NUKEBOOK
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on the Kozloduy Bulgarian NPP

July 2000
Za Zemiata
 

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MANAGEMENT OF SPENT NUCLEAR FUEL OF KOZLODUY NPP

spent fuel storage facilities in Kozloduy
transportation and reprocessing of Bulgarian spent nuclear fuel
legislation and responsible authorities in Bulgaria
the funds
consequences on human health
environmental impact assessment

spent fuel storage facilities in Kozloduy NPP

Spent fuel taken out from the units 1-4 of Kozloduy NPP is stored in pools next to the reactors, and afterwards is transferred to the interim wet storage facility at the site of the plant. The pools of these first four units have already reached their capacity.  An illegal storage method is being used at these pools. A “second floor storage” method is used in which cassettes of spent fuel are arranged on the top of the ones that had already filled the pool. This method is forbidden by international institutions (IAEA), because it hinders the ability to control the condition of the cassettes.  Furthermore, it increases  the water temperature in the pools, which may accelerate corrosive cracking and subsequent radioactive leakage.

Because the interim wet storage facility is not constructed to accommodate spent fuel from 1000 MW units, spent fuel from units 5 and 6 is stored only in the pools next to their reactors.

In October 1997, the Committee on the Use of Atomic Energy for Peaceful Purposes (CUAEPP) suspended from operation the wet interim storage facility because it did not correspond to the safety requirements and the risk of an accident was unacceptably high.

At present, this interim storage facility is without a license, as the program for its seismic consolidation has not been finished yet.  Measures for consolidating and increasing the volume of the storage facility so that it can accommodate spent fuel out of units 5 and 6 will take at least 2-3 more years.

A “National Strategy for Safe Management of Spent Fuel and Radioactive Waste” was approved by the Bulgarian Council of Ministers on 9 November 1999. One of its main objectives is “not to allow a forced closure of reactors 1-4 out of lack of a free space for spent fuel storage”.  In order to meet this objective, the following measures are envisioned:

Short-term measures (1999 – 2001):

  • Seismic consolidation of the existing wet interim storage facility; reconstruction of the facility so it can accommodate spent fuel from units 5 and 6 (VVER 1000) and acquisition of a license;
  • Increasing the volume of  the storage pools close to the reactors 3 and 4 for storage of VVER 440 fuel; 
  • Construction of a new dry cask storage facility at the site of the plant.


Middle-term measures (2001 – 2003):

  • Consolidating and increasing the volume of the existing wet storage facility with two new pools and acquiring of license.


Long-term measures:

  • Returning of the spent fuel for reprocessing in Russia.


The estimated costs of the transportation of spent fuel from Kozloduy NPP, according to the Strategy, are 68 million USD per year. However, the source of this money is not specified. 

Transportation and reprocessing of Bulgarian spent nuclear fuel

Up to 1989 Bulgaria used to send the spent nuclear fuel from Kozloduy NPP to the Mayak  Russian reprocessing facility in South Ural.  Bulgaria didn’t pay Russia for the fresh fuel necessary for the operating of Kozloduy nor did Bulgaria pay for the transportation and the reprocessing of the spent fuel.  From 1989 up to 1998 shipments of spent fuel have not been sent to Russia.  Following an agreement signed in 1998 among the governments of Bulgaria, Russia, Ukraine and Moldova, Kozloduy NPP sent a shipment of 240 spent fuel cassettes from units 1 – 4, for reprocessing at Mayak and had to pay Russia approximately 18,7 million USD. 

It is expected that after the plutonium has been extracted the high reprocessing radioactive waste will be send back to the territory of Bulgaria.  Until now an appropriate and geologically suitable site for long-term storage of high – level radioactive waste has not been found on the territory of Bulgaria.

Moldova was the only signatory which has not ratified this agreement.  As a result its Parliament has to vote each time Kozloduy NPP wants to transport spent fuel through its territory.  In 1999 the Parliament of Moldova refused to vote in favor of the fulfillment of the agreement and in this way the main route for transportation of spent fuel was cut off. 

Another “alternative” route was being negotiated with Romania.  If such route was accepted, the shipments of spent nuclear fuel from Kozloduy NPP would be transferred at the Bulgarian – Romanian Danube river’s border complex Rousse – Giurgiu.  Afterwards they would pass through the territory of Romania using the country’s railway system on the way to Ukraine, thus evading the territory of Moldova.  This “alternative” route has never been used and tested. Romanian railways were designed to serve the population and at present are in a very bad state.  Òrains carrying spent nuclear fuel from Kozloduy would pass along these lines through heavily populated areas, including Romania’s capital, Bucharest.  After assessing the safety of spent fuel casks the Romanian nuclear regulative authority CNCAN  concluded that safety cannot be assured in case of accidents on the territory of Romania.
Thus the negotiations between Bulgaria and Romania on the transport of spent fuel by train were temporarily closed.
 

