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PUBLIC ENVIRONMENTAL EXPERTISE

FINDINGSof the Public Environmental Expertise Commissionon the planned construction of a nuclear power station in the Republic of Belarus

NGO “Ekodom”Minsk2010

Members of the Expertise Commission and personal details Ivan Nikolaevich Nikitchenko, chairman of the Public Environmental Expertise Commis-sion, professor, corresponding member of the Belarus National Academy of Sciences, Doctor of Biology, Doctor of Agricultural Sciences, vice-chairman of the State Agro-Industrial Com-mission 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 Environ-mental 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 Coun-cil 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-Ecolo-gical 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 Con-struction 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 Su-preme 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 "Ekoza-shchita!".

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

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

Anton Vladimirovich Astapovich, historian, chairman of the general committee of the Na-tional 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 His-torical 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 Na-tional Sanctuary “Sarochanskie Lakes”.

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

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Legal basis for conducting the Public Environmental Expertise The right to conduct the Public Environmental Expertise in order to examine the project ma-terials 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, BelarusMailing address: P.O. Box 30, 220086, Minsk,telephone/ fax: +375 172118340,e-mail: [email protected] Registered by the Ministry of Justice of the Republic of Belarus on June 21, 1996Certificate 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 Min-istry of Natural Resources and Environment.

Aim of the expertise

The Public Environmental Expertise aims to complement the State Ecological Expertise in ad-opting 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 pro-ject 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;

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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 con-sisted 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, tech-nical 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 po-tential 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 disin-formed. 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

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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].

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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 growAccording 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).

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[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, http://iea.org/). The 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, http://iea.org/).

[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, http://iea.org/).

[8] – According to Platts PowerVision (www.platts.com), 47,000 MW of new wind turbines and only 9,600 MW of coal fired plants and 1,200 MW of nuclear plants have been installed in Europe between 2000 and 2007.

In late 2008, according to the Global Wind Energy Council (GWEC, http://www.gwec.net/), the total global installed wind power capacity was 120 GW, having increased six times since 2000. In 2008 more than 400 thousand people were employed in the wind power industry around the world. The global market for wind power equipment went up to 46.8 billion U.S. dollars.

Table: Total installed capacity in MW, listed according to countries. (Source: European Wind Energy Association and GWEC, early 2009).

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1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 forecast

2010 forecast

7475 9663 13696 18039 24320 31164 39290 47686 59004 73904 93849 120791 140000 170000

[9] – In accordance with their respective national development plans, countries around the world adopted the following goals:Canada’s target value for 2015 is to generate 10% of its total electricity from wind.Germany plans to produce 20% of ist total electricity from wind by 2020.The EU established the goal to increase the capacity of its wind-driven power generators to 40 thousand MW by late 2010, and to 180 thousand MW by 2020.Spain will install 20 thousand MW of wind power capacity by 2011.India will increase its wind power capacity by 4 times compared with 2005. New Zealands plans to generate 20% of its electricity from wind energy.The United Kingdom plans to produce 10% of its electricity from wind energy by 2010.Egypt plans to install new wind-driven power generators of a total capacity of 850 MW by 2010.Japan plans to increase the capacity of its wind turbines to 3,000 MW by 2010/ 2011.

[10] – On December 7, 2009 9 countries of the European Union (EU) signed a joint declaration to unite their wind-driven power generators in the North Sea into one common network. The participants of the new EU energy project are Belgium, the Netherlands, Luxemburg, the United Kingdom, Ireland, Sweden, Germany, Denmark and France.

The International Energy Agency (IEA) forecasts, that by 2030 the demand of wind power capacity will amount to 480 GW.

[12] – “The total share of nuclear power in electricity production decreases” – forecast for the period from 2010 to 2030 (International Energy Agency, World Energy Outlook, 2009. General provisions. Russian translation, http://iea.org/).

[13] – International Energy Agency, Progress with Implementing Energy Efficiency Policies in the G8. OECD/IEA, 2009.

[14] – „Current capacity growth as well as both short and long run nuclear power development will continue to occur mainly through Asia. 8 out of 10 reactors construction of which began in 2008, are situated in Asia. Of 44 reactors to be finished by the end of the year 28 are situated in Asia, as are 28 out of 39 reactors that recently went on line”(From the report of IEAE Director General at the 53th regular session of the General Conference, August 4, 2009).

1.2. There is no tendency towards an increase in energy consumption in Belarus (Directive №3 adopted by the President of the RB, foreseeing a number of measures to save energy, improve energy efficiency of the economy).

In book 11. Part 1 „Justification of investment…“, p. 18-22, 30 the argument goes, that energy consumption in Belarus – both for heating and electricity – will increase. This theory contradicts the one stated in table 24 on p. 57, part 2, book 11 of the same document, which indicates a decrease in energy consumption by 5.5% per year in all former countries of the USSR.

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For no good reason the justification for the construction of the Belarusian NPP omits an analysis of trends in Belarusian energy consumption in the light of energy-conscious behaviour – notably reducing the energy intensity of the GDP, energy-saving measures, etc. This is not consistent with the Directive №3 of the President of Belarus, the relevant resolutions of the government [1] that set specific targets for reducing energy consumption, and with data on reducing energy intensity of the GDP in 1990 and energy consumption.

The capacities of power plants in Belarus date from the 60ies and 70ies of the last century. They are mostly worn out and will need both modernization and an increase in power efficiency (from an average of 29% to 60% for combined-cycle thermal power plants) regardless of the construction of a NPP.

Thus, the modernization of existing power generating capacities in combination with a sustainable reduction of energy consumption will result in the fact that Belarus will be able to meet its needs without even constructing new power plants, let alone NPPs, as soon as in the next decade.

Hence, the stated increase in energy effectiveness of the GDP and energy-saving measures on the one hand, and the modernization of the main power generating capacities on the other hand, combined with the current decrease of the Belarusian population (census data for 2009 compared to the censuses of 1989 and 1999) should prevent a noticeable increase in energy consumption after the year 2020.

Links, quotes:[1] – National Energy Saving Program for 2006-2020. (approved by Resolution of the Council of Ministers of the Republic of Belarus 02/02/2006 №137)- Directive of the President of the Republic of Belarus №3 “Economy and thrift are the main factors of the economic security of the state" of June 14, 2007;- Resolution of the Council of Ministers № 1122 of August 31, 2007.

[2] – From the Directive of the President of the Republic of Belarus №3:To the Council of Minister of the Republic of Belarus and the Belarus National Academy of Sciences: 1.3.1. to present to the head of state a refined version of the Conception on Energy Security and the Increased Energy Independence of the Republic of Belarus, including: a reduction of the energy intensity of the Gross Domestic product to no less than 31 % in 2010, to no less than 50 % in 2015, to no less than 60% in 2020 compared to the level of 2005;to ensure that in 2012 no less than 25 % of electric and heating energy production will be generated by local fuels, secondary energy sources and alternative energy sources, as well as integration of brown coal deposits of Belarusian origin into the heating balance in 2015.

[3] – „In Belarus energy intensity of the GDP is about twice as high as in other developed countries. Compared to the GDP of 1995 the Belarusian GDP of 2008 shows an increase of 2.5 times with no increase in energy consumption. Nevertheless energy intensity of the GDP remains relatively high in comparison to other developed countries. The country is taking measures to reduce this figure. Thus, while at the collapse of the Soviet Union GDP energy intensity was 750 kg of oil equivalent per 1,000 U.S. dollar of GDP, this figure has fallen to 320 kg in 2008. „We need to further reduce energy intensity, e.g. by reducing fuel consumption and its rational use in energy consumption”. First Deputy of the Prime Minister of Belarus Vladimir Semashko at the plenary meeting of the Belarusian Industrial Forum,

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20/05/2009, official website of the Council of Ministers of the Republic of Belarus http://www.government.by/ru/rus_news20052009.html .

