Author Archives: Nuclear Transparency Watch

12th European Nuclear Energy Forum (ENEF) conclusions

On 01/08, the European Commission published the conclusions of the 12th European Nuclear Energy Forum (ENEF), which took place in Prague in May 2017.

This year, a more participative and engaging format, “the world café” model, was introduced on the first day of the forum and more representatives of civil society were supported to participate, following NTW recommendations.(1)

NTW finds the following general points in the conclusions of special importance:

 The Forum

• Acknowledges that a number of challenges linked with the implementation of the Euratom Treaty priorities were identified, and some challenges are likely to remain for the future, such as the focus on the back end of the lifecycle of nuclear power plants, in particular radioactive waste and spent fuel management and decommissioning, as well as the level of transparency associated with it;

•  Highlights that future initiatives should be undertaken in areas such as:

o ensuring the correct and full transposition and conformity of the Radioactive Waste Directive, amended Nuclear Safety Directive and amended Basic Safety Standards Directive without delay, to ensure fast and visible results for the citizens;

o emergency preparedness & response mechanisms, also ensure cross border and EU level harmonisation of the plans in place in individual Member States;

o ensure increased compliance with highest safety standards and best regulatory practice in the EU, the EU neighbouring and third countries;

o ensure improved application and transparency in the area of investments under Article 41 of the Euratom Treaty (investments), also in the case of long-term operation;

o ensure timely and safe decommissioning of shut-down reactors, with adequate funding available when needed;

Download the conclusions here, or find them on the European Commission website.

(1)See opinion column from Philip Kearney about NGO participation in Bratislava Enef Conference 2016.

Controversial amendments of Nuclear Energy Act: The Hungarian government silently backed off, but independent nuclear oversight is still in peril

The Hungarian government furtively withdrew the two most controversial changes of the Nuclear Energy Act. These amendments passed in December 2016 allowed the government to bypass with a simple decree the valid permits of new nuclear reactors and radioactive waste facilities, originally issued by the formally independent nuclear regulator. [1] Since their adoption, there were reportedly heated discussions with the European Commission that these paragraphs were in breach with the Euratom Treaty. A recent modification of the Act has now returned the final say again to the nuclear regulator. [2] There was no public communication on this, neither on behalf of the Hungarian government, nor the Commission. Energiaklub and Nuclear Transparency Watch consider the retreat of the government a welcome change, but it also raises further questions about the independence of the Hungarian nuclear regulator.

Unfortunately, the looming questions about the independent operation of the Hungarian Atomic Energy Authority (HAEA) are far from settled. Surprisingly, the regulator itself claimed that it initiated the December 2016 amendments that ended up curbing its own powers. The responses to the freedom of information requests submitted by the think tank Energiaklub confirmed this claim. However, these requests also revealed that the government simply ignored several proposals from the nuclear regulator to strengthen its independence and to set a more coherent set of rules for the permitting process, partly based on international legal obligations like the Euratom Treaty and the Convention on Nuclear Safety. An expert mission of the International Atomic Energy Agency (IAEA) repeatedly criticised the limitations of effective independence of the nuclear regulator, such as the inability to fully control its own budget. The government chose to simply ignore these recommendations.

Marton Fabok, energy policy expert at the Hungarian think tank Energiaklub and member of Nuclear Transparency Watch says: “We welcome that the most immanent danger for the independence of nuclear oversight is over. It is still worrying, however, that the government is effectively continues to curb the powers of the nuclear regulator. A strong and independent authority is essential to ensure nuclear safety. Moreover, the Hungarian Atomic Energy Authority was complicit in not speaking out against the lacking guarantees of independent regulatory oversight.”

