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ECCSSafe – Exploring the contribution of
civil society to safety
Deliverable 2:
Case studies and transversal analysis
25th
May 2016
Authors:
Stéphane Baudé (Mutadis, France)
Gilles Hériard Dubreuil (Mutadis, France)
Drago Kos (University of Ljubljana, Slovenia)
Nadja Železnik (Regional Environmental Center for Central and Eastern Europe – Slovenia
Country office)
Mateja Šepec Jeršič (Regional Environmental Center for Central and Eastern Europe –
Slovenia Country office)
Attila Antal (EnergiaKlub, Hungary)

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Table of contents
1. Introduction........................................................................................................................5
2. Method and choice of the case studies.............................................................................7
3. The engagement of the Local Information Commissions attached to nuclear sites in the
decennial safety reviews of the reactors of Fessenheim nuclear power plant (France) ..........9
3.1. Introduction.................................................................................................................9
3.2. Method........................................................................................................................9
3.3. Context of the case study .........................................................................................10
The Local Information Commissions in France...............................................................10
The strategy for openness to society of the Institute for Radiation Protection and Nuclear
Safety (IRSN)..................................................................................................................10
3.4. Presentation of the case study .................................................................................12
The 3rd
decennial review of nuclear reactors: a convergence between 2 process of
engagement of civil society at the national and at the local level ...................................12
Engagement of the CLS of Fessenheim and GSIEN in decennial safety reviews..........12
A national process from 2009 to facilitate the engagement of the CLIs and the ANCCLI
in the decennial safety reviews of French nuclear reactors ............................................18
3.5. Analysis of the case study ........................................................................................21
Understanding of safety and safety culture.....................................................................21
Definition of safety as a public affair ...............................................................................23
Governance ....................................................................................................................23
Controversies and co-framing.........................................................................................24
Trust................................................................................................................................24
4. The hazardous waste incinerator of Dorog (Hungary) ....................................................25
4.1. Introduction...............................................................................................................25
4.2. Method......................................................................................................................25
4.3. Brief History of the Incinerator of Dorog and its Problems........................................26
The Importance of Dorog and considerations for the analysis........................................26
The birth of the Incinerator..............................................................................................27
Safety Problems at the Facility .......................................................................................27
4.4. The Role of the Local Participation...........................................................................29
Why Should the Public Participate?................................................................................30
Tools and Strategies used by the NGO ..........................................................................30
4.5. Civil Contribution to Safety – Experiences of the Interviewees ................................32
Two Strategies: from Civil Activism to Negotiations........................................................32
The NGOs and expertise ................................................................................................32
Trust between Individuals ...............................................................................................33
The Role of Communication and Motivation ...................................................................33

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The Local Government as a Mediator.............................................................................33
Strengthening the cooperation between the local and national NGOs ...........................34
The nature of trust...........................................................................................................34
Main investments concerning environmental protection at the incinerator .....................34
4.6. References for the case study..................................................................................35
5. The local partnerships for site selection for a low and intermediate level radioactive
waste in Slovenia ...................................................................................................................36
5.1. Introduction...............................................................................................................36
5.2. Method......................................................................................................................36
5.3. The local partnership approach in Slovenia .............................................................38
Introduction .....................................................................................................................38
The LP concept in Slovenia ............................................................................................38
Financing ........................................................................................................................39
The implementation of LPs .............................................................................................40
SWOT assessment of LPs..............................................................................................43
A summary of Slovene local partnerships.......................................................................46
5.4. Summary of the answers from invited stakeholders.................................................48
Understanding of safety and safety culture in the case of Local Partnership .................48
Definition of safety as a public affair and definition of the “public” associated to safety .51
Governance of hazardous activities and safety governance ..........................................54
Controversies and co-framing of safety issues with stakeholders ..................................56
Trust................................................................................................................................58
5.5. Analysis of the outcomes of the interviews...............................................................60
Understanding of safety and safety culture in the case of Local Partnership .................60
Definition of safety as a public affair and definition of the “public” associated to safety .62
Governance of hazardous activities and safety governance ..........................................62
Controversies and co-framing of safety issues with stakeholders ..................................63
Trust................................................................................................................................63
5.6. Conclusions and recommendations..........................................................................64
5.7. References for the case study..................................................................................66
6. Transversal analysis of the case studies.........................................................................67
6.1. Introduction...............................................................................................................67
6.2. Understanding of safety and safety culture and identification of the contribution of
civil society to safety.................................................................................................67
6.3. Definition of safety as a public affair and definition of the “public” associated to
safety........................................................................................................................71
6.4. Governance of hazardous activities and safety governance ....................................73
6.5. Controversies and co-framing of safety issues with stakeholders............................73

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6.6. Trust..........................................................................................................................74
7. Conclusion.......................................................................................................................75
Annex 1 – Grid of analysis of the case studies ......................................................................76
Annex 2 – Convention governing access of the GSIEN to information for the 3rd
decennial
safety review of Fessenheim 1 reactor ..................................................................................78

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1. Introduction
From the 1990’s to now, the European context has been marked by the emergence and the
reinforcement of reflections and research on the contribution of civil society to the quality of
decisions concerning hazardous activities in risk governance studies (cf. TRUSTNET
European research projects series, the works of O. Renn, the works of the International Risk
Governance Council). It has also been marked by the development of various legal,
institutional and regulatory arrangements aiming to organise participation of civil society and
local stakeholders in decision-making concerning hazardous activities.
The interactions between civil society and local actors on the one hand and institutional
actors engaged in safety1
of industrial activities on the other hand are most often addressed
either through the general issue of stakeholder involvement, perception studies, risk
governance studies or through the more general issue of the exercise of democracy
regarding technical issues. Social and human aspects of industrial safety are addressed
through the analysis of human and organisation factors of safety that are focused either on
the analysis of single organisations (e.g. operators2
) and their safety culture or address a
safety system where safety is the result of the actions and interactions of operators,
regulators and experts.
We can currently observe that some regulators and technical support organisations, in
particular in the nuclear field (e.g. IRSN in France, SITEX network in Europe), are developing
new approaches where civil society is incorporated in the safety system as an additional
layer contributing to safety, moving from a 3-pillar safety approach (operators, regulators,
experts) to a 4-pillar conception including civil society.
In the same time, international organisations dealing with safety, in particular in the nuclear
field, are evolving from a vision of engagement of civil society purely focused on the issue of
acceptation of technological choices to an acknowledgement of a positive contribution of civil
society to safety culture and to safety itself3
.
In the field of radioactive waste management, the COWAM (Community waste Management)
European research project series4
have emphasised the contribution of civil society to safety
culture. In the nuclear field, empirical studies5
have also started to emphasise the role of civil
society as a contributor to safety. However, this renewed role of civil society as regards
safety has not yet been investigated from a theoretical point of view.
In this context, the ECCSSafe (Exploring Civil Society Contribution to Safety) research
project6
aims to further explore the contribution of civil society to industrial safety by providing
a theoretical framework for the analysis of this contribution, analysing 3 concrete cases in the
1
The concept of industrial safety is defined as the set of technical provisions, human means and
organisational measures internal and external to industrial facilities, destined to prevent accidents and
malevolent acts and mitigate their consequences.
2
In this document, the word “operator” refers to the whole organisation that operates a hazardous
facility (e.g. the electricity company operating a power plant).
3
See notably the report of the IAEA International nuclear safety group “INSAG-20: Stakeholder
Involvement in Nuclear Issues” (2006), which states that the “involvement of stakeholders in nuclear
issues can provide a substantial improvement in safety.
4
See the final reports of the European research projects COWAM, COWAM 2 and COWAM in
Practice available on the COWAM website www.cowam.com
5
See P. Richardson, P. Rickwood, Public Involvement as a Tool to Enhance Nuclear Safety,
International Atomic Energy Agency (IAEA), Vienna, 2012. The study notably concludes that “there
are tangible benefits to be gained from a more frank relationship between the nuclear power industry
and the public, … [which] appears to represent a possible untapped asset for enhancing and
maintaining safety.
6
ECCSSafe is supported by the French Foundation for a Culture of Industrial Safety (Foncsi)

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nuclear field and in other industrial fields in Europe and identifying key issues to address in
further research and proposing guidelines for a larger scale research.
At first, a theoretical and methodological framework7
has been developed in order to set up
the conceptual framework and methodology for choosing and carrying out the case studies.
This document notably included interview guidelines for the interviews, a grid of analysis for
the case studies and criteria for selecting the cases
The present documents presents the 3 case studies:
• The engagement of the Local Information Commissions attached to nuclear sites in the
decennial safety reviews of the reactors of Fessenheim nuclear power plant (France)
• The hazardous waste incinerator of Dorog (Hungary)
• The local partnerships for site selection for a low and intermediate level radioactive waste
in Slovenia
It then proposes a transversal analysis of the 3 case studies along the grid of analysis
developed in the theoretical and methodological framework (see grid of analysis in Annex 1).
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cf. ECCSSafe deliverable 1: Theoretical and methodological framework