1.3. Besides outdated hydrocarbon and nuclear technologies, there are a many other technologies capable of replacing the old output capacities.

According to experts in the field of renewable energy sources (International Network for Sustainable Energy – Europe and the International Academy of Ecology in the report “BelarusVision for Sustainable Energy”; International Network for Sustainable Energy – Europe in collaboration with “Belaya Rus” and other Belarusian NGOs in the report “Sustainable energy vision for Belarus rejecting the use of fossil fuels by 2050") Belarus is able to take part in the global development of renewable energy, since the country does have sufficient potential for the development of renewable and as a matter of fact is already developing them [1;3;4].

Thus wind plants are traditionally used here [2, p. 22]. During a period of 10 years (since 2000) two industrial wind plants with a total capacitiy of about 1 MW, installed in the North-Western part of Belarus (Zanaroch), have proved to generate 10% more energy than similar wind plants in Germany, with a return of investment in less than 10 years and being able to provide industrial current after 6 months from the date of commencement of construction. Although the energy they produce (about 1.5 million kWh/year) amounts to just 4% of the energy demand of the Myadel area, they serve as a good example to show the potential of wind power in North-Western Belarus and a potential scenario for developing regional energy generation without immense investment and environmental risks.

According to the estimates of Vision2050 [1; 3; 4] and [2, p. 25] the residues from plants, wood and livestock can replace 3 to 8 million tons of fuel annually.

Links, quotes:

[1] – Sustainable Energy Vision for Belarus Rejecting the Use of Fossil Fuels by 2050. Possibilities for the use of alternative energy sources in the Republic of Belarus / The International Network for Sustainable Energy (INFORSE) in cooperation with Belaya Rus and other Belarusian NGOs. 2004. 94 p. – online at: http://www.inforse.org/europe/VisionBR-RU.htm

[2] – Chuprov V.A., Bodrov O.V., Shkradyuk I.E. Reduction of the Demand of Natural Gas in Belarus: A Nuclear and an Innovative Scenario. Monography. Minsk, 2009.

[3] – Belarus Vision for Sustainable Energy / International Networl for Sustainable Energy (INFORSE) – Europe and Minsk Division of International Academy of Ecology. November 14, 2008. Document online at: http :// www . inforse . org / europe / pdfs / Belarus - vision . pdf

[4] – A Vision for Belarus Based on INFORSE’s Vision2050 – Background note. INFORSE-Europe 11/11/2008. Document posted on the internet at: http://www.inforse.org/europe/pdfs/Belarus-vision.pdf

1.4. Failure to take into account the need to adapt the Belarusian electric power system to a new large power generating unit.

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Commissioning the NPP will lead to major technical risks in the power system and, in connection with this, to large losses in the economy.

Links, quotes:[1] – Constructing the NPP will mean, that about 20% of the national energy will be generated at this facility. Nuclear electricity generation (2,200 MW) will take up about 70% of the base load (see Fig. 1). This concentration of capacity will result in the fact that almost all gas thermal power stations will operate in peak mode (daily and weekly power surges), which leads to the risk of major accidents in the energy system and to large losses in the economy.

Fig. 1. Typical weekly pattern of electric load of the Belarusian energy transmission system in the heating period (in 2007)

Operating in peak mode is problematic in the long run, since it harms power plants and increases breakdown susceptibility on the whole and of individual elements (boilers, turbines and generators) and also accounts for a number of different repairs. Most accidents happening at plants occur mainly when cold starting them, e.g. boiler explosions, damage to the shafts of the turbine-generator set, fracture of turbine blades, sometimes leading to human casualties. Financial damage of such accidents can amount to tens or hundreds of millions of dollars, as the sad experience of the Sayan-Shushenskaya power plant has shown. Operating in peak mode increases technical risk of both hydroelectric power plants and thermal power plants. In addition to that, construction of the NPP would entail the construction of conventional, non-nuclear facilities for an additional hot standby of 550 MW, costing around 0.8 billion dollars, to compensate for the low flexibility of nuclear power plants.

When nuclear energy generation makes up a large share of total energy generation, it puts the whole power transmission system at risk of power outages, which necessarily accompany the work of nuclear power plants. Unplanned and emergency shutdowns occur systematically leading to collapses in NPP power generation, as it happens, for instance, in Ukraine, see Fig.2.

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Fig. 2 Power generation of the NPP in Ukraine in 2004 taking into account actual repairs. Source: website of the Ukrainian state-owned enterprise "Energorynok".

In Russia there are about 41 unplanned shutdowns every year, of which about 13 are emergency shutdowns (see the annual reports of Rostekhnadzor). That is, up to 1000 MW of power supply are knocked out from one moment to the next 13 times a year. Given the fact that there are 31 industrial reactors in Russia, this translates to a likeliness of 41% of emergency shutdowns per reactor per year. However, in Russia there is the possility to compensate for this knockout by network maneuvers and other actions, whereas for Belarus the fact that emergency shutdowns of NPPs cannot be avoided, will result in serious problems. Even with the availability of hot standby an instantaneous drop of 15-30% of power supply in the power system, that according to the Russian statistics can occur once a year, will pose a significant problem to the electrical system of the country. (E. I. Shirokov, Belarusian Self-sufficiency: NPP or Alternative Energy Sources // Nezavysimaya gazeta, February 9, 2010 appendix “NG-Energiya”. Internet version: http://www.ng.ru/energy/2010-02-09/12_belorussia.html).

2. Construction of the NPP is economically unreasonable.

2.1. Experience in other countries including Russia has shown that nuclear energy is in constant need of significant state subsidies, direct and indirect ones [1].

Links, quotes:

[1] – „Rising costs of NPPs in Russia are artificially controlled, e.g. with the help of numerous subsidies. Since the considerations of Belarusian experts underestimate the scope of subsidies for the nuclear industry, their cost estimates of the NPP are inaccurate. It is essential to take into account at least the following elements of the Russian energy subsidies system:- direct budget subsidies,- foreign aid,- tax incentives.Each year the federal budget of the Russian Federation allocates significant funds to the nuclear industry in the framework of programs such as “Security of the nuclear industry of Russia” and “Security and development of nuclear energy". Annually a total of up to 2.5 billion rubels are allocated through those programs (data for 2004). Additionally approx. 700

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billion rubles will be allocated solely for the construction of new NPPs through yet another program up to the year 2015.(…)Also the fact that physical protection of NPPs and fuel cycle facilities is provided by internal military forces of the Interior Ministry, being employed and payed by the state, represents yet another example of direct budget subsidies. (…)As part of foreign, non-repayable aid Rosatom receives or received funding through the following international programs:- Swedish international project;- TACIS program of the European Commission;- U.S. International Nuclear Safety Program;- nuclear safety program of Great Britain;

In August 2003 Finland alone granted about 300 million Russian rubels to increase safety of the Leningrad NPP.(…)According to the evaluation “What is the cost of nuclear energy” (V.A. Chuprov, Moscow 2004) total subsidies, excluding the contribution of social programs, reduce the the cost of nuclear energy by about 30%."

Chuprov V.A., Bodrov O.V., Shkradyuk I.E. Reduction of the Demand of Natural Gas in Belarus: A Nuclear and an Innovative Scenario. Monography. Minsk, 2009, pp. 35-37.

2.2. Experience with construction of new NPPs (type EPR in Olkiluoto (Finland) and the second unit of Balakovskaya with reactor type VVER-1000) shows that the actual construction costs surpass initial cost estimates, on which economical assessment for the justification of the construction is based, by billions of euros and that it is impossible to build NPPs in the initially projected time frame [1].

