Stress tests

Public participation in stress tests

It will be crucial that the public stays involved and closely follows the process, because the stress tests are voluntary and the extent and depth of testing will be determined by national regulators. Some of the regulators already made clear that they do not expect to go much further than their routine testing. The first one to state that was the ENSREG chairman Mr. Stritar who pointed out the regulators are continuously testing and improving nuclear safety in their countries, also the Czech regulator does not see much news, only admitted that the issue of flooding might have changed since the plants were designed and sited due to climate change.

(Text by Patricia Lorenz/FoEE/Global 2000)

Concerning public participation ENSREG gives the following recommendations:

• At the national level, regulators should consider how to engage the public by organizing a comprehensive information process.
• At the European level, stakeholders will be provided with the opportunity to engage in the stress tests.
• An online consultation of the EC about on Public Feedback on the EU stress tests was available under: http://pfeust.jrc.ec.europa.eu/public-feedback. The consultation was open from January 1 to 20,2012.

Seminars on national reports shall be organized by national regulators. On request, they shall be attended, by a representative of the Board of the Peer Review Process.

Stress tests within the Joint Project 2011/2012

Within the Joint Project the progress on the stress tests is followed closely.

June 2011

In this context in June 2011 several questions have been asked to the nuclear regulators of Bulgaria, Czech Republic, Slovakia and Romania:

1. Which new scenarios which were excluded until now but after Fukushima proved to be realistic, do you ask the operator to assess? Please give us data on the new demands concerning natural disasters (flooding, extreme cold, extreme heat, snow, ice, storms, tornados, heavy rain and other extreme natural conditions.
2. Aircraft crash: Will you demand a deterministic assessment of an aircraft crash? Which criteria will the plant have to prove to withstand?
3. Will the seismic design basis be re-evaluated, which we consider crucial?
4. How long is the plant able to control shut-down and cooling of the reactor and the spent fuel storage pool without external support if ultimate heat sink and power supply are not available due to external impact?
5. Which are the responsible authorities in our country to take care of the part “terrorist attacks”?
6. How will the public be informed about the conduct and the outcome of the tests?
7. Will there be a seminar/workshop for NGO and independent experts while the stress tests are being conducted, e.g. in late August or September to discuss the results?

December 2011

The following letter was sent to the EU Council and (in adapted form) to the national regulators of the Joint Project countries.

Appeal to Heads of States and nuclear regulators on stress tests, on the occasion of the EU Council December 9th 2011
"At this summit, the EU Commission will present a progress report on nuclear power plant (NPP) stress tests, which were initiated in response to the Fukushima nuclear disaster.

We are a group of environmental NGOs based in Central and Eastern Europe who have been following developments in the nuclear field, both in our countries and on a European level. We have been in contact with national nuclear regulators since the beginning of the implementation of stress testing in June 2011, and have received unsatisfactory answers to our questions.

We are very worried about the status of the stress tests. The promise of strict safety assessments in the aftermath of the Japanese accident seems to have faded into a business as usual safety assessment exercise. Instead, a clear end to nuclear safety regime with “unthinkable” scenarios, probabilistic assessment and high in-transparency is inevitable.

Having read the interim reports submitted by EU member states, we would like to point out that:

• Most countries are not able to handle a major accident in one of their NPPs. Necessary measures for emergency preparedness are not in place. This question has to be discussed, clear plans need to be prepared by each country, and must be discussed with the public.
• It is not enough to announce, as the Commission interim report does, that there will be international cooperation. Countries with nuclear plants in operation need to be able to protect their own and neighbouring countries´ citizens.
• The stress tests cannot be seen as the final say on safety; important issues like ageing NPPs and aeroplane crashes are not taken into account.
• The regulators in most countries see themselves as promoters and defenders of nuclear energy, an attitude which seriously endangers safety. Fukushima is just one of many examples.

Based on what we consider very urgent matters to be tackled with regards to the progress of stress tests, we hereby demand:

• Full transparency: we ask member states to open their nuclear safety regulation to public scrutiny – both the stress test results and more generally – in order to prevent catastrophes like the one in Japan in March 2011.
• Establish full transparency of nuclear regulators.
• The highest standards must be applied in the tests. It is not enough to assess that safety margins are “differing” across Europe. Highest standards also need to be applied for the methods, for example on earthquake return periods. The highest standards need to be demanded right away for all reactors in operation in the EU and not, as the Commission report suggests, “best practices for new nuclear power plants to be built in the EU”. We are against any new nuclear plants in the EU, because we consider the risks are too high.
• The new safety legislation should not only be discussed with “national regulators, nuclear regulators and …ETSON” who have been responsible for nuclear safety over the past decades, but should also include independent experts, NGOs and civil society. The same approach needs to be adopted when improving nuclear safety governance, to ensure it is taken seriously.
• Open discussions and workshops for interested public at national and international levels on stress tests.

We ask you to clearly implement far more stringent methods for testing nuclear safety, with clear sanctions
for non-fulfilment. It is not acceptable to postpone measures which we all know to be necessary today. The parallels with the Japanese regulatory failure to take warnings concerning tsunami and seismic risks seriously are highly concerning.

Finally, we do not view the stress testing as a means of proving that EU nuclear plants are safe, but rather to assess their relative risks and decide which ones need to go offline first and which later.. None of this negates the fact that nuclear power is not safe and not sustainable. However, whilst nuclear power plants continue to operate they must be held to the highest safety standards.

Yours sincerely,

Patricia Lorenz

Friends of the Earth Europe
Rue d'Edimbourg 26, B-1050 Brussels
patricia.lorenz@foeeurope.org

Foundation for Environment and Agriculture, Mr. Borislav Sandov
2 Vassil Levski str., 5940 Nikopol, Bulgaria
agroecofund@mail.bg

Za Zemiata, Mr. Todor Todorov
Yanko Sakazov Bul 50, fl. 3, ap. 17, Sofia, Bulgaria
t.todorov@zazemiata.org

South Bohemian Mothers, Mrs. Monika Wittingerová
Nová 12, 370 01 České Budějovice
monika.wittingerova@centrum.cz

Calla, Edvard Sequens
Fráni Šrámka 35, 370 01 České Budějovice
edvard.sequens@calla.cz

Energy Club, Mr. András Perger
Szerb Utca 17 – 19, 1146 Budapest, Hungary
Fax: +36-1-411 35153
perger@energiaklub.hu

Terra Mileniul III, Ms. Ioana Ciuta
7 Armand Calinescu street, 5th floor, app. 20, sector 2, 021011, Bucharest
ioana.ciuta@terraiii.ngo.ro

Global 2000, Mr. Reinhard Uhrig
Neustiftg. 36, 1070 Vienna, Austria
reinhard.uhrig@global2000.at"