Käyttölupahakemus 1

Loviisa nuclear power plant

Operating licence application NUCLEAR POWER PLANT

Käyttölupahakemus 32 Käyttölupahakemus

Contact Details

Fortum Power and Heat Oy Keilalahdentie 2-4, Espoo P.O.Box 100 FI-00048 FORTUM Tel. +358 10 4511 Y-0109160-2 fortum.fi

Base maps: National Land Survey of Finland 2021 Translations: AAC Global Oy Layout and design: Creative Peak Print: Print Mill

The original language of the operating licence application is Finnish. Versions in other languages are translations of the original document which is the document Fortum is committed to.

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TO THE FINNISH GOVERNMENT Operating licence application for Loviisa nuclear power plant

1 APPLICANT The applicant is Fortum Power and Heat Oy (hereinafter Fortum), which has its registered office in Espoo and the business ID of which is 0109160-2. Fortum is the owner and operator of Loviisa nuclear power plant (hereinafter also “Loviisa power plant” or “power plant”), located on the island of Häst- holmen, in the town of Loviisa.

Further details about the applicant can be found in Appendices 1, 2, 8, 10 and 11 to the application.

2 APPLICATION

Fortum is applying for a licence pursuant to section 20 of the Nuclear Energy Act (990/1987): 1. to use the nuclear power plant units Loviisa 1 and Loviisa 2 for the production of energy no

longer than until the end of 2050 and in the manner required by the preparation for the power plant units’ decommissioning no longer than until the end of 2055.

2. to use the buildings and storage facilities, with any necessary extensions thereto, required for the management of nuclear fuel and nuclear waste no longer than until the end of 2090.

In relation to the aforementioned, Fortum is applying for a licence to possess, manufacture, handle, use and store nuclear waste and other nuclear materials1 elsewhere in the power plant area2 than in the final disposal facility for low- and intermediate-level waste as follows:

• A maximum of 12,800 fuel bundles of spent nuclear fuel generated in the operation of Loviisa nuclear power plant.

• A maximum of 10,000 m3 operational waste3 (including decommissioned radiation sources) gener- ated in connection with or as a result of the operations of Loviisa nuclear power plant.

• A maximum of 2,000 m3 of radioactive waste with an activity concentration equivalent to low- or intermediate-level waste generated elsewhere in Finland.

In addition, Fortum is applying for a licence to possess, handle, use and store the fresh nuclear fuel required in the operation of Loviisa nuclear power plant, provided that a licence for the import of the said fresh nuclear fuel has been granted pursuant to the Nuclear Energy Act.

Furthermore, Fortum is applying for a licence to possess, manufacture, handle, use and store other nuclear materials already in the power plant area and other nuclear materials besides those already mentioned, provided that a licence pursuant to the Nuclear Energy Act has been granted for any nu- clear materials subject to an import licence.

According to section 7 g, subsection 2, a licence applicant and a licence holder must have a plan for the decommissioning of a nuclear facility. Unless otherwise mentioned in the terms of the licence, the licence holder must also, during the operation pursuant to the operating licence, regularly, at least

1 Nuclear material refers to materials defined in section 1, subsection 1, paragraph 8 of the Nuclear Energy Decree (161/1988). 2 Power plant area refers, pursuant to section 2, subsection 1, paragraph 8 of Radiation and Nuclear Safety Authority Regulation STUK Y/2/2018, to an area in use by nuclear power plant units and other nuclear facilities in the same area, and to the surrounding area, where movement and stay are restricted by the Decree of Ministry of the Interior issued under Chapter 9, section 8 of the Police Act (872/2011). 3 Operational waste refers to the low- and intermediate-level waste accumulated in the operation of a nuclear power plant.

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every six years, present an updated plan for the decommissioning of the nuclear facility for the approv- al of the Ministry of Economic Affairs and Employment. Fortum proposes that once the energy produc- tion has come to an end, the updated plan for the decommissioning of the buildings and operations necessary for the management of nuclear fuel and nuclear waste be submitted for the approval of the Ministry of Economic Affairs and Employment in connection with the periodic safety review referred to in section 7 e of the Nuclear Energy Act, i.e., at least every 10 years.

3 SUBJECT OF APPLICATION

3.1 LOVIISA NUCLEAR POWER PLANT

The application pertains to Loviisa nuclear power plant, which comprises two power plant units, Lo- viisa 1 and Loviisa 2, each with a nominal thermal power of 1,500 MW; the support functions required for their operation, buildings included; and the related buildings, storages and operations necessary for the management of nuclear fuel and nuclear waste. At the time of this application’s preparation, Loviisa nuclear power plant produces a total of approximately 8 terawatt hours (TWh) of electricity for the national grid every year. This is equal to approximately 10% of Finland’s electricity consumption. The preparation for decommissioning, the decommissioning and the phase of independent operation, all described in more detail in section 3.3 of the application, will begin once the electricity production has ended.

The final disposal facility for low- and intermediate-level waste located in the power plant area (here- inafter also “final disposal facility”) is a separate nuclear facility as referred to in the Nuclear Energy Act and Nuclear Energy Decree, but it is used in connection with Loviisa nuclear power plant and inte- grated into the power plant’s operations. The operating licence application for Loviisa nuclear power plant does not apply to the final disposal facility, for which a separate operating licence application will be submitted.

Loviisa nuclear power plant’s reactors are VVER-440-type water-moderated and water-cooled pres- surised water reactors. The plant units were subject to several changes compared to a standard facility during the design phase to ensure their basic principles met Western requirements. Numerous pro- jects aiming to improve nuclear safety have also been carried out over the years. The Loviisa 1 plant unit was commissioned in 1977 and the Loviisa 2 plant unit in 1980.

3.2 LOCATION Loviisa nuclear power plant is located approximately 12 km from the centre of the town of Loviisa, on the island of Hästholmen. The buildings and structures required for the power plant’s support func- tions, such as security and temporary accommodation for workers employed for annual outages, are located on the mainland. The raw water is abstracted from Lake Lappomträsket, also located on the mainland.

Appendix 3 to the application contains a report on the location of Loviisa nuclear power plant as well as on any residential areas and other activities in its immediate surroundings and land use planning.

3.3 INTENDED USE The reactors of the plant units Loviisa 1 and Loviisa 2 are used to produce thermal energy and further to produce electricity for the national grid. Once the energy production has come to an end, which in accordance with this application will take place no later than in 2050, the nuclear power plant units will be used as required in the preparation of the plant units’ decommissioning for no longer than until

the end of 2055. Among other things this means the storage of the spent nuclear fuel in the reactor buildings and the related operations.

The buildings and storages forming part of the nuclear power plant and necessary for the nuclear fuel and nuclear waste management are used for the handling and storage of the nuclear materials necessary for the power plant’s operation and for the handling and storage of the nuclear waste gen- erated in the power plant’s operation. When necessary, these buildings and storages are also used for the handling and storage of radioactive waste with an activity level equivalent to low- and intermedi- ate-level waste generated elsewhere in Finland as presented in the proposed terms of the licence in the power plant’s application.

In accordance with this application, energy production at Loviisa nuclear power plant would end no later than in 2050, after which the preparation for the decommissioning would be commenced. Phase 1 of the power plant’s decommissioning (the preparation and first dismantling phase) will begin once energy production has ended and will last for 6–10 years. Following the first dismantling phase, mea- sures related to decommissioning and waste management will be carried out at the site of the facility and spent nuclear fuel from the plant units will be stored in the plant parts which have been made independent. The power plant’s plant parts to be made independent are the interim storages for spent nuclear fuel, the liquid waste storage and the solidification plant, any necessary parts from the power plant’s auxiliary buildings and the required support functions. The final disposal facility for low- and intermediate-level waste will also operate as an independent facility. Making a plant part independent refers to the separation of required functions, such as cooling or ventilation, from the systems of the power plant units to ensure the said plant parts to be made independent can function without the power plant units. The second dismantling phase, during which all plants parts made independent will be dismantled, will commence when all the spent fuel has been transferred to Posiva Oy (hereinafter Posiva) for final disposal.

Appendix 5 contains a report on Loviisa nuclear power plant’s technical principles of operation. The reports on the quality and maximum quantity of the nuclear materials and nuclear waste produced, handled, used or stored at Loviisa nuclear power plant, as well as the plans on the arrangement of nuclear waste management, are presented in Appendices 4 and 9 to the application.

3.4 POWER PLANT’S NOMINAL POWER The reactors in the plant units Loviisa 1 and Loviisa 2 each have a nominal thermal power of 1,500 MW and the net electric power is currently around 507 MW. The total efficiency of the power plant units is therefore approximately 34%. The availability and load factors of Loviisa nuclear power plant have been excellent.

3.5 PERIOD OF OPERATION The power plant units are meant to be used for energy production until the end of the licensing period applied for in this application, i.e., until the end of 2050, and to the extent required by the preparation for decommissioning, until the end of 2055.

The buildings and storage facilities necessary for the management of nuclear fuel and nuclear waste, with any necessary extensions and support systems thereto, are meant to be used no longer than until the end of 2090. The spent nuclear fuel will be stored in the storages for spent fuel until such time as the transportation of spent fuel for final disposal to Posiva’s encapsulation and final disposal facility are completed. The second dismantling phase, during which the plant parts that have been made independent will be decommissioned, can be carried out once all the spent nuclear fuel has been transported for final disposal. The final disposal facility will be closed permanently once all radioactive waste from the second dismantling phase has been deposited in final disposal.

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3.6 CURRENTLY VALID OPERATING LICENCE

Government decision (Document no. 6/330/2006) of 26 July 2007 granted Loviisa power plant an operating licence pursuant to section 20 of the Nuclear Energy Act. This operating licence is valid until 31 December 2027 in terms of power plant unit Loviisa 1 and until 31 December 2030 in terms of power plant unit Loviisa 2. The licence also covers the use of the buildings and storage facilities necessary for nuclear fuel and nuclear waste management, as well as any extension thereto, until the end of 2030.

4 GROUNDS FOR THE PROPOSED TERMS OF THE LICENCE

The application presents the licence applied for and a proposal on the new terms of the operating licence. Each licence term proposed in the operating licence is shown below in italics, followed by the grounds for it.

In relation to the aforementioned, Fortum is applying for a licence to possess, manufacture, handle, use and store nuclear waste and other nuclear materials elsewhere in the power plant area than in the final disposal facility for low- and intermediate-level waste as follows:

– A maximum of 12,800 fuel bundles of spent nuclear fuel generated in the operation of Loviisa nuclear power plant.

Appendix 4 to the application includes an estimate of the number of spent fuel bundles in the event that operation for energy production is extended until 2050. In this case, the estimated number of bundles would be 11,400 bundles. The licence term proposed in the application contains a margin which covers, among other things, any changes in the method of fuel loading, changes in fuel planning and a planned increase in the number of dummy elements.

– A maximum of 10,000 m3 operational waste (including decommissioned radiation sources) gener- ated in connection with or as a result of the operations of Loviisa nuclear power plant.

Appendix 4 to the application includes an estimate on the volume of operational waste. The volume of waste proposed in the application’s licence term, 10,000 m3, was determined on the basis of waste volumes and the storage capacities available for solid and liquid waste. The capacity applied for in- cludes a margin for special circumstances (such as plant modifications or a need to return waste from the final disposal facility to the power plant), due to which it intentionally exceeds the needs of normal use. In recent years, the power plant and storage buildings have typically housed some 300–400 m3

of low-level operational waste and some 1,300–1,400 m3 of intermediate-level operational waste. The power plant has existing facilities suitable for the handling and storage of nuclear waste and a possi- bility to modify other premises or build additional facilities according to need. The operation of Loviisa power plant also involves the use of radiation sources for which there is a separate safety licence pur- suant to the Radiation Act. These are used for some process measurements, for example, as well as for the testing and calibration of radiation measuring instruments. Contingencies for the radiation sourc- es in question being deposited in Loviisa’s final disposal facility once they are no longer in use have been made in the power plant’s operations. The volume of waste generated by the radiation sources amounts to only a fraction of the volume of the rest of the waste to be deposited in final disposal. The radiation sources are described briefly in Appendix 4 to the application.

– A maximum of 2,000 m3 of radioactive waste with an activity concentration equivalent to low- or intermediate-level waste generated elsewhere in Finland.

The volume of radioactive waste generated elsewhere in Finland is discussed in Appendix 4. The volume of the waste to be stored at the power plant is estimated to be significantly lower than the proposed licence term, and a large proportion of the waste is likely to be deposited in final disposal relatively quickly after its arrival. Nevertheless, the possibility that this waste will be placed in interim storage or handled at the power plant prior to its transfer to the final disposal facility, or that there will

be a need to return it from the final disposal facility to the power plant, needs to be considered. The first planned batch of waste generated elsewhere in Finland would consist of the decommissioning waste of the FiR 1 research reactor and the Otakaari 3 research laboratory for radioactive materials.

In addition, Fortum is applying for a licence to possess, handle, use and store the fresh nuclear fuel required in the operation of Loviisa nuclear power plant. A licence for the import of the said fresh nu- clear fuel has been granted pursuant to the Nuclear Energy Act.

Loviisa power plant possesses, handles, uses and stores only fresh fuel required for the plant’s own operations.

Furthermore, Fortum is applying for a licence to possess, manufacture, handle, use and store other nuclear materials already in the power plant area and other nuclear materials besides those already mentioned, provided that a licence pursuant to the Nuclear Energy Act has been granted for any nu- clear materials subject to an import licence.

The import and possession of any nuclear materials, machines, equipment and data on site at the facility complies with the provisions of the Nuclear Energy Act and Nuclear Energy Decree.

Fortum proposes that once the energy production has come to an end, the updated plan for the decom- missioning of the buildings and operations necessary for the management of nuclear fuel and nuclear waste be submitted for the approval of the Ministry of Economic Affairs and Employment in connection with the periodic safety review referred to in section 7 e of the Nuclear Energy Act, i.e., at least every 10 years.

According to section 7 g, subsection 2, a licence applicant and a licence holder must have a plan for the decommissioning of a nuclear facility. Unless otherwise mentioned in the terms of the licence, the licence holder must also, during the operation pursuant to the operating licence, regularly, at least every six years, present an updated plan for the decommissioning of the nuclear facility for the approv- al of the Ministry of Economic Affairs and Employment. This application proposes that once energy production has ended, the decommissioning plan referred to in the Nuclear Energy Act be updated in connection with the periodic safety review of the plant parts that have been made independent, i.e., at least every 10 years, in accordance with section 7 e of the Nuclear Energy Act. In line with this application, energy production at Loviisa nuclear power plant would end no later than in 2050. As de- scribed in section 3.3 of the application, plant parts of the power plant will be made independent once the energy production has ended. The applicant considers the updating of the decommissioning plan in terms of these plant parts to be made independent at least every six years to be inexpedient, given that the plant parts and operations to be made independent are fairly limited in relation to the power plant. It is the applicant’s opinion that the decommissioning plan could be updated in connection with the periodic safety review of the plant parts to be made independent, which is prepared every 10 years, in accordance with section 7 e of the Nuclear Energy Act. This updating interval would guarantee that the decommissioning plan is up to date.

5 CONDITIONS FOR THE GRANTING OF A LICENCE (SECTION 20 OF THE NUCLEAR ENERGY ACT)

The conditions for granting an operating licence to Loviisa nuclear power plant are presented below.

5.1 THE OPERATION OF LOVIISA NUCLEAR POWER PLANT IS SAFE Appendix 5 contains a general description of the technical solutions, principles of operation and other arrangements ensuring safety. A report on the safety principles complied with and an assessment on the realisation of the principles are provided in Appendix 6 to the application.

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In Finland, the nuclear energy industry falls within the remit of the Ministry of Economic Affairs and Employment (hereinafter the MEAE). The Radiation and Nuclear Safety Authority (hereinafter STUK) functions as the regulatory control authority for the use of nuclear energy. STUK’s monitoring activities are based on radiation and nuclear safety legislation, regulations and procedures. The applicant’s op- erations meet the requirements of the national authorities. The applicant’s operations also account for international recommendations and rules as applicable. In addition, the applicant is involved in inter- national activities and peer reviews, and any improvement suggestions brought up in their context are taken into account in the applicant’s operations. The applicant also actively follows the events of other nuclear power plants and takes their best practices and knowledge into consideration in its operations.

The professional skills of the applicant’s personnel play an important role in the safe operation of Loviisa nuclear power plant. The applicant provides its personnel and contractors with training focused particularly on the nuclear power plant’s special characteristics, operating methods, safety culture and technology. Appendix 8 contains a review of the expertise at the applicant’s disposal and the nuclear facility’s operating organisation.

In accordance with the applicant’s safety and quality policy, the plant’s operations are based on a first-rate safety culture and quality as well as continuous improvement. Several projects aiming to improve nuclear safety have been implemented at Loviisa nuclear power plant throughout its opera- tion. In recent years, extensive renewals have been carried out on the automation of the power plant, and ageing systems and equipment have been modernised. In 2014–2018, Loviisa power plant imple- mented the most extensive modernisation programme in the plant’s history, in which Fortum invested approximately EUR 500 million. Loviisa nuclear power plant is now considerably safer than when it was originally commissioned, although it already complied with the requirements valid at the time.

