Case: extension of the lifetime of nuclear reactor № 1at South-Ukrainian nuclear power plant (SU NPP)
Region: Ukraine, Mykolaiv region, Yuzhnoukrainsk
Essence of the case: protection of the right to safe and healthy environment during decision-making on extension of the lifetime of nuclear reactor №1 at SU NPP
Parties: EPL, the State Inspection of Nuclear Regulation of Ukraine, the Ministry of Energy and Coal Industry of Ukraine, the Ministry of Ecology and Natural Resources of Ukraine, NEGC «Energoatom»,the Cabinet of Ministers of Ukraine,the public, other states.
Essence of the problem: nuclear rector №1 at SU NPP had been in operation during its project lifetime and is scheduled to undergo modernization to allow extension of its lifetime operation for 10 more years.
Such process was launched in 2004 by the decision of the government on complex program of works on extension of lifetime of nuclear reactors in operation in Ukraine. Since that time the State Inspection of Nuclear Regulation of Ukraine (SINRU) was provided with necessary documentation for the extension of the lifetime of nuclear reactors at NPPs that are coming close to the lifetime expiration. Such decisions are taken by the SINRU without adequate environmental impact assessment, without transboundary consultations as required by Espoo Convention, creating risks of the damage to the environment and human health in the future.
In 2012 state-run company «Energoatom» launched the process of public consultations of the issue of lifetime extension of nuclear reactor №1 at SU NPP.
EPL prepared the analysis of all documents available to public and provided SINRU with the commentson the documents on environmental impact assessment of the lifetime extension of operation of reactor N1 at SU NPP in November, 2012. (AThedocument is in Ukrainian)
On December 20, 2012 SINRU passed the decision № 18 (http://www.snrc.gov.ua/nuclear/uk/publish/article/205102) on impossibility of the extension of the lifetime of reactor №1 at SU NPP and the necessity to stop its operation. Inspection also pointed out at numerous measures that need to be implemented in order to put the issue of the lifetime extension of reactor N1 on the agenda of SINRU one more time.
As a result, operation of the reactor №1 was stopped in March, 2013.
In October 2013, SINRU received again the documentation from “Energoatom” necessary to obtain its positive decision and launched the process of public consultations on this issue and on its draft decision.
On 8 November, 2013 EPL addressed SINRU its comments concerning the available documentation on life-time extension and possible positive decision of the inspection that is scheduled for 28.11.2013. SINRU intends to allow extension of lifetime operation of reactor N1 for another 10 years.
- Violation of Espoo Convention due to the lack of transboundary consultations on environmental impact assessment of the lifetime extension of reactor №1 at SU NPP with neighborhood countries before the decision of SINRU on prolongation of the license duration is taken.
- Violation of Aarhus Convention and procedures of public participation during the decision-making by SINRU on lifetime extension of reactor №1 at SU NPP, namely the lack of access to all necessary and required documentation.
- Lack of expert conclusions of obligatory state expertisas, namely state ecological expertise and state sanitary expertise.
- Lack of the environmental impact assessment documentation of the lifetime extension of reactor N1 at SU NPP. Documents that are prepared by the operator of the NPP for the lifetime extension of reactor N1 (Report on periodic reassessment of the safety, complex safety analysis) during 10 more years are not including the environmental impact assessment documentation of such activity. The so-called “EIA” chapter of the Report on periodic reassessment of the safety is aimed at assessment of the availability of the necessary program of radiation impact control on the environment at NPP, but not the environment impact assessment during extended beyond lifetime operation of the reactor at NPP.