environmental impact assessment

NNC 

Booths Hall, Chelford Road, Knutsford, Cheshire, WA16 8QZ England 

DOCUMENT ISSUE RECORD 

Document Title: ENVIRONMENTAL IMPACT ASSESSMENT OF THE DRY SPENT 

FUEL STORAGE FACILITY AT KOZLODUY NPP - EIA REPORT 

Project No.: 12000 

Client: Kozloduy Nuclear Power Plant, Plc. 

Client Doc. No.: NNC-DSF-018 

Purpose of Issue: Revision 2 

Security Class: Commercial in Confidence 

Issue Description of Issue Originator/Author Checker Approver Date 

I Popov 

P Mynar M Dostal 

01 Revision 0 - draft 

S Traycheva 

22. 12. 2004 

I Popov 


02 Revision 0/2 

S Traycheva 

31. 3. 2005 

I Popov 


03 Revision 1 

S Traycheva 

18. 5. 2005 

I Popov 


04 Revision 1/2 

S Traycheva 

6. 7. 2005 

I Popov 


05 Revision 2 S Traycheva 

30. 9. 2005 

Previous issues of this document shall be destroyed or marked SUPERSEDED 

Distribution: Kozloduy Project Management Unit: 

© NNC, 2005 

All rights reserved. 

1 original + 4 copies in English, 

1 original + 5 copies in Bulgarian 

Document: 12000-TR-001 

Issue: 05 

Page: i

ENVIRONMENTAL IMPACT ASSESSMENT OF THE DRY SPENT 


EXECUTIVE SUMMARY 

This EIA Report is developed in accordance with the Environmental Protection Act SG No. 91/2002, 

amended No. 98/2002, amended SG No.86/30.09.2003, amended SG No.70/10.08.2004, in force since 

1 January 2005 and the Regulation on the Conditions and the Order for Implementing Environmental 

Impact Assessment of Investment Proposals For Construction, Activities and Technologies SG 

No. 25/2003. 

The purpose of EIA Report is to analyse and evaluate the environmental impact of the proposed Dry Spent 

Fuel Storage Facility (DSF), which is planned to be built at Kozloduy Nuclear Power Plant (KNPP) site. 

The construction of Dry Spent Fuel Storage Facility, which would store the spent fuel assemblies from all 

Kozloduy NPP units, is one of the measures proposed in the "National Strategy for spent nuclear fuel and 

radioactive waste safe management". This strategy is approved by the Bulgarian government. The strategy 

is in compliance with Grant Agreement between Kozloduy NPP and EBRD for Kozloduy International 

Support Decommissioning Fund. 

The construction of the DSF has the following objectives: 

• to provide the necessary free capacities for removal and storage of spent nuclear fuel assemblies from 

the Units 1 to 4 of Kozloduy NPP during their decommissioning; 

• to avoid interruption of the KNPP operation by releasing free capacities in the spent fuel pools for 

acceptance of spent nuclear fuel from the operating units; 

• to ensure long term storage of spent nuclear fuel assemblies for a period up to 50 years and to allow 

future safe retrieval and transport of the spent fuel assemblies. 

The main requirements for the DSF are as follows: 

• to process 420 spent nuclear fuel assemblies from WWER-440 and 108 spent nuclear fuel assemblies 

from WWER-1000 reactors per year; 

• phased construction of the DSF with initial capacity of 2800 fuel assemblies; 

• total storage capacity (after its complete construction) of 8000 fuel assemblies from WWER-440 and 

2500 from WWER-1000 units. 

Interim Dry Spent Fuel Storage Facility provides safe and secure storage of spent nuclear fuel before it is 

reprocessed or disposed of as a radioactive waste. A major consideration in the operation of the spent fuel 

storage facility is to achieve and maintain high standards of safety in terms of protecting operating staff, the 

environment and members of the public. 

The main purpose of the Kozloduy DSF is to safely store the spent fuel from the Kozloduy Nuclear Power 

Plant. This is achieved by Storage Technology using a cask storage system. The Storage Technology is 

located in the Storage Building, which provides suitable conditions and environment for the technology, 

operation and maintenance activities. 

The construction of the DSF is divided into two stages: 

Stage I: Storage of 2800 WWER-440 spent nuclear fuel assemblies 

in CONSTOR 440/84 casks (34 casks in total). 

Stage II: Storage of 5200 WWER-440 spent nuclear fuel assemblies 

in CONSTOR 440/84 casks (96 casks in total) 

and 2500 WWER-1000 spent nuclear fuel assemblies 

in CONSTOR 1000/19 casks (132 casks in total). 

When completed, the Dry Spent Fuel Storage Facility will be able to accept and store of up to 8000 spent 

fuel assemblies from WWER-440 and 2500 spent fuel assemblies from WWER-1000. 

The Dry Spent Fuel Storage Facility will be located within the existing Kozloduy Nuclear Power Plant 

boundaries. Functionally, it is an extension of the current activity at the KNPP, i.e. interim storage of spent 

nuclear fuel in Wet Storage Facility (WSF). The environmental effects of the WSF have been already 

assessed in the EIA Report (Kozloduy NPP EIA Report from 1999) and the Ministry of Environment and 

Waters issued Permission (No. 28-8/2001), allowing further electricity generation at Kozloduy NPP. 


Issue: 05 

Page: ii



The storage technology proposed for the DSF is a cask storage system with natural convection air cooling. 

The casks proposed for the DSF are: 

• CONSTOR 440/84 with a capacity of 84 WWER-440 spent fuel assemblies per cask, 

• CONSTOR 1000/19 with a capacity of 19 WWER-1000 spent fuel assemblies per cask. 

The proposed CONSTOR casks meet all the standards of the International Atomic Energy Agency (IAEA) 

regulations as well as the Bulgarian national standards. The cask design ensures sub-criticality of the 

stored fuel, integrity and tightness of the cask, shielding and the heat dispersion in all design cases and 

accidental conditions. The high level of safety and radiation protection is achieved by high standards of 

design and construction which include the ‘zero-release’ concept utilised in the storage casks. The casks 

are designed to fulfil their safety related functions throughout the storage period of 50 years and for all 

design basis accident conditions. 

The DSF building is designed in accordance with architectural and civil engineering requirements to meet 

the functional specification for preparation, control, storage and monitoring of the casks. 

The scope of the EIA report is focused on one location of the DSF (inside the KNPP site) and one type of 

technology (dry spent fuel storage facility). This option is called "Alternative 1". Apart from the 

Alternative 1, "Zero alternative", which means non-realisation of the DSF, is also considered. For the 

completeness "Other alternatives" of dealing with the irradiated or spent nuclear fuel are discussed only in 

general terms. 

The DSF is located within the existing site of the nuclear power plant and therefore, the location aspect is 

less significant for the environmental impact assessment. On the other hand, the effect of the operation 

can have consequences outside the fenced area of the NPP and hence it is more significant for the 

environmental impact assessment. Attention has been paid to the radiation impact and impact on human 

health. For this purpose special studies, such as Risk Assessment, have been performed. The other areas, 

such as impacts on air, water, soil, flora, fauna and cultural heritage, which have lesser importance, are 

assessed in less detail. Nevertheless, the requested scope of the assessment is implemented in 

accordance with the statutory requirements. 

The important and mandatory part of the EIA Report is the evaluation of the effects of potential accidents. 

These effects are analysed from the environmental point of view (impacts on environment in case of 

accidents) and not from the technical point of view (analysis of initial events and their consequences). The 

EIA Report is not a Safety Report of the DSF. Results and data regarding the achieved level of nuclear 

safety from the technical point of view are basis for processing this EIA Report, not its subject. The 

documented evidence that the appropriate level of nuclear safety has been achieved will be contained in 

the Safety Report and it is not included here. 

The safety analyses demonstrate that there is no loss of cask integrity in any foreseeable accident 

conditions, as represented by handling faults resulting in a dropped cask etc. Any adverse effects on the 

environment are prevented even under the most extreme conditions considered within the design basis, as 

represented by external events such as earthquake and fire. 

The expected environmental effects during DSF operation are negligible. The spent nuclear fuel is 

contained within the casks, which prevents the release of radionuclides into the environment and provide 

adequate shielding of gamma and neutron radiation. The contamination of water, air and soil is practically 

zero and for the purpose of impact on the human health can be excluded. Therefore, the only health 

hazard factor to be considered, is the residual level of the ionising radiation, which is not shielded by the 

casks or the DSF building walls. The health risk from the normal operation of the DSF to the nearest 

inhabited place (town of Kozloduy) is negligible. The expected equivalent dose in Kozloduy town is 

insignificant and it is 19 orders of magnitude lower than from the natural radiation to which the inhabitants 

are permanently exposed. 

No significant negative effects on the population or the environment are expected during the DSF 

construction or from the DSF decommissioning, if the decommissioning plan and all the Bulgarian and 

international legislative requirements for the decommissioning of a nuclear facility are followed. 

The EIA Report concludes that no significant negative effects on the population or on the environment are 

expected during the DSF construction, operation and decommissioning. The potentially affected area is 

limited to the fenced area of the Kozloduy NPP. This area is not accessible to general public, it is not 

inhabited and it is used for the industrial purposes i.e. generation of electricity. The potentially affected 

area does not cross the national borders. 


Issue: 05 

Page: iii



LIST OF AUTHORS 

Team leader: 

Svetla Traycheva, POVVIK-OOS, Ltd. 

Registered team leader, Wastes - Certificate No. 489, ............................................... 

Surface water, Groundwater - Certificate No. 1382 

Prepared points: 3.1.1, 3.1.2, 3.10.1, 3.10.2, 3.10.3, 4.1.1.3, 4.1.1.8, 

4.1.2.7, 4.1.2.8, 4.1.2.10, 4.1.3, 4.1.4, 4.1.5, 4.3.1, 5, 6, 7, 8, 9, 10, 11, 12 

Participating experts: 

Elizabeth Grindon, NNC 

Nuclear safety ............................................... 

Harmful radiation, Radioactive wastes - Certificate No. 1595 

Prepared points: 1.2.1.7, 4.1.3 

Petr Mynar, INVESTprojekt NNC, s.r.o. 

Supervise, Description of the Investment proposal, Layout ............................................... 

Noise, Vibrations, Environmental modelling - Certificate No. 1609 

Prepared points: 0, 1, 2, 8, 9, 10, 12 

Pavel Cetl, INVESTprojekt NNC, s.r.o. 

Atmospheric air quality, Climatic factors, ............................................... 

Municipal and hazardous wastes - Certificate No. 1608 

Prepared points: 3.5, 4.1.1.4, 4.1.2.3, 4.1.2.10, 

4.1.3, 4.1.4, 4.1.5, 4.3.3, 5, 6 

Ivo Popov, POVVIK-OOS, Ltd. 

Registered team leader, Waters, Wastes - Certificate No. 20 ............................................... 

Prepared points: 3.2.1, 3.2.2, 4.1.1.5, 4.1.2.4, 4.1.2.10, 4.1.3, 

4.1.4, 4.1.5, 4.2, 4.3.2, 5, 6, 8, 9, 10 

Nelly Gromkova, POVVIK-OOS, Ltd. 

Atmospheric air - Certificate No. 1503 ............................................... 

Prepared points: 3.5, 4.1.1.4, 4.1.2.3, 4.1.2.10, 

4.1.3, 4.1.4, 4.1.5, 4.3.3, 5, 6, 8 

continue > 


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Ada Baynova, POVVIK-OOS, Ltd. 

Hazardous substances, Environmental health ............................................... 

and hygienic aspects - Certificate No. 36 

Prepared points: 3.10.4, 4.1.1.1, 4.1.1.2, 4.1.2.1, 4.1.2.2, 

4.1.2.10, 4.1.3, 4.1.4, 4.1.5, 5, 6, 8 

Rumyana Nikolova, POVVIK-OOS, Ltd. 

Waters, Geology - Certificate No. 567 ............................................... 

Prepared points: 3.1.3, 3.2, 4.1.1.6, 4.1.1.7, 4.1.2.5, 

4.1.2.6, 4.1.3, 4.1.4, 4.1.5, 5, 6, 8 

Elena Zheleva, POVVIK-OOS, Ltd. 

Registered team leader, Soils, Flora - Certificate No. 9 ............................................... 

Prepared points: 3.3, 4.1.1.6, 4.1.1.7, 4.1.2.5, 4.1.2.6, 

4.1.2.10, 4.1.3, 4.1.4, 4.1.5, 5, 6, 8 

Ljubka Kostova, POVVIK-OOS, Ltd. 

Harmful radiation, Radioactive wastes - Certificate No. 1630 ............................................... 

Prepared points: 3.6, 3.7, 4.1.1.9, 4.1.1.10, 4.1.1.11, 4.1.2.9, 

4.1.2.10, 4.1.3, 4.1.4, 4.1.5, 4.3.3, 4.3.4, 5, 6, 8 

Bogdan Bogdanov, POVVIK-OOS, Ltd. 

Registered team leader, Flora, Fauna - Certificate No. 76 ............................................... 

Prepared points: 3.8, 4.1.1.7, 4.1.2.6, 4.1.2.10, 4.1.3, 4.1.4, 4.1.5 

Radoslava Stoyanova, POVVIK-OOS, Ltd. 

Soils, Flora, Landscape - Certificate No. 920 ............................................... 

Prepared points: 3.4, 4.1.1.7, 4.1.2.6, 4.1.3, 4.1.4, 4.1.5 

Zharin Velichkov, POVVIK-OOS, Ltd. 

Also participated: 

Cultural Heritage - Certificate No. 1218 ............................................... 

Prepared points: 3.9, 4.1.1.7, 4.1.2.6, 4.1.2.10, 4.1.3, 4.1.4, 4.1.5 

Mirek Dostal, NNC 

Bob Major, NNC 

Kathy Hillis, NNC 

Edita Ondrackova, INVESTprojekt NNC, s.r.o. 

Tsvetomir Stoyanov, POVVIK-OOS, Ltd. 

Vladimir Marchev, POVVIK-OOS, Ltd. 


Issue: 05 

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TABLE OF CONTENTS 

DOCUMENT ISSUE RECORD ................................................................................................................. i 

EXECUTIVE SUMMARY........................................................................................................................... ii 

LIST OF AUTHORS ............................................................................................................................... iv 

TABLE OF CONTENTS ......................................................................................................................... vi 

LIST OF ABBREVIATIONS .................................................................................................................. viii 

GLOSSARY ............................................................................................................................................ x 

0 INTRODUCTION ................................................................................................................................ 1 

1 PART I - ANNOTATION OF THE INVESTMENT PROPOSAL FOR CONSTRUCTION, 

ACTIVITIES AND TECHNOLOGIES OF DSF AT KNPP SITE ........................................................... 3 

1.1 DSF GENERAL INFORMATION AND AREA LOCATION ............................................................. 3 

1.1.1 Location of DSF site, as a part of the general layout of KNPP site ........................................ 3 

1.1.2 Other activities connected to the existing and approved territorial regulation 

or any other plans ................................................................................................................ 4 

1.2 CHARACTERISTICS OF DSF ...................................................................................................... 4 

1.2.1 DSF general plan ................................................................................................................. 4 

1.2.2 Steps of the investment proposal ........................................................................................ 21 

1.2.3 Description of main construction processes of DSF and of the utilised resources ................ 21 

1.2.4 Description of the main processes during DSF operation and decommissioning phases 

as well as the utilised resources ......................................................................................... 21 

1.2.5 Other activities, related to the investment proposal ............................................................. 26 

2 PART II - ALTERNATIVES OF SITING AND/OR ALTERNATIVES TO THE TECHNOLOGIES 

PROPOSED BY THE CLIENT AND THE JUSTIFICATION OF THE CHOICE MADE ...................... 27 

2.1 ALTERNATIVE "1" ..................................................................................................................... 27 

2.2 "ZERO" ALTERNATIVE ............................................................................................................. 28 

2.3 OTHER ALTERNATIVES ........................................................................................................... 29 

3 PART III - DESCRIPTION AND ANALYSIS OF THE ENVIRONMENTAL COMPONENTS 

AND FACTORS AS WELL AS THE MATERIAL AND CULTURAL HERITAGE 

THAT WILL BE SIGNIFICANTLY AFFECTED BY THE INVESTMENT PROPOSAL, 

THE INTERACTIONS AMONG THESE ASPECTS .......................................................................... 30 

3.1 TOPOGRAPHY .......................................................................................................................... 30 

3.2 HYDROLOGY AND HYDROGEOLOGY, SURFACE AND GROUND WATERS .......................... 33 

3.3 LANDS ....................................................................................................................................... 39 

3.4 LANDSCAPE ............................................................................................................................. 40 

3.5 CLIMATIC AND METEOROLOGICAL CONDITIONS ................................................................. 40 

3.6 RADIATION BACKGROUND, ATMOSPHERIC RADIOACTIVITY 

AND ATMOSPHERIC AIR QUALITY .......................................................................................... 42 

3.7 PHYSICAL HAZARDOUS FACTORS ......................................................................................... 49 

3.8 PROTECTED TERRITORIES, FLORA AND FAUNA .................................................................. 50 

3.9 CULTURAL HERITAGE ............................................................................................................. 51 

3.10 DEMOGRAPHIC, SOCIAL AND SOCIOECONOMIC CONDITIONS ......................................... 51 


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4 PART IV - DESCRIPTION, ANALYSIS AND ASSESSMENT OF THE POTENTIAL SIGNIFICANT 

EFFECTS ON THE POPULATION AND THE ENVIRONMENT RESULTING FROM ....................... 63 

4.1 IMPLEMENTATION OF THE INVESTMENT PROPOSAL .......................................................... 63 

4.1.1 Possible impacts during the DSF construction .................................................................... 63 

4.1.2 Possible impacts during DSF operation and decommissioning ............................................ 69 

4.1.3 Possible impacts resulting from accidents ........................................................................... 83 

4.1.4 Matrix for assessment of potential impacts considering the non-radiation 

aspect during implementation of DSF ................................................................................. 86 

4.1.5 Matrix for assessment of potential impacts considering the radiation 

aspect during implementation of DSF ................................................................................. 89 

4.2 USE OF NATURAL RESOURCES ............................................................................................. 91 

4.3 HARMFUL SUBSTANCES EMISSIONS DURING CONSTRUCTION, NORMAL OPERATION 

OR IN CASE OF EMERGENCY, WASTE GENERATION (CONSIDERED BY SINGLE 

ENVIRONMENTAL COMPONENTS AND FACTORS) ..................................................................... 92 

4.3.1 Solid waste generation ....................................................................................................... 92 

4.3.2 Liquid waste generation ...................................................................................................... 95 

4.3.3 Waste gases generation ..................................................................................................... 95 

4.3.4 Harmful physical emissions ................................................................................................ 96 

5 PART V - INFORMATION ON THE METHODS USED FOR FORECASTING AND ASSESSING 

THE IMPACTS ON THE ENVIRONMENT ........................................................................................ 99 

6 PART VI - DESCRIPTION OF THE MEASURES ENVISAGED TO AVOID, REDUCE 

OR WHERE POSSIBLE, STOP THE SIGNIFICANT ADVERSE EFFECTS 

ON THE ENVIRONMENT AND PLAN FOR IMPLEMENTATION OF THESE MEASURES ............ 101 

6.1 PLAN FOR IMPLEMENTATION OF THE MEASURES ............................................................. 101 

6.2 RECOMMENDATIONS ON ENVIRONMENT MANAGEMENT .................................................. 104 

6.3 RECOMMENDATIONS ON THE SITE MONITORING PLAN .................................................... 104 

6.4 RECOMMENDATIONS ON THE EMERGENCY PLAN ............................................................. 104 

7 PART VII - STATEMENTS AND OPINIONS EXPRESSED BY THE CONCERNED PUBLIC, 

AS WELL AS THE AUTHORITIES INVOLVED IN DECISION MAKING FOR EIA 

AND OTHER SPECIALIZED AUTHORITIES, AS A RESULT OF THE CONSULTATIONS MADE 105 

8 PART VIII - EXPERTS CONCLUSION ........................................................................................... 109 

9 PART IX - NON-TECHNICAL SUMMARY ...................................................................................... 111 

10 PART X - LIST OF THE NECESSARY ATTACHMENTS, LISTS ETC. .......................................... 125 

10.1 GRAPHIC ATTACHMENTS .................................................................................................... 125 

10.2 TABLES ................................................................................................................................. 125 

10.3 FIGURES ............................................................................................................................... 126 

10.4 OTHER ATTACHMENTS ....................................................................................................... 127 

11 REFERENCES .............................................................................................................................. 128 

12 DESCRIPTION OF THE INFORMATION ACQUISITION PROBLEMS 

RELATED TO EIA-R DEVELOPMENT .......................................................................................... 133 

ATTACHMENTS 

Attachment 1 Map and layout attachments 

Attachment 2 Certificates of participating experts 

Attachment 3 Record of the meeting with the concerned public and authorities 

Attachment 4 Letters and notes of the meetings with municipalities and other organizations 


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LIST OF ABBREVIATIONS 

ALARA As Low As Reasonably Achievable 

AMSERC Automatic Measurement System for External Radiation Control 

BLRP Basic Limits for Radiation Protection 

CPS Central Pumping Station 

DC Drainage Channel 

DCM Decree of the Council of Ministers 

DEKO Decontamination 

DSF Dry Storage Facility (Dry Spent Fuel Storage Facility) 

EBRD European Bank for Reconstruction and Development 

EEA Executive Environmental Agency 

EIA Environmental Impact Assessment 

EIA-R EIA Report 

EMR Electromagnetic Radiation 

EPA Environment Protection Act 

EP-1, EP-2 Plant 1 (Units 1-4), Plant 2 (Units 5-6) 

ERC Environment Radiation Control 

ERCL Environment Radiation Control Laboratory 

EU European Union 

FSF Fuel Storage Facility 

HPZ Hygienic Protection Zone 

IAEA International Atomic Energy Agency 

ICRP International Commission on Radiological Protection 

ISAR Interim Safety Analysis Report 

IT Information Technology 

KIDSF Kozloduy International Decommissioning Support Fund 

KNPP Kozloduy Nuclear Power Plant 

LLA Long-Living Aerosols 

LV Limit Value 

MAC Maximum Admissible Concentration 

MEW Ministry of Environment and Waters 

MH Ministry of Health 

NASCMRB National Automatic System for Continuous Monitoring of the Radiation Background 

NCHI National Centre for Health Information at Ministry of Health 

NPP Nuclear Power Plant 

NRA Nuclear Regulatory Agency 

NRRPC National Radiobiological and Radiation Protection Centre 

NICM National Institute for Cultural Monuments 

NSI National Statistical Institute 

OC Outlet Channel 

PSAR Preliminary Safety Analysis Report 

PWR Pressurized (Light) Water Reactor (equivalent of VVER) 

RAW Radioactive Waste 

RAWF Radioactive Waste Treatment Facility 


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RCA Radiologically Controlled Area 

RCE Radiation Control of the Environment Department 

RNG Radioactive Noble Gases 

SAF State Agricultural Farm 

SAGSCEC System for Accelerated Graphic Seismic Control of Equipment and Constructions 

SAR Safety Analysis Report 

SG State Gazette 

SNF Spent Nuclear Fuel 

SRZ Strict Regime Zone 

UNSCEAR United Nations Scientific Committee on the Effects of the Atomic Radiation 

US EPA United States Environmental Protection Agency 

WWER Russian abbreviation for the PWR reactor type (Water-Water Energy Reactor, Vodo- 

Vodjanoj Enegeticheskij Reactor) 

WWTP Waste Water Treatment Plant 

WSF Wet Storage Facility (Wet Spent Fuel Storage Facility) 

ZPPM Zone of Preventive Protection Measures 


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GLOSSARY 

Accident: Extraordinary event, which leads or can lead to exceeding of the limits or 

incompliance with the radiation impact conditions on human and environment, set in 

the regulations and rules for nuclear safety and radiation protection. 

Accident conditions: Deviations from the normal operation that is more severe than the expected 

operation events, including design basis accidents and beyond design basis 

accidents. 

Activities related to the use of nuclear energy: 

1. placement, construction, commissioning, operation, reconstruction and 

decommissioning the nuclear facility, 

2. designing of the nuclear facility, 

3. designing, production, repairs and verification of nuclear facility systems or its 

parts, including materials for its production, 

4. designing, production, repairs and verification of packaging assemblies of 

container sets for transport, storage or deposition of nuclear material, 

5. treatment of nuclear materials and selected elements, and in the case of use in 

the nuclear area, even with elements with double use, 

6. research and development of activities stated in points 1 to 5, 

7. professional preparation of persons specialised from the point of view of nuclear 

safety to activities stated in point 1, 

8. transport of nuclear materials. 

Activities leading to irradiation: Any human activity, through which sources of irradiation or paths of 

radiation are introduced, spreads irradiation to other people or changes the paths 

irradiation from existing sources so that irradiation or the probability of irradiation to 

people or the number of irradiated people grows, especially production, transport, 

operation and other treatment of sources of ionising radiation including radioactive 

waste or introducing ionising radionuclides into the environment. Irradiation is taken 

to mean exposing people and the environment to ionising radiation. 

ALARA principle (As low as reasonably achievable principle): According to this principle everyone who 

uses nuclear energy or carries out activities leading to irradiation or carries out 

interventions to restrict natural irradiation or irradiation owing to a radiation accident, 

is obliged to adhere to such a level of nuclear safety, radiological protection, 

physical protection and accident preparedness as is reasonably achievable upon 

balancing economic and social perspectives when considering economic and social 

viewpoints. 

Back-up (Redundancy): Provision of alternative (identical or varied) constructions, systems or components 

in a way that each of them can perform the required function independently from the 

operation condition or fault of the other constructions, systems or components. 

Cask: Sealed shielded packaging assembly (container) for spent nuclear fuel or 

radioactive waste used for transport or storage. 

Commissioning the Nuclear Facility: Process, during which the systems and components of constructed 

nuclear facility or other source of ionising radiation are in operate condition and 

assessed for compliance with the project requirements and workability criteria. 

Critical population group: Model group of people which is reasonably homogenous from the point of view of 

irradiation from the given source of ionising radiation and given paths of irradiation 

and characterised individuals from the population who obtain the highest effective 

dose by the given path from the given source. 


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Decommissioning: All administrative and technical actions taken to allow the release of a nuclear facility 

from regulatory control under the Atomic Act, including closure of a radioactive 

waste disposal facility or of a spent nuclear fuel storage facility. These actions 

include the processes of decontamination and dismantling. 

Deposit of Radioactive Waste: Permanent location of spent nuclear fuel or radioactive waste to a suitable 

repository (space, building or facility) without the intention of their further relocation. 

Design Basis Accident: Accident for which are envisaged in the design technological means, ensuring the 

limiting of the consequences from it. 

Designed limits for normal and abnormal operation: Parameter values under which a normal operation and 

prevention of unacceptable radionuclides emissions in the environment is 

guaranteed. 

Deterministic (threshold, non-stochastic) effects: are harmful for the health effects, from ionizing radiation 

impact, for which exists a minimal dose, causing a certain effect and above which 

the severity of the effect occurrence increases with the dose accumulation growth. 

Emergency plan: Document describing the actions and measures for mitigation and elimination of 

accident consequences. 

Emergency preparedness: Capability to take immediate actions that will effectively mitigate the impact of a 

possible accident on human health, the environment and property. 

Environmental monitoring: Collection and evaluation of environmental information by means of continuous 

or periodic observation of certain qualitative and quantitative indicators 

characterizing the state of the environmental media and the changes therein 

resulting from the impact of natural and anthropogenic factors. 

External Irradiation: Irradiation of people from sources of ionising radiation, located in the environment. 

Failure: Ceasing of the functioning state of a certain component. The functioning state of a 

certain component is a state during which the component is able to perform a preset 

(desired) function, and the parameters values of the components do not exceed the 

specified limits. 

Fuel assembly: Grouping of fuel rods, which are generally not stripped during fuel exchange in the 

reactor; besides fuel elements also include spacers, upper and lower sleeves, and if 

used, also guide tubes for internal instrumentation or for control rod clusters or for 

neutron sources or for assemblies with discrete burnable absorbers and the fuel 

assembly shroud. 

Fuel basket: Supporting steel construction, which ensures a stable and subcritical arrangement of 

fuel assemblies in pools or casks. 

Fuel rod: Constructional unit whose basic element is nuclear fuel; includes cladding, fuel 

pellets, filling gas, springs, seals etc. 

Fuel system: Fuel assemblies and their components, control rods, combustible absorbers, 

neutrons source rods, reflectors etc. 

Internal Irradiation: Irradiation of persons from radionuclides occurring in the body, generally as a result 

of the intake of radionuclides by ingestion or breathing. 

Limits for normal operation: Limits for safe operation of the nuclear facility, specified and analysed in the 

facility Safety Analysis Reports, including mainly the following: 

a) Limits, within which is necessary to review the physical and technological 

parameters in such a way, that no undesired parameter levels, which can affect the 

nuclear safety systems are reached during operation. Within these limits the safety 

of the facility is proven. 

b) Requirements on facility serving which are important from the nuclear safety point 

of view ensuring that the facility operates in the specified range of requirements. 

c) Values of other important safety parameters in which range the nuclear safety of 

the facility is proven. 


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Manipulation with nuclear materials and radioactive waste: Movement and handling operations with the 

nuclear materials and radioactive waste. 

Maximal Design Basis Accident: Design basis accident with the most severe radiation consequences, 

envisaged in the facility design. 

Natural Irradiation: Irradiation from natural radionuclides or from other spontaneously occurring sources 

of ionising radiation. 

Natural Radionuclides: Radionuclide, which originated or originates freely in nature, without human 

intervention. 

Nuclear facility: Facility and its associated land, buildings and equipment in which radioactive 

material is yielded, produced, processed, used, handled, stored or disposed of on 

such a scale that consideration of nuclear safety and radiation protection is required. 

Any radioactive waste management facility shall likewise qualify as "nuclear facility." 

Nuclear safety: State and ability of the nuclear facility, its systems and persons operating the 

nuclear facility to prevent uncontrolled development of the fission chain reaction or 

inadmissible release of radioactive substances or ionising radiation to the 

environment, prevention of accidents and incidents and restriction of the 

consequences. 

Optimisation of radiological protection: Procedures for attaining and maintaining such a level of radiological 

protection so that the risk of danger to life, human health and the environment is as 

low as reasonably possible when considering economic and social viewpoints. 

Organizational measures: Focused mainly on: 

a) Cases in which the admissible parameters levels have been reached or have 

been exceeded; or the requirements regarding the serving have not been fulfilled; or 

particular protective systems requirements of the processes settings, necessary 

activities and measures which have to be implemented and the time limits for 

performing of those activities and measures have not been carried out. 

b) Responsibilities of the supervision personnel in the organization of the permit 

owners, qualification of selected personnel, requirements for minimal shift work, 

internal and external control of the restraints and conditions and the obligation for 

providing information required by the control authorities. 

Personal dose: General labelling for quantities characterising the degree of external and internal 

irradiation to individual persons, especially the effective dose, load of effective dose 

and equivalent doses in individual organs or tissues; equipment which measures 

personal dose, are labelled as personal dosimeters and the sum of measurements 

and assessment of personal doses is labelled as personal dosimetry. 

Physical protection: Set of all technical and organisational requirements, measures, means and methods 

intended to effectively prevent unauthorised tampering or interference with, or 

unauthorised removal of, nuclear material, nuclear facilities and radioactive 

substances (theft, intrusion into the site of a nuclear facility, unauthorised access to 

areas vital to the safety of the nuclear installation, sabotage, terrorist actions), their 

timely detection, and recovery of misappropriated nuclear material. 

Radiation accident: Event, which results in inadmissible release of radioactive substances or ionising 

radiation or inadmissible irradiation of persons. 

Radiation disaster: Radiation disaster, which requires measures for protection of the population and the 

environment. 

Radiation monitoring: Measurement of the radiation parameters of the workplace and the environment, in 

order to assess or control the exposure, as well as to interpret the results. 

Radioactive waste: Radioactive substance in a gaseous, liquid or solid form for which no further use is 

foreseen by the licensee or permit holder and which is controlled as radioactive 

waste by the Agency according to Atomic Act, including a radioactive source for 

which the safe operating lifetime has ended according to the design documentation. 


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Radioactive waste repository: space, building or facility on the surface or underground serving for the final 

storage of radioactive waste. 

Radionuclide: Totality of radioactive atoms having a certain mass number and atomic number, 

whilst for the isomeric atoms – also having a certain energetic status of the atomic 

nucleus. The radioactive and (and the non-radioactive) nuclides of a certain element 

are called its isotopes. 

Redundancy see Back-up. 

Reliability: General (comprehensive) feature of equipment, consisting in the ability to fulfil the 

required function when maintaining values established by operational indicators in 

the given limits and time according to established technical conditions. It is 

expressed by partial features such as fail-safeness, service life, maintainability, 

reparability, storage life, preparedness etc. 

Routine operation: All modes and operations of planned operation of the nuclear facility whilst adhering 

to limits and conditions of safe operation of the nuclear facility. 

Rupture of fuel element: Rupture of the integrity of the cover, leading to possibility of release of nuclear 

products in the environment. 

Safety culture: Set of attitudes, activities, characteristics of organisation and individuals and mutual 

relations, which ensure that the problem of nuclear facility safety is afforded the 

highest priority as its significance deserves. 

Safety important systems: Important systems, structures and components regarding the nuclear safety are 

those: 

1. Which irregular functioning or breakdown could lead to inadmissible irradiation of 

the personnel or population; 

2. Which prevent accidental situation during expected operational events; 

3. Whose function and characteristics are in regard to the management and control 

of accident consequences. 

Safety limits: Limit values of physical and technological parameters, which directly influence the 

state of physical barriers preventing loss of radioactive substances from the nuclear 

facility to the environment, and which cannot be exceeded. 

Selected equipment: Parts or systems of the nuclear facility, which are important for the nuclear safety, 

classified into safety classes in accordance with their importance for operational 

safety of the nuclear facility, in accordance with the safety functions of the system 

from which they are part and depending on the seriousness of their possible 

breakdown. The classification criteria and separation of the selected equipment by 

classes of safety are set in the legislation in force. 

Spent Nuclear Fuel (or Spent Fuel): Nuclear fuel that has been irradiated in a reactor core and that has 

been permanently removed from the core. 

Stochastic effects of radiation: Ionizing radiation induced harmful health effects, for which is accepted that 

there is no threshold dose and the probability of occurrence of which is greater for a 

higher radiation dose and the severity of which is independent of dose. Stochastic 

effects are the cancers and leukaemia and the hereditary (genetic) diseases. Other 

stochastic effects, induced by ionizing radiation impact do not exist. 

Storage of Radioactive Waste and Spent Nuclear Fuel: Holding of nuclear material or radioactive 

substances, including spent fuel or radioactive waste, in a facility that provides for 

their containment, with the intention of retrieval. 

Subcriticality: Stable state of a fissile material, where the rate of generation of neutrons is less 

than the rate of absorption. 

System: System is understood as a complex of several mutually adherent equipment, 

determined for fulfilling specified functions. 


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Work area: Part of the workplace with sources of ionising radiation, uniquely characterised by its 

protection (isolation, ventilation and shielding) properties, determined spatially or 

technologically (workbench, application or examination box, fume-cupboard, sealed 

vacuum cabinet etc.), where individual work can be undertaken with sources of 

ionising radiation; there can be more work areas in one room, if each forms a 

separate unit from the point of view of work organisation. 


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Backgrounds for EIA Report development 

0 

INTRODUCTION 



1 January 2005 [L.4] and the Regulation on the Conditions and the Order for Implementing Environmental 

Impact Assessment of Investment Proposals For Construction, Activities and Technologies SG No. 

25/2003 [L.84] and the Bulgarian laws, codes, norms and standards and relevant EU rules and EBRD 

policies. 

Purpose of EIA Report 

The purpose of EIA Report is to analyse and evaluate the environmental impact of the Dry Spent Fuel 

Storage Facility (DSF), proposed at the Kozloduy Nuclear Power Plant (KNPP) site. 

Methodology selected for the EIA Report 

Environmental impact assessment generally deals with two aspects: 

• location (proposed location and consequences to the surrounding environment), 

• operation (proposed activities and consequences to the surrounding environment). 

The DSF is located on the existing nuclear power plant site. Therefore, the location aspect is less 

significant for environmental impact assessment. On the other hand, the effect of the operation can have 

consequences outside the fenced area of the NPP and therefore it is more significant for the environmental 

impact assessment. 

Therefore, attention has been given to the area of radiation impact and the impact on human health. For 

this purpose special studies, such as Risk Assessment, have been performed. 

The other areas, such as impacts on air, water, soil, flora, fauna, cultural heritage which have lesser 

importance are assessed in less detail. Nevertheless, the requested scope of the assessment is 

implemented in accordance with the statutory requirements. 

The important and mandatory part of this EIA Report is the evaluation of the effects of potential accidents. 



EIA Report is not a Safety Report of the DSF. Data about the level of assurance of nuclear safety and its 

components from the technical point of view are basis for processing this EIA Report, not its subject. 

The DSF will meet all the Bulgarian standards in the field of utilisation of nuclear energy. These aspects 

are regulated by the Nuclear Regulatory Agency (Bulgarian Nuclear Regulator) and their approval is 

necessary for construction permit. 

Need for Dry Spent Fuel Storage Facility 

One of the measures within the National Strategy for spent nuclear fuel and radioactive waste safe 

management, which is approved by the Bulgarian government by Resolution No. 693/09.11.1999 and is in 

compliance with Grant Agreement between Kozloduy NPP and EBRD for Kozloduy International Support 

Decommissioning Fund, is the construction of a Dry Spent Fuel Storage Facility, which would receive the 

spent fuel assemblies from all Kozloduy NPP units. 

The proposed DSF is in compliance with the National Strategy for the Safe Management of Spent Nuclear 

Fuel and Radioactive Waste (Ministry of Energy and Energy Resources, December 2004). 


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The major requirements for the DSF are as follows: 

• to process 420 spent nuclear fuel assemblies from WWER-440 reactors and 108 spent nuclear fuel 

assemblies from WWER-1000 reactors per year; 

• phased construction of the DSF having initial capacity of 2800 fuel assemblies; 

• total storage facility capacity (after its complete construction) of 8000 assemblies from WWER-440 

units and 2500 assemblies from WWER-1000 units; 

• safely store the spent nuclear fuel for at least 50 years. 

Summary of the Proposal 

In compliance with the National Strategy on Spent Fuel and Radioactive Waste Safe Management, 

approved by the Bulgarian Government by Resolution No. 693/09.11.1999 and the conditions for the Grant 

from the Kozloduy International Decommissioning Support Fund (KIDSF), administered by the European 

Bank for Reconstruction and Development (EBRD), one of the measures is the implementation of a Dry 

Spent Fuel Storage Facility, which will receive Spent Nuclear Fuel from all the units at the Kozloduy 

Nuclear Power Plant site. 

The technology of dry storage implements the principle of defence in depth based on passive safety 

systems (triple-barrier closure system of the casks), for which no environment releases are expected 

during the storage period. The expected environmental impact will be less than that of the currently utilised 

and approved wet storage technology. 

The Dry Spent Fuel Storage Facility will be located inside the existing Kozloduy Nuclear Power Plant 

boundaries and presents an extension of the current activity of Kozloduy Nuclear Power Plant - interim 

storage of spent nuclear fuel - for which the environmental effects have already been assessed in EIA 

Report (Kozloduy NPP EIA Report from 1999 [O.9]). The Ministry of Environment and Waters issued a 

Decision (No. 28-8/2001), allowing further production activity of Kozloduy NPP. 

After the final stage of its construction, the Dry Spent Fuel Storage Facility shall allow acceptance and 

storage of up to maximum 8000 spent fuel assemblies from WWER-440 and 2500 spent fuel assemblies 

from WWER-1000. 


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1 

PART I - ANNOTATION OF THE INVESTMENT PROPOSAL FOR CONSTRUCTION, 

ACTIVITIES AND TECHNOLOGIES OF DSF AT KNPP SITE 

1.1 DSF GENERAL INFORMATION AND AREA LOCATION 

1.1.1 Location of DSF site, as a part of the general layout of KNPP site 

The site is located north-west and north of the existing WSF building of Kozloduy NPP, and is inside the 

perimeter of the Kozloduy NPP site fence. 

The site area is 12 160 m 2 and it is oriented in direction north-south with total length of 180 m and eastwest 

with total length of 110 m. The site is 50 m wide in the southern part and 35 m wide in the northern 

part. 

The whole site is a property of Kozloduy NPP, Plc. 

The location of the chosen site for DSF is indicated on the following drawing: 

Fig. 1.1.1 Location of the DSF site inside the KNPP site 


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1.1.2 Other activities connected to the existing and approved territorial regulation 

or any other plans 

The KNPP site is used entirely for the industrial purposes, i.e. production of electricity, and no other 

activities are planned there. 

The proposed DSF site is located inside the KNPP site and the connection with other activities are as 

follows: 

• connection with WSF - road for the vehicles, transporting the casks; 

• connection with the pools for SNF from Units 1 - 6; the SNF for filling the casks will be taken from 

those pools; 

• KNPP RAW Management - RAW from DSF will be treated the same way as the other RAW form 

KNPP; 

• radiation protection - in accordance with the legislative requirements; 

• KNPP fire protection system - DSF will be included in KNPP fire protection system; 

• water supply - potable and service water (duct at the Trailer Maintenance Shop); 

• sewage connection - the wastewater will be discharged into the KNPP sewerage system; 

• non-radioactive waste management in KNPP - DSF will be included in KNPP non-radioactive Waste 

Management Programme; 

• fuel, oil and lubricant supply; 

• electricity (0.4 kV, 630 kVA, Auxiliary Building 2 - west side); 

• heating; 

• protection from non-radiation factors; 

• transport (on land and aquatic) - transportation of the casks; 

• infrastructure for services and supplies - joint with KNPP infrastructure; 

• auxiliary facilities and activities. 

1.2 CHARACTERISTICS OF DSF 

1.2.1 DSF general plan 

1.2.1.1 General data 

Interim Dry Spent Fuel Storage Facility (DSF) provides the safe and secure storage of spent nuclear fuel 

before it is reprocessed or disposed of as a radioactive waste. A major consideration in the operation of the 

spent fuel storage facility is to achieve and maintain high standards of safety in terms of protecting 

operating staff, the environment and members of the public. 

The main purpose of the Kozloduy DSF is to safely and reliably store the spent fuel from the Kozloduy 

Nuclear Power Plant. This function is provided with the Storage Technology - cask storage system. 

The casks are located in the Storage Building which provides suitable environment and conditions for the 

technology, operation and maintenance. 

The proposal for the DSF is divided into two stages: 


in CONSTOR 440/84 casks (in total 34 casks). 


in CONSTOR 440/84 casks (in total 96 casks) 




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The DSF will meet the following requirements: 

• to avoid interruption in the operation of any of the nuclear units to provide the necessary free 

capacities in the spent fuel pools for acceptance of generated spent nuclear fuel from the operating 

units, 

• to provide necessary free capacities for removal and storage of the spent nuclear fuel assemblies from 

Units 1 to 4 of Kozloduy NPP during decommissioning, 

• to ensure long-term storage of spent nuclear fuel assemblies for a period not less than 50 years, 

• to allow future safe retrieval for transport of the fuel assemblies from the storage facility. 

1.2.1.2 DSF site 

The DSF site is located inside the KNPP site, north-west and north of the existing WSF building. The 

general location is depicted above in the chapter 1.1.1 (see page 3); the detail location is depicted below in 

the chapter 1.2.1.4. (see page 11). 

The site is plantation-free and is grass-covered. In the northern part of the site is situated the workshop 

building, that will be removed. 

Road access to the DSF site is provided using the existing internal NPP roads, the NPP gate with security 

control and external state roads. 

Current status of the DSF site is shown in Fig 1.2.1.2 below: 

Fig. 1.2.1.2 Current status of the DSF site 

The existing WSF building is situated on the right (behind the fence). In the middle is the workshop building (to be removed) and 

behind is the Auxiliary Building No. 2. The access route on the left side will be maintained. 


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1.2.1.3 DSF technology 

The storage technology proposed for the Dry Spent Fuel Storage Facility at Kozloduy NPP comprises of a 

cask storage system with natural convection air cooling. The proposed casks are suitable for storage. The 

following safety and operational features characterise the cask storage system: 

• The cask storage system divides and separates the total activity of the spent nuclear fuel in the facility 

into discrete groups of fuel assemblies. Each group is safely contained within a shielded, gas-tight, 

robust and accident resistant cask that can be easily inspected. 

• The spent nuclear fuel is sealed inside a triple-barrier closure system. No release of radioactive 

materials will occur ("zero-release concept"), even after a low-probability event such as impact or 

earthquake. 

• Decay heat is removed by thermal conduction and radiation from the fuel rods to the cask surface, and 

from there by natural air convection. No active systems to dissipate the decay heat are required during 

normal or accidental conditions. 

