Monday, 5 October 2020

The importance of reporting truth in the nuclear world

Last week the UK national nuclear regulator, the Office for Nuclear Regulation (ONR) published its 2020 Annual Report. Such documents rarely contain much of interest, as they are so carefully edited, so as not to reveal anything reputationally damaging about the organization on whose affairs its reports. I have read this year’s ONR annual report, and below offer some comments on what I regard as the matters glossed over, or omitted, which distort the real picture I have been following nuclear regulation for two decades, and the for past two years, I have been a member of the ONR Chief Nuclear Inspector’s Independent Advisory Panel. None of my insights into this report arise from my participation on the CNI-IAP, which last met on 1st October, and whose discussions are currently confidential. I have highlighted comments of interest in red and underlined, with my observations in italics to follow: Strategic Theme 2 - Inspiring a climate of stakeholder respect, trust and confidence (see pages 22 to 28) Public confidence in our regulation of nuclear safety, security and safeguards is essential. While we are a trusted and respected regulator in the UK and internationally, we operate in an increasingly high profile environment, with heightened political, media, academic and public interest in the nuclear agenda. Openness and transparency underpin our communications approach, to help build and maintain public confidence. My personal experience of ONR‘s approach to openness in th epast year has been highly negative, as the Comms Department, which oversees Freedom of Information (FOI) Requests, has delayed for over a year ( the legal response time set down by the Freedom of Information Act 2000 is three working weeks) providing the full substantive answers to my FOI seeking to find out ONR’s involvement in regulating and /or promoting Small Modular Reactors (SMRs) and Advanced Nuclear Technologies (ANTs). ONR’s team has used every opportunity of exclusion clauses within the FOI legislation to withhold information, mainly to protect the commercial interest of reactor vendors over the public interest. My challenging of this recourse to secrecy has met with serious resistance by the ONR Comms team and I have been sent two letters from the ONR CEO telling me off in the most opprobrious tone for pushing her information teams for disclosures. I think she shoul dhav einterveneed and encouraged them to finda way to disclose information that should be in the public domain. Strategic Theme 2 – Inspiring a climate of stakeholder respect, trust and confidence Headlines • Publication of the first CNI Report on GB nuclear industry; • Consultation on our Strategy for 2020-2025; • Extensive stakeholder engagement associated with Hunterston B safety cases; • International peer review (IRRS Mission) of regulation of nuclear and radiological safety; and • Two formal consultations associated with REPPIR 2019. During 2019/20, we delivered 19 out of 27 corporate milestones as published within the Corporate Plan. Conduct stakeholder survey Met Completed October 2019 Strategic Theme 2: Inspiring a climate of stakeholder respect, trust and confidence 4 Strengthen insight, peer review and effective two-way stakeholder engagement. 5 Lead the UK IAEA IRRS Mission 2019, working with other regulators and government to present a coherent and accurate position of how we regulate in the UK. Openness and transparency Public confidence in our regulation of the nuclear industry is essential. We continued to provide detailed information, as set out in our publication scheme, on how we regulate, the rationale for our regulatory decisions, our research and regulatory intelligence. We strived to improve the way we engage with all our stakeholders, inviting comments and feedback through face-to-face engagement, our digital channels and via more formal consultation (see below). ONR did indeed create several processes to assess Stakeholder satisfaction with its arrangements. The problem has been that when issues regarded as sensitive to ONR have been probed or challenged, ONR has recoursed to strict interpretation both of its own Vires (ie governing legal obligations) or to very narrow interpretation of the FOI Act 2000. I have tried through many emails, severa long personal phone calls with senior ONR officials, and within webinars to exprless my dissent on this matter, but have met almost entirely deaf ears. It does make me wonder whether ONR has been acting entirely independently, or has been leant upon. While I have no evidence for this, it provides one explanation for why people who are ordinarily cordial and collegiate, have taken such an inexplicable hard line over FOI disclosures. Inaugural CNI’s report on GB nuclear industry In October we published the first of a new style of report, in which the CNI gave his view on the performance of Great Britain’s nuclear industry during the previous year. The report also featured details and analysis of safety events reported by dutyholders during the period, as well as ONR’s annual research statement. The CNI reported he was satisfied that overall the industry had continued to meet the high standards of safety and security required to protect workers and the public. The report was launched at an event for senior representatives from the industry, where the CNI set out a number of themes that require continued and collective focus from dutyholders. These were the management of ageing facilities, conventional health and safety performance, and delivering a holistic approach to nuclear security. The report was circulated to our wider stakeholders, including the media, and will become part of our annual reporting cycle. CNI Independent Advisory Panel The CNI’s Independent Advisory Panel met to address topics including strategic workforce planning, ONR’s response to the IRRS recommendations, delivery of ONR’s WIReD project and our approach to regulation of the supply chain. The panel comprises a range of representatives from industry, professional institutions and academia. Membership was further diversified to include two NGO representatives. Not mentioned is that the Spring 2020 meeting of the CNI IAP was cancelled, rather than held via videoconference. Stakeholder survey During October and November, we conducted our third annual stakeholder survey. Acting on our behalf, the independent research organisation YouGov invited almost 1,200 stakeholders to participate in this online exercise, which heard from nuclear site licensees, other dutyholders, Government, arms-length bodies, NGOs, academia, local authorities, and others. A small number of qualitative in-depth interviews were also conducted to gather further insight. The data was a vital source of insight into stakeholder perceptions of ONR and views of our performance, helping ensure we remain responsive and agile to external concerns and needs. Results were generally positive, with ONR performing very well in a number of areas and no significant drops in those areas where feedback had been positive in 2017 and 2018. They must have lost the notes of the interview I did for them! ‘Professional’, ‘independent’ and ‘trusted’ were the attributes most strongly associated with ONR. Areas identified as requiring further attention included stakeholder perception of proportionality, consistency and responsiveness to change. We intend to publish the survey results in autumn 2020. NGO engagement In November, we held the latest of our bi-annual engagement meetings with our NGO community, comprising of local and national nuclear pressure and campaign groups. Our Chair, Mark McAllister, attended the meeting and ONR representatives addressed more than 50 questions on the day. Our second planned meeting was deferred and subsequently cancelled due to the impact of COVID-19 restrictions. Throughout the year, we also engaged through ad-hoc topical meetings, by webinar and in person, to discuss issues, including regulation of civil nuclear new build and climate change. We continued to attend local site-based groups to contribute a regulatory perspective to local community representatives. Wider stakeholder engagement During the year, we engaged and consulted extensively on our Strategy 2020-2025. The Strategy sets the direction and priorities for ONR for the next five years, building on our strengths, continuing to focus on protecting society, and addressing the changing demands we will face as the UK’s nuclear regulator. Our engagement to inform the Strategy 2020-2025 included those we regulate, senior representatives from the nuclear industry, NGOs, other regulators, Government, and our staff. For the first time, we also invited comments from the wider public as we continue to strive for openness and transparency in our regulation and in setting our direction and priorities. Comments from stakeholders were wide-ranging, and included learning and working with others, welcoming innovation and new ways of working, agility and influence – all reflected in the final strategy and detailed in the associated consultation response. Our Industry Conference in June, under the theme ‘Open for Innovation’, was attended by almost 100 external delegates and live-streamed on our YouTube channel. Feedback was positive, describing ONR as progressive, collaborative and engaged. Performance report “COVID-19 does not impact our regulatory activities” (page 10) Really? See Annex I, comprising a chapter on COVID19 effects of n the nuclear sector internationally from the latest World Nuclear Industry Status Report global review, which tells a different tale. Nuclear Site Conventional Health and Safety Our resourcing and resilience strategy for regulation of conventional health and safety has been pivotal in addressing capability and capacity requirements. We combined this with ONR’s internal hazards discipline in order to finalise the full integration of the conventional health and safety discipline into ONR, and formed a new specialism, Nuclear Internal Hazards and Site Safety, under a single Professional Lead. These initiatives are expected to realise further benefits for co-ordinated planning, specialist staff development, and enhancing our assessment capabilities across our core purposes. Another key benefit has been a reduction in our reliance on HSE for front-line support, most notably in the key regulatory functions relating to the Control of Major Accident Hazards (COMAH), which are now delivered and co-ordinated ‘in-house’ and are fully aligned with our divisional plans for nuclear safety regulation. COVID-19 became a significant public health issue in the latter part of the reporting period and we continue to support national efforts to ensure that the risks arising on our sites are being properly assessed and mitigated. Our regulatory focus included assurance from site licensees that they are applying the public health measures introduced to reduce the spread of coronavirus, where appropriate. No mention of explosive chemical found stored inappropriately at Sellafield in August (discussed in my blog of 23 August 2020: Danger threat of Sellafield going bang! http://drdavidlowry.blogspot.com/2020/08/danger-threat-of-sellafield-going-bang.html ; or of the very real difficulties faced at the Hinkley Point C, when the site construction managers, EDF NNB Genco, demonstrably failed to provide Coid19 –safe work conditions; and when they did improve the arrangements under pressure primarily from local stakeholder residents rather than the combined regulators of the construction site. As I have pointed out directly to the chief nuclear inspector, accepting assurances from EDF is not prudent, as the self-same EDF has been fined several millions Euros recently by the French financial regulator for telling lies about Hinkley C finances. Make Decision – permission the start of waste retrievals from Pile Fuel Cladding Silo (PFCS) at Sellafield Not met This ONR milestone was revised to align with updated schedules from the dutyholder Make Decision – permission commencement of Silo Emptying Plant (SEP) 2 active commissioning in Magnox Swarf Storage Silo (MSSS) at Sellafield Not met This ONR milestone was revised to align with updated schedules from the dutyholder Advanced Nuclear Technologies (ANT) We successfully completed the three-year Phase 1 of the government’s ANT project, sponsored by BEIS. Key achievements were: Publication of new GDA Guidance to Requesting Parties, reflecting a modernised GDA process with improved flexibility and better suited for less mature advanced technologies. We also published GDA Technical Guidance; Provision of advice to BEIS on the potential for seven Generation IV Advanced Modular Reactor (AMR) designs, to align with UK regulatory expectations, as input to BEIS’s AMR Feasibility and Development (F&D) project; Increased a lasting capability by continuing implementing our ANT training strategies and plans and capturing our knowledge via our well established ANT Knowledge Management process; Reviewed the applicability of our regulatory guidance to SMRs and outlined a programme to extend this review to other ANTs; and Developed and implemented a programme of research and capture of operational experience (OPEX) to continue increasing our knowledge in key areas of ANT. ONR has also continued to engage with the ANT industry and overseas regulators, and to actively participate in ANT international fora such as, for example, the SMR Regulators’ Forum, IAEA activities on SMR design assessment and licensing, the Western European Nuclear Regulators Association (WENRA) and the Nuclear Energy Agency’s (NEA) Working Group on the Safety of Advanced Reactors (WGSAR). Contents Performance report 1 Overview 1 Chair’s Foreword 2 Chief Executive’s Foreword 3 Chief Nuclear Inspector’s Foreword 4 ONR in numbers 5 Performance overview 7 About ONR 7 Our Strategic Themes (2015-2020) 8 Key Issues and Risks 9 Going Concern 10 Forward Look 2020-2021 11 Performance Analysis 12 Our Financial Performance 37 Environmental and Sustainability Matters 38 Accountability Report 39 Corporate Governance Report - Directors’ Report 40 Statement of Chief Executive’s Responsibilities 43 Governance Statement 44 Remuneration and Staff Report 66 Parliamentary Accountability and Audit Report 83 The Certificate and Report of the Comptroller and Auditor General to the Houses of Parliament 85 ONR Board Chair, Mark McAllister’s Foreword I was delighted to be appointed Chair of the Office for Nuclear Regulation (ONR) on 1 April 2019 for five years. I could not have joined ONR at a more stimulating time in its journey as it entered the final year of its first five-year strategy since becoming a public corporation in 2014. At the same time, the Board was about to embark on a wider, collaborative approach to setting the organ¬isation’s strategic direction for the next five years to 2025. I am relishing the opportunities and challenges that lie ahead. One of my first priorities on appointment was to get a view of ONR from all perspectives. I have spent a significant part of my first year engaging with as many stakeholders as possible from industry and the wider nuclear community through visiting licensed sites, attending ONR-led industry events, and meeting Ministers, officials, Non-Governmental Organisations and ONR staff at every level. I can only say how impressed and assured I have been by the overwhelmingly high regard in which ONR is held by those I have met. While I am sure this honestly and accurately reflects the Chairman of the ONR Board’s experience, it reflects someone who, in my judgment, has not spoken to a wide enough range of stakeholders. ONR, to be sure, is held in high regard, both within the UK and among those from abroad with whom I have to discussed nuclear regulation: but there are significant issues where ngo stakeholders in particular take a very different view from ONR over its approach to regulation: the issue of giving an extension to the operating licence held by EDF for one of the reactors at Hunterston B AGR plant in Scotland recently, is one such very contentious point. I am pleased to report that we have again delivered our mission and achieved our 2020 vision. A key area of the Board’s attention over the last year has been maintaining momentum towards our 2020 strategic intent while also preparing the Strategy 2020-20251 – focussing on our operating environment, our regulatory strategy, a greater focus on regulatory assurance, our people and our organisational effectiveness. We sought assurance, and provided direction, to ensure our readiness to host the International Atomic Energy Agency’s (IAEA) Integrated Regulatory Review Service (IRRS) Mission to the UK. The Board has also paid close attention to our progress in delivering the independent UK State System of Accountancy for and Control of Nuclear Material (UK SSAC). On 31 March, 2020, we said farewell, with thanks, to Penny Boys CB after four years of exemplary service to the Board. I would also like to thank my predecessor, Nick Baldwin CBE, for ensuring a seamless handover last April, and my fellow Board Members for their support throughout my first year. My thanks must particularly go to the dedicated, hard-working and unstintingly loyal staff without whom the organisation could neither flourish nor deliver its purpose to society. This was brought into sharp focus in the latter part of the year through the resilience that was shown at all levels as we responded to the