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Slovenia and Croatia: lack of transparency on radioactive waste , on intake of international nuclear waste.

The transformation of RW TCT from the exclusively national facility to an international radioactive waste treatment provider was done without prior consultation with, and approval by the public and municipalities.

More than 3000 citizens signed a petition against capacity increase of the RW TCT and demand a prohibition of foreign radioactive waste treatment in Slovakia.

Slovakia is not legally or morally responsible for foreign radioactive waste

Slovenia and Croatia – radioactive waste, transparency, shared responsibilities, shared problems, Three case studies on radioactive waste, By Nadja Zeleznik – Nuclear Transparency Watch   9 Dec 21, 

These are case studies in a larger report on radioactive waste and transparency, currently under preparation for the Euratom EURAD programme by Nuclear Transparency Watch.
Publication was expected in October 2021.

Slovenia and Croatia share the nuclear power plant Krško (NEK) which was constructed as a joint venture during 1970-ties in the socialist Federal Republic of Yugoslavia as part of the larger nuclear programme on the use of nuclear energy. 

NEK is a two loop PWR Westinghouse (USA) design with all supporting infrastructure on site, including the buildings for radioactive waste and spent fuel management. Licensing was performed by the Republic Committee for Energy, Industry and Construction as the responsible authority in Slovenia. All other authorities were coordinated by this Committee, including the Expert committee on nuclear safety with its Technical Support Organizations. A safety report with safety analyses was mainly based on the provisions from USA NRC legal framework because the plant was of USA design. Trial operation was granted in 1981, in 1983 commercial operation started, and a license for normal operation was obtained in 1984 under Yugoslav and Slovene legislation…………………………………

Radioactive waste and transparency …………………………………………

Transparency including information provision and public participation (not to mention access to justice) of developed programmes decided by the IC is really a weakness. Decisions are taken by the IC, on websites there is no further information on how decisions have been taken, the public is informed on press conferences about the outcomes. The programmes are published only after they are adopted and there is no public participation. However, individual projects (like the LILW repository) are going through all steps as prescribed in legislation, including an EIA process. The Law on environmental protection already now requires that for strategies or plans, a strategic environmental assessment (SEA) should be performed, also including public participation for important national strategies. Following the definitions in the Aarhus Convention, the Kiev Protocol to the Espoo Convention and the SEA Directive, the DP has to be understood as a national programme which directs radioactive waste and spent fuel management from NEK.

An open discussion on the shared option and a structured dialogue with interested parties from both countries would enable a more flexible approach in which disagreement could be addressed and potentially mitigated and solved.

Foreign radioactive waste treatment in Jaslovské Bohunice, Slovakia
Transformation from a national to international treatment centre

By Michal Daniska (Nuclear Transparency Watch)  Since 2012-2013 (at the latest) foreign low-level (LLW) and very-low-level (VLLW) radioactive waste is treated at the Radioactive Waste Treatment and Conditioning Technologies in Jaslovské Bohunice (RW TCT), Slovakia, mainly through incineration. The transformation of RW TCT from the exclusively national facility to an international radioactive waste treatment provider was done without prior consultation with, and approval by the public and municipalities which, according to available sources, might have found out about it only in 2018-2019 (i.e., after approx. 5 years). The foreign radioactive waste share at incineration varied between approx. 35-45% during 2015-2019. Foreign radioactive waste treatment, especially by means of incineration, was originally categorically rejected by the vast majority of the affected municipalities. However, multiple municipalities later turned their position by 180 degrees on the condition, among others, that they received economic and non-economic incentives. Unusually strong refusal arose also among the public, e.g., more than 3 000 citizens signed a petition against a capacity increase of RW TCT and demand prohibition of foreign radioactive waste treatment in Slovakia. Meanwhile, the operator applied for an increase of the RW TCT treatment limits from 8343 to 12663 t/year in total (including an increase from 240 to 480 t/y by incineration) and a second incineration plant has been constructed. There is evidence supporting claims that Slovakia itself does not need such an increase of treatment capacities and that the second incineration plant might be purpose-built to better fit the specific radioactive waste from the closed Caorso nuclear power plant in Italy. The Slovak Atomic Act allows import, treatment and conditioning of foreign radioactive waste, on condition that the radioactivity level of the imported waste equals the radioactivity level of the reexported (after treatment and conditioning) material. Since the change of government in March 2020, the new Minister of Environment has been trying to ban foreign radioactive waste incineration by law. A corresponding compromise legislative bill has been submitted in the Slovak parliament at the end of May 2020.

