RA Deputy Minister of Territorial Administration and Infrastructure Hakob Vardanyan in his letter HV/22.3/1757-2020 dated on 29.01.2020 answered EcoLur's questions regarding the safety of the nuclear power sector and the construction of a new nuclear power unit. The response of the Ministry of Territorial Administration and Infrastructure of the Republic of Armenia states:
“Question 1: Whether security risk assessment has been carried out in connection with the closedown of ANPP Unit 2 and what the results are?
Response: In the process of risk assessment during decommissioning, the ANPP is guided by the requirements of the applicable legislation in force. According to RA Law "On Safe Use of Nuclear Energy for Peaceful Purposes" (adopted on February 1, 1999), the activities of objects having significance in terms of security are subject to licensing.
According to Decision No. 707 of the Government of the Republic of Armenia dated on June 14, 2005 "On Procedure for Licensing and Approval of License for Decommissioning of Nuclear Plant Operations", the list of the documents to be submitted to the Regulatory Authority for obtaining a license of decommissioning is approved, including the most significant and relevant documents - Decommissioning Project, Security Analysis Report, Environmental Impact Report, as well as Environmental Impact Assessment Report issued by competent public authorities.
The abovementioned documents have also been developed in conjunction with other documents related to the decommissioning with the support of the Council of Europe, taking into account that the operation date of the Nuclear Power Plant expired in September 2016. The form and content of these documents are in accordance with the requirements of the applicable legislation, and in their absence the IAEA requirements/recommendations have been taken into account.
The conducted research indicates that the current regulatory requirements for staff, population and the environment will not be exceeded during the ANPP decomissioning. It should also be noted that all documents related to the extension of the operation of the 2nd power unit for 10 years are subject to review/updating for submission to the regulatory authority within the timeframe provided by the legislation.
Question 2: Whether state audit of $270 million loan and $30 million grant intended for upgrading, modernization and security of the Nuclear Power Plant provided by the Russian Federation has been carried out and what outcomeshave been achieved? Will the remainder of that amount be sufficient for the safe operation of the ANPP by 2027, or will a new loan be required?
Response: RA Audit Chamber periodically conducts financial and economic audit of the loan and grant programs of Armenian Nuclear Power Plant CJSC. The last such audit is in progress, with completion expected by late February 2020. The project works are envisaged to be completied by 2021, according to which the lifetime of the second power unit of the Armenian Nuclear Power Plant is extended for ten years until 2027.
Currently, the major part of the Project has been implemented under the Lifetime extension (LE), totaling US $ 192.9 million (credit - 173.6 million, grant - 19.3 million). Until the end of 2021, the remaining works and deliveries of $107.1 million will be completed (credit - $ 96.4 million, grant - $ 10.7 million) financed by the provided loan and grant (270.0 + 30.0 million USD).
The completion of these measures justifies the further safe operation of the 2nd power unit of the Armenian Nuclear Power Plant by September 2020, as stipulated by the LE Program (to be approved by a new license). The remaining amount of the loan and grant ($ 107.1 million) is sufficient to carry out the final phase of the LE program, so no additional borrowings are required.
Moreover, within the framework of the LE program, the core systems of ANPP have been practically upgraded, which technically ensures the operation of the second unit of the ANPP even after 2016.
According to protocol decision 54 of RA Government dated on December 10 2015 on approving the long-term (up to 2036) development paths of the Armenian energy system envisages the construction of a new 600 MW nuclear power plant as an economically and technically justified option, with the beginning of 2018. The “Strategic Plan for Development of Energy Sector of the Republic of Armenia (until 2040)” does not specify when the construction of the new nuclear power unit will launch. In this regard, please provide information on the following matters:
Question: From what date will the construction of the new nuclear power unit begin, what investment financing agreement has been reached, and with whom, private, state, international banks?
Response: Currently, the Energy Strategy of the Republic of Armenia (up to 2040) has been elaborated and submitted to the Government of the Republic of Armenia for discussion, after which the issues related to the construction of the new NPP will be clarified.
Question: In the scenario of the planned construction of a new Nuclear Power Plant in the Republic of Armenia, what solutions are proposed for the safe operation of the plant when the current Nuclear Power Plant 2 cooling water deficit (Sevjur River and Akna Litch) is already available as a result of lowering of groundwater horizons.
Response: It is difficult to predict what the situation will be for the new NPP in regard to the water resources. At present, the problem for ANPP is being solved through the operation of artesian wells on the site. The construction of the new nuclear power unit will be preceded by numerous studies, including on water resources.
Atomic energy security issues
Question 4: Are the sites of long-term storage of spent nuclear fuel and radioactive waste selected, are the seismic and groundwater impacts of those sites assessed, and are international norms set aside for burial sites and adjacent settlements?
Response: The long-term storage facilities for nuclear fuel storage have been designed and built by international licensed organizations in accordance with the requirements of all international regulatory documents. The dry storage tank of nuclear fuel was built on the basis of a project submitted by French “Framatom” firm. The project is agreed with RA Nuclear Safety Regulatory Committee. For the above-mentioned warehouses, a safety justification has been provided, which also includes an assessment of external impulse risks, such as seismic safety, air crashes, storm surges, etc.
