Author Archives: Nuclear Transparency Watch

13th ENEF 04-05/06/18 Bratislava

The 13th European Nuclear Energy Forum (ENEF) organised by the European Commission with two hosting countries (Slovakia and Czech Republic) took place in Bratislava on 04-05/06.

This event, which received the mandate from the European Council to be to be a  “platform for broad discussion of the opportunities and risks of nuclear energy”, focused this year on the topics ‘Maintaining a critical level of nuclear safety expertise in Europe’ and ‘Small Modular Reactors’.

Members from Nuclear Transparency Watch evaluated this year’s ENEF critically. We will keep you informed about our evaluation of the event, but would like to give already access to the presentations from civil society representatives.

Rebecca Harms, MEP Greens/EFA and Vice-Chair of NTW  made an opening speech on the first panel where she emphasised the importance to focus on radioactive waste and decommissionning rather than new build.

To watch her full presentation, see the Webstream of Day 2. (min 13’34”).

Dr David Lowry, independant researcher at Nuclear Waste Advisory Associates and member of NTW made a presentation on the second panel regarding the “Inconvenient Truths of Small Modular Reactors.” Download here his full paper.

Download the full ENEF2018 programme.

Webstream of Day 1

 

 

International Nuclear Energy Conference-Prague-11/04/2018

The international conference NEC 2018 “Nuclear waste: Unwanted legacy of nuclear power” was organised by Friends of the Earth CZ and Calla and took place in Prague on Wednesday 11/04/2018. The objective was to discuss, in the presence of international and Czech experts, the options of finding a solution to the nuclear waste problem without restricting citizens’ rights to defend their interests and those of future generations.

NEC 2018 was loaded with information on management of spent nuclear waste and the problems of final disposal. 116 participants from 11 countries were then able to compare the new developments in the Germany, Sweden and other countries with the situation in the Czech Republic. The restart of the German repository project was described as was the background to the decision of the Swedish Environmental Court to say no to the Swedisk plans for a repository for spent nuclear fuel.

The final disposal of spent fuel is also a very hot topic in the Czech Republic, as the decision on the selection of four most suitable sites for a repository out of the nine potential ones should be made this year. Brief presentations by participants from Eastern Europe completed the information at the end of the conference. Browse through the presentation, or you can contact the speakers. You can get a feel of the conference atmosphere in the photogallery.

Many members of Nuclear Transparency Watch were there as speakers: Jan Haverkamp (energy and nuclear energy expert, Netherlands) Johan Swahn (director of MKG, Sweden), and Gabriele Mraz (Inrag, Austria), and contributed to the debate from the audience : Marcin Harembski (NGO Common Earth, Poland), Andrey Ozharovsky, Russian Nuclear Energy Expert.

An Taisce Welcomes Public Consultation on UK Hinkley Point C, Nuclear Power Plant

On 20/02, The Irish Government has launched public consultations on the UK’s Hinkley Point C, nuclear power station, 5 years after it should have under UN Conventions. The UK Government are building a nuclear power station, Hinkley Point C, on the north coast of Somerset, some 150 miles (~242 km) from Ireland’s East Coast.

Charles Stanley-Smith, An Taisce’s Communication Officer stated “These consultations have been hard won through court cases and escalation to the compliance committees of two UNECE conventions on consultation rights and obligations. This is the hard work of An Taisce, The Environmental Pillar and Friends of the Irish Environment and German MEP Ms Sylivia Kotting-Uhl”

He continued “The peoples’ rights to these consultations will become increasingly important in our ability to address transboundary impacts of UK projects on our environment, health and economy, into the future. Under UN Conventions, the peoples of neighbouring countries that could be affected by a project need to be consulted. Post Brexit, we may not be able to rely on EU law to safeguard us, but these are UN conventions For instance, the Irish people will now need to be consulted in terms of any other 5 proposed nuclear power station on the UK’s west coast”

Charles Stanley-Smith continued “An Taisce welcomes this Consultation and we would like like to encourage people to participate, in this consultation which is being organised through the Local Authorities across the country. The deadline for your submissions is 17th April 2018”

Find the full press release and recommandations of An Taisce here.

Find here the radio interview of Prof John Sweeney of Maynooth University on the subject.

The Swedish Environmental Court’s NO to the final repository for spent nuclear fuel: a major victory for safety

The Swedish Environmental Court says no to the power industry’s Nuclear Waste Company SKB’s license application for a final repository for spent nuclear fuel in Forsmark, Sweden. This is a huge triumph for safety and environment – and for the Swedish NGO Office for Nuclear Waste Review (MKG), the Swedish Society for Nature Conservation (SSNC), and critical scientists who have been presenting risks of the malfunction of the selected method. Now it is up to the Swedish government to make the final decision.

“This is a victory for us and for the scientists that have had doubts about copper as a canister material. From now on, the work on evaluating safer disposal solutions will continue. The decision that will be made concerns waste that will be hazardous for thousands of years. Several independent researchers have criticized both the applied method and the selected site. There is a solid documentation as base for the Environmental Court’s decision. It is hard to believe the Swedish Government’s conclusions will be any different from that of the Court’s” says Johan Swahn, Director at MKG and Chair of NTW Radioactive Waste Management Working Group. 

This article is an extract of the full article of MKG.

Article by Johan Swahn published on 12/12/2017 on the on-going licensing process in the Swedish Environnemental Court for the proposed final repository at the Forsmark NPP.

Translation into English of the Swedish Environmental Court’s opinion on the final repository for spent nuclear fuel- as well as some comments on the decision and the further process.

Summary of the Court Statement (in swedish)

The Environnemental Court’s Statement to the government  (in swedish)

NTW becomes a member of the SITEX_Network

The SITEX_Network was launched on the 09/01/2018 in Paris, on the premisses of IRSN

The SITEX_Network is a new organisation for primarily technical support organisations (TSOs) working for national regulatory bodies on research on radioactive waste management (RWM). The SITEX_Network also has an interest in interacting with civil society organisations when it comes to research issue in RWM. NTW joins this network which gathers 14 founding organisation members.

The Swedish organisation MKG, board member of NTW, represents the civil society in the Management Board of SITEX.

MKG is directed by Johan Swahn who is also the Chair of our Working Group on Radioactive Waste Management, and who is now the Vice-Chair of the Management Board of SITEX.

