In the following we want to share the impressions of Lavinia Andrei of Romanian NGO Terra Mileniul III on the transparency of the stress tests in Romania (status: June 2014)
““The Romanian authorities are presenting in a very optimistique manner the results of the stress tests for Cernavoda NPP. All their communications for the large public are presenting only the positive aspects. Even the negative observations from the European Comission are translated into a positive language. For example, concerning the topic of seismic risk which the Commission is considering a critical issue, the authorities’ communication to the public was positive, saying that Cernavoda NPP will resist an earthquaqe of 7.8 degrees on Richter scale.
When the nuclear autorities are approached with specific and punctual questions, well targeted on the topic, ussualy they are not answering, or answering with a long delay and pretty vague."
Lavinia Andrei, Terra Mileniul III, on their activities concerning stress tests:
"The chapter of the JP brochure concerning Stress Tests regarding Romanian stress tests was translated into Romanian language and posted on the internet, on our webpage http://terramileniultrei.ro/wp-content/uploads/2013/05/Teste-Stres_Romania_traducere-studiu-grassroots.pdf
In July 2013 the report on stress tests was disseminated via Facebook and Twitter.
In October 2013, we have submitted a letter to CNCAN, Cernavoda NPP and Ministry of Economy and Energy Department, presenting the Romanian analysis on the stress tests done under the JP. There was not any feedback to our letter.
In March 2014, we sent a letter for public information to CNCAN asking for information (under the Law 544/2001 – regarding access to public information) about the stage of the action presented in the 6th edition of the National Report on the Convention of Nuclear Safety, with deadline by the end of 2013. It was the first time when we received a very quick answer (only 2 weeks), pointing out that all the actions were implemented in time.
In June 2014, when we found out from media reports that the Romanian minister for energy took the leadership of the EU nuclear group of countries we wrote a letter to the minister sharing our concerns regarding his policy for promoting nuclear industry instead of promoting energy efficiency and renewable energy. We attached the outputs of the Joint Projects concerning our documentations about stress test and life cycle analyses.
The letter was posted on our webpage and also on the FB
The critical review on the stress tests (output of the last Joint Project, see download section "Stress Tests & Vulnerability Assessment - Recommendations and Experience of the Joint Project group") has been partly translated into Romanian.
The study got big media attention - e.g. Ioana Ciuta talked about the results on Romanian national television on Tschernobyl anniversary day.
Ioana Ciuta summarizes their activities concerning stress tests as follows (status: June 2013):
"In October 2012, when the final reports were out by the Commission, we issued a press release as well,
We pointed out some of the problems not tackled by the reports and pointed out that CNCAN is avoiding important answers. On the same day, the regulator CNCAN representatives gave an exclusive and interview to the online magazine “Hotnews” reassuring about the safety of the CANDU reactors in Romania.
Soon after this, still in October 2012, we sent an email to CNCAN with four very specific questions related to the recommendations in the peer review and how they plan to proceed handling them. These questions were:
“what are the measures that you will take regarding severe accidents, margins for cliff-edge effects, a comparable seismic system to report to and the radiological situation in primary ands secondary control rooms”.
All these have been questioned in the conclusions of the peer review report, and CNCAN long passed the 30-day legal time to answer these questions. We have re-sent them again in December 2012, pointing out that they have breached the law on access to public information. We have also made it very clear again that we are always open for discussion, and that we request solid and realistic information sessions, not only media briefings to 4-5 accredited journalists.
In Feb. 2013 we received the answer from CNCAN. The regulator clearly makes no effort to communicate openly with us. It took them over 2 months to provide answers to 5 simple questions. Their attitude shows nothing but lack of interest for public concerns. They will rather get stuck in the technical details and procedural weaknesses of the Stress Tests process in general, than address issues that could possibly pose a real threat to Romanian population”
In October 2012 Terra Mileniul II asked the following question:
What are the measures that you will take
The following text is a translation of the answer CNCAN sent in early Feb. 2013:
"Improvement measures mentioned represent actions already implemented or ongoing, actions that were indentified by the owner and operator of the power plant (SN Nuclearelectrica) and CNCAN early as 2011. We have to mention that the situation on the improvement actions was presented in March, 2012, and since we recorded a substantial progress.
The European Commission report mentions five main recommendations for Romania.
1. “The absence of a seismic level comparable to the SL-1 of IAEA leading to plant shutdown and inspection is regarded a critical issue at the background that the probability of large earthquakes occurring during the lifetime of the plant is extremely high (recurrence intervals for the Vrancea seismic zone: 50y for Mw>7.4). It is suggested to the regulator to consider implementing adequate regulations.”