The risks of groundwater contamination as a result of these factors were also assessed. The safety assessment of the operation of the dry nuclear fuel storage facility is carried out on a regular basis, about which RA Nuclear Safety Regulatory Committee is notified with relevant reports. Long-term storage facilities for nuclear fuel are located in the sanitary protection zone of the Armenian Nuclear Power Plant, which is within an allowable distance from nearby settlements.
Question 5: Has the Government developed new safeguards for the long-term impact of the ANPP?
Response: The protection of the population of the emergency planning zones of the ANPP is regulated in accordance with the National Plan of Protection of the Armenian Population in Case of Nuclear and/or Radiation Emergencies (External Emergency Plan of the Armenian Nuclear Power Plant) based on the common criteria for protective actions laid down in Decision No. 1219 N dated on 18 August 2006 of the Government of the Republic of Armenia.
Question 6: Was the component of the socio-economic developments of the communities adjacent to the atomic energy facilities considered in the Atomic Energy Development Vision?
Response: The Armenian Nuclear Power Plant plans to build community-based alert systems for the ANPP (5km with 6 communities) and emergency defense planning zone (10km (19km)). The completion of works is scheduled for August 2021. Other components of socio-economic development of communities are provided for in regional and community development programs.
Question 7: Has the Government considered the issue of the allocation of community budget funds for the purpose of radiation safety expenditures of the ANPP area residents or the issue of making the ANPP or State budget funds /Clause 3 of Decision Regulation No 679 of Government of the Republic of Armenia of 25 October 2000 "On Approval of the Procedure for Providing the Population with Personal Protection Measures"/.
Response: The staff of ANPP CJSC, as well as the staff of the subcontracting companies is provided with the necessary supplies of gas masks, respirators and potassium iodide. The population of the settlements within a 10 km radius of the Armenian Nuclear Power Plant is provided with respirators in accordance with the National Plan of Protection of the Armenian Population in Case of Nuclear and/or Radiation Emergencies (External Emergency Plan of the Armenian Nuclear Power Plant)
Question 8: What measures has the Government taken to give the NPP settlements the status of an 'impacted' community/residential area and to receive financial support thereafter?
Response: The decree No. 6-N dated on March 27, 2006 by Chair of Nuclear Security Regulatory Committee defines the following Emergency Planning Zones:
1. 5km zone of Immediate Defense Measures;
Internal border: outline of the platform of the Armenian Nuclear Power Plant
Outer border: 5 km radius of the Armenian Nuclear Power Plant
2. Prompt Defense Measure Planning Zone;
Internal border: 5 km radius from the pipeline of the Armenian Nuclear Power Plant.
Outer border: 10 km radius from the pipeline of the Armenian Nuclear Power Plant.
3. Long-term Defense Measure Planning Zone;
Internal border: 10 km radius from the pipeline of the Armenian Nuclear Power Plant.
Outer border: 100 km radius from the pipeline of the Armenian Nuclear Power Plant.
Question 9: Have the issues and regulations of environmental and radiation level monitoring, transparency of their results and provision of information to the population been observed in the communities of the atomic energy impact zone?”
Response: Ecological and radiation level monitoring is carried out in the communities of the ANPP Impact Zone in accordance with "Regulation on Environmental Control of ANPP" РК.ЭТД.25.0PБ-003 and "Regulation on Radiation System Control" documents. The reports are submitted to Ministry of Environment and Nuclear Safety Regulatory Committee.
Reporting transparency and public awareness issues are regulated by the operating regulations of these agencies. At the same time, we would like to inform you that information received from other agencies on matters outside our jurisdiction will be provided additionally."
The Ministry of Territorial Administration and Infrastructure of the Republic of Armenia
EcoLur was provided with an answer by Ministry of Emergency Situations on issues within its jurisdiction. Its response says:
“1. The calculation of the ANPP of Immediate Defense Implementation and Emergency Planning zones for the population to be provided with personal protective equipment is provided in accordance with the RA Government's December Decision No. 2328-N dated on 22, 2005 “On Approval of the National Plan of Protection of the Armenian Population in Case of Nuclear and/or Radiation Emergencies (External Emergency Plan of the Armenian Nuclear Power Plant)”.
2. “Territorial Service of Seismic Protection” SNCO of Ministry of Emergency Situations conducts seismic monitoring of the ANPP site. Within the frameworks of the technical cooperation between the State Nuclear Safety Regulatory Committee and the International Atomic Energy Agency signed in 2013, 6 state-of-the-art GURALP 6TD seismic stations, provided free of charge to the Ministry of Emergency Situations, are located around the ANPP. As a result, the ANPP has been upgraded with seismic distance network, which significantly increased the reliability of observations. The data is sent in real time to “Territorial Service of Seismic Protection” SNCO of Ministry of Emergency Situations.”
16:29 February 03, 2020