Nuclear transparency under threat in Turkey, by Pinar Demircan

Nuclear developments currently play a front-role in political discussions in Turkey. In this article, we give a sketch of the situation around the most advanced of the three proposed nuclear plants – the Russian build, owned and to be operated project at Akkuyu. We will reflect on methods used during this process, transparency, involvement of civil society, public participation and access to justice.

 Nuclear in Turkey

Being one of the first countries to sign an agreement based on to the “Cooperation With Other Nations” article 123 of the US Atomic Energy Act of 1954, establishing US President Dwight D. Eisenhower’ s Atoms for Peace programme, different Governments of Turkey have pushed nuclear energy as the “development key of the country”. Turkey established an Atom Energy Commission as early as 1956 to work on nuclear energy and radiation safety, which in 1982 was transformed into the current nuclear regulator and licensing authority TAEK (Turkish Atomic Energy Commission). Today there are two research reactors at the Nuclear Research and Training Centre in Istanbul.[1] For further development of the sector, bidding processes were started in 1965, 1972, 1982 and 1993 respectively, but they were never realized due to political and economical uncertainties formed in the atmosphere of military coups that happened almost every 10 years.[2]Also, a strong anti-nuclear movement played an important role. This started in the 1970’s with protests of fishermen and citizens in Mersin and was enhanced by the Chernobyl disaster in 1986. In the end of the 2000s, the plans were once more revived and currently three projects are being pursued: Akkuyu in the South-East, Sinop in the North-East and Igneada in the West. The official justification is a need to reduce dependence on foreign sources.[3]

 By the end of July 2017, Turkey is 74% dependent on imported energy sources [4]. Of its electricity generation, 34% is from natural gas, 31% from coal, 24% from hydraulic power, 6% from wind, 2% from geothermal energy and 3% from other sources.[5]70% of its natural gas comes from Russia.

 In 2010, Turkey signed an Intergovernmental Agreement with Russia to have a nuclear power plant established near Mersin, on a site at the Mediterranean coast. This agreement lets the Russian company Rosatom establish the four-reactor Akkuyu Nuclear Power Plant under a so-called Built-Own-Operate (BOO) model, the first example realised in the world.[6] Under this scheme, the estimated cost of the Akkuyu project is 22 billion dollars for four reactors of the VVER1200 design, and electricity produced by Akkuyu will be bought at a guaranteed price of 12,35 Dollarcent per kWh for 15 years.*

As an international agreement, this deal was reached outside of the public eye and cannot be evaluated within the constitutional rules.

 Although Turkey is not a signatory of the Aarhus and Espoo Conventions, which oblige public participation and an Environmental Impact Assessment (EIA), Turkish law does enshrine the need for an EIA. On the basis of the negotiations for accession to the EU, this law reflects much of the EU EIA Directive. The EIA report of the Akkuyu project was twice refused by the Ministry for Environment and Urbanisation. A third application was approved in the end of 2014, within a week after president Vladimir Putin visited Turkey.

Around the entire process, there was strong public debate. In reaction to the approval of the EIA, a group of 13 civil society organisations and 80 individuals, including physicians, lawyers and engineers associations, environmental organisations and local associations, filed an appeal. Despite local and national public discontent, feasibility studies for the nuclear power plant site were started on 14 April 2015.[8]

Sinop and Igneada – the other Turkish nuclear projects

The Akkuyu nuclear power plant is the first one to enter the construction phase. But in 2013, Turkey signed an intergovernmental agreement with Japan for a second nuclear power station near Sinop, a city on the Black Sea coast. Also here, a Build-Own-Operate (BOO) agreement is foreseen. The Atmea reactors are to be delivered by Mitsubishi in cooperation with French Areva. The Atmea design so far only exists on paper and Turkey is currently the only interested country. The nuclear reactors, according to the agreement, should be capable of using mixed oxide (MOX) fuel, including plutonium from reprocessed spent nuclear fuel. In spite of the project still being in a very early stage and no related permits being given, 600 thousand trees were cut on the land that was transferred from the Ministry for Environment and Urbanisation to the Energy Ministry.

In 2016, the government announced a third project, potentially in cooperation with Chinese nuclear constructor CNG. Igneada is famous for its rainforest nature, located at the border with Bulgaria on 220 kilometres from Istanbul.

The use of three different technologies, implemented and owned by three different countries, raises serious concerns about whether different safety procedures and rules will fit in the still infant nuclear legal infrastructure in Turkey.

Problems around Akkuyu

Although it was envisioned in the BOO model that Rosatom would become the sole owner of the project, difficulties for Russia in financing its part forced it to sell in November 2017 49% of shares[9] to CKK, a consortium of three Turkish companies: Cengiz, Kolin and Kalyon, who currently demand an equal say in the management of the project.[10]

In 2014, an “Integrated Nuclear Infrastructure Overhaul” (INIR) mission from the IAEA concluded that the Turkish legal and procedural structures needed improvement.[11] The findings of this mission were only leaked six months after the report date. One of the central critiques in the mission report was the lack of independence of the nuclear regulator TAEK as prescribed in the Convention on Nuclear Safety (CNS).

Although Akkuyu is far away from most of its neighbouring countries, because Turkey is not a signatory of the Espoo and Aarhus Conventions even 100 km far Cyprus was not able to participate in the EIA procedure.[12]

The project is situated on a remote piece of Turkey’s Mediterranean coast. Critics allege that during the project preparation too little attention is given to nature protection. This includes threats to the wetlands around the Göksu River, and to important Mediterranean red-listed species like loggerhead turtles (caretta caretta) and monk seals (Monachus monachus).[13] There are furthermore concerns about the effects of a 2 degree temperature increase in the waters surrounding the plant due to cooling water.[14]

Turkey is situated in an active earthquake zone and its coasts have an elevated tsunami risk. The civil society appeal of the EIA report highlights the risk of an active fault line at 30 kilometre distance from the Akkuyu project site.

High level radioactive waste from the Akkuyu nuclear power plant

The EIA report contained no explanation regarding radioactive waste issues. At the expert review process of the EIA court case, Rosatom clarified that Russia would, under art. 12 of the Russian Constitution, never take nuclear waste for final storage from foreign sources. There is therefore no clarity about how especially spent nuclear fuel will be treated and high-level waste will be disposed of. Concerns exist in this respect especially about the high seismic risk in the entire Turkish territory, that makes finding a safe final deep depository virtually impossible.