impact of the COVID-19 (Coronavirus) pandemic while ensuring ONR maintained effective regulatory oversight. As we look ahead, I have every confidence in ONR’s senior leadership team to see through the strategic improvement projects already underway that will enhance the organisation’s information and knowledge management system, and successfully deliver the aspirations of our new Strategy. Chief Executive Adrienne Kelbie’s Foreword With four years at the helm of ONR, it is heartening to close out our 2020 strategy in such a positive position and be looking to¬wards an even stronger 2025. This is, of course, tempered by the impact of COVID-19 on people around the globe. ONR took steps to work largely at home, and adjusted our annual plan to ensure focus on effective regulation while keeping our people safe and well. We explain more about this in our 2020/21 Corporate Plan². Our relentless focus on effective regulation has been complemented by our desire to be an exemplar of openness and transparency in how we engage with stakeholders see my very critical comments above our commitment to develop the skills of our people and culture of our organisation, and our attention to improving our infrastructure, systems and processes. I consider myself fortunate to work with colleagues who show unwavering commitment, public service ethos and team spirit. I have asked a great deal of them - to balance significant operational duties with also making changes that have strengthened ONR as an organisation – and they have delivered. So as we close 2019/20, we also close our 2020 strategy having delivered our promises. Of most importance, our regulation maintained a safe and secure nuclear estate across all of the 36 licensed sites and the hundreds of dutyholders, including transport carriers and hospitals, under our purview. We learned from, and influenced, the international nuclear regulatory community by presenting our work, participating in working groups, and contributing our expertise to IRRS peer review missions. We worked more closely with UK regulators, most notably the Environment Agency (EA), producing single, joined-up advice and guidance on topics such as Generic Design Assessment (GDA). On more than one occasion our approach was highlighted as best practice, including our Security Assessment Principles, Organisational Effectiveness Indicators, Integrated Audit and Assurance model, Strategic Framework for International Engagement, our engagement with interested stakeholder groups, and our ONR Academy. Our new nuclear safeguards and nuclear material accountancy function is being seen as an exemplar. Finally, we have successfully completed Phase One of our Well Informed Regulatory Decisions (WIReD) project. Having streamlined processes and engaged with industry, we will now build a new system and pilot it in 2021. In those areas where we did less well, notably in IT delivery and in being perceived as consistently proportionate in our regulatory decisions, we are focused on improvement and I am confident we will succeed. I’m delighted that ONR is an attractive employer, recruiting and retaining the very best people, who increasingly recognise ONR as a single organisation that thrives on teamwork, offers a supportive environment and places a steely focus on our purpose and outcomes. All this has come through hard work by our teams, recognising where we needed to do better, genuinely seeking feedback to help us improve and embracing a more outwards-looking, open-minded attitude. I thank everyone who has helped ONR become the organisation it is today. Chief Nuclear Inspector, Mark Foy’s Foreword I am fortunate to lead a dedicated and professional regulatory team that is focused on effectively delivering our core regulatory purpose. Through the evidence they have gathered, it is my judgement that the majority of GB nuclear dutyholders have continued to meet the requisite high standards of safety and security to protect workers and the public. I think that at Hinkley C construction site and in respect of parts of Sellafield, this is a challengable statement Where dutyholders have fallen short of such standards I am satisfied that their facilities remain safe and that our regulatory focus has had a positive impact on their performance. The rapid emergence of COVID-19 prompted significant changes in how we regulate. Inspectors are carrying out as much work as possible remotely, while still travelling to sites when necessary. I am grateful for the commitment shown by our teams in gaining vital assurance that the industry remains safe and secure in such unprecedented times. Issues associated with the ageing fleet of Advanced Gas Cooled Reactors (AGRs) have again been a major focus for our inspectors. We have dedicated considerable effort assessing the impact of the cracking of the graphite cores at Hunterston B and Hinkley Point B, working with the licensee to ensure the continued safety of the reactors at these power stations. We have permissioned a number of key enabling works at Sellafield in support of major hazard and risk reduction projects. The site will remain at an increased level of regulatory attention due to the nature of the hazards and risks, but I am pleased that good progress is being made. The GDA of the UK HPR1000 reactor design completed Step 3 in February 2020. The design has now entered the final step of the GDA process and we anticipate completing the Step 4 assessment during 2021/22. ONR’s Civil Nuclear Security and Safeguards team has been busy supporting the transition to outcome-focused security regulation, assessing and approving new site security plans across the industry. We have also been further developing our capability to effectively deliver the UK SSAC. During the year, ONR hosted the IRRS mission on behalf of the UK. I was pleased the mission team commented that ONR has a mature regulatory framework that could be emulated by other regulatory authorities to improve their understanding and implementation of IAEA safety standards. Areas for improvement were also identified and we are working with government and other UK regulators to address these. In October 2019, I published the first Chief Nuclear Inspector’s Annual Report2 on the safety, security and safeguards performance of Great Britain’s nuclear industry. It provides a detailed insight into industry performance and ONR’s associated regulatory interventions and, as such, complements this document. The second such report will be published in Autumn 2020. As we embark upon our new five-year strategy, I look forward to working with the Board, Chief Executive and all of the people in ONR to deliver it efficiently and effectively, ensuring the continued protection of the public. Approach to Regulating Innovation 30 September, 2020 http://news.onr.org.uk/2020/09/approach-to-regulating-innovation/ We have published our Approach to Regulating Innovation , setting out how we are open and responsive to facilitating the implementation of innovative solutions. In our recently published ONR Strategy 2020-25 , we made a commitment to embrace innovation, new approaches and technologies in how and what we regulate and to share best practice case studies and encourage dialogue. This document shows how we intend to deliver that commitment. Innovation goes beyond just advances in technology: it also covers new initiatives and novel approaches that address a specific need and we want to create an environment that is constructive and safe, in which innovation can thrive. This document sets out how we will take a leading role in delivering the Government’s better regulation policy. It is based around four themes that align with new workstreams and policy developments from the Better Regulation Executive . These four themes are: • being accessible and enabling; • working in a collaborative manner; • being adaptable, flexible and agile; and • effective horizon scanning Deputy Chief Nuclear Inspector & New Reactors Director, Mike Finnerty, said: “We’re pleased to have published Approach to Regulating Innovation. I know, having spoken to many of our stakeholders, it is highly anticipated. It sets out how we will deliver the commitments made in our recently published Strategy 2020-25 to embrace innovation and to be a modern, transparent regulator. “Our aim is to work with all stakeholders, in the UK and internationally, to identify common objectives that will help achieve new ideas and innovative approaches, while still delivering compliance with the law and ensuring that the high standards of safety and security are met.” Approach to Regulating Innovation http://www.onr.org.uk/documents/2020/onr-innovation-report-2020.pdf https://www.worldnuclearreport.org/IMG/pdf/wnisr2020_lr.pdf ANNEX 1 Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 61 NUCLEAR POWER IN THE AGE OF COVID-19 “With the COVID-19 crisis, for the first time in its history, the nuclear industry is confronted with crisis management involving safety challenges that has not a technical cause linked to its activities as origin.” Bernard Doroszczuk, President, ASN 29 April 2020 INTRODUCTION The COVID-19 pandemic had and continues to have severe global repercussions and the nuclear industry is no exception. Remarkably little information is available on COVID-19 cases in nuclear facilities and amongst regulator staff. Virtually nothing is known about testing and its results. Nevertheless, industry representatives have not stopped claiming how well the establishment has coped with the crisis and how crucial it has been. The World Nuclear Association’s Chair Agneta Rising stated late March 202066 66 - Agneta Rising, “Message: Nuclear power in the fight against COVID-19”, World Nuclear Association, as published in WNN, 27 March 2020, see https://world-nuclear-news.org/Articles/Message-Nuclear-power-in-the-fight-against-COVID19, accessed 28 June 2020. : I would like to pay particular tribute to the utilities, their workers and their suppliers who are keeping their reactors running during this public health crisis. Their work reminds us just how crucial nuclear energy is as a source of 24/7 electricity supply. The OECD Nuclear Energy Agency’s Director General William Magwood pointed out in early April 202067 67 - WNN, “Magwood outlines Nuclear Energy Agency’s response to pandemic”, 9 April 2020, see https://world-nuclear-news.org/Articles/Magwood-outlines-Nuclear-Energy-Agencys-response, accessed 1 July 2020. : It is the norm in the nuclear sector to change processes and practices only after deliberate analyses, with numerous viewpoints taken into account; but today’s crisis calls upon all for quick responses. Decisions must be made rapidly in situations that have no complete parallel. Regulators must adjust their plans for inspections. Operators will defer outages and modifications to their plants. In early June 2020, the European Commission issued an 8-page working paper on “Good Practices to Address Pandemic Risks”68 68 - European Commission, “Energy Security: Good Practices to Address Pandemic Risks”, Commission Staff Working Paper, 2 June 2020, see https://ec.europa.eu/energy/sites/ener/files/1_en_document_travail_service_part1_v3.pdf, accessed 19 August 2020.stating confidently: Nuclear power plant regulators and operators ensured that there was no adverse impact on nuclear safety and supported continued Euratom Safeguard verifications by the European Commission, as far as safely possible. There is no explanation what restrictions were implied by “as far as safely possible”. In fact, the consequences of COVID-19 on the nuclear industry and the regulators are substantial, and the impact will last for many months to come and well into 2021–2022. As Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 62 detailed below, refueling and maintenance outages were postponed, testing of key components delayed, physical inspections by safety authorities halted altogether. Some fear shortages in nuclear fuel supply due to logistical disruptions. These delays could lead to situations when outages need to be carried out in times of high demand. The consumption of electricity, however, dropped significantly in some regions during the confinement periods and is not likely to reach pre-pandemic levels for many months—if not years, given the severe global recession—which will have a major impact on the financial and economic health of nuclear utilities, which were often already facing difficulties. Permanent, independent oversight is crucial in any high-risk activity, for technical reasons and because of the possibilities for human errors. Effective regulation and control are not only of primary importance because of the very large danger potentials involved and the overall advanced ageing of the facilities. There is also a history of criminal wrongdoing, including in the major nuclear countries. Systematic irregularities, including falsifications, of manufacturing documentation has persisted for several decades at Creusot-Forge (now Le Creusot) in France69 69 - ASN, “ASN reviews the steps taken to deal with counterfeit, suspect and fraudulent items (CSFI)”, Information notice, 8 June 2018, see http://www.french-nuclear-safety.fr/Information/News-releases/ASN-reviews-the-steps-taken-to-deal-with-counterfeit-suspect-and-fraudulent-items-CSFI; and ASN, “AREVA has informed ASN of irregularities concerning components manufactured in its Creusot Force plant”, Information notice, 4 May 2016, see http://www.french-nuclear-safety.fr/Information/News-releases/Irregularities-concerning-components-manufactured-in-its-Creusot-Forge-plant; both accessed 28 August 2020.; quality-control procedures have been twisted in Japan for years70 70 - Elaine Kurtenbach and Mari Yamaguchi, “Kobe Steel Announces More Cases Of Faked Inspections Data”, Associated Press, as published by Manufacturing Business Technology, 13 October 2017, see https://www.mbtmag.com/quality-control/news/13227522/kobe-steel-announces-more-cases-of-faked-inspections-data, accessed 28 August 2020.and a new bribery scandal hit the country in the summer of 2020 (see Japan Focus); quality-guarantee certificates were faked for thousands of pieces in the South Korean industry71 71 - Max S. Kim, “How greed and corruption blew up South Korea’s nuclear industry”, MIT Technology Review, 22 April 2019, see https://www.technologyreview.com/2019/04/22/136020/how-greed-and-corruption-blew-up-south-koreas-nuclear-industry/, accessed 26 August 2020.; in Brazil, a former President has been jailed because he was involved in the bribery scheme of a nuclear construction project72 72 - Brad Brooks and Anthony Boadle, “Brazil’s ex-President Temer jailed, accused of heading ‘criminal organization’”, Reuters, 21 March 2019, see https://www.reuters.com/article/us-brazil-corruption/brazils-ex-president-temer-arrested-threatening-fiscal-reform-idUSKCN1R21JW, accessed 26 August 2020.; in the U.S. state Ohio, prominent legislators were indicted for bribery related to legislation to provide subsidies for uneconomic reactors,73 73 - Giulia McDonnell Nieto del Rio, “Powerful Ohio Republican Is Arrested in $60 Million Corruption Scheme”, New York Times, 21 July 2020, see https://www.nytimes.com/2020/07/21/us/larry-householder-ohio-speaker-arrested.html, accessed 29 August 2020; and Gregory Meyer, “Ohio corruption case throws focus on US nuclear plant troubles”, Financial Times, 22 July 2020, see https://www.ft.com/content/451324c6-9f9d-48a1-b2d9-76d731e99db6; both accessed 26 August 2020.in South Carolina, the head of nuclear new build pled guilty to fraud charges related to the canceled project V.C. Summer,74 74 - Andrew Brown and Avery G. Wilks, “Former SCANA executive pleads guilty to fraud charges tied to failed SC nuclear project”, Post and Courier, 23 July 2020, see https://www.postandcourier.com/business/former-scana-executive-pleads-guilty-to-fraud-charges-tied-to-failed-sc-nuclear-project/article_26e23ca8-c50b-11ea-8377-e7b39854212b.html, both accessed 25 July 2020.and a Europe-wide bribery system of nuclear waste shipments involving several European countries shook up the industry in the late 1980s75 75 - Mycle Schneider, “Transnuklearaffäre—Über die Arbeit des Untersuchungsausschusses im EP”, November 1988.. These are merely a few examples, some of which have been thoroughly documented in various editions of the WNISR. Physical inspections by regulatory authorities in nuclear facilities are therefore necessary. Halting them altogether for many weeks is not without consequences.