The Hungarian government changed the controversial law paragraphs after severe critique from the side of the European Commission who was alerted by environmental NGOs and discussions during the 7th Review Meeting of the IAEA administered Convention on Nuclear Safety in Vienna in March/April 2017. [3]


Márton Fabók – Nuclear energy expert at Energiaklub,, +36 20 483 1747

Jan Haverkamp – Vice-chair of Nuclear Transparency Watch,, +31 621 334 619


[1] The Hungarian government is currently about to build a nuclear power station with the vendor Rosatom from Russian loan of €10bn near the existing Paks nuclear power station in the South of the country on the Danube river. The Paks II developer MVM Paks II Ltd. is a 100% state owned company which is led by a minister without portfolio.

[2] The English language translation of the two controversial articles, now withdrawn, is the following:

Act CXLIII of 2016, § 14 (1) and (2):

(1) The following sub-point (dh) is added to point (d) of Section 67 of Act CXVI of 1996: (The Government shall be authorised to regulate, in a decree: (d) in respect of nuclear facilities)‘ (dh) possible ways and conditions of deviating from the official licences at a nuclear facility being established;’

(2) Section 67(w) of Act CXVI of 1996 is replaced by the following: (The Government shall be authorised to regulate, in a decree:) ‘(w) safety requirements for radioactive waste repositories and detailed rules for the related requirements of the authorities as well as possible ways and conditions of deviating from the licences at the radioactive waste repository being established;’

The indicated the recent changes in the Nuclear Energy Act (Act CXVI of 1996), this indicates the December 2016 versions in italic and the June 2016 versions in bold:

  1. (dh) of Section 67 of Act CXVI of 1996:
    “(The Government shall be authorised to regulate, in a decree:)
    (dh) possible ways and conditions of deviating from the official licences at a nuclear facility being established.”

was now replaced by
“(The Government shall be authorised to regulate, in a decree:)
(dh) the rules of procedure for the amendment of the licence of a nuclear facility being established.”

II. (w) of Section 67 of Act CXVI of 1996:
“(The Government shall be authorised to regulate, in a decree:)
(w) safety requirements for radioactive waste repositories and detailed rules for the related requirements of the authorities as well as possible ways and conditions of deviating from the licences at the radioactive waste repository being established.”

was now replaced by
“(The Government shall be authorised to regulate, in a decree:)
(w) the safety requirements for radioactive waste repositories, the detailed rules for the related requirements of the authorities and the rules of procedure for the amendment of the licence of a nuclear repository being established;”

[3] Letter of Energiaklub, Greenpeace, Nuclear Transparency Watch, WISE International, and Nuclear Information and Resource Service to the 7th Review Session of the Convention on Nuclear Safety

[4] Energiaklub analysis of the recommendations to strengthen the nuclear regulatory oversight (in Hungarian)

[5] The legal changes initiated by HAEA in September 2016 acquired by a FOI request (in Hungarian)

IMG SEA public hearing

Report on Responses to Foreign Contributions, Public Hearing of Czech Update of the National Programme on Radioactive Waste and Spent Nuclear Fuel Management

Article by Olga Kališová.

During the public hearing on Update of the National Programme on Radioactive Waste and Spent Nuclear Fuel Management in the Czech Republic and its evaluation in Prague on June 28, 2017 [1], the views of 3 foreign experts (NTW members) were communicated in cooperation with Calla – Association for Preservation of the Environment to the Czech public and the authorities. This report first briefly summarizes the main contributions of foreign contributions and then lists the follow-up responses of the Czech authorities and the SEA processor [2].

In the first contribution, Dr David Lowry of the Nuclear Waste Advisory Associates (NWAA) recommends that:

  • all alternatives to radioactive waste management are evaluated,
  • the government listens to and responds to the voices of the local people,
  • public hearings take place not only in the capital city, but also in areas which are potentially affected by waste management plans.

In the second contribution, Dr Paul Dorfman of the Energy Institute at University College of London:

  • draws attention to the fact that the current strategic environmental assessment (SEA) of the national programme is in contradiction with the critical conclusions of previous studies [3] drawn up in connection with the deep geological repository,
  • mentions insufficient assessment of the options for radioactive waste management.