The Turkish-Russian agreement seems to foresee reprocessing of spent nuclear fuel in Russia with repatriation of resulting vitrified high-level waste. There is, however, no clarity about the transport of spent nuclear fuel and vitrified waste, which might have to pass the highly inhabited area of Istanbul through the narrow Bosporus strait.

Concerns about transparency development

In March 2017, the Turkish government took a decision to start the project in spite of the EIA appeal still pending in court.[15] A decision on this EIA appeal is expected in late December 2017 or early 2018. However, president Erdoğan dashed any hopes on substantial changes to the project or a sincere assessment of its justification by declaring that the Akkuyu nuclear power plant project will be realized despite any environmentalist concerns. This message of the President was interpreted as a directive given to judicial bodies.[16]

NGOs and professional organisations also severely criticise the quality and insufficiency of the information shared with the public around the project, among others in their EIA complaint.

Government seems to attempt to reduce civil society participation in nuclear power plant decisions in other ways. It declared nuclear power plant projects as strategic mega projects, and decisions, including environmental ones, will directly fall to the Prime Minister and the President.[17]

Environmental NGOs, but also professional associations and media that have brought themselves into the public debate around Akkuyu and other nuclear projects, have faced strong verbal attacks by regime-friendly media and on social media, including from the President himself. As a result, they have become extremely careful in their activities and communication around nuclear issues, fearing it might be used as a reason for further intimidation or even legal steps endangering their very existence. Where nuclear power for more than 40 years was a strongly visible element of environmental debates in society, the civil society movement now turns to international solidarity to help save at least a bare minimum of transparency and public participation.

by Pınar Demircan

project coordinator of Nukleersiz.org & Nuclear Energy Editor at Yesil Gazete

 Jan Haverkamp (editor)

vice-chair Nuclear Transparency Watch

[1]             http://www.taek.gov.tr/kurumsal/birimler/bagli-kuruluslar/cnaem.html

[2]             http://www.nukleersiz.org/dosya/tr-nuekleer-karsiti-hareket

[3]             http://aa.com.tr/tr/politika/basbakan-yildirim-enerjide-disa-bagimliligi-azaltacak-projeler-uzerinde-calisiyoruz/680440

[4]             http://www.mfa.gov.tr/turkiye_nin-enerji-stratejisi.tr.mfa

[5]             http://www.enerji.gov.tr/tr-TR/Sayfalar/Elektrik

[6]             The first BOO was to be signed in the US to have one reactor of the Calvert Cliff nuclear power plant by Japanese Mitsubishi, but this was refused because of military security interests under section 104 of the Atomic Energy Act of 1954

[7]                     * 1 Dollar was 1,9 Turkish Lira when the project was started in 2010 and in 2017 1 Dollar is 3,8 Turkish Lira

[8]                     https://yesilgazete.org/blog/2015/04/14/son-dakika-akkuyuda-nukleer-karsitlarina-polis-mudahalesi/

[9]                     https://yesilgazete.org/blog/2017/06/19/rosatomdan-bile-tehlikeli-akkuyu-nukleer-santralinin-yuzde-49u-cengiz-kolin-ortakligina-satiliyor/

[10]                   https://tr.sputniknews.com/ekonomi/201706291029067022-turk-sirketler-akkuyu-esit-yonetim/

[11]                   https://yesilgazete.org/blog/2015/06/01/uluslararasi-atom-enerjisi-ajansinin-akkuyu-raporu-ortaya-cikarildi/

[12]                   https://yesilgazete.org/blog/2015/06/01/uluslararasi-atom-enerjisi-ajansinin-akkuyu-raporu-ortaya-cikarildi/

[13]                   http://chk.barobirlik.org.tr/dokuman/makaleler/3.pdf

[14]                   http://chk.barobirlik.org.tr/dokuman/makaleler/3.pdf

[15]           https://yesilgazete.org/blog/2017/02/27/akkuyu-nukleer-santral-projesini-aklayan-bir-bilirkisi-raporu/

[16]           https://yesilgazete.org/blog/2017/11/23/bu-dava-siyasidir-akkuyu-ngs-ced-iptal-davasindan-degerlendirmeler/

[17]           https://yesilgazete.org/blog/2017/04/11/akkuyu-yer-lisansinin-iptali-davasina-sipsak-bilirkisi-incelemesi/

Public Participation and Involvement in EU Energy Policy Decision-making – why is it important?Paul Dorfman, UCL Energy Institute, NTW MB member

Recent climate change research suggests that, over the next few decades, there will be unprecedented global change, consequently affecting European human welfare and environmental systems. European Union (EU) policy already seeks to mitigate change through low-carbon, energy reduction and efficiency policies – but adaptation will clearly be necessary. Achieving this transition and adaptation at the pace and scale required will not be straightforward, and public knowledge, views and values about energy futures choices and ‘trade-offs’ will play a critical role, with significant implications for EU energy policy.

Creating a low carbon and resource efficient economy will involve major structural changes to the way EU States work and live, including how we source, manage and use our energy – and an ambitious long-term target of 80-95 % reductions in greenhouse gases by 2050 have been set by the EU[1]. In order to start to achieve this, the EU concludes that we need to collectively triple our annual investment in low-carbon technologies over the next decade to EUR 8 billion and make a EUR 20 billion annual investment in energy infrastructure.

The challenge of achieving a transition to sustainable energy will involve different supply and distribution options combined with centralised forms of renewable energy; new European-scale networks for energy distribution; large-scale infrastructures for carbon sequestration; bridging combined heat and power (CHP) gas generation; local scale distributed energy; coal and nuclear fission (with their associated proposals for carbon sequestration and nuclear waste management); significant restructuring of our transmission networks and changes to our transport systems and built. However, these developments will vary in their acceptability to differing sections of the public and for different stakeholders, and will also vary from country to country.

So, we are faced with collective choices – and the purpose of energy appraisal is to inform these choices. Long-term decisions across the entire field of industrial strategy depend on the resulting pictures. It is in this way that we justify scientific research programmes, technology development projects, infrastructure investment portfolios and the implementation of entire suites of policy instruments like taxes, standards, regulations and subsidies. Taken across the full range of public and private actors engaged in energy systems, annual commitments of many billions of Euros rest (directly or indirectly) on the framing of energy policy appraisal[2].