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 63 OVERVIEW OF KEY SAFETY AND SECURITY ISSUES The following analysis focuses on nuclear power plants. However, this does not mean that the potential impact of a pandemic on other nuclear facilities can be neglected. In fact, the operation of most of the nuclear fuel chain facilities considered non-essential for continued short-term operation of nuclear power plants was halted in many nuclear countries, including spent fuel reprocessing plants in France and in the U.K. The operational status of a plant is crucial for any risk assessment. There is a clear difference of the risk level between operating power plants and plants in cold shutdown status. Some of the following areas of concern are also applicable to other nuclear facilities, e.g. reprocessing plants or larger research reactors: Periodic testing with short time-intervals like several weeks. This type of testing is done at systems to provide assurance that vitally important functions like the emergency control room operations, emergency electricity supply, emergency core cooling or (at PWRs) emergency feedwater supply are in good working order. The test intervals had been determined by failure probabilities derived from operating experience. Because of their risk importance, these test intervals are generally fixed by guidelines and/or plant specific provisions; to follow these is a legal obligation of the operator. To prolong the test intervals means a risk increase of unidentified failures of those systems and an increase of failure probability in emergency situations, i.e. situations, where the systems are necessary to prevent catastrophic accidents or to mitigate their consequences. If operators prolong the test intervals without appropriate review and analysis either by the operator or regulator, they violate their safety obligations. There can be—and in fact has been (see examples hereunder)—a formal acceptance by the relevant regulatory authority of prolonged test intervals because of an exceptional situation, like a pandemic. But in some of those cases the authority violates the general principle of “nuclear safety first”. Periodic inspections at low frequency like once in several years. These include detailed inspections of many electrical and mechanical components in key areas of the plant. It includes also ultrasonic testing of large components like reactor pressure vessels, primary circuit components or steam generators at PWRs; the purpose is to follow the growth of cracks or other weaknesses like wall-thinning up to potentially hazardous dimensions. The information gained is necessary to decide whether a repair or a replacement of the component must be implemented. Those tests and inspection walks are necessarily performed during planned outages for maintenance and refueling as the components have to be accessible in terms of temperatures, absence of high pressures and excessive levels of radiation. These outages typically involve significantly increased numbers of workers needed for the preparation and implementation of the tests. The inspection intervals have also been determined by failure probabilities derived from operational experience. To prolong the inspection intervals, for example by the decision to delay outages to avoid large numbers of additional workers on-site, means a clearly increased loss of control over weaknesses of mechanical or electrical components. Normally periodic testing and inspections—both low-frequency and high-frequency—are performed under the four-eyes principle (at least two people have to be always present). This implies close contact between the persons involved. If the rules are Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 64 weakened due to social distancing needs caused by the pandemic, the probability of mistakes grows, which means a higher risk of potential system failures. ɆɆIn some countries, the relevant safety authorities and their Technical Support Organizations (TSOs) have decided to halt site visits or to dramatically reduce their frequency. The U.S. NRC implemented a reduced inspection program, e.g. In countries where the authorities rely on experts from TSOs or from third party inspectors, the analogue reduction of inspections by these experts was or is being considered. Some regulators have shifted to just inspecting the paperwork (e.g. in France). However, there is a significant difference between judging safety only on the basis of paperwork examinations and the physical inspections of facilities; unreported situations might become visible only in the presence of an inspector. Although the operator is entirely responsible for the quality of testing and maintenance, experience has shown that additional inspections by regulators or other entities enhance the quality of the results, as more failures or weaknesses are detected. The reason is clear: different people, especially when they come from different organizations, have different inspection methods and identify issues of non-compliance with standards and regulations. Experience also shows that during a physical inspection sometimes irregularities are detected, which have not been the original focus of a given specific inspection. A well-known example is the inspection in the US-plant Davis Besse, where a strong degradation of the reactor pressure vessel lid was detected by chance. Limiting inspections to paperwork instead of the real plant can hide a lot of safety weaknesses. Again, restrictions or reductions in inspection intensity and quality lead to an increasing probability of major failures. ɆɆSpecial problems arise with the control room staff, people with very specific knowledge and training and with a specific formal qualification. In most countries, a very limited number of people have acquired this qualification. A pandemic needs reduction of social contacts not just at work but in day-to-day life: The full staff of the control room has to be present in a limited space. It is necessary to perform actions under the four-eyes principle, which is impossible without at least two people being in proximity. Each outgoing shift has to inform the incoming shift on all important developments of the previous hour. ɆɆIf there is an infection or the need for quarantine amongst the limited number of qualified control-room staff, this can reduce available operators below the necessary minimum. This seems to be of particular concern for countries with only one (Armenia, Iran, Netherlands, Slovenia) or a small number (<5) of operating reactors (e.g. 3 in Argentina, 2 each in Brazil and Bulgaria, 4 each in Finland, Hungary, Slovakia, Switzerland, Taiwan). However, in most countries shift staff in the control room are not licensed for all or even several reactors in a given country, as they have obtained a license only for a specific plant or for a group of identical reactors. The reason is that the control features and systems often have big differences between individual plants; that is specifically the case for those needed in an emergency. In case of an emergency event, the control room staff must be aware of these very specific features to avoid failures. Therefore, in most cases, it is not possible to replace staff impacted by a pandemic by staff from other plants, as those usually have no additional license and training for various plants (with the exception of staff from identical “sister-plants”). This means, even countries with a large reactor fleet are faced with the same problem. The situation in France, Russia and Ukraine with a significant number of identical Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 65 (or almost identical) plants is not typical for any other country with a large reactor fleet. And even in the case of these three exceptions, a staff exchange would only be possible within a group of one specific design, not for all reactors in the country. For example, the U.S. and Japan have many different designs of control room and emergency systems, even if the nuclear steam supply system can be of a similar type. Even smaller fleets are often surprisingly diverse, e.g. Germany’s remaining six reactors have four different designs, and Switzerland’s four operating units are of three different designs. Quarantining entire shifts—as was done in some cases—is not without risk either. The IAEA stresses: “It is also important to note that there is potential for common cause failure, as operators reside together in communities.”76 76 - IAEA Board of Governors, “The operation, safety and security of nuclear and radiation facilities and activities during the COVID-19 Pandemic”, Report by the Director General, GOV/INF/2020/8, 4 June 2020, see https://www.iaea.org/sites/default/files/20/06/govinf2020-8.pdf, accessed 19 August 2020. In terms of nuclear risk management, the cessation of reactor operation is unavoidable once critical limits are reached and switch to shutdown mode, which requires less staff in the control room. What to do, if even minimum staffing for the shutdown mode is not guaranteed, remains an open question. Fortunately, no such case has been reported yet. Regarding possible nuclear emergency situations in times of a pandemic, it is clear that rules of social distancing and imperatives of addressing the situation contradict each other. This is especially the case, when a nuclear event needs quick response or densely staffed spaces, like the emergency control room or emergency staff rooms. The emergency control room is a second control room in the nuclear power plant, from where it is possible to activate and stop a number of the essential safety systems of the plant. It is implemented for situations when the main control room becomes inaccessible, for example, because of a fire or toxic gas buildup. In general, emergency control rooms are not very large and so incompatible with social distancing. The emergency staff room is separate from the main control room, but onsite. In case of an emergency, a group of additional specialists and decisionmakers (emergency staff) that is collecting information on the situation for evaluation and decision making will be using this room. It is designed for many people to stand or sit side-by-side in a very limited space. The existing rules of procedure for both emergency control rooms and emergency staff rooms do not reflect a situation where social distancing is necessary. Therefore, in the future it would be crucial to have appropriate rules of procedure in advance to deal with such conflicting issues in case of a nuclear accident during a pandemic. Offsite emergency response plans rely heavily on evacuating local population groups to designated centers. These centers densely pack people into areas in which COVID-19 social distancing rules would be violated. Moreover, large numbers of public safety officials must coordinate the offsite response. Current plans, in the U.S., e.g., require large numbers of officials to meet and direct the response from centralized emergency response rooms with limited ability to maintain social distancing. Nuclear plants are highly sensitive for terroristic attacks because of the potential consequences that could result from such an attack. Regarding plausible terroristic attack scenarios, one has to differentiate between external attacks and attacks from inside. The main impact of a pandemic on scenarios of external physical attacks is related to potential reductions in available security forces. These are highly trained teams with particular knowledge of the facilities they have to guard. Similar to control-room staff, there are Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 66 only a limited number of specialized security personnel and contamination amongst these forces could lead to a serious security deficit on-site. In some countries, e.g. the U.S., certain security trainings have been suspended during the COVID-19 pandemic.77 77 - Christopher G. Miller, “Updated Implementation of resident inspector site coverage during COVID-19”, Division of Reactor Oversight, Office of Nuclear Reactor Regulation, U.S.NRC, Memorandum dated 6 April 2020, see https://www.nrc.gov/docs/ML2009/ML20097E538.pdf, accessed 8 September 2020. Attacks are also possible from the inside, be it mechanical or electronical. Scenarios for those attacks include cases with step by step preparation of degradation of safety relevant systems; with the objective that they do not protect adequately, when the attack itself starts. In “normal” times, there is a certain probability that tests and walkdowns for inspection (or even for other purposes) in the respective areas detect such manipulations. If the tests are reduced in number and if walkdowns were strongly reduced, then a potential terrorist has a better chance to prepare an attack and go undetected. RESPONSE STRATEGIES TO COVID-19 BY OPERATORS AND REGULATORS AROUND THE WORLD Several international organizations have issued assessments of the impact and recommendations for nuclear establishments how to cope with the COVID-19 pandemic. The following section provides an overview of reactions by the IAEA, the OECD-NEA and other international and national organizations. On 4 June 2020, the IAEA’s Director General reported to the Board of Governors on the “operation, safety and security of nuclear and radiation facilities and activities” during the COVID-19 pandemic.78 78 - IAEA, “The operation, safety and security of nuclear and radiation facilities and activities during the COVID-19 Pandemic”, Report by the Director General, 4 June 2020, op. cit. The 10-page paper stated: The impact of the COVID-19 pandemic has been far reaching. (…) National policy decisions made by governments have direct and indirect repercussions to organizations in the nuclear and radiological field, for example in the area of human resources. Decisions in one country could have affected facilities in other countries, for example through introducing supply chain difficulties in large scale projects such as outage management, major refurbishment or new plant construction. (…) The stretching of government infrastructure capacity could also potentially have an impact on the emergency preparedness of nuclear and radiation facilities. The IAEA’s DG also pointed out that the crisis is without precedent: “COVID-19 is the first pandemic of this scale in the history of the nuclear industry.” The Agency saw its role as a facilitator of information exchanges between Members States and operators. It set up an international peer-to-peer network (COVID-19 OPEX Network) on nuclear plant operation. The pandemic’s impact on training activities and human resources policies is to be discussed at a special meeting in October 2020. A number of meetings have been cancelled and rescheduled, including the Eighth Review Meeting of the Convention on Nuclear Safety (CNS) and the 7th Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 67 Review Cycle of the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management (The Joint Convention). While the IAEA noted multiple disruptions of ordinary schedules and procedures, 79 79 - A range of issues encountered are important but beyond the scope of the WNISR, e.g. the IAEA DG stated: „There has been significant disruption in the distribution of medical isotopes and radioisotopes.” it remarkably states: “No Member State reported the enforced shutdown of any nuclear power reactors resulting from the effects of COVID-19 on their workforce or essential services such as supply chains.” In fact, according to the IAEA, in Brazil, Finland, Iran, the Netherlands and Switzerland, “generation is expected to exceed original 2020 estimates because outages were either shortened or deferred to 2021”.80 80 - IAEA, “The operation, safety and security of nuclear and radiation facilities and activities during the COVID-19 Pandemic”, 2020, op. cit. In the EU, the European Commission recognizes that the energy sector “faces unique constraints as regards the continuity of critical operations, safety and the immediate cascading effects across sectors and Member States in case of incidents.”81 81 - European Commission, “Energy Security: Good Practices to Address Pandemic Risks”, Commission Staff Working Paper, June 2020, op. cit.The Commission also stated: It is worth noting that the steep reduction in electricity demand during the COVID-19 pandemic has led to a higher share of renewables in the electricity mix, while the electricity system and balancing continued operating normally. The Commission issued guidelines to allow for the free movement of workers to make sure that refueling of nuclear plants as well as other key activities in the energy sector (e.g. maintenance of offshore wind farms) was not impacted. One of 20 “good practices” during the pandemic stipulates a “pragmatic risk-based approach by national regulators, in particular the nuclear sector”.82 82 - Ibidem.Indeed, nuclear safety authorities seem to be handling the crisis in a very flexible and pragmatic manner, as illustrated in the overview below. GENERAL DIFFICULTIES AND MEASURES A range of measures to cope with the COVID-19 pandemic were taken by operators and regulators in most countries operating or building nuclear facilities, in many cases consisting in the reduction or elimination of activities judged non-essential, implementation of social-distancing rules and the rescheduling of refueling and maintenance outages. The IAEA received reports of outage impacts at nuclear plants in 26 of the 30 Member States with operating reactors:83 83 - The 31st country with operating units is Taiwan, which is not an IAEA Member State. In some cases, outage scopes were reduced by eliminating non-critical work to minimise external staff brought on-site. In other cases, outages were extended to allow work to proceed at a slow pace that accommodated physical distancing constraints. In still other cases entire outages were deferred to next year. The full impact will play out over at least the next year as future outage plans are revised to complete deferred work.84 84 - IAEA, “The operation, safety and security of nuclear and radiation facilities and activities during the COVID-19 Pandemic”, 2020, op. cit.