Austria, cesium, Chernobyl, Convention Transboundary Impacts, Economic Commission for Europe, EIA, environment, Environmental Impact Assessment, Espoo, Finland, Germany, Hinkley Point, Ireland, Moorside, Netherlands, new nuclear power stations, non-compliance, Norway, nuclear accident, nuclear disaster, nuclear energy, nuclear power, public participation, radioactive fallout, Sellafield, serious nuclear accident, transboundary impacts, Transboundary Implementation Committee, UK, UN, UN Economic Council, UNECE, weather, wild boar, wind, Windscale
A nuclear accident anywhere in Europe may seriously impact much of Europe, as did the Chernobyl Nuclear disaster, and to an apparently lesser degree the UK’s Windscale Nuclear disaster. In fact, Europe is still so seriously contaminated, albeit in a splotchy manner, from Chernobyl that it really cannot afford another nuclear accident. Similarly, a nuclear accident in the US could seriously impact much of North America. Last year a wild boar in southern Switzerland was found to be contaminated at 9,900 Bq/kg of radioactive Cesium 137, or 99 times the amount of radiation in food allowed in Japan (100 Bq/kg all radionuclides), over 16 times the amount of radioactive Cesium allowed in European food (600 Bq/kg Cs) and over 8 times the exceedly high levels of radioactive Cesium allowed in US food (1200 Bq/kg Cs). 30 years after Chernobyl, half of the high levels of radioactive Cesium 137 which fell upon Europe still remain, since Cesium 137 has a half life of 30 years. The mountain areas appear especially hard hit, having seemingly caught part of the radioactive cloud and/or rain or snow clouds which brought the radiation down with the precipitation. Some other radionuclides have not even been through one half life. In the Fukushima area, approximately 30,000 Bq/kg of radioactive Cesium is found in wild boar. In 30 years Fukushima Wild Boar will presumably be 15,000 Bq/kg. http://www.independent.co.uk/news/world/asia/radioactive-wild-boars-rampaging-fukushima-nuclear-site-japan-a6972361.html https://web.archive.org/web/20160512125610/http://www.bag.admin.ch/themen/strahlung/12267/12274/?lang=fr
In March, the UN Economic Council, Economic Commission for Europe, Environmental Impact Assessment in a Transboundary Context Implementation Committee ruled regarding the proposed new Hinkley Point Nuclear Power Station in the UK “that the characteristics of the activity and its location warrant the conclusion that a significant adverse transboundary impact cannot be excluded in case of a major accident, accident beyond the design-base or disaster. The Committee also finds that, as a consequence of its conclusion concerning the likely significant adverse transboundary environmental impact, the United Kingdom is in non-compliance with its obligations under article 2, paragraph 4, and article 3, paragraph 1 of the Convention.” (ECE/MP.EIA/IC/2016/2 See more further below).
Convention found here: https://web.archive.org/web/20150513040611/http://www.unece.org/fileadmin/DAM/env/eia/documents/legaltexts/Espoo_Convention_authentic_ENG.pdf
“The Convention on Environmental Impact Assessment in a Transboundary Context (informally called the Espoo Convention) is a United Nations Economic Commission for Europe (UNECE) convention signed in Espoo, Finland, in 1991 that entered into force in 1997. The Convention sets out the obligations of Parties—that is States that have agreed to be bound by the Convention—to carry out an environmental impact assessment of certain activities at an early stage of planning. It also lays down the general obligation of States to notify and consult each other on all major projects under consideration that are likely to have a significant adverse environmental impact across boundaries. As of April 2014, the treaty had been ratified by 44 states and the European Union.” https://en.wikipedia.org/wiki/Convention_on_Environmental_Impact_Assessment_in_a_Transboundary_Context
This is our rough map of potential fallout from an accident at Sellafield or the proposed Moorside Nuclear Power Station, further up the coast from Hinkley Point. It is based on maps of the impact of the Windscale and Chernobyl accidents. Essentially all is at risk, depending on wind direction and precipitation. The winds are more variable than one might think, as discussed here: https://miningawareness.wordpress.com/2015/04/25/windscale-moorside-sellafield-accident-impact-fallout-map
However, the official map submitted by Austria quantifies the amount of fallout and shows that the impacts may be even more widespread. https://web.archive.org/web/20140717191049/http://www.umweltbundesamt.at/fileadmin/site/publikationen/REP0413.pdf This is the model which appears in the document submitted by the Austrian government but from its original site.