In practice, the event of an earthquake will cause such vibrations to some equipment (e.g. the turbine) that the power plant will automatically shut down. Although this recommendation is not mandatory, CNCAN evaluates the necessity of current procedures modification.
2. “There is only little information about cliff edge margins, weak point and no evidences that further improvements in the seismic upgrading have been considered. Further work is proposed in this area and it is recommended that the CNCAN obtains good quality programs from the licensees and ensures that the work is appropriately followed up.”
The safety margins for CNE Cernavodă are well known, but the quantification hasn’t been fully done. Clarifications are required, because no assessment methodology was supplied by the European Commission and this is why fourteen out of seventeen countries (including Romania) have not delivered that kind of data, although solid proof has been brought that safety margins do exist. CNCAN made sure that the evaluations for risks due to seismic events has been done with high international standards and international and national experts.
Nevertheless, in the national report of Romania, the assessment methodology used and the results have been presented and the conclusions show that the safety margins are confirmed for CNE Cernavodă. Also the report pinpoints the dominant seismogenic area, Vrancea.
Following the tests for the maximum estimated earthquake (which has a frequency of occurrence of one for every one thousand years), no weak points in the nuclear security of the plant have been discovered, even for earthquakes which exceed eight degrees on Richter scale.
Therefore, the misunderstandings in interpretation of technical detail were generated by the fact that the specifications of the European Commission did not ask for the values at which the nuclear security functions are lost.
Regarding the recommendation of the European Commission for project evaluation at earthquakes with frequencies less that one every 10000 years, this was a main points for stress tests and there were no problems found. CNCAN considers this recommendation closed.
3. “It is suggested to consider improving the volumetric protection of the buildings containing safety related equipment located in rooms below plant platform level. It is also suggested to the regulator to consider routine inspections to the flood protection design features.”
This recommendation regards the protection against foods. Regarding this the safety margins for CNE Cernavodă are sufficient to prevent a cliff-edge event and no weak points have been found during the tests. An event leading to the lost of nuclear security functions due to floods is regarded as unlikely.Also CNE Cernavodă implemented additional improvement measures, and CNCAN has reviewed its inspection plans to cover all the important structures.
4. “The habitability of the MCR and SCA was assessed for various types of accident, but not in the case of total core melt accident associated to a containment failure (or voluntary venting). MCR habitability analysis to be continued (e.g. implementation of a close ventilation circuit with oxygen supply)”
This recommendation is planned for implementation.
5. “Further SAM study is required for shutdown states.”
The implementation of management guides for severe accidents in the moment in which the plant is stopped is planned. Also, for CANDU types of plant, the management guides in cases of severe accidents in operational state are also applicable for the situations in which the plant is stopped."
Letter to CNCAN: October 2012
In October 2012, right after the peer review, Terra sent an email request in October 2012 to CNCAN with a question regarding four specific topics related to the recommendations in the peer review and how they plan to proceed handling them. The question was:
Delay in reply
All these have been questioned in the conclusions of the peer review report, and CNCAN has long passed the 30-day legal time to answer these questions. We have re-sent them again last week, pointing out that they have breached the law on access to public information. We have also made it very clear again that we are always open for discussion, and that we request solid and realistic information sessions, not only media briefings to 4-5 accredited journalists.
Answer: Dec. 12, 2012
CNCAN finally answered after the last email of Terra, in which the NGO re-sent the same questions and pointed out that the legal 30 days deadline had passed. They sent a relatively long answer the 4 questions on Dec. 12, 2012.
In December 2011 Tera Mileniul II sent another set of questions (see section "Public Participation in Stress Tests"). As they did not get any answer right away the NGO asked again in January 2012, the Regulatos´s office replied that the questions asked were answered in the Final Stress Test Reports which wre out by that time.
Romanian NGO Terra Mileniul II sent the following questions concerning Stress Tests to the romanian Nuclear regulatory authority in June 2011:
Romania NGO Terra Mileniul only got the answer to the questions after threatening with a law-suit.
Romanian nuclear regulator CNCAN gave a short reply stating:
The Romanian EU stress test national progress report and final report on the are available under:
http://www.ensreg.eu/documents - reports
The comments of the Romanian NGO Terra Mileniul III (member of the Joint Project) from Oct. 2011 are available here (pdf, 84 KB).