In the third contribution, Dr Jari Natunen of the Mining Delegation of Finnish People:

  • stresses that intervention in the Earth’s crust in relation to the management of radioactive waste will have an impact on the environment and should be properly assessed,
  • recommends transboundary impact assessment of the Czech national programme on the environment,
  • advises on a comprehensive assessment of all alternatives to radioactive waste management.

Three persons responded to the topics mentioned in the contributions.

Deputy Minister of Industry and Trade (MPO) Lenka Kovačovská responded to the contributions as follows:

-The importance of hearing local people’s concerns: deputy minister Kovačovská said that discussions were taking place between MPO and Radioactive Waste Repository Authority (SÚRAO/RAWRA) and local residents in potential sites.

Mrs. Kovačovská’s opinion was in contrast with the viewpoint of Jitka Kantová, a member of the Society for the Rescue of the Church of St. Jiljí (in original Za záchranu kostela sv. Jiljí) in Lubenec in the Ústí nad Labem Region (the Čertovka site), who said at about 1:50:51 that the state conducted a dialogue only with those who agree with the current siting process for a deep geological repository. For illustration, she added her own experience that the mayor of her village meets with state offices on a regular basis, but she is not provided with information from meetings or invited to dialogue (note: the relevant comment was pasted at the end of the audio [2] and you can listen to it at 29:19).

A single public hearing only in the capital: deputy minister Kovačovskásaid the reason for it is the MPO’s intention to have all comments in one place so that everyone has the same access to information.

Deputy minister Kovačovskáalso explained that the SEA process was lengthy due to translations of all the materials into the English and German languages. According to Gabriele Mraz of the Österreichisches Ökologie Institut, however, the problem is that only a non-technical summary of the evaluation was translated into German, not a summary of the national programme itself, which is only in English. Also, the deadline for sending comments within the transboundary SEA process in Austria [4] falls into summer holidays from July 4 to August 1, which is a very unusual approach for Austrian authorities. Other states than Austria, according to deputy minister Kovačovská, had not used their initiative and had not requested a cross-border SEA before 28th June.

-The state closes off its options and eliminates alternatives to a deep geological repository: deputy minister Kovačovská said: “Under current levels of knowledge, and knowing that the lifetime of the intermediate storage facilities is limited, and considering those technologies, we have no other more effective solution” (note: than a deep geological repository).

SÚRAO/RAWRA Director RNDr. Jiří Slovák responded to the following topics:

- Insufficient evaluation of alternatives: director Slovák said that RAWRA has focused on the evaluation of concepts that are verifiable in practice, whereas, for example, the concept of deep boreholes can not be considered as such. In the United States, experiments are in the pilot project stage. The risk is 1/ in the indefinability of the geological conditions at a depth of about 3-5 km and how the material will be stored, so the safety of such storage for hundreds of thousands and millions of years can not be demonstrated, and 2 / in the operational risk of vertical release of the waste to the depth when there is no clear procedure to deal with a possible crash. On the contrary, a deep geological repository can solve all risks.

On the additional comment of  Olga Kališová MSc. that the same argument of impossibility to demonstrate the safety regarding the long-term behavior of radwaste in depth also applies to the deep geological repository due to the inevitable corrosion of the containers, the rock movement and the associated change of the groundwater flow paths, the director Slovák replied that the safety of the deep geological repository is demonstrated for the following reasons: the Finnish store project has undergone the whole process of validation and verification of evidence. The process of corrosion and movement on some fissure systems will, of course, take place. However, the description of the site’s behavior over the last few million years will help roughly predict the behavior of the deep geological repository for millions of years ahead. The behavior of the environment in the future is proven through various scenarios, models and comparison of situations in the rock, Earth’s crust, or through laboratory tests. Additionally, the safety of the deep geological repository is documented on the basis of today’s human knowledge and, according to the decision of the Nuclear Regulator, the concept of a deep repository is safe.

The risks associated with groundwater assessed in the report by GeoBariéra [3]: ​​ director Slovák confirmed that the risk of losing and affecting groundwater was identified at specific repository sites. He said that evaluating the impacts of the national programme on radioactive waste management and spent nuclear fuel did not address these risks. In order to evaluate the risks in the environmental impact assessment (EIA) process, geological survey will be carried out in only two specific sites (note: the two sites are to be selected by 2020), which will demonstrate groundwater impact to a depth of 500 meters and its impact on the Earth’s surface.

