Elisabeth Köstinger Ministry of Sustainability and Tourism
Viennese Platform Nuclear-Free
1200 Vienna Vienna, 30 April 2018
Dear Ms. Stegmueller!
Dear Ms. Mraz!
Dear Ms. Lorenz!
I answer to your letter from 12 march 2018 concerning the NPP project Belene.
First, I want to thank you for your interest and engagement that is visible in your letter. Like I said before, this is valuable for the work of the Federal Government.
I can tell you that I want to follow the Austrian anti-nuclear-way according to the Government’s Programme consequently and with much engagement. This also includes working against newbuilt and replacement of NPPs in Europe, especially in our neighbouring countries, with all political and legal means.
My Ministry is involved from the beginning in the NPP project at the site of Belene.
14 years before, on the 29 April 2004, the Bulgarian Government decided to start finalizing NPP Belene. The environmental assessment report was finished in March 2004.
Austria has analysed since 2004 possible negative impacts by the planned realization of NPP Belene in the meaning of the ESPOO Convention. An official letter was sent by the Austrian Ministry of Environment to the Bulgarian ESPOO contact point in July 2004. The assessment was difficult and took a long time due to the poor quality of the EIA-documents that were provided by the Bulgarian side. Austria therefore reserved its right to participate. At the third Meeting of Parties to the Convention on Nuclear Safety in April 2015, Bulgaria presented a safety concept for the project NPP Belene. This concept included the very ambitious goals for minimizing the effects: No immediate or long-term measures were needed beyond a radius of 800 m around the reactor, and no delayed measures at any time beyond a radius of 3 km. After an Austrian request in September 2005 the State Office “Nuclear Energy and Nuclear Safety” of the Ministry of Energy and Ressources confirmed these presented parameter. Austria concluded that with these modern parameters no significant negative impacts on Austria’s environment could be expected and refrained from participation in the transboundary EIA.
The catastrophe of Fukushima has confirmed Austria’s critical nuclear position. Our sympathy is still with the victims of the catastrophe.
The catastrophe of Fukushima has fuelled some discussions and reflexions in Europe. As a consequence the safety of all nuclear facilities in the European Union was subjected to a “stress-test”, and the Directive for Nuclear Safety was amended to obligatory inclusion the safety goal that accidents with early of large releases of radioactive material in nuclear facilities have to be avoided, and in the case of accident the effects should be minimized. The phrasing in this Directive also shows that severe accidents with significant impacts cannot be excluded completely, not even in new NPPs. The regulation authorities in Europe are aware of this. In a joint document on accident management published at the end of 2014. HERCA (Heads of the European Radiological Protection Competent Authorities) and WENRA (Western European Nuclear Regulators Association) explicitly acknowledged this.
Against this background, the former safety concept of the project Belene has to be questioned. Therefore, first we will ask the Bulgarian side through the ESPOO contact points for clarification of the legal basis, and communicate our request to participate in a possible new EIA procedure.
I ask you kindly to copy this letter also to the other signers of your appeal.
With best regards,
Von: Todor Todorov [mailto:firstname.lastname@example.org]; June 7th 2018
Bulgarian Parliament decided and protest again
The Bulgarian Parliament today decided to give the government a deadline of end of October 2018. To seek and negotiate with an investor for the construction of Belene NPP without state guarantees. The decision was taken with 172 votes YES, and only 14 against.
We will await the decision of the Supreme Administrative Court on our appeal against this decision.
We again protested in front of the Parliament against Parliament decision from today.
Z2018-05-15 17:34 GMT+03:00 Mark Johnston <email@example.com>:
Zombie proposal under consideration for nearly 40 years!!
Bulgarian government to seek mandate for talks with investors over nuclear plant
SOFIA (Reuters) – Bulgaria’s government will ask parliament to give it the authority to negotiate with investors to build the Belene nuclear power project on the Danube River, the prime minister said on Saturday.
The Black Sea state initially canceled the project, estimated to cost about 10 billion euros, in 2012 after failing to find foreign investors and bowing to U.S. and European Union pressure to limit the country’s energy dependence on Russia, which would have supplied some equipment.
The current government of Prime Minister Boyko Borissov, however, is renewing the search for private investors to build the plant after an arbitration court ruled in 2016 that Bulgaria must pay more than 600 million euros ($717 million) in compensation to Russian state nuclear company Rosatom due to the cancellation.
It will be the country’s second nuclear power station after the Kozloduy plant, which is also on the Danube.
In July Bulgaria will host an annual summit of leaders from 16 central and eastern European countries and China, a group dubbed “16+1” by Beijing. China National Nuclear Corp (CNNC) has already expressed an interest in investing in the 2,000 megawatt nuclear power project.
“The moratorium (should) end to allow parliament to give me a mandate to talk to investors before the meeting in July,” Borissov said, adding Bulgaria had already spent 3 billion levs ($1.83 billion) on the project.
Parliament said in March that the Energy Ministry should draw up proposals by the end of June on whether to proceed with or scrap plans for the Belene project.
A month earlier Borissov suggested Belene be built as a pan-Balkan project to boost energy security and connectivity and urged its neighbors in the region to consider the option.
Critics of the project, first launched in 1981, argue that the investment does not justify the benefits and that the project has been a source of corrupt practices for decades.
Reporting by Angel Krasimirov; Editing by Hugh Lawson
If Belene NPP was already built
Still, what would have happened if the project had not been terminated?
Suppose that by mid-2012 the Belene NPP technical project had been approved and the Bulgarian state had begun construction. If, by some miracle, the construction works were perfectly organized, loans of about BGN 20 billion were secured at a reasonable price, if the construction were done without delay, if the power plant were staffed and connected to the power grid … and many other ‘ifs’, could hypothetically, possibly, Belene NPP’s first unit might have already been completed?
The first question to ask here is: Would there be a market for Belene’s electricity?
An overview of the Electricity System Operator’s (ESO) website shows that from the beginning of 2018 until March 12 electricity generation dropped by 4.8% and electricity consumption by 6.8%, compared to the same period in 2017. Last week, for example, the maximum load in the country was only 5286 MB and the minimum 3350 MB.
Since the beginning of 2018, net electricity exports have averaged 424 MW, with large fluctuations.
The state of the national load and exports should be considered in light of the following data:
– Even without Belene NPP currently we have about 11 880 MW installed capacity (including one unit at TPP Varna);
– Kozloduy NPP is constantly generating about 2100 MW;
– Due to the continuous spring rainfall, most hydro power plants (HPPs) with a total generation capacity of 2340 MВ, without the pumps, work at full capacity, sometimes generating over 1600 MW and a total of 8.7% of the electricity generated since the beginning of the year;
– The remaining renewable energy sources (RES) with a total capacity of 1822 MB perform mainly depending on the weather, having generated 5.4% of the electricity produced since the beginning of the year;
– District heating and industrial power plants supply 400-500 MW;
– Coal-fired power plants, with a total capacity of 4 000 MW, cover the rest; although their capacity is deliberately limited, as witnessed by Bobov Dol TPP which the recently was completely shut down.
It is clear that even during the current season the chances of Belene NPP finding a market for its electricity, either in the country, or in the region, would be equal to zero.
The second key question to ask here is: Would Belene NPP be competitive?
According to various forecasts, at full load (two units, 2120 MW in total, 7970 hours of work per year and 16.9 billion kWh gross generation per year) the electricity from Belene NPP would cost between BGN 170 and BGN 200 per MWh and significantly more when operating at lower capacity.
Is this cost high or very high? As always, the answer to the question is found in comparison. For this purpose it is best to use public data from the Independent Bulgarian Energy Exchange (IBEX). In 2017 the average price of base electricity traded on IBEX for the day ahead, was about 80.5 BGN / MWh. According to the Bulgarian Academy of Sciences, this price is expected to grow, yielding a moderate increase to BGN 114 / MWh in 2020.
However, for understandable, though clearly unknown to science, reasons – mainly due to shrinking consumption and surplus capacity – the cost of base electricity for the day ahead on IBEX was logically reduced. For example, in the first week of March 2018 the price was 63.22 BGN / MWh, in the second week, 53.94 BGN / MWh, and in the last 5 days, 37 BGN / MWh. For March 17th, Saturday, the price reached the unthinkable 24.96 BGN / MWh, and for Sunday, March 18, the even lower 14.81 BGN / MWh. A downward trend is also observed in electricity prices for peak and non-peak power.
Therefore, if by some miracle the Belene NPP were already built, in a liberalized market its electricity would be totally uncompetitive and unsellable. An investment of a total of BGN 22-23 billion would have been lost. Moreover, the NPP would generate billions of losses annually for the repayment of loans and accumulated interest, as well as for maintenance. It is should be noted that the state has no way to raise that money, except by increasing taxes and cutting on the costs of salaries for teachers, doctors, policemen, pensioners, and so on.
These are just some of the facts that show that the Belene NPP project has always been and remains a multi-billion-dollar adventure, fueled by corrupt expectations and pro-Russian interests. None of the generously offered suggestions can change that conclusion – suggestions about the Balkan countries’ profound interest in the project, a „request” for European funding, interest by Chinese investors, the viability of the project demonstrated by the Bulgarian Academy of Sciences, the saying that no NPP operates at a loss, about keeping Bulgaria in the Nuclear state’s club, etc.
Mrs. Zveta Karajancheva, Chair, 44-th Bulgarian Parliame
Mr. Bojko Borisov, Prime Minister of Bulgaria
Parliamentary Groups, 44-th Bulgarian Parliament
Mr. Deljan Dobrev, Chair of Energy Commission, 44-th Bulgarian Parliament
Mrs. Temenuzka Petkova, Minister of Energy
by a group of energy experts, politicians and former government officials,
taking action as active citizens, in relation to the future and risks of third attempt to initiate the construction of Belene nuclear power plant
April 20, 2018, Sofia
Once again the idea of a new, third restart of the Belene NPP project has been launched in the public space. None of the responsible state institutions, however, has yet provided the public with an in-depth analysis of why the previous two attempts failed, and how much Bulgarian taxpayers have to pay for that. This time there are new arguments: the National Electricity Company (NEK) has paid for the part of the necessary equipment that has been delivered, but there is no mention of the fact that the purchased equipment represents no more than 10% of the total budget of a new Belene NPP project.
None of us is opponent to the development of nuclear power in Bulgaria, and in our various positions in government institutions and in energy companies, we have all worked for the development of nuclear power. But not by all means, because every new investment project in electricity generation in Bulgaria needs to be assessed in the context of the new European principles for energy development and the impact on final electricity prices on the end users and industry.
In relation to this, we express our concern and strongly disagree with the insistent appeals by some political forces for an immediate start of the third attempt to build Belene NPP without a comprehensive assessment of the implications of this endeavor for the Bulgarian power sector and economy. According to the assessments made by professional analysts in the frame of international projects, the budget of such a project amounts to at least BGN 22 billion and the cost of the produced electricity will be at least EUR 100/MWh. Considering that creditors will inevitably insist on a long-term electricity purchase contract, this will be a high-risk project for the Bulgarian economy, which will weigh on the shoulders of Bulgarian taxpayers for decades.