In accordance with a good safety culture, the licence applicant is committed to the continuous im- provement of the nuclear power plant’s safety until the end of the plant’s operation. The periodic safety review, which is an extensive self-assessment concerning the organisation and the plant’s technology, is an important aspect of continuous improvement. Its content is determined in accordance with applicable international and national recommendations and practices as well as the regulations and requirements issued by STUK. Fortum conducts the safety reviews of the power plant units Loviisa 1 and Loviisa 2 and the final disposal facility in accordance with the valid legislation4 applicable to nuclear safety.

Loviisa power plant’s ageing management has been paid attention to throughout its operation. Well-managed and professional ageing management and maintenance are prerequisites for ensuring the safe, reliable and profitable operation of a nuclear power plant. The ageing management pro- gramme and procedures cover Loviisa power plant in its entirety.

Loviisa nuclear power plant’s extended operation in energy production no longer than until the end of 2050 is safe. Extending the use of buildings and storages necessary for the management of nuclear fuel and nuclear waste at Loviisa nuclear power plant until the end of 2090 is safe.

4 Section 7 e of the Nuclear Energy Act (990/1987).

5.2 ENVIRONMENTAL IMPACT AND CONSIDERATION OF THE SAFETY OF EMPLOYEES AND GENERAL POPULATION IN THE NUCLEAR POWER PLANT’S OPERATION

The environmental impact of Loviisa nuclear power plant’s extended operation and decommissioning was assessed in 2020–2021 in accordance with the Act on the Environmental Impact Assessment Pro- cedure (252/2017). The Environmental Impact Assessment Report (EIA Report) was inspected by the MEAE, as the coordinating authority. In its reasoned conclusion, the MEAE stated as follows:

The assessment report is extensive and diligently prepared. A sufficient number of options for the project are presented. No factors which cannot be mitigated to an acceptable level, or which would prevent the realisation of an option, emerged in the environmental impact assessment.

The EIA Report can be found in Appendix 13 to this application. The reasoned conclusion given by the MEAE is Appendix 15 to the application and the consideration of the reasoned conclusion in the oper- ations of Loviisa nuclear power plant and final disposal facility are reviewed in Appendix 16.

Option VE1 assessed in the EIA Report involves the direct and indirect impact of the extended op- eration of Loviisa nuclear power plant, this impact affecting:

• the population as well as the health, living conditions and comfort of people; • soil, ground, water, air, climate, vegetation as well as organisms and biodiversity, especially

protected species and habitats; • community structure, tangible property, landscape, townscape and cultural heritage; • use of natural resources; and • the mutual interaction between the aforementioned factors.

In accordance with the recommendations of the National Nuclear Waste Management Cooperation Group set up by the MEAE, the application for an operating licence covers a preparedness for the re- ception, handling, interim storage and final disposal, in the Loviisa power plant area, of small amounts of radioactive waste generated elsewhere in Finland.

Loviisa nuclear power plant’s environmental impact is minor in light of the operations’ significance. As a reliable energy source free of carbon dioxide emissions and independent of weather conditions, nuclear power contributes to meeting today’s energy requirements and mitigating climate change. The extended operation of Loviisa nuclear power plant would support the security of supply of Finland’s energy system and reduce the need to import electricity as its consumption grows in the future. The most significant environmental impact is caused by the thermal load that the power plant’s cooling water discharges has on the sea. The impact of the thermal load is nevertheless highly local and limited primarily to the area of Hästholmsfjärden.

Loviisa nuclear power plant has been producing clean electricity for more than 40 years, and the applicant has a long track record as a responsible producer of nuclear power. The applicant operates in accordance with the terms of the licence, continuously aiming to reduce the operations’ impact on the environment by using the best practices and technologies insofar as possible. The operations of Loviisa power plant have been certified to the ISO 14001 Environmental Management Standard.

The emissions of Loviisa nuclear power plant’s radioactive substances into the environment are monitored with continuously operating measuring instruments and sampling. Fortum monitors the en- vironment of Loviisa power plant in accordance with the environmental radiation control programme. The status of radioactive substances in the surroundings of Loviisa power plant has been monitored for a long time. The baseline studies began as early as 1966, before the construction of the power plant began. Loviisa power plant’s radioactive emissions into the environment have amounted to a fraction of the limits set for them. The emissions’ impact on the people in the vicinity and the surrounding environment is minimal. The emissions of Loviisa power plant are reported to STUK quarterly. The independent control carried out by STUK supplements the control carried out by the power plant.

The calculated radiation dose caused by Loviisa nuclear power plant to residents in the surrounding area has been clearly less than a per cent of the dose constraint set in the Nuclear Energy Decree, which is 0.1 mSv a year. The dose constraint is approximately one sixtieth of the average annual radi- ation dose of a person residing in Finland (5.9 mSv)5. In 2010–2019, the calculated radiation dose at Loviisa nuclear power plant has been 0.00014–0.00029 mSv a year.

5 Siiskonen Teemu (ed.). Suomalaisten keskimääräinen efektiivinen annos vuonna 2018. STUK-A263. Helsinki 2020, p. 48.

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The safety of employees working at Loviisa power plant is accounted for in the appropriate manner and occupational safety is considered in all operations. Radiation safety and control is described in Appendix 5 to the application. The radiation doses of the people working at Loviisa nuclear power plant remain significantly below the dose limits for employees.

The emissions of radioactive substances and radiation exposure are assessed in the EIA Report found in Appendix 13. A report on the measures aiming to limit the nuclear power plant’s environmental stress is in Appendix 7 to the application.

Extending the operation of Loviisa power plant until the end of 2050 will be safe for the environment and the population. Extending the use of buildings and storages necessary for the management of nuclear fuel and nuclear waste at Loviisa nuclear power plant until the end of 2090 is safe for the environment and the population.

5.3 THE MANAGEMENT OF THE NUCLEAR WASTE OF THE LOVIISA 1 AND LOVIISA 2 PLANT UNITS IS TAKEN CARE OF IN THE APPROPRIATE MANNER

The operation of a nuclear power plant generates both radioactive nuclear waste and conventional (non-radioactive) waste. The starting point in nuclear waste management is that the waste is isolated from humans and organic nature for as long as necessary, accounting for the radioactivity of the waste.

In addition, the decommissioning of the nuclear power plant generates decommissioning waste and other dismantling waste. The plan pertaining to the power plant’s decommissioning is updated and submitted to the authorities at six-year intervals. The last time Fortum updated the plan in terms of Loviisa power plant was in 2018. The EIA Report also covers any decommissioning occurring after ener- gy production extending until 2050. This application proposes that once energy production has ended, the decommissioning plan referred to in the Nuclear Energy Act be updated in connection with the periodic safety review of the plant parts that have been made independent, i.e., at least every 10 years.

The most central buildings and functions related to nuclear waste management at Loviisa nuclear power plant are the final disposal facility for low- and intermediate-level waste, the interim storages for spent nuclear fuel, the liquid waste storage and solidification plant, as well as the facilities for storing and handling dry waste. All radioactive waste, excluding spent nuclear fuel, is meant to be deposited in the final disposal facility.

The final disposal of nuclear waste in the bedrock is based on multiple release barriers, which effec- tively limit the migration of radioactive substances from the final disposal halls, thereby ensuring a min- imal impact on people and organic nature. The bedrock itself is one of the release barriers. Engineered release barriers include the waste matrix that binds the radioactive substances, the

waste container, the buffer surrounding the waste container, the backfilling of the final disposal halls and the closing structures of the disposal facility. The final disposal of nuclear waste is planned and implemented in a way that does not require continuous supervision of the final disposal location to ensure long-term safety. According to international and Finnish surveys, the necessary nuclear waste management measures can be implemented in a controlled and safe manner.

Nuclear fuel becomes highly radioactive in the reactor during operation. In Finland, spent fuel is not processed further; instead, it is highly radioactive nuclear waste that requires final disposal.

At Loviisa power plant, spent nuclear fuel removed from the reactor is typically stored underwater in the spent fuel pool of the reactor building for 1–3 years, which allows its reactivity and heat production to decrease considerably. The spent fuel is then transferred to the power plant’s interim storage for spent nuclear fuel, where it is stored in pools of water. Water acts as a radiation shield and cools the spent fuel. During the storage, the activity and heat production of the spent fuel will continue to drop.

Once final disposal becomes topical, the spent fuel is transported in special containers from the interim storage to Posiva’s encapsulation and final disposal facility under construction in Olkiluoto,

Eurajoki. Posiva submitted an application for the operating licence of an encapsulation and final dis- posal facility for spent nuclear fuel to the Government on 30 December 2021. Posiva is tasked with the transportation, encapsulation and final disposal of the spent nuclear fuel of the companies which own it. Fortum has a 40% stake in Posiva. The remaining 60% of Posiva is owned by Teollisuuden Voima Oyj, which is the owner and operator of the Olkiluoto nuclear power plant.

The transport from Loviisa to Olkiluoto can take place either by road or as a combination of road-mari- time-road transport. The transport of spent nuclear fuel is strictly regulated by national and international regulations and agreements. In Finland, the transport of spent nuclear fuel requires a permit from STUK.

At the Posiva encapsulation plant, spent fuel is packed and sealed in final disposal capsules, after which it is moved to the final disposal facility for spent nuclear fuel, located underground at a depth of approximately 420 metres. According to current plans, the final disposal of Loviisa power plant’s spent nuclear fuel in Posiva’s encapsulation and final disposal facility would begin in the 2040s.

Appendices 4 and 9 to the application contain further information on the operational waste as well as the applicant’s plans for arranging nuclear waste management and the methods available for it, including the dismantling of the nuclear facility and the final disposal of nuclear waste, and an account of the schedule and estimated costs of the nuclear waste management.

The applicant is responsible for the safe storage and final disposal of different types of nuclear waste.

5.4 FORTUM HAS THE NECESSARY EXPERTISE AT ITS DISPOSAL AND ITS OPERATING ORGANISATION IS SUITABLE

Over the roughly 40 years of Loviisa power plant’s operation, the applicant’s personnel have accumu- lated considerable expertise in the use of nuclear power and plant modifications.

The applicant develops and trains its personnel continuously, thereby ensuring and maintaining the entire personnel’s competence at the level required by the tasks, in terms of knowledge, skills and attitudes. Personnel development is defined in the company’s strategy, and it must be first-rate, long- range, systematic and proactive in nature. The applicant’s personnel have an either direct or indirect impact on the safety of the nuclear facilities. Fortum provides its personnel and contractors with training focused particularly on the nuclear power plant’s special characteristics, operating methods, safety culture and technology.

Loviisa power plant has an extensive and suitable operating organisation, which covers several dif- ferent functions. In addition, Loviisa power plant can rely on the support functions of Fortum Group and the technical support of the Generation division.

Further details on the expertise at the applicant’s disposal and on the operating organisation of the power plant units Loviisa 1 and Loviisa 2can be found in Appendix 8 to the application. Appendix 8 also includes a more detailed description of the personnel’s competence management and training.

The applicant has sufficient expertise, and its operating organisation is suitable.

5.5 FORTUM POSSESSES THE FINANCIAL AND OTHER NECESSARY MEANS TO PURSUE THE OPERATIONS SAFELY

The applicant’s financial means for engaging in the operations are reviewed in Appendices 10 and 11 to the application. The other means necessary for pursuing the operations safely are presented in Appendices 5 and 6 to the application.

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The applicant has ensured that it has taken out the liability insurance for a nuclear facility required by the Nuclear Liability Act (484/1972) or another financial guarantee of equal coverage, the insured amount of which is EUR 1,200 million.

The applicant is not aware of any changes to the facility’s operation, legislation or international ob- ligations which would have a significant impact on the applicant’s means to operate the facility safely and in accordance with Finland’s obligations based on international conventions and agreements.

The applicant has sufficient financial and other means for Loviisa power plant’s safe ope- ration in accordance with legislation and Finland’s obligations based on international con- ventions and agreements.

6 SUMMARY AND ENFORCEMENT

Based on what is presented above and in the more detailed reports and reviews in the Appendices to the application, the applicant is of the opinion that the conditions for granting an operating licence referred to in section of the Nuclear Energy Act and the requirements provided in sections 5–7 of the Nuclear Energy Act – pertaining to the overall good of society, nuclear waste management and the safety of Loviisa power plant – have been met, and the operating licence sought by the applicant can be granted.

The applicant requests that the Government, when granting the licence, decides by virtue of section 122 of the Administrative Judicial Procedure Act (808/2019) that the decision be enforced regardless of a possible appeal, given that the decision’s enforcement should not be postponed due to the public interest.

Climate change and the transition to a low-carbon energy system make reliable and emission-free electricity production even more important than before. The consistent availability and stable price of electricity are also important for society. Loviisa nuclear power plant will continue to play a significant role as a stable base power free of carbon dioxide emissions, supporting steady electricity production alongside the varying production of hydro-, wind and solar power. Loviisa power plant plays an impor- tant role as a producer of steady and emission-free electricity, and it produces approximately 10% of the electricity used in Finland. Loviisa nuclear power plant has been producing clean electricity for more than 40 years, and Fortum has a long track record as a responsible producer of nuclear power. An extension to the service life will require a continued investment in the facility’s usability and safety – work which has been carried out successfully throughout Loviisa nuclear power plant’s history. The work is of a long-range nature and the planning of modifications to be carried out in the future must be started now.

It is in the public interest to dismantle the FiR 1 research reactor in Otaniemi, Espoo, and deposit the radioactive waste of the research reactor and the research laboratory for radioactive materials (Ota- kaari 3), which is set to be decommissioned, at Loviisa power plant. Any delay in the enforcement of the power plant’s and final disposal facility’s licence application would also cause a delay in the reception of the aforementioned waste, which should therefore be stored and possibly even deposited for final disposal somewhere else.

In accordance with section 20 a of the Nuclear Energy Act, the licence for the decommissioning of the nuclear facility must be applied for well in advance so that the authorities have adequate time to assess the application before the termination of the nuclear facility’s operating licence. Should the enforcement be delayed, Fortum would have to commence the preparatory measures for decommis- sioning and the application process pertaining to the decommissioning licence.

It is the applicant’s opinion that the granting of a new operating licence and its immediate enforcement would be in the interest of the overall good of society.

Espoo, March 18, 2022

Simon-Erik Ollus CEO, Fortum Power and Heat Oy

Sasu Valkamo Vice President, Loviisa Nuclear Power Plant

APPENDICES

Appendix 1. An extract from the Trade Register (separate appendix, not included in this hand-out version)

Appendix 2. A copy of the Articles of Association and register of shareholders (separate appendix, not included in this hand-out version)

Appendix 3. Report on the residential areas and other activities in the location of the nuclear power plant and its immediate surroundings and on land use planning.

Appendix 4. Report on the quality and maximum quantity of the nuclear materials or nuclear waste manufactured, produced, handled, used or stored at the nuclear power plant

Appendix 5. General description of the technical solutions, principles of operation and other arrangements ensuring safety

Appendix 6. Report on the safety principles complied with and an assessment on the realisation of the principles

Appendix 7. Report on the measures aiming to limit the nuclear power plant’s environmental stress Appendix 8. Review of the expertise at the applicant’s disposal and the nuclear facility’s

operating organisation Appendix 9. Review of the applicant’s plans for arranging nuclear waste management and

the methods available for it, including the dismantling of the nuclear facility and the final disposal of nuclear waste, and an account of the schedule and estimated costs of the nuclear waste management

Appendix 10. Review of the applicant’s financial position and the applicant’s financial management plan and production plan

Appendix 11. The applicant’s financial statements for the years 1996–2020 (separate appendix, not included in this hand-out version)

Appendix 12. Report on the applicant’s compliance with the valid terms of the operating licence Appendix 13. Loviisa nuclear power plant, EIA Report Appendix 14. Loviisa nuclear power plant’s EIA Report, International Hearing Document Appendix 15. Reasoned conclusion of the Ministry of Economic Affairs and Employment

concerning the environmental impact assessment report for Loviisa nuclear power plant

Appendix 16. Account of the consideration of the reasoned conclusion in the operations of Loviisa nuclear power plant and the final disposal facility

Appendices 1 through 12 are not available in English.