Links, quotes:

[1] – „The construction costs of NPPs in Russia are well ahead of inflation. This tendency is in line with global trends.(…)The experience of adding a third unit to the Kaliningrad NPP has shown, that expanding an existing plant by 50% equals the cost of constructing a plant from scratch. Total cost of the entire power generating unit was 35.9 billion rubels as opposed to the projected 16.8 billion rubels, i.e. more than twice as much as the initial estimate.(…)The same goes for the construction of NPPs in Finland an France. In the course of construction the cost of the reactor in Olkiluoto in Finland (1,600 MW) increased from the contracted amount of 3.2 billion euros to 4.7 billion euros, although the project is far from being complete. (…)The increase of costs during construction is a decisive factor in assessing return of investment and profitability of nuclear power projects”.

Chuprov V.A., Bodrov O.V., Shkradyuk I.E. Reduction of the Demand of Natural Gas in Belarus: A Nuclear and an Innovative Scenario. Monography. Minsk, 2009, pp. 43-44.

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2.3. When calculating the costs of nuclear energy, expenses for decommissioning the power plant are not being taken into account, thus passing them on to future generations.

The EIA report on the Belarusian NPP fails to adress measures for decommissioning the power plant and the asssociated costs. At the same time these activities and expenses are considerable and long-lasting. Aside the fact that the world community is lacking sufficiently positive experience in closing power plants, this experience is also lacking in Belarus. The experience of decommissioning single NPPs according to “brown lawn” concept demonstrates the problem of increasing as well as mostly undefined and unaccounted costs [1].

Links, quotes:

[1] – „As a rule economical assessment of nuclear power fails to consider the entire life-cycle of NPPs. (…) From the moment the NPP ceases to operate it transformes from a source of energy and profit into an object which consumes energy and resources. (…) Current data on the cost of decommissioning reactors include a large number of uncertainties related to difference between possible scenarios of decommissioning, the national policy regarding radioactive waste, spent nuclear fuel, the level of technological development in different countries, etc.In a number of countries, state and operating institutions have made such evaluations. (…) However, practical experience of decommissioning shows that the estimates fall short of reality in a significant way. Thus, the costs of decommissioning a NPP with a VVER-440 reactor in Germany were more than twice as much as predicted by the IAEA. The cost for decommissioning 6 reactors of the NPP „Nord“ amounted to 3.2 billion euros. (…) NPP „Nord" will be in the process of decommissioning for 45 years, from 1990 to 2035, until reaching "brown lawn" state, which is when a technology park is planned to be set up at the site of the former NPP. Still not solved is the problem of radioactive waste, which is currently located in a temporary repository (duration 50 years)":

Chuprov V.A., Bodrov O.V., Shkradyuk I.E. Reduction of the Demand of Natural Gas in Belarus: A Nuclear and an Innovative Scenario. Monography. Minsk, 2009, pp. 50-51.

2.4. The estimated cost of nuclear energy does not include expenses for the treatment of spent nuclear fuel, including those for radioactive waste as a by-product of the so-called “nuclear recycling”.

The EIA report on the Belarusian NPP does not consider the treatment of spent nuclear fuel and waste resulting in the process of the so-called “nuclear recycling” – i.e. the process of separating irradiated fuel rod arrays and fuel elements in order to recover individual elements. However, reprocessing spent nuclear fuel is a service that needs to be paid for. According to Russian experts, the market price for reprocessing spent nuclear fuel of the Belarusian NPP can amount to more than 3 billion dollars taking into account the whole period of operating the Belarusian NPP. However, since the plant for reprocessing spent nuclear fuel of VVER-1200 has not yet been built, this in turn evokes costs for storage of nuclear waste and also poses environmental risks for Belarus [1].

Links, quotes:

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[1] – „Russia does not have a plant to reprocess spent nuclear fuel of the VVER-1200 type NPP, that is planned to be built in Belarus.There will be no possibility to reprocess spent nuclear fuel of the Belarusian NPP, since a reprocessing plant for fuel of the reactor type VVER-1200 – the one that is being offered to us – does not exist. Information on plans regarding its projection and construction is not available either. The idea for its construction dates back to Soviet times, when construction work for the plant “RT-2” on reprocessing nuclear fuel including the one of VVER-1000 started at a mining and chemical plant near Krasnoyarsk in 1984, but stopped in 1991. And as early as "In 2005 intensive works regarding the dismantling of buildings of the unfinished RT-2 were taken up, since the envisaged facility, for which planning had been done 30 years earlier, was outdated. According to the former head of „Rosatom“ A. Rumyantsev ”constructing a reprocessing plant for spent nuclear fuel at the mining and chemical plant can be completed no earlier than in 20 years, if at all possible”, - we can read in the report of Vl. Slivyak and P. Dil („Importing nuclear waste, minimal profits – a maximum of radioactive waste”, p. 15).Thus, until the plant is built, the reprocessing technology is clarified and the potential beneficiaries of the reprocessed components can be identified, spent nuclear fuel of the Belarusian NPP will remain waste rather than resource for an undefined period of time.

Russian legislation prohibits the import of radioactive wasteReturning spent nuclear fuel from the planned Belarusian NPP to Russia will not be that easy, since Russian legislation, in particular Art. 48 of the Federal Russian law "On Protection of the Environment", prohibits the import of radioactive waste from foreign countries to Russia for the purpose of storage or geological disposal. The same law does however permit the import of spent nuclear fuel for temporary technological storage and/ or its reprocessing if a general reduction of the risk of radiation exposure and an increased level of environmental safety in the course of the activity can be guaranteed, ensuring by way of priority the right to return the radioactive waste resulting in the reprocessing to the spent nuclear fuel's country of origin or the right to make provisions for its return.Thus, taking into account the absence of a reprocessing plant, "Rosatom" will have difficulties explaining the necessity to import Belarusian spent nuclear fuel. As for the intermediate storage, Vladimir Slivyak comments in his report, that "The state of storage and the capacities of reprocessing spent nuclear fuel still leave much to be desired. To date the nuclear industry disposes of storage facilities for about 1,500 tons of spent nuclear fuel". By the way, one Belarusian NPP would produce exactly as much spent nuclear fuel in the course of its life cycle, but Russia does have its own NPPs after all.And even if at some point in the future Russia will reprocess Belarusian spent nuclear fuel, Belarus, according to Russian legislation, will have to take back the waste resulting in this process, which “will increase by 200 times due to the formation of liquid radioactive waste”, as the Russian “Ekozashhita!” confirms in its statement”.

Storage and transportation of spent nuclear fuel - excessively expensive venturesThe U.S. renounced from reprocessing spent nuclear fuel, having concluded its futility being a venture that is both not profitable and dangerous. The process of reprocessing spent nuclear fuel involves the extraction of plutonium and uranium, both highly radioactive, and produces various radioactive waste, which in turn has to be treated.There are only very few radiochemical plants worldwide – in France and in the UK - that can reprocess spent fuel of pressurized-water reactors. It is highly unlikely that the construction of such a plant will be started in Russia during or after the current financial crisis. Spent nuclear fuel that can be reprocessed does pose a problem in Russia today –

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storage capacities and reprocessing plants are overcroweded with “raw material”, that has not yet found its application. Consequently, it is hard to explain to both investors and states the need for a new and very pricy reprocessing plant, when the existing ones are problematic and not profitable.