LEGISLATION AND RESPONSIBLE AUTHORITIES IN BULGARIA

The present Act on the Use of Atomic Energy for Peaceful Purposes  was adopted by the Parliament in 1995.  Its article 3 states: "Atomic Energy shall be used in accordance with the aims and the principles of nuclear and radiation safety and protection of the life and health of people and the environment shall have priority before economic and other social needs".   A special committee at the Council of Ministers, the Committee for the Use of Atomic Energy for Peaceful Purposes (CUAEPP), is the body which implements the state policy in this area. The CUAEPP is charged with:
 

  • planning and development of the safe use of atomic energy; 
  • research in the application of atomic energy;
  • education, training and qualification of personnel involved with the use of atomic energy;
  • nuclear legislation; 
  • international aspects of use of atomic energy; 
  • emergency planning and preparedness in the case of nuclear incident.


In parallel with the control, made by CUAEPP, there are some other institutions which have the obligations to oversee matters relating to nuclear.  These are the Ministry of the Environment (radiation monitoring), the Ministry of Agriculture and Food Industry (radiation control), the Ministry of Internal Affairs (control of the physical protection of nuclear material and ionizing radiation sources) and the Committee of Standardization and Metrology (control of measuring equipment).

The present CUAEPP management should regain its autonomous status from other governmental institutions such as the State Agency for Energy and Energy Resources, so that it will be able to overcome bureaucratic obstacles in order to fulfill its functions. 

According to the “National Strategy for Safe Management of Spent Fuel and Radioactive Waste”, approved by the Bulgarian Council of Ministers in the end of 1999, a new Act on the Use of Atomic Energy for Peaceful Purposes is being prepared and should be ready not later than 2001.  This act envisions a new distribution of the roles and responsibilities of the institutions. 

In the same Strategy the Council of Ministers required the creation of an independent  “State-owned Enterprise for the Safe Management of Radioactive Waste” by the end of the year 2000. Such an autonomous and independent institution is of a vital importance 
but in order to implement an effective control its governing body should not be bind to the existing state structures, such as NEK and the State Agency of Energy and Energy Resources. 
 

the funds 

According to the existing Act for the Use of Atomic Energy for Peaceful Purposes (AUAEPP) two funds were created in 1992: The Fund for Safe Disposal of Radioactive Waste and the Fund for Decommissioning of Nuclear Facilities.  While the law required the formal establishment of these funds, no legal mechanism was created to ensure their functioning.  From January 1999 NEK began collecting 8% from the price of the electricity generated by Kozloduy NPP for the Decommissioning Fund and an additional 3% for the Waste Disposal Fund.  By May 2000 NEK had gathered 130 million BG Leva (equal to 66,5 million EURO) from electricity consumers for the two funds, but still has not deposited them.  At present there is no formal accounting of the money collected and the funds are empty. 
 

consequences on human health

According to recent studies conducted by the Oncologic dispensary (Vratza) and information, provided in the National action plan ”Environment – Health” in the region of northwestern Bulgaria, where Kozloduy NPP is situated, the frequency of cancer diseases, genetic disorders and inherited defects is continually rising.

The cancer disease has a latent period of 10 to 30 years after exposure to radiation, during which no disease symptoms are evident. 
Bulgaria still has not developed an efficient system for health monitoring of former workers in the sphere of ionising radiation.  According to the International Atomic Energy Agency and the contemporary concepts for the biological influence of ionising radiation, these people should undergo medical check ups until the end of their lives.  At present only partial check ups are carried out for former workers of Kozloduy NPP, living in the town of Kozloduy and the surrounding villages. 

Proper comparative epidemologic researches on the frequency and the character of the population’s diseases, as a result of the Kozloduy NPP exploitation, have not been conducted. Health assessment of the Kozloduy NPP’s staff and the population, living in the region, as well as biomonitoring of the risk groups population, have been envisaged in the National action plan ”Environment – Health”, but until now none of them was conducted. 

Thus the governmental institutions violates the Constitution of Bulgaria, the United Nations’ Convention for protection of the Children’s Rights and the European Convention of Human Rights.
 

environmental impact assessment (EIA)

According to the Bulgarian legislation Kozloduy NPP is obliged to have an environmental impact assessment in order to have a legal permission to operate.  Until now such environmental impact assessment of the whole site of the power plant has not been completed.  Neither had EIA been completed for the  “National Strategy for Safe Management of Spent Fuel and Radioactive Waste”, spent fuel shipments and the reactor modernization projects carried out.  Thus, the Bulgarian public was kept out of the decision making process.

At present a very controversial EIA of Kozloduy NPP is under preparation.  Some of the experts working on the EIA do have labour relations with the NPP, hence their independence is doubtful. 

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