G. REGIONAL IMPACTS OF THE CONSTRUCTION AND OPERATION OF A DEEP GEOLOGICAL REPOSITORY
1. How will the affected municipalities be able to participate in the site selection process? How will they be able to comment? Do they have veto right?
The process of site selection is not formally regulated by legislation, but the municipalities concerned are able to comment on the selection of DGR site on a non-binding basis within the framework of working groups such as the Advisory Panel of Experts. Only in the environmental impact assessment process will the municipalities have a clearly defined legal role and their interests and views will have to be taken into account or addressed. Municipalities do not and will not have a veto right in any form.
The site selection process itself is not formally regulated by legislation and is a matter of strategic assessment by SÚRAO. It is not a procedure in the formal sense, which would result in an administrative decision, an individual administrative act. In this process, SÚRAO, as the future operator of the DGR, internally chooses between suitable sites and only the final site chosen by SÚRAO will be further assessed in formal administrative procedures. It is possible, however, that the site chosen will be found unsuitable in these procedures and the site selection processes will have to be repeated.
Affected municipalities are involved in this process through participation in interdisciplinary expert panels and working groups, such as the past Working Group for Dialogue on the HoA and the Expert Advisory Panel. In these bodies they can present their views and defend their interests. However, these are non-binding opinions, as even the site selection itself is not legally binding at this stage.
Once the final site has been selected, there will be a phase of formal administrative processes that have clearly legislated outcomes that are binding in nature. These are in particular the Environmental Impact Assessment (EIA), the planning and construction procedures, the procedures under the Geological Works Act and the Mining Act, and the procedure for granting a permit under the Atomic Energy Act. In many of these processes, municipalities have a clear legal role and their interests and views must be taken into account or accommodated. Often they are also parties to the proceedings. The key in this respect is in particular Act No 100/2001 Coll., on Environmental Impact Assessment, according to which the public concerned (not excluding municipalities) has the right to participate in the EIA process, and this right in turn implies the right to participate in the so-called follow-up proceedings and active legal standing. In addition, a legislative initiative is currently underway to strengthen the role of municipalities in these proceedings on the basis of Section 108(4) of the Atomic Energy Act.
Municipalities do not have veto power in any form. Such a right would be an unprecedented encroachment on the principles of the democratic rule of law, which is based on majority rule while respecting and protecting the rights of the minority. A veto right would allow any minority to prioritise its rights at the expense of the rights of the majority, indeed of other minorities, without regard to them (but the majority could behave similarly), which is unconstitutional - contrary to the principle of equality - and therefore unacceptable. Indeed, the above-mentioned recent case law of the Supreme Administrative Court in relation to the DGR is based on similar premises.
2. What will the deep geological repository look like? Will the affected municipalities be able to comment on what the above-ground part of the DGR will look like and where it will be located?
The deep geological repository will consist of two parts - a surface area and an underground area. The surface area will always be located outside the municipal boundaries and will have sufficient connections to the relevant infrastructure. Its size is currently expected to be between 15 and 25 hectares, but it is envisaged that it will be optimised, including a possible change of location. SÚRAO expects to consult and comment on its design and location with the affected sites. The municipalities will be able to comment on the preparation in the framework of the activities of the local working groups and in the relevant procedures (e.g. building permits, etc.) (response from SÚRAO).
3. What will be the process of building up the DGR? How long will it take? What about the extracted rock? Where will the construction workers live?
Accommodation for construction workers will be arranged either directly on site, or it is possible to use potential accommodation capacities in the surrounding villages; commuting of workers is not excluded. This issue will be entirely within the contractor's competence.
Gradual construction is being considered, at the beginning it is a surface area with a construction period of about 5 to 7 years, including administrative permitting, and the underground part is expected to be built in about three to five stages, depending on the location, depending on the layout of the underground part of the DGR. In terms of time, this division corresponds to five to seven-year cycles when the activity will take place underground. The extracted rock is expected to be used partly for the actual construction and finally for the closure of the DGR. There is a high probability that part of the extracted rock will be used in the construction segment as raw material - construction aggregate. Sites have been identified - existing quarries - where there should be sufficient capacity to accommodate surplus rubble in the future (response from SÚRAO).
4. Will we be irradiated?
Man is constantly exposed to some kind of radiation. There is natural radioactivity all around us. Natural radiation exposure is caused by cosmic radiation that reaches the Earth from space and by natural radionuclides that occur in our environment. Only some natural radionuclides are relevant for human exposure, mainly 226Ra,232 Th,40 K, 222Rn. The significant radionuclide in terms of internal exposure is the potassium 40 K isotope, which is present in every human body. Its concentration in the body of an adult corresponds to the average annual effective dose. In the Czech Republic, a person receives an annual effective dose of 2.5 to 3 mSv from natural sources.
The possibility of exposure during RAW disposal is very low even for emergencies. The general limit for the population from exposure to radiation from all permitted or registered activities (also covering RAW disposal in the DGR) is an effective dose rate of 1 mSv/year (see Section 3 of Decree No. 422/2016 Coll.). The initial safety analyses performed indicate that in the time interval 0 - 10 250 years the maximum calculated annual effective dose per representative person reaches a value of 0.136 mSv/year. When the model calculation time is extended to 1 million years, a further maximum annual effective dose is reached only 140 000 y after the closure of the DGR and amounts to 0.0117 mSv/year (answer in cooperation with SÚRAO).