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Lessons Learned from Hearings in Germany – Limits and Problems with Stakeholder Involvement

Lessons Learned from Hearings in Germany – Limits and Problems with Stakeholder Involvement Dr. Volker Kunze Bundesamt für Strahlenschutz Postfach 10 01 49 38201 Salzgitter Germany. Content. The German Waste Management Concept Hearings for Interim Storage Facilities in Germany

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Lessons Learned from Hearings in Germany – Limits and Problems with Stakeholder Involvement

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  1. Lessons Learned from Hearings in Germany – Limits and Problems with Stakeholder Involvement Dr. Volker Kunze Bundesamt für StrahlenschutzPostfach 10 01 49 38201 Salzgitter Germany

  2. Content • The German Waste Management Concept • Hearings for Interim Storage Facilities in Germany • Storage Concepts • Objections regarding ALARA and their treatment by BfS • Conclusions

  3. The German Waste Management Concept • In 1998 the German government decided - in accordance with the utilities - to phase out of commercial nuclear energy utilisation • "Agreement between the Federal Government and the Utilities" of June 2000 • As a consequence in April 2002, a new Atomic Energy Act came into force • As from July 2005, transports of spent fuel to the reprocessing plants at La Hague (France) and Sellafield (Great Britain) are prohibited • Operators of nuclear power plants have to build and to operate interim storage facilities for spent fuel on the site or in the vicinity of NPPs • The aim is to reduce transports of spent fuel and to bridge the time until a geological repository for high-level radioactive waste will be available

  4. Licensing Procedures at BfS 1998 – 2000: 18 licenses for 13 sites have been applied for 13 interim storage facilities (Stade withdrawn) 5 interim storage areas → 17 hearings(Brunsbüttel withdrawn later) → 16 procedures 2000 – 2002: Involvement of the public including a transboundary environmental impact assessment with Austria for 6 interim storage facilities in the south of Germany Until end of 2003: Approval of all 16 licenses April 2005: New application for an interim storage facility at Obrigheim (NPP out of operation)

  5. Overview of the Public Participation Licensing procedures: 17 Objectors: 1,700 … 76,000 per procedure, about 250,000 in total Different objections: 12 … 252 per procedure, 897 in total Public hearings Days of discussion: 2 … 7 per procedure 63 in total Objectors: 16 … 566 per procedure 1,672 in total

  6. Interim Storage Area Concept Characteristics Prefabricated concrete elements Wall thickness 0.3 / 0.4 m Sites Biblis, Neckarwestheim, Krümmel, Philippsburg Time of Operation Only 5 years

  7. Interim Storage Facility (WTI Concept) Sites Biblis Grafenrheinfeld Gundremmingen Isar Philippsburg Characteristics two-nave building wall thickness 0.70 m/0.85 m roof thickness 0.55 m

  8. Interim Storage Facility (STEAG Concept) Characteristics: one-nave-building wall thickness 1.2 m roof thickness 1.3 m Sites Brokdorf, Brunsbüttel Grohnde, Krümmel Lingen, Unterweser

  9. Tunnel Concept at Neckarwestheim exhaust air chimney social area tunnel 2 escape building entrance hall auxiliary facilities connecting tunnel tunnel 1 Characteristics two tunnel tubes shielding rock ~ 15 m exhaust air chimney Site Neckarwestheim

  10. Legal Implementation of ALARA in Germany • In Germany the ALARA principle has been implemented in • § 6 of the Radiation Protection Ordinance (RPO) with the duty • to avoid any unnecessary radiation exposure or contamination of man and environment, and • to keep every radiation exposure or contamination of man and environment as low as possible below the limits taking into account the state-of-the-art of science and technology and the circumstances of the single case. • Principle of commensurability • Efforts (costs) and benefit (gain of safety) must correspond to each other

  11. Objections regarding ALARA • Essential points of criticism were in general • Precaution against damage of casks, in particular in the case of incidents was regarded to be insufficient • The safety in case of a forced aircraft crash with large passenger airplanes, especially after the events of September 11, 2001 • Minimisation and optimisation is taken as a synonym for ALARA • This topic was addressed in about 5 % of the 897 objection letters • The relative portion as compared to all topics was less than 0.5 % ALARA – in this sense - was not a major concern in the German hearings. However, there were some closely related special topics.

