The complicated story behind this public hearing simply begs a comparison with some old TV mystery show of the likes of the Twilight Zone – a seemingly appropriate comparison, at that, given the name of the town, which can be translated as “Polar Lights” – where the viewer is taken to an obscure and arcane world where anything is possible and human logic and reasoning are defied.

The event had initially been planned to take place on April 12, but was cancelled without explanations. The subject to be discussed during the hearing was the preliminary assessment of environmental impact of operating Unit 4 of Kola Nuclear Power Plant at 107 percent of rated capacity.

A few words need to be said about the preparations for the hearing. Three documents that were to make the subject of discussion, totalling altogether just over 200 pages, had been made available to the public on the premises of the Centre for Public Information of Kola NPP. Access permissions: Reading – yes, photographing – yes; a request for an electronic copy, however, went unanswered, something to be likely interpreted as a “no.” Likewise, no mention of any “organisational committee for the preparation to hold the public hearing” was to be found – a detail that would turn out to be of certain importance.

Public organisations sent faxed messages repeatedly asking to view the documents in digital form, but no answer, yes or no, has been provided. The State Nuclear Corporation Rosatom, Russia’s foremost and only authority in all things nuclear, likes to make loud speeches about the policy of transparency and openness in its organisation. Apparently, if it applies at all, it only does so with regard to the actions of the corporation’s upper management and has nothing to do with the daily grind of the subordinates – much less those within the Rosatom-owned structure Rosenergoatom, which operates Russia’s ten nuclear power plants, including Kola NPP. All of this was taking place throughout March and April this year.

Hardly a month had passed when, in early May, a new statement appeared both in the press and on the Internet, on the website of the town of Polyarniye Zori (http://www.pz-city.ru/actual/1725, in Russian), about a public hearing scheduled for June 9, 2011. Furthermore, all documents, the statement said, were available right there, in electronic form, on the website.

There is much to wonder at in this new turn of events: The management of Kola NPP seem to have sharply altered their information policy in quite a short timeframe. It turns out now that all the documents that a number of public organisations had made repeated attempts to get familiarised with were actually accessible in a format used everywhere today in the contemporary world, and could gain access to them without leaving their offices.

Then, on May 11, 2011, this surprising news report appeared (http://www.pz-city.ru/news/1733/, in Russian):

“On May 10, 2011, a meeting took place in the town of Polyarniye Zori of the organisational committee charged with preparations for the public hearing to discuss the preliminary materials of an environmental impact study regarding the operation of Reactor Unit 4 of Kola NPP at 107 percent of nominal reactor capacity.

Organisational committee members – representatives of the administration, public organisations based in the town, and of Kola NPP – gave an account of the work done, planned the areas of focus for further activities, allocated among themselves the responsibilities to be carried by each, and created work groups charged with preparations for the public hearing.

The organisational committee voted unanimously to elect T.D. Rodionova, deputy head of the municipality, the chair of the committee.”

Now, the curious thing is that if this “organisational committee” had existed beginning in March, then all it could now “give an account” of would be the cancellation of the previous hearing; if, on the other hand, it only was put together in early May – a period when the country’s normal day-to-day life is twice interrupted by three-day-long national festivities, the Labour Day and Victory Day – and still had not by then had a chairperson, then the only thing it could report would be how the members spent their holidays.

Or did they maybe report to each other whether the town of Polyarniye Zori had in its midst opponents of increasing the power capacity of Reactor Unit 4? Or how the organisers were planning to fill the assembly hall of the local community centre with enough participants to create the semblance of “full public approval of the plan to introduce additional production of power” – the way that such public hearings are usually arranged in modern Russia?

Anyway, why, all of a sudden, so much attention to a future public hearing in the nuclear town when one can be completely certain that a handful of voices speaking in dissent to a plan to conduct yet another nuclear experiment will have absolutely no impact on the outcome of the little formality that this hearing will be?

The results of a public hearing are largely, as practical experience suggests, of purely recommendatory nature. Two or three notations would be entered on the meeting’s records, maybe, and that’s all she wrote, done and forgotten in a second. All this is well known by environmental organisations, which is why they have filed an application to conduct a public environmental impact evaluation – a document that will have to be taken into account when the state initiates its own environmental impact study of the envisioned experiment.

Let’s take a look at the documents that had been prepared for the cancelled hearing of April 12 and finally published in preparation for the hearing of June 9. For the reader’s convenience, the document titles have been arranged here in a table, below.

As shown above, there are discrepancies. There is even one additional document that appeared after the cancelled April 12 hearing: the so-called Explanatory Note.

But let’s begin at the beginning, the Specification of Requirements. The first version is the work of a team of co-authors based at Kola NPP – deputy chief engineer for safety and reliability I.V. Marakulin; head of the public information centre of Kola NPP V.Yu. Nigorenko; head of the nuclear safety and reliability department I.V. Nigorenko; head of the nuclear reaction department P.I. Nikishayev; deputy head of radiation safety department A.Yu. Smelov. The second one is a document signed by a Rosenergoatom official, V.G. Asmolov.