• Degradation of the fuel cladding is prevented by maintaining an inert gas atmosphere in the cask 

cavity. Even after a long storage period, the condition of the fuel assemblies allows safe handling and 

transport. 

• The spent fuel assemblies are located inside the cask in a structure which guarantees sub-criticality, 

even under accident conditions. 

• The structural design of the casks and the cask materials fulfil their safety-related functions under both 

long-term storage (50 years and more) and hypothetical design accidental conditions. 

• No secondary waste is generated by the cask during the long-term storage period. 

• The dry storage technology avoids corrosion which occurs in wet technology. 

The auxiliary technology systems are proposed for transport and manipulation with the casks, power 

supply, monitoring etc. 




The CONSTOR cask design principle is shown in the next figure: 

Fig. 1.2.1.3-1 CONSTOR cask closure system principle 


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The numbers of casks proposed for the Kozloduy DSF are given in the following table: 

Tab. 1.2.1.3-1 Numbers of stored casks 

DSF stage Spent fuel 

assemblies 

Number of spent 

fuel assemblies 

to be stored 

CONSTOR cask Number of casks 

Stage I (initial) WWER-440 2800 440/84 34 

Stage II (final) WWER-440 8000 440/84 96 

WWER-1000 2500 1000/19 132 

The proposed CONSTOR cask system uses steel for the containment of the cask, heavy concrete for 

additional shielding, and a welded closure system. General design concept is identical for both CONSTOR 

440/84 and CONSTOR 1000/19 casks and includes: 

• cask body with head ring, 

• fuel basket, 

• lid system (primary lid, seal plate, secondary lid), 

• trunnions. 

The basic cask parameters are given in the following table: 

Tab. 1.2.1.3-2 Basic casks data 

CONSTOR 440/84 CONSTOR 1000/19 

Total height 4128 mm 5446 mm 

Total diameter 2580 mm 2390 mm 

Weight unloaded 86 370 kg 99 650 kg 

Weight of basket 7500 kg 9646 kg 

Weight of content 18 480 kg 14 554 kg 

Weight loaded 112 350 kg 123 850 kg 

Cask design is shown in the following figures (for larger scale see Attachment 1). 


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Fig. 1.2.1.3-2 CONSTOR 440/84 cask (M 1:50) 


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Fig. 1.2.1.3-4 Detail of the CONSTOR cask closure system (M 1:10) 

Cask Body, Head Ring: The sandwich design of the cask body consists of two thick-walled liners made 

from fine grain construction steel and heavy concrete (concrete with granulated 

steel) in the inter-space. The "steel - heavy concrete - steel" system provides both 

gamma and neutron shielding, and mechanical strength. 

At the lid-end of the cask, a massive head ring is welded to the inner and the outer 

liner. The cask base is of the same design as the cask wall. The inner and outer 

liners constitute a double barrier containment system, only interrupted by the single 

massive head ring designed for high resistance against extreme accident conditions. 

On the outer surface of the cask body are welded longitudinal fins to dissipate heat. 

The cask cavity has corrosion protection and radiation resistance derived from its 

material properties. On the outside, the cask is protected by multi-layer epoxy resin 

(or comparable coating) with protective properties. 

After loading, the cask cavity is vacuum-dried and filled with inert gas; this prevents 

corrosion and improves heat transfer in the cask cavity. 

Fuel Basket: Each fuel assembly is positioned separately in a hexagonal aluminium pocket built 

into the basket. 

The fuel basket guarantees a sub-critical arrangement and provides fuel assembly 

support during loading, storage and transfer even under worst case accident 

conditions. Borated steel sheets permanently fixed between the profiles ensure the 

sub-criticality. 


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Lid System: The CONSTOR cask is equipped with a triple barrier closure system. This system, 

together with the double-barrier design of the cask body, ensures zero-release of 

activity. The lid-system consists of: 

• the primary lid, sealed by elastomer O-ring (a gas tight barrier for cask handling, 

transport and preparation until welding of the seal plate); 

• the welded seal plate (the first gas-tight barrier for storage); 

• the welded secondary lid (the second gas-tight barrier for storage). 

The primary lid is made from carbon steel and is covered with a corrosion protection 

layer. It is 315 mm thick, which ensures mechanical strength and sufficient shielding 

for cask preparation after loading. It is bolted to the cask body. In the lower surface 

of the primary lid, a groove is machined for holding an O-ring elastomer seal to 

ensure the sufficient leak-tightness after cask loading during cask preparation for 

storage, including welding of seal plate. The primary lid has a penetration used for 

de-watering, drying and filling the cavity with inert gas. This penetration is closed 

and sealed with a flange which is equipped in the same way as the primary lid with 

an O-ring seal. 

The seal plate, as the first leak-tight barrier for storage, is also made from carbon 

steel. It is positioned above the primary lid and welded to the steel head ring of the 

cask body. 

The secondary lid, providing the second leakage barrier, is positioned above the 

seal plate and is also welded to the steel head ring. 

The welds of the seal plate and secondary lid are each surrounded by a groove to 

facilitate horizontal ultra-sonic weld inspection of the multi-pass welds. 

Thin shim-sheets are arranged between primary lid and seal plate, and between 

seal plate and secondary lid, to spread load in the case of accidents involving 

impact. 

The combination of welded seal plate and welded secondary lid guarantees a full 

metal double containment system during long-term storage. The proper function of 

the multi-layer welds is controlled by means of non-destructive testing. With the 

welded lid system, the CONSTOR casks can be stored without active continuous 

monitoring. 

Trunnions: Two trunnions for cask handling operations are attached with screws to the head 

ring of the cask body. The trunnions are made from carbon steel with metallic 

corrosion protection. 

1.2.1.4 DSF building 



The project is divided into two stages: 







The necessary infrastructure for operations under Stage I will be erected first together with some 

provisions for the Stage II (e.g. space for switchboards, structural consideration of the extensions joints 

etc.). For the subsequent extension to the storage area, the building will be designed to allow for 

construction to be carried out without disruption of the normal operation. 

The DSF is divided into two basic operating areas: Reception Hall and Storage Hall. 


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The Reception Hall includes: 

• a controlled transport corridor with an impact limiter built into the floor (to protect the cask in the event 

of a drop); 

• a room for the instruments measuring aerosol and gaseous activity in the extracted air; 

• a workshop; 

• storage rooms; 

• a room for cables; 

• an electrical switch room; 

• personnel entrance; 

• staff welfare facilities including toilets and a changing room with health physics control and showers. 

The Storage Hall serves for storing of the CONSTOR casks is naturally ventilated (it provides sufficient 

cooling of casks). The adjoining Reception Hall is separated by shield wall with a sliding shielded door for 

moving the casks in and out. Handling of the casks is carried out using an overhead crane. 

The basic data of the storage building are given in the following table: 

Tab. 1.2.1.4 Basic building parameters 

Stage I (initial) Stage II (final) 

Usable floor space of the store ca 500 m 2 

ca 2680 m 2 

Capacity of the store (No. of the casks) 34 WWER-440 96 WWER-440 

132 WWER-1000 

Height of eaves ca 15.50 m ca 15.50 m 

Height of crest ca 19.50 m ca 19.50 m 

Length without shielding walls ca 45 m ca 136 + 38 m 

Width without shielding walls ca 28 m ca 28 m 

Inner width of the store ca 26.20 m ca 26.20 m 

The building design and its location are shown in the following figures (for larger scale see Attachment 1). 


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Fig. 1.2.1.4-1 DSF general arrangement - Stage I (M 1:1000) 


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Fig. 1.2.1.4-2 DSF general arrangement - Stage II (M 1:1000) 


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Fig. 1.2.1.4-3 DSF ground floor - Stage I (M 1:500) 


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Fig. 1.2.1.4-4 DSF sections - Stage I (M 1:500) 


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Fig. 1.2.1.4-5 DSF views - Stage I (M 1:500) 


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Foundations and Floor Slab: The floor slab, constructed of concrete will be designed against static loads 

from the casks, dynamic loads from earthquake and impact from explosion (as with 

all other parts of the building). A covering layer will be applied to the floor surface. 

The slab joints for the Stage II extension will be designed to allow a construction of a 

continuous slab. 

Reception Hall: The building structure will be constructed with a mixture of reinforced concrete 

columns and welded steel profiles (in accordance with Bulgarian standards). 

Alternatively the construction can be designed entirely in reinforced concrete. 

Weather protection and thermal insulation of the building will be achieved with 

corrugated steel sheet cladding with non-flammable insulation. The louvers in the 

wall are fitted with roller blinds for winter operation. 

The internal walls are masonry, using siporex moulded bricks or similar. For rooms 

that will be occupied for a lot of time the ceiling is covered with thermal insulation 

and a protective layer of concrete. 

For protection of the casks during transfer from the truck to the cask maintenance 

room, an impact limiter is inserted in the floor plate. Floors of the closed rooms in the 

reception area are covered with anti-static material. The electrical switch-gear and 

distribution boards have false floors to accommodate cable runs. The floor in the 

transport corridor is covered with a dust repelling impregnation. 

The storage hall and the entrance gate to the transport corridor are fitted with 

a sliding door. 

Storage Hall: The storage hall, walls and floor, have the same construction as the Reception Hall. 

1.2.1.5 DSF building services 

The floor slab is epoxy-coated. The outer surface of the casks is heated by the 

decay heat of the fuel to up to average temperature 60 °C (design temperature is up 

to 90 °C) and over a long period of time this could degrade the epoxy. Therefore, 

spacers of an insulating material are placed under the casks to protect it. These 

spacers are grids made from 30 mm thick phenolic resin/glass fibre composite which 

are placed on the floor underneath the casks. 

For Stage I, the shield walls are +9,0 m high and are integrated into the building 

structure. For Stage II, the shielding height must be increased and the wall is 

extended to the roof level. This is why there is an external shielding wall running 

along the side of the building, blocking radiation coming through the ventilation 

inlets. This provides a consistent appearance to the facility when completed. 

At the end of the Storage Hall, as it is constructed for Stage I, are pre-cast 

reinforced concrete wall elements. The height of the wall suits the building crane 

and meets the primary shielding requirements for Stage I, and also for the Stage II 

when the wall elements will be transported to the final position. This construction 

allows the extension to be erected without affecting storage operations. 

The crane supports are conventional rails mounted on a massive steel beam. 

As stated previously, the ventilation works on the principle of natural convection 

through inlet vents along the side of the building and outlets in the roof. All these 

openings may be closed using electrically powered actuators. 

The building is equipped with a potable water source, waste water sewerage, rain and surface water 

drainage, heating, ventilation and air conditioning, power supply, low-voltage installations (telephone 

installation, IT cabling, fire alarms and surveillance/fence/conduit systems), lightning protection and 

earthing equipment. 

Waste water from the controlled area will not be fed directly to the sewerage system, but will be collected 

in the tank. The content of the tank will be checked for the activity and then allowed to flow to the sewerage 

system or sent for treatment, if necessary. 


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There are no demands for a fire water supply. The internal protection is achieved using mobile 

extinguishers, overall protection of the building and infrastructure is the responsibility of the fire brigade. 

Outside the DSF there is sufficient access for the fire brigade to deploy. To prevent fire starting and 

spreading various measures are considered. For the building, source of fire will be restricted to a few areas 

where an efficient design allows it to be extinguished without spreading. Material will have as a minimum 

the classification of "hard inflammable", while most will be "non combustible". The specification of 

equipment takes into account early fire detection and alarms. In both areas (reception and storage) as well 

as in all closed rooms, a system of a fire indication is specified. 

1.2.1.6 DSF radiation protection 

The first consideration when designing any spent fuel storage is to ensure the protection of the personnel 

and the general population. This includes control of ionising radiation and the prevention of the spread of 

contamination in both normal and accidental conditions. This includes: 

• supervising and monitoring access to areas within the facility; 

• minimising work times in a radioactive environment; 

• protecting personnel and public from exposure to radiation; 

• designing components and equipment which may contain or handle radioactive media to ensure safety 

under normal operation and accident conditions. 

The measures for the achievement of these targets will include: 

• a capability to monitor safety-related components; 

• adequate shielding of the casks and buildings protecting personnel and public under both normal and 

accident conditions; 

• multiple barriers to prevent radioactive releases to the environment under both normal and accident 

conditions; 

• prevention of damage to safety-related items from failure of adjacent non safety-related equipment; 

• maintenance operations designed according to ALARA principle. 

The radiological impact on personnel, the general public and the environment under normal operation and 

design basis accident conditions does not result in exceeding the established limits of the exposure doses 

to the personnel and the general public (in accordance with Bulgarian regulations). The following radiation 

levels will not be exceeded: 

Tab. 1.2.1.6 Equivalent dose rate limits for the personnel and population 

Equivalent dose rate at the surface of the cask max. 2 mSv/h 

Equivalent dose rate at a distance of 1 m of the cask max. 0.1 mSv/h 

Equivalent dose rate in the facility - serviced areas max. 5 µSv/h 

Equivalent dose rate in the facility - semi-serviced areas max. 10 µSv/h 

Equivalent dose rate within site limits (controlled areas) max. 1 µSv/h 

Equivalent dose rate beyond site limits (monitored areas) max. 0.025 µSv/h 

KNPP has implemented internal requirements lower than the national requirements. In accordance with the 

Bulgarian Basic Rules for Radiation Protection KNPP has developed applicable dose limits: 

• yearly individual effective dose is limited to 12 mSv for KNPP personnel; 

• yearly individual effective dose is limited to 15 mSv for maintenance personnel; 

• daily individual cumulative dose is limited to 0.1 mSv for personnel in the controlled area without 

a radiation work order; 

• daily (a shift) individual cumulative dose is limited to 0.2 mSv for personnel at the RAWF and the WSF 

with a radiation work order. 

1.2.1.7 DSF nuclear safety 

The DSF technology - CONSTOR casks - meets all the standards of IAEA (and Bulgarian standards as 

well) for storage packages. Casks design provides the sub-criticality of the stored fuel, the integrity and 

tightness of the cask, the shielding and the heat dispersion even in case of accidental conditions. 


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The dry storage concept for the spent nuclear fuel is based on the principle of passive safety, i.e. once the 

full modular storage casks are in their final placement within the DSF they are ‘inherently’ safe. This level 

of safety is achieved by using the principle of defence in depth, where the spent fuel is enclosed within a 

sealed, multiple barrier storage cask. In addition the spent nuclear fuel is stored in a manner that is subcritical, 

cooled only by natural air convection, adequately shielded, gas tight and easily inspected. Thus, for 

the duration of the storage period, no physical intervention is required for maintenance or inspection. 

In terms of the nuclear safety assessment, the main hazards arise from the handling of full storage casks 

within the DSF and transferring full casks from the current WSF to the DSF. Other hazards may arise from 

external events, e.g. fire or earthquake that have no connection with the DSF. 

Kozloduy NPP and the existing WSF have been operational for many years. During this period an 

extensive body of practical experience has been gained on the site that complements theoretical 

assessments of nuclear safety undertaken by the designers of the DSF. Qualified staff will be available 

from the KNPP site for the operation of the DSF. While the existing units at KNPP were not designed to 

accommodate a DSF, and are currently operating using the WSF concept, the fuel route operations at 

KNPP can be changed to accommodate the DSF concept. The operation of the DSF will achieve, and in 

the longer term is expected to exceed, the level of safety demonstrated at the existing WSF. The existing 

nuclear safety arrangements on the KNPP site can be incorporated into the operation of the new DSF 

without significant modifications. 

The nuclear safety of operations associated with the DSF is assured in the design process: 

• The design of the modular spent fuel storage casks ensures that no release of radioactive materials 

will occur, even under accident conditions, such as earthquake, drop load etc. 

• The design, construction and operation of the DSF are consistent with currently accepted principles 

and best international practice. 

• Steps were taken to anticipate potential incidents and accidents during DSF operations. Provisions 

have been put in place to further reduce the likelihood of such occurrences. Such provisions include 

operational constraints within the DSF, e.g. imposing maximum lift heights. 

• Assuming the failure of all such provisions, any adverse consequences for the environment are shown 

to be prevented. 

The high level of safety and radiation protection is achieved by high standards of design and construction 

which include the ‘zero-release’ concept utilised in the storage casks. The casks are designed to fulfil their 

safety related functions throughout the intended storage period (of 50 years) and for all design basis 

accident conditions. 

The analyses of design basis accidents are described in the chapter 4.1.3. Possible impacts resulting from 

accidents (see page 83). 

1.2.1.8 DSF physical protection 

The physical protection system will be in compliance with the Vienna Convention on the Physical 

Protection of Nuclear Material and Regulation of the Nuclear Regulatory Agency for Assurance of the 

Physical Protection of the Nuclear Facilities, the Nuclear Material and the Radioactive Materials [L.25]. 

Since the DSF will be located inside the existing NPP perimeter, the major requirements of the above listed 

regulatory documents are fulfilled. However, the following specific requirements will be respected: 

• Along the inner side of the inner NPP perimeter fence an asphalt-paved road at least three meters 

wide will be constructed for alarm assessment, surveillance, response and maintenance. 

• The DSF will be surrounded with a physical barrier at distance at least 3 (three) meters to the new 

facility. This physical barrier will enclose both the existing WSF and the new DSF (further WSF/DSF 

fence). 

• The WSF/DSF fence will have the same characteristics as the existing one and will be compatible with 

the existing WSF fence system. 

• The WSF/DSF fence will have at least two (2) independent pedestrian and vehicle access points to 

comply with fire protection and emergency regulations. All access points will be equipped with access 

control (security) systems necessary for normal operation or emergency access. 

• The distance between the existing and new buildings will be at least 6 (six) meters. 


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• On-Site communications, security lighting, surveillance equipment and alarm systems for the facility 

will be provided. 

• Facilities for the installation of IAEA safeguard equipment and the interfaces and support needed for 

that equipment will be provided. 

1.2.1.9 DSF monitoring systems 

The CONSTOR casks have a welded redundant lid system and as such do not require active continuous 

monitoring. However, the modern standards for a major spent fuel storage, designed to operate for at least 

50 years, requires a monitoring system that can detect a release of radioactivity. For this reason the 

radiation monitoring system able to detect small increases above the background radiation is proposed. 

The suggested design includes an air monitor as well as a radiation monitor. This monitoring system would 

indicate an onset of cask's leakage and allow an early remedial action. 

1.2.2 Steps of the investment proposal 

The exact schedule of the individual activities (construction process, operation, decommissioning, 

restoration and/or further usage of the site) has not been defined yet. 

The preliminary general schedule is as follows: 

construction phase: 2006 - 2008 

operation start: 2009 

decommissioning: after 2059 

The storage period will be minimally 50 years. 

1.2.3 Description of main construction processes of DSF and of the utilised 

resources 

The exact schedule of the construction works, the construction methods and the amount of building 

materials to be used have not yet been defined. 

Dry Spent Fuel Storage Facility is a relatively simple and small building. The demands for the amount of 

raw materials, energy resources and manpower resources etc. are not exceptionally large and are broadly 

comparable with similar buildings in the energy sector and industry. 

Building and construction materials used are commonly available. From this point of view the demands on 

the natural resources are insignificant. The construction site is located in a flat terrain and therefore there is 

no need for the landfills or major excavations. 

All the necessary energy, water and other supplies for the building or construction purposes are available 

at the KNPP site. 

The building and construction activities will be concentrated on the DSF site within the NPP site. The road 

access for the related traffic is provided using the existing internal roads at the NPP site, the NPP gate with 

security control and external state roads. 

1.2.4 Description of the main processes during DSF operation and 

decommissioning phases as well as the utilised resources 

1.2.4.1 DSF operation 

DSF operation will consist of several partial operations: 

• receipt of the new cask, 

• transport of empty cask from the DSF to the WSF, 

• cask loading, 

• transport of loaded cask from the WSF to the DSF, 

• storage of the loaded casks. 


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All the operations are described below: 

Receipt of the new cask 

New casks will be delivered to Kozloduy NPP dock by barge, then by transporters to the DSF. Cask 

reception in the DSF comprises of the following activities: 

• entry checks in the Reception Hall of DSF (visual check for damage and dirt, cask check for 

contamination, lid seal checked for integrity), 

• transfer to the Storage Hall of DSF using the overhead crane, 

• temporary storage at normal cask storage locations. 

Transport of empty cask from the DSF to the WSF 

Transport of empty cask from the DSF to the WSF comprises of the following activities: 

• transfer the cask from the storage position in Storage Hall to the Reception Hall, using the overhead 

crane, 

• check the cask for contamination, 

• loading the cask on the transporter, 

• transport of the empty cask to the WSF. 

Cask loading 

The cask loading in the WSF consists of the following activities 1 : 

• place the cask on the cask preparation position, 

• remove the protection plate and primary lid from the cask, 

• fill the cask cavity with de-ionised water, 

• transfer the cask to the loading position in the WSF pond (level -6.900 m), 

• transfer the spent fuel assemblies individually from the WSF pond to the cask, 

• place the primary lid temporarily on the cask and lock it to the cask using three locking bolts, 

• move the cask to the pond level +3.600 m, 

• remove three locking bolts and finally bolt the primary lid, 

• decontaminate the cask, 

• transfer the cask to the preparation position, 

• de-water the cask (dried by vacuum) and fill with helium, 

• test the leak-tightness of the cask, 

• measure the contamination, radiation doses and surface temperature, 

• place and weld the seal plate and the secondary lid to the cask. 

The cask handling in the WSF is shown in the following figure: 

1 More detailed description of the cask loading/unloading sequence in the WSF is given at the following pages. 


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Fig. 1.2.4.1 Cask handling in the WSF (no scale) 


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Loading 

The empty cask, fixed in the tilting frame, arrives on the KNPP internal trailer below the hatch (Fig. 1.2.4.1, 

Pos. 4) in the wet storage facility handling hall. 

Then the cask is lifted into the upright position by simultaneous lifting of the crane and displacement of the 

trailer (by means of the existing cable line drive). 

The cask is now placed at one of the cask preparation positions Fig. 1.2.4.1, Pos. 5), which is equipped 

with a bottom shock absorber. 

Next, the cask is prepared for loading. This includes the following operations: 

• attaching the shock absorber to the cask, 

• removing of the protection plate from the cask, 

• unbolting of the primary lid, placing three guiding dowels and removal of the primary lid from the cask, 

• connecting the plastic contamination protection skirt to the cask and bottom shock absorber, 

• fitting of protective covers on the cask surfaces for the primary lid seal and welding area and fitting of 

guiding devices for under-water placing of the primary lid, 

• filling of the cask cavity with de-ionised water. 

Then the cask is transferred to the loading position in the pond (Fig. 1.2.4.1, Pos. 2). The lowering of the 

cask into the pond is performed in steps according to the stepped pond bottom. Starting with the insertion 

of the cask into the water, the contamination protection skirt is successively filled with fresh water. 

In the next step, the spent fuel assemblies are individually transferred from the baskets arranged in a 

separate pond (Fig. 1.2.4.1, Pos. 1) to the cask. 

After completing cask loading, the protection cover of the primary lid bearing surface is removed from the 

cask (by means of thin, long ropes) and the primary lid is placed on the cask. Now the primary lid is locked 

to the cask by means of three locking bolts. These bolts are slidably attached to the primary lid and 

screwed to the cask by means of an extension rod from the pond working platform. 

Then the cask is transferred by stepped lifting and displacements to the pond position 3.600 m (Fig. 

1.2.4.1, Pos. 3). There the water level in the cask is lowered a few centimetres below the primary lid, the 

three locking bolts are removed and the primary lid is finally bolted. 

Next, the cask is transferred to a preparation position (Fig. 1.2.4.1, Pos. 5). There the cask is prepared for 

storage in two main steps. 

In the first step, the cask is drained, dried by vacuum and filled with helium. Two cartridges filled with water 

adsorbing material are inserted into the cask cavity. Then leak-tightness testing of the primary lid is 

performed. For drying and leak-tightness tests a special lid is temporarily placed on the cask. The 

contamination protection skirt is removed from the cask, the connection between bottom shock absorber 

and cask is unlocked and measurements of non-fixed surface contamination, radiation doses and surface 

temperature are performed. 

In the second step, the seal plate and the secondary lid are welded to the cask. Afterwards, the IAEA 

stamp seal is attached to the cask and the cask is transferred to the DSF. 

In the scheduled annual campaign – consisting of the transfer of 420 WWER-440 spent fuel assemblies 

(corresponding to five casks) to the DSF - parallel work at two cask preparation positions is provided. 

Unloading 

Fuel retrieval is achieved by under-water unloading of casks in the WSF. 

In this case, the loaded cask arriving from the DSF is placed at a preparation position (Fig. 1.2.4.1, Pos. 5). 

There, the welds of the secondary lid and the seal plate are removed by means of a milling device. During 

the removal of the weld of the seal plate, air is sucked from the cask lid area via the exhaust duct of the 

WSF ventilation system. After removal of the seal plate, the cask cavity is evacuated via the off-gas system 

of the WSF ventilation system, and filled with fresh nitrogen. 

The cask is then equipped in a similar way as for loading with bottom shock absorber, contamination 

protection skirt, guiding equipment for primary lid and is filled with water using the existing systems for 

water supply and gas and steam releasing (gas and steam are released to the ponds). 


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Subsequently the cask is transferred to Pos. 3 (see Fig. 1.2.4.1) to unbolt the primary lid. Then the cask is 

transferred to Pos. 2 (see Fig. 1.2.4.1). After removal of the primary lid, the spent fuel assemblies are 

transferred from the cask to the baskets arranged at Pos. 1 (see Fig. 1.2.4.1). 

After being withdrawn from the cask, the leak-tightness of the cladding of a spent fuel assembly can be 

verified by sipping. The sipping device consists of 

• a casing, which is arranged in the pond beside the cask and encloses the fuel assembly during the 

sipping process, 

• a measuring system located on the floor of the hall. 

After unloading, the cask will be drained and after replacing of the primary lid, vacuum dried. Then it can 

be replaced at a DSF storage position awaiting preparation for the re-use (e.g. for storage of reprocessing 

waste) or decommissioning. 

Transport of loaded cask from the WSF to the DSF 

Loaded casks, dried and checked in accordance with checking instructions, and all lids welded are handed 

over in the WSF Transport Corridor for transport into the DSF. Transport will take place in the following 

sequence: 

• load the cask on the transporter, 

• transport the loaded cask to the DSF, 

• entry checks on the cask at the DSF, 

• transfer the cask to the storage position in the Storage Hall. 

Storage of the loaded casks 

Casks remain in the storage positions in the Storage Hall for whole storage period, i.e. 50 years. 

1.2.4.2 DSF decommissioning 

Casks 

After the closure of DSF, the casks can be reused for storage of spent fuel or storage of radioactive waste 

or they have to be decommissioned. 

Reuse of the cask reuse requires some refurbishment work, e.g. inspection, possible renewal of the outer 

coating, replacement of lid gaskets, replacement of seal plate and secondary lid etc. For other applications 

e.g. for storage of wastes from fuel reprocessing or storage of wastes from KNPP decommissioning, casks 

have to be equipped with a basket adapted for such an inventory. 

In case that casks have to be decommissioned, the cask radioactivity has to be assessed. The expected 

activation induced by neutron flux in the cask materials is well below the limit of exemption from regulatory 

control and requires no special measures for decommissioning and conventional disposal. Contamination 

of the cask cavity, basket and primary lid requires separation of all detachable parts from the cask, 

dismantling of the basket, contamination control and decontamination of contaminated surfaces. Small 

parts, for which decontamination work would not be an economic procedure and the removed cask surface 

coating, will be disposed as radioactive waste. 

After completing decontamination work, the outer liner of the cask body will be dismantled and the 

concrete filling will be removed and disposed as conventional waste. The metallic materials of the cask 

body will be recycled. 

Buildings and systems 

Contamination of the DSF can be practically excluded. The spent fuel assemblies, the only radioactive 

material to be handled and stored in the DSF, are permanently enclosed inside the gas tight casks. If 

unacceptable contamination is detected on equipment or building structure, this will be removed by 

standard procedures (e.g. suction, wiping, wet wiping and disintegrative surface removal). 


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All exposed surfaces (roof panels, walls, ceilings, floors, roads, surfaces of equipment etc.) will be 

measured and samples taken to verify if there is residual contamination. Regarding any hidden materials 

(insulation, surfaces below coatings, tiles, double floors, cables and pipes in channels etc.), representative 

samples will be taken. The sample will also be taken from the groundwater as well as soils at different 

levels. 

After measurement has shown that negligible contamination is present, equipment and the building 

structure will be released from radiological controls. The usual methods of the dismantling and demolition 

will then be applied. 

1.2.5 Other activities, related to the investment proposal 

No extra activities will be carried out in connection with the investment proposal. 

All the necessary energy, water and other supplies are available at the NPP site for the DSF construction, 

operation and decommissioning, i.e.: 

• sewage connection, 

• nitrogen (available in standard bottles), 

• electricity (0.4 kV, 630 kVA, Auxiliary Building 2 - west side), 

• pressurised air (utility duct from Turbine Hall Unit 4), 

• potable and service water (duct at the Trailer Maintenance Shop), 

• road system, 

• other (chemicals, steam, telecommunication lines etc.). 

The DSF will be integrated into the following procedures of Kozloduy NPP: 

• Radiation and Non-radiation Monitoring Programme for KNPP site and surrounding environment, 

• Complex Programme for Radwaste Management, 

• Non-radioactive Waste Management Programme, 

• System for Separate Collection of Conventional Waste, 

• Emergency Plan, 

• Fire Protection System, 

• Physical Security, 

• Measures for Occupational Health and Labour Safety. 

In accordance with the National Strategy for Spent Nuclear Fuel and Radioactive Waste Safe 

Management, approved by the Bulgarian government, the existing WSF will remain part of the back-end of 

nuclear fuel cycle. The spent nuclear fuel will be transported from the reactor units 1 - 6 to the WSF. This 

operation has been already assessed 1 and approved and therefore it is out of the scope of this report. After 

a period of time in the WSF, the spent nuclear fuel will be loaded into the casks and transported to the 

DSF. 

1 The issues of the current KNPP operations has been assessed in the EIA Report on Kozloduy NPP, 1999 [O.9]. 


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2 

PART II - ALTERNATIVES OF SITING AND/OR ALTERNATIVES 

TO THE TECHNOLOGIES PROPOSED BY THE CLIENT 

AND THE JUSTIFICATION OF THE CHOICE MADE 

The EIA report is focused on one location of the DSF i.e. inside the KNPP site and one type of technology 

i.e. dry spent fuel storage facility, using CONSTOR casks. This option is called "Alternative 1". 

Apart from the Alternative 1, the "Zero alternative", which means non-realisation of the DSF, is also 

considered. 

For the completeness other options of dealing with the irradiated or spent nuclear fuel are discussed in 

general terms under the heading "Other alternatives". 

2.1 ALTERNATIVE "1" 

The alternative "1" is in accordance with the National Strategy for the Safe Management of Spent Nuclear 


2.1.1 Site selection 

DSF site location has been selected in accordance with the Bulgarian legislation and IAEA documents, and 

on the basis of “Site selection for dry spent nuclear fuel storage facility in Kozloduy NPP”, developed by 

EQE Bulgaria [O.25]. 

The Site Selection was defined by the following priorities: 

• protection of the population and the environment from the radiological consequences of radioactive 

releases in case of accident in the DSF, also taking into account releases during the normal operation 

of the facility; 

• timely provision of the necessary storage capacities for Spent Nuclear Fuel in Kolzoduy NPP, using a 

cost effective and socially acceptable approach. 

The site selection has been performed following specific criteria by means of structural and infrastructural 

analysis of the general layout of Kozloduy NPP and the adjacent territories. The following sites for DSF 

have been considered: 

Site No. 1 located west of the existing wet storage facility (WSF) building and within the 

boundaries of Kozloduy NPP site. 

Site No. 2 located south-west of the Checkpoint-4 (EP-2), in close proximity to the Kozloduy 

NPP site, i.e. on the opposite side of the road (south of the Regional Service for Fire 

Protection). 

Site No. 3 located south-east of the Kozloduy NPP site, it is close to he site boundary but 

outside (the old greenhouses). 

The choice of the most appropriate site is based on a generalised evaluation of the acceptability of the 

proposed sites for the DSF in terms of nuclear safety, taking into account the following aspects: 

• Effect of external events on the safety of the DSF (factors of natural or man-made origin). 

• Characteristics of the site and its surroundings, which can help the migration and accumulation of 

radioactive substances from radioactive discharges. 

• Concentration and distribution of the population and other characteristics of the special statute areas, 

as far as they can influence the possibility of applying measures for protection of the population in case 

of accident in the nuclear facility, and the necessity to evaluate the risk for separate persons and for 

the population in general. 


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The evaluation is performed according to safety considerations, economical and organisational indicators 

and considerations for safe environmental management in the region of Kozloduy NPP and social 

acceptability aspects. 

On the basis of the generalised comparative analysis, Site No. 1, located west to the building of the 

existing WSF within the boundaries of Kozloduy NPP site has been chosen as being the most appropriate 

one. A site selection permit has been obtained for this site. 

2.1.2 Technology selection 

The concept is based on the dry cask storage technology. This concept comprises a cask storage system 

with natural convection air cooling. 

The proposed technology has the following advantages: 

• The cask storage system divides and separates the total activity of the spent nuclear fuel in the facility 

into discrete groups of fuel assemblies. Each group is safely contained within a shielded, gas-tight, 

robust and accident resistant cask that can be easily inspected. 


materials will occur ("zero-release concept"), even after a low-probability event such as impact or 

earthquake. 


from there by natural air convection. No active systems to dissipate the decay heat are required during 

either normal or accidental conditions. 


cavity. Even after a lengthy storage period, the condition of the fuel assemblies allows safe handling 

and transport. 

• The spent fuel assemblies are located inside the cask in a structure which guarantees sub-criticality, 

even under accident conditions. 



• No secondary waste is generated by the cask during the long-term storage period. 

The DSF technology is well-tried world-wide as a reliable and safe way of storing the spent nuclear fuel. In 

comparison with the existing WSF technology offers a higher safety (due to the casks and passive cooling 

system) and lower risk of fuel elements corrosion. 

2.2 "ZERO" ALTERNATIVE 

The zero alternative is to not implement the investment proposal. 

The Kozloduy NPP has been producing quantities of spent fuel that must be treated in an appropriate way. 

Therefore the "zero" alternative, i.e. not building the DSF, does not offer a solution as the irradiated fuel 

still needs to be stored in another storage facility in other locality or using other technology. 

Taking into account the insignificant impact of the proposed DSF on the environment, there are no 

significant differences on the quality of surrounding environment between the Alternative "1" and 

Alternative "zero". 

Further, the "zero" alternative does not meet the National Strategy for the Safe Management of Spent 

Nuclear Fuel and Radioactive Waste (Ministry of Energy and Energy Resources, December 2004). 


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2.3 OTHER ALTERNATIVES 

Other alternatives that could be considered in a general way, such as extension of the wet storage facility, 

transport of the spent fuel abroad, reprocessing of the spent fuel, utilising a some new technologies and 

other similar options, are beyond the scope of this report. They are not in compliance with the National 

Strategy for the Safe Management of Spent Nuclear Fuel and Radioactive Waste (Ministry of Energy and 

Energy Resources, December 2004) and are not followed any further. 

Extension of the wet storage facility (WSF). This option had been rejected mainly due to a larger 

production of radioactive waste from the water treatment and radioactive releases 

(even if it is an insignificant amount). The DSF with its passive cooling system is 

considered to be safer than the WSF. Also the risk of corrosion of the fuel rods is 

higher in WSF than in the DSF. 

Transport of the spent fuel abroad. Export of the spent fuel to another country is not a viable option for the 

future. No advanced country allows import of the spent fuel for the purpose of 

storing, except for the purpose of reprocessing. In the latter case, the high-level 

waste has still to be taken back and stored. 

Spent fuel reprocessing. Bulgaria does not have its own reprocessing facility. Reprocessing in other 

country (Russia, France or UK) was rejected due to high expenses. But even in the 

case of reprocessing the high-level radioactive waste must be taken back and 

stored. 

Utilising a new technologies. Possible use of a new technologies (e.g. transmutative technologies which 

allow further utilisation of the energy remaining in the spent fuel and shortening of 

the time of radioactive decay) is not considered. Those technologies are a subject of 

research and are not yet available. The DSF will possibly allow the use of such 

technologies when these are fully developed. 


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3 

PART III - DESCRIPTION AND ANALYSIS OF THE ENVIRONMENTAL 

COMPONENTS AND FACTORS AS WELL AS THE MATERIAL AND CULTURAL 

HERITAGE THAT WILL BE SIGNIFICANTLY AFFECTED BY THE INVESTMENT 

PROPOSAL, THE INTERACTIONS AMONG THESE ASPECTS 

3.1 TOPOGRAPHY 

3.1.1 Location 

The KNPP site is located in North-west Bulgaria in the Vratsa District and the municipality of Kozloduy. The 

site is primarily on the land administered by town of Kozloduy and the village of Hurlets. The site is 3.5 km 

southeast of the town of Kozloduy, 4.0 km northwest of the village of Hurlets, 65 km north of the town of 

Vratsa and 200 km north of Sofia. KNPP site location is shown in Figure 3.1.1-1. 

Fig. 3.1.1-1 KNPP site location 

The 1st and 2nd stage consecutive construction of the KNPP has caused insignificant changes within the 

limits of the 3 km hygienic protection zone (HPZ) of the plant. The 3rd stage i.e. the construction of the 

Units 5 and 6, the HPZ touches a small part of the most eastern outskirts of the Kozloduy town. This is an 

industrial zone of the town where Environment Radiation Control Laboratory, oil-station, heavy machinery 

yard and other industrial facilities are located. The distance between the KNPP and the nearest part of the 

built-up area of the town of Kozloduy is 2600 m. Other entities, which are subject to health protection by 

the municipality i.e. schools, kindergartens, hospitals and other buildings, are located beyond the HPZ. 


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3.1.2 Topography 

KNPP is situated entirely on the non-flood plain, single-loess terrace of the Danube river bank at about 

3.5 km from the right bank of the river. The average altitude of the site is +35 m above sea level. The 

region has the following geomorphologic characteristics: flood-plain terrace, terrace recession, non-flood 

plain terrace, principal slope and watershed plateau. 

The flood-plain terrace occupies the lowest part of the Kozloduy low-land, it has an absolute altitude of 

+25-30 m. 

3.1.3 Geological structure 

3.1.3.1 Lithostratigraphy 

The studied site of KNPP belongs to the area of Lom depression (synclinal, trough or edge hollow) in the 

western part of Miziiska platform (Philipov L., etc., 1992). 

The Lom tectonic structure is filled with Neogene and Quaternary sediments situated on Paleozoic, 

Mesozoic and Paleogenic deposits. The Mesozoic is represented by Triassic, Jurassic and the 

Cretaceous. Only neogene and quaternary depositions are relevant to the investment proposal. 

Neogene includes several groups: Deleynska svita (clays with packs of gypsum or anhydrate), Krivodolska 

svita with Rakevski and Lesurski klin (clays), Dimovska svita (detritus limestone), Fourenska svita 

(limestone with sandy-clayish layers), Florentinska (striped clays), Smirnenska with Lehchevski part 

(sandstones and sandy limestone), Archarska (sands with clayish layers), Brousarska (sandy clays, sands 

and lignite coal) and Beloslatinska (sands of different grain structure and clay layers). 

The Quaternary consists of alluvial-proluvial, eolian-alluvial, eolian and alluvial formations. 

• The alluvial-proluvial formations are represented by gravel coarse-grained sands on the surface of the 

right slope of the valley of the rivers Danube and Tsibritsa. 

• The eolian-alluvial formations of red-brownish sandy clays are at the basis of the loess complex. 

• The eolian formations belong to the loess complex. They are represented by clayish loess and loess 

clay containing buried soils of a black type. They are revealed on the surface of the right slope of the 

Danube. 

• The alluvial formations on the terrace of the Danube in the Kozloduy valley consist of gravel with 

different grain structures and with sandy filling, above which there is a clay-sandy layer. At the 

periphery of the valley a belt of sandy clays with loess is formed. 

• The alluvial formations of first and second bay terraces are represented by gravel different in size with 

sandy feeling at the basis and deposited clayish loess. They are revealed in the southern periphery of 

Kozloduyska valley. 

The geological environment around the site of the DSF in KNPP consists of eolian formations under which 

the described sediments before the Quaternary are situated. 

The eolian formations are represented by sandy loess with average thickness Мср = 6.90 m, clayish loess 

with Мср = 2.10 m and loess clay with Мср = 2.40 m. 

3.1.3.2 Tectonics 

On the Mizia platform there are breaking structures with a sub-equatorial and diagonal (Northwest - 

Southeast, rarely Southwest - Northeast) direction settled as lineation at the end of Palaeozoic and the 

beginning of Triassic. The western part of Mizia platform is characterised by weak seismic and seismicdynamic 

activity. 

Around the region of Kozloduy the tectonic processes have ended at the end of Triassic and the beginning 

of Jurassic. There are no gorges of Jurassic - Paleogenic age. The Neogenic and Quaternary sediments 

lie almost horizontally and there is no surface disclosure of tectonic disturbances. 


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3.1.3.3 Engineering - geological conditions 

To explore the conditions of founding and construction of the different buildings and facilities of NPP 

“Kozloduy” a large amount of engineering, including geological studies, laboratory and spot examinations 

has been made. As a result it was found out that the loess massive consists of one-layer falling zone with 

average thickness Нmass ≤ 15 m and coefficient of relative falling of δпрγ ≤ 0.04. The values of the basic 

physical - mechanical parameters are within the following limits: specific density ρs = 2.70 - 2.78 gr/cm 3 ; 

volume density ρn = 1.40 - 1.89 gr/cm 3 ; water contents W n = 10 - 24 %; volume of the pores n = 42 - 54 %; 

index of plasticity Ip = 2 - 19%; grain structure: 200 - 2 mm: 0 - 1 %; 2 - 0.1 mm: 1-25%; 0.1 - 0.005 mm: 

57 - 88 %; < 0.005 mm: 2 - 34 %; angle of internal friction φ = 16 - 290; cohesion С = 10 - 70 kРа. 

3.1.3.4 Physical - geological processes and phenomena 

Falling of eolian formations and the swamping has more significant development in the studied region. 

Most significant products of erosive-accumulation processes are the asymmetric valleys formed with steep 

right shores and slanting left slopes with clearly expressed terraces of the rivers Tsibritsa, Ogosta and the 

Danube with the Kozloduy valley. 

The sliding phenomena are characteristic of the steep right slopes of the rivers Danube, Tsibritsa, etc. 

They are developed in the Quaternary loess formations and the clay-sandy sediments in the Neogene 

underneath. Within the region of KNPP there are no sliding processes and no prerequisites for their 

appearance. 

The falling is an ability of the eolian loess formations in pressed state caused by external loads and/or their 

own weight to subside under moisture. 

The design and construction works are consistent with the falling of the loess deposits. Despite the 

measures for elimination and decrease of the collapsing properties uneven subsiding of the earth base is 

registered but it is within the design limits. 

Swamping is characteristic of the valleys around the Danube - in parts of the terraces behind the protective 

embankments. It is mainly caused by badly supported draining systems. Additional source of swamping in 

the Kozloduyska valley are the channels of KNPP constructed above the level of the ground waters. 

3.1.3.5 Underground natural resources 

Within the proposed DSF site, the KNPP site and the close proximity there are no underground natural 

resources. In the wider area the geological-lithological structure predetermines the availability of only nonmetal 

underground natural resources, i.e.: 

• fossil fuels - oil and gas, lignite coal; 

• building materials - limestone, gypsum, sand, gravel, loess. 

Oil and gas were found in the middle and upper Triassic sediments at depth more than 3500 m and do not 

have a big potential. The gas resource close to the village of Butan is linked to the Triassic system. 

Lignite coal resources close to Kozloduy are at a depth of 70 - 110 m. The thickness of the coal layers 

together with the clay does not exceed 3.0 m. Their deposits have not been explored. 

A study has been made on the considerable lignite coal deposits to the west of the river Tsiribritsa where 

the Lom coal basin is outlined. 

Gypsum can be of industrial interest only in the region of the town of Oryahovo. 

The limestone of Fournenska svita is a decorative construction material and can be easily processed. The 

limestone deposit close to the town of Mizia is also of interest. 

Loess is used for making bricks. There are small quarries close to Kozloduy and Mizia used for local 

needs. 

Sands and gravel are mainly found within the range of the terraces of the rivers Danube, Ogosta, Skut and 

Tsiribritsa. They are mostly extracted along the Danube. 


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3.1.4 Seismic activity 

The region around KNPP has a radius 320 km and is a part of the Alps-Himalay seismic belt, which is 

characterised by high seismic activity. It is related to the well-known seismic-active zones: 

• Sofiiska 

• Gornooryahovska 

• Marishka 

• Kresnenska 

• Negotinska - Kraina 

• Kumpulimg - Vrancha. 

Earthquakes with magnitude М > 5 and depth up to 50 km are generated in these zones, with the 

exception of Vrancha where the depth of penetration was 150 km. 