SEA assessor RNDr. Milan Macháček (Natura 2000 assessor) responded as follows:

-On the GeoBariéra report: SEA assessor Macháček said that this report had focused on evaluating conflicts of interest of candidate sites. Extensive exploration areas are currently being established (note: their validity expired on December 31, 2016 [5] and the whole process has become complicated [6]). For detailed geological research on two specific locations, the project will be elaborated on using more detailed information about the site and the individual phases of the project will be submitted to the EIA process. There are technical means to limit the environmental impact of geological survey. In his opinion, the assessment of the national programme is not in contradiction with the GeoBaiéra report. The EIA will also be carried out for the construction of an underground research laboratory (URL) in the final location. At that time, further updates of the national programme on radioactive waste management will also have to be developed.

 On the additional comment of Olga Kališová, whether the SEA processor could clarify why the assessment of the concept is not in contradiction with the GeoBariéra report, Mr. Macháček replied that, because he would assume that this would surely be a frequent comment, the answer will be given later in a written record.

Note: During the SEA public hearing, there were also contributions from other Czech non-governmental organizations and experts involved in the radioactive waste management in a long-term, which are not mentioned in this report for capacity reasons.

 Author: Olga Kališová, MSc.


[1] Press release of Nuclear Transparency Watch “Evaluation of the National Program on Radioactive Waste and Waste Management: NTW Calls for Proper Public Discussion and Participation” dated June 28, 2017

[2] Audio from the public discussion “Update of the National Programme on Radioactive Waste and Spent Nuclear Fuel Management in the Czech Republic”  and its assessment on the environment in Prague on 28 June 2017 with the views of 3 foreign experts from 01:01 and Czech reactions at 09:11. Please use your headphones for better sound.

[3]GeoBariéra, Provedení geologických a dalších prací pro hodnocení a zúžení lokalit pro umístění hlubinného úložiště ["Performing geological and other work for assessing and selecting sites for the deep geological repository: Preliminary feasibility study."]; Prague (2005): find the full document in Czech.

[4] Tschechische Entsorgungsstrategie 2017, Umwelt Bundesamt.

[5]Press release of Platform Against Deep Repository “Municipalities threatened by a deep geological repository have succeeded: the state must stop geological surveys in seven sites”dated March 1, 2017.

[6] Press release of Platform Against Deep Repository “Radioactive Waste Repository Authority – our common unpredictable future” dated June 28, 2017


Presentation of Johan Swahn on Radioactive Waste Management, ENSREG 28 June 2017

During the 4th European Nuclear Safety Conference taking place in Brussels in June 28-29, Johan Swahn, director of the swedish NGO MKG and member of the board of NTW was invited to speak in the panel on Radioactive Waste Management as a representative of civil society.

In parallel of the European Commission’s evaluation of the implementation of the Radioactive Waste Directive by the member states, NTW follows the way member states work with radioactive waste management.

Johan Swahn stated that  effective transparency is important for successful decisionmaking in radioactive waste management. All three pillars of the Aarhus Convention (access to information, to public particiption and to justice)  have to be implemented. In addition the civil society has to be resourced in a way that preserves the independence of local communities and environmental NGOs.

Johan Swahn also gave an overview of the Swedish situation, showing how a relatively good implementation of the Aarhus Convention there  allows the civil society  to participate effectively in the consultation processes, especially for the planned repository for spent fuel in Forsmark in Östhammar community.

Download his full presentation here.





Nuclear Life-time extension: Presentation of Jan Haverkamp 29 June 2017 ENSREG

During the third panel in the ENSREG meeting held on 29 June in Brussels, Jan Haverkamp presented the position of NTW concerning the life-time extension of nuclear power plants in Europe.

As the lack of fund for decommissioning is used as a justification for life-time extension of nuclear power plants, our concern is that economic arguments interfere with risk management.