Foreign radioactive waste and plans to increase RW TCT capacity

At RW TCT, foreign radioactive waste is treated mainly by incineration which takes place exclusively at the first incinerator, as the second one has not been commissioned yet. This activity dates back to 2013 when 8.8 tons of Czech waste were incinerated. In 2012 the volume of the incinerated Slovak radioactive waste reached its historical minimum after it had decreased from approximately 140t to 50t between 2007-2012. Gradually, the Nuclear regulatory authority of the Slovak republic (NRA SR) issued permissions for incineration of (1) 39.64t radioactive waste from the Czech nuclear power plants Temelín and Dukovany (31.10.2013); (2) 7t +16m3  institutional radioactive waste from Italy (03.09.2015); (3) 145.2t radioactive waste from Temelín and Dukovany (27.11.2015); (4) 800t ion-exchange resins in urea formaldehyde and 65t sludge from the decommissioned nuclear power plant Caorso, Italy (04.06.2018); (5) 21.7t institutional radioactive waste from Germany (22.01.2019) and (6) 617m3 institutional radioactive waste from Italy (25.01.2019). In total, incineration of approx. 1600 tons of foreign radioactive waste (Czechia, Italy, Germany) was contracted, out of which approx. 300 tons have already been incinerated between 2013 – 2020. In comparison, approx. 1200 tons of Slovak radioactive wastes were incinerated between 2007-2020. In the period 2015-2019, a total of approx. 110-130t were incinerated annually, out of which the Slovak radioactive waste represented 60-85t, the share of foreign waste at incineration oscillated between 34-46% (43-56 tons annually). Although the current legal limit for radioactive waste incineration is 240 t/year, it is allegedly in practice not technically feasible to incinerate more than 130-150 t/year at the first incineration plant. In case the capacity increase is approved (from 240 t/year to 480 t/year) and the second incineration plant becomes operational, the volume of incinerated radioactive waste in practice may increase to approx. 420-460 t/year (i.e., approx. 3,5-fold increase if compared to the current state), and the foreign radioactive share at incineration might exceed 70%.

The public did not participate in the authorization processes for import and incineration (treatment) of foreign radioactive waste in Slovakia held by NRA SR which resulted in the six permits mentioned above. The available information does not indicate that mayors of the affected municipalities were aware of the ongoing foreign waste incineration until about 2018. However, at least since 2014 the mayors have been considering the risk of such activities, although only as a theoretical option in the future. During various EIA processes, the municipalities regularly (as a precaution) expressed their disapproval of foreign radioactive waste treatment in the Bohunice locality until 2019. 

Nevertheless, until 2017/2018, the municipalities were not explicitly notified of the ongoing foreign waste treatment during the EIA processes. The EIA process “Radioactive Waste processing and treatment technology by JAVYS, a.s. at Jaslovské Bohunice location” (December 2012 – November 2014), during which the already existing and operated RW TCT was assessed for the first time on the basis of modern EIA legislation. During a public hearing, which took place in March 2014, the mayors directly and indirectly asked about the possibility of treatment of radioactive waste from locations other than J. Bohunice. In response, JAVYS did not inform about the foreign waste treatment (e.g., incineration) that had already been carried out (8.8 tons from the Czech Republic incinerated in 2013) or that had already been contracted. The statement was formulated in a conditional way, as if the treatment of radioactive waste for other companies (aside from the Slovak Bohunice and Mochovce nuclear power plants) was not a reality yet. Although it was admitted that contracts for radioactive waste treatment and conditioning were being sought, it was not directly mentioned that this would come from abroad. In addition, “foreign radioactive waste treatment” was not even once explicitly mentioned, neither in the EIA plan, EIA report nor during the public hearing. Finally, the Environmental Impact Statement (EIS) from this EIA process (issued in November 2014, with minor changes valid until today) explicitly states that RW TCT serves the treatment and conditioning of VLLW, LLW and ILW from (1) decommissioning of the Slovak NPPs A1 and V1; (2) operation of Slovak nuclear installations; or (3) institutional radioactive waste (IRW) and captured radioactive waste (CRW). The list of purposes does not explicitly mention treatment (incineration) of foreign wastes. In March 2021, the Slovak Ministry of Environment confirmed that “the ongoing foreign radioactive waste treatment (incineration) is inconsistent” with the EIS mentioned above. However, the treatment of foreign radioactive waste at RW TCT continues.