The site of KNPP is situated in the middle of the stable part of Mizia platform characterised by low seismic 

activity. In the period of instrumental registration of earthquakes (1976-1990) only three earthquakes with 

3,0 < М < 3,6 were registered on the whole territory. No historical earthquakes have been documented in 

this region. Their absence and the weak sporadic seismic activities characterise this zone as seismically 

“most stable” in the 320 km area. 

For the seismic protection of KNPP: 

• a local seismic network with three seismic stations in the village of Malko Peshtene, the towns of 

Valchedrum and Oryahovo has been built; 

• a system for industrial seismic protection (SISP) is mounted on each block, which automatically 

switches off the reactors in earthquakes with intensity above the limit; 

• a system for accelerated graphic seismic control of equipment and constructions (SAGSCEC) has 

been introduced since 1993, including accelerated graphs of the type SMA-1 (4 pieces), SMA-2 (3 

pieces) and SSA (4 pieces), located in the free field on different elevations on the third and fifth blocks 

(EIA, 1999 [O.9]). 

3.2 HYDROLOGY AND HYDROGEOLOGY, SURFACE AND GROUND WATERS 

3.2.1 Hydrological characteristics of the region of KNPP 

No river flows through the territory of KNPP. The closest rivers are Danube, Ogosta and Skut. Due to the 

natural topographic conditions and the distance, these rivers cannot have any influence on the power 

station and on the project for construction of DSF in particular. 

The site of KNPP is situated on the terrace of the Danube. The elevation of the site 35 m above the sea 

level is formed on an area considerable in its size. The power station was designed in this location against 

Danube flood, which occurs once in 10 000 years. 

Embankments are constructed between the site and the river designed for the flow of the 1000 year high 

wave along the Danube with the required normative reserve. The draining systems in the region are 

designed to take away the surface waters from intensive rainfalls with different continuity and rain height of 

probability 0.01% (once in 10 000 years). 

During normal operation (average annual power output 2500 - 3000 MW), the water quantity necessary for 

the cooling system is 110-140 m 3 /s or 2.7 - 3.5 % from the river flow. With regard to the average water 

quantity for many years (5719 m 3 /s) this estimation is 3.1 % for continuous work at full power and 1,9 - 

2,4 % in normal operation regime. 

3.2.1.1 Quality of surface water 

The evaluation of the condition of the surface waters is also mainly connected with the basic water source 

i.e. Danube that is the source of industrial water supply to the station and collector of waste waters. 


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The EIA report for KNPP gives a detailed characterisation of Danube pollution in the region of the power 

station, from the point of view of radiological and non-radiological contamination. The present review 

updates and adds to the previous evaluation. 

Radiation Condition 

The Executive Environmental Agency (EEA) and KNPP both monitor radiation conditions in the area. The 

KNPP monitoring system is integrated with the EEA monitoring system. 

Monitoring held by the Executive Environmental Agency for the period 1999-2004 

The radiological monitoring of the rivers, lakes and dams in the country is carried out through a network of 

inspection points controlling the indexes in accordance with Instruction No.7/08.08.86 for indexes and 

norms determining the quality of running surface waters - total beta activity (750 mBq/l), concentration of 

uranium (0.6 mg/l), concentration of 226 Ra (150 mBq/l). 

The region of KNPP is characterised by relatively low activity, i.e. the concentration of uranium, thorium 

and the products of their radioactive decay are below the average for the country. This is due to the 

prevailing sediment origin of the geological formations, on which the studied region is situated. 

The average concentrations of uranium in the Danube are within the limits of (2.0±0,2).10 -6 g/dm 3 

(25 mBq/dm 3 ). Due to the considerably lower solubility of the thorium compounds the river waters are 

characterised by a lower concentrations, which in the Danube do not exceed 0.1 mBq/dm 3 . Of the products 

of radioactive decay of uranium most important for the Danube is the presence of radium ( 226 Ra) - 

2.7±0,9.10 -13 g/dm 3 (9.7±3,4 mBq/dm 3 ). 

Summarised information from the system of monthly monitoring of Executive Environmental Agency (EEA) 

to the Ministry of Environment and Waters (MEW) for the last five and a half years (1999-June, 2004) 

about the total beta-activity of the Danube and the misbalance waters of KNPP is provided below. 

The monthly radiological control of the waste waters from KNPP includes the following inspection points: 

• The Danube in Kozloduy - port 

• Liquid release, 5-6 block - "clean" zone 

• Liquid release, 5-6 block - "special regime" zone 

• Liquid release, 1-4 block 

• Outlet canal 

• Inlet canal 

• New canal “Valyata” 

• Old canal “Valyata” 

• The Danube in Oryahovo - port 

The total Beta activity of the waste waters in 1999 varies within the limits of 0.055 Bq/l - 0.792 Bq/l. In 

2000: 0.056 Bq/l - 0.522 Bq/l, in 2002: 0.040 Bq/l - 0.483 Bq/l, in 2003: 0.036 Bq/l - 0.337 Bq/l, in the first 

half of 2004: 0.047 Bq/l - 0.173 Bq/l. 

Radiation conditions monitored by KNPP for the period 1999 - 2003 

In order to control the radioactive impact of KNPP to the environment there are three zones defined: 

sanitary protection zone - 3 km, controlled zone - 30 km and observation zone - 100 km from KNPP. 

Periodically the radioactivity of the air, air sediments, soils, vegetation and radiological Gammabackground 

are controlled. In addition samples of water, milk, meat, fish, etc are also analysed. Special 

attention is given to the Danube River, where there are several sampling points along the river course and 

drinking water sources are also controlled. Every year 2300 samples are analysed using standard 

methods. 

In the 3 km protection zone around KNPP continuous automatic control for the radiation dose and content 

of 131 I in the air is carried out by means of 10 monitoring stations. In this system there are also 3 automatic 

meteorological stations as well as 5 water stations that measure the radioactivity of the discharged waters. 


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In the 100-km observation zone there are 36 controlling points, where sampling and measurements take 

place on content of natural and technogenic radionuclides. 

The results of the monitoring of fresh waters in dams or open air reservoirs show that the total Beta activity 

varies from 0.026 to 0.44 Bq/l, which represents less than 60% of the norm (0.75 Bq/l). For the water of 

Danube River the maximum value detected is 0.44 Bq/l. The content of Tritium is up to 10 Bq/l. Relatively 

higher values are detected in the outlet canal of KNPP. The maximum value of 46 Bq/l is far less than the 

norm for drinking water of 100 Bq/l. 

The samples taken and analysed for drinking water from the region show that the total Beta activity vary 

from 0.034 to 0.69 Bq/l. Tritium content is 6.9-13.6 Bq/l. Both parameters are far inferior that the required 

minimum values by the norms - Beta activity



Fig. 3.2.1.1-1 Map of the inspection points on Danube River 

In the studied period the average annual concentrations varied, as follows: 

Tab. 3.2.1.1-1 Annual concentrations in 2002, 2003, 2004 

Index (mg/l) 2002 2003 2004 

Dissolved oxygen 7 - 17 4.5 - 14.5 5 - 10 

BOD 1 - 4 1 - 4 2 - 4 

Permanganate oxidation 2 - 5 2 - 6.5 2 - 8 

NH4 - N 0.01 - 0.1 0.02 - 0.15 0.01 - 0.3 

NO3 - N 0,8 - 3 0,2 - 6 1 - 2 

PO4 0.01 - 0.8 0.01 - 1 0.01- 0.5 

Tab. 3.2.1.1-2 The concentration limits for the different water categories 

Index (mg/l) First category Second category Third category 

Dissolved oxygen (О2) 6 4 2 

BOD 5 15 25 

Permanganate oxidation 10 30 40 

NH4-N 0.1 2 5 

NO3-N 5 10 20 

PO4 0.2 1 2 

The change of the water quality in the Danube is characterised by low variation of the measured 

parameters. The concentrations of BOD, permanganate oxidation and nitrate nitrogen according to 

Instruction No. 7/86 correspond to the quality of first category. The concentrations of dissolved oxygen, 

ammonium nitrogen (< 2 mg/l) and phosphates (< 1 mg/l) vary between Category I and Category II. All 

parameters correspond to the norms for first and second category. 

Non-radiation conditions monitored by KNPP 

In accordance with the KNPP programmes monitoring is carried out as follows: 

• monitoring of surface waters and wastewater 

• monitoring of ground water 

The discharge points for surface and wastewater, where sampling is carried out are shown in Figure 

3.2.1.1-2 below. 


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Fig. 3.2.1.1-2 Map of the Danube basin Scheme of the wastewater discharge from KNPP 

№9 and 10 

WWTC 

EP - 2 

CPS 

№8 

№ DC 1 

№1 

EP - 1 

CPS 

WWTP 

№2 and 3 

№ 

4,5 

,6 

Inlet Canal 

Bank Pumping 

Station 

Outlet Canal (OC) 

Key: 

Controlled Points 

Waste Water 

Danube River Water 

KNPP presented detailed information on the surface water quality data collected by their monitoring 

system. The characteristics of the wastewater/surface water monitored in the period 2002 - 2003 are as 

follows: 

• The values of the major part of the indices in the low-pressure collectors (Discharge 1) and in the OC 

(Discharge 7) are below the Maximum Admissible Concentration (MAC) except for residual chlorine. In 

OC there are some sporadic excess of oil products. There has been no exceeding of the emission 

norms. 

• In the waters of Discharge 2 some disturbance of the index pH have been registered both for the 

background and for the emission norms. 

• Some excess of oil products have been detected in Discharge 3. Only once has the emission norm 

been exceeded. 

• In discharges 4 and 5 high values of pH and suspended solids have been registered, exceeding both 

background and emission norms. 

• In Discharge 6 an excess of MAC has been observed and the emission norm for oil products, residual 

chlorine and suspended solids in rare occasions. 

• In the wastewater of EP-1 discharging into DC1 (Discharge 8) there is frequently an excess of the 

emission norm for nitrite nitrogen and in rare occasions for pH, suspended solids, BOD 5, oil products 

and residual chlorine. 

• In the wastewater after the WWTP for the “clean zone” of EP-2, transported by the collector D300 

(Discharge 9) there is a permanent excess of the norm for nitrite nitrogen and sporadically also the 

values for residual chlorine, suspended solids and oil products exceed the norm. 

• In the wastewater after the WWTP from the SRZ of EP-2 transported by the D1000 collector 

(Discharge 10) only in rare occasions has there been a registered excess of the emission norms for 

residual chlorine and suspended solids and exceeding of MAC for nitrite nitrogen, residual chlorine and 

oil products. 

• In the waters discharging DC1 into the Danube River (Discharge 11) there was an excess of the MAC 

only four times - two times oil products, one time residual chlorine and once nitrite nitrogen. 

For the needs of the ground water monitoring five piezometers have been chosen at the territory of EP-1 

and three piezometers at the territory of EP-2 as shown at the Figure 3.2.3.2-3 below. 

№ 

7 


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Fig. 3.2.1.1-3 Location of the piezometers used for non-radiation monitoring at KNPP 

Storage 

for RAW 

Workshop 

for RAW 

RO 

RO 

Machine 

Building 

Block6 

Machine 

Building 

Block 5 

Machine Building 1-4 

RO3-4 RO1-2 

Special 

Building 

2 Service and 

Admin. 

Building 2 

WSF 

Special 

Building 

1 

Key: 

Service and 

Admin. 

Building 1 

Chemical/ 

Physical 

Treatment 

Controlled Points 

Detailed information on the surface water quality data collected by the KNPP monitoring system is 

available. The characteristics of the ground water monitored in the period 2002 - 2003 are as follows: 

• The values of the controlled parameters do not vary significantly for the whole monitoring period, i.e. 

the water quality is sustainable with the time. 

• For the ground water quality it is typical, that the values exceed the ecological limit for nitrates, 

sulphate ions, pH, iron, manganese and dissolved solids. In some particular areas the ecological limit 

is exceeded also for nitrites, ammonia and chlorine ions. 

• In very limited cases the values exceeded the intervention limit for nitrates, nitrites, iron and sulphate 

ions. 

Conclusion on water quality in non-radiation aspect 

The analysis of the measured parameters of the water quality in the Danube shows that the operation of 

KNPP does not lead to pollution of the river. 

3.2.2 Hydrogeological conditions 

According to the hydro-geological district division of Bulgaria the site of NPP “Kozloduy” is in the Lom subregion 

of the North Bulgarian artesian basin in the Dolnodunavska artesian region. 

The hydro-geological conditions of the Lom sub-region are characterised by different types of ground 

waters - Karst and Karst-fissure in the carbonate sediments of the middle Triassic, the Jura, the 

Cretaceous period and the lower Neogene, and pore in the gravel-sandy deposits of the upper Neogene 

and the Quaternary formations (Antonov Hr., etc, 1980). 

The hydro-geological situation in the region of NPP “Kozloduy” is mainly characterised by pore waters 

forming Gornopontiiski water horizon in Archanska svita and the water-carrying complex in Brusarska and 

Beloslatinska svita in the Neogene, as well as by ground waters in the Quaternary formations. 

The static level of the ground waters on the territory of NPP “Kozloduy” is at a depth of approximately 7,0 

m from the surface. The sandy-gravel deposits have a coefficient of filtration up to 5-8 m/d, the sandy 

loess, through which the water-carrying horizon is fed, has a coefficient of filtration 1.5-2.0 m/d. The 

chemical composition of the water is hydrocarbonate-calcium-sodium and hydrocarbonate-calciummagnesium 

with mineralization of 600-1000 mg/l. 

A 

C 

S 


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The most significant ground water formation in the region is in the alluvial creations of the Danube and the 

Kozloduy valley. It consists of a very permeable sandy-gravel part in the basis and a weekly permeable 

part of sandy clays above it with a total thickness of 8-18 m. It is fed by infiltration of atmospheric rainfalls, 

irrigation waters, ground waters from the south and river waters from the Danube and Ogosta at high river 

water levels. It drains into the Danube at low water levels as well as by means of a draining system and 

water-collecting facilities - pipe and shaft wells. The level of the ground waters is settled in the upper 

sandy-clayish layer at a depth of 0.5 - 4.0 m. The filtration properties of the water-carrying collector are 

considerable and are expressed in conductivity within the range of 150 - 2160 m 2 /d. 

The natural resources of the water-carrying layer are estimated to be approximately 160 - 170 l/s and the 

gravitation reserves are 37.10 6 m 3 . They are used for drinking-domestic needs and partially for 

technological water supply of NPP “Kozloduy”. One shaft-well in the region “Valiyata” and six shaft-wells in 

the terrace of the Danube are built for this purpose. 

3.3 LANDS 

3.3.1 Condition of the natural soils 

DSF site is situated within the KNPP site. That is why the natural soils are not present within the DSF site. 

The local natural soils have been transformed into the anthropogenic degraded soils. These soils have no 

agricultural or biological value. 

The soil types found in the 100-km zone around KNPP are: carbonate humus soils (within a broad strip 

around the Danube river); the typical humus soils (to the south of the carbonate soils and in proximity of 

the middle courses of the rivers Ogosta and Skat); lixiviated humus soils (in the higher parts of the territory 

to the south of the typical carbonate soils); grey forest soils (typically above 500-800 m); alluvial (delluvial) 

meadow type soils (surrounding the rivers Cibrica, Ogosta and Skat and their tributaries); and a small 

portion of the eastern part of the terrain, occupied meadow-swampy soils. The variety of the grey forest 

soils, being a result of the influence of bedrock and elementary soil processes, is supplemented by soil 

varieties showing different degree of erosion and various mechanical compositions. 

The concentrations of radionuclides and the total beta-activity of the bottom sediments of the Danube and 

the inner rivers in the region as well as their changes in time are a very indicative factor determining the 

radioactive condition of the soils. 

Every three months EEA makes a radiological control of soils and bottom sediments from the 30-kilometer 

zone of KNPP including the draining canal and the ports Kozloduy and Oryahovo. 

The measured values of the specific activity of 137 Cs vary from



The comparison of the data for the period 1999-2003 (provided by the KNPP Safety and Quality, and 

Environment Monitoring Departments) with data presented in KNPP EIA-R in 1999 [O.9] and historical data 

prior the commissioning of KNPP has been made. It shows an absence of unfavourable trends in the 

radiation situation and the ecological status of the soils within the 100 km zone surrounding the KNPP as a 

result of the plant operation. 

As a whole the radiological monitoring of the soil and river sediments made by MEW in the period 1999- 

2004 does not show any influence on the environmental components caused by the operation of KNPP. 

3.4 LANDSCAPE 

The site envisaged for the construction of DSF has the following boundaries: to the east - the existing 

WSF; to the west - buildings of the “Atomenergoremont” enterprise; to the north - Auxiliary Building 2. 

As a landscape structure the assessed site represents an industrial landscape, because it is situated within 

the limits of the main site of Kozloduy NPP. 

According to the process-landscape division, the site of Kozloduy NPP and the adjacent terrain fit within 

the landscapes of the meadow-steppe and meadow-swampy alluvial lowlands. The major part of Kozloduy 

NPP occupies an agro- landscape and partially meadow and forest landscapes. 

3.5 CLIMATIC AND METEOROLOGICAL CONDITIONS 

The region around the KNPP is located in the western parts of two climatic regions according to the 

climatic regional division of Bulgaria: the Northern and Middle Climatic Regions of the Danube Hilly Plain 

from the Moderate-Continental Climatic Sub-Zone. 

3.5.1 Climatic elements 

3.5.1.1 Air temperature 

The average annual temperature in the region investigated is within the interval 11.5 ºC to 12 ºC, 

decreasing with the increase in elevation above sea level. The annual variation of average monthly 

temperatures is characterised by a maximum in July (between 23 ºC and 24 ºC) and minimum in January 

(between 0 ºC and minus 0.5 ºC). Average temperatures during the winter season are around 0 ºC, and 

during the summer between 21 ºC and 22 ºC. Autumn is warmer than spring, the difference going up with 

increasing the elevation above sea level. 

3.5.1.2 Precipitation 

The annual precipitation in the region of interest is about 518 - 558 mm, which is one of the lowest in the 

country. This precipitation is distributed non-uniformly though the year. The maximum level of precipitation 

is in May-June, there being a secondary maximum in November. The lowest precipitation is in the autumn 

and winter, the minimum being in October. In the winter the precipitation is about 110-120 mm, which 

represents 20 - 24 % of the annual amount. In the spring those are 135 - 150 mm (27 - 28%), and in the 

summer 145 - 150 mm (28 - 30%). 

3.5.1.3 Wind directions 

The dynamics of air transport in the ground-level layer are characterised by the "wind rose". The "wind 

roses" for localities of Lom, Oryahovo and Kozloduy are shown in the following figures. 


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Fig. 3.5.1.3-1-3 "Wind roses" - Lom and Oryahovo stations and in Kozloduy (for the period from 1977 to 1986) 

Figure 3.5.1.3-1 Figure 3.5.1.3-2 Figure 3.5.1.3-3 

The important characteristics of the wind regime are the frequency of strong winds. Strong wind means a 

wind of a speed equal to or higher than 14 m/s. According to “the Climate of Bulgaria” (1991) [O.23], in the 

region of the KNPP the prevailing strong winds blow from west and Northwest and their frequency attains 

80% (at some places up to 90%) of the occurrences of strong winds (Figure 3.5.1.3-4). According to the 

regional division of the country, presented in the reference mentioned above, the region of the KNPP is 

situated in that wind region of the country, for which the probable maximum speed of the wind may reach 

33 m/s, and the corresponding pressure (or loading), which can be applied by such a wind, may attain 550 

N/m 2 . 

Fig. 3.5.1.3-4 Annual distribution of prevailing strong winds 


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3.5.2 Unfavourable meteorological conditions for the dispersion 

3.5.2.1 Temperature inversion 

Conclusions regarding the presence of a phenomenon of this type may be drawn from the aero-logical 

sounding from the period September 1967 - August 1968, performed in the region of the KNPP (Nikolova, 

1972). 

The inversions have been observed in 30 % of the cases, this percentage being about 37 % during the 

cold half-year and about 22 % during the warm half-year. There have been ground-level inversions in 15 % 

of the cases, their frequency being much lower during the warm half-year - about 7 %, whereas in the cold 

season it is about 23 %. 

3.5.2.2 Air pollution potential 

It is determined by the frequency of the slight winds (occurrences of calm weather and of winds of speed 

up to 1 m/s). According to this parameter, there is a regional division of the country, the western part of the 

Danube Hilly Plain being characterised by poor conditions for pollution dispersion, where the frequency of 

slight winds is 60 - 70 %. The conditions in a narrow strip along the river Danube, which also includes the 

area around Kozloduy, are little bit more favourable and the frequency of the slight winds is 50 - 60%. 

3.5.2.3 Conclusion 

Based on the data and assessments, it is possible to make the following conclusions: 

• The air pollution potential in the region is high or very high, which is also deduced from the neutral to 

slightly stable conditions of the lower atmospheric layer in the region. Therefore, assessment of design 

of industrial and transportation facilities usually need to be performed and permanent monitoring of the 

radioactive pollution of the air is required. 

• In this part of the region along the river Danube, ice formation of ground-level installations may occur 

when any of the following combinations between meteorological parameters is observed: temperature 

of the air between 0 ºC and -2 ºC to -4 ºC, wind speed between 0 and 3 to 5 m/s, and relative humidity 

between 95 and 100 %. 

• Hailstorms causing damages in North-western Bulgaria, have been observed during the period 

between May 5 th and July 31 st . In particular in the area of the NPP it is a random phenomenon 

• The absolute maximal intensity (mm/min) of pouring rains is 3 to 4 times higher than the average 

intensity for precipitation with durations up to 30 minutes. 

• Loading induced by wind and snow are estimated as moderate. 

• The probability for snow storms is much lower than that in the north-eastern part of the Danube plain. 

• Fogs are occurring on average 45 days per year. Their duration is up to one day in 80 % of the 

occurrences in January. 

• No tornado has been registered in the region. Investigations indicate a negligible probability for this 

event to happen (of the order of 10 -6 cases per year). 

3.6 RADIATION BACKGROUND, ATMOSPHERIC RADIOACTIVITY 

AND ATMOSPHERIC AIR QUALITY 

3.6.1 Radiation background 

The radiation background measurement for each region is an important element of the public dose 

exposure estimation. 

The natural radiation background consists of two components - cosmic radiation and terrestrial radiation. 


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The cosmic radiation for each specific location depends only on its altitude and latitude, while the terrestrial 

component is determined by the content of the natural radionuclides in the geological environment and can 

vary widely. 

The contribution of radon gas in the terrestrial component is considerable. The radon exhalation rate, 

which is a heavy inert gas, is strongly dependant on the atmospheric conditions, which will influence the 

radiation background value. 

The radiation background for the different regions in the world varies in widely. 

The natural radiation background of the territory in Bulgaria is in the range of 0.06 - 0.60 µSv/h. It is 

measured constantly since the mid 1980s. 

The National Automatic System for continuous monitoring of the radiation background (NASCMRB) in the 

Republic of Bulgaria was established in 1992. The system was commissioned in 1997. It has a hierarchic 

structure and is computer operated. It consists of a Central monitoring station, 9 regional monitoring 

stations, 26 local monitoring stations, one mobile station, a Crisis centre and one emergency station. 

The Central station carries out the overall administration, management, co-ordination and control of the 

local monitoring and mobile stations work, visualisation of the information under normal conditions. These 

activities are executed by the Crisis centre in an emergency case. 

The way of the creation, support, operation and development of the Automatic system is legally regulated. 

A part of the main monitoring stations of the system are shown on the fig. 3.6.1-1. 

Fig. 3.6.1-1 Location of part of the monitoring stations of the national system for radiation monitoring 

There is information on the natural radiation background caused by the soils and Neogenic rocks and on 

the specific activity of the natural radioisotopes from the period before the NPP construction in the reports 

for the pre-operational measurements, conducted by the National Centre for Radiobiology and Radiation 

Protection in 1972-74, so as in the unpublished exploration reports of the former SC Redki metali. 

The region of the Kozloduy NPP is characterised by relatively low radiation background, i.e. the content of 

uranium, thorium and their decay products are under the average values for the country. This is due to the 

prevailing sedimentogenic origin of the geological formations under the nuclear power plant site. 

There are no registered high values of gamma-intensity in the rocks from the geological cuts in the Lom 

depression in the several hundred uranium exploration drillings with a depth up to 250 m. Radioactive 

anomalies of higher gamma ray intensities are fixed only in three boreholes. 

Three zones around the NPP are estimated for control and environmental impact assessment: the 

sanitary-protective zone with a radius of 3km; the controlled zone, with a radius of 12 km and the 

monitoring zone with a 100km radius around the NPP. Sampling for laboratory analyses for technogenic 

radionuclides in the main environmental components (air, water, soil, vegetation) is carried out in 36 

controlled points. Special attention is given to the drinking water sources and the water from Danube River. 


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A continuous monitoring of the dose exposure rate and 131 I content in the near surface air layer is 

performed in the 3 -kilometre zone by means of 10 monitoring stations of the Automatic Measurement 

System for External Radiation Control (AMSERC) “Berthold”. Three automatic meteorological stations and 

five water station for control of the radioactivity in the release water and waste water from the NPP are a 

part of the system, too. 

The Bulgarian Nuclear regulatory body issued permission to merge the NASCMRB and AMSERC. In this 

way a joint information system for radiation monitoring on national level is created. So the 8 control stations 

from AMSERC of the NPP site and 2 km around it are included in the 26 national monitoring points of the 

national network. The competent authorities such as Nuclear Regulatory Agency etc. can receive real time 

data for the radiation background of the NPP site. 

The average values of the radiation background, registered by the 8 stations of the AMSERC in 2002 are 

shown on the Table 3.6.1. 

Tab. 3.6.1 Radiation background, registered by AMSERC in 2002 (average data, µSv/h) 

KS-1 KS-2 KS-3 KS-4 KS-5 KS-6 KS-7 KS-8 

0.113 0.114 0.116 0.109 0.108 0.109 0.120 0.117 

Additionally to the continuous registration of the natural radiation background, it is measured regularly with 

portable radiometric devices of type СРП-68-01, АD2/ADT and a set of CaSO4: Dy type TLDs, installed on 

the fence of the NPP site. 

The results of these measurements are shown on the fig. 3.6.1-2. It is obvious that the dose exposure rate 

is within the natural radiation background. 

Fig. 3.6.1-2 - Intensity of the equivalent dose of gamma-radiation for the period of 1996-2002 (µSv/h) 

KNPP Fence 

A lot of data from the monitoring systems of the Ministry of Environment and Water, the NPP division 

“Environmental radiation control” and the National Centre for Radiology and Radiation Protection are 

summarised and analysed during the preparation of the Environmental Impact Assessment of the 

Kozloduy NPP in 1999 [O.9]. The emphasis of these analyses was on the site characteristics, the region 

around the site, the sanitary-protective zone and the closest settlements - Kozloduy town and Hurlets 

village. An analysis for the existing data for the Zone for urgent protective measures (30 km) and for the 

part of the Zone for long-term protective measures (especially for the Vratza town region) is performed. 

The State agency “Civil protection” through its stationary posts, 5 of them within the 30 km radius around 

the NPP, executes control on the natural radiation background. Periodical measurements are carried out 

by The National Institute for Meteorology and Hydrology by the Bulgarian academy of Sciences with their 

stations in Oryahovo and Vratza. 

The summarised data from the long-term measurements and monitoring of the radiation background in the 

region of Kozloduy NPP shows that: 

• Over the whole period of the NPP operation, the radiation background in the sanitary-protective zone 

and the zones for the emergency planning is stable with little discrepancies during the Chernobyl NPP 

accident in regard to the other regions of the country. The average values of the radiation background 

before the start up (in 1974) and during the operation of the NPP are approaching and comparable. 

After 1995 with the increasing of the measurement accuracy the radiation background values become 

lower, with a smaller variation of the equivalent dose exposure rate. 


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• The radiation background in the region of the NPP site, in the 30km zone and in the monitored 

settlements in the 100 km radius is lower than in the other regions of the country (Bourgas, Sofia, 

Plovdiv), where the average dose rate is 0.16 µSv/h, and the maximum values are up to 0.20 µSv/h in 

some years. 

• The measured by the Romanian authorities radiation background in the nearest to the Kozloduy NPP 

station on the Romanian Danube river bank varies up to 0.1 µSv/h. 

As a whole the dose exposure rate from the radiation background in the different measuring points has 

small variations, caused by seasonal fluctuations, connected mainly with rain and snowfalls. There are no 

statistically estimated differences in the measured dose rates of the radiation background before and after 

the commissioning of the KNPP. 

The condition of the gamma background in 13 different locations in the country at 9 o’clock on the 13th 

February, 2003 is shown on Figure 3.6.1-3. The data shows the value of the absorbed dose measured in 

these locations. 

Fig. 3.6.1-3 Gamma background 

Oriahovo 

Varna 

cape Emine 

Plovdiv 

Sofia 

Petrohan 

Vratza 

Kneza 

V. Tarnovo 

Montana 

Pleven 

Russe 

Vidin 

0 0.02 0.04 0.06 0.08 0.1 0.12 0.14 

3.6.2 Atmospheric radiation 

µGy/h 

The radioactivity of the atmospheric air is controlled by means of estimation of the concentration of the 

natural and technogenic radionuclides in the aerosols from the air and in the samples of the fallout, 

measured by gamma spectrometry. Such measurements are conducted weekly from the Environmental 

radiation control division of the NPP by filter sampling from 11 control points in 100-km zone around NPP. 

The content of the technogenic 137 Cs in aerosols is closed to the background values and is approximately 

1 - 2 μBq/m 3 . These values are typical for the near ground air layer in these geographical regions and the 

global radioactive contamination of the atmosphere. The total beta activity of the long-lived radionuclides is 

within the natural limits, too, and has an average value of 0.47 mBq/m 3 . The results of the total beta activity 

in the fall out samples from 36 control points in the monitoring zone around the Kozloduy NPP vary in the 

region of 0.025 - 3.0 Bq/(m 3 .d) with annual average values of 0.45 Bq/(m 3 .d). 

The data are stable over a 10 year period with small seasonal variations in the months with more rainfall, 

as is illustrated in Figure 3.6.2-1. 


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Fig. 3.6.2-1 Average values of the long-lived total beta activity of aerosols from the zone of preventive measures 

and the 100 km monitoring zone of the Kozloduy NPP, mBq/m 3 (min/max) 

Years Min 

Max 

The radioactivity of the atmospheric air and the radiation background in the region had been measured 

systematically by different organisations before the start of KNPP construction works. 

From the information gathered from the analysis of the radioactive content of the atmospheric air, 

a conclusion can be made that the operation of the Kozloduy NPP up to now has not affected the radiation 

background and the level of the atmospheric radioactivity as a long-term characteristics. 

The gaseous-aerosol emissions are included as an indicator of effective and safe operation of KNPP and 

are constantly controlled. Their values during the last years do not exceed 2,0% of the limit values - Figure 

3.6.2-2. 

Fig. 3.6.2-2 Emissions in the air in % of the limit values 

% 

2.0 

1.8 

1.6 

1.4 

1.2 

1.0 

0.8 

0.6 

0.4 

0.2 

0.0 

1999 2000 2001 2002 2003 

Radioactive noble gases Long living aerosols Iodine - 131 

In the period 1999 - 2003 the total beta activity of the long lived aerosols in the near surface air at the 

control points of the studied zone is within the limits up to 2.4 mBq/m 3 , with average value for the period of 

0.42 mBq/m 3 . These results are characteristic of the region and do not differ from measured values in 

previous years. The technogenic radioactivity of the atmospheric air is close to the background values 

( 137 Cs = 0.3 - 9.4 µBq/m 3 ). The measured activity is 5 orders of magnitude (10 5 ) lower than the limit of 

BLRP-2004. 

During the whole operation of all KNPP units, the emissions of LLA and RNG never exceeded 2 % of the 

limit levels. The contribution of WSF to LLA emissions is estimated to be about 3 % of these values (KNPP 

EIA Report, 1999 [O.9]). 


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3.6.3 Atmospheric air quality 

Measurements of the atmospheric air quality in the region of Kozloduy NPP, Kozloduy town and the village 

of Hurlets village were carried out for the Environmental Impact Assessment in the summer of 1999 [O.9] 

with the Mobile monitoring laboratory of the EEA and the MEW. Samples were taken for estimation of the 

concentrations of volatile organic components (VOC). The comparison of the analyses with measurements 

show that: 

• The dust concentrations within the NPP site are in the range of 0.08 - 0.16 mg/m 3 . They reach 64% of 

the limit values (LV) for the total dust suspension in some hours of the day. The values for the town of 

Kozloduy are slightly less than this at approximately 0.5 times of the daily LV. They are even lower in 

Hurlets village where the registered values are 0.1 mg/m 3 ; 

• The concentrations of the main gaseous pollutants SO2, CO, NOx, H2S, methane and non-methane 

VOC, О3 and NH3 are usually considerably under the limit values. They are also lower than the 2001 

amended LVs for SO2, NO, NO2 and later limits for ozone. 

• The exceptions are the concentrations for NO, NO 2 and CO in the hours with intensive traffic which are 

around 07-08 h and 16-17 h. The concentration of NO reaches 84.5 mg/m 3 (40 % above the LV) in 

calm weather; 

• The concentrations of all other noxious gases with the exception of ozone are lower in the village of 

Hurlets than in the town of Kozloduy; 

• No concentrations of VOC in the atmospheric air above the detectable limits of the chromatographic 

analysis’ techniques are identified. 

The average emissions from industrial and residential sources (information from the National Statistical 

Institute - NSI) during the period 1997-2001 for towns and villages in the vicinity of Kozloduy town are 

shown in Figures 3.6.3-1 and 3.6.3-2. It can be seen, that: 

1. there are no emissions of ozone depleting gases like carbon dioxide (CO2) - Fig. 3.6.3-1; 

2. there are no emissions of near-ground ozone predictors - nitrogen oxides (NOX), dinitrogen oxide 

(N2O) and carbon oxide (CO) - Fig. 3.6.3-2. 

Fig. 3.6.3-1 CO2 averaged emissions over 1997-2001 period for towns and villages 

in the vicinity of Kozloduy city and itself (source - NSI) 

t/y 

300 000 

200 000 

100 000 

0 

Vidin 

Lom 

Valchedram 

Gorni Cibar 

Kriva Bara 

Glozene 

Harlec 

Butan 

Mizi a 

Kozl oduy 

Kneza 

Oriahovo 

CO2 


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Fig. 3.6.3-2 N2O, NOx and CO averaged emissions over 1997-2001 period for towns and villages 


t/y 

2 000 

1 500 

1 000 

500 

0 

Vidin 

Lom 

Valchedram 

Gorni Cibar 

Kriva Bara 

Glozene 

Harlec 

Butan 

Mizia 

Kozloduy 

Kneza 

Oriahovo 

N2O NOx 

CO 

Fig. 3.6.3-3 NH3, SOx and NMVOC averaged emissions over 1997-2001 period for towns and villages 

in the vicinity of Kozloduy city and itself (sources - NSI) 

t/y 

2 000 

1 500 

1 000 

500 

0 

Vidin 

Lom 

Valchedram 

Gorni C ibar 

Kriva Bara 

Glozene 

H arl ec 

Butan 

Mizia 

Kozl oduy 

Kneza 

Oriahovo 

SOx NH3NMVOC 

For the KNPP region the radioactive pollutants (gas and aerosol discharges) are included as an indicator 

for the effective and safe operation of KNPP and not to characterise atmospheric air quality. 

Therefore the basic sources determining the atmospheric air quality in the region of KNPP and the studied 

area around it are not the radioactive pollutants but the industrial ones, which are: 

• Production halls, production and diesel-generator stations in NPP; 

• The transport servicing the power plant; 


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• Public places in the region; 

• Industrial facilities on and around the site; 

The road traffic is the most important source of combustion emissions at the site. The three transport 

divisions of the Kozloduy NPP have about 300 vehicles - buses, trucks, cranes, tractors, cars etc. In the 

rush hour periods at the beginning and the ending of the work days, they create, for short periods of 

approximately 30 min per day, narrow but polluted zones, caused by the exhaust emissions in the surface 

layer. 

The concrete workshops of the companies “Atomenergostroyprogres”, “Zawodski stroeji” and 

“Mehanizatcia i transport”, situated closed to the road north of the NPP site could be treated as potential 

local sources of dust emissions. They could cause local air pollution with dust and other gas admixtures of 

construction activities, concrete and lime whitewash production. 

It could be summarised, that the air pollution concentrations in the surface layer in the region of Kozloduy 

NPP, Kozloduy town and Hurlets village with dust and noxious gases is negligible. 

3.7 PHYSICAL HAZARDOUS FACTORS 

The latest data and analysis of the harmful physical non-radioactive factors impact of the Kozloduy NPP on 

the environment as a result of the nuclear power plant are given in the Environmental impact assessment 

report [O.9]. The conclusions of the EIA report for the different physical factors are as follows: 

3.7.1 Kozloduy NPP thermal impact on the environment 

The most significant physical non-radioactive factor in the nuclear power plant is heating. The major heat 

sources on the KNPP site are described below. 

The maximum design thermal power of the KNPP site corresponds to the four WWER-440 reactors (two of 

which are shut down) and two WWER-1000 reactors. The maximum power of each WWER-440 reactor is 

about 1.4 GW, and each of the WWER-1000 is approximately 3 GW. This is a total installed thermal power 

on the site at the moment of about 11.6 GW. The total thermal power of the operating units (Units 3, 4, 5 

and 6) is about 8.8 GW from which about 2.8 GW is released to atmosphere. 

A generator of residual thermal heating on the site is the existing WSF for storage of spent fuel elements 

that have been previously stored for 3 - 5 years in the spent fuel basins in reactor buildings. The WSF is 

built in a separate building on the territory of Units 1-4 near the Electricity Production-1 (EP-1), and close to 

the Auxiliary Building 2 (AB-2). The facility is of a wet (pool) type – a one-vessel hall with dimensions 

45x78m and a height of 30 m. The WSF is designed for all operational loads and options. The maximum 

thermal release is 1064 kW. The maximum design water temperature is 40°C. The maximum design 

project accident is calculated for a maximum water temperature in the basins and 85°C for the whole 

storage building during 17 days. The WSF can store up to 168 baskets of 30 WWER-440 assemblies or 12 

WWER-1000 at the same time. The WSF is designed to be filled in 6 years by normal operation of all six 

reactors. The cooling of the facility is by means of air re-circulation. 

The transportation of the SNF is done by means of: 

• the transport cask ТK-6 fitted on the auto-trailer “Blumhardt” - for the assemblies of WWER-440 and 

• the transport cask ТK-13, fitted on the auto-trailer “Goldhoffer” for the assemblies of WWER-1000 

The existing two diesel-generator stations of EP-1 (two buildings with 6 diesel-generators in each) are 

designated for emergency power supply; hence they do not work constantly. Normally they are kept in “hot 

reserve” state, i.e. their temperature is constantly maintained within the range of 50 - 65°С, which means 

that in working regime they represent source of heat as well. 

The new DSF will be situated in between the WSF and the Auxiliary Building 2 according to the investment 

proposal. 

There are a lot of additional buildings and installations on the NPP site, each of them could act as a 

separate environmental impact source. 


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The proposed DSF will have no thermal impact on Danube River, because there will be no cooling water 

release. 

3.7.2 Electromagnetic fields 

Electromagnetic radiation with various wavelengths is another non-radiation factor of environmental 

impact. The KNPP EIA Report [O.9] concludes that the parameters of the electromagnetic fields are within 

health standards. The requirements for hygienic protection zones around electrical sub-stations and high 

voltage power lines are observed. The locations with registered in compliance normally are not visited by 

people for long time. 

The impact of these harmful physical factors on humans and environment at the selected DSF construction 

site are negligible. 

3.7.3 Noise and vibrations 

The noise is a constantly active harmful physical factor on KNPP site. During the KNPP EIA report 

preparation examinations were performed, showing non-compliance with the normal noise level up to 

30 dB(A). These levels are registered mainly around the steam-ejector machines, steam collectors, turbogenerators, 

source and pumps. The excessive noise levels are related to the characteristics of the 

machines and imperfection in the foundations and building structures. 

There are no special sources of noise in the area of DSF, which could generate noise over the typical 

noise level for the whole NPP site. The existing diesel-generator stations are intended to be used for the 

secondary electricity supply in emergency case. As such they do not work continuously. 

In the peak hours there are registered increased noise levels, caused by the traffic. 

In general, the increased level of noise background on the KNPP site has no impact on residential areas in 

the town of Kozloduy. 

The vibrations are normal for large-sized machine parts at high rotation speed. Therefore they are an 

insignificant physical factor outside the workshops and KNPP site and for the environment. 

3.7.4 Lighting 

All working places in KNPP are designed in accordance with the technical requirements and standards and 

no incomplience has been registered. 

3.8 PROTECTED TERRITORIES, FLORA AND FAUNA 

3.8.1 Protected territories 

According to the biogeographical regional division (Georgiev, 2004), the DSF investment proposal is 

situated in the North-Bulgarian Biogeographical Region, Danubean Sub-Region. The region includes that 

part, which is located to the north of the Stara Planina Mountain range (to the Black Sea Biogeographical 

Region in east direction). 

There is a protected area (sustained reserve) “Ibisha” (34.3 ha) located more than 20 km away from 

KNPP. Antonov, 1997, defines the vegetation cover as flooded woods composed of: black alder, Alnus 

glutinosa; white and crack willows, Salix alba, Salix fragilis, and black poplar, Populus nigra, combined at 

places with poplar plantations and hygrophytic herbaceous coenoses, i. e. impenetrable plantations with a 

sub-forest represented by dewberries and lianomorphous plants. Its scientific and international importance 

is determined by the colony of egrets and cormorants, the largest in Bulgaria (more exactly: of pigmy 

cormorants; this one of the five nesting places of night herons and spoonbills, which are most important for 


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Bulgaria). The international nature-protected status of the “Coryne Sub-Site” is acknowledged under the 

Ramsar convention as a wet area of international importance. 

The DSF is located within the KNPP site boundaries and far from all protected territories. 

3.8.2 Flora 

Based on the geo-botanical regional division (Geography of Bulgaria 2002), the proposed DSF is situated 

in: 

• the Eurasian steppe and forest-steppe region, including Northern and North-eastern Bulgaria, where 

there is no real steppe vegetation, but there are xerothermic woods (mainly of oak), converted to 

steppe under human influence. 

• the Lower-Danubian province, which includes the most northern parts of the Danubian Plain with 

Dobrudja to the north of the Ludogorie Plateau, and the coastal part of Dobrudja. 

• the Zlatiya region - west of the town of Lom to the lower course of the river Vit. 

During the in-field examination carried out on the site proposed, no presence of protected flora has been 

established. The part of the proposed site is covered with vegetation. 

The vegetation in the region is considered as a subject of impact and indicator for the environmental 

impact. Samples from grass and agricultural products have been analysed: sunflower, barley, corn, 

lucerne. The results show that there is no clear negative impact from KNNP on the flora. 

3.8.3 Fauna 

According to the zoo-geographical regional division, Geography of Bulgaria, 2000, the site, for which it is 

proposed to realise the investment proposal, is situated in the Euro-Siberian Sub-Zone (Georgiev, 1979, 

1982), Danubian region. The latter includes the territory of the Danubian Plain, Ludogorie, and southern 

part of the Dobrudja plateau (without the coastal territory). 

During the in-field examination carried out on the site proposed, no presence of any (protected or nonprotected) 

fauna has been established and during the study no presence of protected fauna has been 

established. 

Environmental monitoring department at KNPP provided summarized results from analyses of fish and milk 

in the 100-km zone. These results are similar to the ones obtained during KNPP operation and before its 

commissioning. The results indicate absence of impact caused by KNPP on the ichthyo-fauna and the 

main foods in the region. 

3.9 CULTURAL HERITAGE 

Тhe construction site and the related facilities are located within KNPP site and no cultural monuments are 

present there. There are no places of worship, buildings of architectural value or places of cultural value, 

within the 3-km zone around KNPP. 

3.10 DEMOGRAPHIC, SOCIAL AND SOCIOECONOMIC CONDITIONS 

3.10.1 Demographic conditions 

KNPP is located in the Kozloduy municipality and consists of the town of Kozloduy and the villages of 

Hurlets, Glozhene, Butan and Kriva bara. The average population density in 2002 was 87,4 people/km 2 . 

This value is similar to the average for the country but it is higher than the value for Vratsa region where 


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the Kozloduy municipality is located. A considerable part of the population of the town of Kozloduy is 

socially and economically related to the NPP. 

The demographic development of the Kozloduy Municipality is rather specific and at the same time typical 

for similar settlements where large industrial plans are erected. The factors determining the population 

specifics areas follows: On one hand there is migration of part of the population (which is usual for 

agricultural regions) to the larger towns -in this case from the villages to the town of Kozloduy; on the other 

hand an increase of the total population number is the result of the movement of construction workers and 

specialists from the interior of the country for the erection and attendance of Kozloduy NPP. 