It is for the weather on that particular day and year. Other days and other nuclear reactors may be found here: http://flexrisk.boku.ac.at/en/evaluation.phtml#form The UK is listed under GB. As would be suspected by looking at this wind map, sometimes France or Spain are badly hit: http://earth.nullschool.net This document shows the total risk for all nuclear power stations for Europe (together) : https://meteo.boku.ac.at/report/BOKU-Met_Report_23_PRELIMv2_online.pdf More information, documents and tools are found here: http://flexrisk.boku.ac.at/en/
Some excerpts from the UN “Economic Commission for Europe Meeting of the Parties to the Convention on Environmental Impact Assessment in a Transboundary Context, Strategic Environmental Assessment Implementation Committee Thirty-fifth session Geneva, 15–17 March 2016“:
“52. Moreover, at its thirty-third session, following a comment by the United Kingdom questioning the decision of the Committee to open a Committee initiative, the Committee recalled its reasoning behind its finding of a profound suspicion of non-compliance and its subsequent decision to begin a Committee initiative. In the Committee’s view, the opportunity provided by the United Kingdom to Austria to participate under the Espoo Convention indicated an agreement of the two Parties that a likely significant environmental impact on Austrian territory could not be excluded, since otherwise there would have been no reason for the United Kingdom to engage with Austria following the latter’s request under the Espoo Convention. The likelihood of a significant environmental impact outside the territory of the United Kingdom had also not been excluded by the Netherlands and Norway, in their letters of 23 January and 5 February 2014, respectively.”
65. Having considered the above, the Committee adopts the following findings with a view to bringing them to the attention of the Meeting of the Parties for formal adoption in accordance with paragraph 13 of the appendix to decision III/2. Notification (article 2, paragraph 4; and article 3, paragraph 1)
66. The Committee notes that the activity at HPC is a proposed activity listed in Appendix I, item 2, and finds that the characteristics of the activity and its location warrant the conclusion that a significant adverse transboundary impact cannot be excluded in case of a major accident, accident beyond the design-base or disaster. The Committee also finds that, as a consequence of its conclusion concerning the likely significant adverse transboundary environmental impact, the United Kingdom is in non-compliance with its obligations under article 2, paragraph 4, and article 3, paragraph 1 of the Convention.”
“1. On 12 and 22 March 2013, a member of the German Parliament provided information to the Implementation Committee under the Convention on Environmental Impact Assessment in a Transboundary Context (Espoo Convention) and its Protocol on Strategic Environmental Assessment, regarding the planned construction of a nuclear power plant (NPP) in Hinkley Point C (HPC) by the United Kingdom of Great Britain and Northern Ireland. In the information provided, the member of the German Parliament alleged noncompliance by the United Kingdom with its obligations under the Convention with respect to the proposed activity noting that Germany had not been notified and the German public had not been consulted on the activity.
2. On 27 March 2013 the Irish non-governmental organization (NGO) Friends of the Irish Environment also provided information to the Implementation Committee regarding the same proposed activity and alleging noncompliance by the United Kingdom with its obligations under the Convention with respect to the proposed activity noting that Ireland had not been notified and the Irish public had not been consulted on the activity“.
“9. On 1 September 2014, the Committee received information concerning the proposed activity in question from the Irish NGO, An Taisce or the National Trust for Ireland.”