„Rosatom“’s service to reprocess spent nuclear fuel may not be affordable for BelarusLet’s assume that a contract on shipping spent nuclear fuel to Russia can be concluded. Then the question arises, why “Rosatom" should be interested in taking the spent nuclear fuel? Sergey Novikov has a straighforward answer to this question: „we are talking about a market service and internationally it is common practice to take on fuel for reprocessing purposes at a negotiated price". Then who is going to subsidize the "recycling" of spent nuclear fuel, which will most probably not take place for quite a long time, and to which extent” Which amounts will Belarus be asked to pay with regard to the waste treatment? Who will be the final beneficiary of this process?Respectively Ukraine’s experience gives an answer to this question, since it is in an identical situation with regard to spent nuclear fuel. „The storage cost of Ukrainian spent nuclear fuel in Russia has increased by 70% since 1995 and to date Ukraine debt to the Krasnoyarsk area (Russia, place of temporary spent fuel storage – T.N.) amounts to about 10 million dollars. Ukraine envisages to stop exporting spent nuclear fuel to Russia and has built a new repository for nuclear waste at the Zaporizhzhya NPP, which permits Ukraine to save up to 250 million Hryvnas per year that have been designated for storage of nuclear fuels". (Vl. Slivyak and P. Dil).According to Russian experts, the market price for reprocessing spent nuclear fuel can amount to more than 3 billion dollars taking into account the whole period of operating the Belarusian NPP”.

Tatyana Novikova. Where will Belarus find a place for the spent nuclear fuel of its NPP? Online newspaper „Belarusian news“, 03/02/2010 at 15:03, http :// naviny . by / rubrics / society /2030/02/03/ ic _ articles _116_166484/

Slivyak V., Dil P. Importing Nuclear Waste. Minimal profits – a Maximum of Radioactive Waste. Moscow, 2005, 70 p. - Document online at:http://www.anti-atom.ru/downloads/report-nwaste-diehl-slivyak.pdf

2.5. The project lacks both assessment of the cost and of the environmental impact of repositories for the disposal of high-level waste including potential waste created by nuclear reprocessing.

The EIA report neither assesses the cost nor the environmental impact of repositories for the disposal of high-level waste including potential waste created by nuclear reprocessing. However, such expenses as well as the assocciated environmental risks are considered an integral part of nuclear energy production. The cost for the construction of repositories for both shor-lived radioactive waste and potential waste created by nuclear reprocessing is considerd to be quite high [1].

Links, quotes:

[1] – „In accordance with plans of the Ministry of Nuclear Energy construction work for a repository for long-term storage of non-reprocessible irradiated nuclear fuel and burial solidified high-level waste is envisaged to start in the Nizhnekansk Granite Formation after 2010. According to data of the experts of the Nuclear Disarmament Forum AG, which also

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include experts of the Nuclear Center of the Russian Federation, the estimated cost of this burial ground amounts to 100 million dollars (3 billion rubles). In seven years of construction this makes up 0.42 billion rubles per year. (…) The cost of a repository for radioactive waste in the U.S. amount to 59 billion dollars“.Chuprov V.A. What is the Cost of Nuclear Energy. Moscow, 2004, pp. 11-12. Report online at: http://www.greenpeace.org/raw/content/russia/ru/press/reports/163305.doc

3. The regulatory framework for nuclear power is inadequate.

3.1. Basic questions regarding it legitimacy are not ressolved.

There is serious concern if it is legitimate to generate nuclear power on the territory of Belarus is legitimate, which, respectively, also extends to a decision on building an NPP.

Art. of the Declaration „On State Souvereignty of the Republic of Belarus" (of June 27, 1990, № 193-XII, adopted by the Supreme Soviet of the Republic of Belarus) and Art. 18 of the Consitution of the Republic of Belarus (with changes and amendments, adopted by national referendum, November 24, 1996 and October 17, 2004) establish: The Republic of Belarus aims to make its territory a nuclear-free zone, and to become a neutral state.

To date Art. 18 of the Constitution of the Republic of Belarus has not been subject to official interpretation according to national procedures. We set forth the available expert positions, which are based on the understanding that generating nuclear energy by way of constructing and operating a NPP puts the following constitutional objectives into question: Belarus as a nuclear free zone. The absence of official interpretation and the existence of contradictory evaluation by experts with regard to the given question can have negative effects on the relization of the planned construction and operation of a NPP. This is why we consider it indispensable to have an official interpretation of this constitutional norm relating to the generation of nuclear energy on the territory of Belarus.

3.2. The regulatory framework of the national legislation shows certain insufficiencies in the field of nuclear power.

Explanatory notes to part 3.1 of the EIA report "Safety aspects. Basic principles and criteria" sets forth the following approach: „The absence of nuclear legislation led to the following approach in addressing the given issue. In accordance with paragraph 1.5 of the minutes of meeting of the interagency commission in charge of coordinating and monitoring the implementation of the main institutional arrangements relating to the construction of a NPP in the Republic of Belarus the State Committee for Standardization has prepared a list of regulatory documents that will be necessary for projecting and operating nuclear power facilities. The list is approved by the chairman of the committee and it is recommended that the obligation of the Russian side to furnish the Belarusian side with the given documents should be reflected either in the Agreement between the government of the Russian Federation and the government of the Republic of Belarus on cooperation on the territory of the Republic of Belarus or in the contract documents” (p. 13).

This statement suggests that when the EIA was handed over for the public environmental expertise the documents “necessary for projecting and operating” the NPP have not yet been handed over to the Belarusian side and that at this point no more than the intention to identify a guarantee for them to be furnished exists. Thus, the EIA can not be conducted in the way it should be.

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The given statement also represents a formal recognition of the fact that significant legal elements do not exist in the legislation of the Republic of Belarus, which is the main legal obstacle to completing the final offical EIA report.

At this stage the work on the EIA should be suspended with a respective justification and with recommendations to the government of the Republic of Belarus regarding the need and obligation to fill the national regulatory framework.

3.3. The Republic of Belarus does not have a law on treatment of radioactiv waste and spent nuclear fuel, which makes it impossible to assess the conformity of the planned project with the respective legislation.

3.4. The existing laws and regulations do not address the issue of full responsility by the operating institution - even if it is the state – for possible damages connected to the work of the NPP.

On p. 34, part 3.1. the EIA report states correctly, that „the primary responsibility for security should be with the person or institution that is responsible for the NPP and for the actions that cause the risk of radiation".

However, in the answers to the questions of the Republic of Lithuania it has been stated, that an operating institution does not exist and that “an operating institution will be determined in 2010”.

Consequently, to date the question of responsiblity by the operating institution is not regulated.

3.5. Existing radiation safety standards fail to take into account the specific situation of Belarus, having been completely affected by the Chernobyl disaster.

3.6. The radiation safety standards do not reflect the latest scientific data on the effects of small doses of radiation.

For many years the international scientific community has shown concern that the radiation that is emitted regularly by nuclear facilities has inherent carcinogenic and damaging effects on chromosomes.

Studies have been published that show an increase of cancer incidence in areas adjacent to reactors, especially among children [1]. It has been confirmed that the risk of exposure to radiation has been initially underestimated by 10 to 100 times. The National Academy of Sciences of the U.S., that has been investigating the risk of low doses of radiation for several years, has come to the conclusion that there is no “safe dose “ of ionizing radiation. Radiation of any intensity leads to serious cumulative risks [2]. In addition to this, the Agency for Environmental Protection of the U.S. officially acknowledged in 2003 that the calculation of acceptable risk for the “average person” does not take into account the fact that children under the age of 16 years face a cancer risk that is 3 to 10 times higher than for adults. Studies by German scientists also confirmed a significant increase (1.5 to 2 times) of the number of leukemia cases among children living in close proximity to NPPs within a few years after the commissioning of the station [3].

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The radiation safety standards do not reflect the German research data on a significant increase of leukemia among children living near NPPs.Links, quotes:

[1] – Laurier D (2008). Epidemiological studies of leukaemia in children and young adults around nuclear facilities: a critical rewiew. Radiation Protection Dosimetry. 132(2): 182-90.

Laurier D, Bard D (1999). Epidemiologic studies of leukemia among persons under 25 years of age living near nuclear sites. Epidemiologic Reviews 21(2): 188-206.

Doll R and Wakeford R (1997). Risk of childhood cancer from fetal irradiation. British Journal of Radiology; 70: 130-9.