There are eight municipalities partially or entirely situated in the 30-km zone. Their centres are Kozloduy, 

Vulchedrum, Hayredin, Mizia, Lom, Byala Slatina, Oryahovo and about 12 small villages in Romania. 

There is a progressive tendency towards decrease of the population in the period 1975 - 2001 in all the 

populated areas, which is related to the negative birthrate. Only the town of Kozloduy has a positive 

growth and the number of its population has increased from 10 498 in 1975 to 14 892 people in 2001. This 

is due to the job opportunities in the operation and maintenance of KNPP. 

Table 3.10.1-1 shows the number of the population in the municipalities located entirely or partially in the 

30-km zone of KNPP on 31.12.2002. 

Tab. 3.10.1-1 Number of population in the municipalities in the 30-km zone of KNPP 

Municipalities in the 30-km zone Number of population 

Kozloduy 24 253 

Mizia 9 107 

Oryahovo 14 495 

Hayredin 6 565 

Vulchedrum 12 573 

Total number of population 66 993 

The total population in the five municipalities in the inspected zone was 69 145, as counted in 2001 and 

66 993, as counted in 2002. There are about 45 populated areas in the 30-km zone of KNPP. On the 

Romanian side, there are predominantly small villages and the total number of the population does not 

exceed 50 000 people. 

The total population in the five municipalities in various categories as of 31.12.2002, and growth of the 

population for the same period, are presented in Table 3.10.1-2. 

Tab. 3.10.1-2 Population distribution on view of age of activity and mechanical growth 

in the municipalities in the 30-km zone 

Municipality/ Number of people Below active age In active age Above active age Mechanical 

growth 

Kozloduy 4 954 14 569 4 730 1 

Mizia 1 369 4 605 3 133 - 96 

Oryahovo 2 200 7 362 4 933 - 141 

Hayredin 920 2 706 2 939 - 97 

Vulchedrum 1 959 5 542 5 072 - 42 

The comparative evaluation shows that the population of the municipalities Mizia, Oryahovo, Hayredin and 

Vulchedrum, and this refers to the whole country as well, is growing older. 

The number of people in active age is considerably lower than the number of people above it. For Hayredin 

and Vulchedrum municipalities the number of people in and above active age is almost the same. From 

social and economical point of view this kind of demographic age distribution is totally unfavourable. 

Regarding the sex distribution, the proportion of women is relatively higher, about 0.8% -1.4% above the 

midpoint. The sex differences in the active population have the following characteristics: the number of 

girls and boys below active age is approximately equal. The relative proportion of men in active age is 

higher than that of women but the differences are not statistically significant. The comparative proportion of 

men above active age is rather reduced in relation to women. This is related to a tendency of higher death 

rate among men above 60 in comparison to women. The main reason for that are the diseases in the 

cardio-vascular system. 

The number of people under and above active age in Kozloduy municipality has a comparatively more 

favourable distribution. There are 200 young people more than those above 60-65 years. The relative 

proportion of people in active age is higher. This can be explained by the job opportunities in KNPP. 


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The mechanical growth is positive only in the Kozloduy municipality. This is related to the job opportunities 

in the operation and maintenance of KNPP. The mechanical growth in the other municipalities is negative. 

This is again related to the more unfavourable opportunities for meeting the social and economical 

demands in these municipalities. 

The unemployment rate in Kozloduy municipality for 2002 is 16%. Approximately 84% of the active 

population has a job. The unemployment is lower than the average for the country (16,3%) and 

considerably lower than the unemployment rate in Vratsa (24%). The above data proves the importance of 

KNPP for the social and economical welfare of the population in Kozloduy municipality and the more 

favourable demographic indexes in the active population distribution. 

Kozluduy municipality includes five population areas - Kozloduy, Hurlets, Glozhene, Butan and Kriva Bara. 

The population density ranges from 84 pers/km 2 in 1992 to 88 pers/km 2 in 2001 (source: National Statistic 

Institute). The population number shows a general trend of negative growth. This tendency follows the 

overall trend for negative growth of population number in the country: 

Tab. 3.10.1-3 Population distribution 

Total Under working age At working age Over working age 

Total Males Females Total Males Females Total Males Females Total Males Females 

2000 

Bulgaria 8149468 3967423 4182045 1373342 704023 669319 4748150 2492181 2255969 2027976 771219 1256757 

Kozloduy 25273 12518 12755 5346 2741 2605 14809 7863 6946 5118 1914 3204 

2001 

Bulgaria 7891095 3841163 4049932 1288193 660795 627398 4673219 2458321 2214898 1929683 722047 1207636 

Kozloduy 24248 11982 12266 4984 2589 2395 14374 7580 6794 4890 1813 3077 

2002 

Bulgaria 7845841 3816162 4029679 1246753 640041 606712 4712052 2478458 2233594 1887036 697663 1189373 

Kozloduy 24253 11966 12287 4954 2579 2375 14569 7661 6908 4730 1726 3004 

In 2000 the population of Kozloduy Municipality represented 0,31% of overall Bulgarian population and this 

value was stable during the following two years. The only positive trend is observed in the group of 

population of working age in 2002. The total index shows a positive growth of 1.35%, the male population 

increases with 1,1% and the female with 1.68%. The number of female population is higher than the male 

one. This trend is a result of the tendency observed in the group of population over working age. The 

groups of population under working age and at working age show an opposite trend. 

The natural growth tendencies are also negative for the country and for Kozloduy Municipality (average 

value for natural growth index for Kozloduy municipality during the years 2000, 2001 and 2002 is average 

minus 42 persons). 

3.10.2 Social conditions 

In the past, the population of the municipality was almost entirely working in agriculture. The staged 

construction of the NPP (Kozloduy - I, Kozloduy - II and Kozloduy - III) has played a significant part in the 

development of the municipality and accounts for the occurred demographic changes in it. 

The unemployment figures for the Kozloduy Municipality for the year 2002 were 16%. This is lower than 

the average figure for the whole country (16.3) and lower then the figure for Vratsa region (24%). 

The unemployment rate in Kozloduy Municipality reached peak values in years 2000, 2001, and 2002. In 

2003 the trend changed and the unemployment rate is lower (source: The National Employment Agency). 

Tab. 3.10.2-1 Unemployment for the Kozloduy Municipality 

Year Total Male Female 

1999 1 859 925 934 

2000 2 315 1 136 1 179 

2001 2 342 1 144 1 198 

2002 2 489 1 188 1 301 

2003 1 989 896 1 093 

The characteristics of the labour market of the Kozloduy municipality directly depend on the economic 

condition of business entities in the area of commerce, manufacture and services. According to the 

National Statistic Institute there are the following registered companies: 


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1 state company, 4 Municipal, and 1120 private companies. The small companies are prevalent in the 

economic structure of the municipality. The number of small size companies is 1052, of middle-size 

companies is 72 and there is only one large company. 

The network of day nursery and primary and secondary schools in Kozloduy Municipality is well developed. 

There are 4 nursery schools, 3 elementary and 2 secondary schools in the town of Kozloduy. There is also 

a Technical School for Nuclear Power Energy. The villages of Hurlets, Glozhene and Kriva Bara have one 

nursery school and one primary school each. In the village of Butan there is one nursery school, one 

primary school and also one Secondary Vocational Agricultural School. 

3.10.3 Socio-economic conditions 

The natural features of the region predetermine it as purely agricultural, characterised by high yield grain 

production (beard grain and forage grain cultures - mainly wheat, barley and maize) occupying 40 % of the 

cultivated land. A significant proportion (20 %) is taken up by other cultures such as sunflower. Vegetables 

and permanent cultures are found mainly in private farms. 

Based on the National Statistical Institute for the end of 2002, the overall area of the Kozloduy Municipality 

was 28 487 ha, of which 23 819 ha was agricultural and cultivated land. Stock breeding is underdeveloped 

in the municipality. 

There are companies in the municipality, which are involved in housing, industrial construction, and 

assembly works. Other companies specialise in repairs and assembly works. These companies are 

located around the Kozloduy NPP and operate both at the NPP and on the territory of North-western 

Bulgaria. 

There are also companies engaged in processing, cannery and sale of fruit and vegetables, and other 

small and medium sized firms. 

The HPZ required for some of them are limited and are covered by part of the Hygienic Protection Zones of 

the Kozloduy NPP. They do not have any significant effect on the components of the environment. 

In 2002 (Healthcare, 2003, NSI, NCHI, Sofia) the region of Vratsa had 28 nursery schools with 818 places. 

Of these 20 nursery schools with 691 places are in the towns. There are 8 social services facilities such as 

homes for old people, daily homes for children and adults with mental problems, social service bureau, 

clubs of disabled people, public canteens, etc with a capacity of 2100 places. 

In 2000 the average gross income per capita in Bulgaria was 1574 BGN and the average income in the 

North-West Planning Region where Kozloduy Municipality is situated was 1707 BGN per capita. In 2001 

the average gross income for the region was higher than the average income for the country (1576 BGN 

for Bulgaria and 1698 for the Region). The same trend was observed during the following year, when the 

average gross income in the North-West region increased by 25 % compared with the year 2001 (source: 

National Statistic Institute). The main reason for this stable positive tendency is the presence of the 

Nuclear Power Plant where the average salary was higher than the average salary in the region. The 

principal sources of income for the population are: salaries, pensions and household plots. In 2002, 30 % 

of the gross income per capita in the region was from salaries, 18 % from pensions, and 31 % from 

household plots. 

3.10.4 Health status of the population and the KNPP personnel 

3.10.4.1 Health status of the population 

Non-radiation aspect 

Using data from the National Statistic Institute and the National Centre of Health Information to the Ministry 

of Health (Healthcare, 2003, NSI, NCHI, Sofia) the Table 3.10.4.1-1 below shows the demographic 

situation of the town of Kozloduy, as of 31.12.2002. 


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Tab. 3.10.4.1-1 Demographic parameters about population movement in the town of Kozloduy - 31.12. 2002 

Total number of population Children born alive Birth rate Total number of dead Death rate Children who died under 1 year 

Number ‰ Number ‰ Number ‰ 

Kozloduy 24253 252 10,4 346 14,3 4 15,1 

Bulgaria 8,6 14,3 13,3 

Compared to the data for the country for the same period the total death rate (deaths per 1000) in the town 

of Kozloduy is equal to the average for the country (14.3 ‰), the birth rate is higher than the average for 

the country (8.6 ‰). The children death rate - death rate of children between 0 and 12 months in Vratsa 

region (12.4 ‰) is lower than the average for the country (13.3 ‰). The children death rate in the town of 

Kozloduy is higher than the average for the country but the difference is statistically insignificant. The 

natural growth of the population in the town of Kozloduy is negative (-3.9 ‰), the natural growth in Bulgaria 

for 2002 is - 5.7 ‰. In conclusion it can be said that the demographic characteristics in the town of 

Kozloduy for 2002 are more favourable in comparison to the other towns in the 100km zone of KNPP 

(Healthcare, 2003, NSI and NCHI, Sofia). The birth rate is higher than the average for the country; the total 

death rate is equal to the average for the country. Although the natural growth is negative, it is lower than 

the average. 

The death rate is an integral index giving indirect information about the diseases among the population. 

The number of death distributed in groups of diseases and the relative share of the death rate per 100 000 

of the population in Vratsa region for 2002 for reasons of death according to the International Classification 

of the Diseases are presented in “Healthcare” (2003, NSI and NCHI, Sofia). Table 3.10.4.1-2 gives 

information about the death rate from diseases in Vratsa region for 2002. The diseases, which are mainly 

linked to the potential unfavourable factors of the environment, are presented in the table. 

Tab. 3.10.4.1-2 Reason for death per 100 000 people of the population of Vratsa region in 2002 according to ICD 

Some diseases related to the impact of the factors of the environment 

Reasons of death ICD -ІХ revision Per 100 000 people 

Totally for Vratsa region 1757.6 

New formations 248.2 

Malignant new formations of the digestive organs and the peritoneum 80.8 

Malignant new formations of the respiratory system and the breast organs 55.1 

Diseases of the endocrine glands, digestion, metabolism and immunity disturbance 20.8 

Diseases of blood and blood-creating 1.8 

Diseases of the nervous system and the sense organs 12.6 

Diseases of organs of blood 1176.4 

Diseases of the respiratory system 46.5 

Diseases of the digestive system 58.7 

Complications in pregnancy, birth and the period after giving birth 0.5 

Diseases of the skin and under skin tissue 0.9 

Inborn anomalies 1.4 

Transport accidents 11.7 

Suicides and self-injuries 19.0 

The standardised data for the death rate in the Vratsa region does not differ considerably from the data in 

other municipalities in the country, which are not identified as “hot points” due to unfavourable impact of 

the environmental factors according to information of MEW and MH (Environment Protection Strategy with 

Action Plan for the period 2001-2006 [L.45] and the national environmental plan - MH and MEW [L.46]. 

There is no reason to suppose that the operation and maintenance of KNPP has a negative impact on the 

diseases and the death rate in the region. 

The malignant new formations registered in Vratsa region in 2002 for 100 000 of the population are 

presented in Table 3.10.4.1-3. 


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Tab. 3.10.4.1-3 Registered malignant new formations in 100 000 people of the population in the region of Vratsa in 2002 

Registered malignant new formations in different locations per 100 000 people 

Totally for Vratsa region 3547.6 

Mouth, mouth cavity and pharynx 200.8 

Digestive organs and peritoneum 463.9 

Respiratory system and breath organs 259.9 

Bones and joint cartilage 13.1 

Skin melanoma 37.9 

Other malignant formations on the skin 909.7 * 

Female mammary gland 982.5 

Uric-sex organs 836.6 

Cerebrum 26.1 

Thyroid gland 46.6 

Lymph and blood-creating organs 89.6 

* - Higher standardised parameter compared to the parameters for other regions of the country. The 

difference is not statistically significant. 

The proportion of mentally ill people in psychiatric hospitals, registered cases of active tuberculosis and 

the number of disabled people, in the region of Vratsa do not differ considerably from the statistics in other 

places in the country. 

According to information in “Healthcare” (2003, NSI and NCHI, Sofia) in 2002 there were 12 medical 

centres in Vratsa - 8 hospitals and dispensaries, 10 medical services for out of hospital assistance, 

including medical-diagnostic and medical-technical laboratories. There is one hospital and one primary 

health care clinic in the town of Kozloduy. The medical personnel in the region are distributed, as follows: 

doctors 31/10 000 people, dentists 4.9/10 000 people and personnel with specialised medical education - 

37.3/10 000 people. The population is well provided with beds for hospital care, medical personnel, 

qualified doctors and dentists. Urgent medical help can be given in cases of accidents. 

The following health establishment works on the territory of the municipality: 

• Municipal hospital - Kozloduy and 3 diagnostic consultative centres 

• Kozloduy Stomatologic Centre 

• Health service - Hurlets 

• Health service - Glozhene 

• Health service - Butan 

• Health assistance centre - Kriva Bara 

• Labour Health service at Kozloduy Nuclear Power Plant 

The municipal hospital in Kozloduy serves both the population of Kozloduy municipality and a great part of 

the residents from neighbouring settlements - employees at the Nuclear Plant and their families. 

The rural health services consist of prophylactic and treatment of the population in the serviced villages. 

The pharmacy network in the municipality is developed at a reasonable level. There are chemist's shops in 

Kozloduy, Glozhene and Butan. There are five private chemist's shops on the territory of the municipality. 

Radiation aspect 

Radiation factors and dose loads of the population residing in the area of the KNPP 

The radiation impact of the KNPP has been studied since plant commissioning in 1974, within the frame 

work of long-term programs, co-ordinated with the control bodies in Bulgaria - the Nuclear Regulation 

Agency (NRA), the Ministry of Environment and Waters (MEW), the Ministry of Health (MH). The programs 

define the sites subject to control, the frequency of examination, the control indices and methods of 

analysis. Laboratory and automated control of the components of the environment are carried out. A 

specialised mobile laboratory is used for field measurements. The current amount of control meets the 

practice of the EC member states operating NPP. 

The radiation impact of the NPP on the environment and population is being monitored within three zones: 

a Sanitary Protection Zone (SPZ) of 3 km; a controlled zone of 12 km and a monitored zone of 100 km 

radius around the NPP. Thirty six control stations for measurement of the contents of natural and 

technogenic radio-nuclides are located within the 1000 km zone. Air radioactivity, atmospheric deposits, 

soil, vegetation and the radiation gamma-background are subjected to period control. Samples of water, 


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milk, meat, fish, etc. are analysed in addition to the stations as above. The waters of the Danube river 

along the course of which are located several control stations, as well as drinking water sources are 

subjected to uninterrupted control. 

Within the 3 km Zone of Preventive Protection Measures (ZPPM) around the plant are located 10 

monitoring stations of AMSERC ‘Berthold’ for continuous automated control of the dose strength and 

contents of 131 І in the ground air. Included in this system are also three automated meteorological stations 

of uninterrupted operation, as well as five water control stations for the activity of the waters and 

wastewater. The AMSERC system of the KNPP is integrated in the national system of MEW, with 

provisions for a bi-directional information exchange. The results from the institutional radiation monitoring 

are annually verified by the programs for radio-ecological examinations of MEW and the National Centre of 

Radiobiology (MH). 

A series of radioactive substances are emitted in the environment as the result of nuclear power plants 

operation. The major paths for introduction into the environment of technogenic radio-nuclides are gas and 

aerosol discharges into the ground atmospheric air (gas and aerosol waste) and the discharge of liquid 

radioactive substances (liquid waste). 

Depending on their significance with a view to population irradiation, the radio-nuclide discharges in the 

atmosphere are divided in five basic groups: 

1. Radioactive Noble Gases (RNG) - radio-nuclides of Argon, Krypton and Xenon. 

2. Tritium - 3 Н with a half-life period Т1/2 = 12.3 y. 

3. 14 С with a half-life period Т1/2 = 5.73.10 3 y. 

4. Long-living Aerosols (LLA) Т1/2 ≥ 8 d. This includes over 100 radio-nuclides from 2 Н (deuterium) to 

trans-uranic nuclides such as Americium and Curium. 

5. Iodine radio-nuclides, mainly 131 І a half-life period Т1/2 = 8.04 d. 

The radio-nuclides discharged with liquid substances are divided in two groups: 

1. Tritium - 3 Н. 

2. All other radio-nuclides in liquid substances. 

The main ways for a direct exposure of the population resulting from the NPP operation are: 

• external exposure by the radioactive gases and aerosols contained in the air; 

• external exposure by radio-nuclides deposited on the ground; 

• inhaling of radio-nuclides (internal exposure); 

• swallowing of radio-nuclides by consuming food of local origin (internal exposure). 

Depending on the periods of half-life of the radio-nuclides, certain types of exposure are realised within 

short time periods (e.g. 131 І), while others are realised during very long lasting time periods of several 

thousand years (e.g. 14 С). 

Under normal operation, the exposure of the population residing in the area of the plant exceeding the 

background radiation is formed mainly from gas and aerosols discharges of radio-nuclides in the ground 

air. According to UNSCEAR (United Nations Scientific Committee on the Effects of the Atomic Radiation), 

the concentrations of radioactive substances in ground air are found to be approximately 96 % of the 

overall annual dose of population exposure. 

The evaluation of the exposure of the population in excess of the background depends on a series of 

factors, the more important of which are: 

• activity of the radioactive substances discharged into the atmosphere; 

• climatic and meteorological conditions in the area of potential impact by the NPP; 

• soil characteristics - prevailing soil types in the area of impact; 

• demographic indices; 

• consumption of main types of food of local origin. 

The summarised results of the measured radiation gamma-background at the control stations and the 

settlements within the monitored zone surrounding the KNPP for the period 1999-2003 have shown, that 

the strength of the equivalent dose of gamma-radiation varies within the limits of the natural radiation 

background of 0.06 to 0.14 µSv/h. 


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The overall beta activity measured in the waters of the open reservoirs in the region is 20% below the norm 

(2,0 Bq/l pursuant to Regulation 9/2001). The maximum measured value for the waters of the Danube river 

is 0,44 Bq/l. The tritium content in the samples from the open reservoirs does not exceed the Minimal 

Detectable Activity (MDA) of up to 10 Bq/l. 

The entry of radioactive isotopes following the biological chain: NPP - water - soils - biota - air - flora - 

fauna - man has a significant contribution to the internal exposure to long-lived radionuclides of the 

population. The largest part for the formation of the individual effective equivalent dose for the residents in 

the area around the KNPP falls to the consumption of vegetables, fish and milk of local origin. Milk 

samples from farms at the town of Kozloduy, the village of Hurlets and the town of Oriahovo have been 

examined by the ERC at KNPP for the purpose of determination of the transfer of radio-nuclides along the 

food chain for the period 1995 - 1998. The average beta activity of milk from the town of Kozloduy is 38.5 - 

44.4 Bq/kg, and for the town of Oriahovo it is 48,5 Bq/kg. The measured values come close to the values 

obtained during and prior to the operation of NPP and indicate the absence of influence by the KNPP on 

the ichthyo-fauna and the main food consumed by the population. 

The additional dose load of the population within the 30 km zone by technogenic radio-nuclides discharged 

in the atmosphere under normal operation of NPP is negligible. The maximum value if the individual 

effective annual dose as the result of gas emissions from the plant for the period 1999 -2003 varies within 

the range of 2.68.10 -7 to 3.76.10 -7 Sv/year. This is less than 0.02% of the background irradiation and below 

0.05% of the norm of 1 mSv according to BNRP 2004. The normalised collective effective annual dose for 

the population of the 30 km zone due to gaseous aerosol emissions varies between 2.68.10 -3 and 3.58.10 -3 

manSv/GW.y. By parameters for RNG and 131 I, dose values fall below the average for the countries with 

nuclear power plants. The doses received by the population from semi-liquid and liquid discharges from 

NPP are negligibly low, amounting to barely 1.66.10 -11 Sv/y. 

It is evident from the above description that the irradiation in excess of the background, though negligible in 

respect of the radiation risk and the health status of the population in the 30 km zone, is due mainly to the 

presence of gases and aerosols in the ground layer of the atmospheric air discharged by KNPP. The 

remaining sources of irradiation of the population in excess of the background, such as external exposure 

from radio-nuclides deposited on the ground surface, and internal exposure from inhalation of radionuclides 

incorporated in food, have an insignificant contribution to the overall exposure. 

The radiation situation within the 100 km zone does not differ from the remaining regions of the country. 

Health status of the population 

The impact of the discharges by the KNPP on the health status of the population of the 30 km zone has 

been studies in Kozloduy, Oriahovo, Mizia, Hajredin and Borovan. In the course of the analysis morbidity 

rate has been considered as priority the groups of diseases, for which a causal relationship to the radiation 

impact can be assumed, such as: 

• Malignant new formations 

• Diseases of blood and blood generation organs 

• Hypertonic disease of adults 

• Endocrine glands diseases, including thyroid gland 

• Nervous system diseases 

• Pregnancy complications, delivery and post delivery complications 

• Congenital anomalies 

The data analysis has indicated an increased frequency of almost all nosologic units, both for children and 

adults, whereas for some of these the growth rate is higher that that for the country. The frequency of the 

all registered diseases is highest in Kozloduy and Hajredin. In respect of morbidity by children afflicted with 

asthma in Kozloduy and the children suffering from skin diseases there has been found a direct positive 

correlation with the electric power generation by years. Extended in-depth studies are necessary in order 

to prove a potential relationship of the diseases with the radiation impact. 

Among the adult population, the diseases of the digestive system, the endocrine system (diabetes) and of 

the blood circulation organs, skin and sub skin tissue have shown a frequency above the country average. 

The conducted analysis of all examined nosologic units and groups of diseases by adults have indicated 

the presence of a positive correlative dependency between the increased electric power generation at the 

plant and the population morbidity rate in respect of: 


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• Diseases of the urogenital system (the village of Hajredin) 

• Thyroid gland diseases (the village of Borovan) 

• Hypertonic diseases (the village of Borovan) 

It is noted that from the interpretation of the stated data, the radioactivity of noble gas and aerosol 

emissions from NPP is below the admissible level. This means that the NPP emissions cannot be the 

single reason for the increase of the new formations, congenital anomalies, diseases of the thyroid gland, 

diseases of the respiratory system, etc. It is obvious that the entire complex of factors of the environment, 

including the total pollution consequential to the accident at the Chernobyl NPP must be taken into 

consideration. There is no doubt that within this complex of factors KNPP occupies a distinguished position 

as emitter of RNG, long-living aerosols and 131 I in the atmosphere, as well as a source of a very large 

amounts of waters discharged into the Danube river. 

3.10.4.2 Health status of the NPP personnel 

Radiation factors of the working environment 

The NPP operation meets the objectives and principles of radiation safety and the protection of human life 

and health and protection of the environment takes precedent over economic and other factors. 

Compulsory hygienic norms and requirements and sanitary rules regarding all aspects of hygiene, 

radiation safety and protection, etc have been established. 

Based on long term investigations of labour conditions in nuclear power plants radiation doses for the 

personnel have been determined. 

The strict standardisation of radiation factors in the working environment is a necessary precondition for 

the implementation of nuclear safety and radiation protection of the NPP personnel. The basic normative 

documents in the field of radiation protection in the Republic of Bulgaria are ‘Basic Norms for Radiation 

Protection’ (BNRP 2004) [L.17]. 

For the purposes of implementing more efficient control and radiation protection, the NPP personnel has 

been divided in two groups: 

• Class A - personnel that might receive an annual effective dose in excess of 6 mSv 

• Class B - personnel not belonging to Class A 

Depending on the character of the operations carried out, the rooms in a NPP are divided into the following 

categories: 

• serviced rooms - the rooms where the impact of the radiation factor on the personnel is practically 

excluded; or this factor is within such normative limits that permit the stay of personnel during the full 

working shift 

• semi-serviced rooms - the rooms where repair or other activities are carried out, which are related to 

exposure of process equipment, temporary storage of radioactive waste, etc. The personnel stays in 

such rooms for not more than the half of the working hours 

• non-serviced rooms - cubicles, chambers and other hermetically sealed rooms where process 

equipment, communications, etc. are installed, which are sources of ionising radiation and radioactive 

pollution. The presence of personnel in such rooms is prohibited under normal operation conditions 

The admissible rate of the equivalent doses for one calendar year: 

• in rooms for permanent occupation by the personnel (attended rooms) - 5 μSv/h (1700 hours) 

• in rooms where the personnel stays for not more than the half of the established working hours (semiattended 

rooms) - 10 µSv/h (850 hours) 

Controlled and supervised (monitored) zones are differentiated on the basis of the characteristics as 

above, with a view to control the sources of irradiation and irradiated persons. Specific arrangement for 

monitoring of personal irradiation and radiation protection are required under normal operation conditions 

within the controlled zone. In the case of accidents, measures for prevention or limitation of the radiation 

impact are also required. Monitored zones are the zones outside the limits of a controlled zone. Radiation 

control of the working environment is carried out in a monitored zone, but there is no requirement for 

radiation protection of the personnel. 


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Radiation situation and dose loading of the personnel of the KNPP 

A brief retrospective analysis of the radiation parameters within the zone of strict control and the monitored 

zone of the KNPP was carried out to assess the potential radiation impact of the DSF on the personnel of 

the NPP and the population within the 30 km zone around the site. 

The analysis of the dose load of the persons employed at the NPP covers the period of operation between 

1983 and 2003. The analysis was made after data from the EIA Report on the KNPP [O.9], and on the 

basis of information by the Direction of Safety and Quality at the NPP. 

Under normal operation, the collective effective dose for the personnel of EP-1 has decreased from 6634 

man.mSv in 1998 to 2153 man.mSv in 2003, whereas for the external irradiation these values are 6412 

man.mSv and 2070 man.mSv, respectively. The contribution of the radio-nuclides to the overall personnel 

irradiation is a comparatively constant value, which expressed in percents, varies within the limits of 

2.89 % and 3.91 % over the years. The control on the internal irradiation exercised by the National Centre 

of Radiobiology in the course of several years has shown that the annual individual dose of incorporated 

radio-nuclides in the examined workers is below 1 mSv. 

The average individual effective annual doses of the controlled contingent at EP-1 are much lower than the 

national limits for worker exposure and are within 3.23 mSv (1998) to 0.69 mSv (2003). 

The same trend towards a dose decrease is observed also by the maximum effective dose of radiation 

workers. The received maximum dose for 2003 is two times lower than the dose received in 1998. 

The information on persons subjected to radiation with doses in excess of 50 mSv has shown that in 

comparison with previous years (1994 - 3 cases; 1996 - 1 case, 1997 - 2 cases) for the period 1998-2003 

there has been no registered excess of the individual annual effective dose over the annual limit for 

personal irradiation. 

The plant personnel are exposed to increase radiation impact during reactors refuelling and diverse repair 

activities, which lead to a relative increase of the individual irradiation. The distribution of the contribution of 

different working operations under normal operation conditions to the overall personnel irradiation, 

expressed as percentage of the annual cumulative dose is as follows: 

• reactor operation and general supervision - 10.8 % 

• routine repairs - 52.6 % 

• preventative maintenance - 3.0 % 

• specialised repairs - 10.0 % 

• radioactive waste treatment - 6.9 % 

• refuelling - 7.7 % 

Clearly, the major part the personnel exposure is determined by the repair works - 71.6 %. 

The basic radiation parameters of the working environment that predetermine a relatively higher exposure 

of the personnel engaged with refuelling and the planned and regular repairs are: 

• external gamma radiation at the workplaces (gamma radiation dose rate) 

• radioactive pollution of surfaces and equipment 

• radioactive air pollution in the working rooms with long-living radio-nuclides 

The gamma radiation dose strength at different workplaces varies within broad limits - from 0.05 mGy/h to 

85 mGy/h. 

The surface radioactive pollution in the two basic working premises in EP-1 where repair works and 

refuelling operations are carried out is within the following limits; 

• in the central hall - from 107 to 4160 β/(cm 2 .min) ; 

• in the cubicle of the steam generators - from 3000 to 8050 β/(cm 2 .min). 

According to BNRP 2004 concerning the surfaces in working rooms for periodic personnel stay and the 

equipment located there, the admissible radioactive pollution with beta-active radio-nuclides is 8000 

β/(cm 2 .min). Under this criterion, the surface radioactive contamination in the central hall and at the steam 

generators may be considered as high. 

To summarise the above data:1. The highest values for the radiation background are found in the 

reactor section, transportation corridors, and in some of the radio-chemical laboratories. The gammabackground 

in some of the rooms is up to 1.5 mSv/h. 


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2. The overall exposure dose for 85 % of the personnel is between 1 - 12 mSv/year. 

3. The personnel of the repair teams, the deactivation department and the personnel of outside 

enterprises receive the relatively highest doses. 

4. The external and internal irradiation of the personnel employed within the monitored zone outside the 

zone of strict control is comparable to the irradiation received from the natural radiation background of 

the plant, which is approximately 2 mSv/year. 

5. The parameters of the radiation situation have significantly varied over the years, without however 

exceeding the limits set by BNRP 2004. 

Health status of the NPP personnel 

Exposure of humans by ionising radiation may cause biological and health effects that are varied in respect 

of organotropy, severity and time of manifestation. A typical feature of radiation damage that it can 

manifest itself in the individuals subjected to radiation are (somatic effects) or in their offspring (hereditary 

or genetic effects). Pertinent to the somatic effects are both malignant new formations and malignant 

diseases. 

Generally, the radiation effects are deterministic (non probabilistic, or non stochastic or threshold) and 

stochastic (probabilistic or without threshold). 

The deterministic effects are characterised by the presence of a radiation dose threshold under which the 

effect does not have a clinical manifestation. The occurrence of deterministic effects depends apart from 

the radiation dose also on the dose strength. The threshold doses for the occurrence of various 

deterministic effects depend on the sensitivity to radiation of tissue and organs. Deterministic or nonstochastic 

are some of the effects specific for various tissue, such as cataract (threshold dose 0.15 Gy/y), 

non-malignant skin damage, suppressed medulla blood generation (0.4 Gy/y), genital cell damage 

(0.4 Gy/y) related to fertility disturbance. Places where non-stochastic effects can occur are also blood 

vessels and conjunctive tissue that may cause lesion to different organs and systems of the human 

organism. 

The stochastic effects are characterised by the absence of a threshold dose for their occurrence. The 

biological effects increase with the increase of the received dose, and latent period is necessary for its 

clinical manifestation. All genetic (hereditary) effects pertain hereto, and radiation induced malignant new 

formations (somatic effects). The cancer genesis is predetermined from the main somatic risk from chronic 

exposure to low doses of ionising radiation. 

The major components of the harmful impact of ionising radiation are the stochastic values: 

• Lethal cancer probability 

• Non-lethal cancer probability 

• Aggravated hereditary effects probability and life expectancy decrease in the case of manifestation of 

damage 

The following values of the so called nominal probability factors of stochastic effects occurrence have been 

determined for the workers in ionising radiation environment: 

• Lethal cancer 4.0.10 -2 Sv -1 

• Non-lethal cancer 0.8.10 -2 Sv -1 

• Aggravated hereditary effects 0.8.10 -2 Sv -1 

• Total 5.6.10 -2 Sv -1 

The probability of increase in radiation induced damage in persons subjected to radiation increases with 

the increase in the received individual annual dose and the cumulative dose received for the whole period 

of exposure. 

The analysis of the morbidity rate for the personnel and affected population was carried out using data 

from the EIA Report of the KNPP. No other data have been submitted and it covers the period up to 1998. 

No information has been submitted concerning the period after that date. The health status of the power 

plant personnel has been monitored by the Health Centre at NPP, as well as by teams of the National 

Centre of Radiobiology and MH. Regular preventative medical checks and routine examinations of the 

personnel, as well as certain checks specific for this contingent have been carried out. 


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The morbidity rate with temporary work disability is one of the basic indices characterising the heath status 

of the active population. The morbidity rate of the NPP personnel expressed in terms of temporary work 

disability for an extended period of time has been 13 days up to 1994. The temporary work disability is 

higher for men than for women. The average work disability for KNPP is approximately 1,5 times higher 

than for other energy sectors in Bulgaria as a whole. The highest morbidity rate is observed by the 

maintenance personnel. This fact deserves attention, since the maintenance teams are subjected to the 

highest radiation doses. The diseases of the respiratory system, digestion system, the sensorium, the 

infectious diseases, the blood circulation diseases, etc, are most frequent. 

Examinations of the haematological parameters have found certain variations of the differential blood 

pattern typical for the impact of low ionisation radiation doses, such as granulocytes decrease and 

moderate increase of the lymphocytes counts. Such observations have been made on workers on the 

controlled zone. The most frequent cases observed for the year 1998 in the whole EP-1 (and mostly for the 

reactor section, where the labour conditions in respect of the radiation factor are most unfavourable) were 

the cases of transitory haemoglobin decrease, followed by cases of overall decrease of leukocytes and 

lymphocytes. A similar pattern is characteristic for suppressed medulla blood generation as a result of the 

chronic impact of small doses of ionised radiation. 

The National Centre of Radiobiology has carried out studies on the risk of inducing of malignant new 

formations by the workers of the KNPP. A methodology for determination of chromosome damage (micronucleuses 

in lymphocytes in peripheral blood) was applied. It is necessary to point out that this type of 

cytogenic examination of persons subjected to radiation does not characterise the health status of the 

individual. The examination provides important information on the degree of mutagenic impact from 

exposure to radiation and may serve for a tentative risk evaluation. The results from the cytogenic 

monitoring on 120 persons occupied with repairs and reactor refuelling, having a cumulative radiation load 

of 250 to 690 mSv have indicated increased chromosome damage in lymphocytes of peripheral blood, 

compared to the spontaneous frequency for the country. Similar results have been observed in persons 

subjected to radiation below the admissible norms, employed within the controlled zone. 

Persons with increased frequency of chromosome disturbance should be subjected to special medical 

observation due to the presence of potential risk of development of late consequences that may occur 

mainly at pension age. 

No permanent unfavourable trends have been found regarding a variation of the haematological 

parameters of the workers at NPP, which are likely to be due to the labour factors at the plant”. It is 

necessary to pay special attention to the fact that deviations in the haematological status are observed 

mainly with workers of the reactor section and the maintenance department. The transitory character of the 

variations of the haematological (blood) status might be caused by temporary failures at the workplaces, 

gaps in radiation protection, labour organisation failures, non-observance of the labour rules, etc. 


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4 

PART IV - DESCRIPTION, ANALYSIS AND ASSESSMENT OF THE POTENTIAL 

SIGNIFICANT EFFECTS ON THE POPULATION AND THE ENVIRONMENT 

RESULTING FROM 

4.1 IMPLEMENTATION OF THE INVESTMENT PROPOSAL 

The impact of DSF on the population and the environment can be divided into impacts during the 

construction, during the operation of the facility and during the decommissioning phase. These impacts are 

considered from the radiation and non-radiation aspects. 

4.1.1 Possible impacts during the DSF construction 

During the construction phase, the impact of the radiation factors caused by the investment proposal is 

nonexistent since absence of any radioactive sources in this phase. The only possible use of ionising 

sources during the construction might be from non-destructive testing of welded components using 

radiography. If radiography is used, the working procedures and the legal requirements shall be strictly 

followed. 

For this reason Sections 4.1.1.1 to 4.1.1.10 only consider the impact on the population and the 

environment during the DSF construction from the non-radiation aspect. Section 4.1.1.11 includes the 

impacts from the radiation aspect related to DSF construction. 

4.1.1.1 The population - excavation of inert materials, roads for the vehicles, which supply 

materials and equipment etc. and the social aspects 

The Kozloduy municipality where, KNPP is situated covers an area of 28487 ha. The population within the 

30-km zone around NPP is 66 993 people as of 31.12.2002. Samples from the atmospheric air, soils, flora, 

water from Danube and various sources of the drinking water within this zone have been analysed. The 

dynamic measurements show an absence of risk from adverse effects caused by pollution above the limits. 

The sanitary-protection zone of 3000 m from Kozloduy NPP as agreed with the Ministry of Health is kept. 

The investment proposal includes the construction of a reinforced concrete building less than 30 m high, 

and plan area of 1560 m 2 for Stage I and 4420 m 2 for Stage II respectively. The construction of DSF Stage 

I will take place from early 2007 until the end of 2008. The construction activities include road traffic of 

trucks, movements of heavy construction machinery and use of large quantities of construction materials 

etc. These activities generate noise and vibrations, pollution of the atmospheric air with irritating and 

hazardous gases, soil and construction dust and fine dust particles with size from 2.5 µm - 10 µm. The 

construction site could be contaminated by spent lubricants from the use of heavy machinery, fuel and 

construction waste containing anticorrosive, hydro-insulation and electrical insulation materials, clays, 

organic solvents and waste polymers. 

Construction will be carried out by contractors selected for this purpose. The contractors have to be 

licensed for a similar type of construction activities. They will also supply inert materials and equipment. 

The existing roads will be used during the construction, which will be additionally loaded with heavy 

machines and vehicles using diesel fuel. 

The expected impact concerns mainly the population of the town of Kozloduy, the Kozloduy municipality 

and the populated areas within the 30-km zone. Potential negative effects could be caused by: noise, 

vibrations, air contamination from the diesel-fuel burning machinery (transport and excavation), dust from 

construction materials and soil dust, danger of transport accidents and incidents with heavily loaded 

vehicles. The adverse effects will be indirect and temporary for about 24 months and the effects are 


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reversible. No secondary and cumulative impacts are expected since the DSF will be used for at least 50 

years without necessity of reconstruction and rehabilitation. 

The population of Kozloduy and the region will be employed in project implementation activities such as, 

planning, preparation activities, construction, supply of inert materials and equipment, accommodation of 

the personnel, collection of construction waste and restoration of the construction site. This means new job 

opportunities and increase of employment. Beside the social and economical importance, the construction 

of a modern facility will have the psychological effect, that the spent nuclear fuel generated at KNPP is 

stored safely. 

4.1.1.2 DSF personnel and KNPP on site personnel 

About 40 qualified people are planned to take part in the construction of Stage I, if they work in one shift. 

The same number of people is likely to be involved in construction of Stage II. For the construction 

workers, who must observe the safety requirements, the impact of the adverse factors of the working 

environment will be direct, temporary and reversible. The construction activities will be related with direct, 

cumulative and combined negative impact of chemical, physical and ergonomic factors on health, risks of 

traumas and incidents. 

The construction activities could have indirect temporary negative impact on the staff of Kozloduy NPP 

working in the present wet storage facility (WSF). The maintenance workshop for the heavy-duty 

machinery will be disassembled and moved to another place. In all cases, the technical personnel from the 

workshop will be exposed to a short indirect, (during the construction) negative impact as a result of the 

construction of the DSF building. 

The main risk factors for the personnel involved with the construction of DSF and the personnel at KNPP 

working in the existing WSF, are related to the hazardous substances (as shown in Table 4.1.1.2-1), 

adverse physical factors of the working environment, physical and psychic-sensor load of the people 

involved with construction, failures and labour accidents (as shown in Table 4.1.1.2-2). 

Tab. 4.1.1.2-1 Hazardous * substances, chemicals and materials with adverse health effects during construction of DSF 

(according to the Material Safety Sheets) 

Chemical substance, 

chemical САS № 

Carbon monoxide 

630-08-0 

Carbon dioxide 

24-38-9 

Nitric oxides 

10102-44-0 

Sulphur dioxide 

7446-09-5 

Diesel 

8006-61-9 

Danger sign Adverse health effects Risk exposition 

F+Highly 

flammable, 

Т Toxic 

Т+ Toxic 

Xn Harmful 

Т Toxic, 

С Corrosive 

Xn Harmful 

N Dangerous to 

environment 

Cement Xi Irritant 

Allergen 

Highly flammable, toxic in inhalation - causes 

hypoxia and hypoxemia. Leads to creation of 

carboxylic haemoglobin. Damages the nervous, 

cardio-vascular system and blood-creating 

organs. Toxic to reproduction. 

Asphyxiator - replaces the oxygen in the air. 

Damages the nervous system. 

Toxic - damage the lungs alveoli causing lipid 

peroxidation. In high concentrations lead to 

edema of the lungs, alveolitis. Irritates the 

respiratory tracks, the eyes, the skin, chronic 

bronchitis , frequent bronchopneumonia. 

Toxic in inhaling -damages the respiratory and 

nervous systems and the heart. In high 

concentrations leads to chemical burns. Irritates 

the respiratory tracks, the eyes and the skin. It 

has a strong unpleasant smell. Dangerous to 

environment. 

Hazardous. Danger of cumulative effects. 

Allergen. Damages the nervous system, bloodcreation, 

the liver and the kidneys. Mutagen. 

Dangerous to environment. 

Irritant to the skin, the eyes and the respiratory 

tracks. Allergen. Contains contaminants (Cr-VI, 

Cd, Co, Ni). Controlled with Regulation of the 

Council of Ministers No. 156/2004** 

(concentration six-valence-chrome up to 

0.0002%). Inflammatory and allergic damage of 

the skin and mucosa. 

In emissions of exhaust-pipe 

gases, risk of anaemia, 

headache, weakness. 


gases, headache. 


gases, chronic bronchitis, 

bronchopneumonia. 


gases, chronic bronchitis. 

Chronic effects, if the 

requirements for safe labour are 

not followed. 



not followed. 


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Asphalt 

84989-11-7 

Polyurethane and 

epoxide covering for 

surfaces and glues 

Dust - from soil and 

construction 

materials 

FDP2.5, FDP5, 

FDP10 

Т Toxic Chronic damage of blood-creation and the 

respiratory systems, the liver, the skin, the 

endocrine glands and the immune protection 

systems. Classified as carcinogen of 2 category, 

allergen, photo allergen. 

Xi Irritant 

Allergens 

Causes acute and chronic diseases due to 

irritation or allergic reactions of the respiratory 

system (bronchial asthma) and the skin. 

Causes chronic inflammations of the upper 

respiratory tracks, chronic bronchitis, eye 

inflammations, deteriorates the cardio-vascular 

system. 



not followed. 

Use without preliminary 

information from the labels and 

the instruction manuals 

In case of incompliance with the 

measures for reduction of dust 

formation during construction, 

envisaged in the technical 

specification. 

* Law for protection from the Harmful Impact of chemical substances, preparations and products [L.10], Law for amendment 

and supplement of the Law for protection from the Harmful Impact of chemical substances, preparations and products [L.10], 

DCM № 316 with Regulation on classification, packing and labelling of existing and new chemical substances, preparations 

and products [L.27] and DCM № 174 for amendment and supplement of DCM № 316 [L.27]. 

** DCM № 156 for amendment and supplement of the Regulation for hazardous chemical substances, preparations and 

products, the trade and use of which is prohibited or limited by DCM № 130 [L.28]. 

The adverse effects related to the hazardous chemical substances from the construction machines and the 

trucks can be reduced, if diesel fuel is used in compliance with Regulation № 17 on the admissible content 

in fuels of lead, sulphur and other environmentally harmful substances [L.29]. 

The other hazardous impacts that could appear resulting from the construction of DSF are summarised in 

Table 4.1.1.2-2. 

