To: EU Commissioner for Energy Mr. Günther Oettinger
Dear Mr. Oettinger,
My name is Georgi Kastchiev and I am senior physicist at the Institute of Safety and Risk Sciences, University of Natural Resources and Applied Sciences, Vienna. I have 37 years experience in nuclear power technology – in start-up and operation of NPP, in research, in regulatory activities and in lecturing. From 1997 to 2001 I was a head of Bulgarian Nuclear Safety Authority.
After the severe accident in Fukushima nuclear power plant (NPP) in Japan, “stress tests” were proposed for European NPPs. I am writing to you today to express my concerns that this idea is a false and even counterproductive approach.
Such “stress tests” would be a task for an independent safety authority in the European Union, which could: define requirements and criteria; accomplish additional specific studies; control the tests and review the results with participation of all stakeholders. As such an organization doesn’t exist, it has been proposed that “stress tests” be performed by nuclear operators (on a voluntarily basis) and national regulators.
These are the very organizations and persons who were responsible for the past and present safety evaluations of NPPs. They are therefore in a visible conflict of interest and would be acting as a judge of their own work. It is not realistic to expect that the people, who assured the public over decades that their reactors are safe, could now come to different conclusion.
After the Fukushima accident, serious failures of the Japanese regulatory system have came to light and there has been much criticism of the fact that key managers in the regulatory authorities had close ties to the nuclear companies that they were supposed to oversee. The situation in Europe, however, is not fundamentally different. If you look to the CVs of main regulators here you will – in many cases - find a revolving door between these agencies and the nuclear industry.
Experience shows us numerous cases where nuclear operators and regulators demonstrated a lack of competence and responsibility (Davis-Besse NPP, 2002, US; Paks NPP, 2003, Hungary; Kozloduy NPP, 2006, Bulgaria). In addition, regulators revealed insufficient independence and all parties demonstrated a lack of safety culture. The importance of this fact should not be underestimated. All three major nuclear accidents (Three Mile Island, Chernobyl, and Fukushima) took place in countries with week regulatory oversight.
As safety requirements differ from one country to the next, I have a problem imagining how European nuclear regulators could express a common position on the safety of each reactor. For example - during discussion of the reactor design for the Belene NPP, the Bulgarian regulator stated that CANDU reactors do not meet Bulgarian safety regulations and they were excluded from the tender. In Romania, however, regulators approved CANDU construction. Another example is the old WWER-440/V-230 Russian reactor. While this reactor design is deemed to meet the present Bulgarian safety regulations, all reactors of the same type were shutdown in Germany in the early 1990s as German nuclear authorities came to the conclusion thatthey do not meet safety regulations and cannot be modernized. A similar case is the WWER-440/V-213, which is assessed as “safe” in a number of European countries, but the only reactor of this type was shutdown in Germany due to the same reason as WWER-440/V230.
Even now, the key nuclear organizations failed to acknowledge the real severity of Fukushima accident. The huge amount of damaged nuclear fuel in reactors and spent fuel pools, radioactive contamination of the see and land, as well as information from Comprehensive Test Band Treaty Organization and French Radioprotection and Nuclear Safety Institute concerning Iodine and Cesium radioactive releases to the environment, clearly show that Fukushima accident has to be classified at Level 7 of INES scale. However, during recent weeks, the IAEA and other nuclear organizations have kept quiet and misled the public concerning the real severity of this accident. In my opinion, this behavior has completely undermined the nuclear community’s credibility and confirmed the public’s perception that the lack of transparency and openness are a typical fixture of the nuclear industry.
The Western European Nuclear Regulators Association (WENRA) has already expressed its position on how “stress tests” should be accomplished. For the following reasons, I see grave problems with the approach and methodology proposed by WENRA:
1. I completely disagree with the idea that “stress tests” should rely on existing studies. Existing studies show that reactors are safe, so why spend resources for unneeded exercise. In my opinion, the problem is that we cannot trust the existing studies. The results of present probabilistic safety assessment (PSA) studies are a prime example. These showed that we could expect a low severe accident frequency of about one per 100 000 years per operating reactor. Taking the current fleet of around 440 reactors into account, we could expect such an event perhaps once in several hundred years. Reality has, however, demonstrated a totally different result – with a total of 14500 reactor-years of this fleet, we have already faced 3 severe accidents, which roughly means once every 10 years. What is worse – the last two major accidents resulted in huge radioactive emissions to the environment. In addition, PSA studies look at each unit individually while reality gave us a four-unit concurrent accident in Fukushima NPP. The existing studies also do not consider the circumstances of the Fukushima accident and its implications for other NPPs.
We should also acknowledge that there has been a tendency to ensure that important studies turned out “customer friendly”. There is no doubt that if “stress tests” (based on existing studies about earthquake and Tsunami threats in Japan) had, been carried out for the Fukushima NPP before March 11, their results would have confirmed the safety of the plant.
