K2R4 Completion project - Oustanding EIA

During the period October 1997 to June 1998 Mouchel Consulting prepared an environmental impact assessment (EIAS) (see project 96-5236), which for the proposed completion of Khemelnitsky unit 2 and Rivne unit 4 NPPs in Ukraine. The EIAS, along with an addendum considering the non-nuclear alternative to the K2/R4 project in both English and Ukrainian languages, formed part of the project presentation that was issued in August 1998 as a basis for formal public participation. The public participation process (PCP) was required by the environmental procedures of the European Bank for Reconstruction and Development (EBRD) and ran from August 1998 to late December 1998. The PCP was organized by Energoatom with the assistance of western advisers operating within the framework of the Project Management Group (PMG) based in Kiev.

The present project aim was to tackle a number of activities of which the following were most significant:

• The preparation of formal draft environmental action plans (EAPs) for the two projects and initial discussion of these drafts; 
• Input to the PCP in the form of assistance with the preparation of answers to questions raised by members of the public, non-governmental organizations (NGOs) and other organizations.
• Additional tasks that had not been anticipated at the time at which the contract was prepared, in particular input to public hearings requested by the Governments of Hungary and Austria.

Acquisition and evaluation of additional information

On the basis of questions received by the PCP co-coordinating committee as of middle October 1999, and issues identified as of potential interest in the original EIAS, a number of key issues were identified for which it was considered prudent to obtain supporting information. These issues included, but were not limited to, the following:

• Matters relating to changes in policy that had occurred during preparation of the EIAS or subsequently. These included the consequences of changes in legislation relating to dose limits for members of the public, environmental protection, decommissioning and radioactive waste management.
• Matters relating to description of the two sites, which might have consequences for nuclear safety, radiological protection and environmental impacts. These included seismicity, hydrogeology, the consequences of water abstraction on local and regional hydrology, and the quality of meteorological information.
• Matters related to the project description, in particular the continued use of the bitumisation process for treatment of radioactive wastes at Rivne NPP.
• Matters related to radiological protection. In particular the state of the existing managements for emergency planning, the systems for on-site and off-site monitoring, and case of tritium (both the status of limits and monitoring).
• Matters related to the assessment of environmental and radiological impacts. In particular 11e quantities of chemical contaminants discharged to the River Styr at Rivne NPP, the use of the cooling reservoir at Khmelnitsky for fish farming, and the possible need to consider the longer-term consequences of accidental events on contamination of water bodies.

The status of assessments of design basis accidents (DBA) and beyond design basis accidents (BDBA).

The requirements for further evaluations of socio-economic impacts of the two projects.

Relevant information on each of the above was initially acquired by Mouchel-IRE (Mouchel's partner organization based in Kiev). Mouchel staff then visited Kiev during November 1998 to evaluate this information and to prepare supplementary questions. These supplementary questions were raised in direct discussion with a number of organizations including staff from Energoatom, Kievenergoproekt, Kiesenergoproekt, the Nuclear Regulatory Administration (NRA) and staff from both NPPs. Supplementary questions were also directed to staff of the European Commission and Euratom.

The information and data were used in December 1998 to prepare a draft addendum to the Ell' s. This addendum supplements the material provided in the EIAS and forms a basis for an were provided to a number of the questions arising out of the PCP. It also formed a basis for a first revision to the draft EAPS for the project (see below).

The report was issued first to EBRD in December 1998 and then to Energoatom and other interested parties via PMG in February 1999. The report contains a series of recommendations that will need to be taken into account during preparation of the Ukrainian EIA (OVNS) and other stages of project development.

Draft environmental action plan

During November 1998, issues raised in the original EIAS were used to construct preliminary EAPS meeting the general requirements of EBRD environmental procedures and in a format agreed with EBRD. Mouchel staff visited Ukraine in November 1998 to discuss these preliminary EAPS with Energoatom. The results of that discussion were used to provide formal draft EAPS for discussion with other project participants and EBRD.

