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Atominė energetika

CEE BANKWATCH NETWORK KOMENTARAI DĖL VISAGINO AE PAV

To: Pöyry Energy Oy,

Lietuvos energetikos institutas

AB „Lietuvos energija

 

Re: Comments to the EIA for the Visaginas new nuclear power plant

 

                                      08 October 2008, Kaunas

 

Dear organizers of EIA for the new nuclear power plant in Lithuania,

 

There are comments to EIA documents submited on behalf of Lithuanian representative of CEE Bankwatch Network Linas Vainius

 

EIA text

Comments

Page 30

To cover all realistic meteorological conditions several cases in different meteorological conditions during the years 2001 and 2002 have been simulated.

 

The reference period used to model meteorological conditions is very limited and further reduces the probability margin, especially with the current climate crysis and the associated uncertainties in terms of temperatures, precipitations level and extreme events. The assessment needs to be revised so that the meteorological models are based on a multi-annual range of data.

 

Page 34

The new nuclear power plant will consist of one to five units. In some parts of this

assessment the impacts are assessed for one or two reactors of about the size of 1600-

1700 MW. In these cases the impacts of three to five units with smaller reactor size are

assumed to be the same as for the two units with greater reactor size.

 

Assessing the impact and risks of a nuclear power plant with either one, two, or up to five units introduces a series of large uncertainties. Together with the fact that a reactor type has not been chosen for the project, these uncertainties indicate that the current EIA needs to be considered a preliminary documentation and a complete EIA needs to be developed once the reactor type and number of reactors are established.

 

Page 35

Typical construction time of a new NPP unit is 5–7 years (Figure 1.4-1). Operation time is approximately 60 years or even more.

 

The typical construction time for a new NPP, considering the global experience in the field, is often longer than designed. Operation time is also often shorter than designed. These aspects need to be treated in a risk analysis and the outcomes of this analysis needs to be reflected in the analysis of alternatives (meaning a proper analysis of alternatives to achieving the objective of the project i.e. bringing new electricity capacity online).

 

Page 43

A new project for construction and commissioning of near surface repository (NSR) for short-lived low and intermediate level waste (LILW-SL) is underway. The site of the NSR has been confirmed at Stabatiske, in the vicinity of the INPP (Resolution No. 1227 of the Government of the Republic of Lithuania, dated November 21, 2007).

 

The costs related to the management of the LIL-SL radioactive waste need to be reflected in the costs of the nuclear power plant and compared to the alternatives. The EIA needs to be revised as such.

 

Page 58

Long-term storage and disposal of SNF will be a subject of an own EIA procedure in the future and this issue is not a subject of this EIA Report. In EIA Program (Section 6.3) it is stated, that during the design stage of the new NPP an initial decommissioning plan should be prepared before the operating licence is issued. The initial decommissioning plan must specify the likely quantity of waste and provide an estimate of decommissioning costs.

 

The costs related to the management of the HL radioactive waste need to be reflected in the costs of the nuclear power plant and compared to the alternatives. The EIA needs to be revised as such.

 

Page 67

Alternatives

 

The analysis of alternatives cannot simply exclude other options in bringing new electricity capacity online. The analysis must consider all possible capacity alternatives and compare all costs, risks, lifetime, availability etc. The EIA has to be revised as such.

 

Page 110

Implementation of the safety requirements for a new NPP

As discussed above the designs of all Generation III+ design and some Generation II and III designs incorporate high safety goals. It is a requirement of the new nuclear power plant that the possibility of an accident leading to reactor core damage is less than once in 100 000 years and large environmental radioactive releases occur less often than once every 1 000 000 years. All candidate reactor plants being considered meet these requirements by a significant margin. As well as the being designed to withstand

severe accidents caused by core melting, the plant must also be designed to withstand external threats and terrorism. Such effects include withstand of a collision with a large passenger airplane, and external threats caused by natural phenomena such as earthquakes or high winds.

 

The risk of accidents must be reflected in the analysis of alternatives. The EIA should be revised as such.

