Author Archives: Nuclear Transparency Watch


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.


IRSN rejet radioactif carte

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
  • Russia tries to be reassuring, November 24
  • IAEA data leaked, 27 November

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 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.


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.

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.



28 recommendations to limit the consequences of a nuclear crisis for the population

The road map established at the conclusion of the European research project Shamisen underlines the importance of involving the population in the management of an accident and taking into account the social, economic and psychological effects, particularly in the context of an evacuation of contaminated territories.

This article was published on the website of the IRSN, and can be found in french here.

What to do or not to do in the case of a nuclear accident? How to improve the medical follow-up and living conditions of the affected population? Because the decisions taken at the time of the accidents of Chernobyl and Fukushima sometimes “did more harm than good”, the European Commission launched Shamisen, a research program that brought together 19 European and Japanese organizations including IRSN , as well as American, Belarusian, Russian and Ukrainian experts.

The work resulted in the development of 28 specific recommendations for the nuclear accident to improve both crisis preparedness, crisis management and the post-accident phase. In addition, general principles have been identified that can be applied to other types of accidents and disasters.

This roadmap aims to extend the management of the nuclear accident beyond the protection of the population against exposure to ionizing radiation. Measures such as the evacuation of contaminated areas have important psychological, social and economic consequences which must be taken into account.

In summary, recommendations focus on three main objectives to involve the affected population in decision-making alongside experts and authorities:

1. Take into account the well-being of the affected population

2.Promote the participation of the affected population and other actors such as medical staff

3.Respect the autonomy and dignity of the affected populations.

Downolad the full 28 recommandations here.

“The legacy of Nuclear Power” by Prof.Andrew Bowers, book review and interview by Jan Haverkamp

In september 2016, Andrew Blowers, Emeritus Professor of Social Sciences at the Open University published « The Legacy of Nuclear Power ».  Nuclear energy leaves behind a dangerous legacy of radioactive wastes in places that are remote and polluted landscapes of risk. Four of these places – Hanford (USA) where the plutonium for the first atomic bombs was made, Sellafield, where the UK’s nuclear legacy is concentrated and controversial, La Hague the heart of the French nuclear industry, and Gorleben, the focal point of nuclear resistance in Germany – provide the narratives for this unique account of the legacy of nuclear power. The Legacy of Nuclear Power takes a historical and geographical perspective going back to the origins of these places. The case studies are based on a variety of academic and policy sources and on conversations with a vast array of people over many years.

Jan Haverkamp is Vice-Chair of Nuclear Transparency Watch. He’s an expert consultant on nuclear energy and energy policy for WISE, Greenpeace Central and Eastern Europe, Greenpeace Switzerland. In mai 2017, he published a book  review in Nuclear Monitor #843 : “The Legacy of Nuclear Power is a book about nuclear waste. But different than most, the retired UK Open University professor Andy Blowers does not approach the issue from the side the techniques under investigation to manage it. His basis is the story of five nuclear legacy sites (note: Hanford, Sellafield, La Hague, Bure and Gorleben) but analysed from the experiences of the communities who live there.” 

« The leading line is the discovery that the nuclear legacy appears to be connected to peripheral places – mostly peripheral in a geographic sense, lowly populated, but also economically weak, becoming depending on a from the outside imposed nuclear mono-culture »

Find the full review on Wise Monitor here.

Jan Haverkamp also interviewed Prof.Andrew Blowers to explore the issues of the book more in detail. This interview is a reflection on what drove Andrew Blowers to dedicate over 30 years of this life to the issue of radioactive waste and the nuclear legacy.

Find the full interview on Wise Monitor here.


legacy of nuclear power

The Legacy of Nuclear Power, by Andrew Blowers

Routledge, Tayler & Francis Group.

Available in hard cover, paperback and as e-book (epub) :

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 Kovačovská said 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 Kovačovská also 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 extension: présentation 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.


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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).