Given the size of the long-term investments that are now needed across low carbon ‘energy futures’ options, European citizens should play a key role in taking these critical, social, environmental and economic decisions. The EU has recognised in the Lisbon Treaty this capacity-building of knowledge and trust via involvement and dialogue between statutory and non-statutory civil society actors at pan-EU, State, Region, and Local levels[3]. The EC Energy Road Map 2050[4]concludes that:

“The current trend, in which nearly every energy technology is disputed and its use or deployment delayed, raises serious problems for investors and puts energy system changes at risk. Energy cannot be supplied without technology and infrastructure. In addition, cleaner energy has a cost. New pricing mechanisms and incentives might be needed but measures should be taken to ensure pricing schemes remain transparent and understandable to final consumers. Citizens need to be informed and engaged in the decision-making process, while technological choices need to take account of the local environment.”

There is a range of strongly EU centred drivers to this dynamic, based on a perceived crisis of legitimacy in ‘top-down’ decision-making models. As a result, throughout the EU, there are clear policy moves to integrate public and community knowledge into decision-making processes. This shift has seen moves toward a two-way dialogue between specialists and non-specialists as a means of forging a more lasting consensus by increasing social involvement and participation, thereby fostering a sense of community[5].

The underlying social force that underpins this move is the drive for more accountable, transparent, and publicly acceptable decision making, with participatory dialogue no longer seen as an optional ‘add-on’ to policy making. It is in this context that civil stakeholder involvement provides a way forward to ensure that future policy solutions meet the needs of the public, and that these solutions are socially, culturally and politically acceptable as well as technologically feasible.

What is participation and involvement?

Participation and involvement is an approach to decision making that allows people to come together to consider information, discuss issues and options and develop their thinking together. Building on dialogue and consensus-building techniques, this kind of engagement provides policy and decision makers with much richer data on stakeholders knowledge, views and values, offers opportunities to more fully explore and express people’s thoughts and ideas, and allows the time to develop options and priorities. For participants, the experience helps them collectively develop their views with experts and decision makers. Participants can also take their recommendations forward to inform policy, which can encourage shared responsibility for implementation[6].

Dialogue about complex and controversial issues, such as energy futures, can also enable greater public confidence in eventual policy decisions. This is because dialogue allows a diverse mix of civil society stakeholders with a range of views and values to:

  • Learn from written information and experts.
  • Listen to each other, share and develop their views in discussion with experts and energy 
sector researchers.
  • Arrive at thought-through collective conclusions, and communicate those conclusions directly to inform decision making.[7]
  • It is important that dialogue should be face-to-face, in order to give all sides the chance to speak, question and be questioned by others. It should take place far enough ahead of policy being made to be able to have some influence over eventual decisions[8].

Involvement methods and tools

There are a very broad range of involvement methods, including: stakeholder dialogues, public meetings, citizens’ panels, events, forums, workshops, ‘kitchen round-tables’, ‘test-beds’, mentoring, ‘visioning’, peer exchange, interactive web-sites, and external communication through press and media.

Central to these involvement methods are practical decision support dialogue tools, and a number of projects applied them very well through framing boundaries, exploring scenarios, quantitative modelling, and evaluation and review. Decision support tools work well, especially in exploring ‘what if’ questions and resulting ‘trade-off’ options, risks and outcomes. Some specific tools are key, including: Scenario building and modelling, participatory multi criteria analysis (PCMA), virtual reality techniques (including 3D visualization and geographic information systems [GIS] mapping), life cycle analysis (LCA) and quantitative environmental assessment.

Of these decision-support tools, the most commonly used is scenario-building. Here, project findings suggest that complex energy and climate change information can be successfully applied and understood through use of coherent scenarios. This is because scenarios shed light on the long- term impacts of energy pathways decisions, especially infrastructure change. It’s also interesting to note that the EC Energy Roadmap 2050 has also used scenario-building as a way to better inform and involve people.

Participatory multi criteria analysis (PMCA) tool is employed in trying to balance and account for both quantitative data and social values. PMCA is used to test technical options and choices, and the social acceptance of change and adaption strategies. Although PMCA is resource intense, it encourages learning, and allows for the acknowledgement of uncertainties, and multiple legitimate perspectives. However, care should be taken in ‘weighting’ options, as this can impact significantly on eventual outcomes.

In terms of digital innovation, virtual reality techniques help people visualize alternative energy transition and climate adaption, mitigation scenarios and the potential consequences of those responses.

Stakeholders and the public can work with complex data

Independent expert involvement is a key part of an even-handed process. Dialogues draw on differing sets of stakeholder knowledge, experience and values. Working with, and integrating, diverse streams of information from multiple sources, sectors and disciplines forges better dialogues and results in more practical outcomes. By adding this element, an important step is made by distinguishing between what is technically and economically possible to what is feasible and acceptable to stakeholders. Encouragingly, in the right circumstances, civil society stakeholders are able to analyse, understand, respond and act on complex data.

‘Better practice’ involvement mobilises people

A very broad range of statutory and non-statutory stakeholders and civil society organisations should be enabled to actively engage in energy futures dialogue, including: policymakers, government departments, devolved administrations, local government and local authorities, energy regulators, transmission system operators, industrial corporations and businesses, trade associations, non-governmental organisations (NGOs), local community based organisations (CBOs), independent energy sector experts, and academic institutions.

But there are challenges to involvement

It is not always a simple task to encourage citizens and the industry to participate co-operatively, and it can be complicated to combine several different tools for decision making into a single coherent process. Tensions have arisen over a number of issues, including: the framing of boundary conditions for dialogues, whether all main stakeholders were included in discussion, the acceptance of all stakeholders as equal contributors, levels of planning options offered, and over perceived openness to serious policy influence.

Given that dialogue should happen over a reasonably extended time frame, an important cause of lack of local acceptance is the absence of a coherent and timely ‘upstream’ and on-going involvement strategy. Although participation of civil society is considered crucial for the implementation of ambitious involvement strategies, a few implementation programs and activities have not yet consistently involved all main stakeholders – focusing more on the business, industrial and research sectors.

So can involvement enable low carbon transition?

‘Business as usual’ energy policy will not deliver sufficient change at the rate and scale required to lower climate change emissions – and public, energy sector, and government stakeholders will all need to play their part in transitioning to low-carbon economies.

The published literature suggests that involving the public in dialogue around complex and technical policy issues is an important contribution to a more transparent and open way of governing – demonstrating that members of the public have the ability to engage with and contemplate large quantities of complex information, and provide detailed responses that inform and enhance governmental decisions.

