Environmental impacts of facilities related to Paks II NPP not assessed

Facilities related to the Paks II Nuclear Power Plant project are being built one after another, but their environmental impacts were not assessed in the environmental permit issued in 2016, as required by the law.

’Huge investments are underway in connection with Paks 2, which are not in line with the environmental permit. In fact, we don’t even know how the authorities are assessing compliance.’ – say the engineers with expertise in environmental licensing with whom we discussed current issues of Paks 2. As the experts have already suffered negative consequences for speaking in public, they have requested that their names be kept confidential.

In connection with the Paks 2 project, a number of other facilities and investments must also be realised. ‘The environmental and other impacts of related installations must also be assessed by the authorities during the environmental licensing process’ – as we learn from an environmental lawyer who helps us navigate the complex maze of legislation, but who also does not want to reveal any personal details. ‘In the case of an investment, the relevant law considers any buildings that serves, supports or supplements the activity as related facilities’.

Although some of these related installations were included in the Paks 2 environmental licence, their expected environmental impacts were not analysed in the impact assessment documents.

Besides, in addition to the above-mentioned installations, there are also construction works in progress that were not even mentioned in the environmental permit – and therefore their impact has not been assessed – although they clearly serve the implementation of Paks 2. These include, for example, the construction of facilities at the so-called Construction and Erection Base (CEB).

The whole CEB area is missing from the permit

According to a statement by Paks II Zrt., ‘more than 80 service buildings, office buildings, assembly halls and warehouses will be constructed in the CEB area. These facilities are necessary for the construction of the two new nuclear power plant units.’

Under the law, these are considered as related installations, as they are part of the investment, even if they are carried out off-site. Their environmental impacts should therefore have been assessed in the Paks 2 environmental permit, but this was not done. If, for some reason, the buildings in the CEB area were not considered to be related installations, they would have been subject to a separate environmental licensing procedure. However, this did not take place.

However, the installations certainly have an environmental impact, for example, the sandblasting and metal removal workshop (1 360 m2), the painting workshop (760 m2) or the solvent and paint storage (318 m2). Both paint and solvent are chemicals, hazardous waste, so it is important to assess potential impacts. Especially as the area falls within a sensitive groundwater protection area category under the legislation.

As the environmental authority was not part of the construction licensing procedure of the above mentioned buildings, it is a mystery how the compliance with the environmental permit was investigated. Apparently, it was not.

A major water utility development was also missed

Also not mentioned in the Paks 2 environmental permit is the major infrastructure development of more than 200 hectares, which is scheduled to be completed by 2025. The design of the project alone cost two and a half billion forints.

The investment involves the construction of drinking water, rainwater and wastewater system in Paks, which, according to the documentation submitted to the authority, is linked to the implementation of the Paks 2 project. It is clear from the documentation that the investment also concerns the Paks 2 site and that the water supply system for Paks 2 is also included. The development is also necessary, inter alia, for the accommodation of the 4 000 workers who will carry out the construction works for the Paks 2 project.

The Paks 2 environmental permit stated that ‘the new power plant can be supplied with drinking water from the Csámpa waterworks.’ Contradictory, now, in order to meet the planned water demand, the waterworks I and II (Borsócséplő) in Paks will have to be renovated, and the capacity of the waterworks III on Dorogi út will have to be increased by renovating the existing wells and constructing three new wells to meet the increased water demand.

Moreover, in the case of the water utility development, the Tolna County Government Office is acting as the competent authority, whereas in the case of Paks 2, the National Directorate General for Disaster Management of the Ministry of the Interior is required by law to act in matters related to the preparation and implementation of Paks 2, both on-site and off-site.

In our legal expert’s opinion, the fact that the environmental permit issued in 2016 did not mention all the related facilities would not be a problem, because it is possible that not all of them were known at the time. However, as soon as the need for the investments became apparent, Paks II Zrt. should have notified the change to the permit, and the Baranya County Government Office should have reviewed the compliance with the original environmental permit.

According to the information sent to Atlatszo by the Baranya County Government Office, however, this did not happen: they did not receive any notification, and the authority did not initiate a review procedure ex officio.

In our legal expert’s opinion, the construction of the Paks 2 project facilities that were not subject to the environmental permit procedure could not have legally started. And in the case of unauthorised construction, the authority is entitled to take measures, including stopping or suspending the works.

Written and translated by Orsolya Fülöp. Cover photo: Átlátszó. Photos: Paks II Zrt. Hungarian version of this story is available here.