It was not until the beginning of 2018 that information on the treatment of foreign radioactive waste resonated for the first time among municipalities and a part of the public. There were two main sources – (1) a press conference of then opposition MPs Mr. Matovič and Mr. Krajčí about incineration of radioactive waste from the decommissioned Italian Caorso nuclear power plant, and their failed attempt to ban incineration of foreign radioactive waste by law (February 2018) followed by (2) publishing the EIA plan “Optimisation of treatment capacities of radioactive waste treatment and conditioning technologies JAVYS, a.s. at Jaslovské Bohunice” (March 2018) where foreign radioactive waste treatment was mentioned among the purposes of RW TCT. However, the treatment and especially incineration of foreign radioactive waste gained more significance and repeated media attention only in the middle of 2020, after the February 2020 elections and the consequent change of government (Mr. Matovič and Mr. Krajčí became the Prime Minister and the Minister of Health, respectively).

EIA processes

The environmental impact assessment (EIA) project “Optimisation of treatment capacities of radioactive waste treatment and conditioning technologies JAVYS, a.s. at Jaslovské Bohunice” stands for capacity increase of RW TCT, from 8343 to 12663 t/year in total (all technologies). It also covers the second incinerator and an increase of the incineration limit from 240 to 480 tons per year (corresponding to the real incinerated volume increase from approx. 130t/y, the technical limit of the first incinerator, to approx. 420-460t/y if both incinerators are in operation); capacity increase of the metallic radioactive waste remelting from 1000 to 4500t/y, and so on. In April 2018, the vast majority of the municipalities categorically refused foreign radioactive waste treatment, especially incineration, and the proposed RW TCT capacity increase, reasoned with arguments of (protection of) a healthy environment for their citizens. …………

There were two public hearings during the EIA process “Optimisation of treatment capacities of radioactive waste treatment and conditioning technologies JAVYS, a.s. at Jaslovské Bohunice” – on 26.08.2019 and 16.12.2019. Among others, JAVYS declared on 26.08.2019, foreign waste treatment as “a complementary activity” (compare this to a 34-46% share of foreign waste at incineration in 2015-2019 and a possible expected increase to over 70% in the future); on 16.12.2019, JAVYS claimed that the foreign radioactive waste share at incineration was 12% only. The public obtained real data about volumes of incinerated waste only in the middle of 2020 after a time-consuming investigation.

At present, after a position change in 2019, the majority of the affected municipalities and the association of municipalities explicitly approved both the RW TCT capacity increase and foreign radioactive waste treatment (up to a 30% share) on the condition (among others) that new economic and non-economic incentives for municipalities in the region are established. Two county towns (Hlohovec, Piešťany) and 10-15 other municipalities continue opposition. More than 3000 citizens signed a petition against capacity increase of the RW TCT and demand a prohibition of foreign radioactive waste treatment in Slovakia.

The Caorso contract

The Caorso contract for incineration of more than 30-year-old 800 tons of ion-exchange spent resins in urea formaldehyde and 65 tons of radioactive sludges (5881 tanks) from the shutdown Italian nuclear power plant Caorso, holds an exceptional position among the 6 contracts for foreign waste incineration at RW TCT. The main reason is the allegedly challenging nature of this waste due to urea formaldehyde, that is said to lead to difficulties during incineration in the shaft furnace of the first incinerator and a suspicion that the second incinerator with a rotary kiln might be purpose-built to better fit the waste from Caorso……………..

However, the alleged connection between the second incinerator and the Caorso contract has not been confirmed, neither by JAVYS nor by the nuclear regulator NRA SR. The Caorso contract itself was, after a significant portion of relevant data had been redacted, published online only in November 2020. Since the change of government in 2020, the new Minister of Environment Ján Budaj has been trying to ban foreign radioactive waste incineration by law. These efforts encounter a significant obstacle represented by huge financial penalties in case the Caorso contract is terminated. Transparency is lacking about the relation between the Caorso contract and the second incinerator (and the preconditioning line) as well as in the Caorso contract itself.