NTW stand is that citizens have a natural legal, moral and logical right  to be consulted in the decisions concerning life time extension of NPPS.  The logical instruments for their consultation and participation are the Espoo and Aarhus Conventions and (transboundary) environmental impact assessment.

Download the full presentation of Jan Haverkamp here.


RWM image

Evaluation of Czech national programme on radioactive waste and spent fuel management: NTW calls for proper public discussion and participation

On 28.06.2017, a public hearing is held in Prague in the strategic environmental assessment (SEA) procedure on the Update of the National Programme on Radioactive Waste and Spent Nuclear Fuel Management, and the Evaluation of the Czech National Programme on radioactive waste [1].

NTW wishes to express its high concerns on several aspects of this evaluation. Our network supports the position of the Czech organizations the Green Circle (The Association of Environmental Organizations) and Calla – Association for Preservation of the Environment [2].

  • The evaluation process ignores the request from the Czech Ministry of Environment at the conclusion of the SEA scoping procedure “To complement and comprehensively evaluate other realistic (feasible and technically feasible) options for the solution of the spent fuel management and to determine their effects on the environment and public health.”[3]It’s important to stress that no alternatives have been added and no evaluation of those alternatives has been carried out. The complexities of the design concept have not been evaluated; for instance, a zero option in the form of long-term storage in interim storage facilities was not analyzed, neither reprocessing of spent fuel and disposal of the waste from that process were fully evaluated – the SEA processors only investigated the option of a deep geological repository, which should be in operation since 2065.
  • NTW fears an increase in distrust in the population because the impacts of deep drilling which will be carried out on two sites and which will have impacts both on surface and groundwater, are assessed as zero without detailed investigation. Also, socio-economic, air, noise, surface and ground water, soil, nature and landscape impacts later in the stage of the construction of an underground research laboratory and repository, are rated as zero or only slightly negative. Such results are in stark contrast with previous studies like the one made by GeoBariera commissioned by the Radioactive Waste Repository Authority (RAWRA) [4].
  • The evaluated national programme already did not deliver on several of its objectives. Several of the targets for 2015 have not been met. The Working Group for Dialogue mentioned in the programme dissolved in 2016.

NTW calls on the Czech authorities responsible for the evaluation and the national programme itself, to amend the presented material according to comments from the public and the Ministry of Environment and submit it to a proper public discussion.

Olga Kališová of Calla said:Despite the sweet talk, the reality shows the Czech state authorities do not effectively promote nationwide public participation in decision-making process related to radioactive waste management. Therefore, I welcome the efforts of the Nuclear Transparency Watch to alert to these serious issues. May this public announcement not “only“ capture attention of ordinary people in the Czech Republic and worldwide, but mainly make a positive shift in a mindset of people dealing with radioactive waste management on all levels. Otherwise, the tension will escalate which will not benefit anyone.“

For more information:

Olga Kališová, MSc., Energy Consultant, Member of Nuclear Transparency Watch, Calla–Association for Preservation of the Environment,   +420 720 995 944,

 Notes to the editor:

[1] Notice of public hearing of the “Update of the National Programme on Radioactive Waste and Spent Nuclear Fuel Management” and its Strategic Environmental Assessment”.  (czech version)

[2] Press release by Calla – Association for Preservation of the Environment and the Green Circle dated June 27, 2017. 

[3] Evaluation of the “Update of the National Programme on Radioactive Waste and Spent Nuclear Fuel Management” elaborated according to Act No. 100/2001 Coll., ECO-ENVI-CONSULT, SOM s.r.o. And EKOEX, January 2017.

[4] GeoBariera, Provedení geologických a dalších prací pro hodnocení a zúžení lokalit pro umístění hlubinného úložiště ["Performing geological and other work for assessing and selecting sites for the deep geological repository: Preliminary feasibility study."]; Prague (2005).