Page 110

Once the selection of a plant has been achieved, work can then start on the preliminary safety analysis report which on completion will be submitted to VATESI in order to obtain a construction licence. This safety report will include detailed plant type-specific safety assessments to demonstrate the integral safety of the design, relevant limits and conditions for safe operation and maintenance, and suitable management arrangements of the operating company and site staff. In addition to the computational analysis describing accidents, probabilistic risk assessments will also be included covering the likelihood of different events e.g. the frequency of core damage and off-site radioactive releases.

 

Once the construction license has been obtained a final safety analysis report will be required in order to obtain an operating license. A condition for granting the operational license is that during construction, the safety analyses are updated to reflect any changes arising due to design changes. Such change proposals will be subject to power plant developer approval and where appropriate submitted to the appropriate authority before the change can be accepted. Commissioning tests will prove the performance of plant and systems in a progressive manner, prior to permission to begin commercial operations. Plans for the physical protection and emergency response arrangements, and a quality management program for operation must be compiled and in place before nuclear operation.

 

 

A complete safety analysis has to be part of the EIA and submitted to Espoo public consultation. The outcomes of the safety analysis need to be considered in the analysis of alternatives. Leaving the safety analysis for later stages only turns it into a mere bureaucratic endeavour, a step in licencing, rather than a requisite of the documentation representing the basis for consultation and decision-making. The EIA needs to be revised so that it includes a complete safety analysis (once the technology has been established), and the outcomes of this analysis must be considered in analysing the alternatives.

 

Page 116

Amounts of ordinary waste generated during the construction of the new NPP.

The exact amounts, nature and volumes are linked to variables that can only be clarified as the project proceeds, such as reactor type and number, final layout of the site etc.

 

It is clear that the EIA team has not had the necessary volume of technical project information in order to properly assess the social and enviromental impacts of the project. It is obvious that clear information is needed in order to do the assessment and that the outcomes need to reflect in the analysis of alternatives. An assessment based on generic data from nuclear reactor providers cannot represent the basis for an EIA. The EIA needs to be revised, at the time that clear technical details are provided to the EIA team.

 

Page 122

The total amount of conventional waste generated every year is around 450–500 tonnes for one reactor unit, 850–900 tonnes if 2 units will be placed in operation.

 

 

The level of uncertainty reflects in the quality of the assesstment. The amounts of waste in this case are estimated for one or two reactors, but previously the assessment considered up to five nuclear units. The EIA needs to be revised, at the time that clear technical details are provided to the EIA team.

 

Page 122

Radioactive waste

Radioactive waste originating from nuclear power plants usually includes spent nuclear fuel, operating waste and the so-called decommissioning waste originating from the decommissioning of the plant.

 

These costs need to be properly addressed and they need to be considered inthe analysis of alternatives. The EIA needs to be revised, at the time that clear technical details are provided to the EIA team.

 

Page 128

Spent nuclear fuel

After SNF is removed from the reactor core, it is stored in storage pools for a certain decay period before SNF could be transferred to off-site facilities for further processing or storage. All NPPs have such spent fuel pools associated with the reactor operations. Recent designs of reactors have incorporated pools that can accommodate SNF generated over periods of up to 30 years. Long-term storage and disposal of SNF will be a subject of an own EIA procedure in the future and this issue is not a subject of this EIA Report.

 

The issue of spent nuclear fuel, or HLW, is clearly part of the nuclear project cycle, and an important part of it. The EIA is not valid if it only covers parts of a project life cycle. Decommissioning and waste management are not less important than the planning, construction and operation of the project. The EIA needs to be revised in order to address these issues.

 

Page 131

Decommissioning plan

During the design stage of the new NPP an initial decommissioning plan should be prepared before the operating licence is issued. The initial decommissioning plan should state in general terms that the plant can be taken out of service, and provide an outline of decommissioning methods and technologies. The initial decommissioning plan must specify the likely quantity of waste and provide an estimate of decommissioning costs.

 

The decommissioning plan needs to be an integral part of the EIA, as decommissioning is an integral part of the project and it impacts project costs and the analysis of alternatives. The EIA needs to be revised in order to address these issues.