Challenges related to the foreign waste

Correct and complete impact assessment of the foreign radioactive waste treatment is a challenging task. For example, tracking down where all foreign radionuclides might end up could be highly relevant. One of the reasons is that the ratio of radioactivity retained in ash after incineration compared to radioactivity of the input waste is variable and on average approx. 65%, i.e., far below 100%. At the same time wastewater from wet filtration of flue gases from radioactive waste incineration, which might contain a significant share of foreign radionuclides, ends up permanently in the radioactive waste repository in Mochovce. In order to analyse the fraction of foreign radionuclides that remain in Slovakia and how these missing radionuclides are replaced by Slovak radionuclides (possible change of national radionuclide inventory) the public requested, mostly unsuccessfully, data about radioactivity streams during waste preconditioning, incineration and post-treatment (e.g., how much radioactivity is carried to the waste water) and the production of secondary radioactive waste. These data are crucial in order to analyse the impact of the foreign waste treatment, especially by incineration. However, when requested, the nuclear regulator NRA SR could not provide (did not have) detailed data about activity streams in the treatment process. The data cannot be obtained from JAVYS either, since it claims not to be a liable entity according to the Freedom of Information Act.

Financial impacts should be assessed in detail as well. For example, the foreign waste owners do not participate in the future decommissioning of the RW TCT (especially the incinerators and the pre-conditioning line), so that the corresponding costs will be covered by the National Nuclear Fund that collects money from Slovak electricity consumers. 

Do Slovak taxpayers not subsidise the foreign waste treatment in any (hidden) way (incl. construction, operation and future decommissioning costs, indirect costs – e.g., if the incinerator lifetime were negatively affected by the foreign radioactive waste treatment)?

One can also argue that foreign radioactive waste treatment challenges the ALARA principle. Slovakia is not legally or morally responsible for foreign radioactive waste, so it is reasonable not to incinerate/treat it and thus avoid any kind of unnecessary negative effects or risks. The Public Health Authority of the Slovak republic, Section of radiation protection justified its 2017 legislative proposal to ban foreign radioactive waste incineration with this argument.

Lack of transparency

The second important issue is the difficulty in access to (objective and complete) information, information verification and possibilities to consult with independent experts in the case of the public and municipalities. In practice, the main source of information about activities at the nuclear site J. Bohunice for the general public are the corresponding EIA processes, since the EIA documentation is easier-to-read for non-experts, is published online and often also the public hearings take place in the affected municipalities. On the other hand, documentation from processes held by the nuclear regulator NRA SR is expert-oriented, can be accessed usually only via physical inspection and sometimes is even declared confidential.

However, even in the EIA processes, the effectiveness of public participation is limited by information asymmetry between the public and municipalities on one hand, and the project proposer on the other. In case of nuclear installations, this asymmetry is further enhanced because of higher complexity of the problem. Due to limited time, expertise and financial resources the public and municipalities are reliant mostly on information provided by the project proposer, either in the EIA documentation or in reactions to additional questions (raised e.g., during the public hearing). Consultations with independent experts appear to be a theoretical option only, not only because of short procedural deadlines and financial constraints, but also due to a lack of suitable independent nuclear experts and/or insufficient free capacities of these experts. Even the Ministry of Environment failed while attempting to obtain an additional independent expert opinion within the EIA process “Optimisation of treatment capacities of radioactive waste treatment and conditioning technologies JAVYS, a.s. at Jaslovské Bohunice” in autumn 2020.

Effective public participation in the decision-making process requires that the public and municipalities are provided with correct and complete information about the project, its impacts and purpose as well as tools for easy information verification. The public should not be dependent on extensive and time-consuming investigation and information verification based on independent sources only. The situation is negatively affected by the fact that JAVYS claims – counter to jurisprudence under the Aarhus Convention – not to be a liable entity with respect to the Slovak Freedom of Information Act. This is difficult to understand, since this company is state-owned, carries out a public service and receives millions of euros from the public budget (through the National Nuclear Fund) each year, de facto holds a monopoly position in management of radioactive waste and spent nuclear fuel in Slovakia and, on top of that, it is also responsible for the project of a Slovak deep geological repository.

December 24, 2021 - Posted by | EUROPE, wastes

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