PaksII: Do not issue the environmental permit!

It has been a bad week for the government and all the avid supporters of the Paks expansion project. The European Commission announced the launch of three procedures in the last seven days in connection with the plans of the new nuclear power plant. First an infringement procedure was launched by the Internal Market Commissioner on the violation of EU public procurement rules. Secondly, the DG for Environment decided to further examine the classification of information contained in the Paks documents, as they might violate rules concerning the publicity of environmental information. These two procedures were launched subsequent to my complaints. And lastly, yesterday Margrethe Vestager, the Commissioner in charge of competition, drew the conclusion following her preliminary investigation that  state aid by the Hungarian government cannot be excluded  despite the contrary clames of the government; therefore, she wishes to have a more thorough investigation on the question.

Bet let us not be misled: the biggest problem with the Paks expansion is not that it violates EU competition or public procurement legistlation, but the fact that this is an investment that causes serious damages not only to Hungarian tax-payers and Hungarian electricity consumers, but also to the environmental heritage of our country. Furthermore, the Hungarian society is constantly deceived about the project; this is how this corruptive Eldorado is being sold to those who – for some reason – are unwilling to see the facts.

Furthermore, this is not only  hypothesis. Today I published an 80-page expert analysis,  on the environmental impact assessment documentation (EIAD) of the new plants, done by experts I hired. The conclusions of the expert analysis are devastating. They reveal that the EIAD on the expansion is extremely low-quality; it is based on false data and false assumptions and has very little to do with reality. What is being given a permit in this case is not the actual power plant, but some surreal dream, as a consequence of which reality is constantly being distorted in order to somehow justify this delirium.


Come, lie something adequate!

The dates for the system-integration of the two new blocks are already wrongly indicated in the permit-request: the permit for system-integration is released for 2025 and 2030, even though we know that the target dates prescribed in the Russian-Hungarian execution contract are 2025 and 2026. The significance of the four-year-difference is quite grand: this is what decides how long the four old and two new blocks will operate simultaneously. However, from an environmental perspective, the transition between the old and new blocks is critical, because during this time, the Danube River will be loaded with 232 m3 of heated cooling-water (the old blocks producing 100, the new ones 132 m3 of extraction), for example. The EIAD generously cheats off 4 years, that is, nearly half of the time lapse in questionfor this critical condition.

Beyond the above, the plan of the facility waiting for the permit is also false. It becomes clear from both the EIAD and tother documents that while they wish to solve the storage of spent fuel in a temporary storage facility, which is yet to be built in the vicinity of the power plant, this facility is nowhere to be found in the permit-request or the EIAD. The permit and description of the “high-technology cooling system”, which the EIAD itself deems necessary to avoid overheating the Danube, that is, constantly exceeding limits pertaining to the Danube’s temperature, is also missing.

The estimation on expected electricity prices is completely false; practically, they have been keeping, for years now, to their estimation of 1.3% increase in consumer demand, which has not been not been the case ever since the financial crisis of 2007-2008; instead, in reality there is stagnation or sometimes even decrease. The price calculations and estimations on the expected price of electricity are false.

There are harsh distortions in the assumptions about the water flow and water temperature of the Danube River. The first – rather ridiculous – point of reference in the water discharge calculation made by tthe EIAD was 1500 m3/sec. But this was too much even for the other times quite flexible authority, so it noted that warm-water extraction will cause problems not in case of average water levels, obviously, but when the Danube has lesser water flowing through, during times when the river is warm anyway, that is, hot summer drought periods. The authority has prescribed the necessity to develop heat-load-models for a 950 m3/s of water discharge as well (let me add here that the Danube’s lowest water levels are around 750 m3). Although during the process of completing deficiencies, this problem was formally resolved, trickery wasn’t avoided. They take a single year’s data as basis to declare a negligible probability for the Danube’s background temperature to be high and at the same time its river-flow to be low. However, if they had looked back on the past 30-40 years of data, they wouldn’t have written down such a statement, because as these data show, there can be multiple occasions in a year of such critical weeks, when, predictably, temperature limits will be impossible to keep to. In such a case the power plant will either be shut down – further exacerbating the already horrifyingly bad return on the investment – or they exceed the limit, pay a probably less harsh financial penalty, and that’s it. Which option do you think they will choose?

However, even a model based on these extended series of data could not completely reflect reality, because we have to take the effects of climate change into account: decreasing water flow and increasing temperature. Even the conductors of the assessment did not dare to completely ignore climate change in 2015; however, their applied climate-model – well, saying it’s hurrah-optimistic is quite an understatement. A 1.8 degrees Celsius rise in the average global temperature by 2100, estimated by the developers of the Paks project, is literally the smallest estimation I have come across during the preparation for the Paris climate summit at the end of the month. Even the 2 degrees Celsius, which is the target of the climate agreement, and the reaching of which currently seems to be light-years away, is higher than the Hungarian estimation.

Moreover, the estimations for utilizations are false as well. Without collateral investments – about which the documentation is silent about – the two new blocks will be utilizable only in a schedule-tracking mode, especially during the phase when the new blocks will operate simultaneously with the four old ones – this will deeply undermine their utilization below the planned 95%, which is something that even a recent national  Transmition System Operator (MAVIR)  study warned about. Lower utilization, in return, will cause increased production prices , thus crushing the last pillars from under the calculations of the developers of the Paks project that were completely flawed anyway. Produced electricity will, therefore, be expensive, so in order to be able to sell it and not push the entire power plant into bankruptcy, you, dear tax-payers, will pay the price. Worth it, is not it?