 

Page 131

 

Decommissioning cost and fund

Once the reactor has started operation, the core is irradiated, and the primary system components have become radioactive, the cost of decommissioning a nuclear reactor is basically fixed and is permanent.

 

In practice, the nuclear industry has acknowledged the uncertainties related to decommissioning costs and waste management costs, which is why the contributions to specific funds are re-assessed and revised on a regular basis. The EIA needs to be revised in order to address this risk.

 

Page 141

However, there are several factors affecting the reliability of this assessment. First, there can be uncertainties in the estimation of the parameters in water balance calculation due to the limited amount of the hydrological data. For instance, the evaporation measurements have been carried out only in one part of the lake and are therefore not necessarily representative for the whole lake. In water balance calculation for regulated lake the outflow has been estimated based on the difference between total annual input and evaporation, because the actual data of the present outflow from the lake does not exist. Second, the regression equation of the evaporation and NPP capacity is based on evaporation measurements carried out mainly for the effects from 0 to 1 500 MW. The evaporation rate, however, is extrapolated over double (3 400 MW) the original measurement range and hence it includes uncertainties. Therefore the represented assessment should be considered preliminary. A precise hydrological study of the water resources and evaporation rate needs to be carried out as a part of the detailed technical design in the project.

 

The EIA needs to be revised in order to include proper data and assessment regarding the thermal impact of the project, this must not take place at a later project stage.

 

Page 150

In conclusion, eutrophication, the increase of salts content and warming of the lake water interact to influence the habitats and ecosystems of the lake. Despite these changes in the lake ecosystem, the parameters examined still meet the requirements and range within the limit (imperative or guide) values set up by Directive 78/659/EEC and national legislation (Order No. D1-663, 2005) concerning the quality of fresh waters needing protection or improvement to support fish life. The water quality and state of the lake are described to be good and to conform to the quality requirements. All the values are of the same order of magnitude as the ones commonly encountered in surface water bodies.

 

Considering that the old nuclear power plant’s operation has led to:

-          eutrophication of the Druksiai lake (page 144 of EIA)

-          evaporation rates have increased (page 144 of EIA)

-          dissolved oxygen content has decreased (page 145 of EIA)

-          increase of sulphates in the lake water and bottom sediments (page 149 of EIA)

-          the amount of the prevailing plankton species decreased 2 to 3 fold in comparison with INPP preoperation (page 151 of EIA)

-          phytoplankton dominants from the pre-starting period of the INPP and zooplankton species have disappeared (page 151 of EIA)

-          The abundance of metazooplankton decreased more than 2.7-fold and protozooplankton halved during the first two years of INPP operation (page 152 of EIA)

-          the crustaceous species which preferred a narrow range of low temperature and well oxygenated conditions (relicts of the glacial period) have been either completely eliminated or their quantity has significantly decreased (page 154 of EIA)

-          the species diversity in Lake Druksiai decreased from 23–26 fish species (before INPP operation) to the current list of 14 species  (page 157 of EIA)

 

it is clear that the thermal impact of the old nuclear power plant has been far from insignificant. Thus, the fact that water quality parameters meet the legislation requirements is rather irrelevant. The EIA needs to be revised in order to indicate how much further alteration of the Druksiai lake will take place in the case of a new NPP construction, and these estimates need to reflect in the analysis of alternatives.

 

Page 371

These indicators will only present the existing health status. Evaluation of the causes of differences in health indicators of the countries has not been carried out as it would require evaluation of relation of mortality rates with specific co-founders (e.g. radiation, smoking, social factors and similar). Such evaluation has not been included in the scope of the EIA. Health status of the residents in proximity of the existing INPP was not assessed for the above mentioned reasons. Collection of the health data of the representative sample for all three countries would require access to crude statistics and explicit epidemiological study that is not the scope of this EIA.

 

 

As the EIA draws much of its data from the operation of the old Ignalina nuclear power plant, the EIA should look thoroughly into the actual health impact of the old plant. An epidemiological study on the impact of radioactive emissions from Ignalina NPP, at least on a range of 30 km should be conducted and the results should be part of the EIA.

 

 

Yours, Linas Vainius CEE Bankwatch Network national coordinator

 
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