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2. Method and choice of the case studies
These three case studies have been selected out of 8 pre-identified case studies, including 4
cases in the nuclear field and 4 cases in other fields of activity8
(the 3 selected case studies
are in italics):
• Case studies in the nuclear field:
o The engagement of the Local Information Commissions attached to nuclear
sites in the decennial safety reviews of the reactors of Fessenheim nuclear
power plant (France)
o The local partnerships for site selection for a low and intermediate level
radioactive waste in Slovenia
o Civil society and local actors engagement on the safety of the Asse II mine
(used as a radioactive waste storage) in Germany through a citizen advisory
group coupled to an expert group
o Contribution of civil society organisations to the re-assessment of copper
canisters quality in the radioactive waste programme of SKB in Sweden
• Case studies in other fields of activity:
o The hazardous waste incinerator of Dorog (Hungary)
o The break of the barrier at the Aika bauxite mine near Kolontár, Hungary
o The role of the Local Information and Dialogue Committees (Comité Locaux
d’Information et de Concertation - CLIC) in the development of Plans for
Prevention of Technological Hazards (Plans de Prévention des Risques
Technologiques – PPRT) in France
o Management of risks of hydro power plant dam destruction at the
hydroelectrical power station Golica in Austria (on border with Slovenia) on
the Bistrica River
The 3 case studies fully developed in this report have been chosen on the basis of the
following criteria:
• Importance of safety among the addressed issues: safety issues should play a
significant role in the considered process of interaction with civil society.
• Availability of information on how engagement of civil society contributed to safety
• Variety of stakeholders engaged in the considered case and availability of a diversity
of stakeholders to be interviewed
• Participation options and organisation: how participation process was organised, was
it formal, the extent (only public hearings, or more intensive role in the process), or
informal pressures groups by civil society?
• Participatory influence: how the proposals and comments were addressed and taken
into account, how the decisions were changed?
• Extent of safety discussion
The three selected case studies all present a developed safety dimension and a possibility to
have access to different stakeholders, both from civil society organisations, from regulators
and from other involved actors (experts and technical support organisations, industrial
organisations, local actors, …).
The method used to develop the case studies has involved collection of written information
(reports, minutes of meetings, websites, …) and desk work as well as interviews with a
variety of stakeholders engaged in the cases. The analysis of the case studies (and the
8
a short description of the 8 cases is available in ECCSSafe deliverable 1.

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process of information collection beforehand) has been carried out according to the grid of
analysis previously developed in ECCSSafe9
, which focuses on the following themes:
• Understanding of safety and safety culture
• Definition of safety as a public affair and definition of the “public” associated to safety
• Governance of hazardous activities and safety governance
• Controversies and co-framing of safety issues with stakeholders
• Trust
9
The complete grid of analysis and the interview guidelines are available in ECCSSafe deliverable
1: Theoretical and methodological framework.

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3. The engagement of the Local Information Commissions attached
to nuclear sites in the decennial safety reviews of the reactors of
Fessenheim nuclear power plant (France)
3.1. Introduction
This case study deals with the engagement of civil society actors in the three successive
decennial safety reviews of the reactors of the French nuclear power plant of Fessenheim. It
describes and analyses how hybrid local dialogue organisations, the Local Information
Commissions (Commissions Locales d’Information – CLI), gathering local elected
representatives, local civil society organisations, representatives of the workers of the power
plant and qualified personalities, commissioned external expert assessment of the decennial
safety reviews of Fessenheim power plant. It also describes how this local process is
embedded in a broader process of opening of the governance of nuclear activities to civil
society in the French context from the beginning of the 1980’s to the beginning of 2010’s
(with strong evolutions in the decade of the 2000’s).
After a description of the method of the case study, we will describe the institutional context
related to the engagement of civil society in nuclear activities and its evolutions. We will then
describe the process of engagement of the Local information commission of Fessenheim in
the three successive decennial safety reviews of reactors of the Fessenheim nuclear power
plant from 1989 to 2012. We will then describe the national process led by the Nuclear
Safety Authority (Autorité de Sûreté Nucléaire – ASN) and the Institute for Radiation
Protection and Nuclear Safety (Institut de Radioprotection et de Sûreté Nucléaire – IRSN)
from 2009 to facilitate the engagement of the engagement of the CLIs in the decennial safety
reviews of nuclear reactors. Finally, the case study will be analysed according to the
common grid of analysis developed earlier in the framework of ECCSSafe.
3.2. Method
This case study was developed on the basis of
• Desk research based on written documentation available about the considered
process (reports, guidelines, laws and regulations, websites of the local information
commission of Fessenheim, of the ASN and the IRSN, …)
• Interviews of actors or representatives of institutions having played a key role in the
considered processes. These interviews were carried out in a semi-directive way,
based on the grid of interviews previously developed in the framework of the project.
The interviews were carried out in conditions of confidentiality: the outcomes of the
interviews are presented as an integrated analysis, without revealing the content of
the individual interviews.
The people interviewed were the following:
• Monique Sené, member of the GSIEN and member of the Scientific Committee of the
National Association of Local Information Commissions and Committees (ANCCLI)
• Ludivine Gili, Nuclear Safety Authority (ASN)
• Franck Bigot, Deputy Director of the Division for nuclear safety expertise, Radiation
Protection and Nuclear Safety Institute (IRSN)
• René Junker, Member of the Local Information Commission of Fessenheim
• Sophie Letournel, Head of the ASN Division of Strasbourg (competent for the
Fessenheim power plant)
It has not been possible to interview a representative of EDF, the operator of the Fessenheim
power plant.
The collected information has then been analysed according to the grid of analysis previously

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developed in the framework of the project.
3.3. Context of the case study
The Local Information Commissions in France
In France, Local Information Commissions (Commissions Locales d’Information – CLI) are
attached to most nuclear sites. These committees are pluralistic dialogue forums gathering
various types of local actors (elected representatives, social and economic actors,
environmental NGOs, and qualified personalities) in order to facilitate dialogue of local actors
with public authorities and operators. The CLIs have a general mission of follow-up of the
activity of nuclear facilities, local dialogue on safety, radiation protection and impact of
nuclear activities on people and the environment, and of information of the public on these
issues. The IRSN, the ASN and the organisation operating the nuclear facility are regularly
invited to the meetings of the CLIs but are not members.
The first CLI was the Local Commission of Surveillance (CLS) of Fessenheim, created in
1977 for the Fessenheim nuclear power plant. The circular of the Prime Minister Pierre
Mauroy of 15th
December 1981, known as “Circulaire Mauroy” opened the way to the official
creation of CLIs in the vicinity of nuclear installations by Departmental Councils, by
encouraging – but not making compulsory – their creation. The 2006 Law on transparency
and security in the nuclear field made the existence of the CLIs compulsory around all
nuclear sites and included provisions on the organisation, role and funding of the CLIs and
reinforced the legal basis of their missions.
The Mauroy circular also provided for a conference of presidents of CLIs to be held at least
once a year. In 2000, this conference was transformed in a permanent organisation: the
National Association of Local information Commissions and Committees (Association
Nationale des Comités et Commissions Locales d’Information – ANCCLI). The ANCCLI
facilitates exchanges of information and common reflections between CLIS, supports the
CLIs (notably through the Scientific Committee), facilitates relationships with IRSN and the
ASN and give the CLIs a voice at the national level, notably through the annual conference of
CLIs and by issuing White Papers on various issues (e.g. governance of nuclear activities,
radioactive waste management, emergency and post-emergency preparedness and
management, dismantling of nuclear facilities). The ANCCLI also created permanent working
groups on various issues of interest for the CLIs, including safety, as a tool to facilitate
exchanges between CLIs and support their work.
Between the creation of the CLI and the creation of the most recent one in 2001, about 30
CLIs were created. They represent a diversity of contexts and experiences that sheds light
on the issue of the contribution of local actors to safety and health and environmental
protection around nuclear sites.
The strategy for openness to society of the Institute for Radiation Protection and Nuclear
Safety (IRSN)
Since 2003, the IRSN has continuously developed a strategy of openness to society that has
contributed to modify the way expertise is framed, developed and made available by the
IRSN.
This process began in a national context of general evolutions of risk governance affecting all
types of hazardous activities since the 1990’s. This context was notably the result of several
public health scandals in France and Europe like the “mad cow crisis“ or the “contaminated
blood crisis“. This notably raised public expectations about transparency and openness of
expertise processes and about separation between expertise and decision-making and about
the independence of expertise organisations. In the nuclear field, these expectations notably
led in 2002 to the creation of the IRSN enacted by Law as an autonomous institution in the
form an independent public technical and scientific institute.