Holding dialogue on difficult and controversial issues is a fundamental enabler for decision-makers to feel confident in the public’s ability to hold the Government to account. There is also clear evidence that engaging people in a meaningful way has the potential to change attitudes, behaviours and actions. In order to better enable participatory deliberation, dialogue should be well informed and appropriately connected to representative democratic decision-making processes. Effective involvement results from a holistic set of pre- conditions, working best when informal non-statutory civil society networks are empowered to interact with formal statutory networks.

Involvement-led innovation can be a powerful means for agreeing and/or delivering national, regional, city, and local strategic objectives, at a lower cost to the public purse and with less bureaucracy than traditional processes. However, formal mechanisms for energy futures involvement, and linking that involvement to policy and decision-making structures, are not yet in place within all EU states.

Whereas the goal in the scientific-technical community is to find the single best solution to a problem, the facilitation of public debate has a broader function – to find a workable process that holds the participants together in a ‘safe space’ and encourages collective negotiation within the bounds of scientific, technical, economic and political feasibility.

[1]1 EC Communication (2009): IP/09/1431, 07/10/2009.

[2]Stirling (2007): Choosing Energy Futures: Framing, Lock-in, and Diversity, In: Dorfman (Ed) Nuclear Consultation: Public Trust in Governance, NCG.

[3] This is underpinned by the Directive on Public Participation in Environmental Plans and Programmes, the EU Public Participation Provisions of the Aarhus Convention, and the EU Directive on Strategic Environmental Assessment. Other public participation related EU legislation includes Directives on Integrated Pollution and Prevention Control and Environment Impact Assessment.

[4] EU, EESC & CR (2011): A Roadmap for moving to a competitive low carbon economy in 2050, Communication from the Commission to the European Parliament, The Council, The European Economic and Social Committee and the Committee of the Regions, COM/2011/0112 final, Brussels.

[5]Dorfman P. et al (2011): Enhancing consultation practices on Air Quality Management in local authorities, Journal of Environmental Planning and Management, 53 (5) pp. 559-571.

[6] Involve, NCC (2008): Deliberative Public Engagement: Nine Principles, NCC. 7 Sciencewise-ERC, Guiding Principles for Public Dialogue:

[7]http://www.sciencewise-erc.org.uk/cms/assets/Uploads/Publications/Guiding-PrinciplesSciencewise-ERC-Guiding- Principles.pdf

[8] Sciencewise: The Government’s Approach to Public Dialogue on Science and Technology, UK BIS:http://www.sciencewise-erc.org.uk/cms/assets/Uploads/Publications/Guiding-PrinciplesSciencewise-ERC-Guiding- Principles.pdf

 

 

The Swedish Environmental Court is to rule on the proposed spent fuel repository in Forsmark

by Johan Swahn, director of MKG and member of the Management Board of NTW

On January 23rd, 2018, the Swedish Land and Environmental Court plans to give its opinion to the government on whether to allow the final repository for spent nuclear fuel in Forsmark. This is an important, but not the last, decision in the review of the license application that was submitted by the nuclear waste company SKB (Swedish Nuclear Fuel and Waste Management Co) in 2011. The ruling will come after 20 days of competent and eventful deliberations in the main meeting of the court during 5 weeks from the beginning of September until the end of October. The main meeting of the court, this is the official translation of the Swedish word “Huvudförhandling”, is the final, open and very democratic deliberation that takes place before the court takes a decision on a license application, and where all parties summarise their views legally and on issues. Anyone can attend and speak their view.

 The decision of the court, that has been postponed from the original plan of December 20th due to the huge volume of information that the court has to take into due account, will be very important for the future of the repository. The court has many difficult issues to manage as it writes its opinion and it remains a clearly open question whether it will say yes or no to the spent fuel repository.

 The planned repository for the final estimated 11 000 tons of Swedish high level radioactive waste in the form of spent nuclear fuel is to be constructed 120 km north of Stockholm on the Baltic coast, immediately South of the Forsmark Nuclear Power Plant in Östhammar Community. A copper canister encapsulation plant is to be constructed at the present intermediate storage facility for spent nuclear fuel, Clab, at the Oskarshamn nuclear power plant on the Southeast coast. The application for a license for the repository according to the Environmental Act was submitted to the court in March 2011 after a long consultation process from 2003-2010 and the choice of Forsmark for the site in 2009.

 The license application to the environmental court is being reviewed in parallel with a similar application to the Swedish regulator SSM (Swedish Radiation Safety Authority) according to the Nuclear Activities Act. From 2011 until the end of 2015 SSM has been asking SKB for additional information to make the application complete. SSM will give its opinion on the license to the government before or after the time of the court’s opinion. The government will use the two opinions to make its own decision whether to allow the repository or not.

 During the main meeting of the court that started on September 5thand was concluded on October 26th there were a number of issues that were under deliberation. The most important one was to what degree uncertainties regarding the long-term safety of the repository can remain after the court opinion and the government decision. This issue became especially important, as there was a highly competent input at the hearings by researchers from the Royal Institute of Technology in Stockholm that claimed that the integrity of the copper canister could be questioned. They claimed that many of the copper canisters encapsulating the spent fuel, and therefore vital for the long-term safety case, could start to leak before a thousand years have passed. The nuclear waste company SKB claims that only one canister will start to leak in a million years. But if a few hundred of the total six thousand copper canisters start leaking relatively soon, the dose limits of the regulator SSM (Swedish Radiation Safety Authority) will be exceeded and the repository should not be given a license.

 There were also other issues at stake during the main hearing; discussions of whether a deep borehole repository would be safer; whether the site is suitable due to geological and other issues; the very high ecological values at the Forsmark site; and many other issues were covered. And there was also, most importantly, an intense legal discussion regarding the implementation of the Environmental Act that governs the work and decisions of the environmental court and the connections with the implementation of the Nuclear Activities Act, which governs the decision-making of the regulator SSM.

 To understand the discussion a little background is needed. The Swedish Environmental Act dates from the late 1990s and requires that all activities that can harm the environment must have a license. The environmental court rules on and gives conditions for the license. The environmental courts have been working for over 25 years so by this time precedents exists for many types of activities. The Swedish Nuclear Activities Act is from 1983 and all nuclear activities also must have a license according to this law. This means that a final repository for spent fuel has to have a license according to both legislations. In both cases the repository has also to be approved by the government. According to the Environmental Act this is true only for a small list of activities that for instance also includes major infrastructure projects. But this means that at this stage in the decision-making process the court and the regulator SSM will only give their opinions to the government. Licenses are issued afterwards if the government says gives its approval.

