Jan Haverkamp est un expert en politique nucléaire pour l’ONG environnementale Greenpeace. Il s’est confié à Lenka Ferenkova d’EurActiv Slovaquie.
If you compare the national nuclear stress test reports, which of them do you consider as the most complex one? And where did you find the highest amount of flaws?
There is no doubt about which was the most complex one. It was the French one. They have the highest number of reactors and they also assessed safety of all the nuclear installations. So in total they carried out tests on 76 nuclear installations and each report had around 400 pages.
Interestingly, even before the regulator – ASN – finished its final report, they had meetings with local information committees which consist of NGOs, ordinary citizens, mainly people not directly linked to the nuclear power stations. These committees form a kind of link between the common population, the power station, the nuclear regulator, nuclear experts and researchers. The committee members went through materials about their local power station, their comments were brought to the French regulator and were also reflected in the final report.
So from all the reports, the French regulator had the most thorough communication.
They basically came with a very large list of changes that need to be implemented whatever the outcome of the stress tests will be. The stress tests are only halfway done. The peer reviews are only starting. But no matter how the stress tests end up, the French have already discovered issues that will have to be addressed.
French authorities said they would tell the operator of nuclear installations to implement safety measures identified in the stress tests. They were also very clear when journalists asked what would happen if the required changes were too expensive. ASN president Andre Lacoste replied simply: if they do not want to invest, they can always close the power station.
That shows you a little difference between the independence of ASN and regulators in Slovakia, Hungary, the UK, Sweden, Bulgaria or in Czech Republic.
What about the other country reports?
First, I have to add that the French exercise was not perfect. As one example among many, the nuclear power station near the borders with Luxembourg and Germany – Cattenom. Luxembourg and Saarland, in this case, have assessed the report of Cattenom and still found a lot of problems that need to be addressed.
What I also found impressive was how the Finnish regulator dealt with the whole stress tests. The French said 'OK, no power station needs to be closed down immediately'. But they did not say 'all our power stations are safe'. The Finnish were even more careful. They only gave the outcome on individual issues, said which ones needed more attention or required more time to resolve. They did not claim anything about passing or not passing the tests. I appreciate their clear communication. All the other regulators in the beginning of January said: 'Our power stations have passed the tests'.
And that is a very fundamental mistake at the moment when you are still before peer reviews. If the peer review teams are critical now, they undermine the credibility of the national regulators.
How do you evaluate the stress tests report of Slovakia?
The Slovak report was not the worst. From what I have read, the Czech one was the worst. It was almost unreadable. They used Czech abbreviations in the English text. They also used different methodologies for Dukovany and Temelín.
The Slovak report was definitely better than that. It was well readable and the final one was better than the intermediate report. The Nuclear Regulatory Authority (UJD SR) deserves credit for the readability but that does not say anything about the quality of nuclear safety in Slovakia.
I would place Slovakia roughly in the middle group of countries that participate in the stress tests. Most of them have only done the minimum, which is also what Slovakia did. They did not go beyond the minimum interpretation of the ENSREG declaration and recommendations. For instance they did not look into airplane crashes, into forest fires or properly into heavy snow situation.
For the Czech plant of Dukovany, the stress test report pointed out that the roof of the main engineering works room would not be able to withstand a large snowfall – the kind that can happen once in a hundred years. That time span is actually quite short. The Czech and Slovak authorities really did only the minimum and there are many holes left.
The impression I get is that it is really difficult for them to think the unthinkable. In the case of France, if somebody came with an idea – from any NGO, academia or from the power sector – they tried to follow it up. They realised that if somebody can imagine such a situation, maybe they should look into it.
Here, Greenpeace pointed out that certain things were missing. After our review of the Slovak progress report in September, we got six pages of defensive language why everything we suggested was rubbish. So you see a clear attitude difference. Some regulators, such as the French, the Finns, and to a certain extent also the Belgians, are capable of looking into things.
With regard to Belgium, their problem is that the director of the regulatory authority is the former director of one of the two nuclear power stations in the country. Also, the Doel nuclear power station is situated only 10 kilometres from the centre of Antwerp and 3.5 million people live within the area of 60 kilometres.