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This context of change in risk governance also included new legal requirements for
transparency and public participation. At the international level, the Aarhus Convention on
Access to Information, Public Participation in Decision-Making and Access to Justice in
Environmental Matters was signed in 1998 notably by EU member states including France
and also by the European Union. At the national level, the legal context included legal
provisions for transparency and participation both for environment-related decisions in
general and in the nuclear field in particular.
The IRSN thus wished to evolve from being a public expert organisation supporting the
decision-making processes of State organisations to a vision of public expertise that also
included being an expert also acting for the public. The IRSN’s strategy of openness to
society aimed to reach this objective by experimenting new relationships with stakeholders
from the civil society, contributing to increase the transparency of its expertise processes
while supporting the development of the technical capacities of those actors regarding
nuclear safety and radiation protection.
The IRSN’s strategy developed continuously from 2003 to the present day, through several
important milestones. The first one was the creation, in 2003, of an internal tool to develop
and implement the strategy under the form of a dedicated department: the Department for
Openness to Society. This Department aimed to
• being an access point for stakeholders from the civil society;
• involving IRSN in European projects related to risk governance;
• and supporting operational IRSN teams’ work in their interactions with stakeholders.
New relations with stakeholders were developed through an experimental approach relying
on pilot projects in which IRSN experts engaged interactions with stakeholders from the civil
society on concrete cases.
The inner tools for developing the IRSN’s strategy were complemented by a cooperation
framework with the CLIs and the ANCCLI. In 2003, a cooperation agreement was thus
signed between the IRSN and the ANCCLI, which included cooperation with the CLIs on pilot
projects with local committees and the creation of joint thematic working groups on topics of
particular interest for the CLIs. This agreement is based on a mutual understanding that the
development of the skills of CLIs and ANCCLI is beneficiary for the CLIs & ANCCLI, the
IRSN and the regulator – the Nuclear Safety Authority (Autorité de Sûreté Nucléaire – ASN).
The engagement of the IRSN towards openness to society was reaffirmed in 2006 at the
occasion of the renewal of performance agreement between the IRSN and the State. The
new performance agreement included “meeting the needs of other social and economic
actors” as one of the four strategic axis of the IRSN in the performance agreement.
The IRSN finally materialised its engagements under the form of a Charter of Openness to
Society in a two-step process. A first step was the participation of the IRSN to the process of
development of a common Charter of Openness to Society by several public scientific and
technical institutes covering different fields of activity. The IRSN and 3 other public scientific
and technical institutes signed the common Charter in October 2008. The second step was
the development of the IRSN’s specific Charter of Openness to Society, which was issued in
April 2009.
The Charter of Openness to society, as well as other strategic documents like the IRSN’s
performance agreement, notably makes explicit the approach of safety underlying the IRSN’s
strategy. In this approach, civil society is incorporated in the safety system as an additional
layer contributing to safety, moving from a 3-pillar safety approach (organisations operating
nuclear facilities, the regulator – the ASN, and public experts – the IRSN) to a 4-pillar
conception including civil society.

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3.4. Presentation of the case study
The 3rd
decennial review of nuclear reactors: a convergence between 2 process of
engagement of civil society at the national and at the local level
The engagement of the CLIs and the ANCCLI in the 3rd
decennial safety review of
Fessenheim nuclear power plant reactors developed at the crossroads of two processes of
engagement of civil society in nuclear safety issues.
• The first one, at the local level, is the process of engagement of the CLS (Local
Information and Surveillance Commission – Commission Locale d’Information et de
Surveillance) of Fessenheim and the independent expert group GSIEN (Scientific
Group for Information on Nuclear Energy – Groupe Scientifique d’information sur
l’énergie nucléaire) in the successive decennial safety reviews of Fessenheim nuclear
power plant.
• The second process, at the national level, is the development by the IRSN, the
ANCCLI and some CLIs (including the CLS of Fessenheim), as a part of the strategy
of openness to society of the IRSN, of a pilot case aiming to facilitate the engagement
of CLIs and the ANCCLI in the 3rd decennial safety review of French nuclear
reactors, and the development of national guidelines by the ASN to facilitate the
engagement of CLIs in the decennial safety review of nuclear reactors.
Engagement of the CLS of Fessenheim and GSIEN in decennial safety reviews
Engagement of the CLS in the 1st
decennial safety review
In 1989, the Fessenheim nuclear power plant underwent the first decennial safety review of
its two reactors Fessenheim 1 and 2. At this occasion, in the framework of its mission of
follow-up of the activities of the nuclear power plant, the CLS of Fessenheim wished to have
an independent opinion on the safety of Fessenheim nuclear reactor 1.
On 14th
April 1989, following a proposition made by the President of the CLS, the
Department Council of Haut-Rhin commissioned and funded a group of French and foreign
experts (including members of the NGO “French Group of Scientists for Information on
Nuclear Energy” – Groupement des Scientifiques pour l’Information sur l’Energie Nucléaire,
GSIEN) to perform a safety assessment of the nuclear power plant at the occasion of the
shutdown of reactor 1.
This pluralistic group was composed of 5 expert: Christian Kuppers et Lothar Hahn (Institut of
Ecology of Darmstadt, Germany), Jochen Benecke (Institut Sollner and University of Munich,
Germany), Luc Gillon (University of Louvain and Center for Nuclear Studies – SCK-CEN – of
Mol, Belgium) and Raymond Sené (CNRS - Collège de France and member of the GSIEN),
and 2 associated consultants : Patrick Petitjean (GSIEN) and Michèle Rivasi (CRII-Rad
NGO, France).
This pluralistic expert group performed its work from 11th
May to 18th
September 198910
. The
works of the pluralistic expert group notably included 3 working meetings with experts from
EDF, the SCSIN and the DRIRE, in presence of experts from the Institute for Protection and
Nuclear Safety – IPSN) as well as a visit of the reactor building. The final report of the expert
group was presented on to the CLS 18th
September 1989 with presence of the press.
The expert group reported good working relations with the regulators (Central service for
safety of nuclear facilities – SCSIN, and Regional direction of industry & research – DRIRE),
10
A complete description of the mission of the expert group is available (in French) in issue 98/99 of
GSIEN’s journal “La Gazette Nucléaire” (year 1989), in the article “Fessenheim, 10 years already”:
http://www.gazettenucleaire.org/1989/98_99p03.html

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which accepted to participate to working meetings, to answer the expert group’s questions
and to give access to safety documents. However, this first citizen assessment of the safety
of reactors Fessenheim 1 and 2 was also characterised by initial reluctance of EDF, the
electricity company operating the power plant, to recognize the expert group, meet the group
directly and allow access to some documents. This reluctance has been partially overcome
during the expert group’s mission and the expert group finally had access to some safety
documents of EDF and experts from EDF took part to some working meetings with the
pluralistic expert group.
The conclusions11
of the pluralistic expert group stressed that, within the time and resources
that were available and with the fragmentary pieces of information at its disposal, the expert
mission has tried to form an opinion on the adequacy of the safety requirements of the
actions performed during the ten-year review, without being able to engage in a
comprehensive expertise and a comprehensive study.
In its conclusions, the expert group considered necessary that EDF give more attention to
safety checks before restarting of the reactors and give further attention to safety issues
including those related to accident beyond design basis. It also regretted that a number of
improvements could not been made before restarting the reactor and recommended that
these improvements can be made as quickly as possible.
The expert group made 3 specific recommendations for safety improvement (based on
comparison with what exists in pressurized water reactors – PWR – of similar design):
• Protection of nuclear fuel storage pool by a roof resistant to falling objects that may
damage the fuel
• Installation in the reactor building of a number of devices for measuring hydrogen that
may be released in case of an accident beyond design basis (i.e. of a greater
magnitude that the accidents scenarios taken into account in the design of the power
plant).
• Installation of fans in the reactor building to prevent the accumulation of hydrogen in
the vicinity of the discharge cover of the pressurizer and neighbouring premises
The expert group also proposed several improvements in the system of monitoring of the
environment of the nuclear site as well as provisions to improve the protection of workers.
Considering the limitation of its works, the expert group concluded that it was able to make
recommendations to improve safety without allowing it to give a blank check. In these
circumstances, the expert mission considered it should not recommend postponement of the
restarting of reactor Fessenheim 1.
In addition to the delivery of a report addressed to the CLS, the mission of the expert group
was also followed up by the CLS and its conclusions were presented ad discussed during a
plenary meeting of the CLS.
Engagement of the CLS in the 2nd
decennial safety review
At the occasion of the 2nd
decennial safety review, in 1999 the GSIEN was solicited anew by
the CLS for Fessenheim reactors 1, and accepted to carry out an external expertise on
safety and environmental impacts. The mission of the GSIEN was co-funded by the
Departmental Council of Haut-Rhin and the ASN and was organised after the 2nd
decennial
safety review. The mission given to the GSIEN was to give an expert opinion on the safety of
the nuclear reactor and on its environmental impacts based on the safety case prepared by
EDF and the safety report produced by the regulator as a result of the safety review.
11
A summary of the expert group’s conclusions is available (in French) in issue 98/99 of GSIEN’s
journal “La Gazette Nucléaire” (year 1989), in the article “Fessenheim, 10 years already”:
http://www.gazettenucleaire.org/1989/98_99p03.html

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To ensure better access of GSIEN to information than for the 1st
decennial safety review, a
convention was signed between the ASN, EDF and the CLS. This convention ensured both
the access of the experts from GSIEN to the EDF’s safety case for the decennial safety
review and confidentiality of commercially sensitive information by non-divulgation clauses.
In order to facilitate information exchange, different technical meetings between EDF and the
GSIEN were organised on various issues:
• steam generators,
• radiation protection of workers,
• reactor vessel
• containment building.
Due to this more structured framework, the GSIEN found the working condition be more
satisfying than for the 1st
decennial safety review. However, GSIEN still pointed out a too
constrained time frame to perform a complete and thorough assessment of EDF’s safety file.
The GSIEN delivered its report to the CLS on 6th
March 2000. In the report, the GSIEN
stressed the convergence between its own conclusions and the outcomes of the safety
review of the regulator. It pointed out different points related to:
• the resistance of the reactor vessel
• the analysis of incidents occurred since 1989
• the catalogue of situations where the primary water circuit and the use of this
catalogue
• how the conclusions of the regulator resulting from the 1st
decennial safety review
were taken into account
The GSIEN concludes, as did the regulator, that the guarantee of a safe operation of the
reactor up to 40 years (i.e. for 20 more years) is not demonstrated. The GSIEN also
concludes that the operation of the reactor for 10 more years can be done under satisfying
safety conditions, under the condition of more regular monitoring and good return of
experience.
The expertise report of the GSIEN stressed that the conclusions of the pluralistic expert
group commissioned by the CLS during the 1st
decennial safety review of reactor
Fessenheim 1 led to additional controls and improved the safety of the reactor. In particular,
EDF has equipped the reactor buildings with hydrogen recombiners to lower the risk of
explosions due to hydrogen discharge. This modification was made not only on Fessenheim
reactors, but also in all nuclear power plants in France.
However, the GSIEN also pointed out that some points of concern expressed by the
pluralistic expert group during the 1st
decennial safety visit were still not taken into account:
• need to prove the resistance of the reactor building to an explosion
• need to fix the opening device on the depressurisation valve of the reactor vessel
• resistance of the nuclear fuel storage building to external aggressions
• vulnerability of the facility to flooding.
In addition to the delivery of a report addressed to the CLS, the mission of the expert group
was also followed up by the CLS and its conclusions were presented ad discussed during a
plenary meeting of the CLS.
The GSIEN was solicited again one year later for the safety review of reactor Fessenheim 2,
under similar conditions (expertise carried out just after the decennial safety review of the
reactor, funding from the Departmental Council of Haut-Rhin, signature of a convention with
EDF and the regulator and technical meetings with EDF). The GSIEN was asked to deliver
an opinion on the safety of the reactor – but not on its environmental impacts.
The GSIEN report included opinions on the following points:

15.
15
• Monitoring of the reactor vessel resistance
• Reactor containment structure
• Seismic and flooding risks
• Analysis of significant incidents
• Mechanical aspects
• Neutron flux
The GIEN concluded that, if they do not share EDF’s opinion in some cases, they
acknowledge the efforts made by the operating company to ensure the safety of the reactor,
understand phenomena of ageing under irradiation, and analyse incidents. They concluded
that, it would be essential to reassess the resistance of the reactor vessel after 25 years in
order to follow-up the defects discovered during the 2nd
decennial safety visit.
The GSIEN finally included an estimation of the human resources that were necessary for
the GSIEN’s to carry out its expert assessment: 60 person-days, i.e. approximately 15 days
of works for 4 experts.
Here again, the works of the GSIEN were followed-up by the CLS and their outcomes were
subject of presentations and discussion during a plenary meeting of the CLS
Engagement of the CLS in the 3rd
decennial safety review
At the occasion of the 3rd
decennial safety review, the local commission of Fessenheim, nom
named CLIS (Local Commission of Information and Surveillance) commissioned anew in
2008 the GSIEN in 2008 to carry out a complementary safety assessment.
This assessment was carried out under a different legal context than ten years before. In
effect, the 2006 Law on Transparency and Safety in nuclear activities (TSN Law) makes
compulsory the existence of one CLI for each nuclear site, gives the chairmanship of the CLI
to the Departmental Council, précises the composition of the CLI members, and defines the
mission of CLIs as a “general gives the CLI a general mission of follow-up, information and
dialogue on nuclear safety, radiation protection and impact of nuclear activities on people
and the environment as regards the activities of the site”. In this new legal and regulatory
framework, the activities of the CLIs are co-funded by the Departmental Council and by the
ASN.
Moreover, the public technical support organisation on nuclear safety and radiation
protection (and technical support of the ASN) had changed its status in 2002, becoming and
fully independent institute, the Institute for Radiation Protection and Nuclear Safety (Institut
de Radioprotection et de Sûreté Nucléaire – IRSN). Since 2003, the IRSN has engaged in a
strategy of openness to society (see subsection “context of the case study” above), which
included support to activities of various CLIs and their national association, the ANCCLI.
The first step has been the negotiation and signature of a convention (see Annex 2) between
the Department Council of Haut-Rhin, the ASN, the GSIEN and one expert commissioned by
the Scientific Committee of the ANCCLI, David Boilley, nuclear physicist and member of the
Association for monitoring of radioactivity in the West of France (Association pour le Contrôle
de la Radioactivité dans l’Ouest – ACRO). This convention set the perimeter of the experts’
mission, which was composed of the following themes:
• Follow-up of the 2nd
decennial safety review of reactor Fessenheim 1: assessment of
the outcomes of the 2nd
decennial safety review and lessons for the 3rd
decennial
safety review.
• Reactor vessel
• Fatigue defects
• Reactor containment structure
• Analysis of significant safety events and influence on safety
• Nuclear fuel

16.
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The convention also fixed the costs of the expert group mission (50 000 euros) and their
funding (50% funding from the Departmental Council, 50% from the ASN). Finally, the
convention set the confidentiality conditions for the access to EDF’s documents: the expert
group has access to EDF’s documents related to the object of the expertise and commits not
to reveal any document which is confidential according to the provisions of the TSN Law12
.
According to the convention, the Departmental Council and the CLIS are bound by the same
engagement.
The way the mission was organised was also different than for the previous decennial
reviews, as the time frame of the experts mission was considerably extended compared to
the first 2 decennial safety reviews, and was larger than the time frame of the decennial
safety review carried out by the ASN. The mission of the expert group formally began on
January 2009 according to the convention and ended in June 2010, while the decennial
review lasted from 17th
October 2009 to 25th
March 2010. The mission of the expert group
was organised in the following way:
• 3 preparatory meetings of the expert group from 25th
March 2009 to 8th
June 2009
• 5 technical meetings with the expert group, the ASN and EDF on Fessenheim nuclear
power plant site from 28th
September 2009 to 12th
May 2010. During some of these
meetings, visits of the expert group in different parts of the nuclear power plants were
organised, including a visit of the reactor building on 21st
December 2009. The last
two meetings were dedicated respectively to a debrief of the decennial safety review
carried out by the ASN (25th
March 2010), and to the statistical study of the incident
which occurred between the end of the previous decennial review (2000) and the
current one (2009)
• The report of the expert group was issued on June 2010.
Beyond the technical meetings with the ASN and EDF, the expert group also had access, as
an experimental process (see section about “the IRSN pilot case on 3rd decennial safety
reviews” below), to the expertise o the IRSN. In effect, the IRSN gave the GSIEN access to
its report on the 3rd
decennial safety review of the 900 MWE reactors in France13
. This
helped the expert group to refine its questions.
The works of the expert group were followed up by the CLIS and their outcomes were
presented to the CLIS and discussed during a plenary meeting of the CLIS.
All interviewees reported good working relations between the expert group, EDF and the
ASN and stressed the full commitment of EDF to facilitate the work of the expert group and
give access to all requested information (as stressed in the conclusions of the final report of
the expert group). The CLIS underlined that the way the expertise was carried out
represented “the maximum that could be done” in this kind of independent expertise process.
The expert group conclusions included various points related to the different topics
addressed by the expert group (as fixed in the convention). The general conclusion14
of the
expert group was that “the analysis of the files and of the answers given by both the operator
and its technical support do not reveal alarming factors, even if points concerning the
maintenance, realization of works, training should be better taken into account and be greatly
improved.
However, some questions remain:
12
article 19 of the Law
13
This report deals with the generic safety of French 900 MWE reactors and is not specific to a
particular facility. It assesses possible safety issues and points of attention for all the reactors of
similar design.
14
See the final report of the expert group, available (in French) at: http://www.anccli.org/wp-
content/uploads/2014/06/Rapport-final-1-VD3-FSH-1.pdf

17.
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- For example, the resistance of the foundation raft in a severe accident sequence
remains an important issue, and that to the extent the probability of such accidents
would increase due to the general aging of the facility and the increased combustion
rate of fuels.
- The waste issue, for those without disposal route and whose storage on site is not
necessarily compatible with the geography of this site (flood risk, for example).
- The increase in releases of Tritium correlated to the switch to Cyclade fuel that drives
the increased use of boron.
- The problems inherent in a system built with equipment designed more than 40 years
ago. The rejuvenation of some equipment may create conflicts between existing
technologies and those of 60-70 years.”
According to the GSIEN, the IRSN and the ASN, there was no significant divergence
between the conclusions of the expert group and the conclusions of the decennial safety
review carried out by the ASN.
Following the 3rd
decennial safety review ad the mission of the expert group, EDF reinforced
the foundation raft of the reactors and demonstrated that this reinforcement increased to 3
days (compared to 12 hours before the reinforcement) the time in which the raft would be
bored in case of a core meltdown.
At the occasion of the 3rd
decennial review of reactor Fessenheim 2 (carried out from 16th
April 2011 to 6th
March 2012), the Departmental Council and the ANS commissioned and
funded an expertise mission of the GSIEN, on proposal of the CLIS, under similar terms and
conditions as for the 3rd
decennial review of reactor Fessenheim 1. During the year 2011, the
convention, similar to the one signed for Fessenheim 1, was negotiated and signed between
the GSIEN, EDF, ASN and the CLIS. The expertise carried out by the GSIEN dealt with the
following issues:
• Reactor vessel (aging of the vessel and follow-up of the vessel’s defects)
• Fatigue defects
• New steam generators (the steam generators were replaced by new ones at the
occasion of the shutdown of the reactor for the decennial safety review)
• Confinement building
The mission of the GSIEN lasted from August 2011 to June 2012. The works of the experts
were organised in a similar way as for the 3rd
decennial safety review of reactor Fessenheim
1. This process included different technical meetings with EDF and the ASN as well as field
visits.
The GSIEN concluded that “the files of the ASN, the IRSN, EDF and its technical support
does not reveal alarming factors and explains the restart authorization for 1 year to reactor
Fessenheim 2.
However, the GSIEN stressed that some questions remain:
• the control of the training of workers, the control of the realization of projects (quality
of work sheets), monitoring of radiation protection (see ASN inspection follow-up
letters);
• the resistance of the foundation raft in a serious accident sequence remains a major
question: GSIEN was not the recipient of technical records on this topic. A thickening
of the concrete of the raft is under consideration. However, the GSIEN, in the state of
his knowledge of the case, is not convinced that this operation can be performed
because this thickening, requested for many years and still undergoing analysis,
should absolutely be done before the end of June 2013.
Regarding the 3rd
decennial safety review, the GSIEN expects the requirements that the ASN

