Information about the Belarusian Astravets Nuclear Power Plant international environmental impact evaluation2013-09-27
In an effort to inform the Lithuanian public and to secure their opportunity to express their opinions regarding the evaluation of the environmental impact of the nuclear power plant in Belarus, the Ministry of Environment of the Republic of Lithuania has informed the public about the translation into Lithuanian of the Ministry of Natural Resource and Environmental Protection of the Republic of Belarus’ report on the evaluation of the environmental impact of the Belarusian nuclear power plant.
The public and other interested subjects may submit their questions, comments and concerns regarding documents on the evaluation of the environmental impact of the nuclear plant being planned in Belarus by writing to the Ministry of Environment (Ministry of Environment, Jakšto 4/9, Vilnius), by fax at 8 5 266 3663, or by email at email@example.com or firstname.lastname@example.org.
The notification of neighboring nations of the construction of nuclear power plants is required by the United Nations’ Convention on Environmental Impact Assessment in a Transboundary Context (the Espoo convention). According to the Espoo convention, an international environmental impact assessment process must be completed before making the final decision on a nuclear power plant’s location and before beginning construction. The main stages of the environmental impact assessment are the submission of EIA documentation and answers to any primary concerns, public hearings on the project in the countries to be potentially affected, and consultations with experts.
It must be noted that the Belarus nuclear power plant’s environmental impact assessment documents were translated into Lithuanian by the Belarusian Ministry of Natural Resources and Environmental Protection, so the Republic of Lithuania’s Ministry of Environment is not responsible for the quality and content of the documents submitted by Belarus (including any differences from the original EIA documents).
We would like to inform you that, having analyzed the information submitted by Belarus, Lithuania’s responsible institutions (the Ministries of Environment, Energy and Foreign Affairs, the State Nuclear Power Safety Inspectorate (VATESI), the Lithuanian Geological Service, the Radiation Safety Center, the Environmental Protection Agency and others) have come to the following conclusions:
1. The environmental impact assessment documentation submitted in Lithuanian by Belarus does not include the analysis of alternative potential nuclear power plant construction sites, which is required by the Espoo convention.
2. The environmental impact assessment documentation submitted in Lithuanian by Belarus is lacking in quality.
3. The environmental impact assessment documentation submitted in Lithuanian by Belarus has not addressed the following questions from Lithuania regarding the safety of the nuclear power plant in Belarus:
a. Regarding the construction site selection criteria.
b. Regarding the comprehensive and equal analysis of alternative nuclear power plant construction sites (in keeping with Espoo convention requirements).
c. Regarding the suitability for nuclear power plant construction of the Astrava construction site and other potential nuclear power plant construction sites.
d. Regarding seismic studies of the Astrava construction site (earthquakes of magnitudes 5-7 were recorded in the Astrava nuclear power plant‘s territory in 1887, 1893, 1896 and 1908).
e. Regarding the cooling of the nuclear power plant (plans call for the Belarusian nuclear power plant to be cooled with water from the Neris).
f. Regarding the effects on the Neris River, its ecosystem, surrounding territories, and people in the surrounding areas under both normal nuclear power plant operational conditions and emergency situations.
g. Regarding the effects on underground drinking water in Lithuania.
h. Regarding the preparation of emergency plans (especially for the evacuation of Vilnius, capital of Lithuania, in the event of an emergency at the Astrava nuclear power plant).
i. Regarding an independent institution-regulator responsible for nuclear safety (according to the International Atomic Energy Agency, the Belarusian Ministry of Emergency Situations’ Department for Nuclear and Radiation Safety (Gosatomnadzor) does not meet the IAEA’s requirement for an independent institution responsible for nuclear safety).
j. Regarding the assurance of financing for the nuclear plant’s entire cycle – from construction to closure (Belarus plans to build the least expensive nuclear power plant in the world, which is incompatible with the IAEA’s requirements – sufficient financing is one of the IAEA’s criteria for safe nuclear energy development).
k. Regarding the holding of stress tests according to EU methods (although Belarus signed a common declaration with the European Commission on the 23rd of June, 2011 regarding the execution of stress tests for all planned and operating nuclear power plants according to EU methodology, Belarus is not participating in this process).
l. Regarding the management of spent nuclear fuel and radioactive waste (Lithuania has not been given any information about Belarus’ plans to manage their radioactive waste and spent nuclear fuel).
m. Regarding the nuclear power plant’s resistance to commercial aircraft impacts (the protective reactor domes being planned in Belarus would only resist impacts from light sports aircraft (An-2; 5.7 ton aircraft) and are not designed to resist impacts from heavy commercial aircraft or high-speed military aircraft; we would like to draw attention to the fact that, at this time, the airspace above the Astrava construction is a major air transport corridor).
We are unsettled by the fact that in the summer of 2011, a 22-meter-high section of reactor protective dome collapsed at the Leningrad-2 nuclear power plant near Saint Petersburg (Sosnovyj Bor) due to poor workmanship. The reactor’s protective dome is its primary safety measure, which must be able to resist impacts from heavy aircraft and must protect the surrounding environment from radioactive materials.
n. And others.
We would also like to remind you that, in June of 2011, Lithuania submitted a complaint to the Espoo convention’s Implementation Committee regarding possible violations during the Belarusian nuclear power plant’s environmental impact assessment process. In their conclusion, published on the 15th of April, 2013, the Espoo convention’s Implementation Committee stated that Belarus had violated the provisions of the Espoo convention with regards to the nuclear power plant in Belarus. Underscoring Belarus’ violations of the Espoo convention, the committee urged Belarus to submit comprehensive answers to all of the questions raised by Lithuania and to take into account comments made by Lithuania’s experts. The committee also encouraged Belarus to ensure that Lithuania’s public has the opportunity to submit comments regarding the nuclear power plant’s construction.
In its efforts to ensure that the Lithuanian public has the opportunity to prepare for this project’s presentation in Lithuania (for public hearings), the Ministry of Environment of the Republic of Lithuania has at this time submitted a request to Belarus that, by the 1st of October, 2013, it answer all essential questions regarding the safety of its nuclear power plant and submit revised environmental impact assessment documentation according to the Espoo convention’s requirements and the Espoo convention’s Implementation Committee’s findings on the matter.
Documents in english can be found HERE.
Public Information Department