Käyttölupahakemus 1716 Käyttölupahakemus

Operating licence application | Appendix 16 1918 Operating licence | Appendix 16

Appendix 16 Consideration of the reasoned conclusion in the operations of Loviisa nuclear power plant and the final disposal facility

CONTENTS

APPENDIX 16: CONSIDERATION OF THE REASONED CONCLUSION IN THE OPERATIONS OF LOVIISA NUCLEAR POWER PLANT AND THE FINAL DISPOSAL FACILITY ....................... 18

1 INTRODUCTION ..............................................................................................................20 2 EIA REPORT’S ADEQUACY AND QUALITY .....................................................................20

2.1 Impact on surface waters ............................................................................................ 20

2.2 Impact on soil, bedrock and groundwater .................................................................. 21

2.3 Impact on climate ........................................................................................................... 21

2.4 Impacts of a severe reactor accident .......................................................................... 21

2.5 Other remarks made in the statements ..................................................................... 21

2.6 International hearing ......................................................................................................22

3 REASONED CONCLUSION BY THE COORDINATING AUTHORITY ............................... 22

3.1 Significant environmental impact of extended operation (VE1) .............................22

3.1.1 Surface waters .......................................................................................................22

3.1.2 Fish and fishing .....................................................................................................23

3.1.3 Greenhouse gas emissions and climate change .............................................23

3.1.4 People’s living conditions and comfort, community structure,

tangible property ...........................................................................................................23

3.1.5 Radioactive waste and its management ...........................................................23

3.1.6 Severe reactor accident, other incidents and accidents ................................23

3.2 Significant environmental impact of decommissioning (VE0, VE0+) .....................23

3.2.1 Surface waters ......................................................................................................23

3.2.2 Fish and fishing ....................................................................................................23

3.2.3 Greenhouse gas emissions and climate change .............................................23

3.2.4 People’s living conditions and comfort, community structure,

tangible property ...........................................................................................................23

3.2.5 Landscape and cultural environment ...............................................................24

3.2.6 Traffic ....................................................................................................................24

3.2.7 Noise ......................................................................................................................24

3.2.8 Radioactive waste and its management ..........................................................24

3.2.9 Severe reactor accident, other incidents and accidents ...............................24

3.3 Significant environmental impact of L/ILW repository’s expansion

(VE1, VE0, VE0+) .............................................................................................................24

3.3.1 Soil and bedrock ...................................................................................................24

3.3.2 Groundwater ........................................................................................................24

3.3.3 Noise ......................................................................................................................24

3.3.4 Use of natural resources ....................................................................................24

3.4 Other impacts .................................................................................................................25

4 SUMMARY ........................................................................................................................ 25

Operating licence application | Appendix 16 2120 Operating licence application | Appendix 16

1 INTRODUCTION This account is part of the operating licence applications of Loviisa power plant and final disposal facility for low- and in- termediate-level waste1.

In accordance with section 10 of the Act on the Environ- mental Impact Assessment Procedure (252/2017, hereinafter the EIA Act), Fortum Power and Heat Oy’s (hereinafter For- tum) coordinating authority in the project is the Ministry of Economic Affairs and Employment. Pursuant to section 23 of the EIA Act, the Ministry of Economic Affairs and Employment has reviewed the adequacy and quality of Fortum’s Environ- mental Impact Assessment Report (hereinafter EIA Report) and prepared its reasoned conclusion on the project’s signif- icant environmental impact.

In addition to the EIA Report in Appendix 13 to the appli- cation for the operating licence, the reasoned conclusion on the project given by the coordinating authority is appended to the application as Appendix 15, as required by section 25 of the EIA Act. Furthermore, the EIA Report’s International Hear- ing Document can be found in Appendix 14 of the application for the operating licence.

According to the provisions in section 26 of the EIA Act, the licence decision must indicate how the EIA Report, reasoned conclusion and any documents pertaining to an international hearing pursuant to section 29 have been considered.

The Ministry of Economic Affairs and Employment gave its reasoned conclusion on the project on 10 January 2022. In its reasoned conclusion on the project, the Ministry of Economic Affairs and Employment states, among other things, that the project options reviewed do not have any significant harmful environmental impact which would be unacceptable, or which could not be prevented or mitigated to an acceptable level.

According to the reasoned conclusion of the Ministry of Economic Affairs and Employment, the comparison of the different options has been carried out in a sufficient manner in the EIA Report.

Based on the requirements of the EIA Act referred to above and the remarks made in the reasoned conclusion of the Min- istry of Economic Affairs and Employment, Fortum addresses, in the following, how the matters and needs for further investi- gations raised in the coordinating authority’s reasoned conclu- sion and in the statements of the other parties are accounted for, if necessary, in the application for the operating licence. In addition, the focus lies on how the matters and investigative needs mentioned in the reasoned conclusion and statements are or will be accounted for in the applicant’s operations insofar as the matters, according to Fortum’s own view, pertain to the operating licence application and operating licence now under discussion. Given that decommissioning is not yet topical, the matters and needs for further investigations related to the de- commissioning are discussed in general terms alone. The de- commissioning will be planned in detail, and the matters raised in the reasoned conclusion and statements will be accounted for as necessary as part of its planning.

1 The final disposal facility for low- and intermediate-level waste is also referred to as the L/ILW repository.

2 EIA REPORT’S ADEQUACY AND QUALITY

In its reasoned conclusion concerning the project, the Minis- try of Economic Affairs and Employment states that Fortum’s EIA Report on Loviisa nuclear power plant meets the content requirements provided for in section 19 of the EIA Act and in the EIA Decree (277/2017), and that it is dealt with as required by the EIA legislation. The EIA Report was prepared in con- sideration of the project’s assessment programme and the statement on it provided by the coordinating authority. The project owner has had sufficient expertise at its disposal for the execution of the environmental impact assessment and the separate reports and reviews.

The Ministry of Economic Affairs and Employment further- more notes that the EIA Report is extensive and diligently prepared. A sufficient number of options for the project are presented. No factors which cannot be mitigated to an ac- ceptable level, or which would prevent the realisation of an option, emerged in the environmental impact assessment.

However, the Ministry of Economic Affairs and Employment took the view that, based on the review as well as statements and opinions received, the assessment could be specified in some respects.

This section discusses in more detail the matters ad- dressed in chapter 3 of the reasoned conclusion given by the Ministry of Economic Affairs and Employment. The headings used below are the same as those used in chapter 3 of the said reasoned conclusion. In addition, Fortum deals with the international hearing under heading 2.6.

2.1 IMPACT ON SURFACE WATERS In the reasoned conclusion, the Ministry of Economic Affairs and Employment states that the impact assessment concern- ing the surface waters and the discussion of the mitigation measures are at a sufficient level at this stage of the project’s planning, but that they must be specified in the future.

Fortum continues its investigations aiming to supply the power plant with cooler cooling water and mitigate the im- pact of the cooling water, and to gain a deeper understand- ing of the factors affecting the state of the nearby sea ar- ea. These efforts are currently carried out as a research and development programme of Fortum, and there are no plans aiming for the implementation of water engineering works.

Fortum contributes to the achievement of the objectives related to water resources management and may take part in the planning of measures improving the state of the wa- terway in cooperation with the Uusimaa Centre for Economic Development, Transport and the Environment (hereinafter the Uusimaa ELY Centre) and the town of Loviisa.

The manner in which the impact of the power plant’s cool- ing water is accounted for in the operations is discussed be- low, in section 3.1.1 .

2.2 IMPACT ON SOIL, BEDROCK AND GROUNDWATER

The statements draw attention to Loviisa’s final disposal fa- cility for low- and intermediate-level waste and particularly its planned expansion as well as its impact on the soil, bedrock and groundwater. Attention is also paid to the monitoring pro- gramme which is to be carried out to prove the effectiveness of the release barriers.

The planned expansions of the final d isposal f acility are located in the immediate vicinity of the existing bedrock spaces. Individual rock fissures are likely to be cut during the excavating, in which case they will be injected in accordance

with the methodologies of normal rock engineering if neces- sary, as has been done during the earlier construction phases.

The positioning of the expansion spaces will be ensured during detailed engineering prior to the excavating, the

aim being to avoid positioning the spaces too close to any signi-ficant water-conductive structures. Among other measures, the positioning will be ensured prior to the actual excavation by drilling a pilot trial hole.

The understanding of the bedrock surrounding the final disposal facility and its groundwater conditions is based on studies commenced prior to the construction of the final dis- posal facility, the monitoring programmes (rock mechanics, hydrology and groundwater chemistry) to be implemented during its usage phase and the modelling supporting them. This understanding is compiled into the regularly updated long-term safety case. Its preparation includes an assess- ment of the quality of the baseline data used in the ground- water flow calculations and further studies, if necessary.

The monitoring programmes were reviewed in the final disposal facility’s periodic safety review drawn up in 2020, in which they were deemed sufficiently extensive and compre- hensive. Their extent and comprehensiveness are reviewed when necessary, such as before the excavating

work related to the expansion of the final disposal facility begins, as is also mentioned in the EIA Report.

The Radiation and Nuclear Safety Authority (hereinafter STUK) also assesses the extent and implementation of the monitoring programmes as part of its continuous supervi- sion. The measurement of the boundary level between fresh and saline water, mentioned in one of the statements, has been found problematic in terms of its interpretation and discontinued, given that the said boundary level’s position in the open hole does not describe the groundwater’s salin- ity in the rock. Instead, it depends solely on the division of the pressure height and the hydraulic properties of the most water-conductive fissures/structures’ points intersecting the hole. STUK had no comments on the extent of the hydrolog- ical monitoring in its inspection of the final disposal facility’s periodic safety review.

2.3 IMPACT ON CLIMATE Fortum agrees with the view of the Ministry of Economic Affairs and Employment according to which the impact of the produced electricity’s greenhouse gas emission-free nature is much great- er in significance than the project’s direct climate impact.

Extending operation will have a significant effect on the achievement of the national targets for emission reductions and thereby on combating climate change.

2.4 IMPACTS OF A SEVERE REACTOR ACCIDENT Many statements commented on the selected source term. The selected source term was 100 TBq of the caesium isotope 137 and the emissions of other substances had been scaled to correspond to it. As is noted by the Ministry of Economic Affairs and Employment in its reasoned conclusion, in Finland, section 22 b of the Nuclear Energy Decree sets 100 TBq of caesium-137 as the limit value for a high emission, and this value is generally used as the source term in Finnish environ- mental impact assessments.

With regard to mitigating the impact of a severe reactor accident, Estonia’s environmental administration commented on the responsible parties.

In this respect, Fortum points out that STUK is responsible for the communications, both nationally and internationally. The mitigation measures to be conducted abroad will be de- cided on and carried out by local parties.

2.5 OTHER REMARKS MADE IN THE STATEMENTS

The statements expressed that research related to climate change should be monitored in the future and that the accu- mulated data should be used to improve the facility’s safety in accordance with the EIA Report.

Fortum follows climate change-related research through the Finnish Research Programme on Nuclear Power Plant Safety (SAFIR), for example, and takes into account the accumulated da- ta in assessing and, if necessary, improving the facility’s safety.

Regarding chemicals, the statements pointed out that nei- ther the chemicals discharged into the sea nor their impact was discussed in the report.

Fortum refers to the EIA Report, in which it is stated that the annually used quantities of chemicals will remain unchanged if operation is extended. In respect of waters conducted into the sea, the company also complies with the limit values set in the conditions of the environmental permit and in legislation. No effects caused by chemicals have been detected in the impact monitoring focused on Loviisa power plant’s nearby sea area.

The statements also note that the consultants who had prepared the EIA Report lacked competence on the impact of radioactive substances.

Fortum is an expert on radiation safety and on assessing the impact of radioactive substances in terms of its opera- tions. Fortum also points out that the impact monitoring con- cerning radioactive substances ending up in the environment is carried out in accordance with an observation programme approved by the authorities. Based on the results of the emis- sion monitoring, the radioactive emissions into the environ- ment have remained considerably below the limits set for the emissions of a nuclear power plant. The results of the impact monitoring show that the quantities of radioactive substanc- es in the surroundings of the power plant are low.

Operating licence application | Appendix 16 2322 Operating licence application | Appendix 16

The power plant’s ageing and the attendant increase in risks was a cause for concern among several of the parties providing statements.

Fortum underscores that the ageing management of Lovii- sa power plant has been accounted for throughout the power plant’s operation. Appropriately executed ageing management and maintenance are prerequisites for ensuring the safe, relia- ble and profitable operation of a nuclear power plant. STUK will assess the safety of the project in connection with the safety review related to application for an operating licence.

In respect of the power plant’s decommissioning and the expansion of the final disposal facility, the statements drew attention to, among other things, the possible contamination of the land areas of the power plant location and mentioned that special attention should be paid to the prevention of noise and dust nuisance during future planning and the li- cence and permit processes.

Fortum notes that the dismantling of Loviisa power plant is not yet topical. Fortum is unaware of any contaminated soil or land areas within the area. The appropriate studies, aim- ing to detect any contaminated soil, will be conducted well in advance of the start of the construction and dismantling work. If any contaminated soil or land areas are detected, the matter will be reported to the authorities and the areas will be rehabilitated in accordance with the requirements of the applicable legislation.

Fortum aims to mitigate the noise nuisance in terms of both the expansion of the final disposal facility and the pow- er plant’s decommissioning with various measures, such as scheduling the noisiest work appropriately and the selection of the location where the concrete is crushed. Fortum will also pay attention to dust management methods when planning the dismantling.

2.6 INTERNATIONAL HEARING In the international hearing, statements were made by the authorities of Austria, Lithuania, Sweden and Estonia. In addi- tion, the Ministry of the Environment received 12 statements from European citizens and organisations.

The statements primarily objected to the use of nuclear energy based on the risk of accidents and concern about the safety of spent nuclear fuel.

Should operation be extended, the work to improve safe- ty will be continued. STUK will assess the project’s safety in connection with the application for an operating licence. It is Fortum’s view that the issues related to safety are discussed to a sufficient extent in the EIA Report.

Some of the statements included a wish that the presenta- tions made in the public event be translated into English or that another event be held for an international audience. The statements invoked the Espoo Convention and the Aarhus Convention.

The Ministry of Economic Affairs and Employment address- es in its reasoned conclusion the realisation of the process related to the international hearing in Loviisa power plant’s EIA procedure. Fortum agrees with the ministry’s view and points out that the international hearing is implemented in

accordance with both the Espoo and Aarhus Conventions and in compliance with the provisions of the EIA legislation.

Furthermore, the question pertaining to transboundary im- pacts posed in the international hearing is addressed in section 2.4 above and the questions pertaining to the power plant’s ageing made in the hearing are addressed in section 2.5.

3 REASONED CONCLUSION BY THE COORDINATING

AUTHORITY This section discusses in more detail the project’s most sig- nificant environmental impacts in terms of extended opera- tion, decommissioning and the expansion of the final disposal facility, addressed in chapter 4 of the reasoned conclusion of the Ministry of Economic Affairs and Employment The head- ings used below are the same as those used in chapter 4 of the said reasoned conclusion.

3.1 SIGNIFICANT ENVIRONMENTAL IMPACT OF EXTENDED OPERATION (VE1)

3.1.1 Surface waters

In its reasoned conclusion concerning Loviisa power plant, the Ministry of Economic Affairs and Employment requires the impact of the power plant’s cooling water to be consid- ered in the operations.

Fortum points out that Loviisa power plant has valid envi- ronmental and water permits which include specifications on the volume and temperature of the cooling water, among oth- er things. The operations comply with the permit regulations and the results of the related monitoring are reported to the authorities regularly.

The EIA Report includes an assessment on the operations’ impact on the nearby sea area and presents potential meas- ures for mitigating any harmful effects.

As part of the option of extended operation, Loviisa power plant’s EIA Programme investigated the possibility of car- rying out water engineering projects in the area, in front of the cooling water intake and the nearby sea area. Based on the preliminary investigations, it can be assumed that by de- creasing the temperature of the abstracted cooling water, it would be possible to reduce the temperature of the dis- charged cooling water, although this would not affect the thermal load being conducted to the sea in any material way. Based on the techno-economic investigations carried out, the water engineering projects were nevertheless removed from the environmental impact assessment procedure. The mat- ter will continue to be studied, separate from the EIA Report, in Fortum’s research project, which aims to find the most cost-effective technical solutions for reducing the tempera- ture of the abstracted cooling water with the help of model- ling. However, there are no plans aiming for the execution of water engineering work.

In terms of the Klobbfjärden body of water, the reduction of the diffuse source input, a significant portion of which is de- rived from the river Tesjoki, plays a key role. The most effec- tive measures include the agricultural measures to be carried out in the river’s catchment area, such as the application of gypsum in agricultural fields.

For its part, Fortum supports the achievement of the tar- gets set for the state of the bodies of water in legislation. Fortum may take part in the planning of measures aiming to improve the state of the waterway in cooperation with the Uusimaa ELY Centre and the town of Loviisa. Over a longer term, Fortum aims to further deepen its knowledge of Loviisa power plant’s impact on the state of the Klobbfjärden body of water. The reports may be related to the state of the benthic fauna and sediment of the nearby sea area, for example, so that the background material of the classification would be sufficient and representative.

3.1.2 Fish and fishing

The power plant has an impact on the icthyofauna and fishing. The reasoned conclusion does not include remarks concern- ing the icthyofauna or fishing which would require Fortum to undertake any measures beyond those assessed and dis- cussed in Fortum’s EIA Report.

Loviisa power plant has valid environmental and water per- mits which include specifications on the volume and temper- ature of the cooling water. Fortum also pays an annual fish- eries charge pursuant to the permit regulation which is used for mitigating any harmful effects of the cooling water in its impact area.

3.1.3 Greenhouse gas emissions and climate change

The power plant’s operations have a significant positive cli- mate impact. The reasoned conclusion does not include re- marks concerning greenhouse gas emissions or climate change which would require Fortum to undertake any measures be- yond those assessed and discussed in Fortum’s EIA Report.

3.1.4 People’s living conditions and comfort, community structure, tangible property

The operations of Loviisa power plant have an impact on peo- ple’s living conditions and comfort. The reasoned conclusion does not include remarks concerning people’s living condi- tions and comfort, community structure or tangible property which would require Fortum to undertake any measures be- yond those assessed and discussed in Fortum’s EIA Report.