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will issue to allow or not the continued operation of Fessenheim 2, those requirements being
expected for the end of 2012. GSIEN will analyse them for the CLIS.
Following the Fukushima accident, additional requirements should be available end of June
2012, concerning among other things, protection against floods and the reassessment of
seismic risk.”
In effect, the 3rd
decennial safety review of reactor Fessenheim 2 as carried out after the
Fukushima accident, at a time when all European nuclear reactors underwent “stress tests”
asked by the European Commission.
Here again, interviews members of the GSIEN, the CLIS, the IRSN and the ASN noted a
strong convergence between the conclusions of the GSIEN and the conclusions of the ASN
report on the decennial safety review.
A national process from 2009 to facilitate the engagement of the CLIs and the ANCCLI in
the decennial safety reviews of French nuclear reactors
The ASN guidelines on the engagement of CLIs in the 3rd
decennial safety review of nuclear reactors
In parallel to the joint works of the IRNS, the ANCCLI and some CLIs, the regulator (ASN)
has also prepared “Guidelines on the engagement of the CLIs in the 3rd
decennial safety
reviews of 900 MWE reactors”, in cooperation with the “Openness to society” unit of the
IRSN. This document, issued as official guidelines of the ASN, was first presented to the
CLIs at the 21st
annual national conference of CLIS on 9th
December 2009; its final version
was issued on 1st
June 2010. These guidelines were prepared based on the experience of
the CLS of Fessenheim with the 3rd
decennial safety visit of reactor 1, and on dialogue with
the CLIS and the ANCCLI, notably at the occasion of the 21st
national conference of CLIs.
These guidelines are intended for the CLIs and aim to help them organising their
engagement in the 3rd
decennial safety reviews and organise, if they would wish so, a
pluralistic expertise. The document also proposes guidelines for organising dialogue between
the ASN, the CLIs and the organisation operating a nuclear power plant.
The guidelines distinguishes three different possible levels of engagements fro the CLIs:
1. A simple information of the CLI by the ASN, which can be completed by presentations
of the works carried out on specific themes
2. The organisation of a pluralistic expertise on a particular theme
3. The organisation of a pluralistic expertise on the whole decennial safety review, like
the one carried out by the GSIEN on the 3rd
decennial review of Fessenheim nuclear
power plant.
In the case of pluralistic expertise, the guidelines notably recommend to have a clear
contractual framework between the Department Council, the organisation operating the
nuclear power plant, the ASN and the experts. The convention signed between the
Department Council of Haut-Rhin, the nuclear power plant, the ASN and the experts for the
3rd
decennial safety review of reactor 1 is proposed as a model of such contractual
framework. The ASN stresses that, according to the current legal framework, pluralistic
expertise processes carried out by the CLIs can be co-funded by the ASN for half the
expenses.
The ASN included in its guidelines an indicative list of themes that can be included in the
scope of pluralistic expertise processes with propositions of independent experts that could
be mobilised on each theme. The guideline also includes a non-exhaustive list of themes on
which the ASN can organise information of the CLIs.

19.
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The IRSN pilot case on 3rd
decennial safety reviews
In 2006, the national public debate on the EPR reactors developed in France raised issues
concerning the access of civil society to information and technical documents covered by
industrial secret or secret defence. As a result, the High Committee on Transparency and
Information on Nuclear Safety (HCTISN)15
recommended new procedures for improved
access to information be tested on concrete cases.
In the framework of its policy of openness to society, the IRSN decided to take the 3rd
decennial safety review of Fessenheim 1 reactor as a pilot case to assess how the IRSN can
facilitate the engagement of CLIs in the process of the 3rd
decennial safety review of French
nuclear reactors. This pilot case took place in a context of already existing cooperation
between the CLIs, the ANCCLI and the IRSN through various pilot cases and through joint
working groups. The pilot process for the 3rd
decennial safety review of reactor Fessenheim 3
pursued three objectives:
• to build upstream technical discussion with the Local Committees and experimenting
procedures for the CLIs to access the operator’s safety reports;
• to support capacity building for the CLIs in the perspective of the 3rd
decennial safety
review of nuclear reactors in France;
• improving the IRSN’s knowledge of the expectations of the CLIs for the 3rd
decennial
safety reviews.
The method developed in this pilot case relied on a national working group including the
IRSN, 4 CLIs (Fessenheim, Gravelines, Blayais and Dampierre), the ANCCLI, EDF and the
ASN. Access to information and documentation was already guaranteed by the convention
signed between EDF, the ASN, the CLIS of Fessenheim and the experts commissioned by
the CLIS at the occasion of the 3rd
decennial safety review (see page 15).
The pilot case was developed between April 2009 and November 2010 and relied on 2 tools
or forums of exchange: the above-mentioned national working group and a final seminar
involving a larger number of CLIs and of participants. The IRSN took preliminary contacts
with CLIs in April 2009. The national working group involved in the project was then formed.
A second step in the cooperation process has the preparation of an independent review of
the IRSN’s safety report by an independent expert group (GSIEN) commissioned by the
Fessenheim CLIS. The IRSN sent its safety report to the GSIEN on May 2009.
In December 2009, the working group identified specific topics of interest for the CLIs in the
3rd
decennial safety review process.
In March 2010, a presentation of the IRSN’s safety report on Fessenheim nuclear power
plant was made available for the working group.
The final step of the process consisted in preparing and organising the final seminar of the
project. From May to June 2010, the national working group identified the topics to be
addressed in the final seminar and prepared the programme of the seminar.
The final seminar of the pilot case was organised in November 2010 and gathered about 35
people, including participants from 10 CLIs as well as the ANCCLI. The programme of the
seminar was organised along two topics of particular interest for the CLIs:
15
The HCTISN was created by the 2006 Law on Transparency and safety of nuclear activities. It has a
mission of information, dialogue and debate on the risks associated to nuclear activities and the
impact of these activities on human health, the environment and nuclear safety. The HCTISN can
issue opinions on any issue in these fields as well as on the associated controls and information. It
can also take up any question related to accessibility of information on nuclear safety and make
proposals aiming to guaranteeing or improving transparency.

20.
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• How to implement an independent expert assessment of a decennial safety review at site
level?
• How can the CLIs perform a follow-up of the facility after the decennial safety review?
Three types of experts were involved in the cooperation process: the experts of the IRSN,
experts from an independent scientific group (GSIEN) commissioned by the CLI of
Fessenheim, and other experts involved in the decennial safety assessment (operator EDF,
Nuclear safety Authority – ASN). Each of these 3 types of experts had a specific role in the
process:
• The IRSN provided information to the CLIs and the ANCCLI on the safety
assessment of the nuclear reactor of Fessenheim, in particular by making available
the IRSN’s safety report;
• The GSIEN provided independent expert review of the IRSN’s safety report;
• EDF and the ASN provided insights on specific issues (stakes of safety assessment
for EDF, regulator’s perspective for the ASN).
The CLIs and the ANCCLI took part in the process as civil society actors with particular
awareness of nuclear safety issues. In the process, their role was to
• Contribute to the framing of the issues addressed in the decennial safety review;
• Take benefit of the interactions with different types of experts in terms of
empowerment and capacity to engage in the process of the 3rd
decennial safety
review.
Civil society actors involved in the process were essentially members of the CLIs and of the
ANCCLI. The members of CLIS and of the ANCCLI taking part to the national working group
had access to information on the safety review of the Fessenheim reactors by different ways:
• access to the IRSN’s safety report
• access to the independent analysis of the IRSN’s safety report made by the GSIEN
• exchanges with the IRSN, the operator of the reactors (EDF) and the Nuclear Safety
Authority within the national working group
• final seminar of the project.
A broader range of CLI members (from 10 CLIs) had access to information on the safety
review process through the final seminar of the project.
The cooperation process resulted in competence building for the members of the working
group. This includes the participating CLIs but also the IRSN, which improved its
understanding of the stakes of the CLIs in the decennial review process and enhanced its
capacity to interact with them in the decennial review processes for other reactors.
The process thus enabled the CLIs and the IRSN to identify topics of particular interest for
the CLIs during a periodic safety review. In particular, this cooperation led the CLIs and IRSN
to identify and share the CLIs’ needs for playing an active, meaningful and effective role in
decennial safety review:
• Access to technical trainings
• Information sharing between CLIs
• Dialogue forums between CLIs and with the institutional actors of periodic safety
reviews (IRSN, Nuclear Safety Authority, operator)
• Access to diversified expert support resources: IRSN, Scientific Committee of the
ANCCLI, independent expert, …
The specifications of the safety review for Fessenheim nuclear power plant were also
adapted as a result of the cooperation process.
Finally, at the end of the process, some CLIs considered continuing the process in an
autonomous way in the context of the 3rd
decennial safety reviews of the French nuclear