What do you think about the reaction of the Slovak nuclear safety regulator (UJD) to your analysis of the final stress test reports?
(Smiles) UJD reacted to our press conference again in a defensive mode. It said that it carried out the stress tests objectively and transparently, and that is exactly what we have said in our analysis: UJD was quite transparent in comparison with others, though there is still room for improvement. For instance, it does not make sense to organise a discussion meeting after you have finished your final report. What influence can such a discussion still have? Nothing.
Within what they could imagine, they were also more objective – for instance in comparison with the Czech SUJB. The problem is that they did not do everything that was in their competence. It is really a pity they have problems thinking out of the box and then confirm that in their official reaction.
What we need for nuclear safety is a fully independent, critical nuclear watchdog – not only a yelping industry lap-dog. In France, nuclear regulator ASN is in sometimes hard, but almost always constructive dialogue with NGOs like Greenpeace, and if necessary bites at EdF. ASN has recognised the fact that only a pack of watchdogs (the regulator, NGOs and local information committees) can keep the economic and political interests endangering nuclear safety in check.
Is it possible to make some assessment chart of the countries involved in the stress tests?
That would be a tricky thing to do. To compare the Slovak report and attitude with the rest of Europe, I would say it was better than in the case of Bulgaria, Romania or Britain, where the regulator did not report everything and where a lot of information was missing. The Swedes were also quite defensive. I would place Slovakia on par with Hungary or Slovenia.
Slovenia was actually quite open about their reports. But I have to add that they only have one reactor. Also the chairperson of ENSREG is from Slovenia so they tried to be a kind of model. However, they also did not look into airplane crashes or other issues, so they could do better.
In conclusion I would say that even if nuclear installations fulfil criteria that are set in the law, it is not equal to say they are safe. The law is not all-encompassing. It is formed gradually and in a political environment.
Do you see any added value of the EU stress tests?
There are a few important things. First, these stress tests have been a lot more transparent than the regular safety reviews. The second win is the peer review phase.
Until now the nuclear safety evaluation was something that was done occasionally in a closed circle of local regulators or by commissions coming from the WENRA or the IAEA looking at the general work.
What we have here is a peer review of very concrete work – people are not just asking general questions. The parties involved also went outside the limits of the normal PSAs – the probabilistic safety assessments. With the stress tests you look at various scenarios, no matter what chance there is that they actually materialise.
The stress tests are very important because they also introduce multi-unit failure scenarios. We do not see this evaluation properly in the Slovak report even though it is very clearly described in ENSREG recommendations. What happens if both Mochovce units are hit by the same phenomenon, an earthquake for instance? What if you have serious troubles in both reactors? Do we have sufficient people or material there? Can we keep everything cool?
That is the first win of the stress tests. We are forced to think of similar situations that made Fukushima so unsolvable. For example, when they were dragging one mobile diesel generator from block 1 to block 3, block 1 was getting so much out of hand that they had to bring back the generator and start pumping there again. In the beginning they only had one diesel generator at their disposal. You have to start thinking in multiple emergency situations.
Do you see any features that are missing in the stress tests?
There are a few very big shortcomings. At the moment there are two tracks. The reports are looking at limited technical issues. Then there is another track that looks at security issues such as acts of terrorism, cyber-attacks, sabotages, acts of war, and thefts of fissile materials. This track is followed by the Ad Hoc Group on Nuclear Safety set up by the European Council. They work in complete secrecy, because they are afraid that the information could bring terrorists on an idea. We agree that it is a correct assumption.
On the other hand, they will have to communicate their conclusions to the public. In December, they prepared a report and my impression is that they may have been looking at theft of radioactive material such as uranium or plutonium. That is what the security people always do – they look at theft prevention. But I feel they haven't looked that much into terrorist attacks and I think that is a real problem.
For instance the German regulator a few weeks ago issued an order for strengthening the security at all nuclear facilities, because they had new information on potential terrorist threats. When Germany was taking its decision on the closure of eight nuclear power stations last year, one of the important arguments was that their protection against terrorist attack was very low. There are reasons for taking terrorist attack as an important issue for nuclear power stations. I am very concerned that this security group is not looking at the real issues. But let's wait until their final report.
