Attachment to letter ref.________dd_____
of SE NNEGC “Energoatom”
Answers to the Questions of Implementation Committee
CONVENTION ON ENVIRONMENTAL IMPACT ASSESSMENT IN A TRANSBOUNDARY CONTEXT
(Twenty–eighth session, September 11, 2013, Geneva)
Item
Question
1
Has the extension of the
lifetime of the Rivne NPP units
1 and 2 been subject to
transboundary EIA procedure
in line with the Convention?
2
In its response to the
Committee of 15 November
2011, Ukraine referred to a
report covering environmental
impacts (Report on the
frequency of power units
security revaluation”). Has that
report been submitted to the
Ukrainian public for comments
What were the contents of
that report? Did it fully cover
the requirements for the EIA
report as set out in article 5 of
the Convention and appendix
II?
Answer
Current legislation of Ukraine does not provide for development of the transboundary EIA in case of NPP power
unit lifetime extension. Every ten years of operation of NPP power units, with their lifetime extension been
substantiated, the Report on Periodic Safety Review (hereafter –PSR) is prepared, one section of which is called
“Environmental Impact”.
The reference was made to the relevant section “Environmental Impact” of PSR. Specific document for Unit #1
and Unit #2 of Rivne NPP is called “Rivne NPP. Power Unit #1. Report on Periodic Safety Review. Volume
5.Chapter 5. Environmental Impact of the Power Unit Operation. 22.1.145.ОППБ.05. 38-741.203.003.ОБ.05»
and “Rivne NPP. Power Unit #2. Report on Periodic Safety Review. Volume 5.Chapter 5. Environmental Impact
of the Power Unit Operation. 22.2.145.ОППБ.05. 38-821.203.003.ОБ.05”. Composition and contents of the data
provided in the sections of the report comply with normative document НП 306.2.099-2004 “General
Requirements to Lifetime Extension of NPP Power Units beyond the Design Life Based on the PSR Results”. Main
provisions of that section are as follows:
 List of potential radiation sources;
 Limits of emissions and discharges;
 Information on the emission and discharge composition since the beginning of NPP operation;
 The project of monitoring of NPP’s 30-km zone;
 Alarm system in case the allowed values of emissions are exceeded;
 Public awareness of the results of radiation monitoring ;
 Changes in utilization of the territory adjacent to the NPP .
It should be noted that the PSR is not an analogue of the EIA. PRS is a document what justify the safety of
nuclear installations.
The conclusion of state nuclear and radiation safety expertise of PSR was provided for the consideration of the
Public Board of the State Nuclear Regulatory Inspectorate of Ukraine (SNRIU is an authorized body that makes
Item
Question
3
Has the public been consulted
in the process for the renewal
of the license of the NPP for
another 20 years?
4
Which Parties could potentially
be affected? Has any of those
countries requested
information regarding the
project in question?
5
When has the decision been
taken by the State Nuclear
Regulatory
Inspection
to
continue operating the NPP
units?
Answer
relevant decision) prior to the SNRIU’s Board meeting. Furthermore, 9 visiting meetings with representatives of
local self-governments and public of the 30–km zone (control area) were held.
In compliance with the Law of Ukraine “On Decision–Making Procedure Regarding Siting, Designing and
Construction of Nuclear Installations and Facilities of State Importance Intended for Radioactive Waste
Management” the decision on lifetime extension of operating NPPs is taken by the state nuclear and radiation
safety regulatory authority (SNRIU) on the basis of the positive conclusion of the state expert review on nuclear
and radiation safety through amendments in the nuclear installation operating license.
In December, 2010 the SNRIU’s Board meeting was held to consider the possibility of renewal of the license for
operation of Units # 1 and #2 of Rivne NPP. The Public Board meeting attended by representatives of a number
of NGOs (Ukrainian Ecological Association, Association “Doctors of Ukraine”, National Ecological Center of
Ukraine, Public Committee for the National Security of Ukraine) was held prior to the SNRIU’s Board meeting.
The decision on lifetime extension of the power unit operation by 20 years beyond the design life under the
condition of safety review every 10 years was taken at the SNRIU’s Board meeting (representatives of the
above-mentioned NGOs were also invited) based on the positive results of the state expert review of NPP PSR
and comprehensive inspection of Units # 1 and #2 of Rivne NPP, the public position been considered
It should be noted that during preparation for lifetime extension of Units #1 and #2 of Rivne NPP relevant
informational materials were placed in the mass-media of Rivne and Volyn oblasts, radio- and TV programs
were broadcasted live.