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21
power plants. As a consequence, the IRSN continued to engage with the CLIs and the
ANCCLI on the issue of decennial safety reviews through meeting with different working
groups of the ANCCLI and discussions with the ANCCLI on the ways the IRSN can support
the engagement of the CLIs in the decennial safety reviews. The ANCCLI is currently
defining with the IRSN the issues on which it wished to engage in the framework of the 4th
decennial safety visits of French nuclear reactors.
The IRSN-ANCCLI seminar on human and organisational factors
Following the Fukushima catastrophe (11th
March 2011), it appeared that this accident was
due not only to a natural disaster, but also to human and organisational factors16
. This led the
CLI and the ANCCLI to pay particular attention to the human and organisational factors in
safety.
On 18th
June 2013, the IRSN and the ANCCLI organised a seminar17
for the members of the
different CLIs on this theme. The objective of this seminar was to facilitate the building and
reinforcement of the competences of CLIs on this issue and organise exchanges between
the different stakeholders (IRSN, ASN, EDF, HCTISN and CLIs). The seminar gathered
about 60 people, including 40 members from 20 CLIs.
This seminar enabled the participants to share information on the history of how human and
organisational factors have been taken into account in the expertise on nuclear safety,
identify themes to further investigate following the Fukushima accident and discuss issues
like competence management or subcontracting.
3.5. Analysis of the case study
Understanding of safety and safety culture
Both the documentation and the interviews show that all involved actors (EDF, the ASN, the
IRSN, the CLIS of Fessenheim and the experts it had commissioned) share a common
understanding of safety as a continuous improvement process.
The understanding of the role of the civil society in this process evolved through time
between the first decennial safety review of Fessenheim 1 reactor in 1989 to the end of the
expertise mission of the GSIEN on the decennial safety review of Fessenheim 2 reactor.
Initially being an initiative of the local actors, the engagement of the CLIS of Fessenheim in
the decennial safety reviews now has become something usual.
The experts commissioned by the CLIS of Fessenheim had a high level of technical
qualification and demonstrated the capacity of civil society to produce sound competent and
precise assessment of technical safety issues with nuanced conclusions. They played both a
role of expertise and of mediation, conveying the results of their expertise to the CLIS in an
understandable way. The CLIS represented a second level of mediation as it gave account of
the outcomes of the expertise of the GSIEN to the general public through its information tools
16
The Nuclear Accident Independent Investigation Commission (NAIIC) set up by the Japanese
Parliament to investigate the Fukushima accident concluded that Fukushima was a “manmade”
disaster (see executive summary of the commission’s report on
http://warp.da.ndl.go.jp/info:ndljp/pid/3856371/naiic.go.jp/wp-
content/uploads/2012/09/NAIIC_report_lo_res10.pdf).
17
The programme of the seminar and the support documents of the different presentations made are
available on the IRSN website: http://www.irsn.fr/FR/connaissances/Nucleaire_et_societe/expertise-
pluraliste/IRSN-ANCCLI/Pages/2-Seminaire-Juin-2013-Facteurs-organisationnels-humains-surete-
nucleaire.aspx

22.
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(website and newsletter) in a form accessible to the general public.
The engagement of the CLIS of Fessenheim and of the experts it commissioned for the first
and second decennial safety review had an actual impact of safety as it led to some technical
modifications of the facility and to adaptations of its monitoring programme. For the 3rd
decennial safety review, there is a convergence of views between the CLIS, the GSIEN, the
IRSN and the ASN on the fact that the engagement of the GSIEN did not bring up safety
issues that would not have been detected by EDF or the ASN assisted by its technical
support organisation, the IRSN. However, the engagement of civil society played a role of
stretching and led the IRSN and ASN to better explain and justify their assessments. Two
quotes from the interviews18
illustrate this assessment of the role of civil society:
“A virtuous process which challenges everyone to better express and explain one’s
positions”
“It is good to have an external glance on the way safety is managed in the nuclear
facilities, in order to cope with the fact every human system generates habituation”
In the current French nuclear safety system, there is a shared understanding between the
CLIS and the ANCCLI, the ASN and the IRSN that the first responsible of the safety of
nuclear power plants are the organisations operating them (in the case of France, EDF),
which is then complemented by the ASN (and its technical support organisation, the IRSN)
as a second layer of safety, the engagement of civil society in safety issue representing a
third layer of safety in this system which plays a specific role of quality insurance, both from
the point of view of institutional players and from the one of civil society. The engagement of
the CLIs on the nuclear safety reviews, which was an unexpected initiative form the CLS of
Fessenheim in 1989, now appears as a normal and desirable component of the process of
the decennial safety visits and is supported by both the regulator (ASN) and its technical
support organisation (IRSN).
In the framework of this case study, it was not possible to determine if EDF also shares or
not this understanding of the safety system where civil society (and in particular the CLIs and
the ANCCLI) constitutes a fourth pillar of nuclear safety. What can be traced in the interviews
and documents is the evolution of EDF’s attitude along the successive decennial safety
reviews, from reluctance to acknowledge the initiative of the local commission of Fessenheim
to a full cooperation and extended and regular dialogue with the local commission and its
experts. According to all interviewees, EDF is fully “playing the game” of the engagement of
the CLIs in the decennial safety reviews and contributed to create an enabling environment
for the CLIs by giving access to its documents and make its own experts available for
meetings and exchanges with the CLIS and its experts.
This shared understanding of civil society as a component of the safety system (at least
shared between the CLIs and ANCCLI, the ASN and the IRSN) is the outcome of a co-
evolution process between civil society and the institutions responsible for safety. This co-
evolution process, which deployed both at the local and at the national level, combines the
progressive engagement of civil society organisation in safety issues, which becomes more
and more structured, with the evolution of the institutional framework, which becomes more
and more supportive to the engagement of civil society. In this process, both civil society and
nuclear safety institutions progressively experienced and acknowledged the benefits of civil
society engagement for safety and for the clarity and transparency of the safety system.
Beyond the contribution of civil society to safety itself, the interviewees also identified the
engagement of civil society in safety issues as a factor improving transparency of the safety
system and mutual understanding between EDF, the ASN, the IRSN and civil society
organisations. The integrity and quality of the work of the IRSN, ASN and CLIs is not
18
The method of the interviews includes an engagement of confidentiality on the content of individual
interviews. The interviewees are therefore not identified in the quotes.

23.
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questioned by any side. Finally, confronting the assessment of the ASN and the IRSN to
external expert scrutiny also contributed to demonstrate the independence of these
organisations.
Definition of safety as a public affair
In the considered case, the relationship between EDF, the regulator, its technical support
organisation and civil society actors is structured around a common good recognised by all:
ensuring that existing reactors operate at the best safety level. All actors share the view that
safety is not granted once for all and requires permanent vigilance and improvement.
Institutional actors (the ASN and the IRSN) note that civil society organisations actively
engage in safety issues and that dialogue on safety of existing nuclear power plants between
civil society organisations, EDF the ASN and the IRSN can be organised whatever the
position of these civil society organisations vis-à-vis nuclear energy.
The fact that nuclear energy production is recognised as a public affair in (e.g. an activity
having consequences on other actors than the ones carrying out the activity, thus giving
ground for these actors to influence the activity) and the consideration of safety as a common
good is reflected in the institution of the CLIs, which are at the same time dialogue forums
where safety issues can be discussed between all the concerned stakeholders and
organisations capable of taking action (e.g. by commissioning non-institutional experts to
analyse the safety of the reactors at the occasion of decennial safety reviews), this action
being supported by the IRSN and the ASN.
The process of decennial safety reviews also showed an agreement between all actors on
the basis of safety assessment and on what should be investigated.
The access to information and expertise for the CLIS and the experts it commissioned has
been improved from one decennial safety review to the next one through the three
successive decennial safety reviews. Starting from a point where the access to the
documents of EDF was a subject of tensions during the first decennial safety review, the
safety system (including the CLIS and its experts) has created a framework enabling access
to EDF’s documentation as well as a facilitated access of civil society to the expertise of the
IRSN and of the ASN. For the third decennial safety review, this framework set a time frame
that accommodates the limitations and constraints of civil society experts. All actors now
consider this framework and the associated practices of work satisfactory, although the
limited number of available independent exerts still constitutes a limiting factor.
Governance
The governance framework in which the engagement of civil society on safety issues took
place has evolved from 1989 to 2012. This evolution has been a result of both the
engagement of the civil society and of the willingness of institutions (including the
Parliament) to open the governance of nuclear society to civil society actors. This evolution
included both local and national components:
• At the local level, the conventions between EDF, the CLIS and the ASN have clarified
the conditions of work and of access to information of the expert commissioned by
the CLIs of Fessenheim and the conditions of interaction between EDF, the ASN, the
IRSN, the CLIS of Fessenheim and the experts commissioned by the CLIS.
• At the national level, the Mauroy circular of 1981 gave a first institutional framework
for the creation of CLIs, which was reinforced and clarified with the 2006 Law on
transparency and safety of nuclear activities. This Law grants a precise role of
information and follow-up of nuclear activities to the CLIs and the ANCCLI.
• Organisations like the ANCCLI (which gives a voice to the CLIs at the national level
and facilitates inter-CLI dialogue) and processes like the pilot process developed by
the IRSN o the decennial safety visits enables to establish links between the local
and the national levels in this governance framework.

