Environmental Impact Assessment on new reactor in Finland

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Until May 20th, 2014 German citizens can send complains against Fennovoima's NPP construction plans;
for other foreign nationalities the deadline is May 8th, 2014


Due to Rosatom taking over e.on's shares in Fennovoima, and thus owning the biggest share of this "Finnish" company, politicians and authorities in Finland required the company to do a new Environmental Impact Assessment (EIA) for the proposed new reactor in Pyhäjoki. The significant changes in the ownership of Fennovoima as well as the massively changed size of the reactor and the different model to be used make it necessary to submit a completely new application, says the responsible Ministry of Employment and Economy, while the Ministries of Environment and of Foreign Affairs agree with this stance.

Currently, Fennovoima holds a decision-in-principle of the Finnish government and parliament politically supporting the new NPP in Pyhäjoki issued in July 2010. This statement required by Finnish law will remain valid only if the construction of the nuclear power station will be started by July 2015. Otherwise, Fennovoima would have to apply for a new decision-in-principle, too. However, there is a debate in the Finnish public whether Fennovoima anyway needs to apply for a new decision-in-principle due to the massive changes in their concept.

A strategy to overthrow this reactor construction attempt is to insist on the qualitative examination of the current concept and plans. Objections, comments and criticism on the EIA can help to reach this approach, if public pressure leads to serious consideration of Fennovoima's application. It is questionable if Fennovoima would try to get a second decision-in-principle, due to their weak economical situation. Thus, sending your statements on Fennovoima's latest EIA will be valuable to prevent another dangerous atomic plant to be built.


key facts:

  • the national EIA procedure for Finnish citizens was open for complaints from February 24th - April 24th, 2014
  • the international deadline for statements in the EIA procedure is May 8th, 2014
  • some countries have other dates, deadline for objections from Germany is May 20th, 2014



Critical aspects of the proposed NPP in Pyhäjoki

A key argument is the Rosatom technology, that poses new additional dangers.

The FlexRISK tool for the assessment of radiation risks to neighbour countries posed by nuclear power plants in Europe provides a brief overview on the Fennovoima NPP and provides a simulator to visualize possible radiation impacts in case of a major accident.


FlexRISK fenn 1 1995012606 A d1 cs137 gnd tot img.gif


What you can do

Best impact in the Environmental Impact Assessment have individual letters. Thus we will provide no prepared text for copy/pasting, but some relevant arguments that can be used in objections, comments and statements on the EIA.

Citizens from Germany and other affected countries should send their statements to:

Ministry of the Environment
PO Box 35
FIN-00023 Government
Finland

The deadline for complaints of German citizens is May 20th, 2014. The Lower Saxony Ministry of Environment provides some information in German on the procedure.


History of Fennovoima's second EIA procedure

On February 13th, 2014 the Finnish Ministry of Employment and Economy announced the Fennovoima environmental report is finished and ready to be published for public evaluation and comments. This 264 page report was prepared by Pöyry company, which has been previously criticized for breaking the European rules of corporate social responsibility. The Ministry is the body responsible one for the EIA process, international EIA (according to the Espoo Convention) is handled through the Ministry of Environment.

So far, there seems to be several additions to the EIA programme, suggested by Swedish organizations. The most important seems to be adding the INES-7 scenario to the EIA. Another one is the effect of pack ice which is said to be included, but it's actually a description of the pack ice itself, no analysis on the reactor behaviour if pack ice prevents cooling etc.[1]

The Lower Saxony Ministry of Environment got the documentation on February 27th, 2014 and published it on March 7th, 2014. The submission period is open until May 20th, 2014. Actually, the public should have been officially informed since 7 March. The whole German public information procedure is violating the Aarhus convention.


Background information

The nuclear company Fennovoima (formerly with the German nuclear company e.on as the biggest shareholder) wants to build a new nuclear power plant (NPP) in Finland in. On October 5, 2011 Fennovoima announced their site selection for this location[2][3][4]. Fennovoima calls the proposed NPP "Hanhikivi 1 Nuclear Power Project".