  12. Topic 1: Safety in Case of a forced Aircraft Crash • Objection • Thinner walls (70/85 cm) and roofs (55 cm) of WTI facilities do not comply with the state-of-the-art of science and technology • STEAG facilities (walls 120 cm / roofs 130 cm) provide more safety • Actions taken by BfS • Investigation of radiological consequences Result: Potential radiation exposure is about 4 (WTI) and 6 (STEAG) orders of magnitude below the respective protection goal of 100 mSv • No further actions required with regard to the principle of commensurability andthe restricted latitude of judgement

  13. Restricted Latitude of Judgement Different formulations in § 6 and § 7 of the Atomic Energy Act in Germany § 6 License for storage of nuclear fuel: “A licence shall be granted if …” § 7 Licensing of installations: “A licence may only be granted if …” • Consequences • In case of § 6 the applicant has a legal claim to get the license if the licensing prerequisites are fulfilled. • BfS is not authorised to modify the concepts applied for.

  14. Topic 2: Radiation Shielding • Objection • Thinner walls (70/85 cm) of WTI facilities provide less shielding as compared to the STEAG facilities (120 cm) • This different grade of protection is not acceptable • Technical facts • Openings in the building are required for heat removal→ conflicting goals of protection (heat removal vs. shielding) • Dose rate in the environment is mainly determined by scattered radiation • A reinforcement of walls would only lead to a small dose rate reduction (direct radiation) No need for BfS (and no legal basis) to demand thicker walls for WTI facilities

  15. Topic 3: Storage Below Ground • Objection • Storage below ground is required due to radiation shielding and the safety in case of a (forced) aircraft crash • Constraining conditions for planning • Tunnel solution at Neckarwestheim was chosen due to limited space (special situation, inside a former quarry) • The applicant is free to select a storage concept, also taking into account economical aspects (such as costs) For other sites - with regard to ALARA - it was simply disproportionate to demand subsurface storage

  16. Topic 4: Accumulation of Risks • Objection • Operation of interim storage facilities at the sites of NPPs lead to an intolerable accumulation of risks due to possible accidents and interferences of the different facilities • An equal and fair distribution of risks (all over the country) was claimed for • Constraining political conditions • The operators of NPPs have the legal duty to build an operate on-site interim storage facilities (amendment of the Atomic Energy Act in April 2002) • BfS paid special attention to possible interferences and their radiological consequences • The concept of on-site interim storage was not called into question • A risk balancing was never performed

  17. Topic 5: Dose-Effect Relationship • Objection • LNT-hypothesis is called in question • The risk of getting cancer as a result of low-dose radiation is generally considered to be too low (Petkau and bystander effect) • Weighting factors for neutron radiation up to a factor of 300 higher • Increased occurrence of cancer and leukaemia for NPP sites in Bavaria • Statements of ICRP and SSK • Present knowledge gives no reason for any changes of the LNT-hypothesis • No conceptual modification, no need for lowering the dose limits of RPO • No evidence for BfS to put the existing regulations into question • Nation-wide case-control study initiated

  18. Conclusions • ALARA in the sense of minimisation / optimisation was not a major concern in the German hearings • Some closely related topics were intensively discussed • Sometimes the objectors made proposals for modification, but in many cases the criticism was unspecified, and thus difficult to deal with • BfS summarised all the objections in the license followed by an evaluation to give reasons for the own way of acting in the decision making process • BfS took care of the implementation of the ALARA principle with regard to the principle of commensurability and the restricted latitude of judgement according to § 6 RPO • As a result, no conceptual changes were necessary and / or there was no legal basis for BfS to demand further improvements

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