24.
24
Beyond the formal governance framework, a steady cooperation has developed between the
CLIs and the ANCCLI, the IRSN and the ASN. This cooperation goes far beyond the sole
issue of safety reviews of nuclear reactors and encompasses a wide diversity of other issues:
radioactive waste management, post-accident situations, decommissioning of nuclear
facilities, …
The building of working practices with EDF, the IRSN and the ASN on the decennial safety
reviews have been facilitated by the monopolistic position of EDF as the operator of all
French nuclear power plants.
Controversies and co-framing
No controversies were identified by the CLIS, the GSIEN, the ANCCLI, the IRSN and the
ASN in the process of decennial safety reviews. The issues addressed were of technical
nature plus the issue of human and organisational factors affecting safety.
The interviewees stressed that they observed, over decades, a progressive separation
between the debate on nuclear energy and the debate on safety of existing reactors, and a
capacity to avoid pro/anti nuclear polarisation of debates. One of the interviewees however
noted that the debate on the extension of the lifetime of French nuclear reactors is now
reconnecting the issues of the debate on nuclear energy and the issue of nuclear safety,
while this does not impede constructive discussions on safety.
In a landscape where a diversity of positions exist vis-à-vis nuclear energy, the CLIs and the
ANCCLI aim to constitute independent information relays with a critical eye between the
public and the regulator, the public expert (the IRSN) and the operator of nuclear reactors
(EDF). In the case of Fessenheim, this independence has been well supported by the
capacity of the CLIS to commission a sound external assessment of the safety review.
Trust
Through the successive decennial safety reviews, EDF and the other institutional actors of
safety have demonstrated have been demonstrated that civil society actors are capable of
constructive interactions. The convergence between the safety assessment of the ASN,
IRSN and CLI/ANCCLI reinforces the credibility of IRSN and ASN. This did not damage the
credibility of the CLIs and ANCCLI as the experts commissioned by the CLIS were capable
of a precise safety assessment, and pointed out different points of improvement of safety.
The engagement of civil society played a role of quality insurance for the safety system and
reinforced the trustworthiness and robustness of the safety system as a whole and
contributed to the transparency and readability of the safety system. In particular, the
interactions between the CLIs and the IRSN and the ASN at the occasion of the 3rd
decennial
safety review (both the process in Fessenheim and the national pilot case developed by the
IRSN) resulted in an improvement of the information delivered by these two organisations,
which adapted their communication to better fit the needs of the civil society and the public.
Finally, the testing of procedures and processes for access of experts commissioned by civil
society to classified information and documentation of EDF has validated these procedures
and processes, and first of all the very principle that an expert mandated by civil society can
access under these condition to documents that cannot be made available to the public. This
reinforces the transparency of the safety system, which is a factor of reinforcement of trust in
this system.

25.
25
4. The hazardous waste incinerator of Dorog (Hungary)
4.1. Introduction
Chapter 1 of this case study is concerning the brief history of incinerator in the town of
Dorog. There are several factors why we have chosen Dorog as the subject of this study, for
instance the civil participation was really active before and after the Hungarian regime
change, so this is an ongoing civil (“watchdog”) control. According to the history of Dorog,
Chapter 1 is dealing with several safety problems of more than 25 years: illegal waste
storage and respiratory diseases; emission and slag problems; “waste of Garé”; serious
water pollution.
Chapter 2 is relating to the role of Environmental Protection Association of Dorog (EPAD):
we are elaborating the aims of public participation, analyzing the tools and strategies of the
Association, which has changed a lot during the operation of the incinerator.
Chapter 3 is about the experiences of the interviews. Several important conclusions can be
drawn:
• From the late 1980s (before the Hungarian regime change) to the early 2000s the
strategy of the local NGO can be characterized by massive civil resistance, pressure
on the incinerator and environmental authorities, demonstrations. From the last huge
disaster (water pollution in 2004) the Association has basically changed its model.
The new strategy is based on negotiation with the incinerator.
• The NGOs motivate the incinerator to operate correctly, on the other hand they have
to trust each other. This trust depends on personal relationship.
• The constant presence of civilian control must be interiorized to the company.
• Without professional expertise the civil organization does not understand the
operation of the facility or the relating problems, they cannot control the incinerator.
• It would be the task of the Hungarian state strengthening the civil capacities (this is
capacity building in a broad sense).
• The civil contribution to safety depends on personal relationships between civil
activists and employees of the industrial facility.
There is a very poor cooperation between the local and national/international NGOs: they do
not share their personal, professional experiences or coordinate their strategies. In the future
contribution to the local and national trust, it would be necessary to strengthen the
collaboration between the several types of NGOs and to reconcile their interest.
4.2. Method
The case study of Dorog is based on desk research and interviews of different stakeholders.
According to Deliverable 1: Theoretical and methodological framework (19 February 2015)
the interviews have been built on a very various range of practical experience: industry,
experts, and civil society, local communities (see the detailed profiles in the Appendix II).
Unfortunately the Hungarian environmental and nature protection systems have been
transformed in the recent months. The Environmental and Natural Protection Authorities
have been integrated to the local Government Offices, which are the parts of the central
Government at county level (there are 20 Government Offices in each counties and one in
Budapest). Up to the closing date of this final version of the case study we do not receive a
response about our interview’s request with a representative of the competent Environmental
and Natural Protection Authority.
That’s why the theoretical and methodological framework used for the interviews has been
semi-directive and a qualitative rather than quantitative survey, on one hand we have used

26.
26
the interview guidelines and on the other hand we have modified and completed at some
points these questions according to Hungarian case. We have invited the interviewees to
present as much freely their experiences as they can. We detail hereunder the different
questions that have been covered during the interviews.
The interviewees were the following:
• Mr. Attila Szuhi, energy policy expert and former activist of Humusz Waste Prevention
Alliance19
, which is a national NGO relating to environmental protection.
• Mr. János Tittmann, Mayor of Dorog since 1994, between 2002-2010 Member of the
Hungarian Parliament.20
• Mr. Tamás Nádor, environmental activist and representative of Environmental
Protection Association of Dorog, which is a local NGO.21
• Mrs. Katalin Lágler, general manager of Sarpi Dorog Ltd. 22
(member of Veolia
Group23
) since 1997.
4.3. Brief History of the Incinerator of Dorog and its Problems
The Importance of Dorog and considerations for the analysis
There are four main factors why the case of Dorog has been chosen the subject of this
analysis:
1. Relating to the history of the Hungarian civil sphere this is the only case in which
before and after the Hungarian regime change the civil participation and resistance
was efficient and remarkable.
2. According to this specificity we can investigate the potentiality and specifications of
the social participation, the resources and attitudes of the civil activists.
3. The role of the civilian control is not particularly significant in terms of violence or
preventing the investment. The real importance is the civil ongoing ("watchdog")
control, which could point out several misappropriations about the facility.
4. The inhabitants and civil activists of Dorog have experienced at first-hand why the
social participation is so important and how it could contribute to safety culture.
19
Their mission: “Humusz Waste Prevention Alliance, originally established by five Hungarian
environment protecting organizations in 1995, works for presenting waste poor, environment
conscious solutions and lifestyle examples. We do show that there is a form of being, in which money
and consumption are not prior to everything else, but one may still be satisfied within it. With the
solutions recommended by us we wish to revive the small, local communities, to turn people towards
each other again, instead of turning towards objects, and to restore trust through common
adventure…. The objective of Humusz is to make sustainable production and consumption an
everyday practice in Hungary. We work in order to create the will, to disseminate the knowledge
required and to develop the societal, economic and environmental framework of conditions needed. In
this regard we consider civil communities, teachers and students attending higher education to be our
outstanding allies. Our tools include the provision of information, education and consulting, the
research for good practices, developing and establishing waste prevention examples, and the
stimulation of community co-operations.” Source: http://www.humusz.hu/english/one-day-you-will-end-
humusz-anyway/721
20
Source: http://www.dorog.hu/index.php?nyelv=angol
21
Source: http://dke.hu/
22
Source: http://www.sarpi.hu/fooldal/lang:en
23
Source: http://www.veolia.com/en

27.
27
The birth of the Incinerator
The idea of incinerator originated back to the Communist ages (in 1984), when the three
main Hungarian pharmaceutical company decided to build a incinerator for hazardous waste.
Dorog has been accepted for two simple reasons: it situates in the center of an industry
region, and 20 thousand barrels of hazardous waste have been accumulated around this
area.
The facility met with a huge social resistance, which was really unprecedented before the
Hungarian regime change. In 1984 the land-use permit has been withdrawnd by the local
authorities and the central government took over the case. Meanwhile the citizens of Dorog
started to collect signatures for protest petitions, public forums has been initiated by local
organizations. The constructions began in 1985 by the direct force of the Communist
government. Before the Hungarian transition the protesters set up one of the first Hungarian
green social organization in 1988 (Environmental Protection Association of Dorog – EPAD).
After the regime change the ‘Dorog-saga’ has not finished, because under the new
circumstances the relevance of the social control has been increased. The incinerator was
denationalized.
The trial operation of the incinerator was in 1989, the commissioning in 1991, the initial
capacity was 25 thousand tons. In 1991, the facility got final approval. Although the
incinerator would burn the waste of the three pharmaceutical companies and the county,
later the facility’s license had been extended to the entire country.
Safety Problems at the Facility
From the beginning, detailed earlier, operation of the incinerator is burdened with several
serious technical and environmental problems. We can say that the incinerator constantly
provided causes and reasons to the civil participation and control.
A. Illegal Waste Storage and Respiratory Diseases
At the beginning of the operation, in the first part of 90s thanks to the investigation of EPAD,
it came to light that the incinerator stored hazardous waste at the local railway station without
any permission and safety measures. Although the company was fined 25 million Forints,
this was not an isolated case. The civil activist of the Association brought to light that the
proportion of children with respiratory diseases has been cautiously increased and by the
end of 90s it was more than three times the national average.
B. Problems with Emission and Slag
In the 90s there were also several problems with the filtration system, namely the dust
removal equipment did not meet the emission standards. The company had been operating
for a long time with inaccurate, unsuitable emission instruments. In this case the town of
Dorog and the public pressured the company and forced it to perform the needed
measurements relating to the emission.
It was also a huge problem to remove the slag from the incinerator. The slag was stored for a
long time near the facility, without any environmental permission. According to Humusz, a
Budapest-based environmental NGO specializing in waste issues: “The company does not
have the necessary documentation, which is inevitable for the reliable and safe operation.
Although the incinerator has the high level ISO 14001 certificate, the slag is not treated in a
proper way. After burning 21 000 tons of waste approximately 12 000 tons of solid
incineration residue is generated every year. This amount has been landfilled on the slag
landfill of the incinerator, in the city area with no respect to the regulations between 1996 and
1998. The landfilled slag has already significantly polluted the groundwater but not yet the