[2] - Goossens, L.H.J., Harrison, J.D., Kraan, B.C.P., Cooke, R.M., Harper, F.T. and Hora, S.C. (1997). Probabilistic accident consequence uncertainty analysis: uncertainty analysis for internal dosimetry. Vols. 1 and 2. Joint Report of the US Nuclear Regulatory Commission and the Commission of the European Communities. EUR 16773, Brussels.

[3] - Spix C, Schmiedel S, Kaatsch P, Schulze-Rath R, Blettner M. Case-control study on childhood cancer in the vicinity of nuclear power plants in Germany 2008 Jan; 44(2): 275-84. E-pub 2007, Dec 21.

Kaatsch P, Spix C, Schulze-Rath R, Schmiedel S, Blettner M. Leukemia in young children living in the vicinity of German nuclear power plants. International Journal of Cancer. 2008 Feb 15; 122(4): 721-6.

Kaatsch P, Spix C, Schulze-Rath R, Schmiedel S, Blettner M. 2008. Leukemia in young chil-dren living in the vicinity of German nuclear power plants. International Journal of Cancer. 122: 721–726.

Spix C, Schmiedel S, Kaatsch P, Schulze-Rath R, Blettner M. 2008. Case-control study on childhood cancer in the vicinity of nuclear power plants in Germany 1980-2003. European Journal of Cancer. 44: 275–284.3.7. In addition to this, radiation safety standards are based on the „model” effect of radiation on healthy white men aged 20, ie. the impact on more vulnerable sex-age and ethnic groups (children, women, other races) is not taken into account [1].

Links, quotes:

[1] – Recommendations-2003 European Committee on Radiation Risk. Identified health con-sequences of exposure to ionizing radiation in small doses fort he purposes of radiation pro-tection: Regulating edition, Ed. K. Busby, with participation of R. Bertell, I. Schmitz-Fur-nake, M. Scott Kato and A. Yablokova; translation from English. Moscow, 2004. 218 p. ISBN 5-87317-187-4. – chapter 5 (pp.41-46).

4. The proposed technologies are dangerous.

4.1. The reactor type – a so-called “water-pressurized" reactor - that is being proposed for implementation, is not considered to be sufficiently safe, regardless of "generation". This is admitted by the developers of the Russian version – VVER – of this type of reactor. „Regardless of all the experience that has been gained while working on them,

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water-cooled reactors can never be considered highly safe... It is impossible to create safe nucear energy based on water-cooled reactors", - academy member Valeriy Ivanovich Subbotin, "Reflections on Nuclear Energy", St. Petersburg, 1994, pp. 53, 101).

The probability of accident or even of disaster cannot be a 100% excluded with the proposed type of reacor. The authors of the EIA report identify four scenarios for accident connected with loss of coolant (part 3.1, p. 58, Fig. 1.22) Thus, they confirm that an accident can lead to destroyal of the reactor vessel and destruction of the protective shell and a massive release of radioactivity into the environment.The authors of the EIA argue correctly (part 3.1, p. 30), that “the NPP is associated with specific risks – the potential radiological hazard to the population and the environment in the event of fission products escaping the plant. […] While the NPP is operating, probability of incidents and accidents including severe accidents that involve damage of fuel elements and, in turn, emission of radioactive substances cannot be ruled out. Severe accidents occur very rarely, but at the same time the severness of their consequences is very high, too”. However, the risks and consequences of possible accidents are played down significantly by the authors of the EIA.

Nevertheless the authors of the EIA report contradict themselves and in many places the report contains false allegations about the insignificance of effects of NPPs, sometimes even alleging their non-existence. For instance, in part 8.1, p. 38, they state: „at normal operation of the NPP both human beings and the natural environment are fully protected from radiation effects of the NPP”.

The authors of the EIA promise (part 3.1, pp. 35-36), that in the future “Report (s) on security will have to be provided as evidence when applying for licences and permits, securing the necessary guarantees".

Thus, it is recognized that key information is missing from the EIA, notably it fails to prove:- that protection is optimized to ensure the highest levest of security, that can be realistically achieved; - that such controls on radiation risk are established, that no one will be subject to unaccaptable risk or harm;- that human beings and environment will be protected from radiation losses, today and in future.

Pointing to the fact that „Report(s) on security will have to be provided as evidence when applying for licences and permits, securing the necessary guarantees”, suggests that at present such proves of security do not exist for the planned activity.

The authors of the EIA recognize (part 3.1, p. 62), that: „When projecting the reactor facilities it is impossible to examine and analyse the course of all possible accidents". Thus, once more the fact is confirmed, that it is impossible to completely exclude the possibility of a severe accident or even emergency.

The following statements are of an declarative, unsubstantiated nature (part 3.1, p. 62): „It has been shown that the use of appropriate design limits, currently applied in reactor systems of generation III+ have high levels of reliability. It has been shown that these values of NPP safety are achieved by introducing into the project design guidelines of IAEA safety and fundamental security functions".

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By quoting regulations and „safety principles“ not only is it impossible to prove the safety of "NPP-2006", it is even impossible to prove it is capable of working at all. As long as not a single reactor of the type VVER-1200 has not been built, as long as there is no experimental evidence of its working capacity, it is only words and paper that serve as “proof” of security of the planned project. That is not enough for such a complex and dangerous object.

4.2. The authors’ statement that the project permits to restrict the zone of required protective measures for the population to not more than 3 km is not justified.

The EIA report states that certain “International regulations”, that fail to be further specified by the authors, identify the following areas and their respective size for the protection of human beings from emergencies:- Area of preventive protective measures (3-5 km);- Area of acute protective measures (20 km) – area around the NPP;- Area of restricted food consumption (300 km).

This contradicts common international practice. For instance, the EIA on the NPP Fennovoima (Helsinki, October 2008, ISBN 978-952-5756-05-0) states on p. 24 that: „Severe accidents of the NPP may have impacts up to a distance of 1,000 km. Short-term restriction - for not more than a few weeks - may be necessary up to [...] a distance of 1,000 km from the NPP site. … In accordance with recommendations of the authorities, children should take iodine pills up to a distance of 100 km of the place of accident in order to limit the dose on the thyroid gland.

The figures stated in the EIA do correspond to the current regulatory documents regarding the distance of nuclear power plants from inhabited localities. But Chernobyl was situated at a distance of 16 km of the NPP and nevertheless its population had to be evacuated following radioactive contamination, and same goes for the town Pripyat. Inhabited localities at a distance of 50-60 km or more from the Chernobyl NPP were evacuated completely or in parts. In the given case the NPP construction is planned in an area including fairly big centers of population, the existence of which somehow fails to be reflected in the table "Characteristics of the construction conditions in the neighboring areas": Oshmyany, Smorgon, Lyntupy, Shvenchenis, Shvenchenlyay, Pabrade, Naroch etc. In the case of an accident similar to the Chernobyl disaster those centers of population may be subject to resettlement. Same goes for Vilnius, capital of the Republic of Lithuania, a city with a population of more than 550 thousand (with surrounding areas almost 850 thousand people).

The calculation of the impact of projected accidents fails to account for both the possibility of spatial distribution of radionucleides in the environment according to the characteristics of the landscape – as it was the case releases of the Chernobyl NPP – and the significant impact of atmospheric transport of radionuclides.

On this basis the authors of the EIA come to the unjustified conclusion that there is no need to plan for an emergency evacuation and appropriate protection of the population. It is known that in severe accidents evacuation of people from places at a distance of tens of kilometers from the place of accident becomes necessary.

Stating that there is no need for evacuation and resettlement of population in the case of accident can lead to the fact, that should a severe accident occur making evacuation inevitable, respective services, forces and means to accomplish it would not be available.