The possibility of the realization of the project by an investor (if there is one) without state aid should be presented as a part of the decision to restart the project together with the publicly available investor’s conditions. Today, any talk of Belene NPP in the absence of endorsed national energy strategy and in violation of the requirements of Art. 4 (2), Art. 87 (3) and Art. 46 (1) of the Energy Act, lacking a technical offer and having a still-unclear project format and budget, is a serious administrative violation.
Belene NPP is not a priority in today’s economic development of Bulgaria; it has been promoted and continues to be promoted by purely lobbyist interests.
The Memorandum from the National Discussion Forum Building Belene – Appropriateness, Alternatives, Economic Models, held on February 20th, 2018 with the participation of more than 70 experts in various fields of energy, economics, environmental science and finance, lists the following important conclusions adopted by consensus:
1. The electricity generation sector in Bulgaria does not, and will not need new base-load generation capacities up until 2040, and any proposal for such a project must be accompanied by a justification detailing which existing plants are being decommissioned, for what reasons and with what socio-economic consequences. The realization of Belene NPP as a regional project is still just a vague idea with a number of technical, logistic and financial risks and problems.
2. The Government’s highest priority actions in the energy sector should be to allocate maximum expert and diplomatic efforts to safeguarding the long-term operation of coal-fired power plants, based on local lignite, as well as to prolong the life time of Kozloduy NPP’s Unit 5 and Unit 6, with a time horizon of 2040 and beyond.
3. The government should investigate the possibilities, and we are convinced that such exist, to sale the delivered equipment, or for the construction of nuclear units in a third country, with the active participation of Bulgarian companies and application of modern know-how together with the Russian counterpart as the chief designer and equipment manufacturer. Investigations by our experts indicate that opportunities exist and there is interest for this kind of endeavor.
4. The Government should not amend its existing Decision 250/28.03.2012 of the Council of Ministers in its first part to abandon the Belene NPP project, nor take action to prepare projects for the construction of new base-load generating capacities, until the restrictions, terms and conditions of operation of local coal-fired-power plants and Kozloduy NPP become clear.
5. Prior to the commencement of any preparatory activities for another nuclear project, the Government shall implement the Governmental Decision 250/28.03.2012 that is in force in its last part, which obliges responsible persons under the Energy Act to evaluate the possibilities of using the supplied equipment for Belene NPP for constructing a 7th unit at the Kozloduy NPP; meanwhile the Belene site should be transformed into a free economic zone for investment in high-tech production capacities.
6. The Ministry of Energy owes to the society updated information on the progress and timeframe for developing the new Bulgarian Energy Strategy. According to the Energy Act (Art. 3), the Energy Strategy should lay the basis for the future energy development of the country and has to be approved by the Parliament. We recommend to the working group to make a critical review, assessment and implementation of the new directions for energy development proposed in the Fourth Clean Energy Package, in line with the current European policies and new energy technologies.
Ladies and gentlemen, representatives of today’s political class, we appeal to you not to make hasty decisions that can set back the country’s economic development for decades. The five solutions, proposed by the experts and set out above, represent a basis for professional decision of the problem with Belene NPP equipment with minimal economic risk to the state.
Plamen Denchev, Kiril Ermenkov,
Chair of the Parliamentary Chair of the Parliamentary
Energy Commission, 1995-1997 Energy Commission, 1997-2001
Martin Dimitrov, Traycho Traykov,
Chair of the Parliamentary Commission on Minister of Economy,
Economic, Energy and Tourism, 2009-2013 Energy and Tourism, 2006-2009
Georgi Stoilov, Stancho Andreev,
Minister of Energy, 1997 Dr. Eng, Senior Scientist, Vice-chair
Committee of Energy, 1997-2001
Krasen Stanchev, Associate Professor Prof. Hristo Vasilev,
Institute for Market Economics Technical University of Sofia
Georgi Mikov, Ivan Hinovski, Eng., Senior Scientist
Executive Director, Executive Director
National Electricity Company, 2008-2009 National Electricity Company,
Prof. Plamen Tsvetanov, Prof. Georgi Kastchiev,
Bulgarian Academy of Sciences, Chair of Bulgarian Nuclear
Institute for Nuclear Research and Nuclear Energy Regulatory Agency, 1997-2001
Ilian Vasilev, Anton Ivanov,
Energy expert Kozloduy NPP EAD
Former ambassador to Russia 2000-2001
Vasil Filipov, Hristo Kazandzhiev,
Executive Director, Director of Mineral resources and
Bulgargaz EAD, 1996-1998 Concessions Department,
Ministry of Energy, 1997-2009
Petar Slavov, Georgi Bosev,
Member of the 43th Bulgarian Parliament Senior scientist
The Fukushima Nuclear Power Plant Accident: The First Seven Years
They say that the first 7 years of a person’s life are very important for his or her further development. What have we learned from the past 7 years since the Fukushima NPP accident? We have understood that the third biggest economy in the world is powerless to cope with the consequences of the nuclear disaster that happened on 7th of March 2011. Even one of the most disciplined and organized nations in the world, the Japanese, is exhausted by the terrible damage. The only point to mark such anniversaries is in preventing the recurring of similar accidents at nuclear power plants that have severe consequences for a huge number of people for decades.
The independent commission dealing with the accident investigation at the Fukushima NPP Unit 1 reactor concluded that the incident was foreseeable, but that the necessary precautions had not been taken. It is important to note that during the 2011 accident investigation, it was proven that the TEPCO (Tokyo Electric Power Company) had sent false reports to the Japanese Nuclear Regulatory Agency, covering up the real dangers of an accident. The company which owns the Fukushima 1 nuclear power plant, has failed to comply with basic requirements for safety, prior preparation for possible collateral damage, risk assessment, and evacuation plans. The company itself admitted its guilt, but said it could not pay $ 100 billion worth of damage. It should be recalled that this private company has owned and operated the Fukushima NPP for forty years. That is, for forty years, the profits were collected by the owner, while the huge damages from the accident are to be borne by the state.
As early as 2012, TEPCO turned to the government with an official request for state aid, in other words, for the nationalization of the company. The operator received more than USD 45 billion from the state budget, since without them, it would have been impossible to cover the electricity supply, the costs of damages to the victims and the decommissioning of the damaged reactors. The Japanese government justified this state aid with the fact that TEPCO supplies electricity to more than 45 million inhabitants of Tokyo and the surrounding regions.
Could it be that the idea of decentralizing energy production is more sensible than maintaining such energy ‘mammoths’ on which millions of families depend?
Despite the advanced and high-tech Japanese economy, the operator still cannot reach the melted fuel rods that have penetrated the reactors; the special robots made for this purpose stop working after a few hours because of the huge radiation. TEPCO thinks that it will take them another 30-40 years to complete the securing of the plant. And considering the ‘cheap and clean energy from nuclear power plants’ mantra, it is good to know that the cost of recovering the damage after the accident will increase further.
Last year the government discontinued the payment of benefits to people who ‘voluntarily’ left their homes located near Fukushima. People are left alone to deal with economic, social and psychological problems Since March 2011 the level of registered suicides in the region continues to rise. The Japanese court already has in several cases convicted TEPCO to pay indemnities to suicide relatives as a result of the Fukushima disaster.
Our conclusion is: The organized criminal group in our country, which has already robbed more than BGN 2 billion from the national budget for the construction of Belene NPP, should be reminded that the cost of building a new nuclear power plant must include also the stricter and very costly European safety requirements following the Fukushima accident, which would make the construction of a second nuclear power plant in Bulgaria entirely pointless from an economic point of view. The public needs to be informed that the best way to avoid such nuclear disasters is to decentralize electricity generation, increase energy efficiency and the share of renewable energy available to households, and that all of these would make large energy mammoths, such as new nuclear power plants, redundant.
Environmental Association Za Zemiata / Friends of the Earth-Bulgaria
Todor Draganov Todorov
Energy and Climate Coordinator
mob: +359 887122801
E-mail: firstname.lastname@example.org, email@example.com
6.3.2018, mail by Todor Todorov
On March 2nd 2018, the Bulgarian Parliament decided to assign a task to the Minister of Energy to submit a specific proposal, within 5
months, related to the implementation of the project assets for construction of the Belene nuclear power plant, including the separation of the assets and liabilities for the project in a separate legal entity..
“We need to look ahead – we have a site, we have a project that has been notified, we have paid for equipment, and it is now here,” said in plenary Energy Minister Temenujka Petkova.
On the question, asked by a an opposition MP in the Parliament, that the NPP project was suspended by the Parliament’s 2012 decision and the moratorium is still in force, Minister Petkova answered: “It is all a matter of legal analysis and legal techniques. Let us first conclude the work, so we can be able to report in the forthcoming months on what we think must be done with the project.“
A conversation with our neighbors is imminent. During the Economics Forum in London on the development of the Western Balkans, the Prime Minister proposed NPP Belene to be financed with European funds and its production to be sold to our neighbors in the Western Balkans. This development of events will necessitate some changes in the planned activities for anti-nuclear and anti-corruption movements in order for us to respond adequately.
It is very interesting for the European public, why should EU citizens must pay over € 10 billion for the construction of NPP with Russian reactors, which will work for the supply of electricity to the Western Balkans.
Foto Margit Quendler
Bulgarian Academy of Sciences report on Belene NPP project:
Its prognoses do not deserve credit 1/2018
The Bulgarian Academy of Sciences – from the White Book to the white flag
The summary of the most recent report on Belene Nuclear Power Plant appears to be created under the pressure to serve the interests of an organized criminal group
In 1990, the Belene NPP “Research and Opinions of BAS”, better known as the White Book of the Bulgarian Academy of Sciences, was published. It included the efforts of 85 scientists and experts from a number of leading scientific institutes of the Bulgarian Academy of Sciences, such as the Institute for Nuclear Re-search and Nuclear Energy, the Institute of Economics, the Laboratory of Ge-otechnics on Weak Terrestrial Foundations and Terrains, the Institute of Ecology, the Institute of Sociology, Central Laboratory of Psychology as well as energy experts from Energoproekt and scientists from the Institute of Nuclear Medicine, Radiobiology and Radiation Hygiene from the Medical Academy.
In spirit of complete professional independence of the teams in developing and formulating their position, they show the full data from their research on 409 pages to justify their conclusion, namely: “In general, the surveys and research lead to the conclusion that from an energy, economic, technical, seismic, envi-ronmental and social point of view, the
construction of Belene NPP is insufficiently justified or unacceptable.”
A clear and firm conclusion with no ifs, ands, or buts.
When the construction was frozen by the government in 1990, BAS’s expertise was at the heart of this decision because they unambiguously demonstrated the lack of appropriateness of building a second nuclear power plant. In the beginning of 2017, the current government entrusted the Bulgarian Academy of Sciences to draw up a “National Energy Strategy (focused on electrical industry)”.
On 16.11.2017, a summary of this strategy and a “Final report on the feasibility of realizing the assets of a Nuclear Power Plant” were presented at the Bulgarian Academy of Sciences.
