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Introduction
This annex is based on the work undertaken by Mouchel Consulting Ltd. who prepared Environmental Impact Assessments (EIAs) for the Khmelnitsky 2 (K2) and Rivne 4 (R4) nuclear power plants (NPPs). The EIAs have been made available by the project sponsor during the public consultation process (see below).
The EIAs set out the policy, legal and administrative framework, details of the existing environments, details of the proposed project including arrangements for radiological protection, and the potential environmental impacts associated with the project, taking into account both normal operation and abnormal conditions. Measures are identified to mitigate possible environmental and radiological impacts.
Environmental Impacts
Assessments of the impacts of predicted discharges from both K2 and R4 during normal operation indicate that the annual radiation dose which would be received by the most exposed member of the public would be substantially less than 1% of the regulatory limit set by Ukrainian regulations. These regulations are consistent with those recommended by the International Commission on Radiological Protection (ICRP).
The annual radiation dose to the population residing within 30km of the NPPs, taking into account the other operational nuclear reactors at the Khmelnitsky and Rivne sites, and assuming normal operations, would also be well within internationally accepted radiological protection criteria. The current use of the cooling reservoir at Khmelnitsky for fish farming could result in an individual who regularly consumes fish from the reservoir and drinks water from the reservoir receiving an annual dose which would be 60% of the limit contained in the relevant Ukraine regulations. It should be noted that the relevant Ukrainian limit for the aquatic pathway is very restrictive.
Transport of fuel will be in accordance with international safety standards which have been designed to ensure a very high level of safety.
An analysis based on consideration of a worst-case design-basis accident at either K2 or R4 - the double-ended rupture of a large primary pipe - has indicated that the consequences of such an accident would be far below the lower threshold for internationally accepted criteria for the implementation of emergency countermeasures. It is considered that it is extremely unlikely that any health consequences would be detected in any epidemiological study undertaken of the population within 200 km of the NPPs, following such an accident.
A comparable analysis has been carried out to assess the potential consequences of a beyond design basis accident (BDBA) in which there would be a major leakage from the primary to the secondary circuit with an open dump valve on a damaged steam generator. Such an accident would have a very low probability of occurrence. There would be no early deaths as a result of the most probable BDBA. The number of delayed deaths from cancer resulting from a BDBA would be extremely small compared with the size of the exposed population and again would be unlikely to be detected in any post-accident epidemiological analysis.
With respect to occupational safety, there has been a significant improvement in recent years in safety culture and in related protection of the workforce at the existing NPPs. Individual and collective exposures of the workforce at the NPPs would be consistent with those that apply to pressurised water reactors (PWRs) in Western Europe. A detailed ALARA (As Low As Reasonably Achievable) approach will be incorporated in the operational procedures of the NPPs to reduce occupational doses still further.
Careful consideration has been given to emergency planning with respect both to the workforce and the surrounding population. Existing emergency plans will be revised and off-site emergency centres completed as part of the Environmental Action Plans.
A further development of the existing systems for environmental and radiological monitoring at the Khmelnitsky and Rivne NPPs will be realised in advance of K2 and R4 being put into operation.
Regulatory documentation dealing with radioactive waste management is currently in preparation together with a national policy on radioactive waste management. The system of radioactive waste management at Khmelnitsky appears well developed and recent installations will allow for increased storage capacity as wastes are further processed and arisings are minimised. Some of the present systems for handling, categorising, processing and storing wastes at Rivne need to be reviewed. Long term plans for waste disposal at both NPPs need to be developed in the context of national policy.
Spent fuel will continue to be stored at both sites for significant periods following the initial three year decay period which is customary prior to fuel reprocessing. Assuming that current proposals for the capacity of the spent fuel ponds at both sites are realised, no significant environmental or radiological impacts are anticipated. A package of regulatory documents dealing with decommissioning is currently in preparation. Prior to commissioning of the reactors, the operator will need to have undertaken an assessment of the different strategies for decommissioning.