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 68 Other measures included regular medical screenings, travel restrictions, self-isolation and physical meeting restrictions. Mitigation plans at some facilities resulted in a need for more licensed personnel, which is being “satisfied by newly trained as well as previously qualified staff, including recent retirees and instructors”, reports the IAEA. “However, this approach in itself is facing challenges in maintaining the required quality and quantity of training in the context of other restrictions limiting the ability to assemble employees.” Nuclear regulators have taken similar steps as the operators to mitigate the effects of the pandemic. These include virtual rather than face-to-face meetings internally and with regulators in other countries, moving from physical inspections to remote monitoring, and issuing exemptions to regulations. Trade journal Nuclear Intelligence Weekly (NIW) reported: These exemptions—allowing significantly longer work weeks for plant employees and deferring maintenance and inspection, in some cases for up to two years—are precisely why regulators are encountering criticism. Beyond that, workers at some plants have complained either publicly, or via media leaks, that operators aren’t doing enough at plant and/or newbuild sites to prevent the spread of COVID-19. And health officials in some communities have requested that refuelings be postponed.85 85 - Jessica Sondgeroth and Gary Peach, “Safety: Nuclear Overseers Vary Response to Covid-19”, NIW, 5 June 2020, see http://www.energyintel.com/pages/eig_article.aspx?DocId=1074603&NLID=104, accessed 19 August 2020. NIW also published a compelling analysis on the impact of the COVID-19 crisis on the nuclear fuel manufacturing industry and the risks to nuclear power plant operators and concluded that …for nuclear operators dependent on one single fuel fabricator, the risks are acute: a severe localized COVID-19 outbreak could threaten the supply of fuel assemblies for whole fleets of reactors in India, Russia, South Korea or the UK. Even for operators with more diversified suppliers in Europe and the US there could be problems.86 86 - Jessica Sondgeroth and Phil Chaffee, “Fabricators Prepare for Potential Supply Disruptions”, NIW, 17 April 2020. The state-by-state response to the COVID-19 crisis and a “dearth of leadership from the top” make the U.S. supply chain “more vulnerable”, according to NIW: Risks to factories are twofold: First, in areas under stay-home orders, their workers might not be declared essential and therefore be forced to quarantine at home, and second—particularly in regions where governments are more lax about quarantining—that a localized outbreak sickens too many employees for the facility to operate safely.87 87 - Ibidem. Reportedly, only Framatome and Westinghouse have requested exemptions to regulatory obligations. According to an NRC spokesperson, “Westinghouse has requested to defer until 2021 an internal emergency planning audit because a Westinghouse corporate team cannot currently go to the site” and a Framatome representative indicated that “although the company has reduced on-site staff at its Richmond plant by almost half, the company has all the components it needs in stock to meet spring and fall refueling outages”.88 88 - Ibidem. The pandemic also impacted the construction of new plants in at least 12 of the current 17 countries building nuclear reactors but apparently nowhere were construction activities halted altogether (see also Middle East Focus). Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 69 COUNTRY-BY-COUNTRY OVERVIEW The following section provides a country-by-country overview of reported COVID-19 cases at nuclear facilities as well as countermeasures taken by operators and regulators.89 89 - Unless otherwise indicated, the information in this section is based partially on IAEA, “The operation, safety and security of nuclear and radiation facilities and activities during the COVID-19 Pandemic”, June 2020, op.cit., and on INRAG, “Nuclear Safety and Security During a Pandemic”, Working Paper, 24 April 2020, see https://www.inrag.org/nuclear-safety-and-security-during-a-pandemic-2, accessed 16 July 2020.In fact, very few operators and regulators have published and regularly updated data about detected COVID-19 cases and their handling. The Swiss NGO Physicians for the Environment (Ärztinnen und Ärzte für Umweltschutz) has openly criticized the refusal by the national regulator to respond to any questions about testing and positive cases in nuclear facilities in the country.90 90 - AefU, “Die Sicherheit der Atomkraftwerke darf keine Geheimsache sein!”, Ärztinnen und Ärzte für Umweltschutz/Médecins en faveur de l’Environnement, Press Release, 23 March 2020 (in German), see http://www.aefu.ch/fileadmin/user_upload/aefu-data/b_documents/Aktuell/20190506_AefU_MM_Corona_u_AKW_Sicherheit.pdf, accessed 18 July 2020. Argentina Measures and Impacts Staff at the three operating reactors in the country work in staggered 14-day shifts, with 14 days off in between. Thermal imaging cameras at the entrances check for body temperatures exceeding 37°C for anyone entering the plant. The nuclear power plant operators have been seeking regulatory approval to reschedule all planned outages.91 91 - Phil Chaffee, “Nuclearelectrica Back in The Driver’s Seat”, NIW, 10 July 2020, see http://www.energyintel.com/pages/eig_article.aspx?DocId=1077846, accessed 19 August 2020. Construction work on the Carem-25 was entirely stopped in March 2020 and had not restarted in early July 2020. Work on the Atucha-1 dry storage project has been given permission to continue during the quarantine as the site is running out of storage space in the spent fuel pool. Armenia Measures and Impacts The shutdown dates for preventive maintenance at Metsamor, the single operating reactor in the country, were postponed for 45 days to 1 July 2020. Reportedly, “borders closures have complicated the conclusion of agreements on the supply of necessary equipment and materials”.92 92 - NEI, “Armenian nuclear plant delays scheduled outage”, 28 May 2020, see https://www.neimagazine.com/news/newsarmenian-nuclear-plant-delays-scheduled-outage-7936742, accessed 19 August 2020. Belarus Infections As of late May 2020, the Ostrovets construction site counted around 100 confirmed COVID-19 cases amongst the workforce of about 4,000.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 70 Measures and Impacts “All the quarantine measures are being observed, but I would particularly like to ask ASE’s [Atomstroyexport’s] leadership and managers of the project to fortify measures even more,” Rosatom Director Aleksei Likhachev said on 26 May 2020. However, NIW noted that “it is difficult to gauge the extent of the virus’ spread given contradictory reports over the past two months and questions raised about the quality of testing in Belarus, one of a handful of countries whose leadership has expressed skepticism about the gravity of COVID-19.”93 93 - Gary Peach, “Belarus Prepares Reactor Launch Despite Covid-19 Surge”, NIW, 29 May 2020, see http://www.energyintel.com/pages/eig_article.aspx?DocId=1073935&NLID=104, accessed 19 August 2020. While the first fuel load had arrived on-site in May 2020, fuel loading of Ostrovets-1, was delayed and only started on 7 August 2020, which will likely lead to further postponing of the plant’s commissioning.94 94 - Reuters, “Belarus begins fuel loading at Astravets nuclear power plant -Rosatom”, 7 August 2020, see https://www.reuters.com/article/belarus-power/belarus-begins-fuel-loading-at-astravets-nuclear-power-plant-rosatom-idUSL8N2F92KJ, accessed 24 August 2020.It also remains to be seen what effect the recent strikes and opposition movements will have on the project. Belgium · “All Necessary Measures”? — No masks. Source: Electrabel, screenshot, 8 August 2020.95 95 - Electrabel, “Coronavirus: les centrales nucléaires belges prennent les mesures nécessaires”, Engie, Undated (in French), see https://nuclear.engie-electrabel.be/fr/news/coronavirus-les-centrales-nucleaires-belges-prennent-les-mesures-necessaires, accessed 8 August 2020. Note: The title of the picture says “Coronavirus: the Belgian nuclear power plants take the necessary measures”. The photo shows three Electrabel employees without masks and no social distancing. The page has not been updated since 15 May 2020. Measures and Impacts Nuclear operator Electrabel delayed refueling outages over the next three years. Basic measures include: The limitation of staff on the nuclear sites; Remote work to the extent possible; Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 71 Respect of social distancing rules; Wearing a mask “at strategic locations”; Delaying of all “non-urgent” training, meeting and maintenance activities. It is unclear how to interpret the term “strategic location”. The photo hereunder shows three Electrabel employees without mask, and without social distancing (see Figure 19). Measures by the Regulator In mid-March 2020, the Belgian regulator Agence Fédérale de Contrôle Nucléaire (AFCN) halted all pro-active and scheduled inspections and its Technical Support Organization (TSO) delayed all topical inspections and reduced periodical inspections. Training certificates for nuclear transport drivers and security advisers were extended up to nine months.96 96 - AFCN/FANC, “Organisation adaptée à partir du 14/03/2020”, Updated 15 June 2020 (in French), see https://afcn.be/fr/professionnels, accessed 20 July 2020; and AFCN/FANC, “Transport de matières radioactives”, Updated 30 April 2020, see https://afcn.be/fr/professionnels/transport-de-matieres-radioactives, accessed 19 August 2020. Other In mid-April 2020, in the EU country the worst hit by the COVID-19 pandemic, nuclear operator Electrabel and its owner Engie requested a Government decision on the potential lifetime extension of two of the country’s seven reactors “by the end of the year”. The move did not go down well with Prime Minister Sophie Wilmès: “Bad timing, and if they don’t understand English, I will tell them that it is really not the moment to speak about that”.97 97 - Belga, “Electrabel met la pression sur Sophie Wilmès pour prolonger le nucléaire”, as published by RTBF, 16 April 2020 (in French), see https://www.rtbf.be/info/economie/detail_electrabel-met-la-pression-sur-sophie-wilmes-pour-prolonger-le-nucleaire?id=10483138, accessed 18 July 2020. Brazil Measures and Impacts Preparatory work in order to restart construction at Angra-3 has slowed but not stopped as a result of the COVID-19 pandemic, which is likely to further impact upon the completion schedule.98 98 - BNamericas, “COVID-19: What next for Brazil’s Angra 3 nuclear plant?”, 15 June 2020, see https://www.bnamericas.com/en/news/covid-19-what-next-for-brazils-angra-3-nuclear-plant, accessed 15 June 2020. Canada Infections No precise information is available. Industry representatives claimed that they were well prepared and have had “no known cases of COVID transmission”.99 99 - CNSC, “Nuclear power plants: Safe adaptation during COVID-19 (Part 1)”, Commission meeting held 17 June 2020, published 10 July 2020, see https://www.youtube.com/watch?v=HPNf-wzTI2c&feature=youtu.be, accessed 28 July 2020.However, it was reported that at least one worker tested positive at the Pickering plant in late March 2020.100 100 - Maryam Shah, “Employee at Pickering nuclear station tests positive for COVID-19: OPG”, Global News, 29 March 2020, see https://globalnews.ca/news/6749184/pickering-nuclear-station-employee-covid-19-opg/, accessed 6 August 2020.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 72 Measures The Canadian Nuclear Safety Commission (CNSC) requires nuclear operators “to develop and implement a business continuity plan to ensure their facilities continue to operate safely at all times, including during a pandemic. Business continuity plans address how to deal with possible labour disruptions while maintaining key staffing positions.”101 101 - CNSC, “CNSC’s response to COVID-19”, 13 March 2020, Updated 10 July 2020, see https://nuclearsafety.gc.ca/eng/resources/emergency-management-and-safety/pandemic-preparedness.cfm, accessed 28 July 2020. The CNSC claimed: We’re maintaining regulatory oversight of the measures licensees are taking to help fight the spread of the virus, including staffing changes and modifications to non-essential work. At the same time: We’re being flexible with licensees, understanding that they will need more time to report to the CNSC on issues that are not safety significant.102 102 - Ibidem, April 2020. Planned upgrade work on the Ontario Power Generation (OPG) Darlington Nuclear Generating Station’s Unit 3 has been postponed. Work to enhance the safety of the plant in the context of the station’s plant life extension has been rescheduled for fall 2020 instead of spring 2020.103 103 - OPG, “OPG targets fall date for Unit 3 refurbishment in response to COVID-19”, Ontario Power Generation, 2 April 2020, see https://www.opg.com/news/opg-targets-fall-date-for-unit-3-refurbishment-due-to-covid-19/, accessed 12 July 2020. OPG has scaled back the number of staff at the local generating stations but has not planned to shut down any of its reactors; indeed, its CEO has argued for continued operations of nuclear plants.104 104 - Jennifer O’Meara, “Lights on, masks up: OPG Darlington and Pickering step up during coronavirus”, DurhamRegion.com, 28 March 2020, see https://www.durhamregion.com/news-story/9917304-lights-on-masks-up-opg-darlington-and-pickering-step-up-during-coronavirus/, accessed 28 July 2020.Further, Unit 2 of Darlington nuclear power plant, off-grid since October 2016, completed refurbishment in the middle of the pandemic, reached first criticality in April 2020 and was reconnected to the grid in June.105 105 - OPG, “Darlington Unit 2 powers on—Refurbishment now complete on first unit”, 4 June 2020, see https://www.opg.com/news/darlington-unit-2-powers-on/, accessed 28 July 2020. Measures at the Regulator Effective 16 March 2020, “CNSC staff have been directed to stay home, while critical staff continue to work to ensure effective regulatory oversight.” All physical site inspections ceased entirely; commission meetings and public hearings have been postponed. On 5 May 2020, limited on-site inspections resumed. A 16–17 June 2020 meeting scheduled was held virtually and was accessible via webcast for the public.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 73 China Very little is known about the COVID-19 crisis management at nuclear facilities in China and authorities have stated that it will not impact nuclear reactor construction.106 106 - Muyu Xu and David Stanway, “China says virus outbreak will not impact nuclear power plant construction”, Reuters, 15 April 2020, see https://www.zawya.com/mena/en/business/story/China_says_virus_outbreak_will_not_impact_nuclear_power_plant_construction-TR20200415nL3N2C311BX1/, accessed 27 May 2020.However, there are estimates that in January and February 2020, nuclear energy’s contribution to the grid declined by 2.2 percent due to the pandemic.107 107 - Xizhou Zhou, “Renewables Emerge as Winner During China’s COVID-19 Lockdown”, IHS Markit, 26 March 2020, see https://ihsmarkit.com/research-analysis/renewables-emerge-as-winner-during-chinas-covid19-lockdown.html, accessed 27 April 2020. Finland Measures and Impacts The Finnish Radiation and Nuclear Safety Authority (STUK) believes that nuclear power plants have prepared adequately for the risks and can be operated safely. STUK, however, announced that on-site inspections will “only be carried out at sites which are the most significant for safety, and the health authorities’ guidelines on avoiding close contact will be taken into account in the inspection arrangements”.108 108 - STUK, “The Radiation and Nuclear Safety Authority (STUK) ensures its operations”, 20 March 2020, see http://www.stuk.fi/web/en/-/the-radiation-and-nuclear-safety-authority-stuk-ensures-its-operations, accessed 28 July 2020.STUK did not provide any definition of sites “most significant for safety” and no details of the measures taken by the operators and the regulator itself. At Olkiluoto-3 (OL3), currently under construction, first fuel loading was planned for June 2020. This schedule has been postponed. As a consequence of further delays of the OL3 commissioning, due to technical reasons and the COVID-19 pandemic, the credit-rating agency Fitch revised owner TVO’s outlook to negative.109 109 - TVO, “TVO - Fitch Ratings confirmed TVO’s long term credit rating at its current level BBB- and changed the Outlook to Negative”, 20 April 2020, see https://www.tvo.fi/en/index/news/pressreleasesstockexchangereleases/2020/fitchratingsconfirmedtvoslongtermcreditratingatitscurrentlevelbbbandchangedtheoutlooktonegative.html, accessed 28 July 2020.At the same time, weaker electricity prices, partially due to the COVID-19 pandemic, impact TVO. The Average Nord Pool system price in the first quarter 2020 was €15.4/MWh (US$16.9/MWh) compared with €46.8/MWh (US$52.5/MWh) for the same period in 2019. France Infections There is no systematic sector-wide information available.110 110 - EDF and Orano have not replied to our questions. ASN and IRSN have communicated partial responses.At the Belleville nuclear power plant site, 29 COVID-19 cases had been confirmed as of the end of July 2020.111 111 - Gilles Reynaud, President of Ma Zône Controlée, personal communication, 30 July 2020.Worker representatives claim there are many more cases. On 20 March 2020, Reuters reported that EDF had “declined to comment about the level of absenteeism or the number of confirmed coronavirus infections among its staff” but had said that “its nuclear plants could operate for Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 74 three months with a 25% reduction in staffing levels and for