belene site posses high seismic risks and officially proposed to abandon it*; Instead, decision to construct shock absorbing foundations below the reactor buildings, about 10 m high. Special drainage systems designed to protect foundations from penetration of water. 10

11. The status of shock absorbing foundations Before 2009: Foundation of unit 1 is still protected; March 16, 2010: Foundation of unit 1 under water. 11

12. The status of shock absorbing foundations Reactor building of unit 1 fully destroyed in 2009 . At its place a big trench occurred – approximately 66 x 66 x 6 m; During autumn - winter season 2009-2010 rains and snowfalls, the trench filled up with tens of thousands tons of water; A big number of freezing – defrosting cycles during the winter. These could result in defects in foundation structure and changes of its shock absorbing features; The drainage system of unit 2 is not in operation since 1991; These circumstances could lead to decreased ability to fulfill the design purposes of foundations in case of big earthquake; If during plant operation this could result in severe accident; No discussions of these problems, or attempts to investigate the status of shock absorbing foundations. 12

13. foundations for the new reactors The shock absorbing foundations designed for WWER-1000/B320 reactors; The selected new reactors are of AES-92 type, reactor buildings have different dimensions, including the bigger ground surface; A part of the new reactor buildings will be outside of the existing shock absorbing foundations; Without additional measures, the reactor buildings will be seated on the foundation volumes with different shock absorbing features; In case of big earthquake during plant operation this could result in severe accident; Still no measures planned to investigate and to resolve these problems, no practical experience. 13

14. additional concerns No big infrastructural projects in Bulgaria since 1992, previous experience lost, specific construction equipment for Belene solved, no big construction companies; Lack of qualified workers and engineers reported in Bulgaria even for construction of classical buildings. Import of working force from other countries would result in qualification, communication and other problems; Poor state control over the quality of construction works; High corruption in the state administration; All these factors would lead to the poor quality of construction works. 14

15. Belene project & the region Negligible nuclear liability: The amount of nuclear liability in Bulgaria is only 100 mln BGN (about 51 mln Euro). It is tens to hundreds times less than liability in Western European countries or in USA. This amount could cover only the evacuation and life expenses for several weeks or months after the accident. The losses of the households and of the business will be not covered; Lack of program for the final repository of the spent fuel: No program exists for the final repository of the spent fuel/high level waste of its reprocessing in Bulgaria and no funds are collected for this purpose; These facts create significant additional risks not only for Bulgarian citizens, but also for the population in the neighboring region in Romania. 15

16. According to the Nuclear Act, a Governmental decision is needed to construct a new nuclear power plant, or decision to cancel decision No 250 from March 2012; A proposal to construct NPP shall be submitted by the Energy Minister accompanied with several assessments, including Environmental Impact Assessment (Article 46 of the Act); The Belene EIA report endorsed in 2004, before Fukushima, before latest European directives in nuclear field, etc. According to the environmental legislation, the report loses its legal force, in case if during the following 5 years there was no start of construction. Restart of the project - Legal aspects

17. EIA report - indispensable component for justification and approval of any nuclear project; Public discussions needed for endorsement of EIA report ; If there is a possibility of trans boundary effects –consultations with other states; Unique possibility to initiate a court case and to revoke the decision for endorsement of IAE report - most effective way. Examples: - in 2013 EIA report that approved construction of research reactor in Sofia cancelled by High Administrative Court (HAC); - in 2013 EIA report that approved construction of national repository for low and medium radwaste cancelled by HAC. The role of the eia report

18. Ministry of Environment and Waters proves Belene EIA report is still in force: during the following 5 years after the endorsement of the report, an information center and residential building were constructed, as well as two local purification facilities. These activities registered in 2016 by the local branch of the Ministry; This position is fully in contradiction with the following facts: - technical design of the plant still not approved by BNSA; - no permit for construction of NPP issued by BNSA; - no contract for construction signed and no financial scheme. It has to be concluded that construction activities listed in the first bullet are illegal and cannot be used as legal arguments; In addition – EIA allows max 2000 MW(el.), the nominal power is 2120 MW (el.) belene eia report

19. The possible new governmental decision for restart of Belene NPP could be appealed in the High Administrative Court due to the problems with the legal force of the EIA report; However recently the Parliament proposed amendments to the legislation that would drastically limit the right to appeal IEA of the most important projects: one level court judgment (already in force) and huge increase of state taxes (still not in force). Open letter of NGOs to EK; Opponents of the project have almost no access to national media and no representatives in the Parliament; Intervention of neighboring and other states, local communities, NGOs, European institutions, etc. could be of great value. optionto stop the Restart

20. conclusion BELENE NUCLEAR PROJECT POSES INTOLERABLE ECOLOGICAL, MACROECONOMIC, FINANCIAL AND POLITICAL RISKS IT HAS TO BE SCRAPPED INSTEAD THE SITE COULD BE USED TO CREATE ECONOMIC ZONE THAT WOULD BE OF GREAT VALUE FOR THE REGION 20