It is very difficult to analyze a summary without having the final report and the baseline data to be subjected to an independent evaluation. The summary is full of scenarios and models in which the Belene NPP construction is possible, full of many ifs, ands, or buts. It is worth mentioning that “region” is multiply referred to as a panacea and a possible market for the Belene NPP production, but there is no evidence of any preliminary contracts between the “region” countries, what-soever.
Unlike the White Book of the Bulgarian Academy of Sciences, this summary does not give any clear and specific answers. The report summary looks more like a white flag banished by the Bulgarian Academy of Sciences under the pressure of the nuclear mafia, than like the White Book.
On p. 5 of this document there is the following forecast: “These scenarios are complemented by a variant of a low-growth alternative to renewable energy after 2020 and the lack of a declared investors’ interest in the realization of new projects of this nature.” This sounds absurd and hopelessly obsolete, in the style of Rumen Ovcharov from 2008.
In fact, the benefit of such an evasive approach to models and scenarios for the continuation of the Belene NPP construction project, is only for the Organized Crime Group (OCG), which drained more than 3 billion leva out of this corruption corps leaving us without a working plant .
We have been already witnessing how representatives of this group and the energy minister report cheerfully to the media that “according to the BAS report” the Belene NPP project could be resumed. They do not need the source data and the full report of the analyzes and surveys, “satisfied” with having a summary of scenarios under conditions.
In the beginning of 2013, this OCG imposed a budget allocation of about 15 million leva on a completely meaningless national referendum: “Should nuclear energy in the Republic of Bulgaria be developed by building a new nuclear power plant?” The only purpose of the referendum was the exculpation of the main initi-ators and participants in the budget draining with illegal “agreements” and “annexes” with Atomstroyexport, consultants and subcontractors without having a final contract signed. Of course, the referendum was a failure and did not reach the organizers‘ goal.
These violations were proven by a review of the Financial Supervision Commission (FSC) in 2012 and confirmed by a prosecutor’s investigation, after which two former bosses of NEC L. Velkov, M. Papazian and a former Energy Min-ister Peter Dimitrov were brought to justice.
It seems to me that with this BAS report, the Organized Crime Group will try to justify the former theft again and secure the possibility of a new budget rob-bery. I hope that when the full report comes out, it will contain accurate and rea-soned predictions, as well as conclusions, provable with correct data.
In order to help the authors of the report, I will give here only a few arguments for them to think about and propose a solution in its final version. So far, nothing has improved in the construction conditions of Belene NPP since the time of the White Paper, but on the contrary:
– the price of 600 million leva in 1990 is now over 20 billion; – the seismicity of the construction site and seismic risk can not be reduced, especially with the increased requirements for construction of new plants after the ac-cident in Fukushima NPP in 2011;
– due to the increase in energy efficiency and the introduction of more advanced technologies, there has been a dеcrease in energy consumption in recent years, which has led to a significant dеcrease in energy exports to the countries of the region; – the energy strategies of the neighboring countries rely heavily on enhancing their energy independence and do not include imports from the “zomby” Belene NPP; – the production of energy from RES in our country takes an increasing share in the energy mix;
– the equipment obtained and “present”, according to the Minister of Energy, is actually 1/10 of the one needed for the construction of a NPP; – it is high time to research the possibility of nuclear-free use of the construction site of Belene NPP, cut the budget expenditure it presents and rather generate revenue. There have been such developments and suggestions since the 1990s. It is still not too late for the team of scientists and BAS experts to preserve their good name and the authority of the institution they represent by presenting realistic data and provable predictions without taking into account the interests of the OCG. To raise the flag of the Bulgarian Academy of Sciences, instead of the white flag.
Belene nuclear project in Bulgaria
Recent development & arising questions
Decision to construct the second NPP at Belene site was adopted in early 80-ies. Construction works started in 1987. During 1990-1991 the project was abandoned due to the lack of money, environmental concerns and public opposition.
In 2002 the Government decided to start preparatory activities to restart the project. During 2002 – 2004 the necessary preliminary and feasibility studies (including report on Environmental Impact Assessment) were performed and the final Governmental decision No 18-8/2004/08 April 2005 on construction of two reactors type AES-92 (B-466) was adopted.
In March 2012 due to same reasons as in 1991, the Government adopted its Decision No 250/28 March 2012 to abandon the project. This decision was supported by the Parliament.
In June 2016 Paris arbitration tribunal decided that National Electrical Company (NEC) has to pay 620 mln Euro to Rosatom for the ordered equipment. Speculations concerning new restart of the project.
In the beginning of May 2017 a new Government formed. During the official procedure the new Minister of Energy stated: “To finish Belene NPP in the best way remains in our plans”. In the following months the Prime Minister Bojko Borisov, his deputy Tomislav Donchev, Minister of Energy and the Minister of finances made the similar statements. In August 2017 the Energy Minister announced a plan to establish Belene project company and in the beginning of 2018 to start a privatization procedure. It was said that several foreign investors from US, China and Turkey are interested in the project (there is no information what, actually does it mean). In case if this plan fails the construction of unit seven at Kozloduy site will be discussed.
Sources (in Bulgarian):
http://www.mediapool.bg 30.09, 15.08, 25.06, 29.05, 25.05, 04.05.2017
http://3e-news.net 29.08, 03.07, 20.06, 05.06.2017
www.factor.bg 29.08, 15.08, 01.07, 20.06, 15.06, 26.05.2017
www.novinite.bg 21.09, 12.09, 29.08, 20.06, 26.05.2017
We are surprised why the ministers are working on Belene nuclear project and considering different options to restart it, as the Governmental decision 250/29 March 2012 is in force – the project is abandoned, so all activities have to stop. It could be stated that such activities are very suspicious from the legal point of view.
New Governmental decision
The Nuclear Act (http://www.bnra.bg/en/documents-en/legislation/laws/zbiae2012-en.pdf) defines a special procedure (Section IV, Art. 45) for construction of nuclear power plants. A NPP could be constructed only following the decision by the Council of Ministers.
A proposal to construct a nuclear power plant shall be submitted by the Minister of
Energy to the Government, accompanied by an assessment of:
- Nuclear safety, radiation protection, environmental impact and physical protection;
- The social and economic significance of the construction of a nuclear power plant
for the nation or for particular regions;
- Radioactive waste and spent nuclear fuel to be generated, as well as their
- If the operation of NPP may impact the public and the environment of another country, the Minister of Foreign Affairs shall notify the competent authorities of that country and to provide, if so requested, all information those authorities may need for evaluation and analysis of the potential impact of the plant on their territory regarding public safety and environmental protection. Any official statement from such authority received shall be attached to the proposal.
In addition – the EURATOM treaty defines a number of other requirements.
In our opinion in order to start (restart) the Belene project, Government has to accept a new decision for its construction, or to cancel the Decision 250 from March 2012. In both cases the decision has to be based on the valid assessment mentioned above.
The existing assessments on nuclear safety, radiation protection, etc. were accomplished in 2002-2004 before definition of the lessons learned from Fukushima severe accidents and before the development and approval of the new European directives in the nuclear field, including:
- COUNCIL DIRECTIVE 2014/87/EURATOM establishing a Community framework for the nuclear safety of nuclear installations, 8 July 2014;
- COUNCIL DIRECTIVE 2013/59/EURATOM laying down basic safety standards for protection against the dangers arising from exposure
to ionizing radiation, 5 December 2013;
- COUNCIL DIRECTIVE 2011/70/ EURATOM on the responsible and safe management of spent nuclear fuel and radioactive waste, 19 July 2011.
- European Energy Security Strategy, European Commission, 28.05.2014
Conclusion: The new Governmental decision has to be based on updated studies and assessments, in line with European and Bulgarian legislation.
EIA Report vital shortcomings
Legal force of the report
According to the Act on Protection of the Environment, the EIA report will lose its legal force if during the next 5 years of its adoption the construction of NPP has not been started.
Our opinion is that the report on Belene EIA has lost its validity and in order to accept the decision to start construction of the plant, a new report has to be developed, and after public discussions and consultations the other countries, eventually to be approved.
We were very much surprised to know that the official position of the Minister of Environment and Waters is – the report on Belene EIA is still in force (MoEW letter 02-00-95/03.10.2016 to Mr. Martin Dimitrov, Member of Parliament; MoEW letter No 48-00-797/14.12.2016 to Mr. Todor Todorov, NGO “Za zamjata”, MoEW letter No 48-00-319/01.08.2017 to Mr. Todor Todorov). The arguments of the Minister of MoEW put forward are more than absurd – it is said that in September 2016 the local branch of MoEW accomplished an audit at Belene site and discovered that during the following 5 years after approval of the EIA report an information center and residential building were constructed, as well as two small local purification facilities. There is no answer when and why these activities have been done without approved technical project and without permit for construction.
Position of the MoEW is fully in contradiction with the following facts;
– Technical design of Belene NPP is (still) not approved by the Bulgarian Nuclear Safety Authority (BNSA official letter No 05-00-5/14.11.2016 to Mr. Petar Penchev). This means that no technical plant design exists;
– Permit for the start of Belene construction is not issued by BNSA (same letter). This means that no construction activities are allowed;
– There was no contract for construction of Belene NPP;
– There was no scheme to finance construction of Belene NPP;
– Even the licensee (NEC) in its Annual Report 2010 p.48 admits that construction works were not started: “All civil structures at the site which were not to be integrated in the new design of Belene NPP were dismantled in the period August 2008 – September 2009. The site is completely ready for starting construction works. “
Source: NEC Annual Report 2010 p.48 (in Bulgarian and English)
Conclusion: “Construction activities” mentioned in the MoEW letters are illegal and cannot be used as legal arguments.
Electrical output of Belene NPP
Decision No 18-8/2004 of the Minister of MoEW (that approves Belene EIA report) defines construction of NPP with maximum electrical output of 2000 MW.
However, according to the information, nominal electrical power of the proposed reactors is at least 1060 MW each. This means that the total nominal electrical output of the plant would be at least 2120 MW. Source 1: Techno-economic analysis justifying Belene NPP construction, NEC, July 2004 (Bulgarian), p.1-11, 94, 96, 203, 204, 205, 206, 207, 208 – nominal el. output 1068 MW; Source 2: NEC Annual Report 2010 (Bulgarian, English), p.46, nominal el. output 1060 MW.
In addition it is quite probable that information to other countries was misleading.
Conclusion: Construction of NPP with nominal el. power at least 2120 MW would be a brutal violation of the one of the major limitations of EIA report that cannot be allowed. The possible decisions are to create a new EIA study or to construct reactors with less output.
Possible future activities
In the case if the Government will use the 2004 Belene EIA report as a basis to approve decision to restart Belene project, this decision will be appealed in the High Administrative Court. The main arguments would include the illegal status of Belene EIA report, violation of the limitation for the maximum electrical power as well as the outdated assessments.
However recently the Parliament proposed amendments to the legislation that would drastically limit the right to appeal IEA of the most important (national) projects, including construction of NPP, high ways, etc. The major changes are introduction of one level court judgment (already in force) and huge increase of state taxes (still not in force). A number of NGOs sent an Open letter to European Commission, still there is no answer.
It should be mentioned that the opponents of Belene project have almost no access to national media and no representatives in the Parliament.