“19. On 9 November 2009, the United Kingdom published a public consultation on six draft energy infrastructure National Policy Statements (NPSs), including one on nuclear energy (the nuclear NPS), as well as a draft appraisals of sustainability incorporating strategic environmental assessments. The nuclear NPS provided a list of potential sites for new NPPs, such as HPC. On 13 November 2009, copies of the energy NPS were sent to the European Union (EU) and European Economic Area (EEA) Member States for consultation on possible adverse transboundary effects.
20. On 19 February 2010, Austria replied that the documentation provided was sufficient for the planning decision, but that transboundary effects could not be ruled out. Therefore, Austria asked to be kept informed.
21. On 22 February 2010, Ireland notified that it reserved its position on transboundary effects. On 27 July 2010, the United Kingdom informed Ireland about its position that, having reviewed all data and advice from the regulators, the United Kingdom believed that the construction of new nuclear power stations was not likely to have any significant effects on the environment of Ireland, and that transboundary effects could be caused only by an unintended release of radiation from an accident, for example, but the probability of such transboundary effects was very low owing to the United Kingdom’s robust regulatory system.
22. On 18 October 2010, consultations on the revised draft energy NPSs were launched, including a revised nuclear NPS and revised appraisal of sustainability, which concluded that there was no likelihood of significant transboundary effects.
23. On 28 October 2010, the revised draft documentation was sent to all EU Member States. On 24 January 2011, Austria replied that transboundary effects were remote, but could not be excluded, while Ireland replied that the conclusion about the likelihood of significant transboundary effects should better be dealt with at the site selection specific stage. Ireland did not request formal transboundary consultations at that stage and stressed that its concerns would better be addressed through on-going dialogue on nuclear issues and at the project level.”
“28. Correspondence for the exchange of information between the two Parties followed until March 2013. In the meantime, Austria decided to carry out the public participation procedure according to the Austrian EIA Act. On 5 March 2013, Austria submitted to the United Kingdom an expert statement7 and comments by members of the public. The expert statement concluded that severe accidents could not be excluded, even if their calculated probability was very low; for this reason and since their effects could be widespread and long-lasting, such accidents should be included in the EIA procedure. The expert statement recommended that a conservative worst case release scenario be included in the EIA, in particular because of its relevance for impacts at greater distance.8
29. On 13 March 2013, the member of the German Parliament wrote to the Secretary of State with the request that the German public be given the opportunity to participate in the EIA procedure in the United Kingdom. On 15 March 2013, the United Kingdom authorities responded that that this representation would be taken into account in the decision on whether to grant development consent for the construction of the HPC.
30. On 19 March 2013, the Secretary of State for Energy and Climate Change issued a Development Consent order for the construction of the reactors. In reaching the decision, the Secretary of State considered the decision of the Planning Inspectorate that there was no likelihood of significant transboundary environmental impacts. In response to the recommendation by Austria that severe accidents with high releases of caesium should have been included in the EIA procedure, the Secretary of State stated that such accidents were so unlikely to occur that it would not be reasonable to investigate the issue for EIA purposes.
[Footnote “7 Hinkley Point C, Expert Statement to the EIA, Environment Agency Austria, Vienna, 201, available at: https://web.archive.org/web/20140717191049/http://www.umweltbundesamt.at/fileadmin/site/publikationen/REP0413.pdf 8 Ibid. recommendation at p. 6, 20 and 27“.]
“33. In the information provided by the member of the German Parliament, it is alleged that the United Kingdom failed to comply with its obligations under the Convention on the grounds that as the Party of origin, it failed to notify affected neighbouring States, including Germany and Ireland, about the proposed construction of the two HPC reactors. As a result, Germany and the public in Germany did not have the opportunity to participate in the EIA procedure.