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4.3. The new type of reactor system (VVER-1200) envisaged for "NPP 2006" has so far not been built anywhere in the world and, therefore, has not been tested in practice. Having increased reactor power to 20 % and many innovations make it differ significantly from the reactor prototype (VVER-1000). Belarus is offering to become a testing ground of „Rosatom”.

The authors of the EIA report, that plans for serial productions of “NPP-2006" will only be developed “some time in the future” (part 3.1, p. 26).

The Russian OAO „Atomenergoprom“ (open joint stock company „Nuclear energo-industrial complex”, http://www.atomenergoprom.ru/nuclear/actual/actual1/ ) states that Russia has not yet made a choice in favour of one of the two competing projects of "NPP-2006". Two nuclear power plant projects of the type „NPP-2006” have been developed: Novovoronezh NPP-2 (general designer is the OAO "Atomenergoproekt, Moscow) and Leningrad NPP-2 (general designer is the OAO Sankt-Petersburg Research and Design Institute “Atomenergoproekt”). It seems that only after construction and commissioning of these two NPPs will it be decided on the basis of the operating experience, which of the two projects will go into serial production.

The Belarusian Ministry of Energy however has already made its choice in favor of the project of the OAO Sankt –Petersburg Research and Design Institute “Atomenergoproekt”. This choice has been made earlier than in Russia. It has been made on the basis of documents, that have been studied, and not on the basis of experience with its operation, which so far does not even exist.

It is worth noting that the technology that is envisaged to be used in the Belarusian NPP, has not been sufficiently tested in Russia to qualify for export (since the requirements for reference set forth an operating period of 3-5 years in the NPP of the supplier). The first Russian NPP of the type VVER-1200 is not expected to go online earlier than 2013.

Three of the four so-called "physical security barriers" have undergone major changes in design: fuel matrix, fuel elements and the reactor vessel. Taking into account that the fourth „physical security barrier", notably the containment shell, has not proved its effectivity in practice, it is fair to conclude that the statements regarding a supposedly high security level of the pilot NPP have not been tested in practice.

The fact that the project "NPP-2006” has to be considered a pilot project can be attributed to the increase in fuel capacity to 20% , but also to the significant construction differences of the reactor plant and the fuel assemblies from the prototypes used in “NPP-92” and other types of NPPs.

Main differences of reactor plant VVER-1200 from VVER-1000 (EIA Report, chapter 8.1, pp. 89, 90): the reactor vessel is 300 mm longer due to an increase in the length of the bearing shell; the diameter of the reactor vessel has increased; the shaft inside the cylindrical part of the vessel is 300 mm longer; the location of the holes in the perforation zone of the cylindrical part of the shaft has been changed;

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in the cubicle the coordinates of the location of holes and the diameters of the longitudinal channels of the cubicle itself have been changed; changes are foreseen in the unit of protective tubes changes are foreseen in the upper part of the reactor.No evidence is presented that the reactor can reach 50-60 years of operating time.

The developers have chosen to use the fuel assembly of the type TVS-2M for the "NPP-2006". (EIA Report, chapter 8.1, p. 92) In comparison with the prototype TVS-2M the following significant changes have been effected:

the fuel rod array has been elongated; the fuel column is higher by 150-250 mm; the construction of the backend has been changed the layout relating to the position of fuel and absorber has been changed.

In addition to this the enrichment of fuel has been increased to 5%.

To date TVS-2M is being operated in pilot mode on one reactor block of Balakovskaya NPP, but has not been adopted for widespread use. Hence, even an immensely important safety element such as the fuel rod array is not yet being operated industrially, but only in pilot mode.

Fig. 20 (EIA Report, part 8.1, p. 98) shows, that to date the development of the elements of the nuclear reactor core of NPP-2006 is not complete: bench tests of fuel rod array and FS CPS have not been carried out, material and dimensions of the absorber have not been verified, corrosion and radiation resistance of the zirconium alloys has not been validated.

A new steam generator, PGV-1000MKP, is proposed for the NPP (EIA Report, part 8.1, p. 100), the outer diameter of which has been increased by 200 mm compared to the prototype PGV-1000M. No evidence is presented that the steam generator can reach 60-60 years of operating time.

Part 8.1 of the EIA report (p. 102) states that a pilot reactor coolant pump unit, GTSNA-1391, will be used in the NPP. It differs from the prototype GTSN-195M as follows: it uses a new radial-axial water-lubricated bearing; the powering system of the block seal assembly has been transferred to a passive supply system of chilled water in the primary circuit; sealing of the load pump, that is not connected to the sources for emergency power supply; the flow part of the pump is placed in a spherical shell with guide vanes.

Life tests of the unit of 6,130 hours duration did not reveal any signs of erosion on the pair of bearings; likewise the new construction of a plate clutch has been tested in the course of 3,000 hours while working on natural stands during the testing of the assembly. However, this is not enough to justify the claim that the average time to failure of the new unit will be 70,590 hours.

Both the steam generator PGV-1000MKP and the main circulating pump unit TSNA-1391 are only used in the planning of nuclear reactor projects for construction of NPPs and no experience proving that it can be operated without accidents on existing NPPs exists.

The EIA Report constantly substitutes the analysis of the proposed pilot project "NPP-2006" by providing information on other types of NPPs that really have been tested in practice. This

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may mislead the decision makers. Examples for this practice are abundant. Very often data on NPP-92 with the reactor type VVER-1000 and other types is cited. In part 3.1, p. 50, Fig. 1.18 provides an overview on the localization of the safety system on a NPP of type VVER-440, whose main elements are (9) the gasholder localization and (14) the perforated sheet, devices that are simply not foreseen as parts of the NPP-2006.In part 3.2, p. 27, section 2.6 „Information on expert evaluations in international competitions" the project "AES-92" with the reactor type VVER-1000 is cited. In the same part, p. 30, in section 2.7.6 “The values of reactor core damage frequency” the elaboration is again only about AES-92. This list can be extended.

As a rule, information on the testing of new parts is missing in the EIA Report. It is being substituted by theoretical calculations and research models. To give an example (part 3.2, p. 35): „The efficiency of newly developed individual equipment (for instance, injection devices in the system of emergency cooling of the reactor core), is being confirmed by calculations and experimental research on models with the rationale for transfer of results to full-scale devices.

For a reliable evaluation of the efficiency and safety of complex new devices and equipment it is necessary to have operational experience and not just calculations and models.

5. Possible impact on environment and human health of the given project is not acceptable.

5.1. The particularity of Belarus as a country, in which the population has suffered most severly from the the effects of the Chernobyl disaster, is failed to be taken into account. Existing international and national radiation safety standards do not take into account the specific situation of Belarus as a country, that has been exposed, still feels and will continue for a long time to feel the impact of the Chernobyl disaster, the effects of which have proved to be more severe and and protracted than anticipated by all predictions.

Hence, Belarus is one of the three countries, that have suffered that have suffered most from the Chernobyl disaster. Almost the entire territory of Belarus was covered by the Chernobyl cloud. 23 % of the country (47 thousand km2) was contaminated with cesium-137 of more than 1 Ci/km2.

In the affected areas radioactive contamination was dangerously high. Even if the present contamination intensity is low, the excessive contamination of the first weeks after the disaster and chronic low contamination lasting for decades has had and will continue to have a significant impact on public health and environment in the decades to come.

All areas affected by radioactive fallout from Chernobyl show a significant rise in overall sick rate. Among the specific human health disorders caused by additional exposure to Chernobyl contamination, numbers and prevalence of the following groups of diseases increase: diseases of the circulatory system, the endocrine system, the immune system, the respiratory system, the urogenital system, the musco-skeletal system, the central nervous system, the optic apparatus, the digestive system, birth defects and development of abnormalities, thyroid cancer, leukemia (blood cancer) and other malignancies (the list is far from being exhaustive).The additional „Chernobyl“ mortality has already amounted to hundreds of thousands of casualties. The number of victims of the disaster will continue to grow for several generations [1, pp. 283-289].