Tab. 4.1.1.2-2 Adverse health effects related to physical factors of the working environment, physiological load and 

accidents during constriction of DSF 

Adverse factors Adverse health effects Risk exposition 

Physical factor of the working environment 

Noise and vibrations * from Damage of the hearing in the high frequency Work with old, not serviced machines, 

construction machines, trucks range, neurosis, neurasthenia, high blood bad tracks, unsafe cabins, no ear 

and construction activities pressure, disturbed metabolism and immune 

protection 

defenders. 

Microclimate outside the Work in the open, getting cold, freezing or Lack of resting places. Bad working 

comfort zone** 

getting hot. Damage of the cardio-vascular 

system and the bones and joints, infectious 

diseases. 

clothes, gloves and shoes. 

Physiological and ergonomic factors of the working environment 

Load lifting Damage of the joints and the bone system, Non-observance of the requirements of 

cardio-vascular problems 

Ordinance № 16/1999 *** 

Physical fatigue and stress Damage of the joints and the bone system, 

neurological and cardio-vascular problems Non-observance of the requirements of 

Psycho-sensor loading Neurosis, neurasthenia, problems of the cardiovascular 

system, stress. 

Ordinance № 15/1999 **** 

Forced working posture 

Failures and accidents 

Damage of the joints and the skeletal system Specific activities during construction 

Labour accidents, traumas Falling in holes from high places, traumas from 

heavy duty machines and equipment 

Specific activities during construction. 

Fires and explosions Burnings, traumas, suffocation. Electric shock Lack of electrical safety, bad storage of 

oil products and fuel. 

Traffic accidents Traumas, burnings, damages caused by fuel oil, Transport of construction materials in big 

release of inert materials. 

quantities. 

* Bulgarian State Standard 14478-82 Noise. Admissible levels in working environment. General requirements of carrying out 

the measurements [L.77]. 

** Bulgarian State Standard 14776-87 Industrial microclimate [L.78]. 

*** Regulation № 15 on the conditions, order and requirements for development and implementation of physiological regimes 

of respite during work time [L.30]. 

**** Regulation № 16 on the physiological norms and rules for manual work with loads [L.32]. 

The enumerated adverse effects are temporary, direct and refer mainly to the personnel involved with the 

construction of DSF. Avoidance and reduction of health risks depends on observance of the requirements 

for healthy and safe labour conditions. The personnel of the facilities of Kozloduy NPP situated close to the 

construction site will be temporarily exposed to the impact of the dust and exhaust-pipe gases from the 

building machines and the trucks and to increased level of noise and vibrations. Only in cases of severe 

violations of the safety rules, single cases of accidents can be expected. 

The investment proposal implementation works will be provided with “Health and Safety Plan”, which is a 

part of the Technical Specification of the Project and will be developed in compliance with Regulation № 2 


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for the minimum requirements for safe and healthy working conditions during the performance of 

construction and installation activities [L.80], harmonized with Directive 92/57/EC. 

Kozloduy NPP has developed infrastructure, safe power supply, fire protection system, drinking water supply, 

sewage, drainage system for avoidance of floods in cases of natural disasters, asphalt and concrete internal 

roads. There are sanitary places, toilets and bathrooms, canteen and lunch shops within the plant. There is a 

medical service providing qualified medical help. This creates possibilities for normal operation of the facility 

and safe labour of the personnel involved with construction. 

4.1.1.3 Tangible assets - consumption of fuel, raw materials and materials 

The construction will include: 

• excavations and foundations; 

• construction of the facility; 

• equipment for physical protection of DSF; 

• appropriate infrastructure. 

The following construction materials will be used: concrete, sand, gravel, cement, lime, steel, bricks, 

framework, pipes, roof covering, electric cables, etc. The construction process will include delivery of 

construction materials on the site. The following services and materials will be needed: electricity, water, 

diesel fuel and lubricants. The quantities of required materials are expected to be significant and will be 

determined in the detailed construction plan. During the construction of DSF, no major impact on the 

tangible assets (fuel, raw materials and materials) is expected. 

The construction materials which will be utilized will comply with the Regulation for the substantial 

requirements and the assessment of the conformity of the construction products [L.81]. The specific (nonstandardized) 

construction materials and equipment for the particular site must have operational 

characteristics in accordance with the design specification for the particular construction. 

During DSF construction, the impact on the tangible assets - consumption of fuel, raw materials and 

materials will be negative, direct, without secondary and cumulative impact, temporary, short term, and 

irreversible. The impact applies to the DSF site, KNPP site, 3-km and 30-km zones from which the 

materials are expected to be delivered. 

4.1.1.4 Atmospheric air and the atmosphere 

In the course of the construction a higher emission of certain noxious atmospheric pollutants, particulate 

matter and other pollutants will be expected, caused by heavy mobile machinery, utilised for earth moving 

and transportation work. 

The emission estimates for off-road construction vehicles and machinery are performed under 

EMEP/CORINAIR Atmospheric Emission Inventory Guidebook, Third Edition, B810 (Other mobile sources 

and machinery). 

For 1 hour work of 1 excavator which has a power output of about 250 kW, 1 Off-Highway Truck (300 kW) 

to transport sand, rocks, etc and 1 Crane (150 kW) the emissions and relevant waste gases concentration 

emitted in the air are: 

Tab. 4.1.1.4 Atmospheric emission 

Emission [kg] 

NOx N2O CH4 CO NMVOC PM NH3 

Excavator (250 кW) 3.60 0.09 0.01 0.75 0.33 0.28 0.0005 

Off-Highway Truck (300 kW) 4.32 0.11 0.02 0.90 0.39 0.33 0.0006 

Crane (150 kW) 2.16 0.05 0.01 0.43 0.19 0.16 0.0003 

Exhaust Concentrations [mg/m 3 ] 

Excavator (250 кW) 4 246 103 14.7 885 383 324 0.590 

Off-Highway Truck (300 kW) 5 096 124 17.7 1 062 460 389 0.708 

Crane (150 kW) 2 548 62 8.8 512 225 186 0.354 

A considerable reduction of working environment emissions can be expected by utilisation of construction 

off-road machinery, which are in compliance with the requirements of Regulation № 10/2004 (Promulgated 

State Gazette №. 28 from 6.04.2004), harmonised with Directive 2002/88/EC, amending Directive 97/68 - 


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relating to measures against the emission of gaseous and particulate pollutants from internal combustion 

engines to be installed in off-road mobile machinery. 

In general, the construction phase is limited in time and has no significant effect on the air quality and the 

environment in non-radioactive aspect. 

During DSF construction, the impact of the exhaust gases emissions from the internal combustion engines 

of the construction machines and dust from the earth works will be negative, direct, without secondary and 

cumulative impact, temporary, short-term, reversible and will be within the DSF site, KNPP site, 3-km and 

30-km zones from which the materials are expected to be delivered. 

4.1.1.5 Water 

The possible impacts on waters during DSF construction can be summarised as follows: 

• The construction of DSF will require water for drinking, cleaning and for the works held on site 

(concrete, wet processes, etc.). That means there will be certain increase in the water use. The 

quantities will be limited and will not represent a serious change in the NPP water use. This impact will 

occur and the extent will be limited to the KNPP site and in particular EP-1. Despite the insignificance 

of the impact, it will be negative and direct. There will not be any secondary or cumulative effects. It will 

be temporary (only for the period of construction) and short-term. The results will be irreversible. 

• During the construction of DSF, limited quantities of wastewater will also be generated mainly from 

cleaning. Suspended solids will be the main pollutant. The wastewater will not represent any problem 

to the NPP site sewerage nor for the wastewater treatment facilities. This impact will occur with 

characteristics similar to the mentioned above and the extent will be limited to the KNPP site. The 

impact is not significant, but it is negative and indirect, because the water mixes up with other waste 

streams from the area. There will not be any secondary or cumulative effects. It will be temporary (only 

for the period of construction) and short-term. The results will be reversible; since the water will be later 

discharged into DC 1 where other treated wastewater streams (from EP-2) are discharged to the same 

receiving water body. The wastewater generated during construction will not disturb the water quality of 

the surrounding water bodies. 

4.1.1.6 Soils and rock environment 

Soils 

During the DSF construction the sources of impact will be: excavation works, transport of building 

materials; and a surplus of the excavated material for storage or utilisation; construction activities on an 

area of 12 160 m 2 and insignificant change of the land use of the NPP site. 

The impact on soils will be negative, direct, temporary, long-term and irreversible, but concentrated within 

the DSF site limits. Indirect impact is likely to occur in the 3-km zone where the excavated surplus earth 

masses will be dumped during the constriction. 

There is no need for the change of category of the land because the construction of new facility does not 

change the existing situation of the KNPP site. 

Geology and rock environment 

The geological structure in the site area, which has a history of large-scale construction of KNPP, is 

affected by the excavation works, embankments and fortification of the numerous buildings and facilities 

and communications under and above the ground. 

Similar impact is expected from the excavation works, embankments, fortifications and other construction 

activities connected with the foundations of DSF. This inevitable influence on the geological structure will 

be negative, direct, temporary, long-lasting and irreversible but of limited scope within the area of the 

construction site. 

Since the DSF foundation is relatively shallow, the rock environment will not be significantly damaged by the 

construction. 


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4.1.1.7 Land usage, landscape, mineral diversity, biological diversity, ecology and cultural 

resources, areas occupied by protected, important and sensitive species of flora 

During DSF construction no impacts from radiation or non-radiation factors are expected on land usage, 

mineral diversity, cultural heritage, natural protected areas. 

Landscape 

As a landscape structure, the evaluated site represents an industrial landscape, because the site exists 

and is located within the boundaries of the site of the Kozloduy NPP. No changes in the structure of 

functioning of the landscape can be anticipated by the implementation of the DSF projects, except for the 

already functioning landscape being the result of the KNPP operation. 

The effect on the landscapes and their components will be local, only within the limit of the site, which has 

an area of 12 160 m 2 . This effect will be present only during construction while the building activities 

(excavation works, soil compaction, erection of the building, road construction, etc.) are carried out. This is 

a limited impact, only on the landscapes located on the site of the DSF. Such impact will not disturb the 

currently existing equilibrium of the landscape types in the region, taking into consideration the significant 

self purification and self restoration potential of the landscapes in the region. Taking into account the 

proper self-restoration of the landscapes in the region will give rise to a new environmental equilibrium. 

Since the DSF construction only impact locally on the landscapes of the site, it may then be stated that the 

works will have a predominantly landscape-esthetical effect. The variations of the landscape components 

are local. There will be no disturbance of the vertical and horizontal structure of the landscape types. 

Biological diversity, areas occupied by protected, important and sensitive species of flora 

These impacts are from noise, vibrations, gases, dust from excavation activities, transport and storage of 

earth masses, construction-assembly and accompanying activities. 

The Kozloduy NPP site is an industrially damaged area with flora and fauna characteristic of anthropogenic 

loaded regions. Limited impacts are expected during construction, such as liquidation of some individual 

representatives of flora and slowly movable fauna types, which are important locally but not to the 

population as a whole. That is why in regard to the general biological diversity of areas occupied by 

protected, important and sensitive species of flora no negative impact is expected. 

The possibilities for negative impacts on biological diversity, areas occupied by protected, important and 

sensitive species of flora are incidental and of negligible occurrence as registered so far. Therefore, it can 

be concluded that during the DSF construction no impact on the general biological diversity, areas occupied 

by protected, important and sensitive species of flora can be expected. 

4.1.1.8 Disposal of constructions related conventional waste 

Possible impacts during DSF construction from the disposal of waste, related to the building activities are 

as follows: 

During the construction of the DSF the potential impact is related to the generation of the following waste: 

surplus excavated soil, domestic refuse generated by the builders, packaging from construction materials 

and equipment, building debris and used oils from the building machinery etc. 

The anticipated impact range is within the boundaries of the DSF where the waste is generated, and within 

the 3 km zone where the waste will be treated or disposed of. The impact is negative since such waste 

contaminates the ground and thus has a direct impact on the DSF site and an indirect impact on the 3 km 

zone. No secondary or cumulative effect can be expected. In terms of frequency, such impact is 

anticipated to be temporary; in terms of duration it will be short term (during construction); and in terms of 

reversibility the impact will be irreversible in 3-km zone and reversible on DSF site. 

Forecast and evaluation of such impacts: only non-radioactive waste will be generated during construction. 

Such waste will be treated in accordance with the established practice at the NPP. Waste will not remain 

on the site; it will be collected immediately after generation and transported outside the site for subsequent 

treatment. The waste is expected to have a negative effect on the DSF site only during construction, i.e. 

the impact thereof on the site is limited and will terminate with construction. 


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4.1.1.9 Noise, vibrations, dust, gases, inert materials mining etc. 

According to the investment proposal, the new DSF will be adjacent to the existing WSF and Auxiliary 

Building 2. 

There are no existing noise sources, exceeding the normal KNPP noise background. 

During the construction, environmental impact of noise, vibrations and dust will be related only to the 

conventional construction activities and equipment. The contractor will specify them in accordance with its 

project implementation plan. 

The major equipment and construction machinery and the corresponding noise levels are given in the 

following Table. 

Tab. 4.1.1.9 Construction machines and noise levels 

Construction machines Typical noise levels [dB(A)] 

Bulldozer 97-105 

Excavator 80-91 

Mobile crane 92-98 

Concrete mixer 85 

Compressor 86-99 

Heavy compactor 85-90 

It is clear that during construction the noise levels of over 90 dB(A) could be expected on the site. Exact 

noise assessment can be made after submission of contractor’s project implementation plan. The utilized 

construction machines and equipment will be evaluated under the conditions of the Regulation for the 

substantial requirements and the assessment of the conformity of the machines and the equipment, which 

will operate in open air regarding the noise from them [L.82]. The Regulation is harmonized with Directive 

2002/88/EC, ammend. Directive 97/68. 

The vibrations generated during construction are related to specific activities only in the area of the 

construction site (DSF site). 

The noise and dust during construction are limited in the area of KNPP site and have no environmental 

impact. Only noise impacts from vehicles, transporting inert materials are likely to occur in the 30-km zone. 

No impact on the geological structure is expected from the extraction of inert materials because the 

Bulgarian River Fleet extracts sands and gravel necessary for construction mainly along the Danube. 

4.1.1.10 Lighting, thermal and electromagnetic radiation 

During the DSF construction there is no expected environmental impact of lighting, thermal and 

electromagnetic radiation. Such an impact is possible during some specific construction activities and if it 

occurs should proceed in accordance with the equipment instruction manuals. 

4.1.1.11 Radiation impacts related to the construction of the DSF 

During the construction phase, there will be no impact of radiation factors caused by the proposed DSF due to 

a complete absence of any radioactive sources in this phase. The only possible use of ionising sources 

during the construction might be non-destructive testing of welded components using the method of 

radiography. The working procedures and the legal requirements shall be strictly followed in such cases. 

During normal WSF operation there is no reason to expect detectable radiation impact on the workers on 

DSF construction site outside the WSF building. 

4.1.2 Possible impacts during DSF operation and decommissioning 

The following section deals with the possible impact of both the radiation and non-radiation factors during 

the operation and the decommissioning of the DSF. The non radiation and radiation impacts on the 

personnel, population and environment are described in Sections from 4.1.2.1 to 4.1.2.8 and the Section 

4.1.2.9 considers only possible radiation impacts, related to DSF operation and decommissioning, Section 

4.1.2.10 considers the cumulative impact of the operation of KNPP and DSF on the environment. 


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The existing WSF has been subject of the EIA study as a part of KNPP (EIA Report from 1999 [O.9]). The 

main conclusion of that report is that its environmental impact is insignificant. One of the reasons for the 

constructions of DSF is that the proposed method for dry storage of SNF is safer, i.e. poses lower health 

risk and lower probability for accidents compared to the wet storage of SNF. Dry storage method excludes 

emissions of waste gases and the amounts of solid and liquid wastes will be lower compared with the storage 

of SNF under water. This storage technology avoids cask corrosion and erosion from water, which occurs in 

WSF. 

4.1.2.1 Radiation and non-radiation impacts on DSF and KNPP site personnel 


During operation 

The closure of the casks is achieved by welded metal lids. This welding will be performed by automatic 

welding machines, in order to minimize personnel exposure to the products of welding, including nonionising 

radiation, high temperature, gas-steam-aerosol mixture of ozone, cyanides, carbon and nitric 

oxides, metal evaporations and oxides. The use of compressor unit, tractors and heavy crane for the 

transportation of the casks may cause pollution with waste products from lubricants and diesel fuel. 

The weight of one cask is around 120 - 130 t. The weight and size of the casks create risks for serious 

labour accidents during transportation and handling of the casks. 

The DSF building consists of: reception hall, instrumental hall for measuring aerosols and gas activity, 

workshop, warehouses, switch room, medical control room, wardrobe and sanitary place with toilets and 

showers. There is also a diesel compressor. The reception hall and the storage zone are separated by a 

sliding door. The casks will be arranged in DSF with the help of a crane, which is operated by a remote 

control. 

In terms of the non-radiation aspect, the main risk factors for the personnel working at the facility are the 

hazardous substances in the working environment (see Table 4.1.2.1-1), the unfavourable physical factors 

of the working environment and also the physical and psycho-sensor load on the staff directly involved in 

the preparation, drying, vacuuming, filling with inert gas, sealing and transportation tasks and the 

prevention of failures and labour accidents (see Table 4.1.2.1-2). 

Tab. 4.1.2.1-1 Hazardous substances and mixtures of them with adverse health effects during operation of DSF and WSF 

Chemical substance/ 

chemical САS № 

Ozone 

10028-15-6 

Ferrous oxides 

Ferrous dust and 

vapours 

Hydrocyanogen, 

cyanides 74-90-8 

Danger sign Adverse health effects Risk exposition 

Xn Harmful Damaged sight, neurasthenia, irritation of the eyes and the 

respiratory tracks, headache, cough, asthma, chronic 

bronchitis, cardio-vascular disturbances. 

Xi Irritant Welding in enclosed premises causes irritation of the 

respiratory tracks and the eyes, cough, asthma, sometimes 

increased temperature. 

T Toxic Headache, weakness, vertigo, cardio-vascular 

disturbances, anemia, endocrine and immune disturbances. 

Helium Inert gas, which can cause suffocation due to lack of 

oxygen in the air. 

Carbon oxide F+Highly Highly flammable, toxic in inhalation - causes hypoxia and 

630-08-0 

flammable, hypoxemia. Leads to creation of carboxylic hemoglobin. 

Т Toxic Damages the nervous, cardio-vascular system and bloodcreating 

organs. Toxic to reproduction. 

Carbon dioxide 

Asphyxiator - replaces the oxygen in the air. Damages the 

24-38-9 

nervous system. 

Nitric oxides 

10102-44-0 

Lubricants, diesel 

8006-61-9 

Т+ Toxic 

Xn Harmful 

Xn Harmful 

N Dangerous to 

environment 

Toxic - damage the lungs alveoli causing lipid peroxidation. 

In high concentrations lead to edema of the lungs, alveolitis. 

Irritates the respiratory tracks, the eyes, the skin, chronic 

bronchitis, frequent bronchopneumonia. 

Hazardous. Danger of cumulative effects. Allergen. 

Damages the nervous system, blood-creation, the liver and 

the kidneys. Mutagen. Dangerous to environment. 

Welding in enclosed 

premises without 

aspiration 



aspiration 



aspiration 

Leakage in the air in 

the working place 

In emissions of 

exhaust-pipe gases, 

risk of anemia, 

headache, weakness. 



headache. 



chronic bronchitis, 

bronchopneumonia. 


requirements for safe 

labour are not followed. 


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The other possible adverse effects on the personnel involved with the operation of DSF are presented in 

Table 4.1.2.1-2. 

Tab. 4.1.2.1-2 Adverse health effects related to physical factors of the working environment, physiological load and 

accidents during operation of DSF and WSF 

Adverse factors Adverse health effects Risk exposition 

Physical factors of the working environment 

Noise (vibrations) from the Damage of the hearing in the high frequencies, Bad maintenance of the equipment, 

compressor, tractors, heavy crane, neurosis, neurasthenia, high blood pressure, no room for resting, no anti-phones 

welding (performed in WSF) disturbed metabolism and immune protection 

Microclimate outside the comfort In de-watering and drying of the casks. Damage Lack of a resting room. Unsuitable 

zone:-Increased air humidity of the cardio-vascular system and the bones and 

joints. 

working clothes, gloves and shoes. 

Microclimate outside the comfort High temperatures in handling SNF and its Mistakes in the temperature control of 

zone: -High temperatures 

storage. Damage of the cardio-vascular system. the working environment. 

Lighting* Danger of accidents, if the working zones do not Non-observance of the lighting 

have the necessary lighting. 

requirements * 

High pressure gases Danger of accidents, traumas and injuries (air or Non-observance of the safety 

helium under pressure). 

requirements. 

Non-ionising radiation during Damage to the eyes. Early development of Unsuitable personal safety devices 

welding (performed in WSF) cataract. 

for the eyes. 

Physiological and ergonomic factors of the working environment 

Load-lifting (cask covers, heavy Damage of the joints and the bone system, Non-observance of the requirements 

equipment) 

cardio-vascular problems. 

of Ordinance № 16/1999 г 

Physical fatigue and stress -big Damage of the joints and the bone system, Non-observance of the requirements 

size of the packing sets. 

neurological and cardio-vascular problems. of Ordinance № 15/1999 

Psycho-sensor load Stress and fatigue, neurasthenia, cardio-vascular 

problems 

Forced working posture In welding (performed in WSF), drying. Damage Specific activities in dry storage of 

Failures and accidents 

of the joints and the bone system. 

SNF. 

Labour accidents Falling in holes from high places, traumas from 

heavy duty machines and equipment 

Specific activities during construction 

Traumas Traumas from heavy duty machines and 

equipment 

Specific activities during construction 

Cask dropping Traumas Specific activities during operation 

Traffic accidents Traumas, burnings, damages caused by oil fuel, Transport of construction materials in 

piling up of inert materials. 

big quantities. 

* Bulgarian State Standard 1786-84 Lighting. Natural and artificial [L.79]. Industrial microclimate [L.78]. Regulation on artificial 

lighting of buildings № 0-49 [L.33]. 

In accordance with the Bulgarian legislation: 

• before their employment the workers should pass a preliminary preventative medical exam from a tem 

of specialists. The conclusion statement must be signed by qualified specialist on internal diseases; 

• every year Labour health service carries out analysis on the workers’ health status. 

The appointment of the workers is performed in accordance with Labour Code. 

Non-radiation impact during DSF operation on the health of DSF personnel and KNPP workers engaged 

with SNF safety is negative, direct, cumulative and combined. It is related to risk of impact of adverse 

chemical, physical, psycho-sensor, physiological and ergonomic factors of the working environment, 

possible incidents and accidents. 

During decommissioning 

DSF is planned to operate for at least 50 years and the decommissioning will be considered after year 

2058. It will be decommissioned in conditions of maximum safety for the personnel and the operation 

processes on the basis of an investment proposal considering the real actual condition of the facility and 

on the scientific and engineering knowledge available at the time. 

The non-radiation impact during DSF decommissioning on the health of DSF and KNPP personnel is 

expected to be similar to that during the construction. 


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Exposure to ionising radiation in Bulgaria is regulated by the Basic Norms for Radiation Protection (BNRP- 

2004) [L.17]. 

This Regulation defines the radiation protection requirements and the measures to be undertaken during 

implementation of activities for the use of nuclear power and ionizing radiation sources (IRS) within the 

terms of the Safe Use of Nuclear Energy Act (SUNEA) [L.1]. In addition, this Regulation controls the 

exposure of members of the general public and to naturally occurring radioactivity. 

In accordance with this document the staff of the NPP and the future DSF is subject to the following 

occupational dose limits. 

The limit of the effective dose for personnel is 100 mSv throughout a 5 year period, but the maximum 

effective dose for each single year shall not exceed 50 mSv. 

The annual equivalent dose limits for the occupational personnel are: 

• 150 mSv for the eye lens; 

• 500 mSv for the skin (this limit applies to the average dose, received from any area of 1 сm 2 , 

regardless the area of the irradiated surface); 

• 500 mSv for palms and forearms, feet and ankles. 

In addition to the limits to radiation exposure specified in this regulation there is an overarching 

requirement to ensure that all radiation exposure should be justified and should be maintained at As Low 

As Reasonably Achievable levels below the dose limit values defined in the Regulation by taking into 

consideration the social and economical conditions. 

Appendix 10 of the Technical Specification of the DSF at KNPP defines the design basis criteria for the 

proposed plant. 

In accordance with the Bulgarian Basic Rules for Radiation Protection [ONRZ-2004] the KNPP Executive 

Director defines every year the applicable dose limits at KNPP. The defined dose limits for year 2005 are: 

• Yearly individual effective dose is limited to 12 mSv for KNPP personnel 

• Yearly individual effective dose is limited to 15 mSv for maintenance personnel of the primary circuit of 

Unit 1-4. 

• For personnel in the protective zone without a radiation work order the daily individual cumulative dose 

is limited to 0.1 mSv, 

• For personnel at the RAWF and the WSF with a radiation work order the individual cumulative dose 

per shift (day) is limited to 0.2 mSv. 

The above doses values are applicable to each part of the human body. The current practice at the WSF 

during normal operation of loading and unloading of a cask is that the maximum individual cumulative dose 

per shift is less than 0.1 mSv. 

The residence time for each individual during the operations, such as sipping, loading, decontamination, 

welding, inspection, transfer and storage, must be calculated and demonstrated to be representative of the 

job(s) to be performed without undue changing of the personnel during the process, i.e. no more than ten 

(10) people shall be involved in all these operations. 

Although the above design basis criteria refer to KNPP staff it is assumed these criteria apply to staff 

manning the DSF. 

The design of the DSF ensures that the radiation exposure of the workers is in accord with the ALARA 

principle and limited by BNRP 2004. It is considered that the experience gained in complying with the 

KNPP procedures likely to be applied during normal operation and accidental conditions shall further 

minimise radiation exposure. 

All legislative requirements, safeguarding radiation protection and nuclear safety of the personnel and the 

population, listed in the Legal References section of this EIA-R will be followed. In accordance with the 

Investment proposal, the radiation protection of personal operating in the storage hall will be achieved by 

means of: 


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• Proper shielding to prevent exposure above permissible limits; 

• On-line radiation monitoring with alarm; 

• Minimisation of work-time for operation and maintenance in a radioactive environment. 

The shielding is provided by the casks themselves and the building walls. 

The following maximum admissible radiation levels have been proposed pursuant to the effective 

legislation as basic criteria for dose loading generated by the new structure under normal operation 

conditions (p. 2.2.5 of the Technical Design Concept, Second Stage): 

• Exposure dose at the cask surface - max. 2 mSv/h; 

• Exposure dose at a distance of 1 m from the casks - max. 0.1 mSv/h; 

• The maximum equivalent doses in the storage room for spent fuel casks of the DSF (protected zone) 

are: 

- for serviced rooms - 5 µSv/h, 

- for semi-serviced rooms - 10 µSv/ h; 

• Maximum equivalent dose within the radiation protection zone of NPP - 1 µSv/h; 

• Maximum equivalent dose outside the radiation protection zone of KNPP - 0.025 µSv/h above the 

radiation background. 

Solid wastes 

Personal protective equipment (PPE) worn by the workers will require to be disposed of as solid 

radioactive waste. It is considered that the quantity of PPE to be disposed of as solid radioactive waste can 

be minimised by the laundering and reuse of clothing, e.g. coveralls, overshoes and caps. Routine 

maintenance and repairs during the operational phase of the DSF may also produce solid radioactive 

waste arising. 

The quantity of PPE to be disposed has not been quantified but is expected to be small in comparison with 

the current corresponding arising at the WSF. 

No data have been submitted on potential dose uptake during implementation of repair works in the DSF. 

The analysis of the stated data has shown that during normal operation of the DSF and if the legislative 

requirements and approved programs for radiation protection are followed, the radiation impact on the 

personnel operating with the casks in WSF can be expected to be within the design criteria, given in the 

Investment Proposal. 


The decommissioning will be conducted under strict compliance with the approved by NRA plans and 

programmes for decommissioning. 

Before the decommissioning of the building, all exposed surfaces will be measured and samples taken to 

verify if there is contamination (roof panels, walls, ceilings, floors, roads, fortified surfaces, surfaces of 

equipment etc.). For hidden or covered materials, representative samples will be taken (insulation, 

surfaces below coatings, tiles, double floors, cables and pipes in channels etc.). For underground, different 

methods will be applied to prove the measurement for release of the area for a conventional dismantling or 

excavation and its disposal. The sampling of groundwater as well as soils at different levels (possibly with 

the help of a robot sent down the sewer pipes) will prove the integrity of the area. 

The dose exposure of the personnel during the decommissioning is expected to be in accordance with the 

regulations valid at the time of decommissioning. The approved programs for decommissioning of the nuclear 

facility and all Bulgarian regulation and international standards will be fulfilled. 


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4.1.2.2 The population during normal operation as well as during decommissioning 

(in health and social aspect) 



Dry storage of spent nuclear fuel leads to lower health risks to the population within the 30-km and the 

100-km zone than wet storage. It reduces the risks of pollution of the environment, the agricultural land 

where mainly forage is grown, the ground water, the drinking water from the sounding wells on the terrace 

of the Danube, the water of the Danube and the banks of the river. 

The height of the fences around the DSF and WSF will be 3 m. The distance between the fence and the 

building of the facility is at least 3 m. All the access doors will be controlled to prevent access of 

unauthorised people. Fire alarm system, a system for closing and locking the doors, emergency alarm 

system and video monitoring are envisaged. They will be operated by remote control. 

European health indicators for the evaluation of the impact of environment on population are: atmospheric 

air quality, noise level, surrounding conditions - including those from home, traffic accidents, drinking water 

quality, accidents with chemical substances and radiation. From the data regarding the non-radiation risks 

connected with the investment proposal, it is concluded that the operation of DSF in the course of 50 years 

will not have negative effect on the population within the 100-km zone. 

Any kind of significant social impact is not expected. 


It is expected that there will be no non-radiation impact during decommissioning on the population beyond 

KNPP site, because there will be no excavation of inert materials and transportation activities outside the 

3-km zone. The negative impact caused by the work of heavy construction machines and transportation of 

large quantities of demolition waste will be limited within the 3-km zone around KNPP where the waste will 

be disposed. 

No negative impact on the population beyond the 3-km zone around KNPP site is expected during DSF 

decommissioning. 



The limits of exposure for a member of the general public are as follows: 

• an annual effective dose of 1 mSv. Exposure in excess of this limit may be permitted under special 

circumstances and under the condition that the average effective dose over the 5 consequent years 

will not exceed 1 mSv. 

The annual equivalent dose limits, whilst following the effective dose limits as per Para 1 and 2 are as 

follows: 

• 15 mSv for the eye lens; 

• 50 mSv for the skin (this limit applies to the average dose, received from any area of 1 сm 2 , regardless 

the area of the irradiated surface). 

Potential impact of the ionising radiation on the population in the vicinity of the Kozloduy NPP is assessed 

in the Safety Case. To quantify these impacts the world-wide methodology based on US Environment 

Protection Agency (US EPA) recommendations has been used. This methodology consists of four steps: 

1. Hazard identification 

2. Dose-response evaluation 

3. Exposure assessment 

4. Risk characterisation 


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1. Hazard identification 

The spent nuclear fuel will be stored inside the sealed casks, which allow no releases into the environment 

and provide adequate shielding from gamma and neutron radiation. 

Other impacts on the environment due to discharges of gaseous, particulate, liquid and solid wastes from 

the loading operations and DSF operations are considered to be small. 

Therefore, the only health hazard factor to be considered is the external radiation emanating from the 

casks during transport from the WSF to the DSF and during storage in the DSF. 

Regarding the health effects, the assessed case represents long-term (even whole-life) exposure to the 

low doses of radiation. The radiation exposure of the workers is within the design constraints during normal 

operations and therefore well below levels at which deterministic effects may be expected to occur. 

However any exposure to radiation is currently considered to result in an increase in stochastic effects in 

proportion to the radiation dose incurred. 

2. Dose - response evaluation 

The health risk assessment is based on the understanding of the relationship between the dose and the 

effect. The current understanding is that exposure to radiation have stochastic effects. This means that as 

the dose increases the probability the occurrence of a stochastic effect, i.e. the likelihood of incurring a 

cancer increases, but not the significance of the consequences. This effect is represented with the number 

of casualties in the population, relatively to the total population (e.g. No. of casualties per million etc.). 

The non-threshold linear model of ionising radiation effects, promulgated by the ICRP (International 

Commission on Radiological Protection, 1991) is the current accepted model. This concept comes from the 

idea that radiation dose (even if minimal) has a carcinogenic effect and the relation between the dose and 

the likelihood of occurrence is (in the range of low doses) linear. For the time being all the regulations, risk 

coefficients and limits are based on this model. 

The key for the limit value is the social acceptability of the risk. The international references quoted as the 

generally applicable suggest a limit of tolerability of risk of 1 casualty per 1 000 000 inhabitants per year 

(1E-06). This is a theoretical value and from the practical points of view an insignificant value. For example 

in Europe every fourth to fifth person dies of cancer. Despite this fact, this strict criterion 1E-06 is used for 

further analyses. 

ICRP have recommended a nominal risk coefficient corresponding to the probability of the death of all 

types of cancer resulting from radiation exposure of the general population of P = 0.05 per Sv i.e. if 100 

people each incurred a radiation exposure of 1 Sv, 5 people would incur a fatal cancer. 

3. Exposure assessment 

The calculated equivalent dose rate at the nearest inhabited area i.e. the town of Kozloduy which is about 

3500 m away is up to 1.3E-20 μSv/h, i.e. up to 1.1E-16 μSv/year (c.f. section 4.1.2.9). 

Because it is assumed the effects of ionising radiation are cumulative, the whole-life dose is obtained by 

multiplication of the annual dose by the 70 years of life 

1.1E-16 μSv/year x 70 years = 7.7E-15 μSv. 

4. Risk characterisation 

According to the ICRP dose - response relationship (1 Sv => P=0.05, i.e. 1 μSv => P=5E-08) it can be 

calculated, that the whole-life risk to an individual in the town of Kozloduy is 

7.7E-15 μSv x 5E-08 μSv -1 = 3.9E-22. 

i.e. 16 orders of magnitude below the international criterion of acceptability (1E-06). The expected risk is 

practically zero. 

Conclusion 

The health risk of the regular operation of the DSF at the Kozloduy NPP in the nearest inhabited place (town 

Kozloduy) is negligible. 


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The DSF expected dose equivalent in the town Kozloduy (about 1E-20 μSv/h) is insignificant in 

comparison with the dose equivalent of the natural background (0.1 μSv/h). It means that the contribution 

of the DSF is about 19 orders of magnitude less than the natural radiation to which the inhabitants are 

permanently exposed. Because of that is assumed that no impact on the population is expected during 

DSF operation. 


During decommissioning controls will be put in place to ensure that any releases of radioactivity to the 

environment. The quantity of radiation released to the environment will depend on the operations and any 

contamination of the DSF during the operational phase. Prior to decommissioning the DSF will be 

decontaminated under controlled conditions so that when it comes to the actual decommissioning of the 

plant all radioactive contamination will be removed. 

4.1.2.3 The atmospheric air and the atmosphere during normal operation 

as well as during decommissioning 

The DSF is divided in two basic operating areas: Reception and Storage halls. From the radiation impact 

point of view the Storage hall is more important. It is naturally ventilated and serves for storing of the 

CONSTOR casks. Appropriately sized air inlets and outlets will support the natural air convection that will 

provide sufficient cooling to guarantee that the maximum allowable surface temperature of the casks will 

not be exceeded. 

The Storage hall will be equipped with a reliable radiation monitoring system connected to the existing 

plant radiation monitoring system. It will be designed to ensure safe and accurate monitoring during both 

normal and accident conditions. 

The Reception hall ventilation system will be designed and constructed in accordance with the accepted 

international safety requirements for nuclear installations. 



There are no emission sources of noxious pollutants and particulate matter in either the Reception hall or 

Storage hall during the operation phase that will have a negative effect on ambient air, because there are 

no activities such as combustion or production processes to produce them. 

The emissions of gaseous pollutants from internal combustion engines of the special transport machinery in 

the DSF area are insignificant. 


During the decommissioning stage of the DSF installation the impact on ambient air will be the same as 

during the construction phase - an over-emission of exhaust gases from internal combustion engines, 

caused by heavy building off-road mobile machinery and dust emission during conventional demolition of 

the building elements and excavation of the reinforced foundations and aprons or roads and the removal of 

the demolished material. 



The concept of the DSF has taken into consideration all the suitable types of licensed systems and 

equipment for receipt, dry storage and eventual removal of spent nuclear fuel with proven qualities. The 

requirements for the proposed DSF are for developed and licensed technology with proven practice of 

storage of spent nuclear fuel. It guarantees the reliable and safe operation in normal and emergency 

conditions and has all the necessary systems and equipment for receipt, storage and eventual sending the 


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spent nuclear fuel for further processing in consideration with the requirements for safety and protection of 

the population and the environment from radioactive discharge. 

The casks will be loaded, sealed and tested in the WSF. Prior to the movement of casks from the WSF to 

the DSF the external surfaces of the casks are decontaminated. On receipt of the casks at the DSF the 

casks are placed in the storage position. Contamination control measures including checks by plant 

personnel will be made of the external surface contamination of equipment at the entrance and the exit of 

each area that requires operator access during normal operation. Also contamination of floors and walls 

will be controlled and monitored in order to minimise the spread of contamination. The storage cask is 

welded system and is designed to be completely sealed from the external environment. Therefore during 

normal operations there will be no discharge of radioactive material to atmosphere. 


No generation of gaseous waste is expected during the process of decommissioning of DSF. 

Decommissioning plans will be developed incorporating the requirements of the regulations in force at that 

time. Therefore, no negative impact on the environment will be expected during the decommissioning. 

4.1.2.4 Waters during normal operation as well as during decommissioning 

Non-radiation aspect impacts 


Given the low quantity of potable water needed (0.6 l/s), it can be considered that the impact to the overall 

KNPP water use and to the sources that provide water for KNPP will be insignificant. The flow of 0.6 l/s 

represents the maximum capacity of the system for water use, in reality the water use will be much lower. 

The loading/unloading operations which will take place at WSF will not create additional impact to the 

water use of WSF. 

The sewage wastewater from washrooms and toilets of the Reception Hall has no impact in terms of any 

radiation aspects. For the non-radiation aspects, it must be stated that the wastewater stream will not 

represent any problem to the site sewerage of KNPP nor for the wastewater treatment facilities of the plant 

if they operate properly. The wastewater generated from washrooms and toilets will not disturb the water 

quality of the surrounding water bodies. 

The cask loading/unloading operations with spent fuel assemblies at WSF will not lead to increased 

impacts to the discharge of wastewater from WSF. 

Rainfall waters have only a non-radiation-related impact that will be insignificant. There will not be 

secondary or cumulative effects. It will be temporary (only when it rains) and long-term. The results will be 

reversible, since the water will be later discharged together with other treated wastewater streams to the 

receiving water body. Rainfall water has not significant but positive effect both to the water quality of the 

surrounding water bodies and to the recovery of the water resources. 

The thermal impact on the Danube river is excluded. 


No impacts are expected to the waters related to the decommissioning period. 

Radiation aspect impacts 


The wastewater generated from the showers and the washing basins of the workshop may impact on the 

environment if the water is contaminated. That is why this stream must be properly retained in tanks and 

discharged to the sewerage only after appropriate control or treatment when necessary. For the radiation 


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aspect of the impact, it will be the same as the rest of the NPP radioactive waste waters. No impact is 

expected. It is not envisaged that liquid discharges from the DSF will be radiologically significant. No 

operations are envisaged that produce a liquid waste stream in normal operations other than arising from 

showers and washing facilities in the change room. 


If unacceptable contamination is detected in the showers drainage systems or the building structure, this 

will be removed using standard procedures e.g., suction, wiping, wet wiping, disintegrative surface 

removal. After measurement has shown that no contamination is present, the building structure and 

equipment will be released from radiological controls and can be handled in a conventional way for 

demolition or recycling. 

4.1.2.5 On the soil and the rock environment during normal operation 

and decommissioning 



The impact of the non-radiation factors is expressed as possible pollution of adjacent territories with 

conventional waste (domestic refuse and production waste), pollution with petroleum products resulting 

from spillage and from gases, from repairs on adjacent structures or on the building of the storage facility. 

Such pollution is typical for any industrial site and also for the NPP site. 

No impact due to non-radiation factors on the soil and the rock environment during normal operation is 

expected. 


No negative impact due to non-radiation factors on the soil and the rock environment during 

decommissioning is expected if decommissioning programme and radiation procedures are strictly followed. 



During normal operation of the DSF no pollution of the lands and soils around it can be anticipated 

because the spent fuel is stored in casks with the required shielding. Only small amounts of solid wastes 

(clothing, shoes) are anticipated. These will be collected and treated in a suitable manner and will not 

pollute the land and soils. 

No radiation effects on the land and soils are expected during normal operation of DSF. 

No impact upon the geological and rock environment is expected during normal operation. 


No impact upon the geological environment, rock environment, land or soils is expected during 

decommissioning. Radioactive releases above the limit are not expected during decommissioning if 

decommissioning programme and radiation protection procedures are strictly followed. 


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4.1.2.6 Land usage, landscape, mineral diversity, biological diversity, ecology and cultural 

resources; areas occupied by protected, important and sensitive species of flora and 

fauna; picturesque sites; sites of historical and cultural importance, sites which are 

protected by international or national laws because of their ecological, natural, cultural or 

any other kind of significance, during DSF normal operation as well as during 

decommissioning 



During DSF normal operation no impacts from non-radiation factors are expected on land usage, mineral 

diversity, biological diversity, ecology and cultural resources; areas occupied by protected, important and 

sensitive species of flora and fauna; picturesque sites; sites of historical and cultural importance, sites which 

are protected by international or national laws. 


During DSF decommissioning, no impacts from non-radiation factors are expected on land usage, mineral 



are protected by international or national laws. 



A high level of safety is achieved in the storage of SNF using the cask technology which incorporates a 

"zero-release" concept. That is why during DSF normal operation, no impacts from radiation factors are 

expected on land usage, mineral diversity, biological diversity, ecology and cultural resources; areas 

occupied by protected, important and sensitive species of flora and fauna; picturesque sites; sites of 

historical and cultural importance, sites which are protected by international or national laws because of the 

‘zero-release’ concept. 


During DSF decommissioning, no impacts from radiation factors are expected on land usage, mineral 



are protected by international or national laws, if decommissioning programme and radiation protection 

procedures are strictly followed. 

4.1.2.7 Generation and disposal of conventional and other waste, 

during normal operation and decommissioning 

Wastes generated during DSF normal operation and decommissioning will be collected, classified, treated, 

stored and disposed of according to the legislation in force and the established good practices at KNPP. 

The possible impacts during DSF operation and decommissioning resulting from the disposal of 

conventional and other type of waste are described below. 



The possible impacts due to non-radiation aspects during operation are related to the generation of the 

following non-radioactive waste: domestic refuse by site personnel; building debris in case of repairs during 


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operation and demolition; production waste, packages and hazardous waste, such as used-up luminescent 

(mercury) lamps. 

The anticipated impact range of non-radioactive waste is within the boundaries of the DSF, and within the 

3 km zone - where the waste is treated or disposed off. The impact is negative and direct on the DSF site, 

and indirect on the 3 km zone. No secondary or cumulative effect can be expected. In terms of frequency, 

such impact is anticipated to be permanent; in terms of duration - it will be long-term (50 years of DSF 

operation); and in terms of reversibility - the impact will be reversible on the DSF site and irreversible in the 

3 km zone around KNPP, because there the waste will be treated. 


The possible impacts due to non-radiation aspects during decommissioning are related to the generation of 

construction waste, resulting from demolition of DSF building and facilities. After a radioactivity check and 

confirmation that it is not contaminated, the waste will be transported by lorries to construction waste site. 

The impact is the same as of the waste generated during the construction phase. 

In radiation aspect 


The possible impacts due to radiation aspects are related to the generation of the following radioactive 

waste: protective clothing, shoes and gloves for the attending personnel. The special protective clothes will 

be treated as radioactive waste; if after having been subjected to decontamination at specialised laundries 

the contamination is in excess of the admissible values stated in BNRP 2004. 

The anticipated range of the impact of such waste is within the DSF site boundaries, and within the limits of 

the Kozloduy NPP, since such waste will be treated there. The impact is negative; the waste has a direct 

impact on the DSF site and an indirect impact on the NPP site, since the amount of treated radioactive 

waste will be increased. No secondary or cumulative effect can be expected. In terms of frequency such 

impact is anticipated to be permanent, since waste will be continuously generated; in terms of duration the 

impact is anticipated to be lasting (since the operation is for an extended period of a minimum of 50 years); 

and in terms of reversibility - reversible on DSF site and irreversible for KNPP. 