That’s why we badly need support and rapid intervention of neighboring and other countries, local communities, NGOs, European institutions, etc. As Bulgarian officials are very sensitive of pressure from outside such support would be of great value.
6 October 2017, Sofia
Dr. Georgi Kastchiev
Albena Varbanova – Foundation for Environment and Agriculture
Todor Todorov – Environmental Association „Za Zemiata“/Friends of the Earth-Bulgaria
Petar Penchev – National Movement Ecoglasnost
Petko Kovachev – Green Policy Institute
Towards where electroenergetics is pulling the state ship
The Bulgarian Energetics: What is behind the curtain
Dr. Georgi Kaschiev – July, 2017
Old faces, new places
Behind the curtain of liberalization of the energy market as official policy, the Bulgarian energy system remains highly dependent on the Russian interests. Just one example — for Deputy Minister of Energetics has been appointed a person who was dismissed in 2011 from the NEC chief office for impairing the interests of the country in favor of Moscow under the Belene NPP project. There were also evidences against him at the time for serious conflict of interest – both he and his son owned energy companies. Apparently he is the strong man of Moscow now, since he was appointed as a state representative in Neftochim, replacing Mr. Rumen Ovcharov (formerly considered as „conductor of Russian energy interests“) on the post. It was said that the man would not receive salary from Sofia for his work at Neftochim. It was probably presumed that he was getting enough from Moscow. This appointment clearly shows that in the energetics the interests of Russia will be strictly taken into account.
What has actually been achieved
The current politicians in power claim that as a result of the measures taken by them, the state electroenergetics is financially stabilized and starts moving in upward direction. However, data for 2016 shows a completely different picture.
Losses getting bigger and bigger
Only „Electricity System Operator“ (ESO) reports (traditionally) a net profit of BGN 73.8 million.
According to the government’s expectations, the National Electric Company – NEC had to end 2016 with a net profit of at least BGN 12 million. However, the result is a huge loss of more than BGN 130 million (BGN 34 million more in comparison to 2015) despite the subsidies of more than BGN 300 million the company received from the fund Security of the Electricity System (SES). By the end of 2016, the company’s liabilities has increased to more than BGN 4 billion and it is obvious that it cannot continue to operate without the financial support from the Bulgarian Energy Holding – BEH and the state. For the year 2016 the state-owned TPP „Maritsa East 2“ registered a net loss of over BGN 90 million, or nearly BGN 19 million more in comparison with 2015.
The export of electricity in 2016 has drastically shrunk to 6.546 billion kWh (10.562 billion kWh in 2015), and by the middle of 2017 it has fallen further with more than 16% as a result of the increased supply of electricity in the region. However, the politicians in power try to ignore this trend and continue to talk that the country should necessarily become the energy center of the Balkans and build the Belene NPP.
These facts illustrate the gloomy state of the national electroenergetics – and completely different from what the politicians are trying to suggest. What else it can be since the main problems are not taken care of – liberalization, manipulated public procurements and auctions, corruption, lobbying, extravagantly expensive repairs, theft, employment of too many unnecessary people, long-term contracts, appetite for megalomania projects, etc.
Towards where electroenergetics is pulling the state ship-II
Little more attention to Kozloduy NPP and the national nuclear program
What is the real price of the electricity produced?
In 2016, the electricity which Kozloduy NPP has produced was with 2.8% more than in 2015. Revenues, however, have decreased and costs have risen dramatically (mainly for external services) and the net profit for 2016 was only BGN 1.359 million (net profit for 2015 was BGN 82.4 million). For the period 2017-2021 a huge amounts of funds (something like BGN 880 million) are planned for absorption to prolong the lifetime of the 5th and 6th power blocks. The amount of these funds is at least double of what was needed to complete the same procedure in Russia with reactors of the same type.
A closer look at the “profit”
The reported profits for 2015-2016 are actually fictitious as the plant has failed to meet its regulatory obligation to transport every year at least 50 tons of heavy radioactive metals (HM) in the spent nuclear fuel (SNF) for storage and processing in Russia. Undoubtedly, this was done with the blessing of Minister Petkova. In the media some ridiculous explanations circulate for this failure such as unfavorable weather conditions, delays in analyzes, and so on. In 2015 and 2016, the NPP has made provisions of BGN 29,942 million for SNF (provision is the most reliable estimate about spendings for settling of a current liability that will be made during the next reporting period). The amount of the provision is negligible given the fact that in 2012, for example, the price for 1 kg HM from SNF from the old reactors was BGN 1054 and for 50 tons of HM respectively it would be at least BGN 52.7 million. However, the necessary expenses are much more because the Russian side asks for a much higher price for processing of the SNF from the new reactors.
Agreement has not been reached yet, that is why as of 2008 the nuclear plant only transports SNF from the old reactors. Practically however, it is already exhausted and the transportation of fuel from the new reactors, at the new prices has to begin. International prices are above USD 1200/ kgTM, which means that the provision should be at least BGN 110 million. Thus, with the blessing of Minister Petkova, Kozloduy NPP in 2015 and 2016 has accumulated liabilities of at least BGN 160 million for the next years, decades and for the future generations perhaps. With the huge spendings planned for 2017-2021, this practice is likely to continue.
A hidden burden to our children
The accumulated financial weights for the future generations are actually much higher. The problem is that SNF (or the highly active wastes from the processing) must ultimately be buried. This should have been regulated in the national strategy for SNF management. All strategies so far, including the one updated in 2015 under the direction of Minister Petkova, however, remain silent on this issue. Therefore, in every report of the Kozloduy NPP is written that the plant is unable to assess its obligations for the disposal of SNF and does not make provisions for it.
How much would it cost to build such a repository in Bulgaria if there is a place for it at all? For a rough estimation may be used the real cost estimates for such repository made from other countries (Finland, Sweden, France, the United States). By comparing the scales of these nuclear programs, it can be concluded, that for Bulgaria the funds that would be needed are about/over EUR 3 billion.
Thus, through the maintaining of the myth about the low cost of the electricity from the NPP and the postponing by every government even the discussions about the SNF final repository, our children and grandchildren are given the task to accomplish very difficult technical solutions and to provide the huge financial resources they would require – comparable in amount to the cost of a new reactor.
Towards where electroenergetics is pulling the state ship-III
NPP „Belene“ forever
A reliable strategic investor for Belene NPP will not appear
Energy consumption reaches new lows
The scientific team from BAS can hardly produce a more accurate assessment than the ESO experts to which it is essential part of their work. Every year, ESO prepares a report with analyzes and forecasts for 10 years ahead on the consumption and production of electricity and presents it to the CREW (Commission for Regulation of Energy and Water). Even ESO has not been able to predict accurately the real consumption of electricity and each year the actual consumption is less than the predicted minimum. Each of the ESO reports concludes that consumption in the country is secured till the end of the forecast period, with huge export opportunities. What ESO says very clearly is also supported from several independent reports from 2010-2011 – the country does not need a new large base station but rather has the need of balancing power facilities (for example steam power plants in Belene and Varna TPP) and / or the participation of large energy consumers for the regulation of the demand peaks.
No mercy for the taxpayer
It seems to me that the authorities has partly begun to realize how huge are the costs (over BGN 20 billion) and the problems of the implementation of Belene NPP project, as well as the high price of the electricity from it (8.5 euro cent per kWh or more). However, this does not lead them to the logical conclusion for total termination of the project, but to ideas how to transfer the expenses to the taxpayers instead. Talks started about the possibility for participation of the state, for which it has no money and no bank would finance it. The foolish idea about subsidizing the price of electricity from the SES fund has also been mentioned, and it will logically meet a huge public resistance. It has been proposed the separation of the assets into a separate company and its privatization. This means months, maybe years of meaningless work, absorption of millions for analyzes, forecasts, consultancy contracts, maintenance of unnecessary administrative structures, and so on.
Back and down
I am convinced that a reliable strategic investor for Belene NPP will not appear. I have in mind that over the last decade the construction of every NPP in Europe and the United States has taken many years of delay and huge increase of their costs, that reach to USD 8 billion dollars per 1000 MW power unit. For these reasons, the shares of the French AREWA fell with over 70% since 2007, and in March 2017 Westinghouse announced bankruptcy after the accumulation of USD 8.3 billion losses for the construction of four nuclear reactor in the USA. So putting huge amounts of money into NPP projects has become very risky. Even the Russian state-owned company has refused to participate as an investor in the Belene NPP project.
If eventually an investor becomes interested, he is very likely to withdraw quickly after getting himself familiar in details with the seismic risk of the NPP site, after seeing the photos of the „water hole“ over the anti-seismic pillow of the first power block and those showing the new equipment dropped in the rain at the port of Belene, or after hearing about the problems of the EIA report, the government’s corruption habits, the history of the project management, the reasons for the withdrawal of all investors so far, the lack of a skilled workforce. If someone goes into this adventure, he will certainly recognize only a small part of the current costs and will certainly demand a guaranteed buyout of electricity with long-term contracts. The state might be required to modernize the national power system and connect the new power plant to it (BGN1.330 billion according to ESO from 2019), to build new power lines to the neighboring countries and keep low the guarantee for nuclear damage and pay the costs for the SNF disposal, etc. If the government accepts such conditions, it would be a national betrayal.
In conclusion – electroenergetics keeps pulling the state ship back and down.
12.05.2017, by Todor Todorov
The Parliament elections in Bulgaria took place on 26th March 2017. Five parties entered the new Parliament. None of them is opposing the development of the nuclear industry and the construction of Belene NPP.
The party who won the elections GERB maintains the position that Belene NPP can be built but without state support or participation, only if a strategic investor is found for the project. During their government (2014 -2016) there were negotiations with Chinese investor for renewal of the project.
The coalition supporting GERB for forming a new government and will provide support in the Parliament is called United Patriots. It consists of 3 nationalistic parties. Two of them (Ataka and VMRO) were pro-Belene NPP project as a Russian project and took active role during the referendum in 2013 – convincing the people FOR the need to construct new NPP.
The socialist, the biggest party in opposition now have always lobbied for the construction of Belene NPP and this elections it was again a priority in their program.
The other two represented parties – DPS and Volya, have not declared a clear position regarding the nuclear energy and the specific project of Belene NPP so far.
Tis specific political configuration makes our effort very important – the efforts to stop the corruption schemes through the court. These corruption schemes were always a part of the development of the nuclear industry in Bulgaria.
After the Bulgarian government stopped the Belene NPP project in 2012, Rosatom filed a lawsuit with the International Arbitration Court in Geneva against the National Electricity Company for the equipment which had been ordered but was yet unpaid for. The court’s decision was that the National Electricity Company should pay 601.6 million Euro for the reactors that had been ordered at an earlier stage. In December 2016 the required amount was paid out from a state budget loan. The Bulgarian Parliament urgently adopted a special law to provide financial support to NEK. After the payment, in April 2017 two Russian reactors arrived and are currently stored at the Belene NPP site.
In addition to a inevitably pro-nuclear government, we now have also two reactors, ready to be installed in a nuclear power plant.
Since July 2016 Za Zemiata has submitted 7 access to information requests to the Ministry of environment and the Nuclear Regulatory Agency. The information we want is regarding the legal status of EIA, as well as weather the safety measures, provisioned in the project for Belene NPP, were completed.