Far be it from us to bore the reader with a detailed page-to-page comparison of the two texts, but a close scrutiny does give us an answer to the question of why a new version appeared in the first place and what errors had crept into the first text, penned by the Kola NPP authors.

These are the phrases that the officials from Kola NPP were too “forgetful,” shall we say, to include in the section entitled “The environmental impact evaluation materials must include:” of their own Specification of Requirements and which were then added to the later version:

“4. Descriptions of alternative methods of achieving the objective set by the envisioned or other economic activity (alternatives available within the mandate of the ordering party), including the suggested option and the “zero” option (abandonment of said activity).

5. Descriptions of possible types of impact brought on the environment by the envisioned or other economic activity as per the alternative options available. 

7. An assessment of environmental impact, including an evaluation of reliability of prognosis made as to the consequences of the envisioned investment activity:

а) as a result of conducting the operation of Reactor Unit 4 of Kola NPP at above-nominal capacity:

– the likelihood of emergence of risk, the nature and scale of possible adverse impact of the licensed type of activity in the field of application of nuclear energy on the environment, complete with specification of most vulnerable components; providing information about the impact of design-basis and beyond-design-basis accidents and enhancing reliability and safety.

б) the necessity of examining alternative methods of implementing the envisioned economic activity, including the “zero” option.”

If someone thinks that this is all small change, a bunch of phrases of little if any importance, they will not be quite right. In our opinion, the addition of these new sentences to the updated version of the Specification of Requirements is exactly the reason why a new, unprovided-for by the regulations, document bearing the heavy title of “Explanatory note to the materials of the environmental impact evaluation of operating Reactor Unit 4 of Kola NPP at 107 percent of nominal reactor capacity (preliminary materials)” appeared at all.

And it was prepared by that same team of authors who wrote the first version of the Specification of Requirements with glaring omissions.

What can be said about that new document, the Explanatory Note?

One. There are – finally, at long last – some sentences pertaining to the “goals and necessity of implementing the envisioned economic or other activity”:

“The goal of increasing capacity of Reactor Unit 4 is to increase electric power output.

At the moment, the Kola energy grid operates without shortages, but an energy consumption forecast indicates both an increase in such shortages within the system and the introduction of new possibilities of transporting excess electric power to regions of Central Russia via the grids of Karelenergo and Lenenergo (after construction of new high-voltage power lines has been completed). Besides that, three projects of increasing electric power export to the Scandinavian energy grid (Nordel) have been developed.”

Doesn’t this sound a lot like a weather forecast? But meteorologists at least tell us some concrete figures: temperatures and wind speeds, for instance, something that can give us a basis for comparisons. Here, the simplicity is simply bewildering: There is just an unidentified, unsourced forecast and, when construction “has been completed,” a free and unobstructed pathway to a nuclear paradise. As if there were no “alternative methods” of achieving the envisioned objective – as if there were no alternatives to nuclear energy.

Two. Indeed, in terms of what alternative options there may be to setting off a nuclear experiment at Reactor Unit 4, the only option the authors of the Explanatory Note thought it possible to examine is the “zero” option (abandonment of activity), with the following substantiation attached:

“The “zero” option (abandonment of activity) can be considered among alternative options.

Abandoning the project of increasing capacity – the “zero option” – will not lead to negative economic consequences in the near future. However, taking into account that decommissioning of Reactor Units 1 and 2 is planned for the years of 2018 and 2019, there may develop a shortage of electric power supply on the Kola Peninsula, with each kilowatt-hour being in demand.

The only alternative option to the envisioned economic activity is the “zero” option, i.e., abandonment of said activity and, as a result, impossibility of any additional impact on the surrounding environment.”

How simple. And how peremptory!

Why wouldn’t the authors examine the possibility of “increasing the thermal efficiency factor of the reactor’s secondary circuit by replacing or upgrading the existing equipment”? Wouldn’t that be an alternative option? Or did they fail to mention it because the project developers had forgotten to mention it in the prepared documents? In absence of a substantiation explaining that this or that option is unfeasible for such and such reasons, the authors simply had to “forget” that such a method exists in the first place. But even a person far removed from the reality of operating a nuclear reactor would grasp that enhancing the performance of one by way of replacing the equipment in use with new components is a much safer and more reliable approach than increasing its thermal capacity. Still, deathly silence sealed the fate of that alternative.    

Of course, why would the nuclear industry bother itself with the issues of the non-radioactive secondary circuit, turbine upgrades, or any other auxiliary equipment, when the real goal at hand is to put to use as soon as possible new nuclear fuel bundles with a higher degree of uranium enrichment? This is simply not on Rosatom’s working agenda, as such upgrades do not contribute much to the amassment of the corporation’s production capacities, nor do they help highlighting its ambitions.

Three. What about the design-basis and beyond-design-basis accidents?

