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WP6: Environmental Impact Assessment Report (EIAR), radiologic and non-radiologic.


In addition to safety and security requirements, the assessment of the environmental impact that may be induced by a nuclear facility like MYRRHA is a key element in the licensing process. In compliance with legal requirements, the assessment of the environmental impact is carried out in a stepwise approach:

  • Specifically for nuclear facilities, a project note is drafted by the initiator and sent to the authorities. This note contains a description of the project and a first global estimation of direct and indirect environmental effects, enabling the authorities to define the necessity and extent of an Environmental Impact Assessment and the procedure to be followed.
  • Already at an early stage of project development, a notification file is drafted and subject to a first public inquiry. The outcome of this inquiry is translated by the authorities to specific guidelines and constraints that have to be considered in the environmental impact assessment of the project.
  • A draft EIA-report is established and sent to the authorities.
  • The final Environmental Impact Assessment Report (EIAR) will take into account possible remarks and additional questions formulated by the authorities on the draft report.
  • After completion and approval of the final EIAR, the application of an environmental permit can be launched. The final EIAR is an integral part of the application.
  • The application for the environmental permit involves a second public inquiry. The EIAR has to be in line with the radiological aspects analysed in the frame of the Preliminary Safety Assessment Report (PSAR) that considers both operational and decommissioning waste management.

Considering that the European environmental regulations have been the main source and reference for the Belgian authorities to elaborate the corresponding Belgian legislation applied to MYRRHA in this field, the objective of Work Package 6 is to provide a review of European EIA reports for similarly large facilities. Further, according to the specificity of MYRRHA of integrating a research reactor with an accelerator and a spallation target, special attention will be devoted within this work package to preventive provisions for environmental impact during accelerator coupling incidents.
The licensing procedure of the multi-purpose MYYRHA irradiation facility was briefly presented and discussed in the occasion of the FP7-Central Design Team (CDT) project. Requirements from the concerned regulatory bodies, the Federal Agency for Nuclear Control (FANC) with its inspection and control body BEL V, were the subject of early information exchanges that are still running in parallel with design development for the different facility structures, systems and components.

Such aspects have been reported from early 2010 up to mid-2012 under task 4.3 of WP4 in compliance with CDT contract terms. This contribution included namely an introduction to the MYRRHA project, the Belgian institutional framework and the scope of expected licensing reports. It further described the more specific pre-licensing approach developed with the regulatory authorities by focusing on innovative aspects that may have a significant impact on the safety of the installation. Such a pre‐licensing phase is estimated to last at least until end 2015.

It should be underlined that the objectives of the pre‐licensing phase are not to provide the detailed analyses or demonstrations expected in a (Preliminary) Safety Assessment Report. It should well converge satisfactorily to a fixed design of the installation for which it is demonstrated that the safety options, security requirements and safeguards obligations implemented by the requester meet the objectives and requirements of the regulatory authority. Of course, their conclusions on the "licensibility" of the installation at this stage are restricted to the pre‐licensing phase and are not binding for the later licensing phase.
A successful outcome of the pre‐licensing phase within the proposed timing became the overall objective for the licensing team and the engineering and R&D programme in progress. In this frame, the scope and planning of the Front End Engineering Design (FEED) contract presently under negotiation is also becoming one of the main drivers of the project. During about 2.5 years, detailed study of the design will lead to revisions of structures, systems and components and consequently, new iterations of safety studies. By mid-2016, SCK•CEN would get from the FEED all final deliverables required for preparing the PSAR in view of the final license application.

If safety remains the reference issue for pre-licensing, many other preparatory actions can of course be tackled on other licensing aspects in order to anticipate from 2014 later development and drafting works with regard to any other required licensing report. One of them is the Environmental Impact Assessment Report (EIAR) that will be the main licensing aspect dealt with in the frame of the MARISA project. It will analyse the consequences expected for people and environment, according to a systematic, objective and scientific approach, highlighting where it may be necessary to take action to avoid or mitigate as far as possible the impact on the environment, in compliance with regional, national and international directives, decrees or treaties supporting the request of exploitation licenses.

According to recent regulations and in order to cover both radiological and non‐radiological aspects, this document will be evaluated jointly by the Federal regulatory body (FANC/AFCN) and by LNE (Leefmilieu Natuur Energie), a dedicated division of the Flemish regional Government. This EIA report is also mandatory when submitting the request for the construction license to local and provincial authorities, another important step in the procedure that will only be tackled once final plans are ready for the installation (nuclear island and balance of plant). At this stage only a "project note" has been drafted in this frame, based on the present design stage (2012).

In practice, the following roadmap is summarizing the main actions to be developed to finally gain the environmental license.

Pre-licensing phase (2011/2015)

    • Drafting and submission of project note to Authorities (WG FANC/LNE)
    • Procedure for EIA Qualification of MYRRHA project
    • Procedure selection expert bureau for EIAR (Specifications, File)
    • Drafting and submission of notification file to Authorities
    • Review of completeness and iteration
    • Administrative procedure in view of public inquiry
    • Mention of results, guidelines and provisions
    • Drafting of a project/concept EIAR
    • Submission/negotiation/revision/assessment (administration/WG)

Licensing phase (2016/2018)

    • Finalisation EIAR and submission for application permit
    • Evaluation of completeness and info review if required
    • Assessment phase including Public Inquiry
Assessment, Decision and Communication to future operator