34. Specifically, according to the information provided by the member of the German Parliament, the proposed activity is an activity listed in appendix I, item 2, of the Convention, and the Party of origin had to comply with article 2, paragraph 2. It is alleged that by failing to notify Germany and providing the German public the opportunity to participate, the United Kingdom failed to comply with article 2, paragraphs 4 and 6; article 3, paragraphs 1 and 8;and article 4, paragraph 2, of the Convention. It is further alleged that by issuing the development consent order of 19 March 2013, the United Kingdom was not in compliance with article 6, paragraph 1, of the Convention.
35. In the view of the member of the German Parliament, calculations of probability cannot be applied to an activity of that size and a severe accident cannot be excluded beyond doubt. In support of this argument, she refers to the events in Chernobyl and recently Fukushima, and to the Finnish EIA report on the Fennovoima NPP, which had acknowledged that the impacts of an extremely unlikely serious NPP accident would extend beyond Finland’s borders.
36. In the information provided by the Friends of the Irish Environment, it is similarly alleged that by failing to notify Ireland about the proposed activity the United Kingdom failed to comply with its obligations under article 2, paragraph 6, article 3, paragraphs 1 and 2, article 5 and article 6, of the Convention. In support of its allegations, the NGO refers to prior findings and recommendations of the Committee with regard to the planned construction of a NPP in Metsamor, Armenia (EIA/IC/S/3) and of an NPP in Ostrovets, Belarus (EIA/IC/S4). It also refers to major, serious and other nuclear accidents with wider consequences to highlight that a severe accident may cause transboundary impacts.
37. In its representation to the Committee, Austria considers itself potentially affected by the proposed NPP. In its view, on the basis of the Convention and other relevant documents, severe accidents or risks with low probability are covered by the Convention. Therefore, countries should be notified about nuclear installations that seem to have a low likelihood of significant transboundary impacts; and conservative worst case scenarios, which are especially relevant for transboundary impacts, should be assessed in an EIA. In the information it provided to the Committee, Austria also claimed that there was lack of clarity as regards applicable legislation in the United Kingdom, including the public participation procedure in the pre-examination and examinations phases within the planning process; that the information it had received was initially scattered and comprehensive information had been received end of December 2012; and that the deadlines imposed on Austria to provide its comments were very tight, since the decision on development consent had been made end of December 2012 and a final decision would be taken by 19 March 2013. Austria explained that due to the time constraints, it did not ask for consultations according to article 5 of the Convention and decided to carry out the public participation procedure according to its domestic legislation.”
[Footnote: 9 Directive 2014/52/EU of the European Parliament and of the Council of 16 April 2014 amending Directive 2011/92/EU on the assessment of the effects of certain public and private projects on the environment Text with EEA relevance“.]
“38. Germany was not notified by the United Kingdom and claimed that taking into account the opinion issued by the European Commission on 3 February 2012,10 it did not consider that the proposed activity was likely to cause significant adverse transboundary environmental impact.
39. Ireland claimed that since the United Kingdom had concluded that the activity was not likely to give rise to a significant adverse transboundary impacts on the environment of another EEA State, the requirements under the Convention regarding notification to other States did not arise and formal notification was not necessary. Ireland, however, was aware since 2009 of the United Kingdom’s nuclear NPS, had actively been involved in that regard and had maintained regular contact at official level with the United Kingdom on nuclear matters.
40. The Netherlands contended that it could not confirm that the proposed NPP was not likely to cause significant adverse transboundary impact on the territory of the Netherlands, because of lack of any information regarding the activity. It added that it would have been reasonable if the United Kingdom had informed the Netherlands, had given an insight in the conclusion that the proposed activity had no likely significant adverse transboundary effects on the Netherlands and had offered the opportunity for public consultations.
41. Belgium confirmed that it had received a notification concerning a proposal of strategic siting assessment criteria for NPPs in August 2008, but not for the HPC. Based on the opinion by the European Commission of 3 February 2012,11 Belgium considered that the proposed activity was not likely to cause significant transboundary environmental impact on its territory.