The goal is to file a court case in the Supreme Administrative court regarding the legitimacy
of the actions that were undertaken by the administration. Our lawyers will consider whether we have grounds for such a court case carefully. In our country lately, there is a tendency that the court puts very high impossible court fees and lawyer’s fees to the NGOs who dare to question and disclose the corruption practices and the lack of transparency in the nuclear field. Thus the nuclear mafia secures its untouchability.
The anti-nuclear campaign has to show the dangers and the corruption in the nuclear industry, and at the other hand It is also important to work on indicating the alternatives for development of the Bulgarian energy sector without nuclear energy.
28.3.2017, sent by Todor Todorow:
Analysis of the programs of political parties in Bulgaria, on the topic “nuclear power”, before the parliamentary elections on 26/03/2017
Early parliamentary elections will be held in Bulgaria on 26.03.2017. We made a brief overview of the attitudes towards nuclear energy in the programs of the major political parties. With these programs the political parties participate in the pre-election campaigns for the votes of the Bulgarian citizens.
Former governors from GERB ( Citizens for European Development of Bulgaria) mentioned that the decision to restart project NPP Belene will be taken after an analysis is made by scientists from BAS (Bulgarian Academy of Sciences). BAS, however, is dependent on the state budget and it can hardly be considered as an independent institution. In the political debate, the representatives of GERB support the idea of restarting the budget with an external investor and without involvement of the state, illusory hoping to regain the previously scattered over 1 billion and 400 million Euros. They do not set as a goal to enhance security for nuclear damage and to increase the financial responsibility of the investor, in order to clear the consequences of the future NPP’s work (the same applies to all other parties), i.e. the lessons from Fukushima aren’t learned.
BSP (Bulgarian Socialist Party), considered the favorite to win the election with a small precedence over GERB, firmly promises to construct NPP Belene with a governmental support. As always, their position lacks any technical and economic analysis on whether our country even needs this new nuclear power. Interestingly, nothing is mentioned about the construction of the seventh unit of NPP “Kozloduy”, although in 2013, during their government, they presented reactor AP1000 Westinghouse as the best reactor in the world, and tens of millions were wasted for developing the project for the seventh block of NPP “Kozloduy”.
DPS (Movement for Rights and Freedoms) traditionally do not hold a position on this issue. They are business oriented and would trade their support for a new NPP in return of a guaranteed “winning” of public orders of firms close to their party.
Patriotic Front – this coalition is composed of three nationalist parties. They do not hold a clear stance in their programs, but the leaders of two of the three parties have supported the construction of NPP Belene throughout the years.
The Reformist Bloc expressed opposition to the construction of NPP Belene, without stating any profound arguments why.
New Republic: The only party that in its program and in disputes clearly opposes the restart of NPP Belene, and offers suggestions on how to implement the supplied equipment for it.
Movement 21 – ABV – they are passionate supporters of the restart of project NPP Belene.
From our analysis, it appears that no party is considering the establishment of an economic zone on the Belene site with state support, for the nuclear-free future of the site and its possibility to start bringing revenue to the budget. What do parties think about the disposal of the highly radioactive waste (HLW) and / or the spent nuclear fuel (SNF) generated by nuclear power was not made clear. The reason is that once again politicians demonstrate that they are not thinking about the next generations, but the next elections.
by Za Zemiata, 17.1.2017
We are presenting to you the most recent developments regarding the project for building a nuclear power plant in Belene as well as regarding the extension of the lifespan of NPP Kozloduy’s Units 5 and 6.
NPP Belene Forever
At the end of 2016 the Bulgarian National Electric Company (NEC) paid the amount of 620 mil euro to Atomstroyexport as a result of the decision of the International Court of Arbitration at the International Chamber of Commerce. The amount was used to pay for the ordered and unpaid nuclear equipment before the official cancellation of the Belene project. As a result the total amount of the funds spent from the state budget increased to 1.2 billion euro. That led the Bulgarian state prosecution to charge three former ministers of energy of dereliction of duty but the charges are very vague and general and aim only to demonstrate activity rather than real interest in accountability and punishment of those responsible for this corrupted project.
The nuclear lobby in Bulgaria increased their pressure insisting that this nuclear power plant should be constructed after such huge amount of money had been invested already. According to the Minister of energy we should receive the two ordered Russian reactors by the end of April.
In August we expect to receive the turbines for the two planned reactors as well. The equipment will be preserved and stored on the site of NPP “Belene” until the need for new nuclear capacity is analyzed and a privatization procedures start. This, however, will be a priority for the new government as we are going to have new parliamentary elections in early April. Ultimately the equipment will remain on the NPP “Belene” site until new buyers are identified or a different decision regarding the notorious project is taken.
The government has granted the Bulgarian Academy of Science (BAS) the task to perform technical, economic and legal analyses of the project. The Minister of Energy claims that the analyses will evaluate the idea of realizing the project purely on market-based principles without the direct or indirect involvement of the State, without state guarantees and without long-term purchase power agreements.
The decision regarding the future of NPP “Belene” will be taken after the results of the analyses are considered.
If the results of the analyses are negative then the government will look for a way to sell the two unused nuclear reactors.
In December 2016 the Prime Minister had a meeting with representatives of the China General Nuclear Corporation (CGN) as well as with representatives from the Industrial and Commercial Bank of China. After these meetings representatives from the government announced that the Chinese companies and the bank declared their intentions to realize the project as per the conditions stated by the Bulgarian government.
In regards to the analyses given to the Bulgarian Academy of Science, we would like to remind that in 1990 the Bulgarian scientists of the Academy expressed their strong objections against the construction of NPP “Belene”. They published their objections in a 400-page study called “The White Book of BAS”.
“Za Zemiata” has been trying to object in court the Environmental Impact Assessment of the NPP “Belene” project which the government claims has been in force since 2004. If we are successful we would be able to delay the renewal of the project with few more years. This is where we need of support to work with lawyers, the media and the campaign.
According to our analysis the privatization of the nuclear project as per the conditions stated by the government is impossible. In the implementation of a nuclear project, the most important issue in private NPP is the insurance against nuclear risk.
Private investor will for sure require the state to take responsibility for the nuclear risk. It will be difficult to find candidates willing to construct NPP “Belene” without state guarantees and some form of guaranteed rate of return through purchase power agreements.
On January 11th, the Parliament rejected the opposition’s proposal to cancel the decision of the Parliament from March 29th 2012 for the cancellation of the construction on NPP “Belene”. Depending on the results of the upcoming at the end of March elections, we expect political and lobby pressure for the restart of the project and we should be prepared.
Extension of the lifespan of NPP “Kozloduy” Units 5 and 6
The most recent news regarding the life extension of Units 5 and 6 of NPP “Kozloduy” is that the cost will be “less than 220 million euro”.
Currently, the two units are being retroffited in order to be granted new operational licenses. The permit of Unit 5 expires in November 2017. The analysis of its state as well as the recommendations for improvements have been submitted for approval to the Nuclear Regulatory Agency. All recommendations should be realized in 2017 for the Unit to get a new license. The permit of Unit 6 expires in October 2019. Currently the unit has been examined to determine what retrofits will be needed to extend its lifespan.
The retrofit work of the units has been performed with the assistance of the Russian company “Rusatom Services”, part of the nuclear company “Rosatom”.
According to the Minister of Energy all investments for the modernization of the Units come from the company-owner of the power plant. On this topic we will try to get more information on the technical parameters of the improvements so we can turn to independent experts for analysis and evaluation.
29th November 2016
On the imaginary nuclear renaissance
The statement that no nuclear reactor in the world operates at loss is false.
by Dr. George Kaschiev
Hereby I provide the following examples from the last few years to prove this point:
During the past four years six reactors in the USA, totalling a capacity of 4730 MW, were shut down before their time. Those are Crystal river 3, San Onofre 2 and 3, Kewaunee, Vermont Yankee and Fort Calhoun-1. The first three must undergo very expensive repairs which would make them a losing enterprise. The remaining three are already turning losses in the current conditions of low energy prices, stagnant demand for electricity and the lower electricity prices from gas-fired power plants. For those reasons 15-20 reactors could be shut down by 2025.
Nuclear reactors are failing to profit in Europe as well. In early 2013 in Spain the Garona nuclear reactor (466 MW) was shut down due to risk of bankruptcy. In Sweden, four out of ten nuclear reactors currently in operation will be decommissioned early, as their owners expect them to begin turning losses. Those include OKG’s Oskarshamn 1 (492 MW) and Oskarshamn 2 (661 MW), projected for shutdown in mid-2017, and Vattenfall’s Ringhals 1 (916 MW) and Ringhals 2 (910 MW), due to shut down in 2020 and 2019 respectively.
Has there been a nuclear energy renaissance since year 2000?
According to the dictionary renaissance means revival, flourishing, resurgence. Facts show, however, that there is no flourishing or resurgence of nuclear energy in the world and that only individual countries continue building reactors for various specific reasons.
International Nuclear Energy Agency In comparison, at the end of 2015 there were 441 reactors with a total capacity of 383 GW. The growth of nuclear capacity for 15 years is negligible – just 33 GW (or 9.4%). In comparison, for the same period, at the end of 2015 wind power capacity had increased by nearly 64 GW (an annual growth of 17,2%), reaching 435,9 GW.
Nuclear power generation is on the decrease.
Moreover, the INEA (International Nuclear Energy Agency)- statistics for 2015 include 44 reactors (mainly in Japan), from which only two produce electricity: Sendai 1 and 2, while the remaining reactors have been shut down for years. If only reactors in exploitation are counted, the conclusion is clearly that there is no growth in nuclear energy, rather the opposite – there has been a decline. This conclusion is confirmed by the following data: in 2015 nuclear power plants have generated 2441.3 Twh, which is less than the energy produced in 2000 (2443.8 Twh. At the same time, the share of nuclear energy has decreased from nearly 18% in 1996 down to a little over 12% in 2014.
In 2000 in EU-28 there were 169 nuclear reactors in exploitation, while in 2015 this number is down to 127 (with a total capacity of 121 GB, or nearly 27% of electricity). During this period only two reactors have been put online – Mohovce 1 and 2, while the construction of just four new reactors was launched. The construction of those has been riddled by long delays (up to 10 years) and huge initial costs (4900-6200 euro per KW of installed capacity. This shows that nuclear energy in the EU is undergoing a strong decline, rather than a renaissance. That renaissance is not due any time soon in the foreseeable future, either – e.g. France decided that its nuclear capacity should remain at the current level of 63.2 GW, while the share of nuclear electricity would fall from current 76.3% down to 50% already in 2025.
European Commission’s forecasts (Nuclear Illustrative Program, PINC) from April 2016 show that the capacity of nuclear reactors in 2050 would decrease to 95-105 GW, while the share of nuclear power generation would fall to 17–21%. Ideally all policymakers ought to read this document, alas, this is not likely to be the case.
After 2000 in USA six nuclear reactors were decommissioned, while only one new reactor was put online which demonstrates the same trend – there is no renaissance, but a decline of the nuclear energy. Currently 99 reactors operate in the USA, totaling a capacity of 99 GB which provides nearly 20% of the electricity. In 2013 the construction of 4 new reactors commenced, which is already delayed by nearly 3 years and whose costs escalated to over 5500 US$ per KW. No new reactors are planned in the foreseeable future.