3.1.5 Radioactive waste and its management

The power plant’s extended operation would increase the to- tal volume of the accumulation of spent nuclear fuel as well as low- and intermediate-level waste. The reasoned conclu- sion does not include remarks concerning the accumulation of spent nuclear fuel or low- and intermediate-level waste

which would require Fortum to undertake any measures be- yond those assessed and discussed in Fortum’s EIA Report.

3.1.6 Severe reactor accident, other incidents and accidents

Fortum addresses the possibility of a severe reactor accident as well as other incidents and accidents in section 2.4 above and the reasoned conclusion does not include any remarks concerning them which would require Fortum to undertake measures beyond those assessed and discussed in Fortum’s EIA Report.

3.2 SIGNIFICANT ENVIRONMENTAL IMPACT OF DECOMMISSIONING (VE0, VE0+)

3.2.1 Surface waters

The thermal load caused by the cooling water will end with the decommissioning and the reasoned conclusion does not include comments on the planning of the decommissioning and Fortum’s operations in terms of the surface waters.

Fortum points out that in the future too, what will play a key role in terms of the state of the Klobbfjärden body of water is the reduction of the diffuse source input, a significant portion of which derives from the river Tesjoki.

3.2.2 Fish and fishing

The thermal load caused by the cooling water which has an impact on the icthyofauna will come to an end once the power plant is decommissioned. The reasoned conclusion does not include remarks related to the icthyofauna or fishing which would require Fortum to undertake any measures.

With decommissioning, the area’s icthyofana and fishing opportunities may return to a state similar to that prevailing in the surrounding sea areas.

3.2.3 Greenhouse gas emissions and climate change

The climate impact of the decommissioning following the cur- rent operating period is expected to be reasonably negative. The reasoned conclusion does not include remarks related to greenhouse gas emissions or climate change which would re- quire Fortum to undertake any further measures.

3.2.4 People’s living conditions and comfort, community structure, tangible property

The decommissioning of Loviisa power plant will have an im- pact on people’s living conditions and comfort and on the energy market, security of supply and the regional economy. The reasoned conclusion does not include remarks concern- ing these issues which would require Fortum to undertake any measures beyond those assessed and discussed in Fortum’s EIA Report.

Operating licence application | Appendix 16 2524 Operating licence application | Appendix 16

3.2.5 Landscape and cultural environment The decommissioning of Loviisa power plant will have an im- pact on the landscape and cultural environment.

Prior to the dismantling of the buildings, Fortum will com- mission a report on the architectural history of the area’s building stock.

3.2.6 Traffic

The decommissioning of Loviisa power plant will have an impact on traffic. The reasoned conclusion does not include remarks concerning traffic which would require Fortum to un- dertake any measures beyond those assessed and discussed in Fortum’s EIA Report.

3.2.7 Noise

The dismantling measures will cause noise during the decom- missioning phase.

Fortum aims to mitigate the noise nuisance with various measures, such as by scheduling the noisiest work appropri- ately and by the selection of the location where the concrete is crushed.

3.2.8 Radioactive waste and its management

The power plant’s dismantling will generate considerable amounts of radioactive waste. The final disposal of the radi- oactive waste will require a significant expansion of the final disposal facility. The reasoned conclusion does not include re- marks concerning the radioactive waste and its management which would require Fortum to undertake any measures other than those assessed and discussed in Fortum’s EIA Report.

Contaminated soil and conventional waste

Regarding the contamination of soil, the Ministry of Economic Affairs and Employment notes that the contamination must be assessed in connection with the dismantling and that the appropriate handling of conventional waste must be ensured.

Fortum addresses the matter in section 2.5 above.

3.2.9 Severe reactor accident, other incidents and accidents

The nuclear power plant’s risk level will decline considerably when it is decommissioned. The reasoned conclusion does not include remarks concerning a severe reactor accident or other incidents which would require Fortum to undertake any measures other than those discussed and assessed in For- tum’s EIA Report.

3.3 SIGNIFICANT ENVIRONMENTAL IMPACT OF L/ILW REPOSITORY’S EXPANSION (VE1, VE0, VE0+)

3.3.1 Soil and bedrock

The expansion of the final disposal facility will result in signif- icant changes to the bedrock as more rock spaces are quar- ried. This is discussed in section 2.2 above. The reasoned con- clusion does not include any remarks that would give reason for changing the current plans. The expansion will be planned in more detail closer to its implementation.

3.3.2 Groundwater

The expansion of the final disposal facility will result in chang- es to the groundwater flow conditions as more rock spaces are quarried. In addition to the EIA Report, this is discussed in section 2.2 above. Section 2.2 also describes some of the questions made about the monitoring programmes in the statement in more detail than the EIA Report does.

While the reasoned conclusion does not include any re- marks that would give reason for changing the current plans, both the extent of the monitoring programmes and the im- pact that the excavation of the expansion spaces will have

will be assessed in more detail closer to the implementation of the expansion.

3.3.3 Noise

The reasoned conclusion draws attention to the noise that will be caused by the excavation, crushing and transports

during the expansion of the final disposal facility. Fortum considers the possible noise nuisance and aims to

mitigate them by a variety of means. The detailed planning of the final disposal facility’s expansion will account for the use of the quarry material and the noise resulting from its crush- ing. The construction work will be planned and carried out in such a way that the noise nuisance will be mitigated to the extent possible.

3.3.4 Use of natural resources

The reasoned conclusion draws attention to the use of the quarry material generated during the expansion of the final disposal facility.

The EIA Report reviews several alternative further uses for the quarry material generated in the expansion of the final disposal facility. The reasoned conclusion does not include remarks concerning the use of natural resources which would require Fortum to undertake any measures other than those assessed and discussed in Fortum’s EIA Report.

3.4 OTHER IMPACTS

The significance of any other impacts is expected to be minor at most.

The reasoned conclusion does not include remarks con- cerning other impacts which would require Fortum to under- take any mitigating measures other than those assessed and discussed in Fortum’s EIA Report.

4 SUMMARY

In its reasoned conclusion concerning Fortum’s project, the Ministry of Economic Affairs and Employment states that the project options reviewed in Fortum’s EIA Report do not have any significant harmful environmental impact which would be unacceptable, or which could not be prevented or mitigated to an acceptable level. The comparisons between the various options have been implemented in a sufficient manner. The project’s assessment programme and the statement given on it by the coordinating authority has been considered in the preparation of the EIA Report, and the EIA Report is exten- sive and diligently prepared. It is the opinion of the Ministry of Economic Affairs and Employment that the project owner has had sufficient expertise at its disposal for the execution of the environmental impact assessment and the separate reports and reviews. The Ministry of Economic Affairs and Employment therefore considers Fortum’s EIA Report to fulfil the content requirements provided in section 19 of the EIA Act and in the EIA Decree and to have been prepared in ac- cordance with the EIA legislation.

In the above, Fortum explains how the matters and needs for investigation raised in the reasoned conclusion of the Ministry of Economic Affairs and Employment and in the statements submitted by other parties are considered in the application for an operating licence, if necessary. In addition, the above discussed how the matters and investigative needs mentioned in the reasoned conclusion and statements are or will be ac- counted for in the applicant’s operations insofar as the mat- ters pertain to the operating licence application and operating licence now under discussion. Considering the reasoned con- clusion of the Ministry of Economic Affairs and Employment and the matters discussed by Fortum above, Fortum is of the opinion that the reasoned conclusion and its processing within the operating licence application meet the requirements of the Nuclear Energy Act and the EIA legislation.

Käyttölupahakemus 2928 Käyttölupahakemus

30 Käyttölupahakemus

Käyttölupahakemus 1

Operating licence application FINAL DISPOSAL FACILITY

Loviisa nuclear power plant

Käyttölupahakemus 32 Käyttölupahakemus

Contact Details

Fortum Power and Heat Oy Keilalahdentie 2-4, Espoo P.O.Box 100 FI-00048 FORTUM Tel. +358 10 4511 Y-0109160-2 fortum.fi

Base maps: National Land Survey of Finland 2021 Translations: AAC Global Oy Layout and design: Creative Peak Print: Print Mill

The original language of the operating licence application is Finnish. Versions in other languages are translations of the original document which is the document Fortum is committed to.

Operating licence application | Operating licence application for Loviisa’s final disposal facility for low- and intermediate-level waste 54 Operating licence application | Operating licence application for Loviisa’s final disposal facility for low- and intermediate-level waste

TO THE FINNISH GOVERNMENT Operating licence application for Loviisa’s final disposal facility for low- and intermediate-level waste

1 APPLICANT

The applicant is Fortum Power and Heat Oy (hereinafter Fortum), which has its registered office in Espoo and the business ID of which is 0109160-2. Fortum is the owner and operator of Loviisa nuclear power plant (hereinafter also “power plant”), located on the island of Hästholmen, in the town of Loviisa.

Further details about the applicant can be found in Appendices 1, 2, 8, 10 and 11 to the application.

2 APPLICATION

Loviisa’s final disposal facility for low- and intermediate-level waste

Fortum is applying for a licence pursuant to section 20 of the Nuclear Energy Act (990/1987) to operate a final disposal facility for low- and intermediate-level waste located in Loviisa’s existing power plant area1 until the end of 2090.

In relation to the aforementioned, Fortum is applying for a licence to possess, handle, store and deposit in the final disposal facility for low- and intermediate-level waste as follows:

• a maximum of 50,000 m3 in low- and intermediate-level waste generated in connection with or as a result of the operations of the nuclear facilities in Loviisa’s power plant area or radioactive waste with properties equal to such waste (operational waste2, decommissioning waste3, other radioactive waste in the plant site with a similar activity concentration, and a small quantity of decommissioned radiation sources);

• a maximum of 2,000 m3 in radioactive waste of the type mentioned above, and with equivalent properties, but generated elsewhere in Finland; and

• a maximum of 50,000 m3 in waste with a very low level of activity, generated in the dismantling of the buildings in the decommissioning of the nuclear power plant.

1 Power plant area refers, pursuant to section 2, subsection 1, paragraph 8 of Radiation and Nuclear Safety Authority Regulation Y/2/2018, to an area in use by nuclear power plant units and other nuclear facilities in the same area, and to the surrounding area, where movement and stay are restricted by the Decree of Ministry of the Interior issued under Chapter 9, section 8 of the Police Act (872/2011). 2 Operational waste refers to the low- and intermediate-level waste accumulated in the operation of a nuclear power plant. 3 Decommissioning waste refers to low- and intermediate-level waste accumulated in connection with the decommission- ing of the power plant or other nuclear facilities, such as the equipment and structures to be dismantled.

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3 SUBJECT OF APPLICATION

3.1 LOVIISA’S FINAL DISPOSAL FACILITY FOR LOW- AND INTERMEDIATE-LEVEL WASTE

Loviisa’s final disposal facility for low- and intermediate-level waste which is the subject of the applica- tion (hereinafter also “final disposal facility”) is a separate nuclear facility as referred to in the Nuclear Energy Act and Nuclear Energy Decree, but it is used in connection with Loviisa nuclear power plant and integrated into the power plant’s operations. Appendix 5 to the application contains a general description of the final disposal facility for low- and intermediate-level waste and of the technical principles of operation.

The radioactive waste generated during the operation of Loviisa power plant, excluding spent nu- clear fuel, is deposited for final disposal in the final disposal facility for low- and intermediate-level waste quarried for the purpose. The facility is located on the island of Hästholmen, at a depth of ap- proximately 110 metres.

The plan is also to excavate in the existing final disposal facility an extension for the decommission- ing waste of the Loviisa nuclear power plant. Hence the extended final disposal facility allows for final disposal of all the radioactive waste, excluding spent nuclear fuel, generated during the operation and decommissioning of the power plant and its parts to be made independent.

3.2 LOCATION The final disposal facility for Loviisa’s low- and intermediate level operational waste is located in Lovii- sa’s power plant area, on the island of Hästholmen, some 12 km from the centre of the town of Loviisa.

The halls of the final disposal facility have been quarried in the island’s bedrock to a depth of approx- imately 110 metres. The location was selected on the basis of field studies focused on the bedrock and hydrological conditions, with consideration for the power plant operations carried out on the island. The final disposal halls have been designed in such a way that any significant water-bearing fracture zones of the bedrock do not intersect with the final disposal halls. The halls of the final disposal facility are located on the island in such a way that no part of them is under the sea or the existing power plant units or any sites reserved for units. The final disposal facility was built on the island of Hästholmen in the 1990s. The first phase of construction was finished in 1997 and the final disposal facility was expanded in 2010–2012.

Appendix 3 to the application contains a report on the location of Loviisa nuclear power plant as well as on any residential areas and other activities in its immediate surroundings and land use planning.

3.3 INTENDED USE The final disposal facility is used for the final disposal of the low- and intermediate-level waste gener- ated in connection with or as a result of the operation of Loviisa power plant and its parts to be made independent or for the final disposal of radioactive waste with equivalent properties. In addition, small quantities (a maximum of 2,000 m3) of radioactive waste with properties similar to the aforementioned waste, but generated elsewhere in Finland, are meant to be deposited in the final disposal facility.

The reports on the quality and maximum quantity of the nuclear materials and nuclear waste pro- duced, handled, used or stored at Loviisa nuclear power plant are presented in Appendix 4 to the application.

3.4 PERIOD OF OPERATION

An operating licence is being sought for the final disposal facility for low- and intermediate-level waste until the end of 2090. In accordance with plans, the operation of the final disposal facility is expected to come to an end prior to this, no later than during the 2080s. The final disposal facility will be per- manently closed during the validity of the operating licence pursuant to this application once the radi- oactive waste from the decommissioning of Loviisa power plant has been deposited in final disposal.

3.5 CURRENTLY VALID OPERATING LICENCE AND PREVIOUS OPERATING LICENCES Government decision (Document no. 1/812/97) of 2 April 1998 granted a licence for the use of the final disposal facility for power plant waste located in the power plant area for the final disposal of the low- and intermediate-level waste generated in the operation of the Loviisa 1 and Loviisa 2 plant units and the storage of spent fuel and, as necessary, for the final disposal of small quantities of waste generated in operations other than the operation of Loviisa power plant until 31 December 2055.

4 GROUNDS FOR THE PROPOSED TERMS OF THE LICENCE

The application presents the licence applied for and a proposal on the new terms of the operating licence. Each licence term proposed in the operating licence is shown below in italics, followed by the grounds for it.

In relation to the aforementioned, Fortum is applying for a licence to possess, handle, store and deposit for final disposal low- and intermediate-level waste in the final disposal facility as follows:

– a maximum of 50,000 m3 in low- and intermediate-level waste generated in connection with or as a result of the operations of the nuclear facilities in Loviisa’s power plant area or radioactive waste with properties equal to such waste (operational waste, decommissioning waste, other radioactive waste in the plant site with a similar activity concentration, and a small quantity of decommissioned radiation sources);

Appendix 4 to the application includes an estimate of the volume of operational waste and decom- missioning waste to be deposited in final disposal. The waste volume of 50,000 m3 proposed in the application’s licence term is based on an estimate of the volume of the waste to be deposited in final disposal in the event that the power plant units operation ends in 2050. The licence term also includes a reasonable margin accounting for the waste volumes, the timespan of the operations and the related uncertainties. The objective is nevertheless to effectively limit the volume of the operational waste and decommissioning waste generated in connection with the operation and decommissioning of the nuclear facilities, and thereby set to be deposited in final disposal. The operation of Loviisa power plant also involves the use of radiation sources for which there is a separate safety licence pursuant to the Radiation Act. These are used for some process measurements, for example, as well as for the testing and calibration of radiation measuring instruments. Contingencies for the radiation sources in question being deposited in Loviisa’s final disposal facility once they are no longer in use have been made in the power plant’s operations. The volume of waste generated by the radiation sources amounts to only a fraction of the volume of the rest of the waste to be deposited in final disposal. The radiation sources are described briefly in Appendix 4 to the application.

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– a maximum of 2,000 m3 in radioactive waste of the type mentioned above, and with equivalent properties, but generated elsewhere in Finland; and

The volume of the radioactive waste generated elsewhere in Finland is discussed in Appendix 4. The actual volume of the waste to be deposited in the final disposal facility is expected to be significantly lower than the proposed licence term. Given that Loviisa power plant already has functions and facil- ities suitable for the handling and final disposal of radioactive waste in place, their availability as part of the overall social solution would be natural and in line with the recommendations of the National Nu- clear Waste Management Cooperation Group4. The first planned batch of waste generated elsewhere in Finland would consist of the decommissioning waste of the FiR 1 research reactor and the Otakaari 3 research laboratory for radioactive materials.

– a maximum of 50,000 m3 in waste with a very low level of activity, generated in the nuclear power plant’s decommissioning and the dismantling of the buildings.

In addition to low- and intermediate-level waste, the final disposal facility may also come to house conventional dismantling waste or dismantling waste with a very low level of activity, such as crushed concrete. The maximum volume of the waste with a very low level of activity would be 50,000 m3, and it would be used, to the extent possible, as the final disposal facility’s filling material, along with quarried rock. The use of concrete as a filling material will increase the pH of the water in the final disposal facili- ty, thereby slowing down corrosion and contributing to the long-term safety of the final disposal halls.