A strong criticism is that the emergency response is not included in the stress tests…
Exactly. I already mentioned the Doel power station near Antwerp. If something goes wrong, how do you evacuate all the people in 24 hours? Maybe the politicians should rethink whether the risk is not too big.
In Fukushima we have seen that the off-site emergency response – evacuation, exposure to radiation, information and compensations for evacuation and relocation costs for the public – was a complete nightmare. Evacuation zones were gradually expanded, communication about what is considered as acceptable level of exposure of radiation was chaotic. It delivered a lot of psychological, physical and economical stress.
However, nuclear regulators themselves have no mandate about off-site emergency response. The issue is dealt with by the interior ministry, fire brigades, police, army and other emergency authorities. This is a big black hole.
One of the ideas that Greenpeace has put forward is to have a third track for the stress tests, which could start this spring or summer. A special group under the Council should be looking if we are prepared well enough for emergency response. If not, what kind of conclusions are we going to draw from that? Is it possible to improve the emergency response system? If not and the nuclear power station is for example 10 kilometres from Trnava, maybe we should think about not extending the lifetime of the power station. Those are political decisions, but we cannot take them now, because we do not have the data.
Do you believe this 'third track' might actually happen?
I think there's a very good chance. On 17 January there was a public meeting with European nuclear regulators in Brussels. I was the only NGO speaker there and I brought this forward. All regulators agreed that it is an important issue and that something has to be done. The Commission did not want to do another stress test and we are not asking for them to do that since the DG structure and competences are so complicated.
Therefore we consider it as a question for the Council, with the different ministers involved in a working group. Our idea has been taken up by Luxembourg, Denmark and Austria. I suppose Germany also will support it because they have already been doing that themselves and I also call on the Slovak government to support that idea.
There is a strong non-official NGO coalition behind our idea, including Friends of the Earth who also have a large network. This black hole remaining even after the final report of stress tests in June will undermine the credibility of the stress tests as such. And that will be a pity.
A British group of energy experts called EnergyFair recently submitted a complaint about nuclear subsidies to the European Commission, asking for them to be removed on the grounds that they create unfair competition for renewables. How do you assess their move and chances of success?
I know these people very well. We worked with them in the early stage of preparing the complaint and analyses on what is and what is not a subsidy. The group is a lot broader than just an NGO, it is now largely people from academia and independent experts. I don’t think that all their issues will get through the Commission but several have a really good chance.
The problem is that illegal state aid is only defined as such if it is concretely given – if money has been transferred, not if they are only policy proposals or even already laws in the UK. The money has not been flowing yet.
Another complaint we have been running is against Romania where the government decided to give a credit guarantee, support from the state infrastructure budget, and also budget payment for heavy water for the Cernavoda nuclear power station.
The reply from Brussels was that the money had not flown yet. Then the Romanians stepped backed explaining it was just an idea. However, there is an official government decree. A few weeks ago, they spent the payments for heavy water. Therefore now we prepared another letter to the Commission reminding them about this case. I think that will lead to an infringement procedure.
Something similar might happen also in the UK case. It is very important also for the investors to keep in mind whether you indeed can build a nuclear power station without relying on government subsides, direct or indirect.
Here in Slovakia we don’t have this problem now. Slovenské elektrárne or ENEL is financing the construction of Mochovce 3 and 4 itself. However, there is one complaint still running that the Commission is still investigating. It concerns the lower payments for radioactive waste and decommissioning funds. This complaint lies at the Commission already for four years.
Last year the EC demanded more information from Slovakia on the exact tariff and Slovakia had to adapt their tariff last year on the amount of money per KW/h. So the Commission is still following it. If Slovakia doest not bring the amount paid to the fund up to reasonable and credible level, it might be seen as illegal state subsidy. The same goes for its decision not to take dividends from SE – where the government now is in budget shortage, a normal market company would not forgo these dividends. If Slovakia still continues to do so, also that might suddenly be considered illegal state aid.