two to three weeks with 40% fewer staff.”112 112 - Benjamin Mallet, “French nuclear plants tighten hygiene procedures over coronavirus worries”, Reuters, 20 March 2020, see https://www.reuters.com/article/us-health-coronavirus-france-nuclear-idUSKBN2172J1, accessed 28 July 2020. Mid-June 2020, EDF finally presented an overview of the numbers of infected staff, stating that, at the peak of the epidemic, the share did not exceed 2 percent. A total of almost 600 infections were identified over a 12-week period.113 113 - EDF, “Fonctionnement du Parc nucléaire durant la période d’urgence sanitaire Covid-19”, Presentation at the Plenary Meeting of HCTISN, Haut Comité pour la Transparence et l’Information sur la Sécurité Nucléaire, 16 June 2020 (in French), see https://www.hctisn.fr/article.php3?id_article=201, accessed 19 August 2020. On 29 April 2020, the Institute for Radiation Protection and Nuclear Safety (IRSN), which serves as the regulator’s Technical Support Organization (TSO), reported 59 active COVID-19 cases, all in the course of recovering.114 114 - Jean-Christophe Niel, Director General, IRSN, during a tele-video hearing at the National Assembly, 29 April 2020. In the middle of the hearing, Mr. Niel for over 2 minutes was unable to reconnect to the event, and the Assistant DG took the floor in the meantime. A lot of things can happen in a nuclear facility in 2 minutes.On 6 August 2020, regulator ASN reported that none of its staff had tested positive so far.115 115 - Marinette Valiergue, ASN spokesperson, personal communication, email to Mycle Schneider, 6 August 2020. Measures and Impacts The pandemic has had major impacts on France’s nuclear workforce. It was reported that of 22,500 employees of EDF’s Nuclear Generation Division 15,000 were put on telework.116 116 - Frédéric de Monicault, “Coronavirus: EDF fait tourner ses centrales avec moins de personnel présent”, Le Figaro, 7 April 2020. In late March 2020, after more than a dozen EDF workers walked off at least three reactor sites over COVID-19 concerns, France’s Nuclear Safety Authority (ASN) asked EDF to “ensure that health and safety conditions are communicated and set up correctly on the sites for all employees.”117 117 - NIW, “Nuclear Overseers Vary Response to Covid-19”, 5 June 2020, op. cit. According to ASN, various precautionary measures have been taken to deal with the COVID-19 crisis:118 118 - ASN, “In response to the Covid 19 epidemic, ASN is adapting its method of functioning while maintaining its rigour in the oversight of nuclear installations”, Information Notice, 27 March 2020, see http://www.french-nuclear-safety.fr/Information/News-releases/Covid-19-epidemic-ASN-is-adapting-its-method-of-functioning-while-maintaining-its-rigour, accessed 28 July 2020. A large number of nuclear installations whose functioning is not vital for the continued activity of the country, operated in particular by the French Alternative Energies and Atomic Energy Commission (CEA), Orano or the National Agency for the Management of Radioactive Waste (ANDRA), have been shut down and are maintained in safe state. Activities necessary for the functioning of the EDF nuclear power plants are nevertheless maintained. Examination work conducted by ASN in collaboration with its technical advisory body, the Institute for Radiological Protection and Nuclear Safety (IRSN), is continuing as normal. At the same time, on-site inspections are suspended, except when judged indispensable. On-site inspections are replaced by remote verifications, particularly concerning the examination of documents relating to day-to-day operation accompanied by audio-conferences with the licensee. Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 75 As part of the post-Fukushima safety improvements, EDF is updating its on-site emergency plans (Plan d’Urgence Interne or PUI) to include potential difficulties in gaining access to the sites, which could render full deployment of the local emergency response teams more complicated. ASN later stated that the crisis management has been taking “a lot of time” (reorganization of work mode, regulatory adjustments, reinforced oversight, etc). On-site inspections remain impossible for the foreseeable future for inspectors that have a high-risk profile if with COVID-19. Major interregional inspections have been cancelled or delayed.119 119 - Christophe Quintin, “Les inspections de l’ASN pendant la crise COVID-19”, Chief Inspector, ASN, Presentation at the HCTISN Plenary Meeting, Haut Comité pour la Transparence et l’Information sur la Sécurité Nucléaire, 16 June 2020 (in French), see https://www.hctisn.fr/IMG/pdf/Organisation_de_l_ASN_pendant_la_crise_COVID_cle8faa21.pdf, accessed 19 August 2020. By late March 2020, IRSN had limited “to the strict service necessities the mobility of its employees”. Non-essential research activities and environment surveillance had been suspended (no environmental sampling was carried out).120 120 - IRSN, “COVID-19 : l’IRSN continue à assurer ses missions”, 27 March 2020 (in French), see https://www.irsn.fr/FR/Actualites_presse/Actualites/Documents/IRSN_27032020_Mesures_Covid-19.pdf, accessed 16 August 2020. In the first week of the COVID-19 outbreak in France, EDF cut its staffing nuclear power plant sites by 70 percent, and even after the end of the lockdown in the middle of May 2020, staff reductions were at 50–60 percent on average. Mid-June 2020 was set as target date to get back to reference staffing levels.121 121 - EDF, “Fonctionnement du Parc nucléaire durant la période d’urgence sanitaire Covid-19”, Presentation at the Plenary Meeting of HCTISN, 16 June 2020, op.cit. Some staff cuts were more significant. At the Flamanville site, for example—Units 1 and 2 are in outage since January 2019 and September 2019 respectively with major maintenance, and Unit 3 under construction—EDF reduced its staff level from 800 to 100. Only people in charge of safety and security remained on-site.122 122 - Bate Felix, “France’s EDF to reduce Flamanville nuclear plant staffing over virus”, Reuters, 16 March 2020, see https://www.reuters.com/article/us-health-coronavirus-france-nuclear-idUSKBN21322Q, accessed 28 July 2020.At Unit 3, the EPR, “all construction activities have been temporarily interrupted between mid-March and early May”.123 123 - EDF, “2020 Half-Year Results”, Press Release, 30 July 2020, see https://www.edf.fr/sites/default/files/contrib/groupe-edf/espaces-dedies/espace-finance-en/financial-information/publications/financial-results/h1-2020/20200730-h1-2020-cp-en.pdf, accessed 19 August 2020.At the Chooz site—with one unit in operation and another one in decennial outage—EDF has reduced the number of workers on-site from 2,200 to 850. The documentation requested by the French regulator from operators has been reduced to a minimum. ASN’s Chief Inspector Christophe Quintin stated: “In general, we are requesting to see a great number of documents. Currently, we know that EDF’s teams work in a just-in-time mode. Therefore, we are going to the essential.”124 124 - Frédéric de Monicault, “Coronavirus: EDF fait tourner ses centrales avec moins de personnel présent”, Le Figaro, 7 April 2020.ASN’s President told the National Assembly at the end of April 2020: The resumption of the activities on-site, which will happen in a context of work overload because of the delays and in a disturbed context for the employees, with the accumulation of fatigue and stress, will have to be subjected to particular attention.125 125 - Bernard Doroszczuk, President, ASN, during a hearing at the National Assembly, 28 April 2020 (in French), see http://www.senat.fr/compte-rendu-commissions/20200427/atdd.html#toc2, accessed 19 August 2020.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 76 Mid-May 2020, ASN published a summary of activities during the lock-down period.126 126 - ASN, “ASN makes an assessment of its oversight since the beginning of lockdown”, 25 May 2020, see http://www.french-nuclear-safety.fr/Information/News-releases/ASN-makes-an-assessment-of-its-oversight-since-the-beginning-of-lockdown, accessed 28 July 2020.Between 15 March and 15 May 2020, “a total of 18 on-site inspections were carried out: twelve on safety and the possible consequences of the epidemic on the working of the facilities and six on labour inspectorate subjects”. As a matter of comparison, in 2019, ASN carried out 1,800 inspections or 150 per month on average. In other words, during lockdown, ASN carried out only 6 percent of normal average inspections. In the case of remote inspections, “ASN used new digital technologies, such as real-time and off-line remote-examination of the physical operating parameters of the reactors. Some of these innovations will be retained permanently.” According to ASN, “both remote and on-site inspections confirmed that Orano and EDF were able to implement appropriate organisations to deal with the health risk (barrier measures, prevention plans) while maintaining the required level of safety”.127 127 - Ibidem. Considering the dramatically reduced level of on-site inspection and the large number of delayed outages and maintenance operations that is a remarkable statement. The overall very positive reading of the French nuclear regulator clashes with the reporting of the sub-contractor organization Ma Zone Contrôlée that, in an open letter dated 12 July 2020 to the Minister for the Ecological Transition128 128 - Gilles Reynaud, President of Ma Zone Contrôlée, Letter to Barbara Pompili, Minister of Ecology, dated 12 July 2020, see http://www.ma-zone-controlee.com/lettre-ouverte-a-madame-la-ministre-b-pompili/, accessed 29 July 2020., in charge of nuclear oversight, claims that Until 27 April 2020, masks for contractors carrying out maintenance operations were not systematically available. “Numerous sub-contractor colleagues have experienced very humiliating and discriminatory situations, when, on certain sites, employees of the operators EDF/Orano had masks at the disposal to protect themselves against the virus but not us. Are we not equal?” Some contractors made use of their right to withdraw. All of them “were subjected to disgraceful pressures by their respective hierarchy, job blackmailing, disciplinary threats”. The remote surveillance carried out by ASN on strictly regulatory and administrative aspects “makes us fear the worst”. Several maintenance interventions were carried out without regulatory oversight under physical presence, as three-quarters of EDF staff were carrying out remote work. Following a COVID-19 outbreak at the Belleville site, the contractor organization requests comprehensive testing on all sites, as they “all become potential clusters”.129 129 - Ibidem. This is not the first time that Ma Zone Contrôlée has alerted the authorities. In a letter to ASN dated 22 March 2020, they reported “large numbers of degraded working conditions and increasing worries of employees”, including absence of hydroalcoholic gels and masks for sub-contractors, lack of systematic disinfection of exit radiation monitoring devices and dosimeters, impossibility to respect social distancing requirements in numerous places Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 77 (shuttle buses, locker rooms, cafeterias…).130 130 - Gilles Reynaud, Letter to the President of ASN, dated 22 March 2020.Three weeks later, the worker representatives sent a follow-up letter to ASN protesting against unequal treatment for sub-contractors compared to EDF/Orano staff now getting equipped with protective gear. While the entire country was in lock-down “hundreds of employees of sub-contractor companies returned at the request of client EDF in order to resume [work during] ongoing outages (Chooz, Civaux, Cattenom, Nogent, Dampierre).” The group, considering the “abundant feedback from the sites remains perplexed about the expected final good results of all ongoing interventions and their direct impacts on the level of safety and security”.131 131 - Gilles Reynaud, Letter to the President of ASN, dated 10 April 2020. A particular point raised by the workers is the absence of usual oversight during interventions as a large share of EDF staff, including oversight personnel, was on telework. Reportedly, there were cases where intermediate checks during maintenance interventions were made over the phone. An accident on 9 April 2020 during the replacement of a hydrogen rack at Belleville-1 leaving two workers injured and leading to a fire that “could have had catastrophic consequences” 132 132 - Ibidem.was clearly due to lack of oversight and “numerous deficiencies” of various types, as an ASN inspection revealed one week later.133 133 - In fact, the alternator presented a hydrogen leak detected in October 2019 but never repaired, which has led to the frequent need of storage tank replacement. ASN, Letter to the Director of the EDF Belleville Nuclear Power Plant, 23 April 2020 (in French), see https://www.asn.fr/content/download/170428/1748644/version/2/file/INSSN-OLS-2020-0702.pdf, accessed 31 July 2020. Some sub-contractor companies have refused to carry out certain work if the required conditions were not fulfilled. Workers from all parts of the country are hired for maintenance work and are often sharing housing with great contamination risks. They were not systematically tested. It is unclear whether this has changed as of the end of July 2020. The regulator constantly juggles between safety concerns and operational necessities. On 30 July 2020, ASN granted EDF a delay for the second time (after February 2019) for the installation of emergency diesel generators for five reactors (Cattenom-4, Flamanville-1 and -2, Paluel-1 and -2). The new deadline for the Paluel site is 28 February 2021, just short of the tenth anniversary of the beginning of the Fukushima disaster. The extra emergency power supply was a requested measure in response to the Japanese catastrophe. The La Hague spent fuel reprocessing plant was shut down for several weeks after employees executed their “right to withdraw” (droit de retrait), a legal right that allows them to refuse work under conditions they individually judge as dangerous. La Hague and fuel chain operator Orano experienced “severe disruptions in service activities” and “interruption of supply chain impacting CAPEX projects”.134 134 - Philippe Knoche and David Claverie, “2020 Half-year results”, Chief Executive Officer and Chief Financial Officer, Orano, 31 July 2020, see https://www.orano.group/en/finance/publications-and-regulated-information-credit-update, accessed 19 August 2020. Germany According to the Federal Ministry for Environment, Nature Conservation and Nuclear Safety (BMU), nuclear oversight has continued to the extent deemed necessary. German nuclear operators carry out pandemic plans, which were adapted to the COVID-19 pandemic. Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 78 These include enhanced hygiene measures, stricter access control to the facility to identify possible infected personnel and rearrangement of working procedures to reduce working contacts to the minimum necessary.135 135 - BMU, “Gewährleistung der nuklearen Sicherheit während der Corona-Krise - BMU-Meldung”, Bundesministerium für Umwelt, Naturschutz und Nukleare Sicherheit, 27 March 2020 (in German), see https://www.bmu.de/ME9001, accessed 31 July 2020. Until 2009, no clear regulation with respect to minimum workforce levels at nuclear facilities in Germany was in place. After an event in a German reactor, during which personnel from the control room had to perform duties in their secondary function in the fire-fighting brigade, the German Reactor Safety Commission (RSK) issued recommendations with respect to the determination of the minimum workforce needed for safe operation.136 136 - RSK, “Anforderungen an die Bestimmung der Mindestschichtbesetzung in Kernkraftwerken zur Gewährleistung einer sicheren Betriebsführung”, Reaktor-Sicherheitskommission, Recommendation of the Reactor Safety Commission, 417th Meeting, 18 June 2009 (in German), see www.rskonline.de/sites/default/files/reports/epanlagersk417hp.pdf, accessed 15 August 2020.According to these recommendations, not including security staff, a minimum number of eight people have to be available on site at all times, five of which are control room staff. The determination of the minimum workforce required must take into account all potential states of the plant, including severe accidents. A corresponding requirement to determine the minimum workforce are since 2012 also included in German safety requirements for nuclear power plants.137 137 - BfS, “Safety Requirements for Nuclear Power Plants”, Bundesamt für Strahlenschutz, Edition 03/15, 3 March 2015. Major outages for nuclear power plants were planned for April and May 2020. The German regulatory authority had forbidden the maintenance and refueling outage of the nuclear power plant Grohnde as originally planned. The shutdown and related activities would have necessitated about 1,000 additional staff beyond the 500 permanent employees for a period of two weeks at the plant site. The outage was then reorganized and took an additional three weeks, while restricting the necessary workforce to a maximum of 250. The reactor was reconnected to the grid on 24 May 2020. Systematic testing for COVID-19 was carried out and no contamination was identified.138 138 - Preussen Elektra, “Revision in Zeiten von Corona: Verlängerter Anlagenstillstand des Gemeinschaftskernkraftwerks Grohnde beendet“, 24 May 2020 (in German), see https://www.preussenelektra.de/de/unser-unternehmen/newsroom/pressemitteilungen/2020/verlaengerteranlagenstilllstandkwgbeendet.html, accessed 2 August 2020.It was expected that the schedule of planned outages at other plants would also change accordingly. Transports of highly radioactive wastes from the Sellafield reprocessing plant in the U.K., planned for the spring of this year, have been postponed, as the required corresponding police operation was not feasible.139 139 - BMU, “Gewährleistung der nuklearen Sicherheit während der Corona-Krise—BMU-Meldung”, 27 March 2020, op. cit. Hungary Measures In Hungary, the scope of planned 2020 outage activities have been reduced mainly due to travel restrictions of foreign vendor companies. Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 79 Japan Infections No systematic information is available. Three people, including one employee’s family member, were infected at TEPCO’s Kashiwazaki Kariwa plant, and two employees were contaminated at its headquarters, interrupting the safety upgrading work to resume.140 140 - TEPCO, “Implementation of additional measures to prevent the spread of the novel coronavirus infection”, Press Release, 27 April 2020 (in Japanese), see https://www.tepco.co.jp/kk-np/data/press/pdf/2020/2020042701p.pdf, accessed 15 May 2020.Kyushu Electric Power Company’s Genkai plant is constructing a facility for dealing with severe accidents. In April 2020, two workers were confirmed to be contaminated. Consequently, about 300 workers were instructed to remain on standby at home and construction was suspended.141 141 - Genkai Town, “Message from the Mayor”, 21 April 2020 (in Japanese), see http://www.town.genkai.lg.jp/site/korona/35850.html, accessed 15 May 2020. As of 1 July 2020, there were no reports about workers infected with COVID-19 within the Fukushima Daiichi Nuclear Power Plant.142 142 - TEPCO, “Covid-19 Countermeasures at the Fukushima Daiichi Nuclear Power Station”, 2 July 2020, see https://www.tepco.co.jp/en/hd/decommission/information/newsrelease/reference/pdf/2020/reference_20200702_01-e.pdf, accessed 21 July 2020.As countermeasures for contamination, workers are obliged to have their temperature taken and wear a mask, but officially no change has been made to the decommissioning plan.143 143 - Ibidem; and TEPCO, “Measures against the novel coronavirus at Fukushima Daiichi Nuclear Power Station”, 28 May 2020 (in Japanese), see https://www.tepco.co.jp/decommission/common/images/d200528_12-j.pdf, accessed 15 May 2020. The evacuation plan for nuclear accidents (nuclear disaster prevention guidelines) formulated after the Fukushima accident does not include measures against infectious diseases at evacuation centers. Therefore, the Cabinet Office decided to include infectious disease control measures in the guidelines in the future.144 144 - NHK, “Evacuation plan for nuclear accidents: Considering measures against infectious diseases”, 14 May 2020 (in Japanese) see https://www3.nhk.or.jp/news/html/20200514/k10012429081000.html, accessed 15 May 2020. Mexico Measures and Impacts The level of maintenance staff on shift was optimized to the level necessary to complete the minimum preventive and corrective maintenance activities. Netherlands Certain work scheduled for the country’s only nuclear reactor Borssele’s annual refueling and maintenance, which began on 29 May 2020, has been postponed until the next planned outage in 2021.145 145 - EPZ, “Nuclear power plant out of service for annual maintenance”, 14 April 2020, see https://epz.nl/actueel/kerncentrale-uit-bedrijf-voor-jaarlijks-onderhoud-1, accessed 10 June 2020.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 80 Romania Measures and Impacts In April 2020, the planned overhaul of Cernavoda-1 was delayed. This would have been done during a planned maintenance which is performed every two years, during May and June and usually lasts 30 days.146 146 - Serbia Energy News, “Romania: Maintenance of NPP Cernavoda’s unit 1 postponed”, 10 April 2020, see https://serbia-energy.eu/romania-maintenance-of-npp-cernavodas-unit-1-postponed/, accessed 18 May 2020.The outage has been delayed and started only 20 June 2020. The unit was reconnected to the grid 4 August 2020 after an extended outage.147 147 - SeeNews, “Romania’s Nuclearelectrica re-synchronizes Cernavoda NPP’s Unit 1 to grid”, 6 August 2020, see https://seenews.com/news/romanias-nuclearelectrica-re-synchronizes-cernavoda-npps-unit-1-to-grid-709048, accessed 26 August 2020. Russia Infections In a quite unique manner, Rosatom’s Director General Alexey Likhachev has been doing weekly video updates for months on numbers and locations of positive cases and recovered staff148 148 - NIW, “Nuclear Overseers Vary Response to Covid-19”, 5 June 2020.(see Figure 20)149 149 - Rosatom, “Обращение главы «Росатома» А.Е. Лихачёва (31 июля 2020)”, 31 July 2020 (in Russian), see https://www.atomic-energy.ru/video/105932, accessed 16 August 2020.. Cumulating active and recovered cases on the graphic illustration presented by Rosatom on 31 July 2020, the order of magnitude of total infections appears to be around 4,500, a very large number compared to any other reported COVID-19 incidence at a nuclear operator (e.g. about 600 at EDF). And while EDF has reported hardly any active cases as of middle of June 2020, Rosatom still accounted for around 1,200 ill people as of the end of July 2020. · Rosatom’s DG Presenting a Weekly Overview of COVID-19 Cases at Rosatom Source: Screenshot—Rosatom, “Обращение главы «Росатома» А.Е. Лихачёва (31 июля 2020)”, 31 July 2020 Note: Active (Red) and Recovered (Green) COVID-19 Cases at Rosatom as of 30 July 2020.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 81 In April 2020, Rosatom raised concerns about the spread of the virus in the three “nuclear cities” which host civil and military nuclear research. But no numbers were released.150 150 - Tom Balmforth, “Coronavirus threatens workforce in Russia’s nuclear cities - Rosatom”, Reuters, 28 April 2020, see https://www.reuters.com/article/health-coronavirus-russia-nuclear-idUSL5N2CG5CY, accessed 16 May 2020.On 1 April 2020, Rosatom announced that four of its employees tested positive for COVID-19 but did not specify the location.151 151 - Charles Digges, “Four nuclear workers test positive for coronavirus as Rosatom steps up pandemic response”, Bellona, 1 April 2020, see https://bellona.org/news/nuclear-issues/2020-04-some-russian-nuclear-workers-isolated-as-rosatom-steps-up-coronavirus-response, accessed 1 August 2020.Consequently, at the Beloyarsk site, after one worker’s wife fell ill, all employees were asked to move to special dispensaries and commute from there. Measures and Impacts On 26 March 2020, Rosatom issued a statement on its COVID-19 response: At present, we have introduced additional measures at all of Russia’s nuclear power plants, including regular health check-ups of our personnel. We have arranged for as many employees as possible to work remotely and purchased personal protective equipment and hygiene-related products in bulk; we are constantly disinfecting our production facilities and vehicles and have essentially cancelled all business trips. We are monitoring our employees’ health in close cooperation with local authorities across our areas of operation. We have developed a number of additional contingency plans for various scenarios of the coronavirus pandemic that may have an effect on the health of our NPP [nuclear power plant] employees.152 152 - Rosatom, “ROSATOM Director General Makes Statement on COVID-19 Situation”, 26 March 2020, see https://rosatom.ru/en/press-centre/news/rosatom-director-general-makes-statement-on-covid-19-situation/, accessed 1 August 2020. A few days later, Rosatom subsidiary Rosenergoatom announced that nuclear power plant staff would be isolated from the general public and required to live onsite at their respective stations.153 153 - Charles Digges, “Russia’s nuclear workers isolated onsite as coronavirus spreads”, Bellona, 3 April 2020, see https://bellona.org/news/nuclear-issues/2020-04-russias-nuclear-workers-isolated-onsite-as-coronavirus-spreads, accessed 1 August 2020.In addition: [Rosatom] has created a kind of ‘mirror-management’ system so that if one manager falls ill with the virus, or any other sickness for that matter, their ‘duplicate’ can step in and continue managing the project or operation.154 154 - NIW, “Nuclear Overseers Vary Response to Covid-19”, 5 June 2020, op. cit. However, apparently, central management leaves broader decisions about staff quarantines up to local authorities both in the Russian regions where Rosatom operates facilities as well as in other countries. On 6 April 2020, it pulled 178 of its employees from the Rooppur construction site in Bangladesh. Rosatom stated: “When our employees find themselves abroad in this difficult situation and want to return to their homeland, we will accommodate their needs.”155 155 - Rosatom, “ROSATOM arranged the return of 178 employees from construction site of Rooppur NPP (Bangladesh) to Russia”, 7 April 2020, see https://www.rosatom.ru/en/press-centre/news/rosatom-arranged-the-return-of-178-employees-from-construction-site-of-rooppur-npp-bangladesh-to-rus/, accessed 1 August 2020. As more than 4,000 people are working at the site, Rosatom assumes no impact on the planned schedule for the project because of the temporary relocation of its employees. It further cites enhanced health care measures to protect people at the construction site, like measuring employees’ temperatures, special disinfection of all office space and the issuing of masks to all employees.156 156 - Ibidem.But the withdrawal of such a large number of Russian staff, many of whom can Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 82 be presumed to be working at higher oversight responsibility levels, means that there could be questions about how safely construction is being carried out. Slovakia Fuel loading of Mochovce-3, under construction since 1985, has been further delayed. Just prior to the COVID-19 pandemic, it was expected at the beginning of the summer of 2020 with “in the worst case, it will be the end of 2020”.157 157 - Slovenske Elektrarne, “Mochovce 3: Nuclear authority issued a draft decision on fuel loading”, 18 February 2020, see https://www.seas.sk/article/mochovce-3-nuclear-authority-issued-a-draft-decision-on-fuel-loading/409, accessed 23 April 2020.However, this schedule will not hold, as due to social distancing measures the number of workers allowed on the site halved in March 2020., even if it was said that “the situation gradually stabilized in April and May”.158 158 - vEnergetike.sk, “Completion of Mochovce NPP may be delayed again”, Webnoviny.sk, 18 May 2020, see https://www.webnoviny.sk/venergetike/completion-of-mochovce-npp-may-be-delayed-again/, accessed 27 June 2020.The national regulator said in May 2020 that “it is impossible to estimate a precise delay for commissioning of the third nuclear unit.”159 159 - vEnergetike.sk, “Mochovce NPP will be delayed, UJD confirms”, 26 May 2020, see https://www.webnoviny.sk/venergetike/mochovce-npp-will-be-delayed-ujd-confirms/, accessed 9 June 2020. Slovenia Measures and Impacts The Krsko nuclear power plant is considered a critical energy infrastructure facility. Following the declaration of the COVID-19 pandemic, the operator reduced the activities to “providing only those functions that are necessary to ensure the safe and stable operation of the plant”.160 160 - Eurelectric, “Impact of COVID 19 on Customers and Society—Recommendations from the European Power sector”, Updated 31 March 2020, see https://cdn.eurelectric.org/media/4313/impact_of_covid_19_on_customers_and_society-2020-030-0216-01-e-h-E7E407BA.pdf, accessed 20 August 2020. South Korea Infections As of 1 July 2020, there were no reported cases of COVID-19 affected personnel working at South Korea’s nuclear power plants. Two employees, one working at the headquarters of the nuclear operator and one security guard, were infected, and there were no reported cases of transmission in nuclear power plants.161 161 - NSSC, “The NSSC Chairperson Visited Nuclear Power Plant to Check Response Against COVID-19”, Press Release, 26 May 2020, see https://www.nssc.go.kr/en/cms/FR_BBS_CON/BoardView.do?pageNo=1&pagePerCnt=10&MENU_ID=90&CONTENTS_NO=&SITE_NO=3&BOARD_SEQ=1&BBS_SEQ=45924&USER_NAME=&TEL_NO=&WRITER_DI=&_csrf=&SEARCH_FLD=&SEARCH, accessed 3 June 2020. Measures and Impacts Schedule and duration of at least one unspecified reactor outage was adjusted to ensure worker safety. Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 83 Measures at the Regulator Meetings of the Nuclear Safety and Security Commission (NSSC) have been held with limited face-to-face interactions since 10 April 2020 by minimizing the number of attendees, checking body temperatures, wearing masks and physically distancing (maintaining a distance of 2 meters) from each other. The head of the national regulator stated: “The NSSC will strictly comply with the hygiene rules suggested by the disease control authorities and try to ensure that safety regulations and nuclear power plant operation are normally conducted.”162 162 - NSSC, “Chairperson Uhm Had Virtual Meeting With Heads of Regulatory Agencies of Other Major Nuclear Countries to Discuss COVID-19 Responses”, Press Release, 7 May 2020, see https://www.nssc.go.kr/en/cms/FR_BBS_CON/BoardView.do?MENU_ID=90&CONTENTS_NO=&SITE_NO=3&BOARD_SEQ=1&BBS_SEQ=45920&P_BBS_SEQ=&CATE_SEQ=&pageNo=2&SEARCH_SEQ=&SEARCH_FLD=&SEARCH=&PREV_IDX=45922&NEXT_IDX=45920&MODULATE_KEY=%242a%2410%24UIapasTfrqWHlufhAJH5iuiIwluEWqGqiXSoLpT2RVPAz01O3DUn6&_csrf=, accessed 1 August 2020. Spain Measures and Impacts Trillo-1 was taken offline for a refueling outage while the operator limited the number of workers onsite, resulting in an outage extension to 35 days. “Low wholesale electricity prices in Spain mean the country’s fleet of seven power reactors is currently operating at a loss”, the Spanish Nuclear Forum said in a statement on 13 May 2020. The nuclear lobby group has urged a review of the fiscal regime under which the reactors operate.163 163 - Gianluca Baratti, “Spain’s power reactors failing to cover operating costs: Foro Nuclear”, Nucleonics Week, 21 May 2020. Market prices are depressed by the COVID-19 pandemic and are “failing to cover the operating costs of the Spanish nuclear plants, not even the amount they pay in taxes and levies which amount to €22/MWh (about US$24/MWh)”, Foro Nuclear President Ignacio Araluce said in the statement.164 164 - Ibidem. Sweden Infections The national regulator, the Swedish Radiation Safety Authority (SRSA), reported in June 2020, that it had “so far seen few COVID-19 cases at plant sites”. 165 165 - NIW, “Nuclear Overseers Vary Response to Covid-19”, 5 June 2020, op. cit.However, there are no precise numbers. Measures and Impacts Measures included isolating control room staff and essential personnel, relatively isolated sites and on-site housing for traveling workers during refueling outages.166 166 - Ibidem.