Environmental impacts which are not related to radiation exposure may arise during completion and operation of the NPPs. The effects of construction impacts would be reduced due to the 3km sanitary protection zone around the NPPs. Such impacts would be of little significance beyond 3km from the NPPs.
The operation of both K2 and R4 would result in increased water requirements at both NPP sites. The exact requirements and the extent to which they can be met from surface or artesian sources will be further assessed. However, the new water treatment facility at Rivne will greatly reduce the quantity of make-up water for the cooling water system, thus enabling the staation to meet current water abstraction limits from the River Styr. An issue raised at Khmelnitsky was that of replenishment of the cooling water reservoir with water from the River Goryn in years of very low precipitation and very low river flows. A detailed assessment of water use and management will be conducted.
Issues identified in the EIAs form the basis for Environmental Action Plans (EAPs) for the two NPPs. These EAPs are currently being finalised and will be covenanted in the project's loan documentation. The project will also be subject to an Environmental Impact Assessment Report (OVNS), as required by Ukrainian law. Many of the actions included in the Environmental Action Plans will be addressed during the OVNS, which is currently scheduled to begin at the end of 1999.
Public Consultation
Public consultation was undertaken at two stages during the process of preparing the EIAs. Scoping meetings were held at three locations in Ukraine at the end of 1996. The outcome of these meetings was taken into account when defining the terms of reference for the EIAs. A further meeting, which was held in Kiev in September 1997, provided information which was taken into account in the preparation of the EIAs. The second phase of public consultation was carried out by Energoatom between September and December 1998. The EIAs, the results of the least cost analysis, and the Final Safety Assessment Report were made publicly available at no cost to the public and were available in hard copy and on CD Rom. Public meetings were held by Energoatom in Kiev and in two towns near the plants (Neteshin and Rivne). Additionally, Energoatom attended public meetings following requests from Austria and Hungary and responded to concerns raised by organisations and individuals outside Ukraine.
A summary document on the PCP was prepared by Energoatom; it has also been placed in public locations in Kiev, Neteshin and Rivne. A copy has also been placed in the Bank’s Business Information Centre. Issues raised during the public consultation process were taken into consideration in the development of the Environmental Action Plans.
The public consultation process was the first of its kind in Ukraine and has met the Bank's disclosure requirements, a conclusion validated by an independent consultant. Notwithstanding the acceptability of the process, it should be noted that the majority of individuals and groups who were opposed to the project at the beginning did not change their stand during the public consultation process. A number of peaceful demonstrations were held at the Bank Headquarters and at several Resident Offices, and petitions were submitted to the Bank from NGOs regarding the financing of the project.
Alternatives
The EIA methodology required that comparison be made between the completion and operation of K2 and R4 and the "no change option", which assumed that the operation of two of the units at the Chernobyl NPP site would continue following completion of an upgrading and safety programme and that K2 and R4 would not be completed. This comparison has indicated that routine discharges of radioactivity from two units at Chernobyl would significantly exceed those from the operation of K2 and R4. There would also be an increased risk of a catastrophic accident as a result of the continued operation of Chernobyl. This would lead to widespread radioactive contamination. Work is also being undertaken on an initial assessment of the environmental impacts which would be associated with a thermal power sector programme in Ukraine which assumes closure of Chernobyl without the completion of K2 and R4.
Work has also been undertaken to assess the likely environmental impacts which would be associated with a thermal power sector development programme in Ukraine which assumes closure of Chernobyl without the completion of K2 and R4. Coal would be the predominant fuel. This study concluded that the non-nuclear least cost option to K2R4 would involve greater overall emissions of CO2, SO2, NOx and particulate matter. For SO2 and NOx, Ukraine’s emissions would increase by approximately 10% and overall CO2 emissions would rise by 8-10%. There would also be indirect environmental impacts arising from the transport and storage of coal and the disposal of large quantities of ash.
There is an Environmental Impact Assesment available for this project.
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