5 CONDITIONS FOR THE GRANTING OF A LICENCE (SECTION 20 OF THE NUCLEAR ENERGY ACT) The conditions for granting an operating licence to Loviisa’s final disposal facility for low- and interme- diate-level waste are presented below.

4 In June 2017, the Ministry of Economic Affairs and Employment appointed a working group to explore the objectives, development measures and alternative solutions for safe and cost-effective nuclear waste management and other radi- oactive waste management from today until well into the future. The final report of the National Nuclear Waste Manage- ment Cooperation Group can be found at http://urn.fi/URN:ISBN:978-952-327-435-8.

5.1 LOVIISA’S FINAL DISPOSAL FACILITY FOR LOW- AND INTERMEDIATE-LEVEL WASTE IS SAFE Loviisa’s final disposal facility meets the safety requirements pursuant to the Nuclear Energy Act. Appendix 5 to the application contains a general description of the technical solutions, principles of operation and other arrangements ensuring safety. A report on the safety principles complied with and an assessment on the realisation of the principles is provided in Appendix 6 to the application. The Environmental Impact Assessment Report (EIA Report) in Appendix 13 also describes Loviisa nuclear power plant’s decommissioning as well as the handling of radioactive waste and its final disposal in the final disposal facility.

In Finland, the nuclear energy industry falls within the remit of the Ministry of Economic Affairs and Employment (MEAE). The Radiation and Nuclear Safety Authority (STUK) functions as the regulatory control authority for the use of nuclear energy. STUK’s monitoring activities are based on radiation and nuclear safety legislation, regulations and procedures. The applicant’s operations meet the require- ments of the national authorities.

The professional skills of the applicant’s personnel play an important role in the safe operation of the final disposal facility. The applicant provides its personnel and contractors with training that focuses on the nuclear facility’s special characteristics, operating methods, safety culture and technology. The expertise and operating organisation at the applicant’s disposal are described further below in the application.

In accordance with the applicant’s safety and quality policy, the plant’s operations are based on a first-rate safety culture and quality as well as continuous improvement. Safety is reviewed compre- hensively at regular intervals in the periodic safety review. Fortum conducts the safety reviews of the final disposal facility in accordance with the valid legislation applicable to nuclear safety. The content of the periodic safety review is determined in accordance with applicable international and national recommendations and practices as well as the regulations and requirements issued by STUK. The periodic safety review submitted by Fortum in 2020 was approved by STUK in 20215.

As part of continuous improvement, the applicant is involved in international activities and peer re- views, and any improvement suggestions brought up in their context are considered in the applicant’s operations. The applicant also actively follows the events of other nuclear facilities and takes their best practices and knowledge into consideration in its operations.

After the operational phase, the final disposal facility will be permanently closed. Long-term safety refers to the safety following the closure of the final disposal facility, in which the primary objective is to limit the radiation exposure caused by the waste to people living in the vicinity of the closed facility and other living beings. Based on the reviews and analyses conducted, the final disposal can be carried out safely. Long-term safety is described in more detail in Appendices 5 and 13.

Extending the operation of Loviisa’s final disposal facility for low- and intermediate-level until the end of 2090 is safe.

5 STUK 5/A42215/2021. Loviisan matala- ja keskiaktiivisen jätteen loppusijoituslaitosta koskeva määräaikainen turval- lisuusarviointi. 17.12.2021.

5.2 ENVIRONMENTAL IMPACT AND CONSIDERATION OF THE SAFETY OF EMPLOYEES AND GENERAL POPULATION

The environmental impact of Loviisa nuclear power plant’s extended operation and decommissioning was assessed in 2020–2021 in accordance with the Act on the Environmental Impact Assessment Pro- cedure (252/2017). The report also covered the environmental impact of the final disposal facility under different options, including the expansion of the facility for decommissioning waste and the reception of radioactive waste generated elsewhere in Finland. The EIA Report was inspected by the MEAE, as the coordinating authority. In its reasoned conclusion, the MEAE stated as follows:

The assessment report is extensive and diligently prepared. A sufficient number of options to the project are presented. No factors which cannot be mitigated to an acceptable level, or which would prevent the realisation of an option, emerged in the environmental impact assessment.

The EIA Report can be found in Appendix 13 to this application. The reasoned conclusion given by the MEAE is in Appendix 15 to the application and the consideration of the reasoned conclusion in the operations of Loviisa nuclear power plant and final disposal facility is reviewed in Appendix 16.

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The final disposal facility is located deep within the bedrock, due to which the waste deposited there for final disposal causes no harm to human health or the natural environment. Further details on the operational waste can be found in Appendix 4 to the application. Appendix 5 contains a general de- scription of the final disposal facility. A description of the final disposal facility’s role as part of Loviisa nuclear power plant’s nuclear waste management can be found in Appendix 9.

In accordance with the recommendations of the National Nuclear Waste Management Cooperation Group set up by the MEAE, the application for an operating licence covers a preparedness for the re- ception, handling, interim storage and final disposal, in the Loviisa power plant area, of small amounts of radioactive waste generated elsewhere in Finland.

The applicant operates in accordance with the terms of the licence, continuously aiming to reduce the operations’ impact on the environment by making use of best practices and technologies insofar as possible. The operations of Loviisa power plant have been certified to the ISO 14001 Environmental Management Standard.

The waste described in the application’s proposed licence terms will be deposited for final disposal in the final disposal facility located in the power plant area. The plan is also to excavate in the existing final disposal facility an extension for the decommissioning waste of the Loviisa nuclear power plant. Hence the extended final disposal facility allows for final disposal of all the radioactive waste, excluding spent nuclear fuel, generated during the operation and decommissioning of the power plant and its parts to be made independent.

The concentrations of radioactive substances in the exhaust air duct and the water on the floors of the facility will be monitored during the final disposal facility’s operational phase, and in practice, no radioactive substances causing a dose are released into the environment.

The safety of employees working in Loviisa’s power plant area and the final disposal facility is ac- counted for in the appropriate manner and occupational safety is considered in all operations. Radia- tion safety and control is described in Appendix 5 to the application. The radiation doses of the people working at Loviisa nuclear power plant remain significantly below the dose limits for employees, and the waste handling and other measures carried out in the final disposal facility account for only a frac- tion of the radiation exposure of the power plant’s personnel.

A report on the measures aiming to limit the nuclear power plant’s environmental stress is in Ap- pendix 7 to the application.

Extending the operation of Loviisa’s final disposal facility for low- and intermediate-level until the end of 2090 is safe for the environment and the population.

5.3 THE METHODS AVAILABLE TO THE APPLICANT FOR ARRANGING NUCLEAR WASTE MANAGEMENT ARE SUFFICIENT AND APPROPRIATE

The operation of the final disposal facility will not produce any new nuclear waste, due to which it will not require separate nuclear waste management measures in addition to those carried out at the power plant. Loviisa’s final disposal facility forms a key part of Loviisa power plant’s nuclear waste management.

The operation of a nuclear power plant generates both radioactive waste and conventional (non-ra- dioactive) waste. The starting point in nuclear waste management is that the radioactive waste is isolated from humans and organic nature for as long as necessary, accounting for the radioactivity of the waste.

In addition, the decommissioning of the nuclear power plant generates decommissioning waste and other conventional dismantling waste. The plan for the decommissioning of the power plant is updated

and submitted to the authorities at regular intervals. The last time Fortum updated the plan in terms of Loviisa power plant was in 2018.

All radioactive waste generated in the operation of the power plant and its parts to be made inde- pendent and decommissioning requiring final disposal, excluding spent fuel, will be deposited for final disposal in the final disposal facility.

The final disposal of nuclear waste in bedrock is based on multiple release barriers, which effectively limit the migration of radioactive substances from the final disposal halls, thereby ensuring minimal impact on people and organic nature. The bedrock itself is one of the release barriers. Engineered re- lease barriers include the waste matrix that binds the radioactive substances, the waste container, the buffer surrounding the waste container, the backfilling of the final disposal halls and the closing struc- tures of the disposal facility. The final disposal of nuclear waste is planned and implemented in a way that does not require continuous supervision of the final disposal location to ensure long-term safety. According to international and Finnish surveys, the necessary nuclear waste management measures can be implemented in a controlled and safe manner.

Further details on the operational waste can be found in Appendix 4 to the application. Appendix 5 contains a general description of the final disposal facility. A description of the final disposal facility’s role as part of Loviisa nuclear power plant’s nuclear waste management can be found in Appendix 9.

The applicant is responsible for the safe storage and final disposal of different types of nuclear waste.

5.4 FORTUM HAS THE NECESSARY EXPERTISE AT ITS DISPOSAL AND ITS OPERATING ORGANISATION IS SUITABLE

Over the roughly 40 years of Loviisa power plant’s operation, the applicant’s personnel have accu- mulated considerable expertise on the use of nuclear power, nuclear waste management and plant modifications.

The applicant develops and trains its personnel continuously, thereby ensuring and maintaining the entire personnel’s competence at the level required by the tasks, in terms of knowledge, skills and attitudes. Personnel development is defined in the company’s strategy, and it must be first-rate, long- range, systematic and proactive in nature. The applicant’s personnel have an either direct or indirect impact on the safety of the nuclear facilities. Fortum provides its personnel and contractors with training focused particularly on the nuclear power plant’s special characteristics, operating methods, safety culture and technology.

Loviisa power plant has an extensive and suitable operating organisation, which covers several dif- ferent functions. The final disposal facility for low- and intermediate-level waste is a separate nuclear facility as referred to in the Nuclear Energy Act and Nuclear Energy Decree, but it is used in connection with Loviisa power plant and is integrated into the power plant’s operations. This also applies to the ex- pertise and appropriate operating organisation at the disposal of the final disposal facility’s operations. In addition, Loviisa power plant can rely on the support functions of Fortum Group and the technical support of the Generation division.

Further details on the expertise at the applicant’s disposal and the applicant’s operating organisa- tion can be found in Appendix 8 to the application. Appendix 8 also includes a more detailed descrip- tion of the personnel’s competence management and training.

The applicant has sufficient expertise, and its operating organisation is suitable.

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5.5 FORTUM POSSESSES THE FINANCIAL AND OTHER NECESSARY MEANS TO PURSUE THE OPERATIONS SAFELY

The applicant’s financial means for engaging in the operations are reviewed in Appendices 10 and 11 to the application. The other means necessary for pursuing the operations safely are presented in Appendices 5 and 6 to the application.

The costs of the final disposal facility have been prepared for as part of preparing for Loviisa power plant’s nuclear waste management. The applicant ensures that it has taken out the liability insurance for a nuclear facility required by the Nuclear Liability Act (484/1972) or another financial guarantee of equal coverage, the insured amount of which is EUR 1,200 million.

The applicant is not aware of any changes to the facility’s operation, legislation or international ob- ligations which would have a significant impact on the applicant’s means to operate the facility safely and in accordance with Finland’s obligations based on international conventions and agreements.

The applicant has sufficient financial and other means for Loviisa power plant’s safe ope- ration in accordance with legislation and Finland’s obligations based on international con- ventions and agreements.

6 SUMMARY AND ENFORCEMENT Based on what is presented above and in the more detailed reports and reviews in the Appendices to the application, the applicant is of the opinion that the conditions for granting an operating licence referred to in section of the Nuclear Energy Act and the requirements provided in sections 5–7 of the Nuclear Energy Act – pertaining to the overall good of society and the safety of Loviisa power plant – have been met, and the operating licence sought by the applicant can be granted.

The applicant requests that the Government, when granting the licence, decides by virtue of section 122, subsection 3 of the Administrative Judicial Procedure Act (808/2019) that the decision be enforced regardless of a possible appeal, given that the decision’s enforcement should not be postponed due to the public interest.

It is in the public interest to dismantle the FiR 1 research reactor in Otaniemi, Espoo, and deposit the radioactive waste of the research reactor and the research laboratory for radioactive materials (Ota- kaari 3), which is set to be decommissioned, at Loviisa power plant. Any delay in the enforcement of the power plant’s and final disposal facility’s licence application would also cause a delay in the reception of the aforementioned waste, which should consequently be stored and possibly even deposited for final disposal somewhere else.

In addition, the new operating licence for the final disposal facility would enable the applicant to organise nuclear waste management in a safer and more flexible manner. Loviisa’s final disposal facility forms a key part of Loviisa power plant’s nuclear waste management. An operating licence for extend- ing Loviisa nuclear power plant’s energy production until 2050 is being applied for with a separate op- erating licence application. It is also important to secure a licence for the nuclear waste management and the final disposal facility in the new operating licence period being sought for Loviisa power plant.

It is the applicant’s opinion that the granting of a new operating licence and its immediate enforcement would be in the interest of the overall good of society.

Espoo, March 18, 2022

Simon-Erik Ollus CEO, Fortum Power and Heat Oy

Sasu Valkamo Vice President, Loviisa Nuclear Power Plant

APPENDICES

Appendix 1. An extract from the Trade Register (separate appendix, not included in this hand-out version) Appendix 2. A copy of the Articles of Association and register of shareholders (separate appendix, not included in this hand-out version) Appendix 3. Report on the residential areas and other activities in the location of the nuclear power plant and its immediate surroundings and on land use planning. Appendix 4. Report on the quality and maximum quantity of the nuclear materials or nuclear waste manufactured, produced, handled, used or stored at the nuclear power plant Appendix 5. General description of the technical solutions, principles of operation and other arrangements ensuring safety Appendix 6. Report on the safety principles complied with and an assessment on the realisation of the principles Appendix 7. Report on the measures aiming to limit the nuclear power plant’s environmental stress Appendix 8. Review of the expertise at the applicant’s disposal and the nuclear facility’s operating organisation Appendix 9. Review of the applicant’s plans for arranging nuclear waste management and the methods available for it, including the dismantling of the nuclear facility and the final disposal of nuclear waste, and an account of the schedule and estimated costs of the nuclear waste management Appendix 10. Review of the applicant’s financial position and the applicant’s financial management plan and production plan Appendix 11. The applicant’s financial statements for the years 1996–2020 (separate appendix, not included in this hand-out version) Appendix 12. Report on the applicant’s compliance with the valid terms of the operating licence Appendix 13. Loviisa Nuclear Power Plant – Environmental Impact Assessment Report Appendix 14. Loviisa nuclear power plant’s Environmental Impact Assessment Report, International Hearing Document Appendix 15. Reasoned conclusion of the Ministry of Economic Affairs and Employment concerning the environmental impact assessment report for Loviisa nuclear power plant Appendix 16. Account of the consideration of the reasoned conclusion in the operations of Loviisa nuclear power plant and the final disposal facility

Appendices 1 through 12 are not available in English.

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Appendix 16 Consideration of the reasoned conclusion in the operations of Loviisa nuclear power plant and the final disposal facility

CONTENTS APPENDIX 16: CONSIDERATION OF THE REASONED CONCLUSION IN THE OPERATIONS OF LOVIISA NUCLEAR POWER PLANT AND THE FINAL DISPOSAL FACILITY ....................... 16

1 INTRODUCTION .............................................................................................................. 18 2 EIA REPORT’S ADEQUACY AND QUALITY...................................................................... 18

2.1 Impact on surface waters ............................................................................................. 18

2.2 Impact on soil, bedrock and groundwater .................................................................. 19

2.3 Impact on climate ........................................................................................................... 19

2.4 Impacts of a severe reactor accident .......................................................................... 19

2.5 Other remarks made in the statements ..................................................................... 19

2.6 International hearing ..................................................................................................... 20

3 REASONED CONCLUSION BY THE COORDINATING AUTHORITY ...............................20

3.1 Significant environmental impact of extended operation (VE1) ............................ 20

3.1.1 Surface waters ...................................................................................................... 20

3.1.2 Fish and fishing ..................................................................................................... 21

3.1.3 Greenhouse gas emissions and climate change ............................................. 21

3.1.4 People’s living conditions and comfort, community structure,

tangible property ........................................................................................................... 21

3.1.5 Radioactive waste and its management ........................................................... 21

3.1.6 Severe reactor accident, other incidents and accidents ................................ 21

3.2 Significant environmental impact of decommissioning (VE0, VE0+) ..................... 21

3.2.1 Surface waters ...................................................................................................... 21

3.2.2 Fish and fishing .................................................................................................... 21

3.2.3 Greenhouse gas emissions and climate change ............................................. 21

3.2.4 People’s living conditions and comfort, community structure,

tangible property ........................................................................................................... 21

3.2.5 Landscape and cultural environment ...............................................................22

3.2.6 Traffic ....................................................................................................................22

3.2.7 Noise ......................................................................................................................22

3.2.8 Radioactive waste and its management ..........................................................22

3.2.9 Severe reactor accident, other incidents and accidents ...............................22

3.3 Significant environmental impact of L/ILW repository’s expansion

(VE1, VE0, VE0+) .............................................................................................................22

3.3.1 Soil and bedrock ...................................................................................................22

3.3.2 Groundwater ........................................................................................................22

3.3.3 Noise ......................................................................................................................22

3.3.4 Use of natural resources ....................................................................................22

3.4 Other impacts .................................................................................................................23

4 SUMMARY ........................................................................................................................ 23

Operating licence application | Appendix 16 1918 Operating licence application | Appendix 16

1 INTRODUCTION This account is part of the operating licence applications of Loviisa power plant and final disposal facility for low- and in- termediate-level waste1.