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 84 United Arab Emirates Measures and Impacts Majority owner Emirates Nuclear Energy Corporation (ENEC) has introduced measures such as locking down the Barakah site with four units under construction167 167 - Barakah-1 went critical on 1 August 2020.and halting “non-essential” work in the wake of the pandemic.168 168 - WNN, “ENEC CEO: Barakah Plant to Start up ‘Very Soon’”, 7 May 2020, see https://world-nuclear-news.org/Articles/ENEC-CEO-Barakah-to-start-up-very-soon, accessed 14 May 2020.Additionally, ENEC’s Nawah company, the subsidiary responsible for Barakah’s operation and maintenance, issued guidelines to reduce the number of workers at the plant and enforce social distancing. Besides following strict quarantine and other preventative procedures at Barakah, UAE’s nuclear regulator, the Federal Authority for Nuclear Regulation (FANR) and ENEC have also established critical staff and functions to manage a potential second-wave of COVID-19.169 169 - NIW, “Nuclear Overseers Vary Response to Covid-19”, 5 June 2020, op. cit. Measures at the Regulator FANR established a COVID-19 crisis management taskforce, which called for measures such as asking employees to work remotely, leveraging digital means to conduct inspection and monitoring activities, and reducing the number of on-site inspectors.170 170 - Christer Viktorsson, “Viewpoint: Regulators are adapting to an unprecedented challenge”, WNN, 11 May 2020, see https://world-nuclear-news.org/Articles/Viewpoint-Regulators-adapt-to-an-unprecedented-cha, accessed 11 May 2020. United Kingdom Infections No comprehensive information is available. A Chinese national working at the Hinkley Point C construction site tested positive for COVID-19 in early March 2020. Four of his co-workers self-isolated but were later tested negative and have returned to work.171 171 - Global Construction Review, “Covid-19 hits UK’s Hinkley Point C nuclear project”, 6 March 2020, see http://www.globalconstructionreview.com/news/covid-19-hits-uks-hinkley-point-c-nuclear-project, accessed 2 August 2020.Mid-March 2020, a staff member of the Sellafield nuclear site had tested positive, followed by another employee with suspected COVID-19 a day or two later who had begun self-isolation. Within days, the number of Sellafield employees self-isolating climbed to about 1,000. The Sellafield complex has approximately 11,500 staff. In late March 2020, the operator decided to shut down the Magnox reprocessing plant at the site.172 172 - Jillian Ambrose, “Sellafield nuclear waste site to close due to coronavirus”, The Guardian, 18 March 2020, see https://www.theguardian.com/business/2020/mar/18/sellafield-nuclear-waste-plant-close-coronavirus-staff, accessed 2 August 2020.It only resumed full operation in the first week of August 2020.173 173 - Sellafield Ltd, “Green light to restart Magnox Reprocessing”, 3 August 2020, see https://www.gov.uk/government/news/green-light-to-restart-magnox-reprocessing, accessed 30 August 2020. EDF Energy mentioned in an 8 June 2020 statement the “tragic passing of one of our own employees from COVID-19 in April” at Hinkley Point B.174 174 - EDF Energy, “Letter to the Hinkley Site Stakeholder Group - 8 June 2020”, 8 June 2020, see https://www.edfenergy.com/media-centre/news-releases/letter-hinkley-site-stakeholder-group-8-june-2020, accessed 2 August 2020.In late July 2020, the entire plant Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 85 of a key concrete supplier for the construction at Hinkley Point C was closed after 22 of the 90 employees tested positive.175 175 - BBC, “Concrete plant closed after Covid-19 outbreak”, 27 July 2020, see https://www.bbc.com/news/uk-england-bristol-53555062, accessed 2 August 2020. Measures and Impacts According to the U.K. Office for Nuclear Regulation (ONR), “all sites have minimum staffing levels, and contingency plans should they fall below these levels, to enable them to remain in control of activities that could impact on nuclear safety under all foreseeable circumstances, including pandemic disease.”176 176 - ONR, “Coronavirus (COVID-19) - ONR Position [26/03/20]”, Office for Nuclear Regulation, 17 March 2020, Update issued 26 March 2020, see http://news.onr.org.uk/2020/03/coronavirus-covid-19-onr-position/, accessed 1 August 2020.In correspondence with independent experts, an ONR representative stated early March 2020 that “staff rotas [schedules] at nuclear sites are resilient to keep generation running in scenarios including pandemic or industrial action. If a generating site needed to be shut down for any reason, it would be shut down safely.”177 177 - David Lowry, “Corona-crisis Hits Nuclear Sector”, Energy Transition, 9 April 2020, see https://energytransition.org/2020/04/corona-crisis-hits-nuclear-sector/, accessed 2 September 2020. · Canteens at Hinkley Point C – Before and After Social Distancing Photos: Canteens at Hinkley Point C, before and after social distancing measures, both pictures are from late March 2020. A local paper quoted workers as saying: “They’ve done their best, but when anybody moves, they’re inevitably immediately within two metres of someone else.”178 178 - The West Country, “Social distancing fears in Hinkley Point C canteen despite EDF’s best efforts”, see https://www.thisisthewestcountry.co.uk/news/somerset_news/18330262.social-distancing-fears-hinkley-point-c-canteen-despite-edfs-best-efforts/, accessed 2 August 2020. In early June 2020, EDF Energy described measures applied by and by at their nuclear sites179 179 - EDF Energy operates all 15 U.K. nuclear reactors.including: Introducing remote working and split shift arrangements in a safe and controlled way, which has reduced the overall daily footfall on the site by over 50 percent; Determining the level of risk associated with vulnerable and high-risk employees and bringing in appropriate measures to support them; Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 86 Increasing hygiene and cleaning arrangements in high footfall areas and introducing social distancing measures across the site; The installation of thermographic cameras at the entrance and the purchase of COVID-19 immunity test kits.180 180 - EDF Energy, “Letter to the Hinkley Site Stakeholder Group - 8 June 2020”, June 2020, op. cit. However, unlike at home, in France, where EDF rescheduled a large number of outages, subsidiary EDF Energy went through with several refueling and maintenance outages, including at Hartlepool-2 and Heysham-2. Even after social distancing measures had been implemented, several environmental NGOs and Local Authorities were not convinced and, in a letter dated 30 March 2020, urged ONR “to exercise your powers and responsibilities to close operations at Hinkley Point C until such time as work can be safely resumed”.181 181 - NFLA, “NGO Forum Co Chairs and NFLA Secretariat issue letter over the ongoing construction work at Hinkley Point in Somerset”, Nuclear Free Local Authorities, 31 March 2020, see https://www.nuclearpolicy.info/news/ngo-forum-co-chairs-and-nfla-secretariat-issue-letter-ongoing-construction-work-hinkley-point/, accessed 2 August 2020.Only two days later, national television news (ITV) quoted a worker as saying: “At the moment I feel like the project is being put before my safety, my family’s safety and everybody on that site’s safety. You’ve still got people in vans - three and up - and all the toilets are rammed. There’s an account that I know of where someone’s been sent home with symptoms and the whole of their workforce - (the people) they work with and have had prolonged contact with - have been told not to isolate.” An EDF Energy spokesperson told ITV, it would be like everywhere else: “We’re actually learning as we go”.182 182 - ITV, “Continued concerns over conditions at Hinkley Point C amid coronavirus pandemic”, 1 April 2020, see https://www.itv.com/news/westcountry/2020-04-01/worker-at-hinkley-point-c-near-bridgwater-says-edf-is-putting-construction-project-ahead-of-staff-safety, accessed 2 August 2020.This sounds a bit different from the “all prepared” message that ONR has been putting out from the start. On 23 July 2020, EDF Energy issued an update to its COVID-19 measures at the Hinkley Point C construction site: That means that social distancing, the use of protective screens and extra cleaning continue on the site and in our canteens and buses. Workers will continue to have their temperature taken before entering the site. Face masks are mandatory on our external busses, as they are on public transport in the rest of the country. Bus services for workers are focused on our park and ride sites and we are no longer picking up workers in the community. We are looking to expand our testing capacity and aim to be able to test new starters for Coronavirus. We are not planning for a full return to offices for those that have been successfully working from home. This will help us maintain social distancing.183 183 - EDF Energy, “Coronavirus update from Hinkley Point C - 23 July”, 23 July 2020, see https://www.edfenergy.com/energy/nuclear-new-build-projects/hinkley-point-c/news-views/coronavirus-update-hinkley-point-c-july-23, accessed 2 August 2020. While the workforce at the Hinkley Point C site was cut to about 2,000 in March–April, by July 2020 levels were back at 4,500, almost pre-crisis levels. Measures at the Regulator While dealing with significant restrictions at the nuclear facilities and at their own organization, The Office for Nuclear Regulation (ONR) remained confident all along:Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 87 On 26 March 2020 A number of inspectors will continue to travel to sites where required, but we will carry out as much of our business as possible via phone, email and Skype. These measures will not have a severe impact on the effectiveness of our regulation of the nuclear industry.184 184 - ONR, “Coronavirus (COVID-19) – ONR Position [26/03/20]”, 17 March 2020, op. cit. On 25 June 2020 We remain satisfied with industry’s response at this time and there has been no significant change to dutyholders’ safety and security resilience. (…) ONR staff continue to work at home, primarily. We have considered our priorities, deferred non-critical activities, and are carrying out as much of our work as possible via videoconference, phone and email. We are inspecting, assessing and permissioning [?] remotely so far as is practicable, although we continue to go to site, as key workers, to conduct urgent and essential regulatory business, in accordance with public health measures.185 185 - ONR, “COVID-19 (coronavirus) – ONR Position”, 25 June 2020, see http://news.onr.org.uk/2020/06/covid-19-coronavirus-onr-position/, accessed 2 August 2020. United States Infections No systematic information on COVID-19 cases in the U.S. nuclear industry or its regulator is available, therefore WNISR only reports on a selection of documented examples. It appears that in a few cases, the outbreak was so large that it was impossible to avoid communication. DTE Energy’s Fermi-2 in Michigan, in the middle of a refueling outage with more than 2,000 workers on-site, reportedly may have had 200–300 positive COVID-19 cases in May 2020, which might have been the largest outbreak at any single place in Michigan. DTE has refused to disclose the number of positive cases among its workforce.186 186 - NIW, “Massive Covid-19 Outbreak at Fermi-2”, 15 May 2020.But DTE did confirm that large-scale testing had begun early May 2020 and by 11 May 2020 it had requested exemptions from work-hour controls (see hereunder). At the Limerick-1 plant in Pennsylvania, two workers tested positive in the days prior to a refueling and maintenance outage began on 27 March 2020, and three additional workers in the days after the outage started. Following these infections, an additional 44 of around 1,400 workers on-site were quarantined, with more than half of the quarantined personnel presenting symptoms of the virus.187 187 - Andrew Maykuth, “More Limerick Nuclear Plant Workers Test Positive for Coronavirus; Refueling to Continue”, The Philadelphia Inquirer, 8 April 2020, see https://www.inquirer.com/business/limerick-nuclear-plant-refueling-coronavirus-workers-infected-20200408.html, accessed 1 September 2020. On 1 April 2020, operator Exelon confirmed the first case at its Quad Cities plant. 188 188 - ANS, “Coronavirus makes its way into U.S. nuclear plants”, American Nuclear Society, 10 April 2020, see https://www.ans.org/news/article-85/coronavirus-makes-its-way-into-us-nuclear-plants/, accessed 27 July 2020.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 88 On 4 April 2020, a contractor working at the Susquehanna two-unit plant, in Berwick, Pennsylvania, prior to the Unit 1 spring refueling outage tested positive for COVID-19 and self-quarantined. Seven people who came into contact with the infected individual were also quarantined.189 189 - Ibidem. In early May 2020, ten workers at the Waterford nuclear power plant had tested positive for COVID-19. Some of the 750 workers that were brought in for the refueling outage told reporters they don’t think enough is being done to protect their health amid the pandemic.190 190 - News 8, “10 workers at Waterford nuclear power station site test positive for coronavirus”, wtnh.com, 5 May 2020, see https://www.wtnh.com/news/connecticut/new-london/10-workers-at-waterford-nuclear-power-station-site-test-positive-for-coronavirus/, accessed 27 July 2020. Another major outbreak was reported at the Vogtle construction site in Georgia. The first case was confirmed on 6 April 2020. On 15 April 2020 it was announced that a “lower productivity levels and a slower pace of completion prompted a 20% workforce reduction”.191 191 - NIW, “Covid-19 Cases Lead to 20% Workforce Reduction at Vogtle”, 1 May 2020.Nonetheless, three weeks after the first confirmed case, as of 28 April 2020, 153 workers had been tested positive for COVID-19.192 192 - News Channel 6, “Updated COVID-19 case numbers for Plant Vogtle”, WJBF, 29 April 2020, see https://www.wjbf.com/lifestyle/health/coronavirus/plant-vogtle-reports-first-positive-coronavirus-case/, accessed 2 July 2020.By mid-June 2020, more than 200 positive cases were reported.193 193 - NIW, “Vogtle Cost Up Another $1 Billion With 80% Component Failure Rate”, 12 June 2020.As of 2 September 2020, while the number of infections were reported to be declining, more than 800 workers on the project had been tested positive with over 100 active cases.194 194 - Matt Kempner, “Georgia nuclear project reports more than 800 COVID-19 cases to date”, The Atlanta Journal-Constitution, 1 September 2020, see https://www.ajc.com/ajcjobs/georgia-nuclear-project-reports-more-than-800-covid-19-cases-to-date/P4BXNDI5ONHX7BSPCPTJYZNWYE/, accessed 2 September 2020.On 10 July 2020, Tom Fanning, President and CEO of the builder’s parent company Southern tested positive.195 195 - ANS, “Southern CEO tests positive for COVID-19”, 14 July 2020, see https://www.ans.org/news/article-343/southern-ceo-tests-positive-for-covid19/, accessed 2 September 2020. The Millstone plant, in Connecticut, had a first confirmed case of COVID-19 prior to the beginning of its refueling outage in early April 2020, which drew 750 temporary workers onsite, sparking concern and criticism from Millstone employees towards insufficient measures put in place, including lack of personal protective equipment, cleaning and sanitizing.196 196 - Sten Spinella, “Millstone security employees criticize COVID-19 safety efforts”, The Day, 3 May 2020, see https://www.theday.com/article/20200503/NWS01/200509848, accessed 3 September 2020.In early May 2020, Dominion reported 10 employees had tested positive.197 197 - NIW, “The Widening Impact of COVID-19”, 8 May 2020.On 18 May 2020, it was revealed that 11 workers had tested positive, three of whom were control room operators.198 198 - Sten Spinella, “Millstone’s positive COVID-19 cases include control room operators”, The Day, 24 May 2020, see https://www.theday.com/business/20200524/millstones-positive-covid-19-cases-include-control-room-operators, accessed 3 September 2020. Measures and Impacts The industry lobby organization Nuclear Energy Institute (NEI) listed a number of measures taken, which have been quite typical for any nuclear country: Utilities are taking actions to limit the potential for infections, such as implementing teleworking where appropriate, practicing responsible social distancing both at work and Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 89 home, and screening personnel allowed on-site. Specific actions by each plant will vary based on the condition at that plant and its plant status. These actions may include, but are not limited to: F mechanisms to maintain awareness and communicate with staff; F telling workers who don’t feel well to stay home and encourage them to seek medical attention, liberalizing the sick-leave policy, developing or updating a policy on telecommuting; F setting up a screening point before people can enter the plant, to identify people who have symptoms; F making masks, hand sanitizer and gloves available within a plant to places where they will be needed; F focusing on extra disinfection of common areas; F using paperless work processes to reduce human contact and teleconferencing when possible.199 199 - NEI, “The Nuclear Industry’s Response to the Coronavirus (COVID-19)”, Nuclear Energy Institute, 1 April 2020, see https://www.nei.org/news/2020/nei-coronavirus-covid-19-response, accessed 27 July 2020. While nuclear operators have identified some tasks that can be done remotely or be postponed, some employees must still come to nuclear power plants on a daily basis because many computers are not connected to the internet (so-called airgap). This is a cybersecurity measure required in operations by the NRC in order to prevent hackers from accessing critical computer systems.200 200 - For an example of a cyber-attack on a nuclear power plant, see M.V. Ramana and Lauren J. Borja, “The Computer Infection of Kudankulam and its Implications”, The India Forum, 10 January 2020, see https://www.theindiaforum.in/article/computer-infection-kudankulam-and-its-implications, 10 January 2020. · Travel Trailers at the Cook Nuclear Plant—Just in Case Photo: Bill Downey, Cook Nuclear Plant, 2020 Based on pandemic plans established a decade ago, at least part of the nuclear plants have cots, blankets, chemical toilets and enough personal care items to sustain the operating crews at Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 90 a plant for several weeks should such measures be necessary.201 201 - Iulia Gheorghiu, “Coronavirus could disrupt normal refueling practices for nuclear facilities as staffing concerns grow”, Utility Dive, see https://www.utilitydive.com/news/coronavirus-could-disrupt-normal-refueling-practices-for-nuclear- facilities/574920/, 26 March 2020.Officials have suggested they might isolate critical technicians at the country’s nuclear power plants and ask them to live onsite to avoid exposure to the virus. In early April 2020, Cook Nuclear Plant staff prepared about 80 travel trailers available through employees on the parking lot of the site—just in case.202 202 - Alexandra Newman, “Cook Nuclear Plant ready if critical employees can’t go home”, The Herald Palladium, 3 April 2020, see https://www.heraldpalladium.com/news/cook-nuclear-plant-ready-if-critical-employees-cant-go-home/article_5af88489-29c1-5f8e-9666-035eff63bfbe.html, accessed 27 July 2020. In reality, the measures have gone deep into work management. Following the large COVID-19 outbreak at Fermi-2 (see above), on 11 May 2020, DTE submitted a letter to the NRC seeking significant exemptions from work-hour controls for staff, pledging that “these controls ensure that covered workers are subjected to the following minimum controls” 203 203 - Peter Dietrich, DTE, Letter to NRC, 11 May 2020.. Three days later, the NRC granted exactly