The 2016 forecasts by the Energy Information Agency of the USA show that there will not be a nuclear energy revival: by 2040 the nuclear reactor capacity will be on today’s level of 99 GW. Meanwhile, the capacity of gas-fired power plants will increase by over 1.5 times (from the current level 202.3 GW to about 318.7 GW).
Developments in Russia, China and other specific reasons:
For special reasons nuclear reactors continue to be built in China, Russia and India (comprising half of the nuclear power plants currently in construction and in operation phases), as well as in Korea and Pakistan.
China is one of the most powerful and fastest growing economies in the world. In order to respond to electricity demand China has built many thermal power plants based on fossil fuels, primarily coal, which in 2015 generated 73% of the electric power. This tendency has lead to significant air pollution, it has turned China into the world’s biggest polluter, and has necessitated the development of nuclear power and renewable energy sources. Currently in China 36 nuclear reactors are in exploitation (total capacity of 31.4 GW), while 20 new reactors (combined capacity of 20.5 GW) are in construction phase. It is noteworthy that China is a world leader in renewable energy development, mostly of wind power, whose total capacity at the end of 2015 was 148 GW. Recently two new large renewable power plants with a combined capacity of 34 GW were put online.
Russia remains a staunch proponent of nuclear energy and that is probably the reason for the pro-nuclear stance of left-wing politicians. Currently there are 36 nuclear reactors in operation in Russia (combined capacity of 26.6 GW), while 7 new reactors are being built (5.5 GW). However, Russia’s ambitious nuclear programme has repeatedly undergone significant changes towards lower ambition. The latest such change occurred in August 2016 when a plan was approved according to which the construction of 11 new nuclear reactors should begin by 2030 (instead of 21 reactors planned in 2013). A high-level official has stated on this occasion that “we will not be building nuclear power plants that are not needed”.
Vietnam’s example is particularly useful for Bulgaria. The economy of Vietnam is growing fast (by 6% annually) and the country had planned together with Russia and Japan to construct two nuclear power plants with two 1000 MW reactors each. However, considering the low and stable prices of natural gas, the renewable energy potential and the falling prices for their installment, the almost double-lower growth of electricity consumption and the enormous initial costs of nuclear power plants, on 22 November 2016, parliament approved the government’s proposal to cancel the construction of those two power plants.
The most important points of the Belene–debate in Sofia, on September 27th, 2016:
1) „Belene is seismically too dangerous for an NPP“ – it is proved already.
2) „It is necessary to have a decision of the government in order the site to be removed from the assets of NEC”.
3) “The innovative idea that the area should become an economic zone covering Svishtov, Belene, Nikopol.”
4) “It was suggested the creation of a citizen´s commission to investigate the illegal actions of the guilty persons.“
„The idea of a citizen-driven investigation committee came up during the debate in reaction to the fact that Bulgarian prosecution officers did not identify guilty persons for the squandering of state funds, the investigation was terminated, then reopened again, but this time focusing only on officials from the NEC (National Electric Company).
A citizen-led commission indeed cannot match the resources of the state, but the idea is to search out documents and witnesses of the corruption surrounding Belene and thus to push state institutions to do their job – so it is rather a form of citizen pressure.“
(Parts of Todor´s email, by Paula Stegmüller)
Debate on the Nuclear-free future for the site of Belene NPP
on 27 September 2016, 10:00-12:00 h
Sofia, The Red House, Pesha Nikolova Hall
Debate_Belene_Prof Yankov. Debate _Belene_Dr. Kaschiev
Environmental and civic organizations propose a nuclear-free future for Belene site
On September 27, 2016 Environmental association Za Zemiata organized a debate on the “Nuclear-free future for the site of Belene NPP.“ Participants in the discussion were Professor Nikola Yankov, Mr. Pepo Petrov, Mr. Yoan Yordanov (representatives of the Committee for ecological and economic protection of Svishtov region), energy expert Dr. George Kaschiev Mr. Krassen Stanchev of the Institute for market economy, Konstantin Kyrenia (Romanian representative to the Danube coalition for a nuclear-free future of the region), Todor Todorov – Za Zemiata, Petko Kovachev from the Green Policy Institute.
The main topics for discussion were:
– Why the project for construction of Belene NPP is unnecessary?
– Who is responsible for „corruption puddle?“
– What are the options for nuclear-free future for the site ?
The economic bankruptcy of the project was analyzed by Mr. Krassen Stanchev, Todor Todorov, Petko Kovachev. Dr. Kaschiev added arguments about the impossibility to build a nuclear power plant in a seismically dangerous region, and the risks brought by such a costly affair.
On the subject of accountability of politicians and officials for corruption-ridden Belene project the participants shared the view that state institutions are not making the necessary efforts for detection of crimes and perpetrators. It was suggested the creation of a citizens commission to investigate the illegal actions of the guilty persons.
The most interesting debate was on the topic of nuclear-free future the site of Belene NPP. It covers 270 hectares area with good infrastructure and communications, its geographical location is favorable for the supply of necessary equipment and materials for construction by the cheapest transport – water – the Danube river.
Professor Yankov proposition is for the site to become an economic zone covering Svishtov, Belene, Nikopol, similarly to the model of the Plovdiv economic zone. Of course, this economic zone could be extended to the Romanian part of the region.
Discussed was the proposal to create an integrated complex to implement innovative and experimental technologies industry. Above all, however, the economic viability of each of the proposals must be carefully assessed.
Participants in the debate shared the opinion that such an economic zone would help to improve the balance in the uneven development between North and South Bulgaria. For this purpose it is necessary to have a decision of the government in order the site to be removed from the assets of NEC.
Professor Yankov recommend to work through wide discussions on national level to generate ideas of a shared strategic vision, strategy and plan to transform the site in Belene into a business complex useful for the region and society as a whole.
Participants in the debate agreed to lay out the steps they believe should be taken on such a project, consult with experts and communicate concrete proposals to the government.
Energy and Climate Team
Todor Todorov from Za Zemiata Bulgaria organizes a roundtable-meeting about:
„Nuclear free future for the site of Belene NPP“
The event will take place on 27th September 2016 between 10-12 am in Sofia , in the Red house, the hall Pasha Nikolova (http://www.redhouse-sofia.org/default.aspx). This is the best place in Sofia for such events and it is a centre for culture and debate with good reputation throughout the years. Many energy and economical experts, political analysts, journalists are invited.
We will start with 10-15 minute presentation of few reports on the following topics:
– Why the Belene NPP project is not needed
– Who is responsible?
– What is the nuclear-free future for the site
After the reports we will have discussion – or after each of the topics.
We expect confirmation of the participation till 20.09.2016.
Todor Draganov Todorov
Energy and Climate Coordinator
SPARE Project National Coordinator
11B „Yanko Sakazov“ str. floor 1
1527 Sofia, Bulgaria
Mailing address: Ekologichno sdruzenie „Za Zemiata“ P.O. Box 975, 1000
Tel/fax: + 359 2 943 11 23
E-mail: firstname.lastname@example.org, email@example.com
Protest in Svishtov against Belene NPP
BY THE COMMITTEE FOR ENVIRONMENTAL AND ECONOMIC PROTECTION OF SVISHTOV REGION*
The Committee for Еnvironmental and Еconomic protection of Svishtov region opposes against the absurd intentions and improvised solutions relating to „start“ once again AND AGAIN the construction of Belene Nuclear Plant (Belene NPP). This project is strongly supported by lobbying circles to complete the construction of the plant at any cost.
IN NATIONAL PLAN:
A very small group of interested individuals and institutions persistently seeks to benefit from Belene NPP implementation, not interested in the interests of the population and the future sustainable development of Bulgaria.
The dream of turning Bulgaria into an energy centre of the Balkans seems more half-wit and increasingly risky.
It is not clear where it will sell electricity generated by Belene NPP due to the fact that Bulgaria currently has sufficient capacity and its in this regard exports decreases.
In LOCAL PLAN:
Belene NPP will destroy the traditional economy of neighbouring municipalities as Svishtov, Belene and Nikopol and will deprive thousands of their inhabitants. A manipulation is that the project will provide ten thousand jobs during its construction!
Employment in the time of Belene NPP functioning is not great – it could employ about 700 – 800 highly qualified specialists.
ECologicAL consequences: Belene NPPwill inflict a severe blow to agriculture, animal husbandry, viticulture, fishing, small businesses and other sectors of the local economy.
The population of the municipality of Svishtov, which now is being subjected to the harmful effects of pollution from existing procedures will be subject to radaoaktivno pollution, even in small doses, even in perfect working NPP will be changing incidence of the most terrible and fatal diseases especially – children and adults – a fact that is confirmed by the practice and the best European NPPs;
Geological and seismic PROBLEMS: Belene NPP is being built in a highly seismic area where the last earthquake of 1977 in Svishtov killed more than 120 people , and in Romania – over 1,000 tragically died. In this regard let’s not forget the tragedy of Fukushima NPP.
On the social front Belene NPP will become unacceptable as permanent living place, and especially – for young people and students. It will destroy Svishtov as an educational centre with centuries of tradition and a high school with eighty-year history.
In PSYCHOLOGICAL PLAN it is difficult to accept people to live normally in the vicinity of several kilometres, with such a dangerous object, regardless of the guarantees of its security.
The adjacent Romanian district – Teleorman also is very sensitive. In this region still in the 90es were collected 40,000 signatures against Belene NPP construction.
These, along with much else unspecified circumstances, require responsible national thinking for non-nuclear use of the Belene NPP site.
*The Committee for Еnvironmental and Еconomic protection of Svishtov region (CЕЕPSR) was established in 1991 mainly to stop the realisation of the the Belene nuclear power station project . It brings together like-minded people with diverse profiles. CEEPSR’s forms of activity have many shapes and scales but mainly those are protests organized in the 90-s and the first decade of the twenty-first century. The Committee assists to the organization of national anti nuclear initiatives. CEEPSR is convened periodically to respond to government decisions related to the ongoing construction of NPP „Belene“. Besides this main goal, CEEPSR take actions to preserve the ecological balance in the area of Svishtov.
Sofia, June 16th 2016:
The Arbitration Tribunal at the International Chamber of Commerce decided:
The Bulgarian National Electricity Company (NEC) has to pay 620 million Euro to Russian ROSATOM as compensation for the suspension of the ordered reactor construction of NPP Belene.
Za Zemiata published an Open Letter against that decision (read more below: Open letter…)
Za Zemiata gave a Proposal how to help the Bulgarian government in this difficult situation. (read more below: The Proposal …)
- Todor Todorov explained the reaction of that letter (mail from July 9th.):
„I had a meeting in the Parliament in the Energy Commission with the representative of the opposition for common actions. I had an invitation for an interview with the National Radio, which was cancelled because of „change in the program“. For now there is no reaction from the Government about the Open Letter.“
Open letter to the Prime Minister of the Republic of Bulgaria
Belene NPP site – a pool of corruption or an opportunity for nuclear-free development?