42. In Norway’s view, experience and impact assessments confirmed that an NPP in operation represented a risk of transboundary pollution in neighbouring countries in case of major accident or incident. Considering its geographical position, Norway could not confirm that in case of major accident or incident, it was not likely that the proposed activity could cause significant adverse transboundary environmental impact on Norway’s territory. Given its proximity to the United Kingdom, Norway considered it important to receive notification and information about any NPP in accordance with the Convention.” [Footnote “10 Opinion of the European Commission of 3 February 2012 relating to the plan for the disposal of radioactive waste arising from the two EPR reactors on the Hinkley Point C nuclear power station, located in Somerset, United Kingdom (2012/C 33/01). The opinion had concluded that, both in normal operation and in the event of an accident of the type and magnitude considered, the implementation of the activity would not be liable to result in a radioactive contamination of the water, soil or airspace of another Member State. Footnote “11 See note 5 above“. Footnote “5 Information on Committee initiatives, including relevant documentation, is available from https://web.archive.org/web/20160401034538/http://www.unece.org/environmental-policy/conventions/environmental-assessment/areas-of-work/review-of-compliance/committee-initiative.html“]
“46. In the view of the United Kingdom, there is no obligation to notify under the Convention, when the risk of a likely transboundary impact is extremely low or practically zero, such as in the case of HPC.”
“51. At that session, the Committee also recalled its previous opinion that: while the Convention’s primary aim, as stipulated in article 2, paragraph 1, was to “prevent, reduce and control significant adverse transboundary environmental impact from proposed activities”, even a low likelihood of such an impact should trigger the obligation to notify affected Parties in accordance with article 3. This would be in accordance with the Guidance on the Practical Application of the Espoo Convention, paragraph 28, as endorsed by decision III/4 (ECE/MP.EIA/6, annex IV). This means that notification is necessary unless a significant adverse transboundary impact can be excluded (decision IV/2, annex I, para. 54).
52. Moreover, at its thirty-third session, following a comment by the United Kingdom questioning the decision of the Committee to open a Committee initiative, the Committee recalled its reasoning behind its finding of a profound suspicion of non-compliance and its subsequent decision to begin a Committee initiative. In the Committee’s view, the opportunity provided by the United Kingdom to Austria to participate under the Espoo Convention indicated an agreement of the two Parties that a likely significant environmental impact on Austrian territory could not be excluded, since otherwise there would have been no reason for the United Kingdom to engage with Austria following the latter’s request under the Espoo Convention. The likelihood of a significant environmental impact outside the territory of the United Kingdom had also not been excluded by the Netherlands and Norway, in their letters of 23 January and 5 February 2014, respectively.”
“62. In forming its view, the Committee evaluates both the impact caused by the activity during its usual operation as well as the impact caused by an accident. The Committee notes that for certain activities, in particular nuclear energy-related activities, while the chance of a major accident, accident beyond design-base or disaster occurring is very low, the likelihood of a significant adverse transboundary impact of such accident can be very high… The Party of origin should make such consideration using the most careful approach on the basis of available scientific evidence, which indicates the maximum extent of a significant adverse transboundary impact from a nuclear energy-related activity, taking into account the worst-case scenario.”
“63. The Committee notes that some of the United Kingdom’s neighboring states (Spain, France, Belgium and Germany) share, to some extent, the United Kingdom’s view that a significant adverse transboundary impact from the activity at HPC can be excluded. However, it also notes that other states neighboring the United Kingdom (Netherlands and Norway) do not share the United Kingdom’s view and cannot confirm that they can exclude a significant adverse transboundary impact from the activity at HPC. Moreover, according to the scientific evidence presented by Austria, which at its request, it was provided the opportunity to submit its views on the planned activity before the decision-making procedure was finalized, a major accident at HPC could have a significant adverse transboundary impact on the Austrian territory (as well as on the territories of France, Germany and Switzerland).1″
Emphasis our own. Original can be found here: https://web.archive.org/web/20160512044545/http://www.unece.org/fileadmin/DAM/env/documents/2016/EIA/IC/ece.mp.eia.ic.2016.2.advance_unedited_8Apr2016.pdf (There is important information regarding nuclear reactors in some other countries, as well, in this document, but we’ve no time to look at these right now).