In accordance with section 10 of the Act on the Environ- mental Impact Assessment Procedure (252/2017, hereinafter the EIA Act), Fortum Power and Heat Oy’s (hereinafter For- tum) coordinating authority in the project is the Ministry of Economic Affairs and Employment. Pursuant to section 23 of the EIA Act, the Ministry of Economic Affairs and Employment has reviewed the adequacy and quality of Fortum’s Environ- mental Impact Assessment Report (hereinafter EIA Report) and prepared its reasoned conclusion on the project’s signif- icant environmental impact.

In addition to the EIA Report in Appendix 13 to the appli- cation for the operating licence, the reasoned conclusion on the project given by the coordinating authority is appended to the application as Appendix 15, as required by section 25 of the EIA Act. Furthermore, the EIA Report’s International Hear- ing Document can be found in Appendix 14 of the application for the operating licence.

According to the provisions in section 26 of the EIA Act, the licence decision must indicate how the EIA Report, reasoned conclusion and any documents pertaining to an international hearing pursuant to section 29 have been considered.

The Ministry of Economic Affairs and Employment gave its reasoned conclusion on the project on 10 January 2022. In its reasoned conclusion on the project, the Ministry of Economic Affairs and Employment states, among other things, that the project options reviewed do not have any significant harmful environmental impact which would be unacceptable, or which could not be prevented or mitigated to an acceptable level.

According to the reasoned conclusion of the Ministry of Economic Affairs and Employment, the comparison of the different options has been carried out in a sufficient manner in the EIA Report.

Based on the requirements of the EIA Act referred to above and the remarks made in the reasoned conclusion of the Min- istry of Economic Affairs and Employment, Fortum addresses, in the following, how the matters and needs for further investi- gations raised in the coordinating authority’s reasoned conclu- sion and in the statements of the other parties are accounted for, if necessary, in the application for the operating licence. In addition, the focus lies on how the matters and investigative needs mentioned in the reasoned conclusion and statements are or will be accounted for in the applicant’s operations insofar as the matters, according to Fortum’s own view, pertain to the operating licence application and operating licence now under discussion. Given that decommissioning is not yet topical, the matters and needs for further investigations related to the de- commissioning are discussed in general terms alone. The de- commissioning will be planned in detail, and the matters raised in the reasoned conclusion and statements will be accounted for as necessary as part of its planning.

1 The final disposal facility for low- and intermediate-level waste is also referred to as the L/ILW repository.

2 EIA REPORT’S ADEQUACY AND QUALITY

In its reasoned conclusion concerning the project, the Minis- try of Economic Affairs and Employment states that Fortum’s EIA Report on Loviisa nuclear power plant meets the content requirements provided for in section 19 of the EIA Act and in the EIA Decree (277/2017), and that it is dealt with as required by the EIA legislation. The EIA Report was prepared in con- sideration of the project’s assessment programme and the statement on it provided by the coordinating authority. The project owner has had sufficient expertise at its disposal for the execution of the environmental impact assessment and the separate reports and reviews.

The Ministry of Economic Affairs and Employment further- more notes that the EIA Report is extensive and diligently prepared. A sufficient number of options for the project are presented. No factors which cannot be mitigated to an ac- ceptable level, or which would prevent the realisation of an option, emerged in the environmental impact assessment.

However, the Ministry of Economic Affairs and Employment took the view that, based on the review as well as statements and opinions received, the assessment could be specified in some respects.

This section discusses in more detail the matters ad- dressed in chapter 3 of the reasoned conclusion given by the Ministry of Economic Affairs and Employment. The headings used below are the same as those used in chapter 3 of the said reasoned conclusion. In addition, Fortum deals with the international hearing under heading 2.6.

2.1 IMPACT ON SURFACE WATERS In the reasoned conclusion, the Ministry of Economic Affairs and Employment states that the impact assessment concern- ing the surface waters and the discussion of the mitigation measures are at a sufficient level at this stage of the project’s planning, but that they must be specified in the future.

Fortum continues its investigations aiming to supply the power plant with cooler cooling water and mitigate the im- pact of the cooling water, and to gain a deeper understand- ing of the factors affecting the state of the nearby sea ar- ea. These efforts are currently carried out as a research and development programme of Fortum, and there are no plans aiming for the implementation of water engineering works.

Fortum contributes to the achievement of the objectives related to water resources management and may take part in the planning of measures improving the state of the wa- terway in cooperation with the Uusimaa Centre for Economic Development, Transport and the Environment (hereinafter the Uusimaa ELY Centre) and the town of Loviisa.

The manner in which the impact of the power plant’s cool- ing water is accounted for in the operations is discussed be- low, in section 3.1.1 .

2.2 IMPACT ON SOIL, BEDROCK AND GROUNDWATER

The statements draw attention to Loviisa’s final disposal fa- cility for low- and intermediate-level waste and particularly its planned expansion as well as its impact on the soil, bedrock and groundwater. Attention is also paid to the monitoring pro- gramme which is to be carried out to prove the effectiveness of the release barriers.

The planned expansions of the final disposal facility are located in the immediate vicinity of the existing bedrock spaces. Individual rock fissures are likely to be cut during the excavating, in which case they will be injected in accordance with the methodologies of normal rock engineering if neces- sary, as has been done during the earlier construction phases.

The positioning of the expansion spaces will be ensured during detailed engineering prior to the excavating, the aim being to avoid positioning the spaces too close to any signif- icant water-conductive structures. Among other measures, the positioning will be ensured prior to the actual excavating by drilling a pilot trial hole.

The understanding of the bedrock surrounding the final disposal facility and its groundwater conditions is based on studies commenced prior to the construction of the final dis- posal facility, the monitoring programmes (rock mechanics, hydrology and groundwater chemistry) to be implemented during its usage phase and the modelling supporting them. This understanding is compiled into the regularly updated long-term safety case. Its preparation includes an assess- ment of the quality of the baseline data used in the ground- water flow calculations and further studies, if necessary.

The monitoring programmes were reviewed in the final disposal facility’s periodic safety review drawn up in 2020, in which they were deemed sufficiently extensive and compre- hensive. Their extent and comprehensiveness are reviewed when necessary, such as before the excavation work related to the expansion of the final disposal facility begins, as is also mentioned in the EIA Report.

The Radiation and Nuclear Safety Authority (hereinafter STUK) also assesses the extent and implementation of the monitoring programmes as part of its continuous supervi- sion. The measurement of the boundary level between fresh and saline water, mentioned in one of the statements, has been found problematic in terms of its interpretation and discontinued, given that the said boundary level’s position in the open hole does not describe the groundwater’s salin- ity in the rock. Instead, it depends solely on the division of the pressure height and the hydraulic properties of the most water-conductive fissures/structures’ points intersecting the hole. STUK had no comments on the extent of the hydrolog- ical monitoring in its inspection of the final disposal facility’s periodic safety review.

2.3 IMPACT ON CLIMATE Fortum agrees with the view of the Ministry of Economic Affairs and Employment according to which the impact of the produced electricity’s greenhouse gas emission-free nature is much great- er in significance than the project’s direct climate impact.

Extending operation will have a significant effect on the achievement of the national targets for emission reductions and thereby on combating climate change.

2.4 IMPACTS OF A SEVERE REACTOR ACCIDENT Many statements commented on the selected source term. The selected source term was 100 TBq of the caesium isotope 137 and the emissions of other substances had been scaled to correspond to it. As is noted by the Ministry of Economic Affairs and Employment in its reasoned conclusion, in Finland, section 22 b of the Nuclear Energy Decree sets 100 TBq of caesium-137 as the limit value for a high emission, and this value is generally used as the source term in Finnish environ- mental impact assessments.

With regard to mitigating the impact of a severe reactor accident, Estonia’s environmental administration commented on the responsible parties.

In this respect, Fortum points out that STUK is responsible for the communications, both nationally and internationally. The mitigation measures to be conducted abroad will be de- cided on and carried out by local parties.

2.5 OTHER REMARKS MADE IN THE STATEMENTS The statements expressed that research related to climate change should be monitored in the future and that the accu- mulated data should be used to improve the facility’s safety in accordance with the EIA Report.

Fortum follows climate change-related research through the Finnish Research Programme on Nuclear Power Plant Safety (SAFIR), for example, and takes into account the accumulated da- ta in assessing and, if necessary, improving the facility’s safety.

Regarding chemicals, the statements pointed out that nei- ther the chemicals discharged into the sea nor their impact was discussed in the report.

Fortum refers to the EIA Report, in which it is stated that the annually used quantities of chemicals will remain unchanged if operation is extended. In respect of waters conducted into the sea, the company also complies with the limit values set in the conditions of the environmental permit and in legislation. No effects caused by chemicals have been detected in the impact monitoring focused on Loviisa power plant’s nearby sea area.

The statements also note that the consultants who had prepared the EIA Report lacked competence on the impact of radioactive substances.

Fortum is an expert on radiation safety and on assessing the impact of radioactive substances in terms of its opera- tions. Fortum also points out that the impact monitoring con- cerning radioactive substances ending up in the environment is carried out in accordance with an observation programme approved by the authorities. Based on the results of the emis- sion monitoring, the radioactive emissions into the environ- ment have remained considerably below the limits set for the emissions of a nuclear power plant. The results of the impact monitoring show that the quantities of radioactive substanc- es in the surroundings of the power plant are low.

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The power plant’s ageing and the attendant increase in risks was a cause for concern among several of the parties providing statements.

Fortum underscores that the ageing management of Lovii- sa power plant has been accounted for throughout the power plant’s operation. Appropriately executed ageing management and maintenance are prerequisites for ensuring the safe, relia- ble and profitable operation of a nuclear power plant. STUK will assess the safety of the project in connection with the safety review related to application for an operating licence.

In respect of the power plant’s decommissioning and the expansion of the final disposal facility, the statements drew attention to, among other things, the possible contamination of the land areas of the power plant location and mentioned that special attention should be paid to the prevention of noise and dust nuisance during future planning and the li- cence and permit processes.

Fortum notes that the dismantling of Loviisa power plant is not yet topical. Fortum is unaware of any contaminated soil or land areas within the area. The appropriate studies, aim- ing to detect any contaminated soil, will be conducted well in advance of the start of the construction and dismantling work. If any contaminated soil or land areas are detected, the matter will be reported to the authorities and the areas will be rehabilitated in accordance with the requirements of the applicable legislation.

Fortum aims to mitigate the noise nuisance in terms of both the expansion of the final disposal facility and the pow- er plant’s decommissioning with various measures, such as scheduling the noisiest work appropriately and the selection of the location where the concrete is crushed. Fortum will also pay attention to dust management methods when planning the dismantling.

2.6 INTERNATIONAL HEARING In the international hearing, statements were made by the authorities of Austria, Lithuania, Sweden and Estonia. In addi- tion, the Ministry of the Environment received 12 statements from European citizens and organisations.

The statements primarily objected to the use of nuclear energy based on the risk of accidents and concern about the safety of spent nuclear fuel.

Should operation be extended, the work to improve safe- ty will be continued. STUK will assess the project’s safety in connection with the application for an operating licence. It is Fortum’s view that the issues related to safety are discussed to a sufficient extent in the EIA Report.

Some of the statements included a wish that the presenta- tions made in the public event be translated into English or that another event be held for an international audience. The statements invoked the Espoo Convention and the Aarhus Convention.

The Ministry of Economic Affairs and Employment address- es in its reasoned conclusion the realisation of the process related to the international hearing in Loviisa power plant’s EIA procedure. Fortum agrees with the ministry’s view and points out that the international hearing is implemented in

accordance with both the Espoo and Aarhus Conventions and in compliance with the provisions of the EIA legislation.

Furthermore, the question pertaining to transboundary im- pacts posed in the international hearing is addressed in section 2.4 above and the questions pertaining to the power plant’s ageing made in the hearing are addressed in section 2.5.

3 REASONED CONCLUSION BY THE COORDINATING

AUTHORITY This section discusses in more detail the project’s most sig- nificant environmental impacts in terms of extended opera- tion, decommissioning and the expansion of the final disposal facility, addressed in chapter 4 of the reasoned conclusion of the Ministry of Economic Affairs and Employment The head- ings used below are the same as those used in chapter 4 of the said reasoned conclusion.

3.1 SIGNIFICANT ENVIRONMENTAL IMPACT OF EXTENDED OPERATION (VE1)

3.1.1 Surface waters

In its reasoned conclusion concerning Loviisa power plant, the Ministry of Economic Affairs and Employment requires the impact of the power plant’s cooling water to be consid- ered in the operations.

Fortum points out that Loviisa power plant has valid envi- ronmental and water permits which include specifications on the volume and temperature of the cooling water, among oth- er things. The operations comply with the permit regulations and the results of the related monitoring are reported to the authorities regularly.

The EIA Report includes an assessment on the operations’ impact on the nearby sea area and presents potential meas- ures for mitigating any harmful effects.

As part of the option of extended operation, Loviisa power plant’s EIA Programme investigated the possibility of car- rying out water engineering projects in the area, in front of the cooling water intake and the nearby sea area. Based on the preliminary investigations, it can be assumed that by de- creasing the temperature of the abstracted cooling water, it would be possible to reduce the temperature of the dis- charged cooling water, although this would not affect the thermal load being conducted to the sea in any material way. Based on the techno-economic investigations carried out, the water engineering projects were nevertheless removed from the environmental impact assessment procedure. The mat- ter will continue to be studied, separate from the EIA Report, in Fortum’s research project, which aims to find the most cost-effective technical solutions for reducing the tempera- ture of the abstracted cooling water with the help of model- ling. However, there are no plans aiming for the execution of water engineering work.

In terms of the Klobbfjärden body of water, the reduction of the diffuse source input, a significant portion of which is de- rived from the river Tesjoki, plays a key role. The most effec- tive measures include the agricultural measures to be carried out in the river’s catchment area, such as the application of gypsum in agricultural fields.

For its part, Fortum supports the achievement of the tar- gets set for the state of the bodies of water in legislation. Fortum may take part in the planning of measures aiming to improve the state of the waterway in cooperation with the Uusimaa ELY Centre and the town of Loviisa. Over a longer term, Fortum aims to further deepen its knowledge of Loviisa power plant’s impact on the state of the Klobbfjärden body of water. The reports may be related to the state of the benthic fauna and sediment of the nearby sea area, for example, so that the background material of the classification would be sufficient and representative.

3.1.2 Fish and fishing

The power plant has an impact on the icthyofauna and fishing. The reasoned conclusion does not include remarks concern- ing the icthyofauna or fishing which would require Fortum to undertake any measures beyond those assessed and dis- cussed in Fortum’s EIA Report.

Loviisa power plant has valid environmental and water per- mits which include specifications on the volume and temper- ature of the cooling water. Fortum also pays an annual fish- eries charge pursuant to the permit regulation which is used for mitigating any harmful effects of the cooling water in its impact area.

3.1.3 Greenhouse gas emissions and climate change

The power plant’s operations have a significant positive cli- mate impact. The reasoned conclusion does not include re- marks concerning greenhouse gas emissions or climate change which would require Fortum to undertake any measures be- yond those assessed and discussed in Fortum’s EIA Report.

3.1.4 People’s living conditions and comfort, community structure, tangible property

The operations of Loviisa power plant have an impact on peo- ple’s living conditions and comfort. The reasoned conclusion does not include remarks concerning people’s living condi- tions and comfort, community structure or tangible property which would require Fortum to undertake any measures be- yond those assessed and discussed in Fortum’s EIA Report.

3.1.5 Radioactive waste and its management

The power plant’s extended operation would increase the to- tal volume of the accumulation of spent nuclear fuel as well as low- and intermediate-level waste. The reasoned conclu- sion does not include remarks concerning the accumulation of spent nuclear fuel or low- and intermediate-level waste

which would require Fortum to undertake any measures be- yond those assessed and discussed in Fortum’s EIA Report.

3.1.6 Severe reactor accident, other incidents and accidents

Fortum addresses the possibility of a severe reactor accident as well as other incidents and accidents in section 2.4 above and the reasoned conclusion does not include any remarks concerning them which would require Fortum to undertake measures beyond those assessed and discussed in Fortum’s EIA Report.

3.2 SIGNIFICANT ENVIRONMENTAL IMPACT OF DECOMMISSIONING (VE0, VE0+)

3.2.1 Surface waters

The thermal load caused by the cooling water will end with the decommissioning and the reasoned conclusion does not include comments on the planning of the decommissioning and Fortum’s operations in terms of the surface waters.

Fortum points out that in the future too, what will play a key role in terms of the state of the Klobbfjärden body of water is the reduction of the diffuse source input, a significant portion of which derives from the river Tesjoki.

3.2.2 Fish and fishing

The thermal load caused by the cooling water which has an impact on the icthyofauna will come to an end once the power plant is decommissioned. The reasoned conclusion does not include remarks related to the icthyofauna or fishing which would require Fortum to undertake any measures.

With decommissioning, the area’s icthyofana and fishing opportunities may return to a state similar to that prevailing in the surrounding sea areas.