2. I am of the firm opinion that “stress tests” cannot rely on engineering judgment (EJ). Each of the three major nuclear accidents contained important elements where EJ led operators and regulators astray. For example, EJ concluded that hydrogen would not pose a credible threat to secondary containment integrity at BWR Mark I. Reality, however, provided us with three hydrogen explosions that completely destroyed the reactor buildings serving as a secondary containment for the Fukushima units. EJ led us to the conclusion that severe accidents in spent fuel pools were so unlikely that upgrades to avoid such accidents were unneeded. Reality provided us with multiple spent fuel pool accidents at Fukushima.
3. I completely disagree with the limitation of studies to the operator actions specified in emergency operating procedures (EOP) as proposed by WENRA. Most of what has happened at Fukushima to date far exceeds the EOP domain and lies instead in the domain of severe accident management (SAM).
4. The time frame for assessments (6 months) meant to provide the basis for the performance of “stress tests” are far too short to obtain meaningful results for necessary decisions, i.e. whether plants should remain in operation, or be modified and remain in operation, or be finally shutdown. Unfortunately, WENRA did not have the courage to tell politicians this and instead limited the scope and extent of the stress test analyses so that they will fit into the politically chosen time frame. Consequently, if the WENRA proposal is adopted, we can expect superficial reports from the operators that merely regurgitate the results of studies already performed and will predictably arrive at the conclusion that “Europe is not Japan” and that “our” NPPs show an acceptable safety level.
All this means, that the likely result of the proposed “stress tests” will be the generation of tons of paper, without any real impact on reactor safety.
In order to effectively decrease the risk of a severe nuclear accident in Europe, we need to arrive at clear decisions on where to continue or stop the operation and/or construction of individual nuclear reactors. As a first measure, deterministic technical criteria have to be established that allow us to come to a simple “yes” or “no” answer. Shutdown criteria should include issues such as the following:
Is the reactor lacking a hermetic full pressure containment structure? Is its spent fuel pool lacking such a containment structure? Is this a first generation reactor? Are there significant seismic or other external hazards?
If the answer is “yes,” such reactors should be shutdown (or their construction should be cancelled). In my opinion, this option has to be implemented for:
All reactors of the first generation such as MAGNOX gas-cooled reactors in the UK;
All units without a containment for reactors and spent fuel pools, including WWER-440/V-213 units in Slovakia, Czech Republic and Hungary;
Old BWRs in Germany, Spain, Sweden and Finland;
The connections of remaining NPPs to the grid have to be strengthened and “stress tests” concerning the reliability of long term onsite power supply and availability of cooling water, plans for evacuation and other emergency response measures to be accomplished.
All remaining units have to be equipped with passive autocatalytic hydrogen recombiners, filtered venting systems, additional diesel generators, movable diesel generators, fire trucks and other equipment used in the Fukushima NPP.
Further required steps are: The construction of reactors at sites with significant seismic risks
and/or without full pressure containment structure must be immediately stopped (Belene 1-2, Cernavoda 3-4, Mochovce 3-4);
The specific risks of terrorists acts for each particular nuclear site should be carefully considered;
European countries should only permit the construction of Generation 4 reactors and ensure that the lessons learned from Fukushima accident are incorporated into their designs.
Even with these measures fully implemented there will still be significant residual risk from some operating reactors outside European Union (old WWER 440/V-230/V-213 and the Bilibino NPP units in Russia, old RBMK in Russia and Ukraine and old BWRs in Switzerland).
I would also like to point out that there are additional safety issues and specific open questions that go beyond the scope of the planned “stress tests”, including:
Intermediate wet spent fuel storages
A number of countries in Europe operate wet storages that are above ground. They are not equipped with containment structure and are not designed to cope with severe accidents. These storages are vulnerable to loss of power and loss of long term She is responsible for nuclear issuesterrorist acts we will face a long lasting nuclear nightmare in Europe;
Civil liability for nuclear damage
According to Merrill Lynch Bank the Fukushima operator will face about 1 trillion Japanese yen ($12,13 billion) in compensation claims if the recovery effort lasts two months. No nuclear operator in Europe maintains this kind of insurance and in some countries it is even less than EUR 100 million. This practice has to be prohibited through political decisions. No nuclear operator should be allowed to operate nuclear facility if it cannot compensate claims up to EUR 10 billion.
Long-term storage of spent fuel and high level radioactive waste
Only Sweden, Finland and partially France have real plans for construction of a deep geological storage for spent fuel and high level radioactive waste in next 10-20 years. Some countries with nuclear programs don’t even have storages for low and intermediate waste. This practice must be prohibited. No nuclear operator should be allowed to operate nuclear facility if it has no real and financially assured plans for long term storage of spent fuel and radioactive waste.
Mr. Oettinger, I hope the EC will begin giving nuclear safety the priority it deserves and halt its practice of giving a “green light” to questionable nuclear projects. In this context, I hope that EC will also reassess its position concerning the construction of specific nuclear projects such as the Belene NPP in Bulgaria, Cernavoda 3-4 in Romania and Mochovce 3-4 in Slovakia.
I am available for discussions and am looking forward to your answer. With best regards, Dr. Georgi Kastchiev April 7, 2011
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