Forecast and evaluation of such impacts: radioactive waste will be generated in time over the whole 

duration of operation; however, the waste quantity will be minimal and related to the protection of the 

operating personnel. Such waste will not remain on the site; it will be collected immediately after 

generation and transported outside the site for subsequent treatment, thus having a limited effect on the 

DSF site. 


Radioactive waste is expected to be generated during decommissioning. It will be collected and 

transported from the DSF to the RAW facility for further treatment according the established practice in 

KNPP. The expected radioactive waste will have very low activity. During decommissioning, no negative 

impact is expected if the plans for decommissioning of the nuclear facility are strictly followed as well as all 

Bulgarian and international legislative requirements in force at that time. 

4.1.2.8 From materially valuable items and reduction the non-renewable resources 

During the operation and decommissioning of DSF, no impact is expected in non-radiation and radiation 

aspect from materially valuable items and reduction of non-renewable resources, because no use of materially 

valuable items and non-renewable resources is envisaged. 


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4.1.2.9 Radiation impacts related to the DSF operation and decommissioning 


An estimate of the radiological consequences due to the movement of the casks containing irradiated fuel 

and their subsequent storage in the DSF has been made. The following assumptions were made in order 

to estimate the external dose due to the movement and storage of this fuel: 

• 420 WWER-440 and 108 WWER-1000 irradiated fuel assemblies will be moved per year (as described 

in attachment 7 of Design And Implementation Of Dry Spent Fuel Storage Facility At Kozloduy Nuclear 

Power Plant Tender Documents Volume III Employer’s Requirements, Revision 3), 

• each fuel movement will comprise of either 84 WWER-440 fuel assemblies per cask or 19 WWER- 

1000 fuel assemblies per cask, i.e. a total of 11 cask movements per year, 

• 1 hr transfer time outside shielded facilities, 

• dose rate of 0.1 mSv/h at 1 m from the fuel cask, 

• no benefit claimed for shielding by surrounding buildings or morphology. 

The estimated time weighted doses due to fuel movements are given in the following table: 

Tab. 4.1.2.9-1 Estimated time weighted dose due to fuel movements 

distance dose rate time weighted 

m Sv/h Sv/y µSv/h 

1 1.00E-04 1.1E-03 1.3E-01 

3 2.98E-05 3.3E-04 3.7E-02 

50 1.47E-08 1.6E-07 1.8E-05 

100 1.32E-09 1.4E-08 1.7E-06 

200 4.25E-11 4.7E-10 5.3E-08 

300 2.44E-12 2.7E-11 3.1E-09 

400 1.77E-13 2.0E-12 2.2E-10 

700 1.25E-16 1.4E-15 1.6E-13 

1000 1.31E-19 1.4E-18 1.6E-16 

1500 2.10E-24 2.3E-23 2.6E-21 

2000 4.23E-29 4.7E-28 5.3E-26 

3500 6.39E-43 7.0E-42 8.0E-40 

A simple calculation of the dose rate as a function of distance was undertaken. The assumptions made are 

described below: 

• the store active area is 40 m x 40 m x 5 m high, 

• full time occupancy at the stated distance, 

• 1 µSv/h at 3 m from the building, i.e. at the DSF perimeter fence, 

• the calculation includes a contribution from air scatter. 

Estimated external dose rates from fuel stored in the DSF are given in the following table: 

Tab. 4.1.2.9-2 Estimated external dose rates 

Distance m Sv/y µSv/h 

1 2.2E-02 2.5E+00 

3 8.8E-03 1.0E+00 

50 1.1E-03 1.2E-01 

100 1.7E-04 1.9E-02 

200 1.9E-05 2.1E-03 

300 3.4E-06 3.9E-04 

400 7.7E-07 8.8E-05 

700 1.7E-08 1.9E-06 

1000 2.9E-10 3.3E-08 

1500 4.1E-13 4.6E-11 

2000 3.2E-15 3.7E-13 

3500 1.2E-22 1.3E-20 

The estimated dose rate to external dose points was found by the summation of the time weighted dose 

rate from the transport of the casks with irradiated fuel and the dose rate from the DSF. 


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The results of the total external dose rate from fuel movements and stored fuel are given below: 

Tab. 4.1.2.9-3 Total external dose rate from fuel movements and stored fuel 

Distance m µSv/h 

1 2.6E+00 

3 1.0E+00 

50 1.2E-01 

100 1.9E-02 

200 2.1E-03 

300 3.9E-04 

400 8.8E-05 

700 1.9E-06 

1000 3.3E-08 

1500 4.6E-11 

2000 3.7E-13 

3500 1.3E-20 

The dose rate at the site boundary (100 m) is predicted to be 0.019 µSv/h which is well within the 

maximum equivalent dose within the controlled zone of NPP of 1 µSv/h. The predicted dose rate at the 

perimeter of the protected zone, taken to be at a distance of 2 km, is estimated to be 4x10 -13 µSv/h, 

significantly below the limit of 0.025µSv/h above the radiation background. 

The distance of the nearest habitation, Kozloduy town, is 3.5 km from the store. It is estimated that the 

dose rate at 3.5 km resulting from operations at the DSF is approximately 1x10 -20 µSv/h. The average 

natural background dose rate is about 0.1 µSv/h. Therefore it can be seen that the additional contribution 

that normal operations at the DSF makes to the public radiation exposure at Kozloduy town may be 

considered to be negligible. 


According to the regulation on safety during decommissioning of nuclear facilities [L.21], art. 6 and the 

Technical Specification, the Owner of the permit for site selection, design, construction and starting of DSF 

operation shall develop initial and intermediate concepts and plans for decommissioning of the nuclear 

facility. All Bulgarian and international legislative requirements on decommissioning of the nuclear facility in 

force during the decommissioning shall be followed. 

The major goal of DSF decommissioning is a complete removal of ionising radiation sources from the site 

with option for later utilisation (art.4 (2) of Regulation for Safe Decommissioning of Nuclear Facilities 

[L.21]). 

According to the National Strategy for SNF and RAW Management (Resolution №693/1999), there is no 

plan to reuse the DSF site, and at this stage, it can be assumed that the DSF site will be completely 

cleared. Therefore, the design concept must include measures for the complete decontamination of the 

DSF facility and of the adjacent site. 

4.1.2.10 Cumulative impact on environment of Kozloduy NPP and DSF operation 


During operation phase and during the decommissioning of the DSF, no cumulative impact of non-radioactive 

noxious substances is expected. The emissions of gaseous pollutants from the internal combustion engines 

of the special transport machinery are insignificant, and they will not been transported to long distance or 

prevent the atmospheric abilities to purge. No cumulative impact from wastes and wastewater is expected 

as well. 


The estimated dose rate at 3.5 km (the distance of nearest inhabited place) resulting from operations at the 

DSF is approximately 1 x 10 -20 µSv/h. It means that the individual effective dose of the public is up to 

1 x 10 -15 µSv/year. 


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The maximum individual effective dose of the public resulting from the gaseous releases of the NPP is 

estimated to be in the range of 2.68-3.76 x 10 -7 Sv/year and resulting from the liquid releases of the NPP is 

up to 1.66 x 10 -11 Sv/year. 

It means that the contribution of DSF to the radiation background in the vicinity of Kozloduy town from 

external radiation is negligible and is at least 4 orders of magnitude below the contribution of the other 

facilities at KNPP. 

There will be no gaseous radioactive discharges from the DSF and no liquid radioactive discharges are 

expected. However as noted the casks are sealed by welding, are cleaned and decontaminated prior to 

transfer from the WSF to the DSF. It is therefore expected that the impact from these routes will be 

negligible. 

It is concluded that the cumulative impact on the environment is negligible. 

4.1.3 Possible impacts resulting from accidents 

The following 3 categories of abnormal events are considered during casks design: 

1. Incidents - these are situations which, on reliability grounds, are expected to occur once or more 

during the operational life of the facility. The design is able to withstand such incidents, such that 

there are no additional environmental impacts above the very low levels associated with periods of 

normal operation. 

2. Postulated accidents - these are situations that, on reliability grounds would not be expected to occur 

during the operational life of the facility but which the design is able to withstand. 

3. Low probability accidents - these are very low frequency events, typically due to unforeseen 

circumstances or external factors. The design is also able to withstand these events. 

The accidents considered within the assessment of nuclear safety are chosen because they represent the 

design envelope of conditions, or stresses that may potentially be experienced by the storage casks. 

None of the accidents considered result in loss of integrity of the fuel cask, based on the “zero-release” 

concept. 

Tab.4.1.3-1 Faults involving a fully loaded modular storage cask considered to represent the design basis envelope 

Fault type Description 

Handling faults 

Drop of a cask during withdrawal from or insertion into the pond of the WSF 

The WSF crane is designed in accordance with the relevant nuclear standard for fuel handling, in particular 

avoidance of a single point failures resulting in a dropped load. The operation of this crane only by suitably 

qualified and operated by trained and experienced operators. 

During transfer of a fully loaded cask from the loading position in the pool, the cask is lifted to a maximum 

height of 9 m above the pool bottom. The cask is protected by a shock absorber mounted to the cask bottom 

during these lifting operations. It is assumed that a cask is dropped from the crane during the lifting 

operation. The drop of the cask (with the shock absorber mounted to the cask bottom) is analysed, treating 

the pool bottom as an unyielding foundation. 

Possible impact on the environment and human health: Not expected. 

Cask drop in the WSF 

The WSF crane is designed in accordance with the relevant nuclear standard for the fuel handling, in 

particular avoidance of a single point failures resulting in a dropped load. The operation of this crane only by 

suitably qualified and operated by trained and experienced operators. 

During cask handling in the WSF, outside of the pool, the cask is lifted to a maximum height of 1.25 m above 

the floor. It is assumed that a cask (with the shock absorber mounted to the cask bottom) is dropped from 

the maximum lifting height onto an unyielding foundation. 



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Handling faults 

External events 

Drop of a cask during lowering onto and lifting from the transporter in the WSF 

The WSF crane is designed in accordance with the relevant nuclear standard for fuel handling, in particular 

avoidance of a single point failures resulting in a dropped load. The operation of this crane only by suitably 

qualified and operated by trained and experienced operators. 

For the transfer of the cask from the cask preparation position to the transporter and vice versa the use of 

two shock absorbers (floor shock absorber next to the cask preparation position and shock absorber on the 

transporter). 

The cask is lifted a few centimetres at the cask preparation position and then lowered to the intermediate 

level of 0.3 m above floor over the 0.2 m high floor shock absorber located in front of the cask preparation 

position. The maximum drop height is less than two metres (assuming that the cask has been lifted at the 

cask preparation position erroneously up to the maximum lifting height of the crane. 

At the hatch in the floor the cask is lowered down from intermediate level to the transporter above the shock 

absorber mounted onto the transporter. The maximum possible dropping height amounts to about six 

meters. 


Drop in DSF during cask receipt 

The casks are transported from the WSF to the DSF in a horizontal orientation on a trailer. When the casks 

are unloaded from the trailer, they are lifted by a crane into the upright position and lowered onto the DSF 

floor. This operation is only allowed at a special position in the DSF, where a shock absorber is integrated 

into the DSF floor. It is assumed that a cask is dropped onto this shock absorber during lifting operations. 


Drop from crane in DSF 

The upright cask is moved by crane in the DSF with a lift height limited to 0.3 m. It is assumed that a cask is 

dropped from this height onto an unyielding foundation. 


Cask hit by cask in DSF 

It is assumed that a fully loaded cask, lifted by crane and moving horizontally with the maximum crane speed 

(0.6 m/s), collides with another, stationary, cask in the DSF. 


Gas cloud explosion in DSF 

It is assumed that a cask is subjected to a pressure wave from a hypothetical gas cloud explosion. The 

parameters for the explosion are taken from German regulations and represent maximum pressure waves 

from chemical reactions. 


Pressure wave 

The DSF is designed against explosions from a pressure vessel associated with units 1-4 of KNPP; from a 

pressure vessel associated with units 5 and 6. 


Fire 

It is assumed that a cask is subjected to the thermal load from a fire. The fire is characterised by an average 

flame temperature of 600 °C and a duration of 1 h. 


Earthquake affecting the DSF 

The absence of evidence of Quaternary activity and tectonics movements and the fact that the strongest 

earthquakes registered were with magnitude М = 3,6 lead to the conclusion that in the region of NPP 

“Kozloduy” no earthquake with Мmax = 4,0 can be expected. This result is in agreement with the seismic 

district division of Bulgaria in “ Regulations for design of buildings and facilities in seismic regions” from 1987 

according to which the buildings and facilities in the town of Kozloduy and around it are protected for degree 

VII with seismic coefficient Kс = 0.10. 

Safety against cask tip-over or sliding is demonstrated for the limit of static accelerations (horizontal and 

vertical). 


Earthquake affecting the WSF 

The earthquake parameters are as above. The cask configuration includes the shock absorber, on which the 

cask is positioned in the supporting nest in the WSF. The analysis demonstrates the cask integrity and the 

stability of the cask position. 



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External events 

External flooding 

KNPP is entirely located the terrain above flood level, about 3.5 km away from the right bank of Danube river 

The average elevation of the DSF site is 35 m above the sea level, while the elevation of the flood terrace is 

25-30 m. 


Tornado 

Dangerous meteorological phenomena for that part of Bulgaria are considered to be a tornado and 

hailstorm. The probability of tornado occurrence is approximately 10 -6 cases per year. In the area of the 

KNPP a hailstorms is a random phenomenon to the statistical point of view due to its infrequency and spatial 

variation. 


Traffic accidents 

The movements of the special transport machinery on the site are controlled by strictly elaborated schedules 

and routes with low velocity and there is negligible probability of vehicle’s accidents. 


In addition to these design basis faults, two more severe faults are considered. These ‘beyond design 

basis’ accidents are chosen to represent highly improbable situations where the storage casks would 

receive greater stresses. Even under these extreme conditions, any adverse effects on the environment 

are shown to be prevented. 

Tab.4.1.3-2 Faults involving a full modular storage cask considered to represent beyond design basis conditions 

Fault type Description 

Beyond design 

basis 

Debris impact 

Impact of debris from an aeroplane crashing onto the DSF is analysed. The maximum load on the casks 

results from compact debris (e. g. turbine shaft), and the analysis is performed for a shaft with a mass of 

1000 kg and speed of 300 m/s impacting centrally onto the cask lid system. The analysis demonstrates that 

the cask integrity is maintained. 


Loss of heat removal 

It is assumed that the DSF building, or parts of it, collapse onto the casks and bury the casks so that the 

heat removal by natural air convection is impaired or completely stopped. The thermal analysis 

demonstrates that there is sufficient time for intervention before the permissible temperature limits are 

exceeded. 


A detailed safety analysis report considering all the identified faults will be developed additionally and 

submitted to the Nuclear Regulatory Agency for approval before active commissioning can take place. 

The inclusion of DSF in the Emergency plan of Kozloduy NPP developed in accordance with the principle 

of ALARA provides the organisation of all activities for prevention of emergency and other situations 

leading to facility safety Kozloduy NPP has an Emergency Plan, which is in compliance with the 

requirements of the harmonised legislative documents and all the necessary safety requirements in case of 

natural accidents i.e. floods, freezing, snowfalls, earthquakes, strong storms and winds, are taken into 

consideration. 

Summary 


which include the ‘zero-release’ concept utilised in the storage casks. The design of this modular storage 

system ensures that the casks can fulfil their safety related functions throughout the intended storage 

period, predicted to be at least 50 years. 

The preliminary safety analysis performed here demonstrates that there is no loss of cask integrity in any 

foreseeable accident conditions as represented by handling faults resulting from a dropped cask. Any adverse 

effects on the environment are prevented even under the most extreme conditions considered within the 

design basis, as represented by external events such as earthquake and fire. 

The accident scenarios (and consequent effect on human health and the environment) that will be 

subjected to a detailed quantitative assessment in the Safety Analysis Report (SAR) will substantiate the 


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‘zero-release‘ concept, and will justify that there will not be any more significant consequences on the 

environment or population then those described in the current EIA. 

As part of the safety licensing process, the approval of the Interim SAR by the Nuclear Regulatory Agency 

is required before construction of the DSF can commence. Approval of the Final SAR by the Nuclear 

Regulatory Agency is required before operation of the DSF can commence. The assessment will be used 

in the update of the KNPP Emergency Plan which will include DSF. 

4.1.4 Matrix for assessment of potential impacts considering the non-radiation 

aspect during implementation of DSF 

Impact 

on/from 

1.1. Personnel 

1.2. 

Population 

1.3. 

Use of land 

Occurrence 

Probability 

Expected during 

construction - 

new jobs 


construction- 

chemical, 

physical, 

physiological 

factors 


the operation – 

new jobs 


the operation- 

chemical, 

physical, 

physiological 

factors 

Expected in 

case of injuries 

during 

construction 

and operation 

or in case of 

accidents 


construction 


the operation 

Expected 

Coverage 1 

Positive / 

Negative 

Direct / 

Indirect 

Secondary Cumulative 

DSF Site Positive Direct Not expected Not expected Temporary Medium Reversible - 

DSF Site Positive Direct Not expected Not expected Permanent Long-term Reversible - 

DSF Site, Negative Direct Not 

KNPP Site and 

the 30 km 

zone 

expected 

30 km zone Negative 

(noise and 

dust) 

The town of 

Kozloduy and 

the 

neighbouring 

municipalities 

The town of 

Kozloduy and 

the 

neighbouring 

municipalities 

Positive 

(new jobs) 

Nature 

Not expected Temporary Short-term Reversible Measures for health & 

safety at work accident 

prevention Regulations, 

Fire Protection, 

Technical Norms in 

compliance with the 

national regulatory acts 

and standards 

Indirect Not expected Not expected Temporary Short-term Reversible Measures according to 

p.1.5, p. 1.11 and p.1.12 

of Matrix 4.1.4 

Direct Not 

expected 

Characteristics 

DSF Site Negative Direct Not expected Expected Temporary Medium Reversible Health & Safety at work 

Regulations 

DSF Site Negative Direct Not expected Expected 

Not expected Permanent Medium Reversible - 

Positive (new Direct 

jobs) 

Not expected Not expected Permanent Medium Reversible - 

Not expected - - - - - - - - - 

1 DSF Site, KNPP Site, 3-km zone, 30-km zone, 100-km zone, country, trans-boundary character 2 Permanent or temporary 

3 Short-, Medium-, or Long-term 4 Reversible or irreversible 

Italic – elements of the matrix, which have positive impacts and elements from which any impact is not expected 

Bold – elements of the matrix, from which significant negative impact is expected 

Underlined - elements of the matrix, form which insignificant impact is expected 

Frequency 2 

Duration 3 Reversibility 4 

Temporary Long-term Reversible 

regarding 

general health 

Measures to prevent, 

mitigate or compensate 

the negative impact 

Health & Safety at work 

Regulations 


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Impact 

on/from 

1.4. Tangible 

assets - 

consumption 

of fuels, row 

materials and 

materials 

1.5. 

Atmospheric 

air, 

atmosphere 

Occurrence 

Probability 

Expected 

consumption of 

fuels and 

construction 

materials 

during 

construction 

Consumption 

of row 

materials and 

materials 

during the two 

stages 

Positive / 

Negative 

Direct / 

Indirect 

For electricity, Negative Direct Not 

water – KNPP 

Site; for 

construction 

materials - 

30 km zone 

expected 

For electricity, 

fuels and 

other 

materials – 

KNPP Site 

Expected during DSF Site; 

construction KNPP; 3km 

(dust and gases and 30-km 

from vehicles zones 

and construction 

technique) 


operation 

(gaseous from 

motor vehicles) 

1.6. Waters Expected during 

construction – 

water 

consumption 


construction - 

generation of 

wastewater 


operation - 

consumption of 

water 


operation - 

generation of 

waste water 


operation - rain 

water 

1.7. 


Soils and rock construction 

environment 

Expected 

Coverage 1 

DSF Site, 

KNPP Site 

(EP-1) 

KNPP Site 

(EP-1) 

Negative Direct Not 

expected 


Not expected Temporary Short-term Irreversible Measures for safe 

transportation, storage 

and effective use of 

fuels, row materials and 

materials 

Not expected Permanent Long-term Irreversible Measures for safe 

transportation, storage 

and effective use of 

fuels, row materials and 

materials 

Negative Direct - DSF Not expected Not expected Temporary Short-term Reversible Use of techniques to 

Site; Indirect - 

minimize dust and 

KNPP, 3-km 

effective planning of 

and 30-km 

zones 

transport activities 

KNPP Site Negative Indirect Not expected Not expected Temporary Short-term Reversible Connection to the existing 

sewage system 

EP-1 Site water 

consumption 

KNPP Site 

(EP-1) – waste 

water outflow 

connection 

KNPP Site and 

3-km zone 

Soils: DSF Site, 

3 km zone 

Rock 

environment: 

DSF Site 

Negative Direct 

Negative Direct Not expected Not expected Temporary 

Negative Direct Not expected Not expected Permanent Long-term Irreversible Measures for reducing 

water consumption, 

proper maintenance 

Negative Direct Not expected Not expected Temporary Long-term Reversible Connection to the existing 

sewage system 

Positive Direct Not expected Not expected Temporary Long term Reversible Connection to the existing 

sewage system 

Negative Soils: Direct - 

DSF Site, 

Indirect - 

3 km zone 

Rock 

environment: 

Direct - DSF 

Site 

Nature 


Expected Not expected Temporary Long-term Irreversible Store the soil dug during 

construction and 

connection of the its 

draining systém to the 

KNPP, EP-1' draining 

systém 


- not expected _ _ _ _ _ _ _ _ _ 



Italic – elements of the matrix, which have positive impacts and elements form which any impact is not expected 



Frequency 2 

Not expected Not expected Temporary Long-term 


Short-term 




Reversible Use of short routes during 

transportation of the 

containers 

Irreversible Measures for reducing 

water consumption 


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Impact 

on/from 

1.8.1 

Landscape 

1.8.2 Mineral 

diversity 

1.9.1. 

Biological 

diversity and 

natural 

components 


construction 

Positive / 

Negative 

Direct / 

Indirect 

DSF Site Negative Direct - 

DSF Site 


Not expected Not expected Permanent Short-term Irreversible Use of techniques to 

minimize dust, effective 

planning of waste 

transportation and 

activities 

Not expected _ _ _ _ _ _ _ _ _ 

Not expected _ _ _ _ _ _ _ _ _ 

1.9.2. 

Protected 

territories and 

Not expected 

cultural 

monuments 

_ _ _ _ _ _ _ _ _ 

1.10. 

Generation 

and disposal 

of 

conventional 

waste 

1.13. 

Genetically 

modified 

organisms 

Occurrence 

Probability 

Expected during KNPP Site, 

construction 3 km zone 

(construction 

waste), 

household, 

industrial and 

some kind of 

hazardous waste 


the operation 

(household, 

industrial and 

some kind of 

hazardous 

waste) 

DSF, 3 km 

zone 

Expected during DSF Site, 3-km 

decommissionin zone 

g 

1.11. Noise Expected during 

construction 

1.12. 

Vibrations 

Expected DSF Site, 

periodically KNPP Site 

during 

opearation (cask 

transportations) 


construction 

Negative Direct - DSF Expected Not expected Temporary Short-term Reversible on 

Site, Indirect - 

DSF Site 

3 km zone 

Irreversible - 

in 3 km zone 

Negative Direct 

DSF Site 

Indirect - 

3 km zone 

Negative Direct - DSF 

Site; Indirect - 

3-km zone 

Not expected Not expected Permanent Long-term Reversible on 

DSF Site; 

Irreversible in 

3 km zone 

Not expected Not expected Temporary Short-term Reversible on 

DSF Site, 

Irreversible in 3km 

zone 

Measures for separate 

collection of conventional 

waste and their treatment 

in compliance with the 

regulatory acts and the 

internal rules of Kozloduy 

NPP, plc. 

Measures for separate 

collection of conventional 

waste and their treatment 

in compliance with the 

regulatory acts and the 

internal rules of Kozloduy 

NPP, plc. 

Negative Direct Not expected Not expected Temporary Short-term Reversible Use of proper routes 

during the transportation 

activities and following the 

sanitary requiments 

DSF Site Negative Direct 

DSF Site 

Not expected Not expected Temporary Short-term Reversible Use of proper routes 

during the transportation 

activities and following the 

sanitary requiment 

Not expected 

during operation 

_ _ _ _ _ _ _ _ _ 

Not expected to 

use such 

organism 

Expected 

Coverage 1 

KNPP Site; 

30 km zone 

Nature 


Frequency 2 


Negative Direct Not expected Not expected Temporary Short-term Reversible 

_ _ _ _ _ _ _ _ _ 









- 

Measures for following the 

acting sanitary 

requirement during 


opearation 


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4.1.5 Matrix for assessment of potential impacts considering the radiation 

aspect during implementation of DSF 

Impact 

on/from 

1.1. Personnel 

1.2. Population 

Not expected 

during 

construction 

Not expected 

during DSF 

operation 


normal operation. 

The radiation 

impact on the 

personnel 

involved in 

activities in WSF 

can be expected 

to be within the 

design criteria 

given in the 

Investment 

Proposal 

Positive / 

Negative 

Direct / 

Indirect 


_ _ _ _ _ _ _ _ _ 

_ _ _ _ _ _ _ _ _ 

DSF Site Potential 

Expected in case DSF Site, WSF 

of an accident Site 

during the 

operation 

negative health 

impact 

Direct Not expected Cumulative Temporary 

during cask 

movements 

Negative Direct Not expected 

depending on 

remediation 

measures 

Not expected, 

depending on 

remediation 

measures 

Short term Reversible Strict control on the individual 

cumulative doses for the 

personnel. The requirements 

of the Investment proposal 

and the legislative documents 

for radiation protection must 

be strictly followed. 

Temporary Short-term Reversible Measures for radiation 

protection and emergency 

planning of the DSF and 

integration in KNPP’s 

Emergency Plan 

Not expected 

during 


normal operation 

- - - - - - - - - 

Expected in case 30 km zone Negative Direct Not expected 

of an accident 

depending on 

remediation 

measures 

1.3. Atmospheric Not expected 

air and the during 

atmosphere construction and 


1.4. Waters 

1.5. Soil and 

inside the 

ground 

1.6.1. 

Landscape 

1.6.2 

Mineral 

diversity 

Occurrence 

Probability 

Not expected Temporary Short-term Reversible In compliance with KNPP 

Emergency Plan for 30km 

zone protection 

- - - - - - - - - 

Expected in case KNPP Site and Negative Direct Not expected Not expected Temporary Short-term Reversible Measures for and 

of an accident the 30 km zone 

environmental radiation 

during the 

protection and emergency 

operation 

planning for DSF and 

integration to KNPP’s 

Emergency Plan 

Not expected 

during 



- - - - - - - - - 

Expected in case 

of transportation 

emergency 

KNNP Site Negative Direct Not expected Not expercted Temporary Short-term Irreversible Following all the fuel 

transportation procedures 

in force at KNPP Site and 

Regulations 

Not expected 

during 



- - - - - - - - - 

Expected in case 

of transportation 

emergency 

Expected 

Coverage 1 

Nature 

KNPP Site Negative Direct Not expected Not expected Temporary Short-term Irreversible Following all the fuel 

transportation procedures 

in force at KNPP Site and 

Regulations 

Not expected - - - - - - - - - 

Not expected 

- - - - - 


Frequency 2 Duration 3 






Reversibility 4 

- - - - 





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Impact 

on/from 

1.7.1. 

Biological 

diversity 

natural 

components 

1.7.2. 

Protected 

territories and 

cultural 

monuments 

1.8. 

Waste 

generation 

and disposal 

Occurrence 

Probability 

Small amounts KNPP Site - 

of liquid RAW WSF 

are expected to 

be generated 


Gaseous 

radioactive 

waste are 

possible to be 

generated in 

case of 

emergency 

(during fuel 

handling 

operations) 

Positive / 

Negative 

Direct / 

Indirect 


Not expected - - - - - - 

Not expected - - - - - - 

Small amounts 

of solid 

radioactive 

waste related to 

personnel 

protectin are 

expected to be 

generated 


and transfer of 

the fuel 

Solid and liquid 

radioactive 

waste are 

possible to be 

generated in 

case of 

emergency 

(during fuel 

handling 

operations) 

Expected 

Coverage 1 

DSF Site, 

KNPP Site - 

WSF 

Negative Direct - DSF Not expected Not expected Permanent 

Site and KNPP 

Site (WSF) 

Indirect - 

KNPP Site 

Negative Direct Not expected Not expected Permanent Long-term Reversible - WSF Following the existing 

Site, Irreversible - KNPP practices 

KNPP Site 

DSF Site Negative Direct 

Nature 


Frequency 2 

30 km zone Negative Direct Not expected Not expected Temporary Short-term Reversible Application of the 

procedures for leakage 

detection as well as 

Radiation Control 

Programme 






Duration 3 

- - 

- - 

Not expected Not expected Temporary Short-term 

Reversibility 4 




Long-term Irreversible on In compliance with 

KNPP Site regulations and the 

Reversible on DSF instruction and procedures 

and WSF Site in force at KNPP, the 

generated radioactive 

waste will be treated at the 

existing radioactive 

treatment plant 

- 

- 

Reversible on DSF In compliance with 

Site Irreversible regulations and the 

for KNPP Site instruction and procedures 

in force at KNPP, the 

generated radioactive 

waste will be treated at the 

existing radioactive 

treatment plant 


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4.2 USE OF NATURAL RESOURCES 

An anthropologically fragmented site is assigned for the construction of DSF. Excavations, back-filling, 

transportation and construction works will be carried out on the site. 

Natural resources, which will be used during construction, are water and inert materials, only water will be 

used during the operation. 

4.2.1 Water 

As described in the Technical Proposal, water will be used in DSF for the staff welfare facilities including 

toilets and a changing room with health physics control and showers. 

In addition to the water that will be supplied directly to DSF some water will be used also in the WSF while 

loading/unloading, the casks with fuel assemblies in the area of WSF. De-mineralised water will be used in 

WSF for filling the cask and the contamination protection skirts. Fresh water will be used also for outside 

washing of the contamination protection skirt and bottom shock absorber in the course of the cask 

withdrawal from the pond. This use does not significantly differ from the usual water use in WSF. 

4.2.1.1 Drinking and Domestic Water Supply 

Water for drinking and sanitary purposes will be brought to the DSF by means of a branch line from the 

potable water main supplying the present KNPP - CP-3, duct at the trailer maintenance shop. The total 

length of the branch made of PE DN 25 is approximately 150 m and it will supply the toilets and the 

showers in the Reception Hall. No potable water is needed for the Storage area. The total drinking water 

quantity is assessed to be 0.6 l/s based on the Method for calculation of the specific flows of the fittings 

and simultaneous use of more than one tap, which represents 0.001 % of the total water used by KNPP. 

Considering the working regime - 11 loadings per year the real consumption of water can be determined 

on the basis of best professional judgement and will be considerably less - not more than 1 m 3 /d. 

There is no need for a water supply for internal fire control, since this will be achieved using mobile foam 

extinguishers for the area around the truck, the maintenance room and the other rooms in the Reception 

Hall. 

The fire water supply for the area is not part of the DSF project and is provided by the KNPP. The new 

access to the area, together with the cover provided by the fire brigade, satisfies the requirements. 

4.2.2. Inert Materials 

The following inert materials will be used during the DSF construction: sand and gravel. They will be 

obtained from quarries for construction materials. The necessary amounts of these materials will be 

specified with the detailed design, but they are not expected to be significant. Therefore, it can be 

concluded that there will be no significant impact on the inert materials during DSF construction. 

No inert materials are expected to be used during DSF operation, except for repair works, but these 

quantities will be quite small. 


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4.3 HARMFUL SUBSTANCES EMISSIONS DURING CONSTRUCTION, NORMAL 

OPERATION OR IN CASE OF EMERGENCY, WASTE GENERATION 

(CONSIDERED BY SINGLE ENVIRONMENTAL COMPONENTS AND FACTORS) 

4.3.1 Solid waste generation 

4.3.1.1 Determination of the type and amount of the generated waste and the method of 

treatment, including waste resulting from construction or demolition 

Different types and quantities of waste generated in the DSF will be established in the process of the 

operation of the facility. 

The activities and obligations with regard to the management of non-radioactive waste are regulated by the 

Waste Management Act (WMA) [L.9] and with regard to radioactive waste - by a Regulation on the safety 

by the management of radioactive waste [L.16]. 

Since the DSF is part of the Kozloduy NPP, and similar type of waste is generated there, then all waste 

types from DSF will be collected, transported and treated in accordance with the Program for management 

of non-radioactive waste and with the Program for management of solid radioactive waste from the plant. 

To this end, it is necessary to incorporate the management of non-radioactive waste and for radioactive 

waste from DSF into the respective programs of the Kozloduy NPP. 

In accordance with Article 25 WMA [L.9], non-radioactive waste from DSF should be included in the 

relevant record books for such waste. Furthermore, pursuant to Article 7, Paragraph 1 WMA [L.9], the 

persons applying for a building permit are required to submit, in parallel with the documentation pursuant to 

Article 144, of the Spatial Development Act (SDA) [L.5], information on the quantity and kind of the process 

and hazardous waste that will be generated upon implementation of the investment project. Upon 

commission of operation of DSF and in accordance with the requirement of Regulation № 3 on waste 

classification [L.63] (Article 7), it is necessary to fill in work sheets for classification of the generated waste, 

in which an unambiguous classification of such waste is made. 

During construction 

Domestic waste, building debris and hazardous waste are expected to be generated as follows: 

Domestic waste 

• Domestic waste - code 20 03 01 (mixed household waste) from the builders, with a quantity of 

approximately 0.5 m 3 per worker per annum, or a total of 20 m 3 , which will be disposed off at the landfill 

for non-radioactive domestic refuse and production waste. 

Building debris 

• Building debris - code 17 01 07 (mixes from concrete, bricks, tiles, faience and ceramic goods) - 

small-size waste materials from construction, of an anticipated quantity of approximately 1000 m 3 , 

to be transported by the building companies for disposal at a specified site. 

• Surplus earth masses - code 17 05 06 (excavated earth masses). The anticipated quantity is around 

2 000 m 3 . These will be dumped at a terrain allocated for the purpose, and upon a radioactivity check 

and verification that they are not contaminated; such earth masses may be used for cover layers of the 

landfill for non-radioactive domestic refuse and production waste. 

Industrial waste 

• Packing code 15 01 01 (paper and cardboard packing), code 15 01 02 (plastic packing) and code 

15 01 06 (mixed packing) - from materials and equipment. The expected is amount approx. 20 m 3 . 

Hazardous waste 

• Waste oils - code 13 02 05 (non-chlorinated motor oils, lubrication oils and gear drive oils on mineral 

basis) from the machines of the building mechanisation, of anticipated quantity of 20 l. These will be 

submitted for recycle to outside companies. 


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Domestic waste, building debris, production waste, hazardous and radioactive waste are expected to be 

generated during operation. 

Domestic waste - code 20 03 01 - mixed household waste from the attending personnel with a quantity of 

approximately 0.5 m 3 per worker per annum, or a total of 6 m 3 annually, which will be disposed off at the 

landfill for non-radioactive domestic refuse and production waste. 

Building debris - code 17 01 07 (mixes from concrete, bricks, tiles, faience and ceramic goods) - in the 

case of repair during operation with at an anticipated quantity of approximately 10 m 3 per annum. 

Hazardous waste - used mercury and luminescent lamps - code 20 01 21 (fluorescent tubes and other 

mercury containing waste) - ca. 20 nos. per annum. Temporary storage in specially designed containers. 

Treatment will be pursuant to the Regulation on the requirements for sale of mercury containing 

luminescent lamps, and for treatment and transportation of out-of-use luminescent and other mercury 

containing lamps [L.64]. 

Radioactive waste - protective clothing shoes and gloves. These will be in small quantities of 

approximately 40 sets annually and will be treated in the exiting installations: laundries and facilities for 

solid waste treatment. 


Construction and radioactive wastes are expected to be generated during decommissioning. The amount 

of these wastes cannot be estimated at present. They will be treated as follows: 

• for construction waste - after a radioactivity check and confirmation that it is not contaminated, the 

waste will be disposed of at the non-radioactive domestic and industrial waste site or construction 

waste site 

• for radioactive waste - RAW facility 

Following accidents 

This includes interruption or failure of the processes, traffic accidents, spillage, fire and explosions, natural 

disasters such as earthquakes, floods and others. Any of these could lead to a generation of nonradioactive 

and radioactive waste. The exact types and quantities of generated waste are presently not 

known. Suitable regulators and indicators for monitoring of the trends in the safety area have been 

implemented and subjected to permanent updating at the KNPP. Attention is given to the non-admission 

by the personnel of failures during operation and repair of the equipment, for observation of the instructions 

and process parameters, environmental protection requirements, fire safety and emergency safety with the 

Zone of Strict Control (ZSC), etc. Thus, all measures for non-admission of breakdowns are being taken. It 

is necessary to develop an emergency plan for the DSF and to include it in the emergency plan of the 

KNPP. Such a plan should list precisely all anticipated waste resulting from eventual breakdown, and the 

method of treatment of such waste in accordance with the procedures in force at the KNPP. 

4.3.1.2 Description of the methods for collection, storage, treatment, 

transportation and final disposal of the solid waste 

The choice of waste collection containers from DSF and the equipment for the transportation will be based 

on the present experience, and with the aim to facilitate collection, transportation and disposal of the 

waste. It is necessary that waste transportation and treatment is carried out in accordance with the 

requirements of the Regulation on the requirement of treatment and transportation of industrial and 

hazardous wastes [L.67]. 

Collection, storage, treatment, transportation and final disposal of all types of waste resulting from 

construction, operation and decommissioning of DSF will be carried out under the existing practices set in 

KNPP. These types of waste are not new for KNPP - they represent a small part of the waste generated 

and treated at KNPP at present. 


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During construction and operation 

Domestic waste: this will be collected in the containers of 4 m 3 volume, which will be transported to the 

landfill site for non-radioactive domestic refuse and production waste. 

Building debris: Pursuant to the EIA Report of the Kozloduy NPP, such waste will be transported by the 

construction companies after an inspection for radioactivity and will be transported to the landfill for nonradioactive 

domestic refuse and production waste. 

Surplus soil may be temporarily piled up in the open in a specified location, and, upon a radioactivity 

check, be transported by motor trucks to the Landfill for non-radioactive domestic refuse and production 

waste, where such waste will be used for intermediate layer and landfill re-cultivation. 

Industrial waste: packages will be collected in designated containers, transported by road and disposed off 

at the Landfill for non-radioactive domestic refuse and production waste. 

Hazardous waste: 

• Used mercury and luminescent lamps can be collected in specially designed container for temporary 

storage (to be treated in accordance with the Regulation on the requirements for sale of mercury 

containing luminescent lamps, and for treatment and transportation of out-of-use luminescent and 

other mercury containing lamps [L.64]. 

• Waste oils from the machines to be collected in barrels by building contractors and subsequently 

submitted to outside companies for recycling. 

Radioactive waste - protective clothing, shoes, gloves. The work clothing will be decontaminated in a 

specialised laundry, if the contamination exceeds the admissible values stated in BNRP 2004. It will be 

treated as radioactive waste. The radioactive waste is collected in plastic bags and transported via a 

specified route in transport containers on a transportation vehicle accompanied by a vehicle equipped with 

apparatus for radiation control, personal protective devices, devices for fire fighting, deactivation and other 

means necessary for action in emergency. For each activity, concerning radioactive waste there are 

approved instructions, the observation of which is of importance for the radiation safety and personnel 

protection. Treatment of the radioactive waste is carried out at the production facility for radioactive waste 

treatment. 

Construction and radioactive wastes are expected to be generated during decommissioning. These wastes 

will be treated as follows: 

• construction waste - after inspection for radioactivity and confirmation that they are not contaminated, 

transportation by road and disposal at non-radioactive and industrial waste site or construction waste 

site; 

• radioactive waste - transportation by specialised vehicles and treatment according to the established 

practice in KNPP in the production facility for radioactive waste treatment. 

4.3.1.3 Consideration of the location for final waste disposal of all types of solid waste 

The location for final waste disposal is as follows: 

Non-radioactive waste 

Final disposal of domestic waste and industrial waste is carried out at the landfill site owned by the plant. 

The landfill for non-radioactive domestic waste and industrial waste is located 3.7 km south of the Danube 

river, opposite to km 693 of the flooded river terrace. A protective dike with an average crest elevation of 

28 m has been constructed. The nearest settlements are the town of Kozloduy (3.75 km to Northwest), the 

village of Hurlets (3.7 km to the Southwest) and the village of Glozhene (4.75 km to the Southwest). The 

requirements for a sanitary protection zone of 1000 m to the closest settlement have been observed 

(according to Regulation 7 on sanitary protection zones, issued by Ministry of Health). The landfill covers 

an area of 11 385 m 2 and was constructed on a land allocated for the needs of NPP. 

East of the landfill are the supply channels for process water to the plant. To the west are the HV power 

lines, and to the south is the lime storage facility, the radioactive waste storage facility and the open 110 

kV switch gear. The requirements for sanitary protection zones pursuant to Regulation 7 of the Ministry of 

health have been observed in respect of the listed sites. 


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The landfill was designed in 1996 and the positive resolution on its EIA Report is positive. In 1999 the 

design was updated in accordance with the requirements of Regulation 13/6.11.1998 on the conditions and 

requirements for construction and operation of sanitary landfills (replaced with Regulation 8/24.08.2004 on 

the conditions and requirements for construction and operation of sanitary landfills and other facilities and 

installations for waste utilisation and disposal [L.65]), which has been harmonised with the European 

legislation in this field. The landfill started its operation in December 2001 and since April 2002, following 

optimisation of the waste management process; it is used for all types of waste generated within the KNPP 

protected zone. 

Building debris are dumped at the landfill for non-radioactive domestic and industrial waste. 

Radioactive waste 

Treatment of radioactive waste is carried out by the production facility for radioactive waste treatment 

according to the established practice in KNPP. 

4.3.2 Liquid waste generation 

4.3.2.1 Non-radioactive liquid waste 

The total quantity of the wastewater generated by the DSF during operation is estimated to be 0.55 l/s 

(90% of the water supplied to the facility). Considering the working regime, the quantity is expected to be 

about 0.9 m 3 /day. It will join the wastewater stream generated by the Units 1-4. As mentioned in Section 

1.2.5, discharging point of the wastewater generated from EP-1 area is Point 8. The average quantity 

discharged in this point is 18 980� m 3 /day. 

Three wastewater streams are as follows: 

• Sewage water from washrooms and toilets of the Reception Hall 

• Sewage water from showers and workshop of the Reception Hall 

• Rainfall water 

As described in the Technical Proposal the wastewater from the washrooms and toilets goes to the outside 

sewer (PVC-pipe, D=150 mm; length 100 m). The sewage water from the building is connected into the 

existing KNPP system. 

Rainwater from the roof and adjacent areas will discharge into a DN 300 collector situated along the road 

leading to a connecting point, about 200 m from the main building. The sewers along the sides of the 

building will be provided with inspection shafts. The individual drains of the rainwater ducts will join the 

branches in inspection shafts in the new sewers. The estimated quantity of the rainfall water is about 

120 l/s, based on the Method of the utmost rain intensity for calculation of rainfall water flows. 

No non-radiation wastewater streams will be generated at WSF in connection with the cask handling. 

4.3.2.2 Radioactive liquid waste 

The outlet from the shower room and washbasins from the workshop goes through the SANIMAX-S 

pumping equipment. Inspection shafts will be positioned at appropriate positions. The wastewater from the 

tanks is checked and then either allowed to flow to the sewerage system or sent for treatment if necessary. 

Wastewater from the outside cleaning (performed in the WSF) of the contamination protection skirt goes to 

the WSF loading pond and consequently is processed following the usual techniques established in KNPP 

for decontamination of spent fuel pools and sludge. 

4.3.3 Waste gases generation 

The proposed technology for dry storage of SNF has all the necessary systems and equipment, that allow 

the acceptance, storage and delivery of SNF for processing, taking into account the requirements for 

safety and protection of the people and the environment from radioactive, as well as of other gas 

emissions. Having in mind that the design and construction of the new DSF SF is in accordance with the 


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international safety standards, it is presume that there will be no significant changes in the gaseous 

releases from the plant site. 

Non-radioactive waste gases 

During transportation of CONSTOR® casks from WSF to the DSF there will be some exhaust gas 

emissions from heavy transport trucks. These are well under limits as the casks will be loaded and 

transferred to the DSF very infrequently. 

The other hazardous non-radioactive substances are generated randomly and in short terms in controlled 

and uncontrolled ways. They have a low and localised impact on the near surface air. 

Radioactive waste gases 

The process of acceptance, dry storage and delivery of SNF to the DSF does not lead to any possibility of gas 

emissions to the ambient atmosphere during the normal operation, equipment failure or during emergency 

situations. 

4.3.3.1 Description of the type and quantity of the gaseous emissions resulting from the 

investment proposal 

The dry storage of SNF in DSF does not lead to any release of gaseous emissions to the atmosphere. The 

estimates of emission for the off-road construction vehicles and machineries are based on the 

EMEP/CORINAIR Atmospheric Emission Inventory Guidebook, Third Edition, B810 (Other mobile sources 

and machinery). 