3.2.3 Greenhouse gas emissions and climate change

The climate impact of the decommissioning following the cur- rent operating period is expected to be reasonably negative. The reasoned conclusion does not include remarks related to greenhouse gas emissions or climate change which would re- quire Fortum to undertake any further measures.

3.2.4 People’s living conditions and comfort, community structure, tangible property

The decommissioning of Loviisa power plant will have an im- pact on people’s living conditions and comfort and on the energy market, security of supply and the regional economy. The reasoned conclusion does not include remarks concern- ing these issues which would require Fortum to undertake any measures beyond those assessed and discussed in Fortum’s EIA Report.

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3.2.5 Landscape and cultural environment The decommissioning of Loviisa power plant will have an im- pact on the landscape and cultural environment.

Prior to the dismantling of the buildings, Fortum will com- mission a report on the architectural history of the area’s building stock.

3.2.6 Traffic

The decommissioning of Loviisa power plant will have an impact on traffic. The reasoned conclusion does not include remarks concerning traffic which would require Fortum to un- dertake any measures beyond those assessed and discussed in Fortum’s EIA Report.

3.2.7 Noise

The dismantling measures will cause noise during the decom- missioning phase.

Fortum aims to mitigate the noise nuisance with various measures, such as by scheduling the noisiest work appropri- ately and by the selection of the location where the concrete is crushed.

3.2.8 Radioactive waste and its management

The power plant’s dismantling will generate considerable amounts of radioactive waste. The final disposal of the radi- oactive waste will require a significant expansion of the final disposal facility. The reasoned conclusion does not include re- marks concerning the radioactive waste and its management which would require Fortum to undertake any measures other than those assessed and discussed in Fortum’s EIA Report.

Contaminated soil and conventional waste

Regarding the contamination of soil, the Ministry of Economic Affairs and Employment notes that the contamination must be assessed in connection with the dismantling and that the appropriate handling of conventional waste must be ensured.

Fortum addresses the matter in section 2.5 above.

3.2.9 Severe reactor accident, other incidents and accidents

The nuclear power plant’s risk level will decline considerably when it is decommissioned. The reasoned conclusion does not include remarks concerning a severe reactor accident or other incidents which would require Fortum to undertake any measures other than those discussed and assessed in For- tum’s EIA Report.

3.3 SIGNIFICANT ENVIRONMENTAL IMPACT OF L/ILW REPOSITORY’S EXPANSION (VE1, VE0, VE0+)

3.3.1 Soil and bedrock

The expansion of the final disposal facility will result in signif- icant changes to the bedrock as more rock spaces are quar- ried. This is discussed in section 2.2 above. The reasoned con- clusion does not include any remarks that would give reason for changing the current plans. The expansion will be planned in more detail closer to its implementation.

3.3.2 Groundwater

The expansion of the final disposal facility will result in chang- es to the groundwater flow conditions as more rock spaces are quarried. In addition to the EIA Report, this is discussed in section 2.2 above. Section 2.2 also describes some of the questions made about the monitoring programmes in the statement in more detail than the EIA Report does.

While the reasoned conclusion does not include any re- marks that would give reason for changing the current plans, both the extent of the monitoring programmes and the im- pact that the excavation of the expansion spaces will have will be assessed in more detail closer to the implementation of the expansion.

3.3.3 Noise

The reasoned conclusion draws attention to the noise that will be caused by the excavation, crushing and transports during the expansion of the final disposal facility.

Fortum considers the possible noise nuisance and aims to mitigate them by a variety of means. The detailed planning of the final disposal facility’s expansion will account for the use of the excavation material and the noise resulting from its crushing. The construction work will be planned and carried out in such a way that the noise nuisance will be mitigated to the extent possible.

3.3.4 Use of natural resources

The reasoned conclusion draws attention to the use of the excavation material generated during the expansion of the final disposal facility.

The EIA Report reviews several alternative further uses for the excavation material generated in the expansion of the final disposal facility. The reasoned conclusion does not in- clude remarks concerning the use of natural resources which would require Fortum to undertake any measures other than those assessed and discussed in Fortum’s EIA Report.

3.4 OTHER IMPACTS

The significance of any other impacts is expected to be minor at most.

The reasoned conclusion does not include remarks con- cerning other impacts which would require Fortum to under- take any mitigating measures other than those assessed and discussed in Fortum’s EIA Report.

4 SUMMARY

In its reasoned conclusion concerning Fortum’s project, the Ministry of Economic Affairs and Employment states that the project options reviewed in Fortum’s EIA Report do not have any significant harmful environmental impact which would be unacceptable, or which could not be prevented or mitigated to an acceptable level. The comparisons between the various options have been implemented in a sufficient manner. The project’s assessment programme and the statement given on it by the coordinating authority has been considered in the preparation of the EIA Report, and the EIA Report is exten- sive and diligently prepared. It is the opinion of the Ministry of Economic Affairs and Employment that the project owner has had sufficient expertise at its disposal for the execution of the environmental impact assessment and the separate reports and reviews. The Ministry of Economic Affairs and Employment therefore considers Fortum’s EIA Report to fulfil the content requirements provided in section 19 of the EIA Act and in the EIA Decree and to have been prepared in ac- cordance with the EIA legislation.

In the above, Fortum explains how the matters and needs for investigation raised in the reasoned conclusion of the Ministry of Economic Affairs and Employment and in the statements submitted by other parties are considered in the application for an operating licence, if necessary. In addition, the above discussed how the matters and investigative needs mentioned in the reasoned conclusion and statements are or will be ac- counted for in the applicant’s operations insofar as the mat- ters pertain to the operating licence application and operating licence now under discussion. Considering the reasoned con- clusion of the Ministry of Economic Affairs and Employment and the matters discussed by Fortum above, Fortum is of the opinion that the reasoned conclusion and its processing within the operating licence application meet the requirements of the Nuclear Energy Act and the EIA legislation.

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Reasoned conclusion of the coordinating authority

10.1.2022 VN/20577/2021 VN/20577/2021-TEM-58

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Reasoned conclusion of the Ministry of Economic Affairs and Employment concerning the environmental impact assessment report for Loviisa nuclear power plant 1 Project information and the environmental impact assessment procedure

The environmental impact assessment (EIA) report deals with the extension of operations at Loviisa nuclear power plant and the alternative decommissioning options. The nuclear power plant is located on the island of Hästholmen in Loviisa. Fortum Power and Heat Oy (Fortum) is the project owner. Ramboll Finland Oy serves as the EIA consultant to Fortum in the project. Under section 10 of the Act on the Environmental Impact Assessment Procedure (the EIA Act, 252/2017), the Ministry of Economic Affairs and Employment serves as the coordinating authority for projects concerning nuclear power plants referred to in the Nuclear Energy Act (990/1987).

1.1 Description of the project and the different alternatives

The operating licences for the Loviisa 1 and Loviisa 2 power plant units and the associated buildings required for the management of their nuclear fuel and nuclear waste will expire in 2027 and 2030. The report also deals with the use of the final disposal facility for low- and intermediate-level nuclear waste. The report analyses three different alternatives for the extension of nuclear power plant operations. Under Option 1 (VE1), the company will extend the operations of both power plant units by a maximum of approximately 20 years after the current licence periods. The buildings and storage facilities required for nuclear fuel and nuclear waste management, as well as the final disposal facility will continue in use and will be expanded where necessary. The nuclear power plant could also be used for the processing, interim storage and final disposal of small amounts of radioactive waste generated elsewhere in Finland. Under Option 0 (VE0), the nuclear power plant will be decommissioned after the expiry of the current licences, that is, in 2027 and 2030. The buildings and storage facilities required for the nuclear waste management of the plant units, as well the final disposal facility will continue in use until rendered unnecessary or decommissioned. Option 0+ (VE0+) is the same as Option VE0 in all other respects, except that it would also allow the nuclear power plant to be used for the processing, interim storage and final disposal of small amounts of radioactive waste generated elsewhere in Finland.

1.2 Environmental impact assessment procedure

Fortum submitted its environmental impact assessment report (EIA report) to the Ministry of Economic Affairs and Employment on 6 September 2021. The report follows the EIA procedure and the programme stage, which began on 13 August 2020, when the party responsible for the project submitted the environmental impact assessment programme to the Ministry of Economic Affairs and Employment. The ministry issued its opinion regarding the programme on 23 November 2020. The project falls within the

2 (22) scope of the environmental impact assessment procedure because it is a project referred to in points 7b and 7d of Appendix 1 (list of projects) of the EIA Act.

1.3 Interfaces with other projects

According to plans, the spent fuel from the Loviisa nuclear power plant will be deposited for final disposal in Posiva Oy’s repository in Olkiluoto, Eurajoki. The project will affect the amount of spent fuel deposited in the final disposal facility. The assessment procedure also examines options for using the nuclear power plant for the processing, interim storage and final disposal of small amounts of radioactive waste generated elsewhere in Finland. In this respect, the project is linked to ongoing Finnish projects that are typically conducted by the industrial sector, health care sector and research institutions and generate low- and intermediate-level waste. The project is also linked to the decommissioning of the FiR 1 research reactor of the VTT Research Centre of Finland and the research laboratory for radioactive materials at Otakaari 3 (OK3). The assessment procedure also addresses the possibility of depositing low- and intermediate-level waste from the decommissioning projects in interim storage at Loviisa power plant and in final disposal in the L/ILW repository. The project may be linked to various plans and programmes concerning the use of natural resources and environmental protection, including national target programmes and international commitments. According to the report, no projects have been identified in and around the power plant area that could contribute to cumulative effects if the operations were extended or if the plant were decommissioned. In the future, the project may impact the continued use of present transmission lines and the utilisation of the thermal energy generated by the plant, but these aspects were excluded from the current assessment procedure.

1.4 Other procedures and land use planning

The operation and decommissioning of a nuclear power plant requires a licence as specified in the Nuclear Energy Act. Such licences are issued by the government. The project may also require other licences in accordance with section 21 of the Nuclear Energy Act, issued by the Radiation and Nuclear Safety Authority STUK. The operating licences for the Loviisa power plant units will expire in 2027 (Loviisa 1) and 2030 (Loviisa 2). The licences for the buildings and storage facilities required for the units’ nuclear fuel and nuclear waste management, as well as their expansions will expire in 2030. If the party responsible for the project wishes to extend the use of the nuclear power plant units, new operating licences must be applied for. If not, a decommissioning licence must be sought. The operating licence for the final disposal facility for reactor waste (the L/ILW repository) will expire in 2055. If the party responsible for the project wishes to use the L/ILW repository for longer than this, a new operating licence must be applied for. Owing to the substantial differences in the operating times of the power plant units and the L/ILW repository, decisions on the operating licence for the L/ILW repository must be made in a separate process. Other radiation practices at Loviisa nuclear power plant require a safety licence issued by the Radiation and Nuclear Safety Authority STUK in accordance with the Radiation Act. The safety licence is valid until further notice and must be updated in accordance with changes. Regarding the transport of nuclear waste and radioactive substances, a transport or safety licence must be applied for or a notification must be submitted to STUK. The transport licence is also handled by STUK. Other permits discussed in the impact assessment report are those related to the Land Use and Building Act (132/1999), the environmental permit specified in the Environmental Protection Act (527/2014), the permit for water resources management and the permit for extracting domestic water specified in the Water Act (587/2011), as well as the permits specified in the Act on the Safe Handling of Dangerous Chemicals and Explosives (390/2005). These acts also contain provisions on various notification

3 (22) obligations. The existing local detailed plan for the area enables the implementation of the alternatives laid out in the procedure. The impact assessment report also discusses the project’s connections to various plans and programmes concerning the use of natural resources and environmental protection. These include various climate policy targets, Finland’s national climate and energy strategy and the water resources management plans and marine strategy.

2 Public participation and a summary of the statement and opinions submitted on the impact assessment report

The Ministry of Economic Affairs and Employment organised a public hearing concerning the report in accordance with the Act on the Environmental Impact Assessment Procedure and the Government Decree on the Environmental Impact Assessment Procedure (277/2017). The environmental impact assessment report was published on the Ministry’s website on 6 September 2021. An open consultation was organised from 20 September to 18 November 2021. An announcement regarding the report was published on the ministry’s website on 20 September, as well as in the project’s municipality and neighbouring municipalities in accordance with section 108 of the Local Government Act (410/2015). An announcement regarding the open consultation was also published in the following newspapers: Helsingin Sanomat, Hufvudstadsbladet, Kymen Sanomat, Uusimaa, Loviisan Sanomat, Östnyland, Itäväylä, and Nya Östis. The Ministry of Economic Affairs and Employment requested statements on the assessment report from the following parties: the Ministry of the Environment, Ministry of the Interior, Ministry for Foreign Affairs, Ministry of Defence, Ministry of Agriculture and Forestry, Ministry of Transport and Communications, Ministry of Social Affairs and Health, Ministry of Finance, Radiation and Nuclear Safety Authority (STUK) and the nuclear safety committee, Regional State Administrative Agency for Southern Finland, Uusimaa Centre for Economic Development, Transport and the Environment, Helsinki-Uusimaa Regional Council, Finnish Safety and Chemicals Agency (Tukes), Finnish Environment Institute, Eastern Uusimaa Emergency Services Department, Eastern Uusimaa Police Department, City of Loviisa, Municipality of Myrskylä, Municipality of Pyhtää, City of Porvoo, Municipality of Lapinjärvi, City of Kouvola, Akava – Confederation of Unions for Professional and Managerial Staff in Finland, Confederation of Finnish Industries, Finnish Energy (ET), Geological Survey of Finland, Greenpeace, Fennovoima Ltd, Fingrid Oyj, Central Union of Agricultural Producers and Forest Owners (MTK), Porvoo Museum, Finnish Society for Nature and Environment, Posiva Oy, VTT Technical Research Centre of Finland, Teollisuuden Voima Oyj, Finnish Confederation of Professionals (STTK), Finnish Association for Nature Conservation, Federation of Finnish Enterprises, Central Organisation of Finnish Trade Unions and WWF. Other parties and citizens also had the opportunity to express their opinion about the project. On 10 September 2021, the Ministry of Economic Affairs and Employment requested the Ministry of the Environment to organise a transboundary consultation in accordance with the Espoo Convention related to the environmental impact assessment procedure of Loviisa nuclear power plant and submit the feedback to the coordinating authority.

During the programme phase, Sweden, Estonia, Russia, Norway, Denmark, Germany, Lithuania, Austria and the Netherlands indicated their intention to participate in the assessment procedure. The Ministry of the Environment requested statements from these countries on 20 September 2021. The announcement, the environmental impact assessment report and the statements and opinions received during the consultation period were published on the website of the Ministry of Economic Affairs and Employment at https://tem.fi/en/loviisa-eia-report. An English-language version of the report and report summary were also available on the site.

2.1 Public event

The Ministry of Economic Affairs and Employment organised a public event at Lovisaviken School on the extended operation and decommissioning of Loviisa nuclear power plant in accordance with the EIA procedure on 7 October 2021. The event was streamed online to enable remote participation. Five

4 (22) participants followed the event in person and a maximum of 63 people online. Fortum handled the practical arrangements. The event consisted of expert presentations and a discussion during which the public could ask questions and express their opinions. The presentations were given in Finnish and Swedish, and essential parts also in English. Questions could be posed in all three languages. The presentations addressed local aspects, such as the impact on surface waters, the regional economy and the results of resident surveys. The discussions focused especially on nuclear waste management and the final disposal of nuclear waste, as well as on the impact of cooling water on nearby waterways. The carbon neutrality of nuclear power, as well as radiation safety and security of supply were also on the agenda. The minutes of the event are archived in the ministry’s document management system.

2.2 Summary of the statements and opinions

A total of 22 statements and opinions related to the national hearing were submitted to the ministry. The statements mainly described the report as being comprehensive. Many Finnish respondents were in favour of continuing the nuclear power plant’s operations, basing their opinion on the security of energy supply and on nuclear electricity being free of greenhouse gas emissions. Most of the comments concerned the impacts of cooling water. In the transboundary hearing, statements were submitted from Austria, Lithuania, Sweden and Estonia and their respective authorities. The ministry also received 12 statements from European citizens and organisations. These statements mainly opposed the use of nuclear energy because of the risk of accident and concerns about the safety of the final disposal of spent nuclear fuel.

2.2.1 Authorities and municipalities

According to the Regional State Administrative Agency for Southern Finland, the assessment report provides an adequately detailed description of the impacts on human living environments caused by the different options, taking into account the other licences required for nuclear power plant operations. The statement was prepared by the agency’s unit for environmental health care. The Regional State Administrative Agency points out that data on the environmental health impacts of current operations are available from a long period of time, and monitoring is carried out regularly. The agency refers to the assessment report, according to which extending operations does not imply significant changes to the current impacts and monitoring, in addition to which the expansions are not expected to have significant impacts on the nearest susceptible areas. Regarding decommissioning, the Regional State Administrative Agency notes that if the power plants are completely dismantled (according to the greenfield principle), special attention must be placed on the prevention of noise and dust disturbance in further planning and the licence processes. The agency supports the idea, included in options 1 and 0+, of the power plant being able to receive and process, as well as accept for interim storage or final disposal, small amounts of radioactive waste generated elsewhere in Finland. The unit for environmental health care approves of the idea, seeing as the power plant has the functions and facilities suitable for the processing and final disposal of radioactive waste.

