Dear sirs,

3. Responses to the Remarks and Proposals of the Department of Environment of
the Republic of Latvia
Remark 1: The documentation about influence on the environment does not
contain a qualitative and quantitative estimation of the possible radiation
contamination which may influence on the territory of Latvia in case of the
accident. Such estimation is required for assessment of the conditions of
probability of the worst scenario and the unfavourable meteorological conditions.
Response: The dose limits and the target probability factors established for the
power unit of the Nuclear Power Plant–2006 completely correspond to the requirementsof the acting Russian Regulations, the recommendations and safety norms of IAEA, theInternational Advisory Group on Nuclear Safety (INSAG 1– INSAG12) and therequirements of the European exploiting organizations to the projects of the NuclearPower Plants of the new generation with the reactors of PWR type. The Table presentsfor comparison the target indices of the radiation and nuclear safety of the power unitsof the increased safety for different projects of Nuclear Power Plants and therequirements to them.
Table –Indices of Radiation and Nuclear Safety of the Nuclear Power Plant
radiation of the regulatedpopulation in theresult ofdischarge abnormaloperation ofNPP, µ3v/yearThe effective population incase of design-basis accidents,mSv/event.
dose for thepopulation incase of design-basis accidents,mSv/year a seriousdamage of theactive zone,1/year, reactor large disvchargefor which it isnecessary totake countermeasuresoutside the site,1/year, reactor The Table presents for comparison the calculated values of maximum permissible discharge and the requirements to them established in different countries and projects.
Implementation of the planned strategy in the projects lowered the expected levels ofmaximum permissible discharge grounded according to the above-mentionedrequirements.
Table – Maximum Permissible Discharge and Requirements to them, TBq
Requirements
Requirement
to location of
NPP, USSR,
Council of
* The requirement has been excluded at reissuing of the document. The document PNAEG-03-33-93, NP-032-01 harmonized the requirements of the Russian standardregulations with the recommendations of IAEI (INSAG – 3): the measures for controland reduction of the consequences of the serious accidents should reduce theprobability of large discharge outside the limits of the site, for which promptcountermeasures are necessary outside the site with the level of 10-7 1/year reactor.
The Table shows the quantitative and qualitative composition of the discharge in case of a serious out-of-design-basis accident being used to estimate the radiologicalconsequences in case of an accident at the Belarusian Nuclear Power Plant.
Table – Discharge of Radionuclides to the Environment, Bq
Radionuclide
Activity, Bq
Radionuclide
Activity,
Radionuclide
Activity,
The comparison of the data of the Tables and MPD of LNPP–2» shows that more powerful discharge has been used for calculations: on iodine – 131 – by 4 times, oncesium–137 – by 1.7 times and on strontium–90 – by 10 times. The results of thecalculation have shown that the maximum calculated dose of irradiation of the thyroidgland at the given scenarios of out-of-design-basis accident will exceed the criteria ofinterference of 50 mSv during the first seven days after the accident at a distance up to25 km from the Nuclear Power Plant, hence, in radius of 25 km from the Nuclear PowerPlant the necessary countermeasure will include the iodine prophylaxis at the earlystage. Taking into account that the distance from the Nuclear Power Plant to the borderof the Republic of Latvia is 110km, it is possible to say that there will be noconsequences for the Republic of Latvia in case of the accident at the BelarusianNuclear Power Plant.
Remark 2: We consider it is necessary to discuss the problems of monitoring and
control in detail, and also to describe in detail the information about the system of thepreliminary warning and about the International cooperation, especially in case of anaccident in order to receive more effective information and to control the risks.
Response:
The monitoring of environment is being carried out within the framework of the National System of Monitoring of Environment (NSME) in the Republic of Belarus as perthe legislation of the Republic of Belarus and other standard legal acts: The Law of the Republic of Belarus “On Environment Protection”; Regulations on the National System of Environment Monitoring in theRepublic of Belarus approved by Resolution № 949 of the Council ofMinisters of the Republic of Belarus dated July 14, 2003/ As per point 2 of the Regulations on the National System of Environment Monitoring inthe Republic of Belarus the NSME includes the following types of environmentmonitoring being organizationally independent and carried out on the ground of thebasic principles: The Figure represents an approximate scheme of location of the points of observationof radiation control and monitoring within the radiation control area of the BelarusianNPP.