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As shown by numerous independent studies, compiled by the European Committee on Radiation Risk (ECRR), the existing model of the International Commission on Radiological Protection (ICPR), which serves as the basis for the current regulatory frameworks, is inaccurate. In many cases this risk model provides 100- to 1,000-fold distortion. To date the maximum permissible exposure of the population is considered to be 1 mSV per year. According to the evaluation of the ECRR, the "total maximum permitted dose from all anthropogenic resourses should not exceed 0.1 mSV for population, and 5 mSv for staff. This should significantly limit the operation of NPPs and reprocessing plants for spent nuclear fuel" [2, p. 191].

Repeated exposure to anthropogenic radionuclides of areas, where Chernobyl contamination exists, is considered to pose an inacceptable risk to the population of Belarus, since it can lead to a significant increase in sick rate.

Links, quotes:

[1] – Yablokov A.V., Nesterenko V.B., Nesterenko A.V. Chernobyl: Human and Environmental Consequences of the Disaster. - St. Petersburg: Nauka, 2007. – 376 p.: - ISBN 978-5-02-026304-8.

[2] – Recommendations-2003 European Committee on Radiation Risk. Identified health con-sequences of exposure to ionizing radiation in small doses fort he puproses of radiation pro-tection: Regulating edition, Ed. K. Busby, with participation of R. Bertell, I. Schmitz-Fur-nake, M. Scott Kato and A. Yablokova; translation from English. Moscow, 2004. 218 p. ISBN 5-87317-187-4.

5.2. The implementation of the project will have a dangerous impact on humans and environment, since the NPP will be emitting radionuclides like tritium, radiocarbon, radioiodine, krypton-85.

The EIA on the same reactor type “NPP-2006” being built as second stage of LAES-2 [1], states correctly on p. 145, that a dose of internal radiation from inhalation of radionuclides is divided into 14C (radiocarbon) and 3H (tritium) and that C14 is a critical radionuclide that accumulates in grain.

If the authors of the EIA on LAES-2 take into account the impact of these radionuclides, than their impact as critical, dose-forming radionuclides should equally be considered in the EIA on the Belarusian NPP. However, the EIA on the Belarusian NPP states neither the danger nor the dos-forming charactersitics of these radionuclides.

Links, quotes:

[1] – NPP – 2006. Justification of investment on construction of the second stage of the Len-ingrad NPP-2. Volume 5. Environmental Impact Assessment / Federal Agency for Atomic Energy. Federal unitary state enterprise „St. Petersburg Research and Design Institute “Ato-menergoproekt”. 2009. - 210 p.

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6. Selection of the site is unfortunate.

6.1. The site proposed for the NPP is not acceptable, since it is situated in the in a place with unique natural, historical and cultural heritage. This region is a recreational area for residents of Belarus.

In terms of assessing the impact on cultural heritage the EIA does not meet the requirements of a number of legal documents.

In particular: it does not meet the requirements of the „Instruction on how to assess the environmental impacts of projected economic and other acivities in the Republic of Belarus”, prepared in accordance with the law of the Republic of Belarus “On Environmental Protection” and the law of the RB “On State Environmental Expertise”, which clearly indicates that:a) within the technical scope of the impact assessment the contractor is obliged to provide, among other things, a descriptions of cultural sites (paragraph 31.1);b) the report on the results of the environmental impact assessment should inter alia include a projection of the impact on man-made objects (buildings, architectural and archaeological momuments, other material and cultural values) and assess possible changes in their condition after the start of the planned activities (paragraph 61.6).

The list of objects of historical and cultural heritage in the area of the projected NPP construction that are is presented in the EIA report is incomplete. The information provided includes only certain historical-cultural values within a zone of 30 km around the site projected to accomodate the NPP; this list is incomplete and contains errors (EIA Report, part 2, pp. 51-52; part 8.2, pp. 351-352; part 11, pp. 91-92). Regarding the 30-kilometer zone a list of objects of historical and cultural heritage included in the Register of Cultural Heritage of the Republic of Lithuania is missing (http://kvr.kpd.lt/heritage/). Historical and cultural heritage of the Belarusian part of the 30-kilometer zone, that is not included in the State List of Historical and Cultural Values is in no way accounted for, including movable and intangible heritage.

The EIA provides no information neither on the conduct of archeaological research in the area projected to accomodate the NPP nor on its result. This suggests a tardive or incomplete fullfillment of the Regulations on the Protection of Archaeological Sites during excavation and construction works.

It does not comply with paragraph 8.2.6 of TKP 098-2007 on the execution of a historical and archival search of indications for past earthquakes with a view to collecting additional data on the most powerful earthquakes of the area that is to accomodate the NPP along with data on their destruction force relating to the period preceding technical measurements. The only specified source of information on seismic characterization of the place to accomodate the NPP is the Progress Report on the Work of the “Complex of seismotectonic studies on the Ostrovets point and the area of projected for NPP accomodation" Stage 19.3 „Preparation of a generalized seismotectonic model of the region of place and area projected for NPP accomodation at 1:100,000 to 1:50,000. Belarus National Academy of Sciences, Institute for Nature Management, Center of Geophysical Monitoring”. (EIA Report, part 4.1, p. 28). As far as it can be established, the authors of the EIA acquire information on the earthquake in the Ostrovets region in 1908 from later publications (see for instance the article of the geologist Boborykin, Garetsky and others [2]), which cannot be regarded as an independent historical and archival research of the Ostrovets region. The following further indicates, that the

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requirement of TKP 098-2007 has not been fullfilled: „Description of past earthquakes should be carefully documented, indicating the source and its whereabouts".

It does not comply with paragraph 9.4.3.1 TKP 099-2007 in as far as: the EIA Report does not provide a photo montage depicting the view of the NPP in the landscape setting.

The report denies any impact of constructing and operating the NPP on the historical and cultural heritage. However, according to our assessment this impact will be significant.Construction of the NPP will fundamentally change the cultural landscape, since “the buildings of the plant significantly differ from the environment both in size and nature, thus creating a new visual landmark, which will dominate the wide and open landscape and change character, hierarchy and uniformity of the natural environment” (EIA NPP Fennovoima [1], p. 240). Water-cooling towers of 170 meters height and with a diameter of the mouth of the tower of 86.8 meters will be the highest build-up structure in the area of NPP accomodation and will become the main visual reference points of the terrain. The nature of the landscape will be irreversibly changed from an agricultural and natural to an industrial setting, since in addition to the reactor blocks with tall vent pipes (height no less than 100 m) and evaporative cooling towers there will be built: high voltage power lines, new railway lines of 32 km, a new road, an asphalt batching plant, “plants for the production of steel construction, pipe spools accompanied by paint, anticorossive and chemical protection work" (EIA Report, part 3.3, p. 7-8); open cast mines will be dug as well as industrial waste and many other industrial facilities will be set up. In addition to that, there are plans for the construction of a “regional center for long-term storage of radio-active waste" (EIA Report, part 3.3, p. 35) at a place outside the station that is not being further specified (possibly within its close proximity).

To date the area foreseen fort he accomodation of the NPP has a high recreational potential thanks to the presence of a rich cultural heritage and a natural environment that is relatively unscathed from industrialization and urbanization. This is also recognized in the present report: „The area for construction of the NPP and the 30-kilometer zone surrounding it is located within the Poozerie province of glacial lakes, morene and hilly-morene-lacustrine landscapes, which have a high potential for recreation and wellness due to ther aethetic, bio-climatic and environmental qualities” (EIA Report, part 8.2, p. 361). Obviously the construction of the NPP will undermine the existing recreational potential. Because of ordinary and extraordinary radioactive releases from the NPP, tourists will become reluctant to visit the area accomodating the NPP and this will cause significant economic losses. Developing rural and ecological tourism will be virtually impossible. The coast of the British county Cumbria is a good example for the losses in the touristic industry, being the place of the lamentably famous Sellafield complex, that in the course of extraodinary and accident release even affected the East coast of Ireland.