Anomalies in Flamanville EPR reactor vessel: ACRO calls for more transparency

EPR cuve du réacteurThe steel anomalies in the reactor vessel of the EPR  in Flamanville and many steam generators have led to one of the most serious crises faced by the French nuclear industry.

The report of the High Committee on Transparency and Information on Nuclear Safety (HCTISN) highlights the absence of precise information from Areva and EdF on the serious problems affecting the reactor vessel of the Flamanville EPR . The finding would be the same for steam generators. ACRO, therefore calls for more transparency.

The association made an inventory of the available documentation and reconstructed a chronology of the events on a dedicated website:

Find the full press release of ACRO published on 21.06.17 in french here.

New study: Health effects of ionising radiation and their consideration in radiation protection

By Gabriele Mraz from the Austrian Institute of Ecology and Oda Becker, Independent Expert for the Risks of Nuclear Facilities based in Hannover. It is supported by the Vienna Ombuds-Office for Environmental Protection. 

While the effects of high radiation doses on humans (like acute radiation sickness) are documented quite well, the health effects of low radiation doses are still discussed highly controversially in radiation protection. Low doses result from nuclear installations during normal operation, from accident situations in nuclear facilities for workers and the public, from the nuclear bombs on Hiroshima and Nagasaki, but also from medical exposure and natural background.

Based on new insights in health effects it can be concluded that the dose limits and levels in the BSS-Directive (Council Directive 2013/59/Euratom) and in the Food Level Regulation (Council Regulation Euratom 2016/52) are too high. They do not provide enough protection, especially for the embryo/foetus, children, pregnant women and young adults.

The extended summary can be downloaded here: summary

Downolad the full study

In the Joint Project, European NGOs and research institutions cooperate since 2003 on safe and sustainable energy issues with a focus on anti-nuclear activities in Central and Eastern Europe.
The long-term goals of the Joint Project are a nuclear phase-out in Europe, no new-build nuclear power plants, no renaissance of nuclear energy, no lifetime extension of old reactors, safe management of spent fuel and radioactive waste and adequate public participation.

JS enef

How can civil society influence nuclear waste decisions? Johan Swahn, ENEF May 23 2017

The Chair of our RWM working group Johan Swahn was a panelist in ENEF forum on 22-23 may in Prague.  The theme this year was: “60 years of Euratom”. We publish here his presentation. 

“First of all I would like to thank the European Commission for its efforts to make the ENEF more balanced when it comes to the points of view represented at the meeting. It is really vital that many voices can be heard. The challenges ahead are large as much of Europe is moving ahead and are ending the nuclear energy programmes that were started 60 years or so ago. Some European Member States have not yet come to the understanding that the apparent advantages of nuclear energy, such as low carbon dioxide emissions compared to coal, are countered by many disadvantages compared to strongly expanding renewable energy systems.

 I have worked with radioactive waste issues for many years, first at university and since 12 years for the Swedish environmental movement. In Sweden the systems set up for access to information, consultation and public information are very favourable for dialogue. It is not always easy to interest the general public or politicians in the complexity of radioactive waste issues, but the interactions between the industry (SKB), the regulator (SSM), the nuclear communities (Östhammar and Oskarshamn), the Swedish Council for Nuclear Waste (the Government’s scientific advisory board), academia, the environmental movement and other actors are well developed.

In order to allow strong engagement from an environmental movement that has many priorities and limited resources the Government has since 2004 even resourced them. MKG has for many years, like the nuclear communities, received funding from the Swedish nuclear waste fund. Coming from the Swedish experience, the transparency of European and national radioactive waste management governance is vital from an NGO perspective. In order to achieve successful and safe radioactive waste management it is vital to involve civil society in an open process all the way from early planning through decision-making to implementation. This also means giving environmental NGOs the resources to engage in a strong and sustainable manner.

 Yesterday, and today, as I listened to speeches, presentations, and sat around the tables in the World Café, two things struck me. The first was positive. I clearly felt that many, but not all, persons I interacted with were willing to listen and take in things that perhaps were new to them. Just as I have learnt that by listening and taking in new information I can come to develop a more informed opinion.