For 1 hour work of 1 excavator which have a power output of about 250 kW, 1 off-road truck (300 kW) to 

transport sand, rocks, etc. and 1 crane (150 kW) the emissions are: 

Tab. 4.3.3.1 Expected emissions during 1 hour of construction works 

Emission [kg] 

NOx N2O CH4 CO NMVOC PM NH3 

Excavator (250 кW) 3.60 0.09 0.01 0.75 0.33 0.28 0.0005 

Off-road truck (300 кW) 4.32 0.11 0.02 0.90 0.39 0.33 0.0006 

Crane (150 кW) 2.16 0.05 0.01 0.43 0.19 0.16 0.0003 

4.3.3.2 Description of the content and the toxicity of the air emissions 

The dry storage of SNF in DSF does not lead to any release of gaseous emissions to the atmosphere. 

Regarding WSF, the gaseous emissions are described in Section 3.6.2 and they are unlikely to change 

after start-up of DSF operation. 

4.3.3.3 Foreseen methods for collection, treatment and release of the air emissions 

Serviced areas will have a forced ventilation system. There is no filtration for the naturally ventilated areas. 

4.3.4 Harmful physical emissions 

4.3.4.1 Non-radioactive harmful emissions 

During construction 

Noise, vibrations and dust - In accordance to the investment proposal the DSF is situated between the 

existing WSF and the AB-2. There are no noise sources above the background 

noise level, typical for the whole NPP site. 

During the construction phase sources of noise, vibrations and dust are connected 

only with the conventional construction activities and the type of the used 

construction equipment and machinery. Тhey will be chosen by the constructor and 

will be in accordance with his construction organisation plan. 


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Commonly used machinery and construction equipment and the noise level 

generated by them are given in the following table: 

Tab. 4.3.4.1 Typical noise levels of construction equipment 

Type of the construction equipment Typical noise level [dB/A] 

Bulldozer 97-105 

Digger 80-91 

Auto crane 92-98 

Concrete mixer 85 

Compressor 86-99 

Тruck 85-90 

The data in the table are from the relevant information sources. 

A precise estimation of the noise could be done when the constructor provides his 

plan for organisation of the construction works and the foreseen construction 

equipment and machinery. 

Vibrations, generated during the construction are connected with certain specific 

activities and are limited to the construction site. 

The dust concentration during the construction will be kept within legally required 

limits using sprinkling and is fully under the control and the responsibilities of the 

constructor. 

Heating, lighting and EMR - During the construction of the DSF use of machinery and equipment, which 

could be significant sources of heating, lighting and EMR are not foreseen. If the 

future constructor will use such equipment for some specific construction activities, 

he shall proceed in accordance with the operation manuals of the corresponding 

equipment. 

Normal operation 

Noise and vibrations - Storing of the spent fuel is a silent activity. Significant levels of noise are not 

generated. The actual storage of the casks does not cause noise. The small and 

insignificant increases of the noise levels are expected during the cask transport or 

during the service activities. Those noise levels will not affect the noise situation 

outside the NPP area. Transport of the casks outside the NPP area (the new ones 

from the manufacturers and eventually the full ones to the repository) will not affect 

the noise situation any significant way. The negative impact of vibrations can be 

reliably excluded. 

Heating - The DSF is a significant source of heating due to the residual heat generation from the 

radioactive decay in the stored SF. This factor is given special attention during the 

design and the licensing due to its importance for the nuclear safety. In this chapter 

only, some results in regards to the thermal impact on the air and on the 

environment will be discussed. 

The thermal radiation is conducted reliably from the interior of the cask to its surface 

and then to its surroundings. Maximum thermal power of the DSF (Stage I+II), 

released to atmosphere, will not exceed 4.8 MW. In comparison with the total 

thermal power of the KNPP, released to atmosphere (for operating units ca 2800 

MW), this is negligible value. The local climatic characteristics will not be affected. 

Lighting and EMR - The designed lighting in the storage room is in accordance to the German technical 

standards DIN 5035. Use of abnormal lighting sources and generators of abnormal 

radiation is not foreseen. The equipment, potential source of radiation, such as 

measuring devices, monitors etc. are designed in accordance to the technical 

standards. No impact of EMR is expected. 

During extraordinary situations - There are no defined extraordinary situations in the investment proposal. 


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4.3.4.2 Radioactive harmful emissions 

The distance to the nearest habitation, Kozloduy town, is 3.5 km from the store. It is estimated that the 

dose rate at 3.5 km resulting from operations at the DSF is approximately 1.10 -19 µSv/h. The average 

natural background dose rate is about 0.1 µSv/h then it can be seen that the additional contribution that 

normal operations at the DSF makes to the public radiation exposure at Kozloduy town may be considered to 

be negligible. 


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5 

PART V - INFORMATION ON THE METHODS USED FOR FORECASTING 

AND ASSESSING THE IMPACTS ON THE ENVIRONMENT 

The main document used for this analysis was the EIA report for KNPP prepared in 1999 [O.9]. It has been 

approved by the Supreme Experts Committee of MEW and thus the report offers reliable information on 

the current condition and the future impacts on the environment from KNPP operations. 

The following information sources were selected on the base of the best expert’s judgements and used 

during the impact assessment of the environmental components: 

Health risk 

The health risk assessment for the population within the sanitary-hygienic and the monitored zones around 

the Kozloduy NPP during DSF construction and operation is based on the gathered information for hazards 

identification, on the determination of the dose-effect and dose-answer dependency for the chemical, 

physical and physiological factors of the environment, and on the assessment of exposition and risk of 

accidents and breakdowns. The recommendations of international organisations and the health risk 

assessment methodology have been utilised (WHO, 1994 [O.3], WHO/UNEP/ILO, 2001 [O.4]). Other data 

that have been considered are: the European indicators for assessment of the impact of environment on 

human health; the Principles and methods for assessments of indirect and cumulative non-radiation 

impacts of the environment (including inhabited environment and working environment) on health, as well 

as their interaction, as represented in the Walker & Johnston, 1999 monograph. 

Air 

• Methodology for calculating of hazardous air emissions (pollutants), using balance methods (Order 

№RD 299/16.06.2000 of MEW), developed on bases of Joint EMEP/CORINAIR Atmospheric Emission 

Inventory Guidebook, Copenhagen, EEA, 1994; 

• Joint EMEP/CORINAIR Atmospheric Emission Inventory Guidebook, B810 (Other mobile sources and 

machinery), 3rd edition September 2003 UPDATE (http://reports.eea.eu.int/EMEPCORINAIR4/en) 

The above two methods were used in compliance with the harmonization of the Bulgarian legislation with 

the EU legislation. 

Waters 

• Method for calculation of water flows on the base of the specific flows of the fittings 

• Method of the utmost rain intensity for calculation of rainfall water flows 

Lands and soils 

For the forecast and evaluation of the impact of DSF on the lands and soils, the comparative 

environmental method is used. The method consists of determination of the different parts of the ecosystems 

(in this case the types and kinds of soils) and possibilities for damage of the production from such 

lands and soils, which reflects on human and animal health. Also comparative analysis of the management 

of the internal relationships; relations among the eco-systems, or respectively the soils and the surrounding 

environment at system’s entry and exit; functioning of the soil system and its changes a result from 

external impacts. The generalised conclusions have been made based on analyses and discussions of 

literature data, data from own investigations accomplished by the Department of Environment Monitoring, 

Direction of Safety and Quality, at the Kozloduy NPP, and data from the examinations by competent 

departments of the MEW. The data has been analysed according to the requirements of the Bulgarian 

legislation on radiation protection and protection of the environment. 


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Landscape 

• 1. Methods of Physical Geographical and Landscape Division, Georgiev, M., Landshaftoznanie, 

“Zemizdat”, Sofia, 1982 p. 92-113; 

• 2. Methods of Physical Geographical and Landscape Division, Georgiev, M., Physical Geography of 

Bulgaria, University Publishing House “Sveti Kliment Ohridski”, Sofia, 1991 

• 3. Fundamentals of the Landscape Differentiation, Petrov, P., Geography of Bulgaria, Bulgarian 

Academy of Sciences, Sofia, 1997 , p. 340-345; 

• 4. Fundamentals and Methods of Landscape Division, Petrov P, Geography of Bulgaria, Bulgarian 

Academy of Sciences, Sofia, 1997, p 345-356; 

Cultural heritage 

The study of the archaeological sites has been made in accordance with the requirements and methods of 

the Regulation of location archaeological studies in Republic of Bulgaria (State Gazette 12/1997). The 

other cultural monuments have been studied in accordance with Instruction № 5 of the Ministry of Culture 

[L.75]. 


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6 

PART VI - DESCRIPTION OF THE MEASURES ENVISAGED TO AVOID, 

REDUCE OR WHERE POSSIBLE, STOP THE SIGNIFICANT ADVERSE EFFECTS 

ON THE ENVIRONMENT AND PLAN FOR IMPLEMENTATION 

OF THESE MEASURES 

6.1 LIST OF MEASURES TO BE IMPLEMENTED 

The investment proposal envisages complex measures for reduction, mitigation or elimination of the risk to 

the environment and personnel and population health, during construction and operation of DSF. The 

proposed measures are in accordance with legislation on health, labour and environment. The measures 

proposed by the investor for prevention, reduction or compensation of the impact caused by DSF meet the 

requirements for radiation protection at this level of impact. 

There is a requirement KNPP to follow all relevant industrial safety rules and Regulations. Specific 

measures identified by the EIA-R authors to be implemented are listed below: 

Air 

• Utilisation of the off-road machines during the construction phase: only machines which are in 

compliance with the requirements of the Regulation for the substantial requirements and the 

assessment of the conformity of the machines and the equipment, which will operate in open air 

regarding the noise from them [L.82], should be used. The Regulation is harmonized with Directive 

2002/88/EC, amending Directive 97/68. 

Water 

• The wastewater treatment tank must be sized to contain the total amount of the accumulated water to 

prevent any spillage. The monitoring of the water must be done in accordance with the wastewater 

generation schedule. 

Soils 

• Construction materials, surplus soil and workers to be transported on designated roads, in order to 

avoid dust spreading and damaging the surrounding areas. 

• During construction, the roads to be sprinkled and cleaned in order to avoid pollution of surrounding 

areas with dust. 

• Disturbed soils and lands during construction, to be re-cultivated and grassed in accordance with an 

approved project. 

• Good greenery of the adjacent area around DSF and connecting road shall be maintained. 

Protected Territories, Flora and Fauna 

• Since the impact on the protected territories, flora and fauna is expected to be insignificant, no 

additional measures are recommended except good territory development and greenery. 

Landscape 

• For insertion of the Works in the surrounding landscape is necessary to develop an urbanisation and 

greenery design of the site giving special attention to the aesthetic shaping of the terrain surrounding 

the building. 


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Cultural Heritage 

• In the event that during construction an archaeological site not registered so far is discovered, it should 

be treated in accordance with the regulations. In such cases the work should temporarily be stopped 

and within a month the measures, which have to be undertaken, should be announced and 

implemented. 

Waste 

• The management of all types of waste, generated from construction, operation and decommissioning 

of DSF, to be carried out in accordance with the existing practice in KNPP and the relevant legislative 

documents; 

• Development of Environmental Plan in accordance with the EBRD environmental policy, which will 

include measures to mitigate or to avoid the impact of construction waste on the environment. 

Population 

• Based on the design and operation requirement, the effect on the population in Kozloduy municipality 

will be insignificant. There is no risk of additional pollution of the atmospheric air, drinking water, soils, 

forage agricultural crops grown in the region and the food chain. Therefore no additional measures are 

proposed. 

Site personnel 

• Although the personnel will be chosen among the people working at Kozloduy NPP, the specific 

technological process requires special preliminary training and creation of good safety practices and 

habits. 

• It is recommended to follow strictly the enumerated in Chapter 4.1.2 Legislative requirements for 

healthy and safe labour conditions. 

• It is recommended in the annual preventative medical examinations (according to Art.35, para.3 of the 

Regulation BNRP-2004 the preventative medical examinations are obligatory at least once per year) to 

invite the following specialists: internist, laryngologist, cardiologist, neurologist and ophthalmologist (for 

welding). 

• When working next to sources generating high levels of noise the personnel should wear ear 

protection. 

• To provide and require obligatory use of special working clothes and helmets with ear protectors to 

protect from traumas. 

Radiation 

All programmes and procedures relating to radiation protection in WSF need to be updated to reduce 

radioactive impact and prevent radioactive irradiation of the personnel. These activities are required by the 

new conditions following the start-up of DSF operation. 

The above recommended measures are summarised in the following Table 6.1-1. 

Tab.6.1-1 Envisaged measures and implementation plan 

Measures Period of 

implementation 

Results 

1. Air 

Utilisation of the off-road machines during the construction phase: During the Maintaining noise levels below 

only machines which are in compliance with the requirements of the construction phase the limits set with the 

Regulation for the substantial requirements and the assessment of 

the conformity of the machines and the equipment, which will 

operate in open air regarding the noise from them, should be used. 

The Regulation is harmonized with Directive 2002/88/EC, amending 

Directive 97/68. 

legislation 


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2. Water 

The wastewater treatment tank must be sized to contain the total During the design 

amount of the accumulated water to prevent any spillage. 

phase 

The monitoring of the water must be done in accordance with the 

wastewater generation schedule. 

3. Soils 

• Construction materials, surplus soil and workers to be 

transported on designated roads, in order to avoid dust 

spreading and damaging the surrounding areas. 

• During construction, the roads to be sprinkled and cleaned in 

order to avoid pollution of surrounding areas with dust. 

• Disturbed soils and lands during construction, to be re-cultivated 

and grassed in accordance with an approved project. 

• Good greenery of the adjacent area around DSF and 

connecting road shall be maintained. 

4. Protected Territories, Flora and Fauna 

Since the impact on the protected territories, flora and fauna is 

expected to be insignificant, no additional measures are 

recommended except development of territory and greenery. 

5. Landscape 

For insertion of the Works in the surrounding landscape is necessary 

to develop an urbanisation and greenery design of the site giving 

special attention to the aesthetic shaping of the terrain surrounding 

the building. 

6. Cultural Heritage 

In the event that during the construction an archaeological site not 

registered so far is discovered, it should be treated in accordance 

with the regulations. In such cases the work should temporarily be 

stopped and within a month the measures, which have to be 

undertaken, should be announced and implemented. 

7. Waste 

• The management of all types of waste, generated from 

construction, operation and decommissioning of DSF, to be 

carried out in accordance with the existing practice in KNPP and 

the relevant legislative documents; 

• Development of Environmental Plan in accordance with the 

EBRD environmental policy, which will include measures to 

mitigate or to avoid the impact of construction waste on the 

environment. 

8. Population 

Based on the design and operation requirement, the effect on the 

population in Kozloduy municipality will be insignificant. There is no 

risk of additional pollution of the atmospheric air, drinking water, 

soils, forage agricultural crops grown in the region and the food 

chain. Therefore no additional measures are proposed. 

9. Site personnel 

Although the personnel will be selected fro the people working at 

Kozloduy NPP, the specific technological process requires special 

preliminary training and creation of good safety practices and habits. 

It is recommended to strictly follow items in the Chapter 4.1.2 

Legislative requirements for healthy and safe labour conditions. 

It is recommended in the annual preventative medical examinations 

(according to Art.35, para.3 of the Regulation BNRP-2004 the 

preventative medical examinations are obligatory at least once per 

year) to invite the following specialists: internist, laryngologist, 

cardiologist, neurologist and ophthalmologist (for welding). 

When working next to sources generating high levels of noise the 

personnel should wear ear protection. 

To provide and require obligatory use of special working clothes and 

helmets with ear protectors to protect from traumas. 

During the 

operation phase 

Results 

Prevention of tank overflow 

Prevention of radioactive 

wastewater discharge 

During the Reduction of dust spreading 

construction phase 

During the Reduction of dust spreading 

construction phase 

During the Rehabilitation of the disturbed 

construction phase land and improvement of the 

environment 

During the Rehabilitation of the disturbed 

operation phase land and improvement of the 

environment 

During the Development of site and 

construction phase greenery 

After construction 

phase 

Harmonization of the site with 

the surrounding landscape 

During the Protection of any archeological 

construction phase sites found during the 

construction 

During the 

construction 

phase, 

operation and 

decommissioning 

Legally sound management of 

all types of waste and in 

accordance with the existing 

practice in KNPP and the 

relevant legislative documents. 

During the Mitigation or Reduced impact 

construction phase of construction waste on the 

environment. 

Not applicable Not applicable 

During the 


During the 


During the 


During the 



Establishment of good safety 

practices and personnel 

habits; 

Maintenance of healthy and 

safe labour conditions; 

Establishment of good 

prophylaxis practice and 

prompt diagnostics 

Protection of the personnel 

from excessive noise levels; 

Protection the personnel from 

traumas 


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10. Radiation 

All programmes and procedures relating to radiation protection in Before the 

WSF need to be updated to reduce radioactive impact and prevent beginning of 

radioactive irradiation of the personnel. These activities are required 

by the new conditions following the start-up of DSF operation. 


6.2 RECOMMENDATIONS ON ENVIRONMENT MANAGEMENT 

Results 

Reduction of the radiation 

impact on the environment and 

the personnel 

Environment management is necessary to be implemented in accordance with an Environmental 

Management Programme. Since the DSF is located in the area of and is part of the Kozloduy NPP. The 

KNPP Environment Management Program should be updated with this new facility. 

The expected impacts to the atmospheric air, water, geological structure, soils, flora, fauna, protected 

territories, landscape and cultural heritage, during the DSF construction and operation are not significant, 

and no specific mitigation measures except those pointed out in the regulations, are necessary. The 

environmental management capacity currently existing at KNPP is sufficient to deal with all potential 

adverse impacts. 

6.3 RECOMMENDATIONS ON THE SITE MONITORING PLAN 

Since DSF is part of Kozloduy NPP, the self-monitoring plan should be updated with this new facility. Some 

specific recommendations have to be added to the established procedures at KNPP as follows: 

Water 

No specific recommendations need to be added to the established procedures at KNPP for surface water 

monitoring related to the realisation of DSF project. 

Periodical testing of the wastewater in the holding tanks must be conducted in accordance with the 

established procedures for such type of wastewater. 

Health risk 

The following recommendations are made to the site monitoring plan of the Labour Medical Service: 

• Measurement of the equivalent levels of noise because a considerable part of the processes generate 

production noise; 

• Measurement of carbon monoxide, carbon dioxide, nitric oxides, hydro-cyanogen and ferrous oxides at 

working places, where welding is done; 

• Measurement of microclimatic parameters, because activities in conditions of high temperature and 

high relative humidity are expected; 

• Measurements of intensity of the artificial light, this should be done after the commissioning of the DSF 

facility. 

6.4 RECOMMENDATIONS ON THE EMERGENCY PLAN 

KNPP has developed an Emergency Plan, which is in compliance with the requirements of the harmonised 

legislative documents. All the necessary safety requirements in cases of natural hazards (floods, freezing, 

snowfalls, earthquakes, strong storms and winds) are taken into consideration. 

The new DSF will be incorporated into the existing KNPP Emergency Plan, which is in compliance with all 

legislative documents. 


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7 

PART VII - STATEMENTS AND OPINIONS EXPRESSED BY THE CONCERNED 

PUBLIC, AS WELL AS THE AUTHORITIES INVOLVED IN DECISION MAKING 

FOR EIA AND OTHER SPECIALIZED AUTHORITIES, 

AS A RESULT OF THE CONSULTATIONS MADE 

In 2003, the Technical Specification for the design and implementation of the Dry Storage Facility for spent 

nuclear fuel from Kozloduy NPP was developed. 

Information about the DSF project was published on Kozloduy NPP website, the EBRD website and in the 

newspaper ’Dunav’. 

In September 2003 a Notification of the DSF investment proposal was sent to the MEW for the purposes 

of obtaining an EIA screening decision. Subsequently, the Mayor of Kozloduy was notified in addition. The 

local population was informed via the local radio station ’Elto’ and notices were placed in the House of 

Power Engineer in the town of Kozloduy. 

In 2004, the Terms of Reference for the EIA were developed in co-ordination with the MEW, RIEW Vratsa 

and the Kozloduy Municipality. After receiving the MEW decision on the requirement for an EIA, the Terms 

of Reference was reviewed in a meeting with representatives of Kozloduy municipality and the RIEW 

Vratsa. Letters with statements on the Terms of Reference were received by Kozloduy NPP from the 

Kozloduy municipality, the RIEW and MEW. 

A public meeting was held on 3 November 2004 in the House of Power Engineer in the town of Kozloduy, 

regarding the EIA Report in preparation for the DSF planned for the KNPP site. The meeting was held 

according to the requirements of the Bulgarian Environmental Protection Act [L.4] (Article 95, Paragraph 2) 

and the Regulation on the Conditions and the Order for Implementing Environmental Impact Assessment 

of Investment Proposals for Construction, Activities and Technologies [L.84]. 

The purpose of the meeting was to present the scope, contents and format of the EIA Report in 

preparation for the DSF planned for the KNPP site. 

The meeting was attended by representatives from KNPP; KPMU; RWE NUKEM/GNS; NNC/POVVIK- 

OOS Ltd.; EBRD; BNRA; Municipality of Kozloduy; RIEW, Vratsa; National Centre for Health Care; State 

Agency for Civil Defence; Syndicate of Atomic Power Engineers, NPFE-NPS; EQE Bulgaria, ENPRO 

Consult. 

The meeting was carried out under the following agenda: 

• Opening by a representative of the Investor (KNPP) 

• Presentation of steps already performed under the project. 

• Brief description of the project. 

• Contents and accents of the EIA report. 

• Questions, opinions and positions. 

Following the presentations, members of the audience were invited to present opinions or statements or 

ask questions of the project representatives present. 

Record of opinions, statements or questions with corresponding reply is presented in Appendix 3. The 

highlights of the meeting are summarised below: 

1. Ms. Evelina Alexandrova. Environmental Chief Expert. Kozloduy Municipality 

Ms. Alexandrova made a statement about the involvement of the Municipality of Kozloduy in the DSF 

investment proposal so far. She expressed satisfaction that an EIA for the DSF is being produced. In 

addition, she read an extract from a letter to be sent that day concerning the improvement of life and 

infrastructure in Kozloduy to the Executive Director of KNPP as follows: 


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"For the population it is of vital interest to have a positive change and stability of the municipality as well as the 

building of social infrastructure. The state power giant does not resolve the problem about the municipality's 

economic development. There is not clarity for the future progress of the municipality. In the new strategy about 

municipality's growth there is a decision made that it's development to be reoriented towards other directions 

including ecological tourism. This understanding is reflected in the programme for the environmental preservation. 

Even if the EIA report proves that there is not any impact, we consider that there is possibility that the site 

expansion and DSF existence will deter this development and to create a bad image for the municipality." 

Ms. Alexandrova stated that she did not require an immediate response to this position. Ms. Tranteeva 

responded by stating that this is a new programme, which has not been identified as a concern in any 

previous meeting. She added that KNPP has satisfied all previous requests from the Municipality and 

answered all questions. 

This was a new issue which would be reviewed and should be the subject of a separate meeting between 

KNPP and Municipality. 

2. Mr. Georgi Tzenov. Director Regional Inspectorate of Environment and Waters. Vratsa 

Mr. Tzenov asked for clarification about the responsibility for the safety assessment of the DSF. Ms. 

Traycheva responded by stating that the safety assessment report is produced by the design/construction 

contractor and that this is a separate document from the EIA. 

3. Professor Ada Bainova. Toxicologist and EIA Expert 

Professor Bainova asked three questions: 

1. How many people will be engaged in the construction of the DSF? 

Mr. Botzem responded by stating that outside companies will be used during the project. The actual 

numbers used will depend upon how much of the facility is prepared as pre-cast units offsite. A figure of 

approximately 40 workers on site at anyone time during construction is likely. 

2. What is the policy for the administrative management of these workers? Will they be KNPP workers or 

hired from another company? If it is the latter, they will need special training for this work? 

Ms. Tranteeva stated that KNPP policy is to re-deploy personnel following the shutdown of Units 1 and 2 

rather than make them redundant. As a consequence, there is an availability of trained, experienced 

workers onsite suitable for employment in new decommissioning activities including the new facility. 

Concerning workers from other companies, experience initially on modernisation work on Units 3 and 4 

and, subsequently, Units 5 and 6 shows that external companies can work safely on the KNPP site and 

that their workers are fully trained in nuclear safety, radiation protection and KNPP orientation. 

3. How many people will be involved in the transfer of spent fuel from the Wet Storage Facility to the DSF 

including management/supervisors? 

Ms. Tranteeva replied that it is not expected that there will be many workers involved in the operation of 

the DSF. Those working there will be fully trained for this job with input from the design/construction 

contractor 

4. Ms. Marieta Vitkova. Chief Inspector. Nuclear Material and Physical Protection Department. 

BNRA 

Ms. Vitkova stated that dry storage of spent nuclear fuel is the safest technology known in the world for this 

material. Fuel handling and transportation is kept to a minimum and the CONSTOR technology to be used 

will ensure that there is no possible dispersal of any contamination from the fuel into the environment. The 

national goals on management of spent fuel are completely satisfied by the proposed DSF at KNPP. The 

application by KNPP for a design permit had been received and is currently under evaluation. A decision 

on the issuance of the permit is expected to be made soon. 

Ms. Vitkova asked what was the accuracy of the burn-up data of the fuel to be used in the cask design 

calculations, bearing in mind a maximum cladding temperature of 330 °C. Dr. Thomas, GNS Cask Design 

Expert, explained that the highest known values for burn-up will be used in the design of the cask ensuring 

that the cask can withstand the most conservative situation regarding fuel burn-up. 


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These were the opinions, statements or comments received at the meeting. 

The concerned population, institutions and public organisations have been informed at the meeting about 

the investment proposal, the ongoing EIA and the potential health risks. In accordance with the legislation 

procedures the EIA-R will be submitted to Kozloduy Municipality and available for public access for one 

month. After that the EIA-R will be discussed on a public meeting before the competent authorities take 

their decision on the EIA-R. 

The received suggestions, opinions, statements and comments are summarized in table 7-1: 

Tab. 7-1 Suggestions, opinions, statements, comments 

№ Author Suggestion, opinion, statement, comment Answer 

1 Ms. Evelina Alexandrova. 

Environmental Chief Expert. 

Kozloduy Municipality 

2 Letter 636/21.04.2004 from 

Regional Inspectorate of 

Environment and Water 

(RIEW) - Vratsa 

3 Letter 73-00-37/26.04.2004 

from Municipality of Kozloduy 

In the new strategy for municipality's growth 

there is a decision made that it's development 

to be reoriented towards other directions 

including ecological tourism. This 

understanding is reflected in the programme 

for the environmental preservation. Even if 

the EIA report proves that there is not any 

impact, we consider that there is possibility 

that the site expansion and DSF existence 

will deter this development and to create a 

bad image for the municipality. 

As per item 4.1.2. from the Description of the 

Expected Contents of EIR to implement a 

predicted assessment of the cumulative 

impact on the environment from the operation 

of the Nuclear Power Plant and the realization 

of the Investment Proposal. 

To make clarification in item 1.2.4 

“Decommissioning of DSF”, from the 

Description of the Expected Contents of EIA- 

R about what kinds of activities shall be taken 

up for further disposal (storage) of the Spent 

Nuclear Fuel, after the decommissioning of 

the Storage Facility. 

In the process of making consultations for the 

definition of the scope, the contents and the 

format of the EIR, according to the Letter of 

the Ministry Council (LMC) №59/2003 

Chapter 3, Article 9/1, - to inform the nongovernmental 

organizations about the 

actions, taken up by the Investor according 

the procedure. 

Due to the specific nature of the Investment 

Proposal, the new for the country method of 

dry storage of spent nuclear fuel, and in 

accordance with Article 10/5 – to inform the 

special competent bodies of the Ministry of 

Health and to make consultations with the 

same. 

It is necessary that the EIA-R throws some 

more lights upon the advantages of the 

chosen method, as well as on the possible 

alternatives. 

All the assessments in the Report should take 

into account the cumulative effect from the 

construction of the storage facility. 

All the assessments in the Report should take 

into account the cumulative effect from the 

construction of the storage facility. 

The Kozloduy Municipality Authorities are 

expecting to receive answers to the question 

given in letter №73-00-93 from 26.02.2004, 

which are of vital importance for the 

population of the region 

DSF construction and operation will not 

disturb the development of ecological tourism, 

because no negative impact is expected and 

the information for the dry storage of SNF as 

a more safe technology will have favourable 

long-lasting effect. 

In the EIA-Report item 4.1.2. a predicted 

assessment of the cumulative impact on the 

environment is performed 

In the EIA-Report item 4.1.2. a predicted 

assessment of the cumulative impact on the 

environment is performed 

At the meeting on 03.11.2004 the NGOs have 

been informed about the actions, taken up by 

the Investor according the procedure. 

At the meeting on 03.11.2004 the special 

competent bodies of the Ministry of Health 

have been informed and consultations with 

the same have been made. 

In the EIA-R are clarified the advantages of 

the chosen method, as well as on the 

possible alternatives. 

In the EIA-R the cumulative effect from the 

construction of the storage facility is taken 

into account. 

Answer is given in KNPP letter ИЕ- 

1875/24.02.04 and in the EIA-Report 


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№ Author Suggestion, opinion, statement, comment Answer 

4 Minutes of meeting with 

representatives of Kozloduy 

Municipality and RIEW – 

Vratsa, took place at 

Kozloduy NPP on 15.04.2004 

5 Ms. Alexandrova 

Kozloduy Municipality 

6 MEW letter № 26-00- 

1418/10.05.2004 

During the EIA implementation the accent 

should be put on the alternatives and the 

advantages of the chosen method 

Consultations shall be planned with the 

Radiation 

Control Service at the Ministry of Health 

The opinion of the population and of nongovernmental 

organizations on the EIA of the 

Investment Proposal shall be investigated 

A comprehensive Plan for monitoring of the 

facility shall be included in the designing 

To establish contact with the relevant 

coordinator from MEW for the project, to 

make consultation about the ways, in which 

the non-governmental organizations can be 

informed about the location of the information 

on the project 

The EIA should take into account the 

cumulative effect from the construction of the 

storage facility of the „Kozloduy“ NPP Plc site 

After notifying the population of Kozloduy, to 

continue with notification for the Investment 

Proposal on regional and national levels, as 

well as of both the governmental and non- 

governmental organizations 

EIA must give answers to the questions 

stated in letter № 73-00- 93/ 06.02.2004 

submitted by the municipality of Kozloduy 

The risk of incidents during the transportation 

of the spent nuclear fuel from the location of 

its underwater storage to the New Storage 

Facility 

The cumulative impact to the environment 

resulting from the nuclear power plant 

operation and the Dry Spent Nuclear Storage 

Facility 

In part II alternatives to the technologies 

proposed by the client and the justification of 

the choice made 

KNPP invited representatives of the 

Radiation Control Unit to the Ministry of 

Health to the meeting of 3 November 

During the period 27.10. - 28.11.2003 there 

was a public awareness campaign regarding 

the investment proposal, took place in the 

House of Power Engineer in the town of 

Kozloduy. 

At the meeting held on 3 November 2004 the 

opinion of the population and of nongovernmental 

organizations on the EIA of the 

Investment Proposal was investigated. 

Designer should prepare 

Plan for monitoring 

Performed by POVVIK-OOS 

Yes, in point 4.1.2.10 - comulative impact on 

environment of KNPP and DSF operation 

Will continue with notification at the EIA-R 

public hearing 

Answer is given in KNPP letter ИЕ- 

1875/24.02.04 

It has been described in EIA-R item 4.1.3 

Possible impacts resulting from accidents 

It has been described in EIA-R item 4.1.2.10 

Cumulative impact on environment of 

Kozloduy NPP and DSF operation 

All received correspondence related to the EIA is included in the Attachment 4, as well as minutes of 

meeting between KPMU and representatives of the RIEW - Vratsa and the Municipality of Kozloduy: 

• letter 73-00-93/06.02.2004 from the Mayor of Kozloduy Municipality, 

• letter 413/18.02.2004 from KNPP to MEW, 

• letter ИЕ-1875/24.02.2004 from KNPP to Mayor of Kozloduy Municipality, 

• letter № 636/21.04.2004 from RIEW - Vratsa, 

• letter № 73-00-37/26.04.2004 from the Mayor of Kozloduy Municipality, 

• letter № 26-00-1418/10.05.2004 from MEW, 

• anouncement in newspaper "Monitor", regarding the meeting at the House of the Energetics, 

Kozloduy, for presentation of the scope and the contents of the EIA Report, 

• article in the “Purva atomna” magazine, issue VІ/2004, regarding the public meeting for discussion of 

the ToR for the EIA, 

• article in website regarding the public meeting for discussion of the ToR for the EIA, 

• article in the newspaper "Dunav" - Kozloduy regarding the investment proposal for DSF construction, 

• minutes of meeting KPMU/DSF-017 - meeting between KPMU and representatives of the RIEW - 

Vratsa and the Municipality of Kozloduy. 


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8 

PART VIII - EXPERTS CONCLUSION 

The EIA Report describes and assesses the impact of the Dry Spent Fuel Facility on the environment and 

on the public health. 

In the whole EIA study, there are no findings which should, from the environmental point of view, prevent 

the construction, commission, operation and/or decommissioning of the Dry Spent Fuel Storage Facility. 

Any potential negative impact on the environment and public health including allowance for synergetic 

effects of the background, are acceptable. 

The contribution of DSF to the radiation background in the vicinity of Kozloduy town from external radiation 

is negligible and is at least 4 orders of magnitude below the contribution of the other facilities at KNPP. The 

cumulative impact on the environment is negligible. 

The potentially affected area is within the perimeter of the Kozloduy NPP site. This area is not accessible 

to general public, it is not inhabited and it is used only for the industrial purposes i.e. generation of 

electricity. The potentially affected area does not cross the national borders. 




period, predicted to be at least 50 years. The preliminary safety analysis performed here demonstrates that 

there is no loss of cask integrity in any foreseeable accident conditions as represented by handling faults 

resulting from a dropped cask. Any adverse effects on the environment are prevented even under the most 

extreme conditions considered within the design basis, as represented by external events such as 

earthquake and fire. 

The main conclusions for the partial components of environment are as follows: 

During the construction of DSF 

• Existing infrastructure at KNPP facilitates safety of the construction and KNPP personnel. 

• The impact of the radiation factors caused by the investment proposal is non-existent since absence of 

any radioactive sources in the phase of construction. 

• The wastewater generated will not affect the water quality of the surrounding water bodies. 

• The rock environment will not be significantly damaged. 

• No impacts are expected on land usage, mineral diversity, cultural heritage, natural protected areas. 

• There will be no disturbance of the structures of the landscape types. 

• No impact on biological diversity, areas occupied by protected, important and sensitive species of flora 

can be expected. 

• The noise and vibrations are limited to the area of KNPP site and have no environmental impact. 

• The environmental impact of lighting, thermal and electromagnetic radiation is not expected. 

During normal operation of DSF 

• Existing infrastructure at KNPP facilitates safety of the personnel during the normal operation of the 

DSF. 

• Dry storage method excludes emissions of waste gases and the amounts of solid and liquid wastes will 

be lower compared with the storage of spent nuclear fuel under water in WSF. 

• The radiation impact on the personnel attending the site and facility can be expected to be within the 

design criteria given in the Investment Proposal. 

• The non-radiation risk during the 50 years of operation will not have any negative effect on the 

population within the 100-km zone. 


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• The health risk to the population in the nearest inhabited place (town Kozloduy) is negligible. 

• Air release will not significantly affect the quality of the atmosphere in regard to the radiation. 

• The emission of gaseous pollutants from internal combustion engines of the special transport 

machinery in the DSF area is insignificant. 

• Given the small quantity of potable water used, the impact on the overall KNPP water usage is 

insignificant. 

• No impact due to non-radiation factors on the soil and the rock environment is expected. 

• No radiation effects on the land and soils and no impact on the geological and rock environment are 

expected. 

• No impacts from non-radiation factors are expected on land usage, mineral diversity, biological 

diversity, ecology and cultural resources; areas occupied by protected, important and sensitive species 

of flora and fauna; picturesque sites; sites of historical and cultural importance, sites which are 

protected by international or national laws. 

• No impacts from radiation factors are expected on land usage, mineral diversity, biological diversity, 

ecology and cultural resources; areas occupied by protected, important and sensitive species of flora 

and fauna; picturesque sites; sites of historical and cultural importance, sites which are protected by 

international or national laws because of the ‘zero-release’ concept. 

• The contribution of DSF to the radiation background in the vicinity of Kozloduy town from external 

radiation is negligible and is at least 4 orders of magnitude below the contribution of the other facilities 

at KNPP. The cumulative impact on the environment is negligible. 

• A high level of safety is achieved in the DSF design, primarily because of the ‘zero-release’ concept 

utilised by the storage casks. 

• The process of acceptance, dry storage and delivery of SNF to the DSF does not lead to any 

possibility of gas emissions to the ambient atmosphere during the normal operation, equipment failure 

or during emergency situations. 

• During the operation and decommissioning of DSF, no impact is expected in non-radiation and 

radiation aspect from materially valuable items and reduction of non-renewable resources. 

• During operation phase and during the decommissioning of the DSF, no cumulative impact of nonradioactive 

noxious substances is expected. 

During decommissioning of DSF 

• No negative impact on the population beyond the 3-km zone around KNPP site is expected during 

DSF decommissioning. 

• No generation of gaseous waste is expected. 

• No impacts are expected to the waters related to the decommissioning period. 

• No negative impact due to non-radiation factors on the soil and the rock environment is expected if 

decommissioning programme and radiation procedures are strictly followed. 

• No impact upon the geological environment, rock environment, land or soils is expected and 

radioactive releases above the limit are not expected. 

• No impacts from non-radiation factors are expected on land usage, mineral diversity, biological 

diversity, ecology and cultural resources; areas occupied by protected, important and sensitive species 

of flora and fauna; picturesque sites; sites of historical and cultural importance, sites which are 

protected by international or national laws. 

• No impacts from radiation factors are expected on land usage, mineral diversity, biological diversity, 

ecology and cultural resources; areas occupied by protected, important and sensitive species of flora 

and fauna; picturesque sites; sites of historical and cultural importance, sites which are protected by 

international or national laws. 

• No negative impact from radioactive waste is expected if the plans for decommissioning of the nuclear 

facility are strictly followed as well as all Bulgarian and international legislative requirements in force at 

that time. 


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9 

PART IX - NON-TECHNICAL SUMMARY 

This summary contains some basic information on the EIA process and description of the investment 

proposal. It also includes main results of the assessment i.e. the environmental effects of the investment 

proposal. 

Backgrounds for EIA Report development 



1 January 2005 and the Regulation on the Conditions and the Order for Implementing Environmental 

Impact Assessment of Investment Proposals For Construction, Activities and Technologies SG No. 

25/2003 [L.84]. 

The purpose of EIA Report is to analyse and evaluate the environmental impact of the Dry Spent Fuel 

Storage Facility (DSF), proposed at the Kozloduy Nuclear Power Plant (KNPP) site. 

Dry Spent Fuel Storage Facility (DSF) general information 

Kozloduy NPP general information 

Kozloduy NPP is the first nuclear power plant in Bulgaria. Its construction commenced in 1970. 

The NPP is located in North-west Bulgaria in the Vratsa District and the municipality of Kozloduy. The site 

is 3.5 km southeast of the town of Kozloduy, at the Danube river coast. 

The first two units (Unit 1 and 2) were commissioned in 1974 and 1975. These units are equipped with 

pressurized water reactors of 440 MW electrical capacity, type WWER-440, model V-230. 

The next two units (Unit 3 and 4) were commissioned in 1980 and 1982. These units are equipped with 

reactors WWER-440, enhanced model V-230 with improved safety systems and stainless cladding of the 

reactor pressure vessels. 

The last two units (Units 5 and 6) were commissioned in 1988 and 1993. These units are equipped with 

pressurized water reactors of 1000 MW electrical capacity, type WWER-1000, model V-320. Units 5 and 6 

are equipped with reinforced concrete containment and systems for automation of the technological 

processes. 

Presently, the Units 1 and 2 are permanently shutdown and will be decommissioned. The Units 3 and 4 will 

be shut down in a foreseeable future and units 5 and 6 have been improved. 

Need for DSF 

One of the measures within the National Strategy for spent nuclear fuel and radioactive waste safe 

management, which is approved by the Bulgarian government by Resolution No. 693/09.11.1999 and is in 

compliance with Grant Agreement between Kozloduy NPP and EBRD for Kozloduy International Support 

Decommissioning Fund, is the construction of a Dry Spent Fuel Storage Facility, which would receive the 

spent fuel assemblies from all Kozloduy NPP units. 

The proposed DSF is in compliance with the National Strategy for the Safe Management of Spent Nuclear 


The major requirements for the DSF are as follows: 


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• to process 420 spent nuclear fuel assemblies from WWER-440 reactors and 108 spent nuclear fuel 

assemblies from WWER-1000 reactors per year; 

• phased construction of the DSF of the initial capacity 2800 fuel assemblies; 

• total storage capacity of 8000 assemblies from the WWER-440 units and 2500 assemblies from the 

WWER-1000 units; 

• Safe storage of the spent nuclear fuel for at least 50 years. 

Description of DSF 

Interim Dry Spent Fuel Storage Facility provides the safe and secure storage of spent nuclear fuel before it 

is reprocessed or disposed of as a radioactive waste. A major consideration in the operation of the spent 

fuel storage facility is to achieve and maintain high standards of safety in terms of protecting operating 

staff, the environment and members of the public. 

The main purpose of the Kozloduy DSF is to safely and reliably store the spent fuel from the Kozloduy 

Nuclear Power Plant. This function is provided with the Storage Technology - cask storage system. 

The casks are located in the Storage Building which provides suitable environment and conditions for the 

technology, operation and maintenance. 

The proposal for the DSF is divided into two stages: 







After the final stage of its construction, the Dry Spent Fuel Storage Facility shall allow acceptance and 

storage of up to maximum 8000 spent fuel assemblies from WWER-440 and 2500 spent fuel assemblies 

from WWER-1000. 

The technology of dry storage implements the principle of defence in depth (triple-barrier closure system of 

the casks) based on passive safety concept, for which no environment releases are expected during the 

storage period. The expected environmental impact will be less than that of the currently utilised and 

approved wet storage technology. 

The Dry Spent Fuel Storage Facility will be located inside the existing Kozloduy Nuclear Power Plant 

boundaries and presents an extension of the current activity of Kozloduy Nuclear Power Plant - interim 

storage of spent nuclear fuel - for which the environmental effects have already been assessed in EIA 

Report (Kozloduy NPP EIA Report from 1999). The Ministry of Environment and Waters issued a Decision 

(No. 28-8/2001), allowing further production activity of Kozloduy NPP. 

DSF location 

The site is located north-west and north of the existing WSF building of Kozloduy NPP, and is inside the 

perimeter of the Kozloduy NPP site fence. 

The site area is 12 160 m 2 and it is oriented in direction north-south with total length of 180 m and eastwest 

with total length of 110 m. The site is 50 m wide in the southern part and 35 m wide in the northern 

part. The whole site is a property of Kozloduy NPP. 

The location of the chosen site for DSF is indicated on the following drawing: 


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Layout of the DSF site within the KNPP site 

Current status (2004) of the proposed DSF site 


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DSF technology 

The storage technology proposed for the DSF at Kozloduy NPP comprises of cask storage systems with 

natural air cooling. The proposed casks are suitable for storage. The following safety and operational 

features characterise the cask storage system: 

• The cask storage system divides and separates the spent nuclear fuel in the facility into discrete 

groups of fuel assemblies. Each group is safely contained within a shielded, gas-tight, robust and 

accident resistant cask that can be easily inspected. 


materials will occur, even after a low-probability event such as impact or earthquake. 


from there by natural air convection. No active systems are required to dissipate the decay heat during 

the normal or accidental conditions. 


cavity. Even after a long storage period, the condition of the fuel assemblies allows safe handling and 

transport. 

• The spent fuel assemblies are located inside the cask in a structure which guarantees a stable state of 

the fissile material (spent nuclear fuel) under all conditions. 



• No secondary waste is generated by the casks during the long-term storage period. 




The proposed CONSTOR casks meet all the standards according to the International Atomic Energy 

Agency (IAEA) Regulations as well as the Bulgarian national standards. 

The proposed CONSTOR casks are made of steel and heavy concrete for additional shielding. Welded 

closure system completes the containment. General design concept is identical for both CONSTOR 440/84 

and CONSTOR 1000/19 casks and includes: 

• cask body, 

• fuel basket, 

• lid system (primary lid, seal plate, secondary lid), 

• trunnions. 

The sandwich design of the cask body consists of two thick-walled liners made from fine grain construction 

steel and heavy concrete (concrete with granulated steel) in the inter-space. The "steel - heavy concrete - 

steel" system provides mechanical strength and shielding against gamma and neutron radiation. 

