BULGARIAN INDUSTRY STATEMENT
A review of the plans to close down the Kozloduy NPP VVER Units 3&4
by the end of 2006
In line with the 1992 G7 Munich Council approach to the then safety
of VVER nuclear power plants1 and in context of
the accession negotiations between EU and Bulgaria, it was agreed to
close down four out of six units of the Kozloduy Nuclear Power Plant
(KNNP). Two units of an older design have already been closed down
in 2002 and Units 3&4 of more recent design are to be closed by the
end of 2006. Since the closure decision was taken, relevant changes
occurred at the Kozloduy NPP. These changes combined with the fact
that overall energy and climate situation has evolved considerably,
highlight how the originally agreed closure dates can no longer be
justified from either a technical or economic perspective.
1. With regard to safety requirements at the KNPP Units 3&4, the
latest International Atomic Energy Agency (IAEA) Report2
of the expert mission to review the results of safety upgrading
activities, from June 2002 concluded that “the plant operational
safety is a priority for the KNPP management and that in the process
of its improvement the plant has reached the level that corresponds
to the level of plants of the same vintage worldwide”. “Regarding
Units 3 and 4 (…), the main safety functions were improved to the
level or in some cases beyond the level, which meets the IAEA
initial recommendations”.
2. In June 2003, a World Association of Nuclear Operators (WANO)
Peer Review3 was conducted at Units 3&4. The final
report, which was officially submitted in September 2003, stated
that during the last decade KNPP has carried out impressive upgrades
of both its processes and work practices. The expert team announced
that the plant has competent and capable personnel providing its
safe and reliable operation. According to WANO’s performance
indicators, Kozloduy 3&4 now rank among the best half of plants
worldwide.
3. According to the procedure for monitoring candidate countries’
commitments regarding the recommendations contained in the “Report
on Nuclear Safety in the Context of Enlargement” the EU Council’s
Atomic Questions Group/Working Party on Nuclear Safety conducted a
"Peer Review" mission to Bulgaria on 16-19 November 2003. After the
peer review process, the expert group stated that
1 Communiqué: Economic
Declaration : Working Together for Growth and Safer World, Safety of
Nuclear
Power Plants in the New Independent States of the Former Soviet
Union and in Central and Eastern Europe;
G7 Summit: Munich, July 6-8, 1992.
2 Report of the Expert Mission to Review the Results of
Safety Upgrading Activities of the Kozloduy
Nuclear Power Plant Units 3&4; Bulgaria, 22-28 June 2002; IAEA.
3 World Association of Nuclear Operators Peer Review at
Kozloduy Units 3&4, June 2003.
“There was evidence that all the AQG recommendations have been
addressed adequately”4. The expert group added
that it does “not consider further monitoring activities to be
necessary on the recommendations of the AQG/WPNS”.
4. Based on the new safety status of Units 3&4, and bearing in mind
the requirements of the Law for the Safe Use of Nuclear Energy, the
Bulgarian Nuclear Regulatory Agency issued new operational licenses
for these units – until 2011 and 2013 respectively.
5. On a request of the Bulgarian Ministry of Energy, the IAEA has
prepared a study on the energy, economic and environmental
consequences of the early closure of the KNPP Units 3&45.
One of the main results to emerge from the analysis was that the
economic impacts of the early closure of KNPP Units 3&4 are
substantial both in terms of direct financial losses and of energy
system losses. In the short term, the closure will affect not only
Bulgaria but all South-East European countries that rely on
electricity supplies from Bulgaria. The report also found that the
early closure of KNPP Units 3&4 at the end of 2006 will result in
overall higher discounted system costs of ˆ575 Million over the
entire study period (2001-2025) when compensated for by alternative
imported energy.
On the environmental side, the IAEA report stated that closing KNPP
Units3&4 will result in lost (potential) revenues. Having a larger
non-carbon share in the energy mix opens the opportunity to export
electricity and trade carbon emission certificates - both of which
are sources of revenue likely to be enhanced with the enforcement of
the Kyoto Protocol and accession to the EU. The lost generation
capacity will have to be compensated for partly by an increased
output of remaining Units 5&6, and partly by more generation
capacity from lignite or from imported coal or gas. This negative
trend should also be viewed within the context of energy
sustainability and Bulgaria’s emission reduction obligations.
6. As outlined in the European Council Conclusions of the EU Summit
on 23-24 March 20066, Europe is facing a number of
challenges in the energy field which have a direct impact on the
EU’s environment as well as on jobs and growth potential. In
response to these challenges, the European Council calls for a
Energy Policy for Europe that fulfils, in a balanced way the three
objectives of security of supply, competitiveness and environmental
sustainability. The early closure of the units 3&4 of the Kozloduy
NPP should be viewed also within the context of the challenges
identified by the European Council.
7. Since 1992 Bulgaria has invested more than ˆ600 Million to
address its NPP safety concerns. The European Commission contributed
ˆ50 Million to the Modernisation Programme. That investment has now
been lost. At the same time
4 “Report on Nuclear Safety in
the Context of Enlargement”, Atomic Questions Group/Working Party on
Nuclear Safety; 2003.
5 Integrated Comparative Economic Assessment of Different
Operating and Closure Schedules for Units 3&4
of Kozloduy Nuclear Power Plant, Report prepared by IAEA, September
30, 2005.
6 Presidency Conclusions, Brussels European Council, 23/24
March 2006.
the premature closure of these units will prevent the accumulation
of additional decommissioning funds which are assessed to reach up
to ˆ700-800 million (approximately 15% of the costs of the
construction of a new NPP).
8. On April 13 2005 during the plenary session in Strasbourg, the
European Parliament (EP) approved the entry of Bulgaria and Romania
into the European Union in 2007. The EP voted in favour of Mr.
Geoffrey van Orden report on Bulgaria’s application for membership
of the EU7 which “congratulates Bulgaria on the
steps taken to ensure a high level of nuclear safety at the Kozloduy
Nuclear Power Plant”, “expresses concern that a considerable
decrease in the region’s reserve generating capacities has now been
forecast for 2010-2012” and “calls on the Council (…) to be prepared
to view the closure dates within that agreement with more flexibly
until new generation capacity can come on stream in Bulgaria”.
This statement confirmed that the EP recognizes the changed energy
security situation in Bulgaria.
9. The early closure of Units 3&4 will have a negative impact on
security of energy supply within the expanded EU, creating the risk
of grid instability and black-outs. This argument becomes more
relevant when one considers the recent gas supply disturbance, which
affected some of the EU Member States as well as the oil prices
run-up. At a time when Europe is increasingly dependent upon energy
imports and expanding energy demand, the EU cannot afford to lose
880 MW of the existing safe, efficient and clean generation
capacity.
Based on these facts, it is feasible to argue that a contradiction
exists between the early closure decision and data provided by
international experts and opinions expressed by certain EU
policy-makers. We urge, therefore, the European Council, and the
European Commission to reflect the EP’s Resolution of April 2005 and
to adopt a flexible and open-minded approach that takes into account
the interest of the countries affected in the region and the current
criteria in order to reassess and if needed to reopen the discussion
on the early closure of Units 3&4 at the KNPP.
7 Bulgaria’s application to
become a member of the Union, P6_TA(2005)0117, 13 April 2005.