But there was also a feeling of travelling back in time. Maybe discussing the “60 Years of Euratom” contributed. I was not there in the 1950s, but it must have been similar. At that time nuclear energy was a new technical possibility, a peaceful atomic age was growing from the nuclear weapons developed during the Second World War. Everything was positive. Radioactive waste was not a problem. Accident risks were seen to have such a low probability that they could be ignored. Routine releases from operational reactors were not worse than the chemicals that were released from other industries. Nuclear power would be cheap and save the world.

 I had a feeling that was what I also heard many times yesterday. Nuclear has no problems. And it can save the world from climate change. All that has to be done to once again realise the vision of a great future for nuclear energy, is to inform the public, and people like me, so that we will understand. That nuclear energy is not so expensive. And that it does not cause so much release of carbon dioxide.

 But this is 2017. What if the general public now understands that nuclear energy may not the best way forward? What if they are willing to pay extra to make their energy future a modern one based on renewable energy?I know that some of you have researched and understand how the European and global energy systems are developing. But many of you have not. Knowing many people working in the renewable energy sector I have to say that my impression is that their knowledge of nuclear is much larger than many nuclear enthusiasts’ knowledge of alternatives.

 But I digress. This panel is about radioactive waste management. On the other hand there is a connection. One clear reason that the general public sees nuclear energy as more problematic than a renewable energy system is that nuclear energy produces waste. And not just any waste. Waste that is highly dangerous to begin with and needs to be isolated from mankind and environment for ten thousand, a hundred thousand or even a million years.

 In this panel we will among other things discuss the European Commission’s report on the Member States’ implementation of the Spent Fuel and Radioactive Waste Directive. It is a very good report. The Commission has taken a broad perspective on what is happening in Europe. Well worth reading, but also food for thought and for humble reflections. There are many interesting things to discuss after reading the report. Why are there so poor estimates for future waste production? Why are so many Member States still lacking regarding policies, concepts, plans and site selection, especially for high-level radioactive waste? Why do so many Member States have unverifiable systems for paying for waste management and decommissioning of reactors meaning that there is a significant risk that the tax-payer will have to pay for the nuclear industry’s waste? Why do so many member states not have appropriate systems for transparency of information and good public participation processes?

 For an environmental NGO this last issue is of extra importance. The Commission needs to request clarifications and express its opinion to Member States on the implementation of Article 10 on transparency in the Spent Fuel and Radioactive Waste Directive. The Commission also needs to encourage a broad discussion of transparency in radioactive waste management among the Member States at the European level, as well as continuing to support civil society participation in such discussions.

I end by stating something that may be evident, but unfortunately still needs to be said. After the ENEF Plenary there will be a report written that will try to summarise some conclusions from the meeting. This will be done by the Steering Committee led by the Commission. It is important that all views that have been presented at the plenary are taken into due account by all parties when summarising these two days and also when looking forward and planning the next ENEF plenary. In this meeting there are once again many environmental NGO’s ready to interact and learn. They are also well worth listening to. The goal of the ENEF is dialogue. Let us respectfully continue it.”

You can find the agenda of the 2017 ENEF meeting here.

You can watch again the streaming of the ENEF: here.



The struggle of Rosatom to understand what transparency is

NTW member, journalist and activist Andrey Ozharkovsky is refused information

Blog from Jan Haverkamp, 19 May 2017

When he was preparing for his speech for a group of local citizens and experts in the town of Mersin in South-East Turkey about how the nearby situated Akkuyu nuclear energy project is seen from a Russian perspective, member of the Russian Socio-Ecological Union – one of the oldest environmental organisations in Russia – and journalist Andrey Ozharkovsky tried to get much as possible information also directly from the side of the foreseen builder, owner and operator of the power plant, Rosatom. Without success he approached Rosatom’s Turkish daughter for the project JSC Akkuyu Nuklear for the latest version of the EIA documentation. Also requests to Rosatom itself for many documents went without response. On the basis of his own inside knowledge and whatever there is available publicly, he could, however, still sketch an insightful picture. He has studied the dynamics around the Hanhikivi project that Rosatom is pushing in Finland, the Astravetz project in Belarus. He has followed for decades the work of Rosatom in countries like Bulgaria and Hungary. He could get access to a lot of documentation published in the Russian, Turkish and international media about Akkuyu as well.