Or a tale of a guilty conscience and impudence
The decision of the Arbitration Tribunal at the International Chamber of Commerce, regarding the lawsuit between the NEC (NEC = National Electricity Company) and Atomstroyexport for suspension of the construction of NPP Belene, is now a fact. Despite a delay, the result was as expected. In other words, the NEC will have to pay over 1 billion BGN to the Russian side for the supply of the equipment that has been ordered. Following the principle ‘there’s no smoke without fire..’, the media immediately started releasing statements by some of the major culprits in a fresh attack on the Bulgarian interests in the energy sector in favour of the Russian interests. Mr. Parvanov, Mr. R. Ovcharov and various other ‘experts’ started flagrantly explaining that it was the right moment to built the Belene NPP and what a favourable effect it would have on the Bulgarian economy. It has to be remembered that, over several years, Rosatom increased the price for the construction of the Belene NPP from 3.9 billion Euro to 10 billion Euro.
What is the benefit for our country exactly?
In fact, since its very beginning, the idea of a new NPP in Belene has been void of common sense and unnecessary for our country. As early as 1990, in the so-called ‘White Book’, a team of scientists from the Bulgarian Academy of Science came out with the following opinion:
‘From an energy, economic, technical, seismic, environmental and social point of view, the construction is ill-grounded and unacceptable.’
Za Zamiata has been warning several governments again and again that an unprecedented theft of state budget funds is under way by a group of politicians and advisers acting in favour of the Russian energy lobby.
In 2009, the prosecutor’s office and the State Agency for National Security started an investigation into the fraud, but no results have appeared so far.
Over 2 billion BGN were stolen from the state budget through procurement of equipment without a contract being awarded, for ‘reports’, ‘analyses’, ‘studies’, and construction of an information centre. One of the most scandalous budget items of the project are the expenses for consultancy services, to the tune of 210 million Euro! A particularly huge amount of these expenses were the 203 million Euro paid to Worley Parson for consulting services which have failed to produce any public results. According to experts, a report on a project that has not yet even started, cannot possibly cost more than 2 million Euro.
Taking into account the scale of the ‘utilised’ sums and the fact that no prosecution has been started, it is completely understandable why the same persons now want to engage in the same type of robbery scheme.
For years, we have been providing official evidence that the available power generation facilities in Bulgaria are more than the country actually needs.
Available data for this year show that, from the beginning of the year until 5 May, the export of energy has more than halved, i.e. the excess of generated power cannot be exported.
Despite this, instead of promoting energy efficiency, the government representatives keep speaking of new energy facilities and of keeping all the outdated facilities. This is in conflict with the European and worldwide trend for pure and efficient energy.
Author: Za Zemiata, Todor Todorov, Energy and Climate Coordinator, published in:
The proposal of Za Zamiata Environmental Association
after the decision of the Arbitration Tribunal at the International Chamber of Commerce for suspension of the construction of NPP Belene:
In no case should the ‘advice’ of the Russian parties in Bulgaria for a direct meeting between Borisov and Putin to discuss the payment of the ordered equipment be followed. Being aware of the arrogant negotiating style of the Kremlin, we wish to shield our prime minister from such humiliation.
We recommend the participation of European experts in our expert group during the negotiations with the Russians, which will help dampen Russian strong-arm tactics. On the other hand, since the principle of solidarity is paramount for the EU, this is one of the moments when Bulgaria needs support.
In January 2012, we launched a national contest for the future of the Belene site. Of course, we are not the only ones seeking alternatives.
In 1991, the Council of Ministers adopted Decision No. 288 to explore the possibilities of building a gas-and-steam power plant and any possible use of the existing infrastructure. All prepared documentation – studies, analyses, reports – is either gathering dust in the ministries or has been destroyed.
We propose our government initiate an international contest for the future use of the existing site in Belene with clear parameters and choose the best project after economic analysis of its costs and benefits, in compliance with the requirements for environmental protection in the region. Thus this symbol of corruption will no longer waste new budget funds, but will instead generate revenue and foster the development of the region.
We recommend that:
The approved projects have a long-term vision for the development of the site
They should take into account any local and regional specifics and environmental conditions
They should be innovative and support sustainable development
Priority should be given to projects without participation of Russian experts
The proposals may refer to a part of the site or combine several ideas
proposals may refer to a part of the site or combine several ideas
This should not be interpreted as releasing from liability those persons who are guilty of the huge waste of state funds, or those politicians and government officials who signed agreements with Russia without even reading them.
A prompt and efficient response is needed from the prosecution, in order to reveal the result of the investigation of the Belene NPP case that went on for several years.
Todor Todorov, Energy and Climate Coordinator, Za Zemiata, June 16th in Sofia.
Points for the case in SAC against the second EIA for the National Repository for Radioactive Waste (NRRW) in Bulgaria:
Peter Kardjilov June 20th 2016
1. There is a manipulation of the demographic data on population movements in the area Dolj – while in the first EIA are set 13.7% mortality in the area and 11.7% in Romania country, then in the second report there are no values, but a schedule with exactly opposite results.
In this regard, the Supreme Administrative Court (SAC) in decision № 11040 / 22.07.2013, rejecting the first EIA emphasized absolutely the same exceeded two points of mortality for Kozloduy Municipality compared to the state Bulgaria, and the court notes that the diseases of circulation take the first place. The same diseases are on first place in the area Dolj also, according to the first EIA which is colcealed in the second EIA.
2. SAC focuses on the first EIA report stated 50 years durability of reinforced containers with radioactive waste and the same durability of containers is also mentioned in the second EIA report.
Remains unanswered this motive in the SAC decision № 11040 / 22.07.2013, rejecting the first EIA – how this fact correlates with the announced reliability of 375 years of NRRW.
3. Remains unanswered the position of the Bulgarian Ministry of Health that presented in the first EIA report radionuclide inventory of planned radioactive waste disposal in the NRRW besides qualifyied as low and intermediate level radioactive waste from category ‚2a‘, there are four long-living radionuclides (Carbon-14, Nickel-63 Niobium-94, Iodine-129).
While the permited for disposal in this NRRW Cesium-137 the half-life is 30 years (which is the statutory ceiling on the half-life of buried RW), the half-life of those four pointed out by the Ministry of Health Carbon-14 is 5730 years, and for Iodine-129 is 17 million years, ie availability of these long-living radionuclides are already a category ‚2b‘ and determine normative choice of geological type of NRRW – not to be near surface and at a certain depth located entirely underground.
4. In the second EIA was repeated the assertion noticed by court decision № 11040 / 07.22.2013 on that potential radiological impact is localized to the site of the repository when this unsubstantiated allegation has already been critically challenged by the Executive Environmental Agency in the first EIA report.
That allegation is repeated again in the second EIA, this time is suppressed by the EEA.
5. SAC focuses on decision № 11040 / 22.07.2013, when assessing the first EIA that are not covered in the survey of „Mineproject“ JSC standards for the type of store with outlets for recommending the construction of ‚tunnel type‘ full depth underground, not ‚trench type‘ on the ground.
6. In the second EIA, the same way as in the first one, still in the assignment made by the State Enterprise „Radioactive Waste“ is again destined for choosing type of store ‚trench type‘ and place of the site – „Radiana“ in the territory of NPP “ Kozloduy „, which has seized the opportunity and the regulatory requirement that judgment to be made after a reasonable analysis by the authors of the EIA report.
7. Two studies on study of potential sites for the disposal of radioactive waste in Bulgaria are neglected.
The first report is under contract under the program „PHARE“ from 1997 authored by John Mathieson, Cassiopee; Andew Temple, AEA Technology; Gerrard Obin, SGN and Anton Boyadzhiev, Risk Engineering. It evaluated 20 sites on 12 criteria and the site „Radiana“ is missing in this choice.
The second report of the Geological Institute of the Bulgarian Academy of Sciences (BAS) from 2000, were assessed 30 sites on 28 criteria. In this report again site „Radiana“ is missing.
Based on these studies „Mineproject“ AD, under the „Phare“ and BAS, the Board of SE „RW“ has decided to build a ‚tunnel type‘ NRRW but that decision was changed after the appointment of the current CEO of SE „RW“ Mr. Dilyan Petrov. He adopted a ‚trench type‘ repository, commissioned a new report in BAS in 2006, geologists made „new“ assessment of the otherwise unchanged centuries-old geological structure in Bulgaria and gave a certain priority to the assigned site „Radiana“ for near-surface repository.
Finally we quote SAC decision № 11040 / 22.07.2013, rejecting the first EIA:
„The system of measures for radiation protection involves selecting an appropriate site for the deployment of a nuclear facility. The basic criterion in the selection should be radiological rather than economic criterion. The report says that according to the criteria of safety the best site location is „Marichin valog“… The report lacks a detailed comparative analysis of alternatives and technologies with regard to the construction of the facility, which is mandatory according to Art. 96, para. 1 pt. 2 of the Act for assessment of environmental impact. „
These reasoned conclusions of the court are not removed in the proposed for public comment second EIA report for the NRRW.
Our proposal is the Ministry of Environment and Water (MEW) of the Republic of Bulgaria to return, without entering underway procedure for judicial review, for the third time making third EIA report, but this time to assign a new team of experts because the second EIA report was unlawfuly assigned to the same team – whose first report was declared by the court for poor. And something more significant – disabilities referred by the court of the first report are literally ‚copy-paste‘ are placed in the second report. Applied by SE „RW“ category „unforeseeable circumstances“ of the Public Procurement Act and the notification of the Ministry of the Romanian Ministry of Environment and Forests that the report was returned by the court due to ‚technical flaws‘ – do not correspond to the truth, as stated in above only part of the essential notes of SAC in decision № 11040 / 07.22.2013, confirmed by the second and third instances of the same court.
We would like to hope that in the third EIA report:
1. purpose of the NRRW to add that type of waste – except ‚2a‘ and part of long-lived category ‚2b‘;
2. Review the use of containers with a short life of 50 years;
3. The site be moved from the site „Radiana“ (sand-clay strata) to a stable geological structure allowing deep construction;
4. type of construction of the NRRW to restore the previous choice of SE „RW“ for ‚tunnel type‘ – located entirely below ground, not on the surface.
8.1.2016, Todor Todorov
Bulgarian Government Seeking Investor to Build Unit 7 at Kozloduy NPP
Following Bulgarian Prime Minister’s visit to China in late November, news came out that he has suggested to a Chinese company to explore the opportunities for building Unit 7 at Kozloduy NPP.
In mid-December Tomislav Donchev, Deputy Prime Minister for Economic Matters, and Temenuzhka Petkova, Minister of Energy, brought representatives of the Chinese state-owned company SNPTC to Kozloduy NPP to get first-hand knowledge of the Plant’s site. The company is one of the three operators of nuclear capacities in China and a major partner of Westinghouse.
The state-owned company plans to become involved in the project in our country via the group’s investment division.
Deputy Prime Minister Donchev stated that the government has proposed that the project be implemented without Bulgarian funding, with a large portion of the funds to be provided by the strategic investor, without government-backed guarantees. According to him, however, the option of the government keeping some minority share interest is not ruled out either. „After all, the capacity would be built on a site, which is government property. We do have reason to claim a share in this project“, said Donchev.
