Public Environmental Expertise

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PUBLIC ENVIRONMENTAL EXPERTISE

FINDINGS

of the Public Environmental Expertise Commission

on the planned construction of a nuclear power station in the Republic of Belarus

NGO “Ekodom”

Minsk

2010

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Members of the Expertise Commission and personal details

Ivan Nikolaevich Nikitchenko, chairman of the Public Environmental Expertise Commission, professor, corresponding member of the Belarus National Academy of Sciences, Doctor of Biology, Doctor of Agricultural Sciences, vice-chairman of the State Agro-Industrial Commission of the Belorusian SSR (1986-91), chairman of the general committee of the Western regional divison of the All-Union Academy of Agricultural Sciences of the Soviet Union (1987-91), member of the scientific and technical council to the Government Committee for Overcoming the Chernobyl Accident Consequences (1986-91), chairman of the board of the social-ecological association “Support Center for Chernobyl Initiatives”;

Aleksey Vladimirovich Yablokov (Russia), professor, Doctor of Biology, corresponding member of the Russian Academy of Sciences, foreign honorary member of the American Academy of Arts and Sciences, vice-chairman of the Ecological Committee of the Supreme Soviet of the USSR (1989-91), advisor on ecology and health issues to the Russian president (1991-93), chairman of the Government Committee on Sea-based Radioactive Waste Disposal (2002 to date), coordinator and chairman of the Interdepartmental Commission on Environmental Safety of the Security Council of the Russian Federation (1993-96), member of the European Committee on Radiation Risk (2002 to date), vice-chairman of the Scientific Council of the Russian Academy of Sciences on Environmental Problems and Emergencies (2000 to date), founder and president of the Center for Russian Environmental Policy (1993-2005), manager of the Programme on Nuclear and Radiation Safety of the International Socio-Ecological Union (1997 to date).Author of more than 22 monographies, reports and textbooks on popular-scientific and evolutionary biology, ecology and problems of nuclear and radiation safety.Laureate of the international “Nuclear-Free Future Award”.

Georgij Fedorovich Lepin, physicist, professor, Doctor of Technical Sciences, involved in overcoming the consequences of the Chernobyl accident, worked on the destroyed reactor block and in its immediate proximity (1986-92), coordinator and first chairman of the All-Union organization “Chernobyl Union” founded in Chernobyl in 1988, one of the authors of the draft law “On Social Protection of Citizens Who Suffered from the Chernobyl Nuclear Power Plant Disaster”, member of the Government Committee on the Necessity of the Construction of a Nuclear Power Station in Belarus (1998).

Yuriy Ivanovich Voronezhtsev, physicist, Candidate of Technical Sciences, inventor of devices in the field of radiation dosimetry, executive secretary of the Commission of the Supreme Soviet of the USSR to address the causes of the accident at the Chernobyl Nuclear Power Plant and assess the actions of officials in the post-accident period, laureate of the Komsomol Prize of Belarus in the field of science and technology (1986), chairman of the sub-Committee of the Supreme Soviet of the USSR on Environmental Problems in the USSR's Industrial Sector.

Evgeniy Ivanovich Shirokov, Candidate of Technical Sciences, International Academy of Ecology.

Andrey Vyacheslavovich Ozharovskiy (Russia), engineer-physicist, project coordinator of the international group „Ekozashchita!”.

Vladimir Vladimirovich Slivyak (Russia), co-chair of the international group "Ekozashchita!".

Vladimir Alekseevich Chuprov (Russia), manager of the energy section of Greenpeace Russia, Bachelor of Economics.

Nina Evgenevna Polutskaya, ichthyologist, member of the Public Environmental Coordination Council at the Ministery of Natural Resources and Environment of the Republic of Belarus, project leader in the CCB for the preservation of Atlantic Salmon in the rivers of Belarus.(CCB – Coalition Clean Baltic:International environmental organization based in Sweden.)

Anton Vladimirovich Astapovich, historian, chairman of the general committee of the National Council of the NGO "Belarusian Volutary Society for the Protection of Monuments of History and Culture", member of the Public Supervisory Committee for the Protection of Historical and Cultural Heritage at the Ministry of Culture.

Vladimir Vladimirovich Volodin, Master of History.

Elena Borisovna Tonkacheva, lawyer, chairman of the general committee of the Foundation for Legal Technologies Development, member of the Belarusian-Russian Commission of the Council on Civil Society under the President of the Russian Federation (2005-07).