If you study this enough days you will see that even Spain may be impacted by nuclear reactors on the west coast of Britain: http://earth.nullschool.net The wind map is of the entire world. Winds patterns are much more complex and varied than one might think. The repercussions in the event of a nuclear disaster are often surprising and always frightening.
Excerpted from the Summary of Austria’s
“REPORT REP-0413, Wien 2013, HINKLEY POINT C, Expert Statement to the EIA“, by Oda Becker:
“Taking into account all the presented facts of the application documents, the preservation of the containment integrity neither in the long-term nor in the short term during a severe accident is guaranteed by the proposed safety design and features yet.
The claimed “practical elimination” of a large early release is not sufficiently demonstrated.
Severe accidents with high releases of caesium-137 (>100 TBq) cannot be excluded, although their calculated probability is below 1E-7/a. Consequently, such accidents should have been included in the EIA since their effects can be widespread and long-lasting.
Many relevant factors are not included, because they fall outside the scope or are not addressed appropriately (for example, Common Cause Failure (CCF)). PSA results in any case should only be taken as very rough indicators of risk. All PSA results are beset with considerable uncertainties, and there are factors contributing to NPP hazards which cannot be included in the PSA. Therefore, for rare events, the probability of occurrence as calculated by a PSA should not be taken as an absolute value, but as an indicative number only.
In the Environmental Statement, EDF Energy claims: “Significant transboundary environmental effect arising from construction and operation of HPC are not considered likely.” In the transboundary screening document, the Secretary of State confirmed this view.
For the estimation of possible transboundary impact, calculations of the flexRISK project are used. The flexRISK project modelled the geographical distribution of severe accident risk arising from nuclear power plants in Europe. Using source terms and accident frequencies as input, for about 1,000 meteoro-logical situations the large-scale dispersion of radionuclides in the atmosphere was simulated.
For each reactor an accident scenario with a large release of nuclear material was selected. For a severe accident at Hinkley Point B, a caesium-137 release of 53.18 PBq is assumed. This source term is comparable with UK EPRTM source terms calculated in the PSA 2.
This possible caesium-137 release at Hinkley Point C, would result in a considerable contamination of the Austrian territory. Most parts show depositions of about 1,000 Bq/m² which is beyond the thresholds (650 Bq/m²) that agricultural intervention measures trigger.
The presentation of the results of the analysis of transboundary impacts of a potential severe accident at the Hinkley Point NPP site illustrate that an impact on Central European regions (including Austria) cannot be excluded. The results indicate the need for official intervention in Austria after such an accident.
Recommendation of this Expert Statement:
A conservative worst case release scenario should have been included in the EIA. A source term, for example for an early containment failure or containment bypass scenario, should have been analysed as part of the EIA – in particular because of its relevance for impacts at greater distances. It is recommended that this should be taken into consideration before granting further permissions.
Austria should be kept informed regarding the ongoing progress resolving the “Assessment Findings” concerning severe accidents.” Emphasis our own. Entire original document may be found here: https://web.archive.org/web/20140717191049/http://www.umweltbundesamt.at/fileadmin/site/publikationen/REP0413.pdf
It is notably that whereas Ireland apparently imports power from the UK, apparently some nuclear, through grid connection, Austria no longer imports nuclear power:
http://www.renewablesinternational.net/austria-is-100-percent-nuclear-free/150/537/85017/ It is illegal to construct nuclear reactors in both countries. Through grid interconnection it seems that Ireland has made itself once again dependent on its former master, the UK. What a shame.
Influence of windward-side of mountains enhancement of precipitation discussed on pp. 72-73: https://meteo.boku.ac.at/report/BOKU-Met_Report_23_PRELIMv2_online.pdf