 The parallel decision-making processes could be problematic if the court and the regulator SSM did not have the same basis for license review. In order for this to be the case the Nuclear Activities Act was immediately changed to have Chapter 2 of the Environmental Act with the “General rules of consideration” incorporated to be used for decisions. In addition when the new legal framework was set up it was foreseen that the decision-making according to the two legislations was to be parallel and coordinated.

 The “General rules of consideration” of the Environmental Act are very important for environmental decision-making and praxis has been established what has to be shown, how to consider the precautionary principle and how to define and evaluate the use of best possible technology and site. In its evaluation of the license application according to the Nuclear Activities Act the regulator SSM is to use the same evaluation criteria.

 At the main hearing of the court it became evident that something was amiss regarding SSM’s decision-making in relation to the Environmental Act. SSM had already in June 2015 told the court that the application was complete with regards to the Environmental Act. One year later SSM told the court that it was plausible that it could be shown that the repository would have a sufficient radiation safety in the long term. Some issues remained, amongst them issues regarding the integrity of the copper canister, but these could be resolved in the step-wise decision-making that SSM foresaw after the government’s decision. SSM will give a license for construction first and then later a license for trial operation and finally for operation.

 During the main hearing the environmental court was indirectly very critical of SSM by asking the regulator a number of questions. This started already on the third day of the proceedings and the questions from the court grew in number and complexity throughout the main meeting. The court wanted to know how SSM saw its role in the decision-making according to the Environmental Act. The court wanted to know why SSM stated that it was “plausible to show” only and not that “it is shown” as is required according to the “General rules of consideration”. Also it became apparent that the definition of best available technology that SSM was using is less strict than that used by the environmental courts.

 It would appear as though the court will have a problem with the actions of the regulator when deciding what to say to the government. It appears as though SSM has not put in enough effort to ensure they have the information they need to say that it is shown that the repository is safe. Instead SSM wants the court to let it deal with issues later. But the court cannot deal with issues later and would expect the SSM to follow its own legislation. Towards the end of the main meeting SSM boldly stated that the environmental court should not deal with issues where it had stated that it is “plausible to show”. The court can do this. It is not legally obliged to take on issues that other authorities can handle, i.e., the radiation safety issues that SSM examines. In the case of a spent fuel repository the long-term radiation safety is of course a central environmental issue, and it can be questioned if the court should follow the wishes of SSM, and the nuclear waste company SKB, to stay away from radiation safety issues. But, legally it is up to the court to decide.

 If the court were to leave the radiation safety issues to SSM for the government’s decision and for the future decision-making process, it would have to trust the integrity and independence of the regulator. During the main hearing the court SSM in its various statements agreed entirely and without any reservations with what the nuclear waste company SKB was stating regarding long-term safety, as well as choice of site and method. This despite the on-going controversies in the room. Towards the end of the proceedings leaked documents from SSM were published in Swedish media showing that there was no consensus within the regulator about going ahead and saying that long term safety was plausible. Instead, it was revealed that several of SSM’s experts, including the materials and corrosion expert, were opposed to giving the go-ahead. This behaviour of SSM has generally weakened the trust of the regulator, but to what extent it has influenced the court remains to be seen.

 The court will give its opinion to the government on January 23rd. SSM has said it will give its opinion to the government around the new year. The government then has to ask the two communities involved in the project, Östhammar and Oskarshamn if they approve or not. Östhammar community is planning a referendum on the issue for March 4th. The government will prepare for a decision during the spring but it is uncertain whether a decision will be taken before the next elections in September. After the elections it will take time to form a new government, so a likely timeframe for a government decision on the spent fuel repository is in the spring of 2019.

 If the government says yes, there is still a long legal procedure ahead until the licenses to start construction will be ready. The government’s decision according to the Environmental Act can be appealed. The court has then to decide on the license and conditions, likely with a new hearing beforehand, and the court’s decision can be appealed. The government’s decision according to the Nuclear Activities Act can be appealed. SSM has to review a new safety analysis report before deciding to give a license to start construction.

 Finally, it will take at least seven years to build the repository and the regulator has to give licenses both for a trial operation and a full operation. If everything goes as the nuclear waste company SKB hopes there could be an operational Swedish repository for spent nuclear fuel in the mid-2030s.

If the environmental court says no on January 23rd the repository may still get a go-ahead from the government. If Östhammar community says yes despite a no from the court the Government can overrule the court, but it cannot contradict the Environmental Act doing it. If Östhammar community says no, the veto of the community is not absolute. The government under certain conditions can override the veto. However, the nuclear waste company SKB has said it will not go ahead with the repository against the will of Östhammar community.

 It is not an understatement to say that what the court says on January 23rd, 2017, will be of utmost importance for the future of the Swedish nuclear industry’s plans for disposal of spent nuclear fuel.

 

NTW celebrates its 4 years of existence, by Nadja Zeleznik

Nuclear Transparency Watch was created in November 2013 as a European, non-profitassociation founded under French Law which gather together different civil society representatives. Its main objective is to ensure greater vigilance and public involvement in relation to all activities in nuclear sector. Therefore, the NTW has chosen as a lead message to “Prevent and anticipate through transparency and participation” and has the principal focus on transparency as a means to guarantee safety and the protection of human health and the environment against ionizing radiation.

NTW includes two types of members: individuals as qualified members and organizations which are implicated in or concerned with the monitoring of nuclear activities. The NTW counts currently 48 members and doubled the number of members since 2013. These members represent 17 EU countries (Italy, France, Germany, Netherlands, Belgium, Luxembourg, UK, Ireland, Spain, Sweden, Austria, Slovakia, Hungary, Czech Republic, Poland, Bulgaria) and 3 non-EU countries (Ukraine, Russia, Turkey), also qualified members coming from variety of EU Parliament parties. In addition, there is also a wider group of interested NGOs which joint to the NTW for particular project or activity.

 The topics which are of interest to NTW are currently also organized as Working Groups and include:

  • Emergency Preparedness and Response, dealing with the EU and national arrangements for nuclear or radiological accident and their improvements,
  • Radioactive Waste Management, focusing on the EU and national requirements, implementation strategies and encountered problems in different countries,
  • Nuclear Power Plants Ageing performing investigations on the challenges of ageing of nuclear installations, related transparency problems and ways to improve the situation.