Andrey Aleksandrovich Andrusevich (Ukraine), lawyer, member of the general committee of the Resource and Analysis Center, member of the general committee of the “European ECO Forum".

Igor Aleksandrovich Pastukhov, ecologist, expert on ecotourism, former director of the National Sanctuary “Sarochanskie Lakes”.

Tatyana Anatolevna Novikova, journalist, executive secretary of the Public Environmental Expertise Commission.

Legal basis for conducting the Public Environmental Expertise

The right to conduct the Public Environmental Expertise in order to examine the project materials on the justification of investment regarding the construction of a nuclear power plant (NPP) in the Republic of Belarus is based on:

- Article 61 of the law of the Republic of Belarus (RB) “On Environmental Protection” of November 26, 1992 (as amended on 08/07/2008 № 367-3);

- Minutes of meeting of the Council Bord of the NGO “Ekodom” on November 11, 2009

Information on the non-governmental organization carrying out the expertise

NGO “Ekodom”

Address:14 Ul.Zelenaja, Komarovo, Svir village council, Myadel District, Minsk Region, 222394, Belarus

Mailing address:P.O. Box 30, 220086, Minsk,

telephone/ fax: +375 172118340,

e-mail:

Registered by the Ministry of Justice of the Republic of Belarus on June 21, 1996

Certificate of registration № 01469

The main objective of the NGO „Ekodom“ is the development and dissemination of the concept of sustainable development and of an ecologically sound way of life.

The NGO "Ekodom" is member of the Public Environmental Coordination Council at the Ministry of Natural Resources and Environment.

Aim of the expertise

The Public Environmental Expertise aims to complement the State Ecological Expertise in adopting an objective and well-founded decision regarding the assessment of the NPP project in accordance with article 11 of the Law of the RB “On the State Environmental Expertise” of June 18, 1993, № 2442-XII.

In the framework of the Public Environmental Expertise have been conducted:

- an environmental risk assessment of the project and an assessment of the admissibility of its realization, as well as an exhaustive identification of the foreseeable environmental impact of the planned project design;

- an evaluation of the economic efficiency and of the social consequences of the planned project design.

Material under review

The analytical basis of the Expertise included the following information on the project:

• Material of the Preliminary Report on the assessment of environmental impact of the Belarusian NPP (the Justification of investment regarding the construction of a NPP in the Republic of Belarus.Book 11. Evaluation of environmental impact.1588-PZ-OI4 / Ministry of Energy of the RB.National unitary project research enterprise „BELNIPRIENERGOPROM“.In 11 parts.Minsk, 2009.);
• Materials provided by the State Corporation “Rosatom“ on the project “Nuclear Power Plant-2006” with the reactor system VVER-1200 type V-491;
• Materials posted on the official websites of KB Gidropress, ОАО (Ltd.) „Atomstroyeksport”, OAO “Kontsern Energoatom”, OAO “SPbAEP”, OAO “NIAP”, the State Corporation “Rosatom”,

and other sources related to the construction and operation of NPPs.

Findings of the Public Environmental Expertise

Abstract

The Public Environmental Expertise Commission (hereafter – Commission) concluded that realizing the project is inacceptable due to economical, technical, ecological, legal and other reasons.The justification of investment (JOI) has not been carried out in an objective way and the material used in the Environmental Impact Assessment Report of the Belarusian NPP (hereafter EIA Report) did not include a truly independent view on the effects, but rather consisted of an uncritical reproduction of advertising material produced by the Russian nuclear industry.

Both the material used in the EIA Report as well as those parts of the JOI, that have been at the commission's disposal, were lacking a complete and unbiased evaluation of the impact on the environment and human health with regard to building and operating the nuclear power plant, possible accidents, decommissioning the reactor as well as the impact on landscape and cultural sites, therefore making it inadequate to use it as grounds to justify the building of the NPP.

The authors have not been able to ensure that the material for the EIA Report consisted of up-to-date, comprehensive and accurate information on the envisaged activity and its impact on the environment and human health.Details regarding fundamental aspects of the project design (on the use of natural resources, the scope of nuclear waste, physical parameters, technical characteristics and technology used) that are being evoked by the authors of JOI and EIA Report are contradictory, incomplete and sometimes inaccurate.

