Environmental Impact Assessment (EIA) for New Reactor Units at the Dukovany Site/CZ

The EIA for Dukovany II was completed with the so-called expert report (posudek) and the positive Final EIA Statement issued by the Czech Ministry of Environment (MZP) in June 2019, which has to be taken into account in the subsequent procedures. More information can be found in the Statement on behalf of Ökobüro and Gobal 2000 for the Aarhus Convention Compliance Committee meeting March 2020.
The expert report includes final recommendations on measures for prevention, exclusion, decrease or compensation of adverse impacts of the construction and operation of the evaluated project on the environment and public health. This list of measures includes 47 so-called conditions that were adopted without changes into the binding Final EIA Statement. The final conditions need to be taken up in the following procedures of the project preparation (mainly siting and building procedure).

The most important problems of the project that became obvious during the EIA are:

  1. A comparative assessment of possible alternatives for energy production was not made. No justification for the need of a new NPP was given.
  2. The safe disposal of spent fuel and radioactive waste is not guaranteed, only future plans were offered without a "plan B" - but what will happen if the planned facilities will not be ready in time?
  3. Seven different pressurized water reactors are taken into consideration as reference projects. But during the tender for NPP Temelín the Czech authorities were looking for a reactor type that was "not first of a kind", meaning a reactor that was already licensed in the EU and which has operational experience. A criterion that is used for Temelín should also be used for the Dukovany project, one could think. But it is noteworthy that the reactors listed in the EIA actually are not in operation, not completed or not even ordered by anyone (Atmea), have been cancelled during construction (AP1000 V.C. Summer NPP), are not safe enough even on paper (KEPCO EU-APR), have not been licensed in the EU (VVER-1200 in Hanhikivi) or have been under construction for decades and are only getting more and more expensive (EPR in Olkiluoto und Flamanville).
  4. Severe accidents were not assessed, only accidents without a containment failure or bypass. But it was not proven in the EIA that such severe accidents could not happen in the reactor types under consideration. If a containment fails or is bypassed, huge amounts of radioactivity could be released and will contaminate large parts of Europe severely.
  5. Even the assessed accidents without containment failure or bypass in the EIA documents show that neighbouring countries like Austria can be contaminated. It cannot be excluded that measures according to the Austrian Intervention Regulation would have to be implemented in border regions, esp. the iodine prophylaxis for children. Moreover, at such contamination levels agricultural countermeasures have to start and losses of harvests have to be expected.

The Final EIA Statement, condition 13, does not take into account the Austrian recommendations during the transboundary EIA. In Austria, iodine prophylaxis for critical groups of persons (children, pregnant women, breastfeeding women) starts earlier than in the Czech Republic. Bilateral consultations of the Austrian and the Czech side during the EIA showed that if the calculated severe accident (DEC) would occur it cannot be excluded that measures according to the Austrian Intervention Regulation would have to be implemented in border regions; in concrete terms this would be iodine prophylaxis, starting for children at 10 mSv dose to the thyroid gland. The respective condition should have been formulated more specific: “the need of sheltering and iodine prophylaxis will be ruled out according also to law in force in neighboring countries in distance greater than approximately 5 km”
Also this condition for the restraining of agricultural production is incomplete. In Austria it is a significant environmental impact if countermeasures like an earlier harvest have to be conducted. The calculated DEC could contaminate Austria up to a distance of 380 km in such an amount that agricultural countermeasures have to start. In a nuclear free country like Austria this is not acceptable and will lead to heavy image problems of the Austrian agricultural products even if the same agricultural contamination would be acceptable in Czech Republic. The condition should be amended to “agricultural countermeasures at a distance of more thann approximately 5 km will not be necessary to be conducted”.

  1. It remains open if the new NPP can withstand attacks with a commercial big airliner.
  2. It is not clear if there will be enough cooling water for all reactors at the site from the river Jihlava or from other water sources, especially in cases of extreme draught, extreme frost or congestion of the supply pipe.
  3. It is still open how the project could be financed.

International Hearing in Třebíč/CZ

On 19 June 2018 an international hearing took place in Třebíč which is situated approximately 30 km northwest of Dukovany. NGOs from Austria and the Czech Republic participated and asked many important questions. Also the Austrian Ministry of Sustainability and Tourism participated, and representatives of the Federal States of Lower Austria, Upper Austria and Vienna. Slowakia, Poland, Germany and Hungary who participate in the transboundary EIA did not send their authorities.

The hearing started at 12h and lasted until nearly 21h. The South Bohemian Mothers were very active in asking questions,and also the Czech Green Party. From Austria, esp. the Waldviertler Energiestammtisch took part and engaged in the debate. A group of people were arguing in favor of the NPP. First, the discussion circled around alleged facts on renewable energies versus nuclear, and on a study on the provision of jobs by the NPP. Austrian NGOs and official were prepared to counter with proven facts on energy production and on advantages of renewable energies. Then the debate moved to nuclear safety and possible consequences on the neighbouring states. Again the Czech side was not able to proof that the reactors in consideration will never suffer a containment failure or bypass. Costs and questions of uranium supply were also discussed.

Non-official minutes can be downloaded here (in German only).
After the event in Vienna and the international hearing the Austrian Ministry for Sustainability and Tourism published another expert statement including results also from bilateral consultations of the Austrian and the Czech side. This expert statement can be downloaded here.

Public information events in Vienna, Budapest and Munich

On 6 June 2018 an information event was held in Vienna, which was not a formal part of the ESPOO procedure due to the Czech EIA-law which does not foresee hearings abroad in the frame of EIA procedure, such an event has the status of a public debate. The Austrian Ministry of Sustainability and Tourism requested the Czech side to consider the discussions at the event nevertheless. A transcript of the event can be downloaded here (only in German).
In Budapest, an information event was held on 3. May 2018. Energiaklub took part and asked critical questions reactor types, the very low source term, nuclear security and water usage.
On 13 June 2018 an information event took place in Munich. Patricia Lorenz participated. Amongst others, questions were asked on the formal status of this event, it was requested that the concerned public in Germany will be able to participate when the reactor type is chosen.

EIA Dukovany II/CZ new NPP - main phase since winter 2017

The company Elektrárna Dukovany II, a.s, part of ČEZ, changed its plans for the construction of the new nuclear power plant at the Dukovany site to one or two reactors with up to 2,400 MWe (not 3,500 MWe as was proclaimed in the scoping phase).
The Joint Project prepared a statement for the Environmental Impact Assessment (EIA).
The Austrian Ministry for Sustainability and Tourism submitted an expert statement that can be found here.

Scoping procedure EIA Dukovany II

The operator ČEZ plans to build one or two new NPPs in Dukovany with an output of up to 3,500 MWe. Operation start is planned in 2035 with a lifetime of 60 years. The NPP site Dukovany is already hosting four VVER-440 reactors. A transboundary EIA procedure has started in August 2016 with the scoping phase. Find here the statement of the Joint Project of Sept. 2016 based on the analysis of the scoping document.

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