28.
28
karst water.”24
This caused serious groundwater pollution, according to an expert research
chlorinated solvents, carbohydrogens, benzenes, dioxins and different organic compounds
can be found in the groundwater. The EPAD and the whole public sphere pressured the
company to eliminate the pollution.
C. “Waste of Garé”
One of the most important scandals relating to the operation of the incinerator is the “waste
of Garé”. The case of Garé25
is very similar to Dorog and the case reveals the problems of
incineration itself.
Because of the heavily polluted site, Garé has become one of the most dangerous cases of
the Hungarian environmental history. This hazardous waste dumping site in Garé, a small
village in southern Hungary, was used by the Hungarian Chemical Company for 10 years
during the 1970s and 1980s. Because of financial difficulties the company was unable to
comply with the standards and orders of the environmental authorities to clean up the site. In
the early 1990s the company established a joint firm with a French hazardous waste
incinerator company to build an incinerator near the dumping site. The planned incinerator
would have burnt all the waste in one and a half years, but thereafter would have handled
additional waste from other places. The problem of hazardous waste treatment and the
planned incinerator represent a priority environmental dilemma for the southern region of
Hungary. The key question is whether Hungary needs a second hazardous waste incinerator
in addition to the existing one in Dorog. Due to strong opposition from the public, the regional
inspector refused to issue an environmental permit in this case.
The first Government of Viktor Orbán solved this huge environmental and social crisis by
burning the waste of Garé in the operating incinerator at Dorog. Despite the fact that it was
technically unsuitable, the Government tried it: during the experimental burnings it has been
showed that that the incineration of the waste of Garé emitted six times more dioxins than
the environmental limits.
Residents of Dorog protested against the burning of unknown type of toxic waste; the
NGO claimed that the incinerator failed to keep its emissions below the allowed maximum.26
As a result of the civil protest the company gave up the burning process, nevertheless until
then a huge amount toxic waste has been burnt by the incinerator. In addition, the company
tried again the incineration in 2001, and the only thing which prevented this, was the huge
pressure by the residents.
D. Water Pollution
The latest pollution due to the incinerator happened in the summer of 2004. In that summer,
the incinerator leaked a huge amount of toxic waste into the soil, contaminating local drinking
water sources. According to Humusz, from one of the deposit tanks of the Dorog waste
incinerator pollution was leaked out into the Danube and, from there, to the drinking water of
Esztergom. Technical problems, technological indiscipline and human faults caused the
environmental catastrophe. The environmentalists expressed their concerns that there were
many malfunctions and the company informed the authority with a significant delay and did
not even let the authorities’ people into the site right away. Furthermore information was kept
back so the authorities were not aware of the different pollution materials that were spilled.
Due to the lack of information the prohibition of the drinking water consumption came into
force with remarkable delay. As a result the inhabitants were drinking the polluted water for
24
Humusz, 1995
25
Fülöp Sándor (1996). Case Examples from Central and Eastern Europe. Garé Hazardous Waste
Incinerator Case. In: REC, 1996 Source:
http://archive.rec.org/REC/Publications/BndBound/Hungary.html
26
Gille, 2007 174. p

29.
29
many days.
There was no accurate information on the pollution in the water, their composition and
therefore not even on their impacts on the human life. The drinking of the water from the
pipeline was prohibited temporarily (the inhabitants could drink water in bottles only for
weeks). “Residents of surrounding settlements could not drink tap water for two weeks, and
the company is now facing not only a huge fine but also an ever-louder demand that the
incinerator be shut down.”27
There were several demonstrations, collecting signatures, residential forums. The NGOs
demanded the following:
• to suspend the operation of the incinerator until the entire environmental impact
assessment,
• the punishment of the people in charge,
• the remediation of the damaged environment,
• compensation of the city and the inhabitants,
• strengthening the environmental and health authorities in order to be able to prevent
stricter the hazardous activities in the future,
• the cost of environmental restoration should be paid by the concerned companies,
• the relevant regulations should be more severe,
• the municipalities and public should be regularly informed,
• and the municipal and public control of companies with hazardous activities should be
implemented.
The company and its management have been fined, but there were no further (for instance
criminal or administrative) consequences. However, these massive protestations were
needed to inform and protect the public.
The operator (at that time, ONYX Hungary Kft.) had submitted a request to the environmental
authorities for additional capacity enlargement in September 2004, just weeks after the
serious water pollution occurred in Esztergom. Although the authorities gave a free way to
the capacity enlargement, many NGOs expressed deep concerns about the company that
caused a serious environmental pollution. The increased capacity meant that the absolute
amount of emitted pollution was increasing, even if the emission is below the value limits.
Based on past experiences, the local NGO considered the capacity enlargement as a serious
mistake.
4.4. The Role of the Local Participation
After the regime change in 1989-1990, the EPAD continuously struggled against the
contamination of the facility. The Association has become a member of Humusz Waste
Prevention Alliance, which is a network of Hungarian civil organization and was established
in 1995. The civil association has become an unavoidable player at the local politics with
several representatives at the town council. One of the matchless outcomes of the
Association is establishing a local newspaper, called Green Lines (Zöld Sorok)28
concerning
local and regional environmental issues. It is nearly unprecedented that an NGO can
establish and finance a local medium. This was one of the main factors of the success of this
27
Gille, 2007 175. p
28
Source: http://dke.hu/index.php/zold-sorok-lapszamai?start=25

30.
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environmental movement.
The protests with thousands of participants indicate the power of the organization. Without
this continuous civil control the incinerator would have caused several irreversible damages
(for instance at the case of Garé). We can say that the civil society contributed to safety and
sometimes took over the authorities’ responsibility. The case of Dorog was proved
awareness-raising at the national level. The fact that the Hungarian public could know about
the problems and doubts about the procedure of incineration depended on this persistent
civil activism.
According to Kiss: “In modern societies dealing with environmental issues has become a part
of everyday life. Making decisions on waste- or water-related issues is part of the public
discourse in Hungary as well. The Hungarian literature on public participation discusses
different participatory tools applied in particular policy fields. Public participation seems to
have greater significance in environmental decisions than any other kind of democratic
decision making processes.”29
The EPAD has proven that in the field of environmental
protection there are several formal and informal participative techniques which could be very
successful against industrial facilities.
Why Should the Public Participate?
If we would like to understand the civil tools and techniques, we have to answer the question
why the public should participate in environmental decisions? There are several arguments
relating to public participation. Kiss Gabriella distinguishes six arguments: “Democratic
arguments come from the theory of democracy itself and the three models of democracy.
Arguments from Habermas’ theory are based on deliberative democracy and communication
theories. Green arguments are rooted in the concept of sustainability and connected to the
model of environmental democracy. The arguments on risks and particularly environmental
risks are based on the different risk approaches and assessments. The relationship between
science and society could be the basis for the next argument. The behavioral arguments
stem from behavioral economics and add a psychological point of view to these approaches.”
Tools and Strategies used by the NGO
Sherry R. Arnstein argues “that citizen participation is a categorical term for citizen power. It
is the redistribution of power that enables the have-not citizens, presently excluded from the
political and economic processes, to be deliberately included in the future. It is the strategy
by which the have-nots join in determining how information is shared, goals and policies are
set, tax resources are allocated, programs are operated, and benefits like contracts and
patronage are parceled out. In short, it is the means by which they can induce significant
social reform which enables them to share in the benefits of the affluent society.”30
Arnstein
classified the types of participation and "non-participation". This typology of eight levels of
participation is “arranged in a ladder pattern with each rung corresponding to the extent of
citizens' power in determining the end product.”31
We would like to use this concept to
illustrate the evolution of techniques of the EPAD.
29
Kiss, 2014 13. p
30
Arnstein, 1969 216. p
31
Arnstein, 1969

31.
31
Eight rings of
citizen
participation
Type of citizen
participation
Tools and Techniques
used at the Case of
Dorog
Cases, Disasters When?
(8) Citizen Control
Citizen Power
Visiting the Facility
Direct Cooperation
Interpersonal Relations
-
Last 5 -
10 years
(7) Delegated
Power
(6) Partnerism
(5) Placation
Tokenism
Demonstrations
Data Requests
Environmental Information
Litigation
Pressure on
Environmental Authorities
Water Pollution
“Waste of Garé”
1990s -
2000s
(4) Consultation
(3) Informing
(2) Therapy
Non-participation
Demonstrations
Civil Disobedience
Collecting Signatures
Residential Forums
Litigation
Pressure on Local and
Central Power,
Environmental Authorities
Problems with
Emission and Slag
Illegal Waste
Storage and
Respiratory
Diseases
1980s -
1990s(1) Manipulation
Table 1 - Arnstein's participation ladder and the case of Dorog
According to the safety problems a significant displacement has happened as the local NGO
of Dorog changed its strategy and the incinerator accepted the Association as a partner as
well. The emergence of this trust structure is the main contribution to safety. Nevertheless,
we cannot say that the demonstrations and pressuring were unnecessary, because without
these tools the cooperation would not have happened.