The procedure and the system of prompt warning of the neighboring countries in caseof the accident is being worked out by the competent organizations as a part of theproject of the Belarusian Nuclear Power Plant and is not the object of EIA. It should benoted that the named procedure must provide for carrying out of the obligationsundertaken by the Republic of Belarus within the framework of the treaty “TheGovernment of the Republic of Belarus, the Government of the Republic of Polanddated October 26, 1994”, “The Treaty between the Government of the Republic ofBelarus and the Government of the Republic of Poland on Prompt Warning about theNuclear Accidents and Cooperation in the Field of Radiation Safety”.
In accordance with the “Technical Protocol” of the Ministry of Natural Resources andEnvironment Protection of the Republic of Belarus and the Ministry of Environment ofthe Republic of Lithuania about cooperation in the field of monitoring and exchange ofinformation about the state of the trans–border surface water dated April10, 2008, atpresent the trans–border monitoring on the hydro chemical indices at the transborderrivers of Viliya River (settlement of Bystritsa) on the Belarusian territory and of NyarisRiver (settlement of Buividzhay) – on the territory of Lithuania is being carried out.
Besides, the interlaboratory comparison of the results of measuring of the the contentsof the chemical contaminating substances are being conducted.
The Belarusian party has prepaped the proposals for conducting of radiation monitoring at the same range lines and the interlaboratory comparison within theframework of the above-mentioned “Technical Protocol”.
Remark 3: We also consider it is necessary to discuss in detail the problems of
the spent fuel and the control of radioactive waste.
The conclusion about the influence on the environment must contain more
extensive information about the supposed actions on storage of radioactive
waste, their distribution and control, and not only the description of possible or
supposed variants.
Response: In EIA of the Belarusian Nuclear Power Plant the problem of
radioactive waste handling is being discussed in Section 7.5.2. The Section contains theclassification of the radioactive waste, the description of the technology of handling ofvarious radioactive waste being used in the project of the Nuclear Power Plant–2006,the approximate information about the radioactive waste subject to handling andstorage at the Nuclear Power Plant is presented; it is shown that the final volume ofsolid waste (after treatment and not subject to treatment) does not exceed the value of50m3/year from one unit. The Section describes the storage of solid radioactive waste atthe Nuclear Power Plant.
The problem of nuclear fuel handling on the territory of the site of the Nuclear Power Plant is described in Section 8 of EIA of the Belarusian Nuclear Power Plant.
The problems of radioactive waste and nuclear fuel handling outside the site of theNuclear Power Plant are not the subjects of EIA of the Belarusian Nuclear Power Plant.
At that at present the concept on spent fuel handling is being worked out in the Republic of Belarus. The concept on radioactive waste handling has been developed in2000. At present the concept is being revised. Both concepts will be considered in detailin the course of development of architectural (engineering) project of construction of theNuclear Power Plant in the Republic of Belarus.
As for your question concerning Verkhnedvinsky site we inform you that on the basis of the works carried out at the stage of choosing the site for the BelarusianNuclear Power Plant it has been decided that on the basis of all essential factors theOstrovetsky site is prior (basic), and Krasnopolyansky and Kukshinovsky sites are thereserve sites. The Verkhnedvinsky site has been rejected and is not being consideredas the site for possible location of the Nuclear Poweer Plant in the Republivc of Belarus.
4. Responses to the Remarks and Proposals of the Radiation Safety Department
of the Republic of Latvia
Remark 4: - The text of IEA contains the results concerning only the neighbouring
state – the Republic of Lithuania. But there are no quantitative data concerning theRepublic of Latvia, the borders of which are at a comparatively small distance - at adistance of 110 km from the Nuclear Power Plant.
- Latvia needs the information about the maximum supposed radiological contamination on the territory of Latvia in case of the accident on the above-namedNuclear Power Plant, especially in case of unfavourable meteorological conditions.
Response: In EIA two scenarios of the out-of-design-basis accidents have been
considered which differ in various weather conditions at the moment of maximumconcentrations of radionuclides in the atmosphere. This leads to a diametrically differentcharacter of precipication on the earth surface: the first scenario was characterized by a relatively low wind velocity andby moderately stable state of the atmosphere which determined precipication of a large quantity of radioactive substances (up to 20000kBq x m2 by the trace axis) at a relatively small territory (severalthousand of hectares); the second scenario was characterized by high speed of displacementof air mass with a moderate fluctuation which caused the formation oflarge areas (many hundred of hectares) of fields of radioactivecontamination with a relatively small surface activity (0.5 – 37 kbq x m-2).