As a cross-cutting area there is a Working Group on transparency and public participation which foster implementation of Aarhus and ESPOO convention in nuclear sector, including the right to access to information, participation in decision-making process and justice in environmental matters. In addition, NTW also support the right to the effective access to resources, including financial resources, which are necessary in order to achieve enduring, knowledgeable, rigorous and constructive engagement.

 At the end of our fourth anniversary we can say that NTW has become an important player at EU level gathering different representatives of civil society concerned with nuclear safety and radiation protection. The NTW is now involved in many EU activities and has established relationships with EC institutions, assures the transboundary participation in relevant topics and provides the support at national level for civil society organizations, many times lacking the national support. We will also in the future aim to increase the transparency of nuclear activities and the engagement of civil society to achieve and maintain a high level of nuclear safety in the European Union and at its borders.

Nadja Zeleznik is the president of NTW and senior Expert at EIMV Slovenia.

Strong radioactive release finally recognized in Russia: analysis of the french association for control of radioactivity in the West (ACRO)

Updates at the end of the document:

  • Russia recognizes ruthenium contamination, but denies leak, Nov. 20 2017
  • Russia tries to be reassuring, November 24
  • IAEA data leaked, November 27
  • Result of the “independent” survey led by Rosatom, December 8
  • Rosatom recognized ruthenium-106 released into the environment, December 14
  • Ruthenium 103 was also present in the rejection, February 5 2018

The Institute for Radiation Protection and Nuclear Safety (IRSN) has just announced (in French and English) that traces of ruthenium-106, a radioactive element, detected in Western Europe last September, were probably due to a massive release, on the order of 100 and 300 terabecquerels, “somewhere between the Volga and the Urals without it being possible to specify the exact location of the point of discharge with the available data.

The Institute adds that “the consequences of an accident of this magnitude in France would have required locally to implement measures to protect populations on a radius of a few kilometers around the place of rejection.

Still according to the IRSN, the release would have taken place during the last week of September 2017 and would be finished.

Ruthenium-106

Ruthenium 106 is a radioactive fission product from the nuclear industry that does not exist in its natural state. Its half-life is a little over a year (373 days), which means that the present amount is halved each year. By disintegrating, ruthenium-106 is transformed into rhodium-106, which is also radioactive with a half-life of 30 seconds. Each decay of ruthenium-106 goes with the disintegration of rhodium-106, shortly after. Thus, the ruthenium-rhodium pair should be considered which doubles the quantity released of 100 and 300 terabecquerels announced by the IRSN.

Rhodium-106 will be responsible for most of the dose caused by the incorporation of inseparable pairs of radioactive isotopes.

Origin of the release

In case of release from a nuclear reactor, various radioelements are detected. Here, since ruthenium-106 and rhodium-106 are the only radioelements to have been identified, the origin can not be a nuclear reactor. On the other hand, it may be the accidental release of a spent fuel treatment facility or the manufacture of radioactive sources.

ACRO sometimes detects the ruthenium-rhodium pair around the Areva factories in La Hague. In 2001, two incidents in these factories led the association to demonstrate that the operator, still known as Cogéma, underestimated its ruthenium-rhodium releases into the atmosphere. In May and again in October 2001, the quantities actually released were about 1,000 times higher than what had been announced (see technical note in french). Studies following this ACRO alert showed that atmospheric ruthenium-rhodium releases have been systematically underestimated.

In February 2016, ACRO had again detected this pair of radioelements around the La Hague plants, which was indicative of greater atmospheric release than usual, possibly indicative of undeclared dysfunction.

Quantity released

IRSN announces a source term in Russia of 100 and 300 terabecquerels for the only ruthenium-106, and therefore the double also taking into account rhodium-106. A terabecquerel is 1,000 billion becquerels.

As a comparison, the authorization of atmospheric discharges from the Areva factories in La Hague is 0.001 terabecquerel (1 GBq) per year for beta-gamma emitters (including ruthenium-rhodium) other than tritium, rare gases and iodines. For liquid discharges, for the only ruthenium-106 released at sea, the limit is 15 terabecquerels per year.

The quantity released during the incident reported by the IRSN is therefore considerable and this event should be classified at Level 5 of the INES international scale. Chernobyl and Fukushima were at 7, which is the maximum level. However, no information is available on the IAEA website.

Provisional conclusion

60 years after the Kychtym disaster in the Urals and more than 30 years after the Chernobyl disaster, the fact that an event of this magnitude can remain secret for more than a month is incredible. This is particularly serious for local populations who have been exposed without any protection, as in 1957 and 1986.

It should be noted that as early as October 11, the Bundesamt für Strahlenschutz in Germany pointed to the South of the Urals (communicated in German and English), stating that IRSN shared this point of view. There was therefore no progress in a month in identifying the origin of this rejection.

Is such secrecy explained by the fact that a military installation is involved? Russia has denied being behind this rejection. It should publish all its measurement data in the environment.

Mayak?

Several websites are targeting the Mayak nuclear complex in Chelyabinsk Oblast as the source of this contamination, without our being able to validate these claims. Originally, this secret military-industrial complex is designed to manufacture and refine plutonium for nuclear warheads and has become infamous for its serious nuclear accidents, including that of Kychtym. The site is still active and serves as a spent fuel treatment center (operator’s website).

Russia recognizes ruthenium contamination, but denies leak , Update on November 20

At the request of Greenpeace Russia, it was the Russian meteorological agency that finally admitted that the origin of the leak is in Russia (release in Russian). The press releases is entitled: “extremely high and high pollution”. Meanwhile, the state-owned company Rosatom still denies being at the origin of this pollution. (release in English). In its press release, the weather agency does not give the ruthenium-106 or rhodium-106 contamination, but rather the total beta contamination of aerosols. But we can suppose that the excess is essentially due to this couple of radio-elements.

The highest concentration was found in Argayash, in Chelyabinsk Oblast, which includes Mayak and Kychtym between September 26 and October 1: 7,610 × 10-5 Bq / m3, or 986 times more than is usually measured in this station. In Novogorny, still in the Chelyabinsk Oblast, it was 5,230 × 10-5 Bq / m3 these days, 440 times more than the usual values. Excessive radioactive aerosol values ​​were also detected in the North Caucasus, up to 2,147 × 10-5 Bq / m3, or 230 times background noise, and in Tatarstan. Other data is available in this document in Russian.

