The Czech environmental organizations Calla and South Bohemian Mothers in Ceske Budejovice filed questions to the Czech Nuclear Regulator SUJB. For easier reading the answers are put directly next to the questions.
Questions arrived at SUJB on March 22 2011, the answer letter was dated April 4 2011.
Concerning the information request of the association Calla, which we received on March 22 2011 asking for information on the preparation of a new nuclear capacity in the Czech Republic, we can provide you with the following information within the legally stipulated time:
a) Calla: How and in which time frame will the licence for the nuclear reactor at the Temelin site be granted? Will this process be broader, both in technical and in formal terms, than the granting of the licence for individual activities in line with § 13 of law 18/1997 Coll.?
SUJB: SUJB will assess the permit application for siting und probably also the next phases of the permitting procedure for the new nuclear capacity at the Temelin site, according to the law No. 18/1997 Coll. (Atomic Bill) for the period of permit application, in particular the provisions § 9, § 13 to § 16 and annexes to this law and its implementing laws. It is not possible to predict the time frame for the start of the permitting process , which starts with the siting process according to paragraph 9.1 a) of the Atomic Act, becaus the dates for filing the application are fully in the hands of the applicant, which was not handed in yet.
b) Are there considerations to take over licences granted by regulators abroad, e.g. NRC for the AP-1000 reactor?
SUJB: The Atomic Act does not allow to take over the licencising process conducted and issued by a regulator of another state, i.e. that the licensing process will be performed completely according to the Czech legislation. Part of assessing the permit applicaton will among other criteria also consist of assessing the licence which had been issued for the new nuclear plant in the country of origin, as well assessing the other regulators´ statements on the subject, the authority SUJB will discuss issues on a case to case basis with the other regulators.
c) Will the investor or technology supplier partly contribute in granting the licence? If so, in which form, to which amount and who will receive the money for this?
SUJB: When we leave out the applicant´s general tax duty towards the state budget, then the investor did not make any financial contribution to the licensing activities so far.
d) Please list the laws, implementing legislation, norms, safety standards or international recommendations, which will be applied when granting a license for the technology for the new nuclear power plant.
SUJB: Concerning an overview over laws and implementing laws, we recommend to visit our website, where the section Legislation lists all relevant legal regulations. An overview over the norms and safety standard will be made available depending on choosing the concrete nuclear plant and its country of origin.
e) In which phase of licensing the new nuclear capacity the public participation will be conducted?
SUJB: The assessement of a new nuclear capacity according to the Atomic Act foresees only the licence applicant as participant in the licensing process. The public takes part in assessing this capacity in the frame work of other legal provisions (EIA, building permit process).
The past years saw attempts by SURAO, the Czech Radioactive Waste Repository Authority RAWRA, to find a site for high level nuclear waste, however, they failed because of very strong resistance of the people in the villages chosen as possible sites. They all conducted referenda on yes or no to the site: all were against hosting the Deep Geological Repository (DGR). Currently the Czech Republic is trying an interesting process of DGR search. Contrary to most other DGR programmes, the CR still has geological criteria and seems to be taking them seriously until now.
SURAO, the Czech Radioactive Waste Repository Authority RAWRA, took information of citizens seriously and replied within 12 pages and offered a meeting or even a broader public debate since the inquiry was sent by an NGO. The following text is partly a summary into English, important comments complete the translation of the answers by SURAO. The questions raised by the NGOs are bold, answers follow.
1. Geological criteria for a Deep Geological Repository for highly active radioactive waste und spent fuel.
For this applies the Atomic Bill 18/1997 Coll., SUJB decree 215/1997 Coll. on the siting of nuclear facilities and international conventions, as listed in the Annex to this letter.
According to the Concept for Waste Management until 2025 there are several steps to be taken. E.g. there is a multi-criteria phase of geological assessment to find an adequate site (in the project GeoBariera 2003-2005 or for the projects looking into the question of whether the military zones are adequate or not).