A joint task group including the potential investor’s representatives has already been set up. The negotiations are intended to clarify the economic model via which the investment could be implemented. The major issue is whether the Chinese company would have a majority or minority stake in the project.
The task group is given a deadline of April 2016 to come up with an opinion whether Unit VII of Kozloduy NPP will be built by a Chinese company.
Deputy Prime Minister Donchev confirmed that he expects the task group’s analysis to result in several possible options for the Bulgarian government to choose from.
Of course, in our opinion it is a different issue whether there is any realistic option in the first place or Kozloduy 7 would just repeat the corruption scheme associated with the supposed “construction” of Belene NPP where the state budget was drained.
26.11.2015, Genadi Kondarev
Postcard from Chernobyl
Shortly before the 29th anniversary of the tragedy in Chernobyl I had the chance to take one of the notorious Chernobyl tours that bring tourists from Kiev, Ukraine, to the nuclear Disneyland. I paid 60 EUR for one of the most depressing experiences in my life.
There are strange attempts and hopes that soon this exclusion zone will be brought back to a state which is fine for people to live there. Even now there are nearly 2000 people living there. Despite security measures old people came back to their houses as they used to live like aliens elsewhere after the evacuation. The presumption is that cancer develops much slower in the body of people of age while the mutations are much faster and lethal in young body. Still in the exclusion zone there is a ban for young people and pregnant women to live. This should remain for ages and centuries ahead. I was surprised to encounter many Ukrainians who suffered the consequences and lost dear people and still believe there is no alternative to the nuclear energy.
We saw the deserted town of Pripyat and the Chernobyl NPP which seems like it will never be put under control. Our guides tried to ensure us how the nature turned wild and vivid, and the wild animals took over this humanless kingdom. Behind this story we encountered mutated plants and a fox in Pripyat that suffered some unknown disease which was likely also a mutation.
The very next day after our visit and the 29th anniversary of the tragedy coincided with an Orthodox feast dedicated to the dead people. The entry to the exclusion zone was easier and fires were set by someone in the dry fields around the plant. It all started close to a graveyard. It was obviously not an accident because the fires started from more than three locations. We stood in Kiev with our radiation counters in hand to prevent the massive panic that was rising. Not that there was no reason for worry – radioactive isotopes spread in the air with every forest fire after the explosion and keep the ghost of the radioactive danger alive and taking new victims. I could not believe someone would dare to set fire in the fields. This madness could have had many reasons – even the fact that Ukraine was (and is) in war with Russia.
I felt pity for this wonderful country and the wonderful people that live there. As a Bulgarian I feel quite close with the Ukrainians and their struggles. The country has all the potential for clean energy development but the centralised and oligarchic way of governance, combined with the heavy heritage of the communism and the constant interference from Kremlin to keep the country in dependence of the Russian energy resources is spoiling every attempt for a different future.
When I was back from my visit to Chernobyl I was feeling depressed for weeks and my immune system was down in a very unusual way. I was a bit ill – like minor flue, but this state continued for a few weeks. Usually when I suffer some sickness it passes away very quickly. I have no idea whether this was due to the emotional charge I got from the visit or maybe even the levels of radiation we experienced.
I offer to everyone interested to see the album with info in English and in my facebook profile – it is public for review and consists of the highlights from this tour. One album that I cannot wish to the people that will review „Enjoy watching“.
Todor Todorov („Za Zemiata“/Friends of the Earth-Bulgaria)
Screening of a film about Chernobyl and Ukraine’s Nuclear Reactors
On 15th October 2015 at “Klub na pateshestvenika”, we from Environmental Association “Za Zemiata” arranged a screening of the film “The End” about the nuclear reactors in Ukraine. The film belongs to CEE Bankwatch – an international network of NGOs. “Za Zemiata” has been a member of the network for more than 10 years now. One of the important issues addressed in the film is the danger of life-span extension of nuclear reactors in Ukraine.
The war in Ukraine is happening perilously close to the nuclear reactors. The country has 15 aging reactors dating back to the Soviet era. 12 reactors will have reached the end of their life by 2020. In a country torn by corruption, the reactors’ lives have been extended using EU funding regardless of any safety measures, international conventions, or national laws. Ukraine should consult with its neighbours prior to extending the reactors’ life. Instead, the country is attempting to circumvent all laws regulating nuclear energy.
The audience showed notable interest in the shots taken at Chernobyl in late April of this year. The group of activists who visited Chernobyl, also included Genady Kondarev, a representative of “Za Zemiata”.
Following the film screening we held an audience discussion on the topic of life-span extension of nuclear reactors – a dilemma we are also facing in Bulgaria with Units 5 & 6 of NPP “Kozloduy”.
Todor Todorov from “Za Zemiata” spoke about the hazards associated with extending the life of the old Kozloduy reactors, as well as about the economic inexpediency of such solution. Energy generation in Bulgaria has for years been exceeding the demand by 40% in combination with the export market increasingly shrinking.
There was also an interesting discussion about the stopped construction of the nuclear fuel production plant in the Ukraine. Its construction started in 2012 in cooperation with the Russian company TVEL. Such a plant cannot sell its output due to the refusal of an ever growing number of countries to develop nuclear energy.
What caused the biggest interest was Genady Kondarev’s first-hand account of the group’s visit to Chernobyl and the film scenes with actual readings of dosimeters at various hot spots within the area of the 1986 nuclear disaster.
The members of the audience were very impressed by the film and got actively involved in the discussion on the topic of the future of nuclear energy in Bulgaria and Europe.
September 2015, Todor Todorov
Overview of the progress of planned construction of new nuclear reactors in Bulgaria in Belene and Kozloduy 7
The project for construction of a new nuclear power plant in Belene was planned to be built by Russian Atomstroyexport and work with Russian VVER reactors.
Since October 2014 Bulgaria is ruled by a right-wing coalition government. The main coalition parties initiated the termination of the Belene NPP project in March 2012, during their previous term in government. The same parties initiated the replacement of the Belene nuclear power plant (NPP) project with the idea for construction of a new reactor at the Kozloduy NPP site.
One of the smaller parties (left-wing ABV) that supports the government still continues to push for the Belene NPP project to be resumed.
The losses for Bulgaria caused by the pro-Russian nuclear lobby which drained the state under the false pretense of building a new nuclear power plant in Belene now amount to more than 1 billion euro. The money were drained through consultants‘ contracts, research reports and analyses, as well as the procurement of unnecessary facilities in the period 2003-2012. For this period the official costs for the construction of the plant rose from US$ 4 billion to US$ 10 billion.
Za Zemiata asked the Ministry of Finance, in accordance with the Law on access to public information, to provide information about how much state budget money had been spent on the Belene NPP project since the moment of its official termination (March 2012) to date. As the requested information has not been released by the Ministry, Za Zemiata filed a case against the Ministry for implied refusal of information, which is to be ruled by 5th October 2015 by the Administrative Court.
The Kozloduy 7 project gained currency in 2013 when, after a surprise visit to the US, the then-energy minister Stoynev said he had „selected“ a Westinghouse reactor for new nuclear unit. A preliminary agreement with the company was signed, subject to confirmation by the next Bulgarian government.
The project for construction of a new US reactor on the Kozloduy site was planned to be executed by Westinghouse. According to the company selected, the cost of construction of the new reactor would be US$ 7 billion. The current government supports the construction of Kozloduy 7, but due to the financial and economic crisis in the country, is unable to finance this project. An investor is being sought who would put „fresh“ money in the project, without imposing costs on the state budget. The proposal made to Westinghouse in April 2015 was to participate as an investor in the construction, for which it would get 49% of the plant.
Westinghouse refused this proposal because the company is a manufacturer of equipment and not an investor in nuclear power plants. Quite apart from this, is the fact that if a manufacturer of equipment should become also the investor, it would come into obvious conflict of interest. Westinghouse’s refusal is the reason for the plans to build a new reactor Kozloduy 7 to be shelved until an external investor is identified.
So far no expert economic analyses have been published in Bulgaria that prove the necessity of building a new nuclear power plant. In this way, Bulgarian governments for many years have been trying to take political decisions dictated by the nuclear lobby.
14.09.2015, Todor Todorov („Za Zemiata“/Friends of the Earth-Bulgaria)
Prospects to the energy market in Bulgaria
1. Currently in Bulgaria there is a regulated energy market for electricity and natural gas. This regulated market has all the negatives of the past (including the “transition” period) – politically managed, very corrupted, dependent on external global players, relying on the old “classical” energy sector and hostile towards efficiency and clear energy technologies, economically ineffective and thus – not transparent for its clients, on the edge of de-capitalization and collapse. Due to all its negatives the “market” itself is more a mix of command-administrative and quasi-market relationship than real, free, honest and mutually helpful market relationships.
2. The sensitivity of the external non-market (political and geopolitical) signals and factors makes the sector unpredictable and any measurable prediction – problematic. This requires the review of many dependent on different factors hypotheses and alternatives for the future which makes the selection of the most realistic of all them almost impossible. Only a strong government could take the risk to create and follow an adequate strategy based on modern trends, consistent with the national abilities, the protection of the environment and measuring the goals related to climate change.
3. The development of the electricity market in Bulgaria is objectively unpredictable at this moment as far as it is on the verge of liberalization for which it is not ready. The system is de-capitalized and on the brink of a collapse, command methods are applied, including the government commanding the “independent” regulator to decrease the prices for populist reasons. Numerous alternative scenarios are possible as the most likely one includes the creation of a broader quasi-market where the smallest consumers will stay for the time being on regulated (“social”) prices. There will be a hidden and obvious obstruction to the massive implementation of RES and “smart grid” technologies which will be supported by the slower economical recovery. Efforts will be put towards keeping the status quo but in the form of “market support”. Eventually the prices will rise in order to keep the system without having to make any radical changes. There are two main issues with this:
• Once let loose it is difficult to keep the market in some quasi-market scheme especially if the closer regional integration is further developed;
• The game of “changes without changes” hides a risk of collapsing the system which will have a catastrophic consequence but could serve as the necessary “turning point” for an overall and radical reform of the sector.
4. The gas sector hides many unknowns which hinder the forecast whether and when it is possible to have a real market in the sector. First, it is the pressure from Russia for the construction of “South Stream” and monopoly control over the gas deliveries and prices not only in Bulgaria but also in southeast Europe. The construction of interconnectors and connections with gas transition systems of neighboring counties is problematic as well as the delivery of gas from other sources using the same infrastructure. Second, it is the question of increase of the share of household gasification and co-generation using gas – the two main factors for the development of the gas sector. Third, there are the unknowns surrounding the research for oil and gas in the Black sea. Fourth, it is the question about the duration of the moratorium banning the development of shale gas in Bulgaria. Lastly, it is the question for the development of biogas generation which has the potential to become an important source in some agricultural regions in the country. The future of these questions will determine the development of the gas sector including the creation or not of a gas market.
5. Considering all trends, we can conclude with a high level of confidence that in Bulgaria it is not expected to have a real functioning gas and electricity market in the next 5 – 10 years unless some significant changes in the political government of the country happen.