The following values of discharge have been taken for modelling: iodine – 131 = 3.1 x 103 TBq and cesium – 137 + 3.5 x 102TBq which is higher than the maximumpermissible discharge for the Nuclear Power Plant–2006 on iodine by 31 times, and oncesium - by 35 times. Even at these values of discharge the maximum density of thecontamination of the territory – under the worst weather conditions amounted to, oncesium – 137 1.9 x 105 Bq/m2 (5.1 Cu/m2) at a distance of 30 km from the NuclearPower Plant.
Hence, we consider that there is no sense to calculate the density of the contamination at a distance of 110km.
Remark 5. In the text of EIA there is not enough information about observing of
such an important International requirement as the prompt warning about an accident oran incident, about the readiness to react and the reliable operation of the warningsystem.
Response: The procedure and the system of prompt warning of the neighboring
countries in case of the accident is being worked out by the competent organizations asa part of the project of the Belarusian Nuclear Power Plant and is not the object of EIA.
It should be noted that the named procedure must provide for carrying out of theobligations undertaken by the Republic of Belarus within the framework of the Treaty“The Government of the Republic of Belarus, the Government of the Republic of Polanddated October 26, 1994”, “The Treaty between the Government of the Republic ofBelarus and the Government of the Republic of Poland on Prompt Warning about theNuclear Accidents and Cooperation in the Field of Radiation Safety”.
Remark 6. It is not specified which conditions are being used for choosing of three
possible sites subject to examination for choosing the optimum site for location of theNuclear Power Plant.
Response: The detailed information about the competitive sites
(Krasnopolyanskaya, Kukshinovskaya, Ostrovetskaya) is represented in the summaryvolume on the complex of research and investigation works for choosing the site forlocation of the Nuclear Power Plant in the Republic of Belarus (1588 – PZ – OIZ.
General Explanatory Note. Part I).
The choice of the site for location of the nuclear object is a multifactor task connected with taking into account the influence of the environment on the nuclearobject and vice versa. The safety of the Nuclear Power Plant, the radiation safety of thepopulation and protection of environment in the region of the Nuclear Power Plant incase of the normal operation and with regard to the design-basis accidents and out-of-design-basis accidents along with the technical facilities and organizational measuresare being provided for by the choice of the favourable location for the Nuclear PowerPlant and its proper remoteness from the populated areas, the industrial enterprises, theobjects of culture and health services, etc. Thus, when taking the decisions about thesuitableness of the site for location of the Nuclear Power Plant, the following factorshave been taken into account: connected with the influence of the Nuclear Power Plant onenvironment and the radiation safety of the population; stipulated by the events and actions connected with the activity ofpeople; connected with the influence of the natural conditions on the safety ofthe Nuclear Power Plant.
Criteria of Comparison
The choice of the priority site has been conducted on the basis of the analysis of the competitive sites according to the chosen criteria of comparison, on the followingdirections; correspondence to the requirements of the normative documents of theRepublic of Belarus and the recommendations of IAEA; ecological factors, including the radiation contamination; Question 4. There is an insufficient experience of operation because other
reactors of the similar type are only at the stage of construction.
Question 5. There is an insufficient analysis of the reason why just this type of the
reactor has been chosen. Probably, the choice to a great extent has been grounded bythe experience of using the technologies of the Russian Federation, and also possibleeconomic, but not technical considerations.
Response to questions 4-5: Among the reactors of PWR type of generation III+
the world market proposes: - AP – 600, 1000 (USA and Japan); The project AP – 600 and AP – 1000 exists only on the paper, it is not being constructed anywhere.
The Project EPWR-1600 is superfluous on power (1600 МW) for the energy system ofthe Republic of Belarus and does not provide for stability of the energy system in caseof introduction of it to the energy budget of the Republic.
The project «NPP – 2006». Russia is the only country which is actively engaged in construction of the Nuclear Power Plants with PWR–1000 abroad during the last tenyears: China, India, Iran, Bulgaria. Some Nuclear Power Plants have been put intooperation: Rostov Nuclear Power Plant in 2001, Kalinin Nuclear Power Plant in 2005,the Nuclear Power Plant “Temelin” in 2001 and 2002, Tianwan Nuclear Power Plant in2007. The closest prototype of the project of the Nuclear Power Plant – 2006 has beenput into commercial exploitation in 2007 in China (2 power units). As per the Russianprojects of the third generation construction of two units in India is coming to an end,construction of two units was started in Bulgaria and of four units – in Russia.