RAWRA prepared criteria for assessing the sites and choosing a main and a reserve site, which are presented in the following documents (4 documents which were available in Czech only, were listed). After the site proved to be safe for storing HLW and spent fuel, the acceptance for the solution by the public – the affected villages, will be tested.
2. What is the current status of the technical project for the Deep Geological Repository?
While RAWRA explains to not be sure what is meant with the term “technical project”, RAWRA explains that they are working with the term “reference project” - a technical project set up for a hypothetical site, which is being constantly updated, now its updating is underway, based on the research and developments done internationally and in the CR. It is referred to as the “reference project 2011.” This project will be the basis for assessing each site concerning the potential site for a DGR and its safety case. The final peer review of the project and complete information of the public is expected at the end of the year, or first quarter of 2012.
The following data on the reference project 2011 can be published for now:
Requirements for spent fuel and highly active waste disposal in the future DGR (reference project 2011):
Origin No. of fuel assemblies:
No. of packaging sets (Packaging set = storage containers):
Area needed for the DGR (reference project 2011)
3. How will the decision on which technology to use be taken? E.g. the storage containers?
The decision on which containers to use is taken by the NPP utility. Currently CASTOR transport containers are being used, which are apt for long-term storage of spent nuclear fuel and its transport to the DGR. For storage the storage containers will be used.
4. Will the safety case for the DGR have to be proven for 1 million years (like e.g. the AKEND process in Germany suggested) or for another time period and if so, why?
The safety will be proven according to valid legislation, taking into account international IAEA and NEA/OECD recommendations. Rather than a concrete period of time, the time requirements are deducted from the contaminant movements in the assessed scenarios.
5. Which studies were conducted in the context of the DGR search in 2005?
A list of those studies can be found in the Czech original RAWRA letter.
6. Are you considering the introduction of something along the lines of the Swedish funding model, which could be used by NGOs and communities for systematic and long-term cooperation in the DGR search?
In the case of the CR no such model is foreseen. This is due to the organisational and legislative framework for the Nuclear Fund (contrary to Sweden, SURAO is a state organization).
SURAO intends to conduct public participation in the process of choosing a site by setting up partnership agreements with the affected communities and their participation in the process of determining a suitable site for DGR. It will be up to the communities to decide upon the form of their involvement. According to this agreement, SURAO will make financial contributions to their participation independently of the form or shape this participation will take place.
7. How will the public and the communities and NGOs will be involved? To which extent can they influence the decision for a specific site and project?
Currently the so called Working Group is preparing these questions. The Working Group consists of representatives of the sites (2 representatives of each site), 1 representatives of NGO, who are according to their statutes active in the protection of interests of life at the site, 2 representatives with nationwide activities. The last two were nominated by the Green Circle.
The Working Group intends to strengthen a transparent process for the site search and taking into account the interest of public.
The Working Group is focused on – quotes from its statutes:
issue of fulfilling demands and possibly necessary modifications of relevant valid legislative documents, e. g.:
The Working Group is an advisory body for MPO (Ministry of Industry and Trade) and MZP (Ministry of the Environment) and its competences include:
As affected we consider:
i. Communities lying in the suggested area, i.e. communities, on whose territory the preparations for the considered site for the DGR are located who are neighbouring;
ii. Citizen initiatives, whose seat and competence lies in the territory as specified in point i.:
This is one way of involving the public, which is already working well. The Working Group had its constituting meeting in November 2010 and its first meeting on February 2 2011. The next meeting is planned for May 17 2011.
The next preparatory forum is the direct participation of the communities (of their appointed representatives) in the process of choosing a suitable site for the DGR.
To answer the second part of your question to which extent the public can influence the decision taking on the future repository, so certainly to a very decisive extent. The solution of course always needs to fulfil the basic demand – demands for the strictest long-term safety. And finally such a solution has to be acceptable for the affected communities, micro-regions and the whole society.