Pyhäjoki has been founded a governing county in 1573 by Johan III, the king of Sweden. As a municipality, Pyhäjoki started its operations in 1865. The current borders were set in 1895 when Merijärvi congregation became independent from Pyhäjoki. These days about 3,400 residents are living in this area located in North Ostrobothnia. Active villages are Parhalahti, Yppäri, Pirttikoski, and Liminkakylä. Pyhäjoki is part of Raahe region with approximately 35,000 residents. The total area is 549 km² - including 542 km² land and 7 km² water. It holds 88 km of coastline on the Bothnian Bay and hosts around 150 companies and 130 farms.[5]

In July 2010 the Finnish parliament granted Fennovoima a decision-in-principle for its plans to build a new nuclear power plant, but the company has not been able to apply for a construction license from the Finnish government yet. An attempt to construct a new reactor in Pyhäjoki, on the Hanhikivi peninsula, a mainly untouched area with many endangered natural habitat types, is one of the most arrogant ones in the whole of Europe. Hanhikivi is an important nesting area for almost twenty endangered bird species, especially significant resting area for migrating arctic birds. If the nuclear power project is realized, the area will dramatically change to an industrial area.

The proposed plant site is located in Hanhikivenniemi (Hanhikivi Peninsula) about seven kilometers north from the center of Pyhäjoki. In Summer 2007 the nuclear power company Fennovoima had almost 40 alternative site options. In 2008 the Municipal Council of Pyhäjoki voted 15:6 for the EIA process. One year later, in December 2009, Fennovoima only considered two alternative sites for their NPP, Pyhäjoki and Simo, both with a strongly supporting local government. In 2010 the new regional land use plan for nuclear power was ratified by the Ministry of the Environment, and the municipal council of Pyhäjoki voted again 15:6 for the detailed and partial master land use plans. Also on the decision-in-principle of the Finnish government the municipal council of Pyhäjoki voted 16:5 for the project. Eventually, in October 2011 Fennovoima selected Pyhäjoki to be the NPP site. In June 2013 appeals against the new master and detailed land use plans in Pyhäjoki were rejected by the Supreme Administrative Court.[5]

Hanhikivi is a cape which is located in the municipality of Pyhäjoki, at North Ostrobothnia, on the coast of Bothnian Bay. Minor piece of the capes end belongs to the town of Raahe. The cape is about 5 kilometers long.[6] Hanhikivi means “Goose rock” in English. The name of the area comes from a relic: an erratic block which is located at the capes end.[7]

Hanhikivi area is a significant conservation entity of land uplift coasts. There are none exactly as large unitary forest areas of this kind of coast at North Ostrobothnia. Hanhikivi area includes coast biodiversity, quite representative herb-rich forests of land uplift area, small flood meadows and hardwood-spruce swamps. In addition, the area includes other statutory preserved objects such as sea-shore meadows and gloe lakes. The area of Hanhikivi has been noted in North Ostrobothnia county planning as a nature multipurpose area. There are, also, nationally significant relics and scenically valuable rocky area. Hanhikivi area is partially limited to Parhalahti-Syölätinlahti-Heinikarinlampi-Natura area.[8]

About 63 % of Hanhikivi area has been preserved. About 170 hectares were preserved in Merestä metsäksi project (forest programme) during 2005–2006 by natural values trading, subsidy for preserving ecological values and by buying land to state. There are, also, about 110 hectares preserved in other ways.[8]

Hanhikivi is a very valuable bird migration area. Hietakarinlahti-Takaranta area has been qualified as a nationally important bird area, FINIBA area (Finnish Important Bird Areas). FINIBA areas are remarkable areas for nature conservation. They are nesting and gathering places for threatened species and species for international special responsibility.[9]

Parhalahti-Syölätinlahti and Heinikarinlampi are Natura 2000 areas (code FI110420). It is defined as an nationally valuable bird water area. Also, the sea-shore meadows of Maunus are qualified as a regionally valuable traditional landscape and as the last clear-preserved sea-shore meadows. The surface area is about 275 hectares.[9]

Hanhikivi is also the name of a fixed relic, the delimeter from historical age. It has been qualified as a nationally valuable object and protected by the Antiquities Act (295/63). The Treaty of Nöteborg (Pähkinäsaaren rauha), also known as Treaty of Oreshek, is the peace treaty that set the first east border concerning Finland. The treaty was the first settlement between Sweden and Novgorod Republic regulating their border. The border began at Rajajoki, went to northwest across the Karelian Isthmus and ended to coast of Bothnian Bay. Hanhikivi is found as the delimiter of the Treaty of Nöteborg.[10]

Fennovoima still does not own all the land and water areas they would need for the construction, the land use plans for the nuclear power plant are not legally valid, and the company has not been able to show any solution for the disposal of its nuclear waste, which is prerequisite for granting the construction license. In autumn 2012 the master plan and the more detailed land use plan of the Hanhikivi area were in the Supreme Administrative Court of Finland, because of complaints made by the local NGO Pro Hanhikivi.