Short, no figures or details, which was probably thought to be fully convincing for anyone reading this text:

“In particular, an analysis has been done of the most severe design-basis accident scenario, from the point of view of radiation consequences, as caused by the onset of a leak from the main circulation pipeline of the primary circuit, [in conditions of a through-and-through rupture] complete with leakage of the coolant on both sides. The results of this analysis show that the development of such an accident does not lead to exposure doses exceeding those established for the personnel or the population, nor to [levels of contamination] exceeding acceptable norms established for discharges or content of radioactive substances in the surrounding environment. Besides that, means of managing beyond-design-basis accidents and of limiting their consequences are provided for at Kola NPP, including at Reactor Unit 4, and the functioning of these does not depend on the level of capacity at which the reactor unit is operated. Therefore, the main criteria of safety for nuclear power plant reactors are observed, as per [the safety assurance regulations for nuclear power plants].”

“As part of preparations of the unit for operation at increased capacity, an additional analysis has been conducted of accident scenarios, including beyond-design-basis accidents. Necessary amendments have been introduced to the instructions on accident liquidation and guidelines on accident management.”

Difficult to come up with adequate commentary to such language: All the good words are seemingly there, all the right concepts duly stipulated in the text, but still no clear and necessary information with at least some proof or argumentation. We are supposed, apparently, to understand it like this: Dear readers, we have provided for all the contingencies, we’ve checked and double-checked it all, everything’s going to be alright. Don’t worry, leave it all with us. In other words, trust us on our word alone.

As known facts tell us of various accidents that have taken place at sites of application of nuclear energy, exposure doses suffered by cleanup personnel alone in every case – and especially, of course, during the Chernobyl catastrophe – reached levels close to maximum ones, or exceeded them. But Kola NPP is apparently the Twilight Zone – anything is possible there; or rather, this, extreme exposure or contamination, is not possible at all under any circumstances.

How possible is it, though, to have complete certitude with respect to predicted exposure doses for Kola NPP personnel in case of an accident? What sort of values do the authors of this document have in mind anyway? Is it 0.02 sieverts, or 0.05 sieverts, or even more? The only people who know this are those who wrote these oblique and essentially meaningless phrases. And yes, we have to, for the time being, take their word for it or else we end up “blaspheming the policy of transparency and openness.”

Four. The main and most important point: The Specification of Requirements makes it absolutely clear, in black and white, what objective the environmental impact assessment report must achieve in its substantive content. There is no Explanatory Note that this specification has to provide any guidelines for, and there is no mention of a document under such title. How did it appear, on what grounds? As paperwork goes, this sort of documents can be written for any occasion at all, a dime a dozen, starting with a trivial memo explaining the reasons for being late for work. According to the latest version of the Specification of Requirements, the responsible officials at Kola NPP were to introduce corrections into the text of the environmental impact assessment – not invent some mysterious Explanatory Note, of which the only mention exists in that note itself. It’s the Flying Dutchman of a bureaucratic conundrum: Now we see it, now we don’t. 

There is among the documents prepared for the public hearing one entitled “Environmental impact assessment of increasing electric power output at Reactor Unit 4 of Kola NPP. Stage 2. Report ‘Protection of the natural environment when increasing and operating Reactor Unit 4 of Kola NPP at above-nominal capacity.’ Explanatory note KL. 4-0-77-PZ-002.” And there is a strange and inexplicable error in that document. The first version of this text – the one that was prepared for the cancelled hearing of April 12 – contains the following sentences on pages 9 and 94, respectively:

“The gamma field in the vicinity of Kola NPP-2 remains at levels close to average values across the territory of Russia.” And:

“The water resources of the Imandra water reservoir have more than a sufficient margin to provide for the operation of the processing water supply system of Kola NPP-2.”

There are photographs of the original document, clearly showing these two passages. What Kola NPP-2?

The same document posted in electronic form mentions once again this non-existent Kola NPP on page 9, but page 94 is already cleared of this unpleasant error. This, mind you, is a 2008 document. In other words, in three years since it was initially put together, no one among the authors or those who read and approved the text has been able to catch and remove an embarrassing “typo” that immediately casts doubt on the quality of the report as a whole.

Does one have today to run a painstaking, manual word-by-word analysis of two versions of the same text to make sure the copies are identical?

A non-technical conclusion

So what’s there to do if it’s not a TV show that stops to exist as soon as the switch-off button is pressed on the remote control? Is there a way out of this labyrinthine reality? There just might be:

1. Acknowledge the documents prepared for the second public hearing as unsatisfactory.

2. Send the report “Environmental impact assessment of operating Reactor Unit 4 of Kola NPP at 107 percent of nominal reactor capacity” (preliminary materials)” for follow-up revision to bring it to conformity with the Specification of Requirements.

3. Postpone the public hearing scheduled for June 9, 2011, sine die.

That way, just maybe, we could make our safe return from the twilight zone back into the real world.