As for the Tianwan Nuclear Power Plant, on September 23, 2009 in Lyanjungan (China), the negotiations between ATOMSTROYPROJECT Close Corporation (NPP,Close Corporation) and Jszyansus Nuclear Power Corporation (JNPC) took place inconnection with termination of the term of the guaranteed operation of the second unitof the Tianwan Nuclear Power Plant.
The parties signed the joint “Protocol of Negotiations on the Issue of Final Acceptance of unit 2 of ТNPP in accordance with which the two–year period of theguaranteed operation of the second unit of the Tianwan Nuclear Power Plant isconsidered to be completed. The Protocol has been signed on the Russian part by theFirst Vice–President of ATOMSTROYPROJECT Close Corporation Alexander Nechaev,on the Chinese part – by the Director General of JNPC Mr. Tszyan Gouan.
The similar Protocol of the final acceptance after completion of the guaranteed period of operation of the first unit of the NPP has been signed in June of this year.
The guaranteed period of operation demonstrated the reliable operation of the Nuclear Power Plant. Both power units of the Tianwan Nuclear Power Plant operatestably at the level of the rated contract power of 1060 MW and have high technical andeconomical indices. Since the moment of the start of the first two units the NuclearPower Plant has worked out more than 30 mlrd kW x hour of electric power. TheTianwan Nuclear Power Plant which has been constructed as per the modified Russianproject is the most safe among the Nuclear Power Plants operating in the People’sRepublic of China.
The proposed projects of the Nuclear Power Plants with the reactors of generation III+ have the comparable indices by reliability, frequency of the maximum accidentdischarge etc. It should be admitted that a definite role has been played by theexperience of using the technologies of the Russian Federation, the community of thelanguage, of the technical requirements, etc. However, the major role in choosing theproject played the problems of safety of the Nuclear Power Plant.
Question 6. There is insufficient information about the quantity of radioactive
waste and discharge to the environment just from this type of the reactor.
Reponse: The Table contains the data on the quantity of the solid radioactive
waste coming for treatment and further storage to the building for the treatment of thelow–activity waste from two units of the Nuclear Power Plant-2006.
Table – Quantity of Solid Radioactive Waste Subject to Treatment and Further
Storage in the Building for Treatment of the Low –Activity Waste from two Units
Name of Waste
Place of formation
Quantity of Waste
from Two Units
Coming to the
Building 00UKS,
m3/year (at normal
operation,
maintenance and
repairs /at
accidents)
1. Low – activity Solid Radioactive Waste
Building of thetechnological,control systems ofnormal operationand special waterpurification 2. Medium- Activity Solid Radioactive Waste
technological,control systems ofnormal operationand special waterpurification 3. High – Activity Solid Radioactive Waste
The final volume of the solid waste (after processing and not subject to processing does not exceed 50m3/year from one unit.
The real discharge of radioactive substances from the Nuclear Power Plant with the reactors PWR–1000 are listed in EIA of the Belausian Nuclear Power Plantaccording to the data of the “Annual Report on the Activity of the Federal Department onEcological, Technological and Nuclear Supervision in 2005”. The portion of theradionuclides being discharged and dropped relative to the fixed SpNPP – 03 valueshave been also stated there.
Question 7. The analysis of the information is being complicated because there is
of ten no references to the sources of literature.
Response: We accept this remark. In the final wording of EIA of the Belarusian
Nuclear Power Plant this drawback has been removed.
Question 8. The reference to page 93 to the computer program MULTIBOX and
comparison of its results with the other programs on analysis of migration ofradionuclides is not sufficiently grounded because for checking of the model and thesystem the data about temporary storages of radioactive waste, the initial information ofwhich is not correct enough, at the same time there is no ground to affirm that thesystem of supporting of the given decision within the limits of the error is as reliable asmany others being tested more thoroughly.
Response: The program complex MULTIBOX describes a multi–chamber model
with a variable cell, in the basis of which the method of system analysis lies. This type ofmodels has found wide use both in solving the practical migration and hydrogeological problems for prompt predictions, and in solving of complicated problems of spreadingthe radionuclides in the lithosphere, hydrosphere, biosphere in the native andInternational practice. The model and computing programs MULTIBOX have beentested by comparing the results of the computations on the International programs suchas DUST, GWSCREEN, AMBER, ECOLEGO. The International models DUST,AMBER, ECOLEGO which are also mult –chamber models have been recognized,approved and widely used at the International level.