The fuel basket guarantees a safe and stable arrangement of the fissile material and provides support of 

the fuel assemblies during loading, storage and transfer under all normal and accident conditions. 

The CONSTOR cask is equipped with a triple-barrier closure system. This system, together with the 

double-barrier design of the cask body, ensures zero-release of activity. The lid-system consists of: 

• the primary lid, sealed by elastomer O-ring (a gas tight barrier for the cask handling, transport and 

preparation until the seal plate is welded in); 

• the welded seal plate (the first gas-tight barrier for storage); 

• the welded secondary lid (the second gas-tight barrier for storage). 

Two trunnions for cask handling operations are attached with screws to the cask body. 

The cask design principle is shown in the following figure: 


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CONSTOR cask closure system principle 

The usual auxiliary technology systems (e.g. cranes) are proposed for transport and manipulation of the 

casks, power supply etc. 

DSF building 



The necessary infrastructure for operations under Stage I will be erected first together with some 

provisions for the Stage II (e.g. space for switchboards, structural consideration of the extensions joints 

etc.). For the subsequent extension to the storage area, the building will be designed to allow for 

construction to be carried out without disruption of the normal operation. 

The DSF is divided into two basic operating areas: Reception Hall and Storage Hall. 

The Reception Hall includes: 

• a controlled transport corridor with an impact limiter built into the floor (to protect the cask in the event 

of a drop); 

• a room for the instruments measuring aerosol and gaseous activity in the extracted air; 

• a workshop; 

• storage rooms; 

• a room for cables; 

• an electrical switch room; 

• personnel entrance; 

• staff welfare facilities including toilets and a changing room with health physics control and showers. 

The Storage Hall serves for storing of the CONSTOR casks is naturally ventilated (it provides sufficient 

cooling of casks). The adjoining Reception Hall is separated by shield wall with a sliding shielded door for 

moving the casks in and out. Handling of the casks is carried out using an overhead crane. 

The building location and its design are shown in the following figures: 


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DSF (Stage I) views (scale 1:1000) 

DSF general arrangement. Stage I, Stage II (scale 1:2000) 


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DSF operation 

DSF operation consists of the following operations: 

• receipt of the new cask, 

• transport of empty cask from the DSF to the WSF, 

• cask loading, 

• transport of loaded cask from the WSF to the DSF, 

• storage of the loaded casks. 

The new casks will be delivered to Kozloduy NPP and DSF by road transport. Casks are loaded in the 

WSF building. The loaded casks are dried, checked in accordance with the checking instructions and the 

lids are welded. Then the casks are transported to the DSF. In the Storage Hall, the casks are stored for 

the whole storage period of 50 years. 

DSF construction 

Dry Spent Fuel Storage Facility is a relatively simple and small building. The demands for the amount of 

raw materials, energy resources and manpower resources are not very large and are broadly comparable 

with similar buildings in the energy sector and industry. 

Building and construction materials used are commonly available. The construction site is located in a flat 

terrain and therefore there is no need for the landfills or major excavations. 

All the necessary energy, water and other supplies for the building or construction purposes are available 

at the KNPP site. 

The building and construction activities will be concentrated on the DSF site within the NPP site. The road 

access for the related traffic is provided using the existing internal roads at the NPP site, the NPP gate with 

security control and external state roads. 

DSF decommissioning 

After the closure of DSF, the casks can be reused for storage of spent fuel or storage of radioactive waste 

or they have to be decommissioned. 

Reuse of the casks requires some refurbishment work, e.g. inspection, possible renewal of the outer 

coating, replacement of lid gaskets, replacement of seal plate and secondary lid etc. For other applications 

e.g. for storage of wastes from fuel reprocessing or storage of wastes from KNPP decommissioning, casks 

have to be equipped with a basket adapted for such an inventory. 

In case that casks have to be decommissioned, the cask radioactivity has to be assessed. The expected 

activation induced by neutron flux in the cask materials is well below the limit of exemption from regulatory 

control and requires no special measures for decommissioning and conventional disposal. Contamination 

of the cask cavity, basket and primary lid requires separation of all detachable parts from the cask, 

dismantling of the basket, contamination control and decontamination of contaminated surfaces. Small 

parts, for which decontamination work would not be an economic procedure and the removed cask surface 

coating, will be disposed as radioactive waste. 

After completing the decontamination work, the outer liner of the cask body will be dismantled and the 

concrete filling will be removed and disposed of as conventional waste. The metallic materials of the cask 

body will be recycled. 

Contamination of the DSF can be practically excluded. The spent fuel assemblies, the only radioactive 

material to be handled and stored in the DSF, are permanently enclosed inside the gas tight casks. If 

unacceptable contamination is detected on equipment or building structure, this will be removed by 

standard procedures (e.g. suction, wiping, wet wiping, and disintegrative surface removal). 

All exposed surfaces of the DSF building (roof panels, walls, ceilings, floors, roads, surfaces of equipment 

etc.) will be measured and samples taken to verify if there is residual contamination. Regarding any hidden 

materials (insulation, surfaces below coatings, tiles, double floors, cables and pipes in channels etc.), 

representative samples will be taken. The sample will also be taken from the groundwater as well as soils 

at different levels. 


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After measurement has shown that negligible contamination is present, equipment and the building 

structure will be released from radiological controls. The usual methods of the dismantling and demolition 

will then be applied. 

DSF nuclear safety 

The DSF technology - CONSTOR casks - meets all the standards of the International Atomic Energy 

Agency as well as the Bulgarian standards. The cask design ensures safe state of the nuclear fuel (so 

called sub-criticality), the integrity and tightness of the cask, the shielding and the heat dispersion even in 

case of accidental conditions. 


which include the ‘zero-release’ concept utilised in the storage casks. The casks are designed to fulfil their 

safety related functions throughout the intended storage period (of 50 years) and for all design basis 

accident conditions. 

The safety analysis demonstrates that there is no loss of cask integrity in any foreseeable accident 

conditions, as represented by handling faults resulting in a dropped cask. Any adverse effects on the 



DSF alternatives 

The scope of the EIA report is focused on one location of the DSF (inside the KNPP site) and one type of 

technology (dry spent fuel storage facility). This option is called "Alternative 1". 

Apart from the Alternative 1, "Zero alternative", that means the option of not implementing the DSF, is also 

considered. 

For the completeness, other options of dealing with the irradiated or spent nuclear fuel are discussed in 

general terms under the heading "Other alternatives". 

Alternative 1 The site selection has been performed according to safety considerations, 

economical and organisational indicators and considerations for safe environmental 

management in the region of Kozloduy NPP and the social acceptability aspects. On 

the basis of generalised comparative analysis, the described site, located west of 

the existing wet storage facility (WSF) has been chosen as being the most 

appropriate location. The dry technology is well-tried world-wide as a reliable and 

safe way of storing the spent nuclear fuel. 

Zero alternative This means that the investment proposal is not realised at all. Kozloduy NPP has 

been producing quantities of spent fuel that must be treated in an appropriate way. 

Therefore the zero alternative, i.e. not building the DSF, does not offer a solution as 

the irradiated fuel still needs to be stored in another storage facility in some other 

locality or using some other technology. Considering how insignificant is the impact 

of the proposed DSF on the environment, the differences on the quality of 

surrounding environment between the alternative "1" and alternative "zero" is 

negligible. Moreover, the zero alternative does not meet the National Strategy for 

the Safe Management of Spent Nuclear Fuel and Radioactive Waste. 

Other alternatives Other alternatives that could be considered in a general way, such as extension of 

the wet storage facility, transport of the spent fuel abroad, reprocessing of the spent 

fuel, utilising a some new technologies and other similar options, are beyond the 

scope of this report. They are not in compliance with the National Strategy for the 

Safe Management of Spent Nuclear Fuel and Radioactive Waste (Ministry of Energy 

and Energy Resources, December 2004) and are not followed any further. 


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EIA Report summary 

In accordance with the Bulgarian legislation, Environmental Impact Assessment (EIA) of the investment 

proposal is performed at the earliest posibble stage to assess the feasibility of the implementation and to 

consider potential modification or rejection of the proposal. EIA is based on the information for the 

investment proposal sufficient to assess the potential impact on human health, bio-diversity including flora 

and fauna, soil, air, water, climate, landscape, historical monuments and scarce materials or interaction 

between any of these elements. 

EIA steps 

The Environmental Impact Assessment Process according to the Bulgarian legislation includes the 

following steps: 

Investment proposal Preparation. The investor prepares the Terms of Reference for the investment 

proposal and for the feasibility study. In 2003, the Technical Specification for design 

and implementation of the Dry Storage Facility for spent fuel from the WWER-440 

and WWER-1000 reactors at Kozloduy NPP was developed. Information about the 

DSF project was published on the websites of Kozloduy NPP and the EBRD and in 

the newspaper ’Dunav’. In September 2003, the Notification of the DSF investment 

proposal was made. 

Screening. Under Article 93, paragraph 5 of EPA, a decision on the necessity for an EIA is 

required from the competent authority (the MEW in this case) and this is carried out 

by a screening process: 

• The competent authority (MEW), the local authorities and population are 

informed in writing and by mass media. 

• A request for decision on the need for an EIA is submitted to the MEW. 

Scoping. The investor shall carry out consultations with the EIA competent authorities, 

relevant specialised institutions and the public regarding scoping Terms of 

Reference and the content of the EIA. 

The Terms of Reference and the scope of the EIA report were developed in 2004 in 

coordination with the MEW, RIEW Vratsa and Kozloduy Municipality. After receiving 

the MEW decision that an EIA is required, the Terms of Reference were reviewed 

during a meeting with representatives of Kozloduy Municipality and RIEW Vratsa. 

Environmental Studies. The investor has assigned the production of the EIA report to British copany NNC 

Limited and Bulgarian subcontractor POVVIK-OOS Ltd. Their experts have 

certificates and are registered by MEW under the relevant procedures. They do not 

have a personal interest in the implementation of investment proposals and are not 

in legal working relations with the competent environmental authority. 

Submission of Environmental Information to Competent Authority. The investor submits the results of the 

environmental impact assessment to MEW. 

Review of Adequacy of the Environmental Information. The competent authority shall evaluate the contents 

of the report in compliance with the requirements of the environmental legislation 

within 14 days from the report submission. 

Consultation with Statutory environmental authorities, other interested parties and public. Upon positive 

evaluation, the investor shall organise a public hearing. All interested natural and 

legal persons may participate in the hearing, including competent authorities, local 

executive administration, public organizations and citizens. 

Consideration of the Environmental Information by the Competent Authority before making Development 

Consent Decision. The evaluation of the investment proposals shall be completed 

by a decision issued by the Minister of Environment and Waters or the Director of 

the respective RIEW on the basis of a decision of the Supreme Expert 

Environmental Council, or the RIEW Expert Environmental Council, respectively. 

The competent authority shall make a decision on EIA within 3 months after of the 

public hearing. 


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Announcement of Decision. Within a period of 7 days of the enacting of the decision, the competent 

authority shall announce the decision through the mass media or by other suitable 

means. 

Post-Decision Monitoring if Investment proposal is Granted Consent. The competent authorities shall 

control the action plan implementation for the measures and the compliance with the 

conditions from the environmental impact assessment decision. 

Selected methodology 

Environmental impact assessment generally deals with two aspects: 

• location - proposed location and consequences to the surrounding environment 

• operation - proposed activities and consequences to the surrounding environment 

The DSF is located on the existing nuclear power plant site. Therefore, the location aspect is less 

significant for environmental impact assessment. On the other hand, the effect of the operation can have 

consequences outside the fenced area of the NPP and therefore it is more significant for the environmental 

impact assessment. Therefore, attention has been given to the area of radiation impact and the impact on 

human health. For this purpose special studies, such as Risk Assessment, have been performed. The 

other areas, such as impacts on air, water, soil, flora, fauna, cultural heritage which have lesser importance 

are assessed in less detail. Nevertheless, the requested scope of the assessment is implemented in 

accordance with the statutory requirements. 

The important and mandatory part of the EIA Report is the evaluation of the effects of potential accidents. 



EIA Report is not a Safety Report of the DSF. The level of assurance of nuclear safety and its components 

from the technical point of view are basis for processing this EIA Report, not its subject. The proof of the 

appropriate level of nuclear safety will be performed in the DSF Safety Report and it is not a subject of the 

EIA Report. The DSF will meet all the Bulgarian standards in the field of utilisation of nuclear energy. 

These aspects are regulated by the Nuclear Regulatory Agency (Bulgarian Nuclear Regulator) and its 

approval is necessary for construction permit. 

Description and analysis of the environmental components and factors 

Topography. KNPP is entirely situated on the non-flood plain, single-loess terrace of the Danube 

river bank at about 3.5 km from the right bank of the river. The average altitude of 

the site is +35.00 m above sea level. The geological environment around the DSF 

site consists of sandy loess and clayish loess. The design and construction works 

are consistent with the falling of the loess deposits. 

Hydrology and hydrogeology, surface and ground waters. The only surface water body, which has a 

decisive influence on the operation and safety of KNPP is the river Danube, as the 

KNPP is situated on the terrace of the Danube river. The power station was 

designed agaist a flood (from Danube), which occurs once in 10 000 years. 

The water quantity necessary for the cooling system at normal operation of the NPP 

is 110 - 140 m3/s or 2.7 – 3.5 % from the river flow. 

The natural resources of the water carrying layer are used for drinking and domestic 

needs and partially for supply of technological water to KNPP. Seven shaft-wells in 

the terrace of the Danube are built for this purpose. 

From the comparison of the results from the beta-activity measured in the period 

January 1999 – June 2004, analysis from previous years and analysis made 

upstream and downstream in the region of KNPP if follows that the operation of 

KNPP creates no trend of radioactive pollution of the Danube river. 

The analysis of the measured parameters of the water quality in the Danube shows 

that the operation of KNPP does not lead to pollution of the river. 

Lands. DSF site is located on the territory of the NPP and hence some degradation of land 

and soils is present. 


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As a whole the radiological control on soils and bottom sediments made by MOEW 

in the period 1999 – 2004 does not detect influence on the environmental 

components caused by the operation of KNPP. 

Disturbance or changes of the land categories by radioactive pollution have not 

been registered. There is no damage to the soils or change in the soil fertility within 

the region around the Kozloduy NPP. 

Landscape. As a landscape structure the assessed site represents an industrial landscape, 

because it is situated within the limits of the main site of NPP Kozloduy. 

Climatic and meteorological conditions. The region around the KNPP is located in the western parts of two 

climatic regions according to the climatic regional division of Bulgaria: the Northern 

and Middle Climatic Regions of the Danube Hilly Plain from the Moderate- 

Continental Climatic Sub-Zone. 

Radiation background, atmospheric radioactivity and atmospheric air quality: 

Radiation background. Over the whole period of the KNPP operation, the radiation background in the 

sanitary-protective zone and the zones for the emergency planning is stable. The 

average values of the radiation background before the start up in 1974 and 

during the operation of the NPP are comparable. With the increasing accuracy of 

measurements (after 1995), the radiation background values became lower, with 

smaller variation of the equivalent dose exposure rate. 

The radiation backgrounds in the region of NPP, in the 30-km zone and in the 

monitored settlements within the 100-km radius are lower than in the other parts 

of the country. 

The radiation background measured by the Rumanian authorities on the 

Rumanian side of Danuše and close to the KNPP station varies up to 0.1 µSv/h. 

Atmospheric radiation. The operation of the KNPP does not affect the radiation background and the 

level of the atmospheric radioactivity as a long-term characteristics. 

Atmospheric air quality. The air pollution concentrations of dust and noxious gases in the surface layer 

in the region of KNPP, Kozloduy town and the neighbouring villages is negligible. 

Physical hazardous factors: 

Electromagnetic fields. The impact of the harmful physical factors on humans and environment at the 

selected DSF construction site is negligible. 

Noise and vibrations. In general, the increased level of noise background on the KNPP site has no 

impact on residential areas in the town of Kozloduy. 

Protected territories, flora and fauna. DSF is located far enough from all protected territories around KNPP, 

hence they shall not be considered. 

From KNPP EIA-R (1999) and RCE annual reports it can be concluded, that there is 

no negative impact on the flora, fauna and the protected territories as a resultfrom of 

the KNPP operation. 

Cultural heritage. The construction site of the DSF does include any archaeological or cultural 

monuments directly endangered by the construction of the DSF and the 

accompanying facilities. 

Demographic, social and socioeconomic conditions. Kozloduy NPP is located in Kozloduy municipality 

consisting of the town of Kozloduy and the villages of Hurlets, Glozhene, Boutan 

and Kriva bara. The average population density is 87.4 people/km2. It is comparable 

to the average for the country but is higher for Vratsa region where Kozloduy 

municipality is located. A considerable part of the population of the town of Kozloduy 

is socially and economically related to the NPP. 

There are eight municipalities partially or entirely situated within the 30-km zone. 

Their centers are Kozloduy, Vulchedrum, Hayredin, Miziya, Lom, Byala, Slatina, 

Oryahovo and about 12 small villages in Romania. 


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The mechanical growth is positive only in Kozloduy municipality. This is related to 

the job opportunities in the operation and maintenance of Kozloduy NPP. 

The unemployment rate in Kozloduy municipality in 2002 was 16%. 

There are no grounds to suppose that the operation and maintenance of Kozloduy 

NPP have a negative impact on disease and the death rate in the region. 

Radiation situation and personnel dose loads- the parameters significantly varies 

over the years, without however exceeding the limits set by BNRP 2004. 

Radiation factors and dose loads of the population residing in the area of the Kozloduy NPP. The radiation 

impact of the Kozloduy NPP has been studies within the framework of long-term 

programs coordinated by Nuclear Regulation Agency (NRA), Ministry of 

Environment and Waters (MEW), the Ministry of Health (MH) since the plant 

commissioning in 1974. The radiation impact of the NPP on the environment and 

population is being monitored within three zones: a Sanitary Protection Zone (SPZ) 

of 3 km; a controlled zone of 12 km and a monitored zone of 100 km radius of the 

NPP. 

The results of the measured background of gamma radiation at the control stations 

and settlements within the monitored zone for the period 1999-2003 have shown, 

that it varies within the limits of the natural radiation background of 0,06 to 0,14 

μSv/h. 

Potential impacts during DSF operation 

The expected environmental effects during DSF operation are negligible. The spent nuclear fuel is 

contained within the casks, which prevents the release of radionuclides into the environment and provide 

adequate shielding of gamma and neutron radiation. The contamination of water, air and soil is practically 

zero and for the purpose of impact on human health can be excluded. Therefore, the only health hazard 

factor to be considered is the residual level of the ionising radiation, which was not shielded by the casks 

or the DSF building walls. The health risk of the regular operation of the DSF at the Kozloduy NPP in the 

nearest inhabited place (Kozloduy town) is negligible. The expected equivalent dose in Kozloduy town is 

insignificant and it is 19 orders of magnitude lower than from the natural radiation to which the inhabitants 

are permanently exposed. 

Potential impacts during DSF construction 

DSF is situated within the site of Kozloduy NPP. No significant negative effects on the population, on 

workers or on the environment are expected. All requirements of the construction will be fulfilled. 

Potential impacts during DSF decommissioning 

The decommissioning process of the DSF will start after the DSF has fulfilled its purpose which is expected 

to be in about 50 years. During the decommissioning, no negative impacts are expected. Contamination of 

the DSF building can be practically excluded, the expected radioactive waste will be very low activity. The 

decommissioning plan and all the Bulgarian and international legislative requirements for the 

decommissioning of a nuclear facility that is valid at the time of decommissioning will be fulfilled. 

Potential impacts resulting from accidents 




period, predicted to be at least 50 years. 

The safety analysis demonstrates that there is no loss of cask integrity in any foreseeable accident 

conditions, as represented by handling faults resulting in a dropped cask. Any adverse effects on the 



The proof of the appropriate level of nuclear safety will be performed in the Safety Report. 


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Proposed mitigation measures 

The DSF does not require any extraordinary mitigation measures to avoid, reduce or stop the significant 

adverse effects on the environment or on the population. The proposed mitigation measures are focused 

mainly on the ordinary fulfilling of the legislative or safety requirements and comprise: 

• measures focused on the protection of environment, site personnel and population during the 

construction phase; 


operational phase; 


decommissioning phase. 

EIA Report conclusions 

The EIA Report describes and assesses the impact of the Dry Spent Fuel Facility on the environment and 

on the public health. 

From the whole EIA study, there are no findings which should, from the environmental point of view, 

prevent the construction, commission, operation and/or decommissioning of the Dry Spent Fuel Storage 

Facility. Any potential negative impact of the proposed DSF on public health and environment when added 

to the effects of the current situation, is acceptable. 

The contribution of DSF to the radiation background in the vicinity of Kozloduy town from external radiation 

is negligible and is at least 4 orders of magnitude below the contribution of the other facilities at KNPP. The 

cumulative impact on the environment is negligible. 

The potentially affected area is within the perimeter of the Kozloduy NPP site. This area is not accessible 

to general public, it is not inhabited and it is used only for the industrial purposes i.e. generation of 

electricity. The potentially affected area does not cross the national borders. 


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10 

PART X - LIST OF THE NECESSARY ATTACHMENTS, LISTS ETC. 

10.1 GRAPHIC ATTACHMENTS 

Attachment 1 Map and layout attachments: 

10.2 TABLES 

Attachment 1.1 Republic of Bulgaria, location of Kozloduy NPP 

Attachment 1.2 Regional location map 

Attachment 1.3 DSF location on Kozloduy NPP site 

Attachment 1.4 Scheme of boreholes location on the site of units I and II 

Attachment 1.5 Scheme of boreholes location on the site of units III and IV 

Attachment 1.6 Scheme of boreholes location on the site of units V and VI 

Attachment 1.7 CONSTOR 440/84 

Attachment 1.8 CONSTOR 1000/19 

Attachment 1.9 DSF general arrangement - Stage I 

Attachment 1.10 DSF general arrangement - Stage II 

Attachment 1.11 DSF ground floor - Stage I 

Attachment 1.12 DSF sections - Stage I 

Attachment 1.13 DSF views - Stage I 

Tab. 1.2.1.3-1 Numbers of stored casks 

Tab. 1.2.1.3-2 Basic casks data 

Tab. 1.2.1.4 Basic building data 

Tab. 1.2.1.6 Equivalent dose rate limits for the personnel and population 

Tab. 3.2.1.1-1 Annual concentrations in 2002, 2003, 2004 

Tab. 3.2.1.1-2 The concentration limits for the different water categories 

Tab. 3.6.1 Radiation background, registered by AMSERC in 2002 (average data, µSv/h) 

Tab. 3.10.1-1 Number of population in the municipalities in the 30-km zone of KNPP 

Tab. 3.10.1-2 Population distribution on view of age of activity and mechanical growth 

in the municipalities in the 30-km zone 

Tab. 3.10.1-3 Population distribution 

Tab. 3.10.2-1 Unemployment for the Kozloduy Municipality 

Tab. 3.10.4.1-1 Demographic parameters about population movement in the town of Kolzoduy - 31.12. 

2002 

Tab. 3.10.4.1-2 Reason for death per 100 000 people of the population of Vratsa region in 2002 

according to ICD. Some diseases related to the impact of the factors of the environment 

Tab. 3.10.4.1-3 Registered malignant new formations in 100 000 people of the population 

in the region of Vratsa in 2002 

Tab. 4.1.1.2-1 Hazardous * substances, chemicals and materials with adverse health effects 

during construction of DSF (according to the Material Safety Sheets) 


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Tab. 4.1.1.2-2 Adverse health effects related to physical factors of the working environment, 

physiological load and accidents during constriction of DSF 

Tab. 4.1.1.4 Atmospheric emission 

Tab. 4.1.1.9 Construction machines and noise levels 

Tab. 4.1.2.1-1 Hazardous * substances and mixtures of them with adverse health effects 

during operation of DSF and WSF 

Tab. 4.1.2.1-2 Adverse health effects related to physical factors of the working environment, 

physiological load and accidents during operation of DSF and WSF 

Tab. 4.1.2.9-1 Estimated time weighted dose due to fuel movements 

Tab. 4.1.2.9-2 Estimated external dose rates 

Tab. 4.1.2.9-3 Total external dose rate from fuel movements and stored fuel 

Tab. 4.1.3-1 Faults involving a fully loaded modular storage cask considered to represent the design 

basis envelope 

Tab. 4.1.3-2 Faults involving a full modular storage cask considered to represent beyond design 

basis conditions 

Tab. 4.3.3.1 Expected emissions during 1 hour of construction works 

Tab. 4.3.4.1 Typical noise levels of construction equipment 

Tab. 6.1-1 Envisaged measures and implementation plan 

Tab. 7-1 Suggestions, opinions, statements, comments 

10.3 FIGURES 

Fig. 1.1.1 Location of the KDSF site inside the KNPP site 

Fig. 1.2.1.2 Current status of the DSF site 

Fig. 1.2.1.3-1 CONSTOR cask closure system principle 



Fig. 1.2.1.3-4 Detail of the CONSTOR cask closure system (M 1:10) 

Fig. 1.2.1.4-1 DSF general arrangement - Stage I (M 1:1000) 

Fig. 1.2.1.4-2 DSF general arrangement - Stage II (M 1:1000) 

Fig. 1.2.1.4-3 DSF ground floor - Stage I (M 1:500) 

Fig. 1.2.1.4-4 DSF sections - Stage I (M 1:500) 

Fig. 1.2.1.4-5 DSF views - Stage I (M 1:500) 

Fig. 1.2.4.1 Cask handling in the WSF (no scale) 

Fig. 3.1.1-1 KNPP site location 

Fig. 3.2.1.1-1 Map of the inspection points on Danube River 

Fig. 3.2.1.1-2 Map of the Danube basin Scheme of the wastewater discharge from KNPP 

Fig. 3.2.1.1-3 Location of the piezometers used for non-radiation monitoring at KNPP 

Fig. 3.5.1.3-1-3 "Wind roses" - Lom and Oryahovo stations and in Kozloduy (for the period from 1977 to 

1986) 

Fig. 3.5.1.3-4 Annual distribution of prevailing strong winds 

Fig. 3.6.1-1 Location of part of the monitoring stations of the national system for radiation 

monitoring 

Fig. 3.6.1-2 Intensity of the equivalent dose of gamma-radiation for the period of 1996-2002 (µSv/h) 

Fig. 3.6.1-3 Gamma background 

Fig. 3.6.2-1 Average values of the long-lived total beta activity of aerosols from the zone of 

preventive measures and the 100 km monitoring zone of the Kozloduy NPP, mBq/m 3 

(min/max.) 


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Fig. 3.6.2-2 Emissions in the air in % of the limit values 

Fig. 3.6.3-1 CO2 averaged emissions over 1997-2001 period for towns and villages 


Fig. 3.6.3-2 NO2, NOx and CO averaged emissions over 1997-2001 period for towns and villages 


Fig. 3.6.3-3 NH3, SOx and NMVOC averaged emissions over 1997-2001 period for towns and 

villages 

in the vicinity of Kozloduy city and itself (sources - NSI) 

10.4 OTHER ATTACHMENTS 

Attachment 2 Certificates of participating experts 

Attachment 3 Record of the meeting with the concerned public and authorities 

Attachment 4 Letters and notes of the meetings with municipalities and other organizations: 

Attachment 4.1 Letter 73-00-93/06.02.2004 from the Mayor of Kozloduy Municipality 

Attachment 4.2 Letter 413/18.02.2004 from KNPP to MEW 

Attachment 4.3 Letter ИЕ-1875/24.02.2004 from KNPP to Mayor of Kozloduy 

Municipality 

Attachment 4.4 Letter № 636/21.04.2004 from RIEW - Vratsa 

Attachment 4.5 Letter № 73-00-37/26.04.2004 from the Mayor of Kozloduy 

Municipality 

Attachment 4.6 Letter № 26-00-1418/10.05.2004 from MEW 

Attachment 4.7 Anouncement in newspaper "Monitor", regarding the meeting at the 

House of the Energetics, Kozloduy, for presentation of the scope 

and the contents of the EIA Report 

Attachment 4.8 Article in the “Purva atomna” magazine, issue VІ/2004 regarding the 

public meeting for discussion of the ToR for the EIA 

Attachment 4.9 Article in website regarding the public meeting for discussion of the 

ToR for the EIA 

Attachment 4.10 Article in the newspaper “Dunav” - Kozloduy regarding the 

investment proposal for DSF construction 

Attachment 4.11 Minutes of meeting KPMU/DSF-017 - Meeting between KPMU and 

representatives of the RIEW - Vratsa and the Municipality of 

Kozloduy 


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Project references 

11 

REFERENCES 

[P.1] Terms of Reference for the Environmental Impact Assessment of the Dry Spent Fuel Storage 

Facility at Kozloduy NPP. Revision 1. KPMU, 18. 5. 2004 

[P.2] Notification of the Dry Spent Fuel Storage Facility Investment Proposal at Kozloduy NPP, Plc. 

Revision 1. Translation. KPMU, undated 

[P.3] Updated Detailed Description of Technical and Performance Characteristics of Facilities (Attachment 

5 of Volume I Second Stage Tender)). GNB Gesellschaft für Nuklear-Behälter mbH, RWE NUKEM 

GmbH, undated 

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[L.3] Law of Energy Efficiency, Promulgated in State Gazette № 18, 5 March 2004 

[L.4] Environmental Protection Act, Promulgated in State Gazette № 91, 25 September 2002, amend. 

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[L.9] Waste Management Act. Promulgated in State Gazette № 86, 30 September 2003, modified in State 

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[L.11] Protected Areas Act, SG 133/11.11.1998. SG 133/11.11.1998, amend. SG 98/99, SG 28/2000 

[L.12] Soil Contamination Protection Act, in force since 28.01.00, SG 113/1999 

[L.13] Law on Protection of Agricultural Land, SG 35/1996 

[L.14] Water Act, State Gazette № 67/27.1999, effective 28.01.2000, amended and supplemented, SG № 

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[L.15] Cultural Monuments and Museums Act (CMMA), State Gazette 29/ 1969 


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[L.16] Regulation for Safe Management of Radioactive Waste. Adopted by DCM № 198 dated 3 August 

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[L.17] Regulation for Basic Norms for Radiation Protection. State Gazette № 5 of 16 January 2001. 

Regulation for the Basic Norms for Radiation Protection, adopted by DCM № 190/30.07.2004, 

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[L.18] Regulation for Emergency Planning and Readiness for Nuclear and Radiation Accidents. Adopted 

by DCM № 189 dated 30 July 2004, promulgated in State Gazette № 71, 13 August 2004 

[L.19] Regulation for Nuclear Power Plants Safety Assurance. Adopted by DCM № 172 dated 19 July 

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[L.20] Regulation on The Rule For Issuing Licenses and Permits Regarding the Safe Use of Nuclear 

Energy. Promulgated in State Gazette № 41, 18 May 2004 

[L.21] Regulation for Safe Decommissioning of Nuclear Facilities. Adopted by DCM № 204/2004, 

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[L.22] Regulation for Safety Assurance of Spent Nuclear Fuel Management. Adopted by DCM № 196 

dated 2 August 2004, promulgated in State Gazette. № 71, 13 August 2004 

[L.23] Regulation for the Terms and Conditions of Notification of the Nuclear Regulatory Agency on 

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DCM № 188 dated 30 July 2004, promulgated in State Gazette № 71, 13 August 2004 

[L.24] Regulation for the Procedure of Defining and Imposing Sanction in Case of Damaging and 

Contamination of the Environment Beyond the Permissible Limits. Decree of the Council of Ministers 

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State Gazette № 69, 5 August 2003 in force since 6 September 2003 

[L.25] Regulation for Assurance of the Physical Protection of the Nuclear Facilities, the Nuclear Material 

and the Radioactive Materials. Promulgated in State Gazette № 77, 3 September 2004 

[L.26] Regulation № 7/25.05.1992 of the MH for the Hygienic Requirements for Health Protection of the 

Environment in Settlements (SG 46/1992, suppl. and amend. SG 46/1994, SG 89,101/1996, SG. 

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[L.27] Decree of CoM № 316 with Regulation on classification, packaging and labelling of existing and new 

chemical substances, preparations and products (SG 5/2003) and Decree of CoM № 174 for 

amendment and supplement of Decree of CoM № 316 (SG.66/2004) 

[L.28] Decree of CoM № 156 for amendment and supplement of the Regulation for hazardous chemical 

substances, preparations and products, the trade and use of which is prohibited or limited (SG 

69/17.07.2002) adopted by Decree of CoM № 130/SG. 69/2002 (SG 62/2004) 

[L.29] Regulation № 17 on the admissible content in fuels of lead, sulphur and other environmentally 

harmful substances (SG 97/1999) 

[L.30] Regulation № 15 on the conditions, order and requirements for development and implementation of 

physiological regimes of respite during work time. (SG 54/ 1999) 

[L.31] Regulation № 7 on the minimum requirements for occupational health and safety conditions and 

while using working equipment SG 88/1999 

[L.32] Regulation № 16 on physiological norms and rules for manual work with loads (SG 54/ 1999) 

[L.33] Regulation on artificial lighting of buildings № 0-49 SG 7/1975, amend. and suppl. SG 64/1976 

[L.34] Regulation № 14 on occupational medicine services. (SG 95/ 1998) 

[L.35] Regulation № 5 on the order, the way and the periodicity for carrying out risk assessment. 

(SG 47/1999) 

[L.36] Regulation № 13 on the protection of employers against risks, connected with chemical agents 

exposure during work. SG 8/2004 


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[L.37] Regulation № 4 on signs and symbols for work safety and fire protection. (SG 77/1995) 

[L.38] Regulation № 4 on the training of the representatives of the work conditions committees and groups 

of the enterprises. (SG 43/ 1998 г, amend. and suppl. 85/2000) 

[L.39] Regulation № 3 on the employers’ and workers’ instruction on work health and safety and fire 

protection. (SG 44/1996) 

[L.40] Regulation № 3 on the special working clothes and personal safety guards. SG 46/2001 

[L.41] Regulation № 3 on the compulsory preliminary and periodic medical examinations of workers. 

SG 16/1987 г, amend. and suppl. SG 65/1991, SG 102/1994 

[L.42] Regulation № 23 on notification, registration and reporting on occupational diseases SG 5/1985, 

amend. and suppl. SG 34/1994, SG 87/1994, SG 47/1999 (Decree № 79/2001 does repeal it) 

[L.43] Decree of CoM № 79 Regulation on notification, registration, confirmation, appealing and reporting 

on occupational diseases SG 33/2001 

[L.44] Decree of CoM № 263 for Regulation on determination, investigation, registration and reporting on 

employment accidents, SG 6/2000 

[L.45] Environment Protection Strategy with Action Plan for the period 2001 – 2006 (Council of Ministers, 

2001) 

[L.46] National Environment - Health Action Plan (Council of Ministers, 2002) 

[L.47] Decree of CoM № 84 on the conditions and procedure for issuing of permits for construction and 

operation of new establishments and installations and for operation of existing establishments and 

installations. (SG. 38/2003 г) 

[L.48] Regulation № 2 on the constructional engineering fire-precaution norms for inflammable liquids 

storage facilities. (SG 58/1987, amend. and suppl. SG 33/1994) 

[L.49] Decree of CoM № 262 of December 6, 2000 for passing Regulation on the requirements of the soil 

protection when sewage sludge is used in agriculture, SG 101/2000 

[L.50] Regulation № 1 on geo-protection activity, SG 12/1994 

[L.51] Regulation № 1 of 1974 on determination, co-ordination and approval of the layout and terrain of 

linear objects according to the requirements of the Law for Protection of the Arable Land and 

Pastures SG 83/1974 

[L.52] Regulation № 3 of 1979. about Norms for maximum allowable concentrations of harmful substances 

in soil, SG 36/1979, supplements: SG 54/1997, SG 12/2000 

[L.53] Regulation № 5 of May 10, 1999 on the digital record structure of cadastral plans and maps, of 

planning schemes and soil categories plans, SG 56/1999 

[L.54] Regulation № 26 of 2.10.1996 on recultivation of disturbed areas, betterment of low productivity 

lands, taking and utilisation of the humus layer, SG 89/1996 

[L.55] Instruction № 2 of February 4, 2000 on fighting erosion, SG 43/2000 

[L.56] Decree of CoM 17.4.1.04-88. General requirements of soil classification and the influence of 

chemical pollutants on soil 

[L.57] Decree of CoM 17.4.3.01-86. General requirements regarding the methods for determination of 

polluting substances 

[L.58] Environmentally contaminated lands by industrial activity, Decree of CoM № 50, SG 24/1993 

[L.59] Norms on designing structures and facilities in seismic areas, 1987 

[L.60] Regulation № 1/01.09.1996 on designing of flat foundation laying (SG 85/1996) 

[L.61] Regulation № 8/16.03.2001 on the quality of water intended to be used for drinking and domestic 

purposes. (SG 67/2001) 

[L.62] Regulation № 22 of 04.07.2001 of Ministry of Agriculture and CPUAE for biological production of 

plants, plant products and nutrition of plant origin and its denotation SG 68/03.08.2001 


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[L.63] Regulation № 3 of 01.04.2004 on waste classification (Art.7 – the operator have to start filling in 

work sheets on classification of the generated waste, where simple determination of these wastes is 

done) 

[L.64] Regulation on the requirements about putting on the market of mercury containing luminescent 

lamps and for the treatment and transportation of out-of-use luminescent and other mercury 

containing lamps, adopted by Decree of CoM № 260/05.12.2000 

[L.65] Regulation № 8/24.08.2004 on the conditions and requirements of construction and operation of 

sanitary landfills and other facilities and installations for waste utilisation and disposal 

[L.66] Regulation on the requirements of production and putting on the market batteries and accumulators 

and on the treatment and transportation of spent batteries and accumulators, adopted by Decree of 

the MoC № 134/17.07.2000 

[L.67] Regulation on the requirements of treatment and transportation of industrial and hazardous wastes 

(SG 29/1999) 

[L.68] Norms of Loads and Impacts on Buildings and Installations (in force since 1.07.1989) – Order № 

RD-02-14-403/28.12.1988. Construction and Architecture Bulletin. Year XXXIII, Issue 4, 1989 

[L.69] Regulation № 1 of 7 July 2000 on the Exploration, Use and Protection of Groundwater (State 

Gazette № 57/14.07.2000 - effective 14.07.2000, corrected, SG № 64/4.08.2000) 

[L.70] Regulation № 5 of 8 November 2000 on the Procedure and Manner for Establishment of Networks 

and on the Operation of the National Water Monitoring System (SG № 95/21.11.2000, effective 

21.11.2000) 

[L.71] Regulation № 6 of 9 November 2000 on the Limit Values for Admissible Contents of Dangerous and 

Harmful Substances in the Waste Water Discharged in the Water Bodies Promulgated (State 

Gazette № 97/28.11.2000) 

[L.72] Regulation № 7 on the Terms and Procedure for Discharge of Industrial Waste Waters into 

Settlement Sewer Systems (State Gazette № 98/1.12.2000) 

[L.73] Regulation № 9 of 16 March 2001 on the Quality of Water Intended for Human Consumption (State 

Gazette № 30 of 28 May 2001) 

[L.74] Regulation № 10 on Issuing Permits for Waste Water Discharge into Water Bodies and Setting 

Individual Emission Limit Values for Point Sources of Pollution (State Gazette № 66/27.07.2001, 

effective 27.07.2001) 

[L.75] Instruction № 5 of the Ministry of Culture, State Gazette 60/1998 

[L.76] Order № 272 on the categorisation of water sources and water receiving bodies 

[L.77] BSS 14478-82 Noise. Admissible levels in working environment. General requirements of carrying 

out the measurements 

[L.78] BSS 14776-87 Industrial Micro-Climate 

[L.79] BSS 1786-84 Lighting. Natural and artificial 

[L.80] Regulation №2 for the minimum requirements for safe and healthy working conditions during the 

performance of construction and installation activities, SG 37/2004 

[L.81] Regulation for the substantial requirements and the assessment of the conformity of the construction 

products, SG 93/2000 

[L.82] Regulation for the substantial requirements and the assessment of the conformity of the machines 

and the equipment, which will operate in open air regarding the noise from them, SG 11/10.02.2004 

[L.83] Biological Diversity Act. State Gazette 77/09.08.2002 

[L.84] Regulation on the Conditions and the Order for Implementing EIAs of Investment Proposals for 

Construction, Activities and Technologies 


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Other references 

[O.1] Work Safety Bulletin MHSC, Sofia, 1995 

[O.2] Walker, L. J., J. Johnston Guidelines for the assessment of indirect and cumulative impacts as well 

as impact interactions, NE 80328/D1/3 May 1999, European Communities, Luxembourg, 1 – 172 

[O.3] WHO Assessing human health risks of chemicals: derivation of guidance values for health-based 

exposure limits. Environmental Health Criteria) 170, World Health organisation/ International 

Chemical Safety Program, 1994, Geneva 

[O.4] WHO/UNEP/ILO Approaches to integrated risk assessment Document, World Health organisation/ 

United Nations Environmental Program/ International Labour Office/01/12, December 2001, Geneva 

[O.5] BAS, 1984. Red Book of the Republic of Bulgaria, p. І and ІІ, С. 

[O.6] Beshkov, Vl., Nanev, Kr., 2002. Amphibians and Reptiles of Bulgaria, Pensoff, С. 

[O.7] Geography of Bulgaria, 2002, Forcom, S. 

[O.8] Georgiev, G., 2004. National and Natural Parks and Reserves in Bulgaria, Gea. S. 

[O.9] EIA Report on Kozloduy NPP, 1999. TU-Sofia, SRU.S. 

[O.10]Karapetkova, М., Zivkov, M., 2000. Fish in Bulgaria, Realibris, S. 

[O.11]Nankinov, D., 2000. Endangered Animals in Bulgaria, Acad. publishers. Prof. М.Drinov, S. 

[O.12]Popov, V., Sedefchev, A., 2003. Mammals in Bulgaria, Geasoft ЕООD, S. 

[O.13]Register of the existing methods of evaluation and forecast of impacts on environment, 1997, MEW, 

Phare, C. 

[O.14]General conclusions on water and air radiation monitoring within the 100 km area of Kozloduy NPP, 

1999-2003. 

[O.15]General conclusions on radioactivity of some environment and food samples within the 100 km area 

of Kozloduy NPP, 1999-2003. 

[O.16]General conclusions on radioactivity of some Kozloduy NPP industrial site samples, 1999-2003. 

[O.17]Excerpt from “Environment radiation monitoring program during Kozloduy NPP operation, ident. № 

UB.MEW.PM.262/01 

[O.18]Antonov, Hr., Danchev, D., 1980. Ground waters of Bulgaria 

[O.19]Minkov, М., etc., 1969. Kozloduy NPP. Engineering-geological conditions and foundation design of 

the main frame (corpus) with thick loess with heavy beetle and cement-loess pillow structure. 

[O.20]Philipov, L., etc., 1992. Explanatory note to geological map of Bulgaria, Map sheet Kozloduy, М 

1:100 000 

[O.21]Ivanov, P. and Latinov, L., 1993: Meteorological Conditions for the Formation of Tornado and Dust 

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Calamities and Accidents, Vol. V – Seismic Hazard, Meteorological and Hydrological Aspects of 

Calamities and Accidents 

[O.22]Climatic Reference Book of the People’s Republic of Bulgaria, 1983. Nauka i Izkustvo 

[O.23]Climate of Bulgaria, 1991. BAS Publishing House, Sofia, 500 p. 

[O.24]Nikolova, N., 1972. On the Meteorological Condition Assessment in the Region of Kozloduy Nuclear 

Power Plant in Connection with the NPP Construction Project. Proceedings of IHM, Vol. XIX. 

[O.25]Site selection for dry spent nuclear fuel storage facility in Kozloduy NPP, EQE Bulgaria 


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12 

DESCRIPTION OF THE INFORMATION ACQUISITION PROBLEMS 

RELATED TO EIA-R DEVELOPMENT 

For the purpose of the EIA report all the necessary data was provided by the investor or was obtained from 

various accessible sources. The usual problems of obtaining up to date, detailed data relating to some of 

the environmental components have been encountered and resolved in the course of the EIA study. 

This EIA report is being written independently of and ahead of the scheduled completion date of the Interim 

SAR (following the requirements of the Bulgarian legislation) so a detailed quantitative assessment of the 

accident scenarios discussed in this document will be developed as a next obligatory step defined under 

the requirements of the licensing concept for safety measures. As such, the safety issues are only 

discussed in general terms (using the conservative approach) in the EIA report, based on the safety 

requirements, and are not focused on the technical aspect of the safety analyses, i.e. whether the required 

level of nuclear safety is achieved or not. Approval of the Interim SAR by the Nuclear Regulatory Agency is 

required before construction can commence (and approval of the Final SAR by the same body is required 

before operation can commence) so the main assumption in the EIA report is that the DSF meets all 

Bulgarian regulations in the field of utilisation of nuclear energy and that all necessary regulatory approvals 

will be obtained. 


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