PSR materials demonstrate that during normal operation and under potential emergencies at the power units
there is no additional environmental impact in the sanitary protection zone (2.5 km) and radiation control area
(30km) of the NPP, and the thresholds established in safety codes and standards will not be exceeded (It should
be noted that the limiting values are fully compliant with the international requirements as established by the
IAEA). Even in case of the Maximum Design-basis Accident the design concepts of the power units provide for
the prescribed safety criteria. Analysis of the less probable events related to the potential reactor core damage
that can be referred to the hypothetical events proved that adverse environmental impact outside the sanitary
protection zone would be absent in view of all safety criteria. In view of that the impact on the neighboring
countries has not been considered. The neighboring countries have not submitted requests related to the
planned activities on lifetime extension.
The decision was made on December 10, 2010 following the results of the SNRIU’s Board meeting ( See Answer
to Q3 above). Following the Board meeting the license for operation of nuclear installation was renewed to
license activities at the “Operation” stage of nuclear installation lifecycle.
Item
Question
6
Did the EIA documentation
prepared for the authorization
of the original Rivne NPP
address the issue of potential
adverse
transboundary
environmental,
including
safety, impact , in particular in
case of accident? If yes, what
countries were considered to
be potentially affected?
7
Since when has the NPP been
operating? What was the final
decision
permitting
tits
operation?
8
Is there any monitoring in
place for the operation of the
NPP?
Answer
Unit #1 and#2 of Rivne NPP were commissioned in 1980s when Ukraine was a republic of the USSR. At that time
the requirements for EIA development were absent. Environmental impact assessment was considered in the
framework of approval of the design documents for a power unit construction. EIA for the whole NPP site (4
power units) with assessment of transboundary impact consequences under NPP normal operation and
emergency modes was developed at the time of decision-making on construction of Unit #4 of Rivne NPP in
1998. The assessment proved that based on main criteria (level of air pollution; density of fall-out; doses in the
acute period of an accident; doses for 50 years after the accident, risk indicators) the radiation safety in the
Ukraine’s neighboring countries during accident case will be a lot more favorable than that required by the
international regulations.
Power unit #1 and power unit #2 were commissioned on December 22, 1980 and December 22, 1981,
respectively. Permission for power unit commissioning: signed certificate of the state acceptance commission
(in compliance with the legislation in force at that time).
In compliance with applicable legislation several independent types of monitoring are held in the area of the
NPP location. One type of the monitoring is in-house monitoring organized by the operating body (SE NNEGC
“Energoatom”).
A system of NPP radiation monitoring is established and efficiently operated at Rivne NPP. It assures:
- Condition monitoring of the protective barriers;
- Process radiation monitoring;
- Dosimetric radiation monitoring;
- Environmental radiation monitoring;
- Radiation monitoring of non-dissemination of radioactive contamination;
- Radiation monitoring under conditions other than normal operation;
- Radiation monitoring of heating and heated media at the heat supply from the NPP.
Automated radiation monitoring system (ASKRO) is used to execute continuous automated remote control of
radiation situation at the industrial site of the NPP, at the sanitary protective zone, NPP radiation control area
under all operating modes of the NPP, including DBA and BDBA. ASKRO consists of the required equipment and
tools of radiation situation monitoring; process parameter display system, prediction system, tools of local
computer network of Rivne NPP are used. All monitoring posts are equipped with control, communication and
electricity supply means. Modernization of the automated radiation monitoring system was performed in the
framework of construction of Unit #4. In December, 2005 ASKRO laboratory was dignified in the competition
“Leader of the Fuel and Energy Complex of Ukraine” in the nomination “ Environment Protection Project”.
Item
Question
9
What are the reasons for
considering that the extension
of the Rivne NPP does not
constitute a major change?
10
How do you take into account
the stress tests to inform the
decision for the extension of
the lifetime?
Answer
Furthermore, the certified environmental and chemical laboratory that monitors the contents of hazardous
(non-radioactive) substances in the natural environments is operated at the NPP. The results of such monitoring
shall be submitted to the local branches of the Ministry of Ecology and Natural Resources of Ukraine upon
relevant request.