No evaluation of the impact of decommissioning the reactor has been made at all.The authors of the EIA Report disinform the public when they relate a possible treatment of radioactive waste and ignore the fact that "permitted" emissions and leakage of radionuclides pose serious dangers to human health.The effects of water-cooling towers on health and environment are not being taken into account.

The description of the environmental impact of the planned activity does not include all potential factors and their possible consequences are underrated.

The materials of the EIA Report fail to describe the envisaged technology of radioactive waste disposal and neither mention the impact of possible accidents involving radioactive waste on environment or human health nor describe the impact of its storage and burial.

Comparisons with other possibilities for eletricity production are faulty, less dangerous and expensive alternatives thus being discarded on the basis of improper justifications.

Consequently both the public and the officials in charge of the decision are being disinformed.The materials in question must be withdrawn and assessment of the project realization on their basis has to be suspended by the contracting entity.

1. Justifying the need to build a Nuclear Power Plant in the Republic of Belarus conducted improperly

1.1. Incorrect assessment of current trends in the development of global electricity production

The explanatory notes to the EIA (*) only refer to data and forecasts of the World Energy Council (WEC), which date from 2005 to 2007. They therefore represent pre-crisis data and need to be adjusted.Moreover, the authors of the explanatory notes to the EIA come to erroneous conclusions, which directly contradict both the WEC’s evaluations they themselves cited and other widely accepted sources, notably the International Energy Agency:

- incorrect and groundless predictions projecting an increase in nuclear energy generation [1];

- denial of the current trend of rapid growth in the renewable energy sector;

- failure to take into account the tendency towards an increase in energy efficiency;

- failure to take into account the projected decrease of global energy consumption from 2015 onwards;

- the conclusions ignore forecasts that do not project a sharp increase in prices for primary energy sources in the coming decade, but rather a trend to price stabilization [1.1].

Furthermore, the justification of the NPP construction fails to analyse tendency and forecasts regarding global energy consumption.

Tendencies in global energy consumption in the years 2007-2009 and forecast for the years 2015-2030:

1.1.1. Even highly conservative forecasts project a reduction in energy consumption growth rates in the years 2007-2010 and after 2015.

Primary energy sources:According to the International Energy Agency, the increase in global energy consumption in the years 2007-2010 is slowing down as a result of the economic crisis and will only take up after 2010 with the return of economic growth.After the year 2030, however, energy growth rates of primary energy sources will slow down [3], [4].

Power consumption:According to conservative forecasts gobal demand for electricity will grow at 2.5 % until 2030, however scenarios taking into acount an increase in energy efficiency do show a lower demand [5].

1.1.2. Renewable energy is developing swiftly and its share will continue to increase rapidly

In 2005 renewable energy sources made up 18 % of the global energy production.The most conservative estimates predict the share of renewable energy in global energy production to go up to 29 % by 2030 [6], [7].Highest growth rates are projected for renewable energy that is not connected to hydropower (according to conservative estimates increasing from 2,5% in 2007 to 8.6% in 2030 [7]).Wind power is expected to experience the most rapid development and will continue to grow up to 2030 as well as in the long run [8], [9].

Along with wind power the market for solar energy in the EU is developing swiftly and will continue to do so in the future.Notably in Germany the market development of solar energy proves to be highly dynamic.

1.1.3. The share of nuclear energy is getting smaller and will continue to diminish in the coming decade

Share and growth capacities of nuclear energy around the world will diminish after 2010 and this trend will continue in the coming decade [2.1], [8], [12].

The developed countries of Europe and Amercia do not envisage to build further NPPs [14].

Even Russia is rapidly cutting down on its ambitious plans on NPP construction year after year, one of the examples being the adjustment of a programme which envisaged to introduce 34 new reactor blocks by 2020 in 2009. Now the discussion goes to introduce those 34 blocks as early as 2030. Moreover, the authors' view that countries in Europe seek to reduce their dependency on petroleum suppliers by way of nuclear power generation does not correspond with reality ( EIA Report, part 2, p. 74). So far no such policy has been adopted by the European countries. The existing transport infrastructer does simply not allow for large-scale substitution of petroleum with nuclear power.

1.1.4. Energy-efficiency in all sectors of the economy has a high potential and will continue to grow

According to the report and forecasts of the International Energy Agency (IEA) the countries of the "Group of Eight" (G8) have been able to realize some of the IEA's recommendations and measures for an increased energy-effciency in 2009 and the data indicates that there is great potential for further increase worldwide [13].