 He started his introduction with: “”I am an anti-nuclear activist in my country. I believe in the need to maintain good-neighbourly relations between our two countries, but nuclear issues can create problems in our relations.” He ended his presentation:  “I think that the Akkuyu nuclear power plant construction project is an example of mutual non-beneficial cooperation, as a result of which a threat to the good-neighbourly relations between Russia and Turkey can be created.”

Rosatom listened in. After his presentation in Mersin, it finally reacted with a 2 page densely written diatribe (see illustration): “You sent a request for the Akkuyu nuclear power plant. Before returning to this issue, we want to report the following. Turkish media Jumhuriyet published an article on May 2, 2017 on the issue of nuclear waste, which will be produced during operation of the Akkuyu nuclear power plant. The author of the material, Abidin Yagmur, quotes and refers to your speech at the panel discussion organized in the Mersin House of Physicians, where you came by the invitation of the Antinuclear Platform. To our great regret, we are forced to pay attention to your erroneous statements, which are baseless and contain inaccurate information on this issue.” It then continues to accuse Ozharkovsky of not having asked Rosatom experts for up to date information, of making false public statements and misleading the public.

 Although Russian legislation is quite clear that it bans the import of nuclear waste, and only allows nuclear waste to be transported to the country for reprocessing, whereby resulting waste has to be returned to the country of origin, Turkish citizens believe that there is a bilateral agreement in place that will allow full transfer of nuclear waste from Akkuyu to Russia. Ozharkovsky had pointed out that this issue is not at all settled and feared that Turkey might be misled into believing that transfer for reprocessing would be a solution to the high-level waste problem. An impression that also the public in Bulgaria and Hungary sometimes still has, although these countries are now struggling with what to do with returning wastes. Rosatom quotes Ozharkovsky’s speech that “the nuclear waste that will be generated during the operation of the Akkuyu nuclear power plant could cause a crisis in relations between Turkey and Russia.”

 It then accuse him of “insulting remarks to the professionals of the Russian nuclear industry, which celebrated its 70th anniversary last year. We consider such statements unethical and unacceptable. Rosatom State Corporation, which always stands for the development of an open dialogue based on reliable and relevant information, has the right to draw a conclusion about your unwillingness to constructive dialogue and interest in loud statements that do not correspond to reality.” After an indeed factually right description of the reprocessing agreements Rosatom has in place with different countries and a description of the international and national basis for the cooperation between Turkey and Russia, it concludes: “Thus, the statement about the absence of a long-term waste management plan for the Akkuyu nuclear power plant is erroneous and has no basis.”

 Well, that is a wrong conclusion, because Ozharkovsky had made clear that also Russia has no final disposal for radioactive waste, nor is there one for the foreseeable future in Turkey. And it is that lack of clarity and confusion of short term management with final solution that could, according to Ozharkovksy, lead to future tension between the countries.

Rosatom then provides one paragraph of general PR-talk about the containment of Akkuyu – one of the issues about which Ozharkovsky had requested substantial information.And then it states: “Sorry, we are not ready to discuss with you on this subject, despite your unconditional knowledge in the design of special objects and the possibility of computer modeling.”

 That attitude towards transparency does not bode well for cooperation between Rosatom and citizens in European countries where it wants to be active, including Turkey. A justification discussion including the environmental, social and economic risks of new nuclear projects cannot be based on PR talk and has to include a well informed public. That needs openness to requests for information from the public, and most certainly from informed NGOs and their members. It needs openness to discuss those issues without intimidation. And above all, it needs honesty about the facts and uncertainties and true, not only formal respect for these citizens.

 ILLUSTRATION: download Rosatom letter translated in english here.

See the scan of the russian version here.