According to the monitoring results actual values of emissions and discharges represent negligible per cent (15%) of the threshold values established for the NPP and agreed upon with the regulatory authority. Thus,
environmental impact for the period of power unit operation does not exceed the authorized safety criteria and
is so small as the design solutions allow.
Laboratories of the regulatory authorities carry out state monitoring for check measurements (in the field of
ecology, health protection, nuclear and radiation safety). Its results confirm the above given conclusion.
The information resulted from the monitoring is included in the NPP periodic reporting documents. For instance,
reports on radiation safety condition are sent quarterly and annually to the regulatory authorities. Also, the
NNEGC prepare the annual evaluation report on the impact of non-radiation factors on the environment in
order to perform supervisory functions, a comparative analysis of environmental parameters of nuclear power
plants, and informing regulatory body, ministries, research organizations, experts and the public about the
environmental safety in nuclear power plants. Тhis information are sent annually to the Ministry of Ecology and
Natural Resources for preparation of the National Report on Environment Safety in Ukraine.
Besides, the information on the monitoring results is placed on the web-sites of NPPs and NNEGC
“Energoatom”.
Positive conclusions of the PSR report and compliance with the safety codes and standards, i.e. confirmation
that operation of the power unit beyond the design lifetime will not result in adverse environmental impact and
deterioration in health of the population living in the vicinity of the NPP constitute a prerequisite for the power
unit lifetime extension.
It is considered during the safety review of the power unit that the power unit will be operated with the main
design –basis technical parameters ( thermal and electrical power of nuclear installation, reactor installation
type, list of main equipment and its features, conditions of special gas and water treatment, norms of allowed
limits of emissions and discharges) unchanged.
In addition, technical activities on upgrading aimed at safety enhancement are implemented at NPP power
units, which also contribute to mitigation of the environmental impact in the framework of existing design basis.
A decision on lifetime extension was taken in December,2010, prior to the accident at Fukushima-Daiichi NPP.
Following Fukushima events, technical specifications for the stress-tests were developed under the WENRA
auspices with participation of Ukrainian experts.
Based on the Ukrainian NPP stress-tests reports the SNRIU of Ukraine issued the National Report submitted for
Item
11
12
Question
According to Appendix II to the
Convention,
the
EIA
documentation should contain
a
description
of
the
environment likely to be
significantly affected by the
proposed activity. In your
response to the Committee,
you indicated that the EIA
documentation for the Rivne
NPP "has unspecified
project term of exploitation"
and "parameters were not
changed". Do you have any
evidence that after 30 years the
environment likely to be
affected by the
activity in Rivne has not
changed?
Is the Government of Ukraine
aware
of
any
complaints/concerns
expressed by the general
public/NGOs at the national
level concerning the extension
of the Rivne NPP?
Answer
the peer review of the European Commission and ENSREG.
Based on the stress-test results additional safety enhancement measures were determined. These measures
were included in the current Ukrainian NPP safety improvement program. The completion date is 2017, the
same as for the majority of the European Commission states. The stress tests results are placed on the ENSREG
web-site
at:
http://www.ensreg.eu/EU-Stress-Tests/Country-Specific-Reports/EU-NeighbouringCountries/Ukraine
Based on the safety re-assessment results, the PSR report concluded that for the existing RNPP units operating
on rated power for the next decade, the values of the design-based radionuclides emissions into the
atmosphere and discharges into the water facilities would not override the permissible values set by the
international standards. However, it should be noted that the periodic safety review is conducted every ten
years and the potential for continuation of further operation is substantiated following the results of this
review.
For RNPP, the EAI Report was developed on the basis of the state civil engineering standards ДБН А.2.2-1-2003
«The content and structure of the materials on the environmental impact assessment (EIA) in case of designing,
construction of enterprises, buildings and structures”. Moreover, the provisions of this ДБН standards were
developed taking account of the Convention’s requirements (specifically, para. 1.11 reads that in case the
proposed activity has an impact on the territories of neighboring countries, EIA shall be performed taking into
account the requirements of the Convention on Environmental Impact Assessment in a Transboundary Context,
which was ratified by Ukraine on March 19, 1999).