The verification and approval of the model MULTIBOX has neen carried out on the basis of comparing the calculated and experimental research being conducted at thepoints of the burial of waste of deactivation of the Chernobyl origin which have beenexamined, certified and controlled during 10 years. This model has also proved itselfwhen being used during examination of the profiles of contaminations of the soil layersas a result of migration of radionuclides on the territories contaminated by radionuclidesin the result of the Chernobyl and global accidents.
The satisfactory consent of the results of computations by the model MULTIBOX and International models, and also with the data of the field research gives the groundsfor applying the developed model to evaluation of the potential danger of the radioactivecontamination of the underground water in cases of local and site sources ofcontamination in the zone of observation of the planned Nuclear Power Plant at thestage of investing to its construction.
The received conclusions on the calculated research carried out on the basis of using the developed models, coincide with the conclusions of the Russian geologicalexpeditions, which during the last twenty years actively carry out the geologicalresearch in the regions adjacent to the operating Nuclear Power Plants (Smolensk,Kursk, Novovoronezh, Kalinin, Leningrad). The main direction of these research was tofind out by geochemical methods the influence of the atomic power objects on theenvironment within 30 km zone from the Nuclear Power Plant. The main content ofthese conclusions is that at normal operation of the Nuclear Power Plants ratherunsatisfactory radiation situation is being provided for on the territories adjoining tothem. The standard methods of control of the radiation situation in the environment donot permit, in the majority of cases, to detect the influence of their activity.
Question 9. There is no grounds for the scenario at page 94 – how were the
boundary conditions chosen – 15m3 and 600 Cu of the liquid radioactive waste theinfluence of which is further being analyzed, and that the isotopic composition of thewaste is not characteristic of the reactors of PWR type.
Response: The hypothetical scenario of the local source of contamination of the
underground water has been synthesized on the basis of the analysis of the emergencysituations at the operating Nuclear Power Plants in Russia which caused the localcontamination of the geosphere at the sites of the Nuclear Power Plants. (KuznetsovV.M. “The Basic Problems and Modern State of Safety of the Enterprises of the NuclearFuel Cycle of the Russian Federation”, 2002). As an example, the incident has beenconsidered which took place at the Beloyarsk Nuclear Power Plant when at the Plant ofpumping the liquid radioactive waste the room for servicing the pumps of the storage ofthe liquid radioactive waste has been flooded. The liquid radioactive waste passed intothe safety tray and, because of absence of tightness, as well as because of overfilling ofthe tray, got in the soil under the storage of the liquid radioactive waste, and then – tothe cooling reservoir. The total quantity of the liquid radioactive waste beingaccumulated in the tray amounted to 15m3. Other characteristics of the liquidradiotechnical waste (isotope composition, specific activity of the radioisotopes,summary activity of the discharge etc.) have been formed from different sources in view of lack of reference information. The calculations on the given scenario were carried outonly for the purpose to evaluate protection of the underground water againstradioactive contamination in the zone of the influence of the Nuclear Power Plant and todevelop later on the systems of radiation monitoring and the measures for preventingspread of the radioactive contamination in the water–bearing strata in the emergencysituations.
Question 10. On page 96 the analysis of the epidemiology is being carried out by
means of using the data about the Belarusian people only, and the planned location ofthe Nuclear Power Plant is situated at a distance only 40 km from Vilnius – therefore theanalysis should be executed for the population of the neighbouring countries.
Response: The Ministry of Nature and Environment Protection of the Republic of
Belarus on request of the Ministry of Energy of the Republic of Belarus (Letter №15/992dated March 9, 2009) has sent to the Ministry of Environment Protection of the Republicof Lithuania by Letter № 14-16/1487-вн dated March 24, 2009 an enquiry onsubmission of the necessary information. The information on the demographic situationwithin the area of 30 km zone of the Belarusian Nuclear Power Plant has not yet beenreceived from the Ministry of Environment Protection of the Republic of Lithuania tillnow, in view of which it cannot be clarified in EIA of the Belarusian Nuclear Power Plant.
The authors of EIA had at their disposal only the information on the population of theterritory of Belarus.
Question 11. On page 110 there is no correspondence of the scale or location of
Response: On page 110 a drawing is presented but not a map, therefore the
scale has not been observed. The drawing bears a reference character.

Source: http://www.vpvb.gov.lv/data/files/ivn/latvia_atb.pdf