The document discusses appeals against the decision to extend the operation of nuclear reactors 5 and 6 at the Kozloduy Nuclear Power Plant in Bulgaria without an environmental impact assessment. Specifically: 1) Appeals argued the decision violated several laws and regulations regarding environmental assessments and public participation. It also lacked thorough safety assessments and analysis of potential transboundary impacts to Romania. 2) Letters from the Romanian Ministry of Environment raising concerns about transboundary impacts were hidden from the Bulgarian Ministry of Environment and Waters. 3) The public hearing process was misleading and did not meet legal requirements for public participation. The municipality also did not receive requested information about extension plans.

1. The lifetime extensions
of nuclear units in Bulgaria
Units 5 and 6 at “Kozloduy” NPP
Petar Kardjilov, PhD
The Greens, Bulgaria – TBC
PUBLIC PARTICATION IN THE NUCLEAR SECTOR:
THE ESPOO AND AARHUS CONVENTIONS
30 March 2017, European Parliament

2. MEW Decision
• July 25, 2014
Minister of Environment and Waters retired
Stanislav Atanasov signed on decision that there is
no need to assess the environmental impact of
investment project "Extension of operation of the
fifth and sixth units at NPP "Kozloduy" because it "is
not likely to have a significant negative impact on
natural habitats, populations and habitats of
species subject to conservation in protected areas."

3. Appeal /1/
Non-compliance and violation of the Law on
Environmental Protection, the Regulation on
conditions and procedures for assessing the
environmental impact, the Regulation on conditions
and procedures for assessing the compatibility of
plans, programs, projects and investment proposals
with the object and purpose conservation of
protected areas and the Regulation on ensuring the
safety of spent nuclear fuel.

4. Appeal /2/
There have not been clarified in full and are not
subject to discuss a number of issues essential for
the preservation of the environment for present
and future generations and the protection of
human health, preventing and reducing pollution,
biodiversity conservation, transboundary effects
and so on. The decision was issued in
considerable violations of the administrative
procedure rules, which requires its cancellation
and return of the administrative file for
reconsideration.

5. Appeal /3/
The Decision lacks a reference to the detailed
analysis of the Radiological impact on Republic of
Romania to assume that as a result of the IP can
not be expected transboundary impacts. It is not
reported that the Danube passes through other
public areas to discuss possible radiation
pollution in other European countries.
Later during the lawsuit two letters from the
Ministry of Environment and Forests of Romania
were hidden from MEW and neglected by SAC.

6. Appeal /4/
The Decision does not includes a depth
comparative analysis of the location and
characteristics of the IP and they are superficially
assessed. The Decision also lacks complete and
thorough safety assessment facility for
radioactive waste management in accordance
with OSMRW, which requires analysis of the
ability of the facility to perform its safety
functions not only during normal operation but
also in the event of any anticipated conditions
and events incl. in case of emergencies and
disasters.

7. Appeal Conclusion
 The issuer of the relevant act, staying only one month
as a body - minister of environment and waters,
misapplied art. 14, para. 3 pt. 2 of the Regulation on
conditions and procedures for assessing the
environmental impact.
Тhe competent authority has not committed a reasoned
and thorough research on the completeness and accuracy
of the included decision information, as well as the
objectivity of its findings meet the regulatory criteria of
the assignor, and obediently copied and pasted them as
provided by the assignor.

8. Public (mis)hearing?
 NPP “Kozloduy”mislead the court by submitting to MEW a
print screen of Kozloduy-bg.info, which reported that the
municipality will host a discussion on Units 5&6, and that
such discussions are usually present environmentalists as
Petar Penchev and Ivan Ivanov and even published their
photos. But the information on this site is not for a meeting
with the public. And it doesn’t perform the requirements of
the procedure under the Ordinance. By brush and paint is
fabricated an entire section of the intended procedure
instead perform real access to public information.
 Kozloduy Municipality has not received repeatedly
requested information concerning the extension of the two
reactors, and the program for further activity of the NPP,
for example by letter №73.00-37 / 05.06.14

9. Letters from Romania
requirements

10. Increasing design capacity up to 104%

11. Lawsuits Timeline