During the past years the company has faced a number of setbacks. Several of the Finnish shareholders have withdrawn from the project, the company has fired the chairman of the board as well as their CEO, and there is a lot of speculation in Finland about the possible collapse of the whole project. The latest turn at the end of October 2012 was, that the biggest shareholder in Fennovoima, the German energy giant e.on announced they will give up on the project and the interest in Fennovoima. As of February 15, 2013 e.on handed over their Fennovoima shares to Voimaosakeyhtiö, the consortium of Finnish companies now owning 100% of Fennovoima.[11][12]) Still, Fennovoima tries to move ahead with its plans at full speed. The company has started an official process through the Ministry of Employment and the Economy in order to expropriate the land areas they are still lacking. This means that the company is trying to take more than 100 hectares of land by force from private persons in Pyhäjoki. In the meantime the local government prepares the infrastructure for the huge construction site - forests have been clearcut, roads built and a big empty site is now waiting to host future construction work companies[13]. The art project CASE PYHÄJOKI in late summer 2013 criticized Fennovoima's image washing attempts in the region.

The Russian atomic power giant Rosatom expressed preliminary interest in supplying a AES-2006 (VVER-1200) reactor for Fennovoima[14] as well as buying a stake in the company in February 2013.[15] On July 3, 2013 Fennovoima announced their intention to join the deal with Rosatom[16]. Already in spring 2013, the boss of the Finnish nuclear safety authority, Jukka Laaksonen, had switched to Rosatom - a couple of months later it was announced that Rosatom would like to take over the Pyhäjoki NPP project[17].


  1. NukeNews #13 as of April 16, 2014
  2. http://www.yle.fi/uutiset/news/2011/10/new_nuclear_reactor_to_be_built_at_pyhajoki_2925634.html as at October 5, 2011
  3. http://www.fennovoima.com/en/press-releases/press-releases/fennovoima-nuclear-power-plant-to-be-constructed-in-pyhajoki as at October 6, 2011
  4. http://www.wirtschaftsblatt.at/home/schwerpunkt/greeneconomy/eon-konsortium-baut-noerdlichstes-akw-der-eu-in-finnland--491109/index.do?_vl_pos=r.3.NT as at October 7, 2011
  5. 5.0 5.1 http://www.nuclear-heritage.net/images/0/00/Case_Pyhajoki_presentation_introduction_municipality.pdf as at August 7, 2013
  6. map link
  7. http://www.hanhikivi.net/en/hanhikivi.php as at May 9, 2010
  8. 8.0 8.1 http://www.hanhikivi.net/en/hanhikivi.php?sivu=preservingofhanhikivi as at May 9, 2010
  9. 9.0 9.1 http://www.hanhikivi.net/en/hanhikivi.php?sivu=birdarea as at May 9, 2010
  10. http://www.hanhikivi.net/en/hanhikivi.php?sivu=hanhikivirelic as at May 9, 2010
  11. http://www.handelsblatt.com/unternehmen/industrie/beteiligung-eon-zieht-sich-aus-letztem-akw-projekt-zurueck/7790040.html as at August 9, 2013
  12. http://www.voimaosakeyhtio.fi/en/tiedotteet.php as at August 9, 2013
  13. http://casepyhajoki.info/en/ollinmaki-smooth-roads-are-waiting/ as at May 8, 2014
  14. source: Greenpeace briefing: "Rosatom nuclear new build plans outside Russia", 2013-07-22
  15. Reuters 23.2.2013: Russia's Rosatom says in talks with Finnish firm on nuclear reactor, http://uk.reuters.com/article/2013/02/23/business-us-fennovoima-rosatom-idUKBRE91M08I20130223 in: Greenpeace briefing: "Rosatom nuclear new build plans outside Russia", 2013-07-22
  16. http://www.world-nuclear-news.org/NN_Fennovoima_focuses_on_Rosatom_0306131.html as at May 8, 2014
  17. http://www.hs.fi/english/article/Retired+Finnish+nuclear+safety+boss+hired+by+Russian+nuclear+energy+company/1135270343566 as at July 30, 2013