It is now confirmed that a serious rejection has taken place on a Russian nuclear installation which is still secret. But the meteorological agency has apparently not launched a warning and it is the local populations, who live in an already highly polluted environment, who have been exposed. What are its tags for? The meteorological agency explains that the levels recorded are well below the local limits set at 4.4 Bq / m3. A non-event in Russia.  These concentrations are very high compared to what is usually measured and is the unambiguous signature of an abnormal rejection. On the other hand, the atmospheric concentrations announced do not require sheltering or evacuation, even under French standards.

The measurement station at Argayash (Aragasy), where the highest concentration has been measured, is about thirty kilometers from the Mayak nuclear complex. Near the point of discharge, pollution may be higher. Independent environmental measures are essential. The Russian meteorological agency also mentions fallout from 10 to 50 Bq / m2 and per day, in places. the IAEA website still does not indicate anything.  It should be noted that the weather agency also mentions radioactive iodine pollution in the Obnisk region (Обнинск), located about 100 km southeast of Moscow. Concentrations reached 1.85 × 10-3 Bq / m3 on 18 and 19 September and would be due to a local research center.

On November 21st, IRSN stated in French media that the results of its modeling gave much higher values ​​in the immediate vicinity of the discharge point. But, if the tags whose results have been published are not under the winds at the time of rejection, it remains compatible. And the Institute adds: “We can therefore ask ourselves the question of the role of the IAEA. It is not normal to arrive at this situation. It is not normal to observe ruthenium in the air of all Europe, without ever knowing the source.

Russia tries to be reassuring, Update on November 24

The regulator of agricultural products Rosselkhoznadzor issued a statement (in Russian only) denying the contamination of Russian agricultural products. It  talks about panic in the grain market that would be due only to rumors and media speculation, but gives no measurement results.
Meanwhile, the Institute of Nuclear Security of the Russian Academy of Sciences (IBRAE RAS) announced the creation of a commission of inquiry in a statement (in Russian only) whose purpose is to determine the origin ruthenium and rhodium pollution. It is also reassuring by saying that the levels found in Russia are largely in the norms and has already concluded that Rosatom, the Russian national company, is not involved. And Rosatom will inform the public of the results of the investigation.
In the absence of an independent laboratory on site, there is still room for improvement in terms of public transparency and radiation protection in Russia.

IAEA data leaked, Update on November 27 

ACRO uploads data collected by the IAEA on ruthenium pollution detected in Europe that the UN agency refuses to make public. This table, dated October 13, 2017, does not contain any Russian data.  As for Rosatom, the Russian state-owned company,  it invites journalists and bloggerson its Facebook page  to visit Mayak, which, according to Western journalists, has become the cradle of ruthenium. On the agenda, “literacy” on ruthenium.

Result of the “independent” survey led by Rosatom, Update on December 8 2017

The state-owned nuclear company Rosatom held a press conference to communicate the findings of the “independent” ruthenium-rhodium contamination survey carried out in late September throughout Europe: it is not responsible for this pollution. Nothing on his website for the moment … To be continued!

Only an independent international inquiry will shed light on this rejection. Russia could start by publishing all its environmental data in the suspected area.

Rosatom acknowledges releasing ruthenium-106 in the environment, routinely, Update on December 14, 2017

According to News Agency AP, Yuri Mokrov, an adviser to the Mayak Nuclear Center’s managing director, acknowledged that processing spent fuel leads to releases of ruthenium-106 into the environment. He then added that Mayak plant is not the cause of the abnormally high rejection that was detected throughout Europe last September. According to him, discharges would be minimal and hundreds of times below allowable limits. Authorized levels are not given in the article.

Our summary:
Russia first didn’t detect radioactive ruthenium detected throughout Europe;
Then, following the calculations made in Germany and France that pointed to the Urals, the country ended up admitting to having detected it at extremely high levels, but without danger. In fact, the advertised levels are much higher than what is measured routinely, but do not require any particular protection measure. The measurement of an air pollution is done by filtering the air for several days. This may be a long-term average that mitigates the peak pollution. The measurement period is not given.
Rosatom, the state nuclear industry in Russia denies any involvement in the rejection. It sets up an “independent” commission which concludes in the same direction and which brings out the thesis of the fall of a satellite. And there, all of a sudden, Rosatom recognizes regular rejections of ruthenium-106 in the environment and declares these rejections are within the admissible limits. And there wasn’t any particular incident to report. This means the limit must be very high.

The conclusion is that Russia has not changed much since Chernobyl. Without an independent laboratory on site, glasnost did not affect the nuclear sector.

Ruthenium-103 was also present in the rejection , February 5 2018

A meeting with international experts took place in Russia at the end of January 2018 about this ruthenium case, including IRSN. It appears that in some countries ruthenium-103 was also present in the radioactive cloud. Surprisingly, there has been no official communication so far, which gives some indication of the potential source of this contamination. On January 22nd, the Bundesamt für Strahlenschutz in Germany was still saying that there was only ruthenium-106.

 The half-life of ruthenium-103 is 39.26 days, which means that it disappears much faster than ruthenium-106, which has a half-life of 373.6 days. And so the nuclear fuel at the origin of the rejection must not be out of the reactor for a long time: 3 to 4 years maximum. However, in general, the treatment of spent fuels is done on older fuels.

 The Russian press deduces that this exonerates the Mayak site. It does makes it possible to exclude a priori vitrification which was strongly suspected until now, unless, for some obscure reason, young fuel could be treated and the residues vitrified. On the other hand, the manufacture of radioactive sources is generally done on “young” spent fuel. And Mayak makes sources …

French press mentions the commission by CEA and INFN in Italy to the Mayak nuclear complex of a source of cerium-144 for a physics experiment. However, the production of this source requires the treatment of “young” fuels, less than 5 years old. The article speaks of troubling coincidence.

This rejection is mysterious enough to put everything on the table and we hope for an official communication from the international experts present in Russia.

On February 6, IRSN posted a briefing note in French and English and a report in English only summarizing its investigations confirming the detection of ruthenium-103 and studying the hypothesis of the manufacture of a source of cerium-144. The report is rich in information.

Article initially published on November 11, 2017 on the ACRO website.

ACRO is a French non governmental organisation that operates a laboratory for radioactivity analysis. It was created in 1986 as a response to people’s demands for information and reliable independent testing. It is a member of NTW since 2013.