Overview of the EIA procedure for the Paks II nuclear project in Hungary

The Paks Nuclear Power Plant is located on the right bank on the Danube, approximately 100 km south of Budapest. A new project with two reactor units from Rosatom (VVER1200) is planned as an addition to the existing four-block nuclear power plant, Paks-1 that currently generates some 40% of the Hungarian energy production.
The environmental impact assessment (EIA) procedure for this project is currently being conducted. It’s made under Hungarian law, implementing the Espoo Convention (the Convention on Environmental Impact Assessment in a Transboundary Context), the EU EIA Directive (Directive 2011/92/EU on the assessment of the effects of certain public and private projects on the environment) and the Aarhus Convention (the Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters).

In April 2015, Hungary submitted the EIA Report for the transboundary EIA procedure. This EIA Report was prepared in order to identify and evaluate the impact of the planned nuclear power plant technology on the environment. The study was prepared by the project company MVM Paks II Ltd[1], which has submitted its application for the development consent together with the EIA documentation to the competent Hungarian authority, South Transdanubian Regional Inspectorate for Environment and Nature. Today, The Paks EIA process belongs to the Baranya County Government Office.
A few months after the official documents for the EIA procedure have been published, Benedek Jávor, Member of the European Parliament and of NTW, obtained secret documents. On our website[2], he declared that the MVM documents contain fundamental mistakes. The grid integration was not modelled as would have been necessary. The construction was not budgeted and planned, as would be needed at this stage of implementation. The analysis completely ignored external factors like the application of the EU competition law. The thermal pollution of the Danube caused by the cooling water was miscalculated.

To better analyse the EIA report, several expert assessments have been published:

Download: Expert statement on the Environmental Impact Study (EIS) of the PAKS II NPP
by Oda Becker, commissioned by Greenpeace Germany, October 2015.
The independent nuclear expert Oda Becker was commissioned by Greenpeace Germany to prepare an Expert Statement on the EIA report. The objective of the assessment was to investigate whether the information presented in this study is reliable and sufficient to determine the potential risks for other countries, in particular Germany. This expert evaluation comes to the following conclusion: “The content of the EIS was found to not to be in line with the EIA Directive general requirements and IAEA specific recommendations. Much additional information is necessary to assess the possible consequences of the Paks II for Germany. However, the information at hand indicates that a severe accident with a major release and consequences for Germany cannot excluded.”

Download: summary of Expert analysis on the environmental impact assessment documentation (EIAD)
by experts commissioned by Benedek Javor, Member of the European Parliament and NTW, November 2015.
The conclusions of the expert analysis reveal that the EIAD is extremely low-quality; it is based on false data and false assumptions and has very little to do with reality.
Zsuzsanna Koritár, expert of Energiaklub and member of NTW, also pointed out the main deficiencies of the EIS, such as the unresolved problem of radioactive waste and spent nuclear fuel, the inadequate analyses regarding nuclear safety, the heating problems, as well as the lack of alternative energy scenarios.

On 7 May 2015, public hearings were held in Hungary, Paks and in Autumn 2015 all over Europe (Germany, Ukraine and Austria).

Find feedbacks from NGO representatives:

Public hearing in Paks, Hungary
According to Jan Haverkamp, the Paks hearing did not fulfill EIA and Aarhus specification, some of the reasons being the restrictions for participation of citizens and NGOs and the fact that only short questions were allowed during the hearings.
Download: Comments on the environmental impact assessment implementation of new nuclear power plant units at the paks site made by MVM Paks II
By Ir. Jan Haverkamp,
expert consultant on nuclear energy and energy policy for Greenpeace in central and eastern Europe, qualified member of NTW
+ Addendum

Public hearing in Vienna, Austria
On 23rd September 2015, a public hearing for the planned new reactors in Paks was held in Vienna, with 65 attended people opposing a podium of 20 hungarians delegates. The deadline for public participation for Austria has to be prolonged, as 7 additional official documents were published on the MVM website, without have been officially submitted to Austria. Therefore the public was not aware of their existence while participating in the hearing.
Download: Summary of the public hearing in Vienna, transboundary environmental impact assessment NPP Paks II
By Gabriele Mraz, Austrian institute of ecology, member of NTW, September 2015.

Public hearing in Munich, Germany
The public hearing for Germany was held in Munich on 20 and 21 October 2015.
According to Brigitte Artmann, member of NTW, “this public hearing didn’t answer to every raised question, questions still remain open. Further serious questions about the lack of rescue staff in the emergency case were raised. Moreover, 30.000 submissions from Germany demand that German public concerns must be included into the EIA procedure without discrimination. Hungarians will get technical information of the chosen reactor and another hearing with documents in Hungarian language. German NGOs demand the same for Germany.”
Download: Summary of the public hearing in Munich, transboundary environmental impact assessment NPP Paks
By Brigitte Artmann, Greens Fichtelgebirge, member of NTW, October 2015.

Oda Becker commented also that: “On the basis of the known factors and the formally issued, more than 2,000-page environmental impact study, the biggest problem with Paks-2 is that serious accidents involving large quantities of radioactive material emissions cannot be ruled out. From the received reactions of the Hungarian delegation, the picture emerges that they believe that if something is highly unlikely, then it doesn’t have to be, because it “cannot happen”. This is not a modern, not a responsible way of thinking.”

End of November 2015, the European Commission announced the launch of three procedures about the new nuclear power plant in Paks. First, an infringement procedure was launched by the Internal Market Commissioner on the violation of EU public procurement rules. Secondly, the DG Environment decided to further examine the classification of information contained in the Paks documents, as they might violate rules concerning the publicity of environmental information. And lastly, Margrethe Vestager, the Commissioner in charge of competition, drew the conclusion following her preliminary investigation that state aids by the Hungarian government cannot be excluded despite the contrary claims of the government. Therefore, she wishes to have a more thorough investigation on the question.