These aren’t the droids you’re looking for

Given the above, we can seafely say that the EIAD is based on a series of flawed assumptions and false data, but what is not included at all is also worth noting. The fact that the planned new power plant on Paks will be a Russian type that was never used in any other part of the world, is completely left out. We don’t even exactly know what it will contain: only the basic template or did we ask for additional, e.g any safety-increasing extensions? Will the Hungarian NPP be similar to the Belarus or the Finnish one? In the case of such a prototype, uncertainty is always greater: there are solutions here that are being tested for the first time, the practical performance or reliability of which we know very little about. The EIAD generously ignores to analyse these risks and uncertainties. ‘We will build up the new power plant in ten years and it will operate at a 95% utilization,’ they say. In the meanwhile, altogether three Russian power plant constructions were given over in the last ten years, all of which took 19-27 years to build. And what if PaksII will not be built in ten years? Failure, thanks to the government to have signed a loan with the Russians, in which we bind ourselves to pay back that loan from  15th of March, 2026, even if the power plant is not completed by that time. An annual 2-300 billion forints will have to be produced in a way that will only take but not produce money in the first stage. In comparison: the entire annual income of the current Paks Power Plant (not the profit, mind you – the income!) is around 170-200 billion forints. This is what we will have to force 2-300 billion reimbursement out of.

The EIAD does not take possible cooling alternatives into consideration, either. The environmentally more beneficial but also more expensive solution of closed systems, such as a cooling tower, was among the more strongly supported solutions in earlier studies (the documents of the Lévai-project); now the EIAD generously stepped over this option and focused solely on the examination of fresh-water cooling (extract cool water out of the Danube and releasing warm water back into it). Necessary collateral investments are scarcely mentioned.

The need for a 400-kilovolt wire is mentioned to drive produced electricity away, but not its costs. The question of a safety reserve is also left unresolved. Briefly, it is about the fact that in all electricity systems, it is necessary to build a reserve for the system’s largest electricity producing unit in order for it to become an immediate substitute in case of malfunction without causing a blackout in half the country. Currently, the biggest units of the power plant are the 500 MW blocks. We have reserve capacities for these. The new blocks, however, will be 1200 MW blocks, which means that there is a need for the establishment of a 700 MW reserve capacity (one and a half times larger than the current Paks block) in order to comply with the system requirements. Has anyone heard governmental officials tweet about this at any point? Anything on how and with what technology and at what cost will this be constructed? Well, the EIAD is also deeply silent about it. As it is silent about the necessary system regulation elements as well, even though during simultaneous operation – if they do not wish to operate the plants at half-performance – these have to be concerned, because of night-time overcapacities, for example (the six Paks blocks together will, in themselves, produce more energy than what the country actually consumes, ie more than the base load). Hitherto, there has been only one expert recommendation for this issue: a pumped storage facility, which can cost 3-400 billion forints and wonderful debates about which hill we should destroy for its construction.

My uncle, called Reality

However what is not a lie and is not missing from the documentation, i.e., what is more or less seemingly realistic, also gives reason for serious concern. Although heat-load models are based on false data, they still suggest the possibility of constant difficulties with keeping the prescribed limits for the Danube’s temperature. The recommendation for such an occurrence is either temporarily shutting down the power plant or the development of the so-called “high-technology cooling system”. Do we find any allusion in the EIAD to the permission of such a high-tech facility (e.g. a cooling lake)? Of course not.

The principle of multi-level security is commonly accepted when it comes to NPPs; however, what raises safety concerns in the Paks case is exactly the question of cooling-water supply, which is the Achilles’ heel of power plants in general – because in Paks we will only have a single security system. There is only one cool-water canal transmitting cooling water to the plant; if something happens to this canal, there is no cooling water. What this means is that we have not a single, but actually merely half-security, as the very same single cooling canal will be the one supplying the new blocks as well. The capacity of this canal, in its current form, is not sufficient to supply all of the six blocks (4 old + 2 new) simultaneously, therefore it has to be deepened by two meters. This will be executed in a way that PaksI will constantly operate in the meantime. I repeat: the cooling canal will be dug up while PaksI will be constantly operating at full performance. This infers unacceptable safety risks. What would you think about a car mechanic who recommend fixing your car’s cooling system on the M1 highway while going with 130 km/h?

We could go on and about, describing the series of problems with the documentation. For those who are interested in the details I would suggest reading the complete study (note of the editor:the executive summary is avialable in English).

However, based on all the above, we could safely say that this EIAD cannot be taken as a basis for an environmental permit for the Paks expansion.


We demand the authority to refuse issuing a permit due to the provision of false data!

We demand the conduction of a new impact assessment documentation, based on real data and real models, that truly analyses all occurring problems!

We demand the prescription of an entirely new conceptual approach for the fulfilment of environmental requirements, e.g. for the solution of the cooling system (cooling tower, cooling lake, etc.)!

And above all, we demand all insidious lies to be stopped!

We will not let small-scale political interests to bring on unbearable financial burdens to be paid back by current and future generations, we will not let them to make the Danube River constantly overheated for 60 years in advance and we will not let them create safety risks that have never been authorized by anyone!