The materials of the Periodic Safety Review Report demonstrated that for the last decade the characteristics of
induced radionuclide activities had been shown to be stable and tended to the reduction of contamination. This
allows us to predict the minimum environmental impact of further operation of RNPP power units provided that
the unit is operated in compliance with the effective nuclear and radiation safety regulations and standards, the
technical condition of systems and components of the power unit is kept compliant with the design
requirements and the environmental measures are implemented.
In 2011 the International Charitable Organization ”Environment-People-Law” filed a claim to the Administrative
Court of Kyiv demanding to cancel the license issued by the State Nuclear Regulatory Inspectorate of Ukraine for
the right to perform the activity ”operation of nuclear power units #1 and #2 of RNPP”. The Court dismissed the
claim of the International Charitable Organization “Environment-People-Law”.
Item
Question
13
Please provide information on
how you plan to provide for the
extraction of Uranium and for
the short- and long-term
storage of the radioactive
waste, for the extended
operation period of 20 years.
14
Would
the
Government
implement
the
full
transboundary EIA procedure
provided for by the Convention
for any new NPP? If so, what is
the procedure and the time
frame for the implementation
steps?
15
How many permits are
required in the national law for
the construction/ operation of
a new NPP (explain the
national permitting procedure
for
the
construction/operation of new
NPPs)?
Answer
At the period of the lifetime extension of power units #1 and #2 RNPP the spent fuel system and radioactive
waste management is carried out in full accordance with the procedures reasonable in plant design. Safety has
been confirmed in the PRS, developed in the decision of lifetime extension of these units.
Once the utilization term of nuclear fuel loaded into the core has expired, SF (uranium containing spent fuel)
can be placed in spent fuel pools (which are located near the reactors) for residual heat removal during the
period, which is needed to allow for further safe transportation of SF. Then, loaded into the transport casks, SF
is dispatched to the Russian Federation for further reprocessing. Once the Central Storage Facility has been
completed in Ukraine, the spent fuel from NPP can be sent there for long-term storage.
RAW is temporary stored according to the safety requirements at the special storage facilities on NPP site until
the National RAW Disposal Facility is put into operation.
According to the results of multiple international missions (WANO, OSART), the RAW and SF management
systems are compliant with the international requirements and effective legislation.
General questions on the legislative framework
Yes.
In the context of construction of KhNPP Units #3 and # 4, the following materials were developed, namely: “Part
14 – Assessment of the effects of cross-border transport in normal and emergency modes. Volume 13 –
Environmental Impact Assessment (EIA)” and the Information and Analytical Survey of the materials
“Khmelnytsky nuclear power plant. Feasibility study (FS) for construction of nuclear power units #3 and #4”.
Guided by the provisions of the Espoo Convention, the Ministry of Ecology and Natural Resources of Ukraine
sent these materials to Austria, Hungary, Poland, Romania, Slovakia, Belarus and Moldova in April 2012. In
August 2013 the comments of these countries were received.
In late August – early September 2013 expert meetings with the representatives of Austria, Hungary and Poland
took place .
For the time being, the permitting procedure includes the steps as follows:
1) the Cabinet of Ministers of Ukraine adopts a Resolution on the approval of the feasibility study (FS) for
construction of a new power unit of the NPP that received a positive conclusion of the Comprehensive State
Expert Review. The EIA Report is an integral part of the FS.
2) the Verkhovna Rada of Ukraine (Ukrainian Parliament) passes a Law on siting, designing, construction of a
new power unit of NPP (as required by Ukrainian Law № 2861-IV “On Decision–Making Procedure Regarding
Siting, Designing and Construction of Nuclear Installations and Facilities of State Importance Intended for
Radioactive Waste Management”, dated 08.09.2005). Its draft is being prepared by the Cabinet of Ministers of
Ukraine, and the following materials are to be attached thereto:
а) FS approved by the Cabinet of Ministers of Ukraine (see item 1);
Item
Question
16
Is the construction/operation of
a new NPP subject to national
EIA procedure?
17
Are there plans to construct
new NPPs and/or to extend the
lifetime of existing NPPs close
to the borders with neighboring
countries?
What does the Government of
Ukraine consider as possible
significant
adverse
environmental impacts of a
new NPP? Does it consider that
the impacts of the extension of
18
Answer
b) conclusions of the State Ecological Expert Review;
c) results of a consultative referendum, if any, held in the administrative and territorial units concerning the
siting of a nuclear installation or facility intended for radioactive waste management; or the decision of
central executive authority responsible for the legal status of the territory which was radioactively
contaminated as a result of the Chornobyl disaster, in case they are expected to be located within the
exclusion zone and mandatory evacuation zone;
d) report on actions aimed at informing the neighboring countries about potential transboundary impact;
e) other documents as required by the Law.