Links, quotes:

* - Justification of investment regarding the construction of a NPP in the Republic of Belarus.Book 11. Evaluation of environmental impact.General provisions.Justification of the need for NPP construction.Explanatory notes.

[1] – „All scenarios identify an increase in the share of nuclear energy.Scenario 4, for instance, describes a revival of nuclear energy in the EU and an increased share of 30-35% in overall power generation by 2050 in proportion to improving economic performance” (EIA Report.1588-PZ-OI4.Part 1.4 Justification of the appropriateness of NPP construction in the Republic of Belarus.1.4.1 General trends in the development of global power engineering, p.18).

[1.1]- As grounds for increasing the share of nuclear energy are considered:

- the depletion of non-renewable, conventional energy sources;

-the increasing competitiveness of nuclear power in connection with rising prices for fossil fuels and coals” (EIA Report. 1588-PZ-OI4.Part 1.4 Justification of the appropriateness of NPP construction in the Republic of Belarus.1.4.1 General trends in the development of global power engineering, p.18).

[2] – WEC data of the years 2005-2007:

„With regard to consumption an average increase of 1.8% annually is being projected and the energy intensity of the GDP is expected to decline at about 1% annually” (EIA Report.1588-PZ-OI4.Part 1.4, p. 23).

„A moderate price developement of energy commodities can be assumed" (EIA Report.1588-PZ-OI4.Part 1.4, p. 25).

„It should be noted, that petroleum prices have been projected to drop below the level of the year 2000 and will not exceed this level by 2030. The price development of natural gas will be commensurate with the dynamics of petroleum prices, since those two fuel types are competing in the area of final energy consumption.Since the known world reserves are extensive and because of the traditional technologies of its use, no changes in the price of coal are foreseen, especially in the long run” (EIA Report.1588-PZ-OI4.Part 1.4, p. 26).

[2.1] – „The share of nuclear energy will increase up to the year 2010 and will stabilise subsequently” 1588-PZ-OI4.Part 1.4, p. 23).

[3] – „The basic scenario shows an increase of global demand for primary energy of 1.5% annually – from 12,000 million tons of oil equivalent (mill.TOE) in 2007 to 16,800 mill.TOE in 2030 – with an overall growth of 40%. This growth is largely taking place in the Asian developing countries, followed by countries in the Middle East.(…) On average demand slightly drops in the years 2007-2010 (…) Accordingly, demand resumes at an average growth rate of 2.5% per year in 2010-2015. As a result of the further development of countries in transition and of the slow-down of growth of the world polulation, the growth rate will slow down after 2015. (International Energy Agency, World Energy Outlook, 2009, General provisions.Russian translation, so-called base scenario, which is the foundation of the IEA forecast, is based on the fact that current trends and the national policies that are connected to them, do not change, i.e. everything remains “as it is”.The scenario 450 assumes the collective adoption of long-term measures to reduce greenhouse gases in the atmosphere to a level of 450 parts per million (ppm) CO2 equivalent.

[4] – World primary energy consumption including petroleum, natural gas, coal, nuclear fuel and hydropower has grown by 1.4% in 2008, which is the lowest growth rate since 2001. (Primary Energy Consumption.British Petroleum,2009).

[5] – „According to our estimates, world demand of electric energy will increase at 2.5% annually up to 2030. More than 80% of growth occurs in countries outside the OECD.(...) China will reach the highest growth capacities (about 25% of the total growth)” (International Energy Agency, World Energy Outlook, 2009. General provisions.Russian translation,

[6] – „In 2005 the global use of renewable energy sources (including hydropower) supplied 18% of the consumed electricity, a little less than 3% of the consumed heating (excluding the use of traditional biomass) and 1% of the consumed motor fuels.The Alternative Scenario of the year 2007 in the IEA's "World Energy Outlook", that is based on the implementation of the strategies and policies under consideration, predicts that in 2030 renewable energy sources will acount for 29% of power generation and 7% of motor fuels” (IEA “Introduction of renewable energy sources”, 2010).

[7] – „The base scenario shows the highest growth rates of renewable energy other than hydropower (wind power, solar energy, tidal, wave, geothermal and bio-energy).Their share increases from 2.5% in 2007 to 8.6% in 2030. The highest demand in absolute terms is expected for wind power.Also, the use of biofuels in transportation increases significantly, hydropower, however, decreases from 16% to 14%" (International Energy Agency, World Energy Outlook, 2009. General provisions.Russian translation,