Comments on the draft EAPS were received from PMG in early January 1999. These comments were responded to and the original drafts were used as the basis of PMG's subsequent proposal to EBRD on behalf of Energoatom.

The drafts are currently being used is a basis for ongoing discussions between EBRD and Energoatom.

Since the EAPS form an integral part of any EBRD loan agreement, the final EAPS will not be published in the public domain unless both EBRD and Energoatom agree that this is to be the case.

Input to the public consultation process

Mouchel provided technical support to Energoatom during the course of the public meetings took place in Netishin (Khmelnitsky), Rivne and Kiev over the period 26-31 October The meetings, including Mouchel responses to questions raised on the EIAS were reported in full as part of tile PCP.

Mouchel then provided a senior member of staff to participate in a back-stopping experts meeting held in Kiev 23 to 27 November 1998. The purpose of this meeting was to provide initial evaluation of questions that had been received by the PCP organizing committee to assist with preparation of the draft report on the PCP.

Mouchel and Mouchel-IRE provided technical responses to a selection of questions. Many of these related to matters had been identified by Mouchel as being of particular interest to NGOs and members of public.

During December 1998, Mouchel provided detailed technical responses to reports that had n submitted to the PCP organizing committee by NGOs and other organizations. Mouchel then provided a senior member of staff for a further meeting of backstopping exerts in Lyon over the period 4-8 January 1999. The purpose of this meeting was to complete answers to all questions and responses received by the PCP organizing committee, to provide input to the final report on the PCP.

A significant proportion of the questions were received during the PCP related to matters that had n discussed in the EIAS. Mouchel assisted with a complete response to all relevant questions and provided inputs to all components of the PCP report

These included:

• Response to questions received from members of the public and others in Ukraine;
• Response to questions remaining from public meetings in Ukraine;
• Response to "open'' questions remaining after the public meeting in Austria Response to questions received from members of tile public and others in Hungary;
• Response to detailed technical reports provided on behalf of the Austrian Ministry of Environment;
• Response to "Eight Five Reasons Against K2/R4" provided by CEE Bankwatch;
• Response to reports by the OKO Institute and AAI;
• Response to a statement presented by Greenpeace International;
• Response to petitions and other submissions received from a variety of sources;
• Response to questions directed to EBRD Input to the questions and answers books Input to the final report on the PCP.

Additional tasks performed, (though not foreseen within the contract)

On special request of Energoatom (outside the original contract and Terms of Reference), Mouchel provided a senior member of staff to support Energoatom during public meetings held in Vienna and Budapest over the period 8-12 December 1998. In addition to attending the meetings and providing technical responses to questions raised, Mouchel provided significant additional inputs reviewing and commenting on a sequence of detailed technical reports that had been prepared by consultants for the Austrian Ministry of Environment.

Given the extent of the questions and responses received during the PCP and at the request the PCP adviser, Mouchel provided a senior member of staff to extend the back-stopping experts meeting in Lyon for the period 11-12 January 1999.

On the request of EBRD, Mouchel also further revised the draft EAPS prepared by PMG in January 1999 to provide a basis for direct discussions between EBRD and Energoatom.

These additional tasks required an additional and unforeseen input to the project of 15 mens senior professional staff, and additional unforeseen costs associated with short notice - base of international air fares (London-Vienna, Budapest-London, London-Lyon-London), local travel, accommodation and subsistence.

Conclusions

All items identified in the terms of reference for the contract have been completed in a timely and professional manner. Energoatom has stated in public its satisfaction with the work, that has been undertaken within the contract and PMG advisers have verbally firmed such statements.

In short, the following outputs have been provided:

• An addendum to the original EIAS summarizing recent additional information;
• Draft environmental action plans for the two projects which formed the basis for discussions between Energoatom and EBRD;
• Responses to all questions raised on the EIAS during the public consultation process.

Additionally, a series of recommendations has been provided for topics that will need to be addressed by Energoatom during preparation of the Ukrainian.