Links, quotes:

[1] - Environmental Impact Assessment Report for a Nuclear Power Plant / Pöyry Energy Oy. Helsinki: Fennovoima Oy, October 2008. ISBN 978-952-5756-05-0.

[2] – Boborykin A. M., Gareckiy R. G., Emelyanov A. P., Sildvee Kh.Kh., Suveyzdis P. I. Earthquakes of Belarus and the Baltic states // Current status of seismic observations and their generalizations (Methodical studies of the European Clearing Case House. Issue 4). Minsk: Institute of Geology, Geochemistry and Geophysics, Academy of Sciences of Belarus, 1993. pp. 29-39.

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6.2. Additional exposure to nuclear power would exacerbate the increased sick rate of people that is typical for the region.

Statistical data provided in the EIA Report describe the increase of the sick rate in the Grodno region is 2-3 times higher than on national average. In the period of five years (2003-2008) the incidence of blood diseases increased by 51.9% at a national rise of 31.9%. The incidence of diseases of the endocrine system increased by 50.9% compard to a national rise of 27%. The frequency of congenital anomalies increased by 81.3% compared to a national rase of 17.7% [EIA Report, part 5.1, p. 14].

Birth-rate in the Ostrovets area was 11 persons per 1,000 in 2008, which complies with the average national indicator. However, death-rate in the same year was 16.7 persons per 1,000, which is significantly higher than the national average. Deaths outnumber births by almost 51.8%. This is significantly worse than the average national population reduction.

In the neighbouring Myadel area primary cancer incidence increased by 55.8% between 2004 and 2008 [EIA Report, part 5.1, p. 16].Even when „normally“ operating, NPPs emit man-triggered radionuclides into the envrionment, which even at so-called low doses of exposure result in additional cases of malignant neoplasms, a higher frequency of infant mortality, inheritable genetic defects, an increased overall mortality crate and premature aging of the population [1].

As a result of the combination of man-triggered radiation and other causes of morbidity a further deterioration of the epidemiological situation can be expected.

Links, quotes:

[1] – Recommendations-2003 European Committee on Radiation Risk. Identified health consequences of exposure to ionizing radiation in small doses for the puproses of radiation protection: Regulating edition / Ed. K. Busby, with participation of R. Bertell, I. Schmitz-Furnake, M. Scott Kato and A. Yablokova; translation from English. Moscow, 2004. 218 p. ISBN 5-87317-187-4.

6.3. Using water from the river Viliya for the NPP can have fatal consequences for wildlife of global implications.

The technical decision to use water from the river Viliya is expected to lower the river level by 3%. The EIA Report, however, does not provide a forecast on the impact of reducing the water level of the river. In addition to this, the EIA Reports lacks information on how the intake of water from the river Viliya will be effected. Experts believe that a scooping channel will be dug, which causes sever spreading of sediments. The EIA does not describe how the digging of a scooping channel will affect the river wildlife. Suspended matter and the mud accumulation of the channel can have negative effects not only on the spawning grounds of salmon, but also of barbel (another object of the red book of Belarus, which is why we consider it necessary to provide a calculation of the damage to fish stocks by increased turbidity.

The technical decision to depose of water that has been used to cool the reactor in the river Viliya (EIA Report, part 4.4 and 4.5, pp. 36-38 and 51-53, section 4.5.2 or 4.6.6 respectively) will lead to thermal pollution of the river Viliya. The EIA Report foresees the disposal of sewage water amounting to 87.6 million cubic meters/year (about 120,000 cubic meters/day)

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with a temperature of +37 °C, which will reduce O2 in the water and lead to a deterioration of the hydrological regime of the river in winter (increasing the power of ice jams). Salmon eggs are only incubated in winter at a water temperature of 3-6 °C. Given the above, we believe that the artificial heating of water can significantly change the behaviour of fish, the incubation of eggs, can couse failure to spawn and disrupt migration. It is therefore necessary to develop additional technical measures, so that used water can be cooled down to natural temperature prior to being discharged back to the river Viliya.

Emissions from the NPP (even in normal mode) will result in radioactive contamination of the river Viliya and its water zone. Taking into account that the river Viliya is about the only source of water supply of the capital of Lithuania, such a contamination can be disastrous for the residents of Vilnius and other popluated areas along the water course of the river.

The description of fauna and flora of the region is not complete. The EIA fails to describe preventive measures on environmental protection of the region from "... possible negative consequences" of constructing and operating the NPP. It should be noted, that a protected landscape reserve of national significance – the “Sorochanskie Lakes” – is located at a distance of 8 km from the proposed plant site.

This makes the conclusion of the authors of the project documentation, in which they comment on the prospects of the development of ecotourism in the region in connection with the construction of the NPP, inappropriate (paragraph 10.1.5, part 4.10.1 of the EIA). Worldwide experience shows that in areas adjacent to NPPs ecotourism does have no chance for development.

Thus, the expertise arrives at the general, preliminary conclusion, that the proposed project is inadmissible for Belarus, due to economic, technical, ecological and other reasons.

7. The NPP will not help Belarus in meeting the requirements of the Kyoto Protocol.

The EIA states, that constructing the NPP will help in fulfilling the requirements of the Kyoto Protocol. This statement is unjustified. Indeed, „nuclear activity“ is not included in the mechanisms of the Kyoto Protocol because of ist potential risks and because of the fact, that significant greenhouse gas emissions occur at all stages of the nuclear fuel chain, especially at the stage of uranium enrichment.

The presented justification of the „purity of nuclear power and the absence of ist influence on the greenhouse effect“ does not consider significant aspects.A nuclear power plant serves an entire network of enterprises, from mining and processing of uranium ore and ending with reprocessing and disposal of the waste. Each of these enterprises consumes energy and emits carbon dioxide. Therefore, we should not talk about CO2 emissions of the reactor alone, but of the whole nuclear cycle. Calculations made by U.S. experts indicate, that with the use of relatively rich uranium ore emissions in CO2 make up 20-40% per kWh compared with the cas cycle. This represents a fairly high emission level and should prevent us from talking about “clean" nuclear energy. However, uranium resources face rapid depletion and enrichment of uranium from low-level ore will result in an increase of CO2 emissions. A nuclear fuel cycle beginning with low quality ore producec no less CO2 emissions than a gas station. A study conducted by the Öko-Institut in Germany showed that emissions for a NPP of a capacity of 1,250 MW amount to about 1.3 million tons of CO2 a

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year. Such a level of emissions makes nuclear power a more dirty option, when compared to saving energy, renewable energy sources and steam-gas stations.Moreover, enrichment of uranium is a very dirty procedure. For instance, data of the U.S. Energy Department shows, that U.S. enrichment plants emitted 405.5 tons of CFC in 2001. As it is commonly known, CFCs have a strong impact on the greenhouse effect, but also destroy the ozone layer. In addition to that , one enrichment plant in the U.S., the Paduka plant in Kentucky, consumes as much energy as two 1,000-MW power stations produce, making a significant contribution to CO2 emissions and other pollutants.In fact, nuclear power can only divert precious resources from the expansion and commercialization of existing technologies to reduce the emissions of greenhouse gases [1].Links, quotes:

[1] – False promises / Nuclear Information and Resource Service (NIRS); translated from English. Moscow, 2008. Chapter 1 and 2 (p. 15-21).

Matthes F.K. Nuclear energy and climate change // Nuclear energy: Myth and reality / The Heinrich Böll Foundation; general wording: Felix Christian Matthes. Translated from English. Moscow: Zvenya, 2006. pp. 201-242.

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