what the industry had asked for: Individuals will work up to 16 work hours in any 24-hour period and up to 86 work hours in any 7-day period, excluding shift turnover; A minimum 10-hour break is provided between successive work periods; 12-hour shifts up to 14 consecutive days; A minimum of 6 days off are provided in any 30-day period; and Requirements have been established for behavioral observation and self-declaration during the period of the exemption.204 204 - NRC, Letter to Peter Dietrich, DTE, 14 May 2020, see https://www.nrc.gov/docs/ML2013/ML20133K055.pdf, accessed 27 July 2020. The Fermi-2 decision was not isolated. Between 3 April and 14 May 2020, the NRC granted similar exemptions, typically for two months, from work-hour controls for at least 14 reactors (Beaver Valley-1&2, Braidwood-1&2, Fermi-2, Ginna, Limerick-1&2, Palo Verde-1&2&3, Quad Cities-1&2, Seabrook-1).205 205 - Office of Nuclear Reactor Regulation, “COVID-19 Regulatory Activities for Nuclear Reactors—10 CFR Part 26 Work Hour Requirements”, U.S.NRC, Updated 27 May 2020, see https://www.nrc.gov/about-nrc/covid-19/reactors/part-26-work-hour-req.html, accessed 27 July 2020. These are major exemptions to standard rules for essential staff members in the following key workforce categories: operators, health physics and chemistry, fire brigade, maintenance and security. Challenges to safety and security through additional stress and fatigue are likely under those conditions. The NRC has developed an ad-hoc process to review work hour limits, because the existing regulations never considered a pandemic. Using existing exemption provisions, the NRC will approve requests with minimal initial review. Industry observers pointed out that this “suggests that a certain amount of guesswork—and subjectivity—will be involved in decision-Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 91 making, with outside observers and critics left mostly in the dark about how decisions are being made”.206 206 - NIW, “United States: NRC to Ease Regulatory Burdens During Pandemic”, 3 April 2020, see http://www.energyintel.com/pages/eig_article.aspx?DocId=1068608, accessed 28 July 2020. As Fermi-2 was shut down on 21 March 2020 and had not returned to service by 24 July 2020, the 4-month outage is one of the longest in the plant’s history, and the longest since a major fire left the plant seriously damaged in 1993.207 207 - The Blade, “Most work done, but will virus keep Fermi 2 offline much longer?”, 15 July 2020. Tennessee Valley Authority (TVA) has been scaling back some of its planned maintenance work at Watts Bar to limit the number of individuals on site and is performing health screenings of all TVA employees and contractors coming to the plants. Limerick-1 owner/operator Exelon presented the refueling outage as exemplary—and quite the opposite of the Fermi-2 case. Lasting from 27 March to 13 April 2020, it was completed in a plant-record 16 days, and no additional COVID-19 infections were reported during the outage. A contractor told media a different story. On 3 April 2020—in the middle of the outage—he claimed that social distancing was not in place: From the first day I got there, there were no less than 100 people in the training room being processed. I have pictures from that day of people literally sitting on top of each other, no one enforcing social distancing. There were computer labs for people to take the tests they need to get into the plant, people sitting at every computer elbow to elbow. So, I’ve been concerned since the minute I walked in there.208 208 - Pottstown Mercury, “Workers ‘terrified’ at Limerick nuclear plant amid coronavirus”, 5 April 2020, see https://www.pottsmerc.com/news/coronavirus/workers-terrified-at-limerick-nuclear-plant-amid-coronavirus/article_934efb34-76a4-11ea-afbe-17495d88f209.html, accessed 27 July 2020. Measures Taken at the Nuclear Regulator On 19 March 2020, the NRC changed its modus operandi in response to COVID-19 and updated its guidance for resident inspectors on 6 April 2020 “to protect the health of inspectors and site personnel, while maintaining oversight that supports reasonable assurance of adequate protection of public health and safety”209 209 - Christopher G. Miller, “Updated Implementation of Resident Inspector Site Coverage During COVID-19”, Director, Division of Reactor Oversight, Office of Nuclear Reactor Regulation, Memorandum to Ho K. Nieh, Director, Office of Nuclear Reactor Regulation, U.S.NRC, 6 April 2020, see https://www.nrc.gov/docs/ML2009/ML20097E538.pdf, accessed 28 July 2020.: Deferring of baseline inspections requiring onsite presence such as force-on-force and outage inspections. Use of remote means of event response for “uncomplicated plant trips/transients”. Practice of social distancing when on site and following site specific requirements for COVID-19. Remote access of operator information using all available technology (remote connectivity, personal computer, phone, email). Visiting each site “approximately once every three business days”.210 210 - Ibidem. Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 92 On 28 May 2020, the Director of the Office of Nuclear Reactor Regulation issued a new memorandum on “inspection guidance during transition from COVID-19 mandatory telework”.211 211 - Ho K. Nieh, “Inspection Guidance During Transition from COVID-19 Mandatory Telework”, Memorandum, Office of Nuclear Reactor Regulation, U.S.NRC, 28 May 2020, see https://www.nrc.gov/docs/ML2014/ML20141L766.pdf, accessed 2 September 2020.The guidance was “intended to balance the importance of protecting the health and safety of our inspectors and site personnel along with the need to conduct effective oversight that supports NRC’s critical safety mission”.212 212 - Ibidem.Many activities have been further delayed with the objective to have them completed within the year. Concerning force-on-force (FOF) security inspections the guidance states that “continued COVID restrictions may necessitate further delays”.213 213 - Ibidem.Early July 2020, nuclear industry representatives made it clear that they want the NRC not to resume but cancel all FOF inspections this year (about 20 reactor sites).214 214 - Edwin Lyman, Tweet, Union of Concerned Scientists, 9 July 2020, see https://twitter.com/NucSafetyUCS/status/1281216879714095104?s=20. The industry made the case that FOF “brings different challenges that lead to a higher possibility of cross-contamination of a critical group of employees”.215 215 - NRC, “Considerations surrounding security oversight for nuclear power plants in relation to the COVID-19 public health emergency”, Transcript of Public Meeting, Undated.An NRC representative stated that the Atomic Energy Act “specifically highlights that this is a performance-based inspection which cannot be accomplished through paperwork review or tabletop exercises”.216 216 - Ibidem. A letter signed by 86 organizations to Vice-President Michael R. Pence in late April 2020217 217 - Nuclear Information and Resource Service, Beyond Nuclear et al., “Letter from 86 Organizations to Vice President Michael R. Pence: Urgent Actions Required to Mitigate COVID-19 Impacts in Nuclear Energy Industry”, 22 April 2020, see https://www.nirs.org/wp-content/uploads/2020/04/Nuclear-COVID19-letter_WH-CoV-Task-Force_86-organizations.pdf, accessed 2 September 2020.asked for “urgent actions required to mitigate COVID-19 impacts in nuclear energy industry”. The organizations expressed their concern that the NRC “has abdicated its legal responsibility to protect public health and safety during the COVID-19 public health emergency, and to insist upon immediate corrective action”. The appeal, sponsored by the Nuclear Information and Resource Service (NIRS), and supported by a long list of well-known national NGOs including Union of Concerned Scientists (UCS), Sierra Club and Friends of the Earth points out: As the near disaster resulting from the deferred inspection at the Davis-Besse reactor in 2001-2218 218 - A large, pineapple-sized hole was discovered in the reactor vessel head leaving only the liner as barrier. It was later calculated that the hole would have widened to the point where the liner ruptured in another 2 to 11 months of operation. Because Davis-Besse ran 18 months between refueling outages, had the damage been missed during the 2002 outage, it seems likely that a large loss of coolant accident would have occurred. See Mycle Schneider, Georgui Kastchiev, Ed Lymann et al., “Residual Risk—An Account of Events in Nuclear Power Plants Since the Chernobyl Accident in 1986”, May 2007, see http://large.stanford.edu/courses/2013/ph240/bechstein1/docs/kastchiev.pdf, accessed 2 September 2020. showed, every single delayed/deferred safety inspection coupled with fatigued and ill workers clearly reduces the overall safety of the 96 [now 95] operating US nuclear power reactors. The organizations ask for a range of immediate measures including the establishment of an interagency COVID-19 Nuclear Task Force “to develop plans and protective measures for nuclear workers and reactor operations.” The NRC brushed off any criticism: “As we’ve said in several forums, the NRC’s authority covers radiological health, not infectious disease health,” NRC spokesperson Scott Burnell stated.219 219 - NIW, “Nuclear Overseers Vary Response to Covid-19”, 5 June 2020.Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 93 LONGER-TERM IMPLICATIONS As of mid-2020, the COVID-19 pandemic so far has not led to any interruptions of primary energy or electricity supply in monitored countries. The Council of European Energy Regulatory (CEER) proudly stated: No COVID-19 network congestion issues or problem with security of supply have been reported. The EU regulatory framework of liberalised energy markets regulated by independent regulators working for an integrated internal energy market has shown its resilience.220 220 - CEER, “Keeping the lights on saves lives – Energy sector and regulators guarantee energy supply during lockdown”, Council of European Energy Regulatory, PR-20-02, 14 April 2020, see https://www.ceer.eu/documents/104400/-/-/9ab3bcce-b191-4414-4e1b-97e6545c24fd, accessed 3 September 2020. Eurelectric, representing the European electricity industry, at the end of March 2020 published a useful country-by-country overview of impact on the sector and measures taken by Governments and companies.221 221 - Eurelectric, “Impact of COVID-19 on Customers and Society – Recommendations from the European Power Sector”, 31 March 2020, see https://cdn.eurelectric.org/media/4313/impact_of_covid_19_on_customers_and_society-2020-030-0216-01-e-h-E7E407BA.pdf, accessed 2 September 2020.In general, most of the countries have experienced significantly declining power consumption and lower prices. According to one estimate, the five Western European countries France, Germany, Italy, Spain and United Kingdom averaged a drop of 8 percent in power demand over the first half-year 2020, ranging from –9 percent in Germany to –15 percent in France. The analysts expect demand remaining –4 to –8 percent (–10 percent in the U.K.) below 2019 levels222 222 - Andreas Franke and Jonathan Fox, “EU5 Q2 power demand down 12% on year at 367 TWh”, S&P Global Platts Analytics, 2 July 2020, see https://www.spglobal.com/platts/en/market-insights/latest-news/electric-power/070220-eu5-power-demand-for-q2-down-12-on-year-at-367-twh, accessed 2 September 2020.Power prices plunged to around €20/MWh in the EU as a whole. The longer-term impact of low consumption and low prices on the finances of the electricity utilities will be significant. In France, massive outage rescheduling at the 56 nuclear reactors looks likely to extend into the high-consumption winter months 2020-21, and the country will probably need to rely on much more expensive power from other suppliers including from other countries. Operator EDF plans to shorten the duration of refueling and maintenance outages by up to 2.5 months at 23 reactors to ease some of the effect.223 223 - Sophie Tetrel, “EDF shortens planned outages at 23 reactors”, Montel, 3 July 2020.Considering the operator’s incapacity to respect its outage schedules over the past years (see France Focus), it will be interesting to see how EDF will perform. Credit-rating agencies were quick to act. On 24 April 2020, Fitch revised EDF’s outlook to negative from stable, reflecting “production cuts due to the pandemic” as a key rating driver.224 224 - Fitch, “Fitch Revises EDF’s Outlook to Negative; Affirms IDR at ‘A–’”, 22 April 2020, see https://www.fitchratings.com/research/corporate-finance/fitch-revises-edf-outlook-to-negative-affirms-idr-at-a-22-04-2020, accessed 2 September 2020.Two days later, Moody’s did the same, arguing reduced output projections in particular “as a result of confinement and staff protection measures”.225 225 - Moody’s, “Rating Action: “Moody’s changes aoutlook on EDF to negative, affirms ratings”, 24 April 2020, see https://www.moodys.com/research/Moodys-changes-outlook-on-EDF-Trading-to-negative-affirms-rating--PR_423223, accessed 3 September 2020.Standard & Poor’s went further and Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 94 on 22 June 2020 downgraded EDF by one notch from A– to BBB+ stating that “the prolonged lower nuclear availability reflects greater operational weakness, which will contribute to a significant decline in profitability”.226 226 - S&P, “French Utility EDF Downgraded To ‘BBB+’ On Prolonged Operational Weakness, Lower Output Due To COVID-19; Outlook Stable”, 22 June 2020. The lower ratings will make the service of the company’s debt more expensive. As of mid-2020, EDF’s net debt had grown to €42 billion (US$47.5 billion). It lost about €1 billion (US$1.1 billion) to the COVID-19 circumstances and its profit plunged by 56 percent. EDF warned that the construction interruption at the Flamanville EPR “could result in further delays and additional costs”.227 227 - EDF, “2020 Half-Year Results”, Press Release, 30 July 2020, see https://www.edf.fr/sites/default/files/contrib/groupe-edf/espaces-dedies/espace-finance-en/financial-information/publications/financial-results/h1-2020/20200730-h1-2020-cp-en.pdf, accessed 2 September 2020. In Japan, the reduction in electricity generation from nuclear power in 2020 due to extended shutdowns coincides with a significant decline in demand and wholesale prices due to the COVID-19 pandemic.228 228 - Aaron Sheldrick, “Japan power prices hit zero as coronavirus hammers industrial activity”, Reuters, 13 May 2020, see https://www.reuters.com/article/us-health-coronavirus-japan-electricity/japan-power-prices-hit-zero-as-coronavirus-hammers-industrial-activity-idUSKBN22P0PA, accessed 19 May 2020.As reported by Reuters, day-ahead prices on the Japan Electric Power Exchange (JEPX) dropped as low as ¥0.01 (US$c0.01) per kilowatt hour (kWh)—virtually free power— in February 2020. The impact on the finances of the nuclear utilities could be substantial. CONCLUSION ON NUCLEAR POWER IN THE AGE OF COVID-19 There is no comprehensive information available for any nuclear country concerning identified cases of COVID-19 in the workforce of companies operating nuclear facilities and their supply chain. Some nuclear operators—like EDF in France—have explicitly refused to publish any data. There is no more information available on the situation at the national nuclear regulators and their technical support organizations. It remains entirely unclear to what extent and under what rules staff are being tested or not for COVID-19, and thus it remains uncertain how comprehensive the current knowledge of the impact of the pandemic in the nuclear sector actually is. Operators and regulators have implemented widespread measures including telework and social distancing. In some cases, regulators stopped physical inspections almost entirely, and carried out site visits only in urgent cases like incidents relevant to safety or security. Remote work raises cyber-security issues and has its limitations. Most of the computers in nuclear facilities and at regulators are not connected to the internet and do not have any outside connection at all (airgap) in order to lower the possibility of hackers entering sensitive information systems or control functions. There is no doubt that the quality of oversight of operators of their subcontractors has been seriously impacted, as witnessed by numerous workers. Many outages have been delayed or Wo r l d N u c l e a r I n d u s t r y Status Report | 202 0 | 95 shortened, which means certain periodical exams and maintenance operations have not been carried out as scheduled. While it is difficult to assess the degree, it is obvious that the cumulation of these circumstances leads to a shrinking of safety and security margins. It is very surprising under these conditions to see the respective national regulators assuring the public that everything is under control.

3 comments:

  1. David as a campaigner against Bradwell B I am really interested in what you have to say here, unfortunately the lack of spacing makes the text extremely difficult to read. Is there anyway that your blog can be formatted to provide paragraph spaces and to easily separate out for identification, your comments as opposed to the statements from ONR. With appreciation, Linda Gemmill - Team facilitator BAN

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  2. I agree, David. Please do your readers some favours, and also make links clickable.

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