3) Once the Law has passed (see item 2) a resolution can be issued by the Cabinet of Ministers of Ukraine,
concerning approval of the design of a nuclear facility;
4) Under the Ukrainian Law ”On the Licensing Activity in the Field of Nuclear Power Utilization» (No. 1370-XIV,
dated 11.01.2000) the license is required for the individual stages of the nuclear facility life cycle, namely: siting,
designing, construction, commissioning, operation and decommissioning.
Yes. The state civil engineering standards ДБН2.2-1-2003 «The content and structure of the materials on the
environmental impact assessment in case of designing, construction of enterprises, buildings and structures”
specify that EIA materials should be developed as a part of the designing documentation for a new build,
extension, reconstruction and technical retrofitting. As for NPP, the EIA materials are developed only in case of
construction of new power units. Also, it should be noted that the above-stated standards were developed
taking account of the provisions of the Espoo Convention (specifically, para. 1.11 reads that in case the proposed
activity has an impact on the territories of neighboring countries, EIA shall be performed taking into account the
requirements of the Convention on Environmental Impact Assessment in a Transboundary Context that was ratified
by Ukraine on March 19, 1999).
The Energy Strategy of Ukraine for the period till 2030 provides for commissioning of 5 power units of NPPs
including KhNPP Units 3 & 4 and another three power units, for which the sites have not yet been selected. The
provision was also made to extend the lifetime of all nuclear power units of operating Ukraine NPPs.
Firstly, NPP are included in Annex 1 to the Espoo Convention.
Secondly, under the effective laws of Ukraine, an NPP is a higher-risk facility and, therefore, the decision on
designing and construction is made and the safety analysis report is developed with taking into account
additional requirements of nuclear and radiation safety along with the fire safety and sanitary & epidemiological
safety requirements. All factors of “possible significant adverse impact on the environment" are considered in
the preparation of project documentation, which includes the EIA and which runs a comprehensive state
Item
19
20
21
Question
Answer
the lifetime of an NPP differ? If expertise.
yes, please explain.
In carrying out activities to extend the operation of nuclear power plants are no "significant changes in activity"
does not occur and, therefore, the EIA is not developed.
At the same time note that the results of the monitoring of the radiation situation in the RNPP control area
shows that the levels of radioactive emissions are minimal, and for the past 10 years do not exceed 1.3% of the
allowable emissions. Discharges of radioactive substances in the last 10 years did not exceed 1.4 %.
Also, Non-radiological impacts associated with the operation of RNPP are within established limits and
normative values and do not have any impact on the ecosystem or around the plant. NPP operation did not
cause any environmental changes that would indicate a deterioration of the environment in the area of the
nuclear power plant as compared to previous years. This allows to predict a minimal impact on the future
operation of power units 1, 2 RNPP on the environment.
What are the requirements set The Ukrainian Law (No. 2861-IV, dated 08.09.2005) “On Decision–Making Procedure Regarding Siting, Designing
by legislation to extend the and Construction of Nuclear Installations and Facilities of State Importance Intended for Radioactive Waste
lifetime of an NPP, e.g. for Management” reads that decision on extending the lifetime of nuclear facilities in operation shall be made by
another 20 years?
the State Nuclear and Radiation Safety Regulatory Body according to the conclusions of the state expert review
a.
Does this require only a on nuclear and radiation safety, through introducing changes to the license for nuclear facility operation (in the
renewal or a prolongation of life cycle stage ”Operation”).
the license? If, in addition,
other permits/decisions are
required by legislation, please
specify.
b.
Is there a possibility to
continue the extension of the
lifetime of an existing NPP
without renewing the license?
In your legislation: what is the The decision-making process is explained in item 15.
final decision for a new NPP?
In your legislation what is "Major changes in the activity" - is, in fact, change the actual object of the project, which requires, inter alia, the
considered a major change in a development of the EIA.
given project or activity? In
absence of legal provisions
setting quantitative indicators,
please explain what is the
Item
Question
procedure for determining “a
major change”?
Answer