Geological Survey of Finland considers the need for additional excavation for the L/ILW repository to be significant. The potential impact that the extension may have on local groundwater conditions should be explored in greater detail.

In terms of hydrogeological impacts, the extension’s surface area may be of greater significance than its volume. The current facility is located between two horizontal fragmented rock zones. The report does not indicate how the additional excavation will be carried out, but presumably the intention is to keep within the same rock segment. The network of fissures in the upper part of the rock may be water- bearing and difficult to avoid due to its wide scope. If water-bearing fissures are cut into extensively, there will be more leaks and a greater need for injection.

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According to Geological Survey of Finland, this means that surveys of the rock quality must also focus on the water-bearing features of the fissures. Although the impacts are expected to be restricted to the close vicinity of the excavated area and its use, the chapter on the present state of groundwater (9.15.3) states that fluctuations in the level of groundwater are connected to the sea and the mainland. While this does not necessarily mean the flow of groundwater, lateral hydraulic connections exist over a wider area.

Disturbances at the interface between fresh and saline water during the construction of the L/ILW repository is an indication of vertical connections (9.15.3). The surge of saline water is a common observation and the result of a change in the hydraulic pressure caused by water pumping. Based on Figure 9.26, the chemical groundwater conditions have levelled out at a depth above 120 metres, but have not returned to the conditions preceding construction. The expansion of the L/ILW repository may exacerbate the disruptions, and saline water may rise closer to the repository.

Based on this, Geological Survey of Finland believes that the decision to discontinue the monitoring of the fresh-saline water interface in 2015 was unfounded. In Geological Survey of Finland’s opinion, challenges related to interpretation are not a reason for discontinuing data collection. If parts of the groundwater system are not understood adequately, the situation must be rectified. Vertical connections can also offer channels for gases occurring naturally in the bedrock that have dissolved in the groundwater and are released when the pressure drops.

For these reasons, it is important to conduct groundwater monitoring over the entire lifecycle of the power plant site, engage in an integrated interpretation based on various data sources and continue to update the materials. The impacts of excavation can be influenced by addressing the bedrock structures and the hydrogeological and hydrogeochemical conditions in adequate detail in the location and implementation of the expansion.

According to the report, the rise in seawater temperature due to climate change, discussed in chapter 7.5.6, may result in power restrictions. The report does not take a stand on whether the limit for cooling water flow determined in the environmental permit needs to be raised in the future. At present, the cooling water flow is close to the limit in late summer.

In the opinion of Geological Survey of Finland, it is reasonable to continue the plant’s operations in view of Finland’s security of energy supply and the management of radioactive waste generated elsewhere. According to Geological Survey of Finland, the report did not raise any aspects that would require any other solution.

The Eastern Uusimaa Emergency Services Department says it provides expert statements on the construction permit procedure for the new buildings and renovations included in Option 1. The possibility included in Options 1 and 0+ to receive, process, place in interim storage and deposit in final disposal radioactive waste generated elsewhere in Finland must be taken into account, as necessary, in the external emergency plan and other safety documents. Regarding the decommissioning options, the Emergency Services Department affirms that it will maintain the external rescue plan and organise related statutory preparedness drills for as long as the site is considered to pose a special hazard as specified in section 48 of the Rescue Act.

The Eastern Uusimaa Police Department points out that, from a national perspective, the Loviisa nuclear power plant is a very important special power production site. Under normal conditions, the safety of the nuclear power plant is the responsibility of the licence holder’s safety organisation. On the whole, operations at Loviisa nuclear power plant have been safe and free of disturbance. In its statement, the police department only addresses aspects that directly affect police operations and the planning of operations. Option 1 does not involve changes to the present state. The impacts of maintenance work and fuel transports, for example, will remain the same. Should Option 1 be selected, the police department will continue its contingency planning and measures maintaining preparedness. Option 0 means a reduced risk of hazard on the site. However, safety measures will still be required to ensure the safe handling of nuclear material and radiation sources, as well as to prevent their use for illegal purposes for as long as the site contains nuclear material and radiation sources. Transports of

6 (22) nuclear material and radiation sources will continue to require contingency planning and safety measures In the police department’s opinion, the impacts of Option 0+ are otherwise similar to those of Option 0, except that the transports of nuclear material and radiation sources will have substantially larger impacts and will raise the hazard level of the site. The Municipality of Lapinjärvi is in favour of operations continuing at the nuclear power plant, but disapproves of the transport and storage of radioactive waste generated elsewhere. The municipality emphasises that special attention must be placed on the safety of nuclear fuel transports and the long- term safety of storage, as well as on mitigating any rise in seawater temperature. The City of Loviisa supports Option 1. According to the statement, climate change and increased electricity consumption call for the use of nuclear energy for at least 20 years. The statement mentions the maintenance work carried out on the site, the appropriateness of area use and land planning, as well as the investments in infrastructure. The Ministry of Social Affairs and Health expresses its satisfaction with the report, taking into account the recommendation made by the national coordination group for nuclear waste management concerning waste generated elsewhere in Finland (VE1, VE0+). In the ministry’s opinion, it would benefit society at large if Fortum could offer other operators waste treatment and final disposal services of radioactive waste. The handling of radioactive waste generated in places other than nuclear plants belongs to the administrative branch of the Ministry of Social Affairs and Health. The amount of waste is minor compared to the amount of radioactive waste generated in nuclear power plants. The ministry agrees with the report’s estimate, according to which the final disposal of waste will not cause radiation-related problems for employees or residents in the area. Options 1 and 0+ require a new operating licence to be obtained for the L/ILW repository. The ministry does not have other comments on the assessment report. In the opinion of the City of Porvoo, the assessment report is thorough and addresses the local executive’s statement on the EIA programme. The city does not have any remarks on the report. According to Porvoo Museum (with regional responsibility for Eastern Uusimaa), the extension of operations has only a minor impact on the landscape and cultural environment. Regarding new buildings, the impacts on the landscape can be minimised by leaving buffer zones in place and by paying attention to the height and colour scheme of buildings. As no relics or other archaeological cultural heritage sites are known to exist in Hästholmen, continued operations do not have direct physical or landscape impacts on the area’s archaeological cultural heritage. For decommissioning plans, a survey of the area’s historical building stock and its conservation value must be carried out. The options described in the report can also be seen as having a positive impact on the landscape structure. VE0+ does not imply special impacts on the landscape or the cultural environment. According to the Radiation and Nuclear Safety Authority STUK, the assessment report meets the criteria for radiation and nuclear safety specified in section 19 of the EIA Act. STUK is of the opinion that its statement on the assessment programme has been taken into account adequately. In its statement, STUK requested further details about the application of the BAT principle in efforts to reduce radioactive emissions, as well as about the impact that extending the duration of operations will have on Posiva Oy’s activities. According to STUK, Fortum’s estimates on the environmental impacts of radioactive substances, radiation monitoring, measures related to ageing management, processing of radioactive waste generated elsewhere in Finland and decommissioning are adequate at this point. The accident modelling and handling of impacts is also sufficient for now. STUK will conduct a detailed assessment to determine whether safety-related requirements are met when inspecting the application for an operating licence or decommissioning licence. The Uusimaa Centre for Economic Development, Transport and the Environment considers the assessment report to be comprehensive and appropriately drafted. In the centre’s opinion, the project has significant adverse impacts on surface waters, the state of water bodies, the achievement of the goals of water resources management and marine strategy, as well as aquatic organisms and fish. The

7 (22) centre emphasises the need to better plan the measures mitigating these impacts and to carry them out in full. The centre considers the rise in temperature caused by the discharge of cooling water to be one of the most significant adverse impacts of the plant. Therefore, the intake of cooler cooling water discussed in the assessment programme and the engineering work required for this should have been examined as part of the assessment. More detailed assessments of these impacts should be carried out in further project planning. The assessment report finds that a slight deterioration in the status of the Klobbfjärden body of water resulting from the combined impact of the thermal effect and the point source diffusion of nutrients cannot be ruled out. According to the Uusimaa Centre for Economic Development, Transport and the Environment, the impact that continued operations will have on the state of water bodies and the need to mitigate the adverse effects should have been examined in greater detail and analysed in the light of the water resources management plan. In further planning, a more detailed assessment of the project’s impacts on the ecological state of the body of water and the contributing factors must be carried out to ensure feasibility.

The centre also calls for a more detailed assessment of the impacts on the marine strategy and the state of the sea, addressing the impacts on the descriptors of a good status of the marine environment and the related indicators, as well as the changes caused by the project in ecosystems and species. The centre emphasises that reducing diffuse pollution has a key impact on the state of water bodies, and Fortum can affect the state of waters in the project’s area of influence by adopting measures to reduce diffuse pollution. The Uusimaa Centre for Economic Development, Transport and the Environment is prepared to cooperate with Fortum and jointly plan mitigating measures.

The impacts of continued operations on the state of surface waters should have been compared more clearly with the impacts of Option 0 over the entire planned period. According to the centre, a separate discussion of each option and comparison with the present state does not provide a clear picture of the changes in the state of waters. This merits further attention in the future. The centre considers that the report addresses climate impacts comprehensively, except for a few minor deficiencies. The assumptions used and the content of calculations have been described clearly, but the discussion of uncertainties is partly insufficient and the analysis of mitigating measures is superficial. The direct climate impacts from operations and decommissioning in the different options could have been discussed separately from indirect climate impacts related to electricity. The significance of climate impacts from continued operations is considered to be reasonably positive, which appears to be an accurate assessment. Thanks to developments in driving power and vehicle technology, the climate impacts from operations are expected to be minor, even if the construction of new buildings in the project area and the process-based methane and nitrous oxide emissions from the power plant’s wastewater treatment plant are taken into account. The overall evaluation of the climate impacts from decommissioning (moderately negative) is most likely fairly accurate, although the centre questions the assessment according to which emissions from decommissioning are negligible (Table 9-33). The assessment does not take into account the climate impacts from the construction sites for the demolition of the facility, as well as the expansion and closure of the L/ILW repository. Moreover, emissions from the processing of demolition waste or the required construction materials (e.g. concrete and steel) are not discussed at all. According to the centre, research related to climate change must be followed in the future and the resulting information must be used to improve the safety of the plant, as described in the report. As for fishery, the centre observes that the impacts from Option 1 are much the same as currently. In the case of decommissioning, the impacts on fishery are positive, as the adverse factors will cease to exist. In the centre’s opinion, the soil and bedrock have been discussed adequately in the report, and the assessment corresponds to the centre’s understanding. Areas with contaminated soil must be determined well in advance before initiating construction and demolition work. Plans must be made for the handling of contaminated soil, which may be found in connection with demolition work. The sources

8 (22) for soil, bedrock and groundwater models have been added appropriately to the report. Adequate seabed surveys have been conducted to determine the state of soil layers and sediments. According to the centre, noise and vibration have been analysed in sufficient detail. The assessed significance of the impacts resulting from different options is most likely correct, assuming that the adverse effects are mitigated adequately. The centre expects noise disturbance to occur especially during demolition, making it important to mitigate noise and vibration nuisance due to the long duration of demolition and the proximity of holiday housing. Measures for mitigating adverse effects are discussed in parts in the report. In the centre’s view, in addition to adopting noise control measures, the noisiest work should be scheduled outside nesting and holiday seasons. Impacts on nature have been discussed appropriately, and the most significant impacts have been addressed. The centre emphasises the importance of monitoring the quality of seawater to follow developments related to non-native species. Condensed waters pose the risk of introduction and spread of non-native species. The report contains a sufficient review of traffic impacts. If the power plant is decommissioned, road transport routes must be planned carefully. Sea transports of nuclear waste do not cause nearly as many adverse traffic impacts as road transports. Concerning land use planning, the centre observes that the Helsinki-Uusimaa Land Use Plan 2050 has entered into force insofar as the appeals filed on it were dismissed by the Administrative Court. The parts of the previous regional land use plans that remain in force are the Natura 2000 sites marked in the Uusimaa regional land use plan and the phased regional land use plan 2, as well as the wind power solution, Natura 2000 sites and nature reserves marked in the phased regional land use plan 4. The regional land use plan for Östersundom also remains in force. The Helsinki-Uusimaa Regional Council commented on the regional land use plan valid in the project area and on the region’s climate goals. The council found the impact assessment to be comprehensive and did not have any remarks on the conclusions. According to the council, the report provides an accurate description of the regional land use plan’s steering role. In its previous statement, the council found that the options presented comply with the valid regional land use plans and the phased regional land use plan for Eastern Uusimaa approved by the regional council. After the statement had been submitted, the Helsinki Administrative Court stayed the implementation of the phased land use plan based on the appeals filed, which did not, however, concern the Loviisa nuclear power plant. The plan has later entered into force on most parts. The final decision on the matter will be made by the Supreme Court. The Helsinki-Uusimaa Regional Council does not find reason to change its views expressed in the previous statement based on these events. According to the Helsinki-Uusimaa Regional Council, of the options examined in the assessment procedure, the extension of operations would best help achieve the general provision of transitioning to a climate sustainable energy system included in the phased regional land use plan for Eastern Uusimaa. Furthermore, the Regional Council believes that continuing operations at the nuclear power plant will support the Uusimaa region achieve its goal of carbon neutrality by 2035. The Ministry of Transport and Communications, Ministry of the Interior, Ministry for Foreign Affairs, Ministry of the Environment, Finnish Safety and Chemicals Agency and the Finnish Environment Institute announced they did not have any remarks on the matter.

2.2.2 Statements by other countries and authorities

Austria indicated its interest in continued consultations in accordance with Article 5 of the Espoo Convention and Article 7 of the EIA Directive. The response submitted by the Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology included an appendix with an expert statement from the environment agency, containing 39 questions related to the assessment procedure. The Ministry of Economic Affairs and Employment prepared answers to the questions in cooperation with the project owner and STUK. The ministry will take Austria’s final statement into account in the further stages, as required.

9 (22) The Lithuanian Ministry of Environment did not have any remarks on the report but requested the ministry to submit further information on some aspects. The Ministry of Economic Affairs and Employment prepared answers to the questions in cooperation with the project owner and STUK. The Swedish Environmental Protection Agency organised consultations in accordance with the Espoo Convention, which resulted in statements from the Swedish Board of Agriculture (Jordbruksverket) and Sami Parliament (Sametinget). The Board of Agriculture is of the opinion that transboundary impacts affecting Sweden can only occur as a result of a severe reactor accident. According to the board, the report should address a more severe accident, whose fallout and impacts on Swedish agriculture and forestry would be modelled for various weather conditions. The Sami Parliament observed that their previous statement has been taken into account in the procedure. In terms of reindeer husbandry, the plant’s decommissioning poses fewer risks and is thus the best option for the future. The Estonian Environment Agency believes that the report’s accident modelling should be more conservative and that higher values should be used in it. In many drills, the emissions of the radionuclide Caesium-137 (Cs-137) are around 2%, which would lead to emissions of some 3,300 TBq in the case of Loviisa nuclear power plant. The section on transboundary impacts and their mitigation should indicate the party responsible for carrying out the measures. The Netherlands, Norway, Germany, Denmark and Russia had no remarks on the report. The German state of Mecklenburg-Vorpommer referred to its statement provided during the programme stage, in which it supported the plant’s decommissioning.

2.2.3 Statements by private persons, organisations and companies

Atomstopp atomkraftfrei leben!, an Austrian organisation, expressed its disappointment in the arrangements of the consultation and hearing. In the organisation’s view, alternative forms of energy should have been presented in the environmental impact assessment report. Based on flexRISK calculations determining the impacts of a severe reactor accident in Europe, the organisation observes that under unfavourable weather conditions, a severe reactor accident at the Loviisa power plant would result in substantial contamination in nearly all European countries. The organisation is also of the view that the nuclear waste management solutions have not been criticised or tested in practice. Similar statements were submitted by the organisations Anti atom komitee, Wiener Platform Atomkraftfrei, Nuclear Transparency Watch, Friends of the Earth Austria and Friends of the Earth Europe. Organisations from the Czech Republic, Poland and Bulgaria also contributed to the statement of the last of these. Ekoenergo Oy is in favour of extending the service life of the Loviisa power plant on the basis of the need for domestic electricity and on carbon dioxide emissions. The company proposes using waste heat from the plant for heating in Helsinki. Extending the plant’s service life has a greater impact on Finnish carbon dioxide emissions than any other single measure. Fennovoima Ltd observes that the Loviisa nuclear power plant plays a significant role in Finland’s electricity production, energy self-sufficiency and low carbon goals. The company hopes to see an extension to the plant’s service life and says it trusts the authorities’ ability to assess the safety of operations. Fennovoima appreciates that the report discusses the option of the Loviisa power plant receiving and processing radioactive waste generated elsewhere in Finland as well as accepting such waste for interim storage or final disposal. Fingrid Oyj observes that Finnish electricity production is changing rapidly and that it is increasingly being located in northern Finland. In view of the Finnish power system, the decommissioning of the Loviisa power plant would increase the pressure to invest in north-south power transmission links and would probably make it difficult to maintain mainland Finland as a harmonised bidding zone for electricity trading. Decommissioning would most likely have short-term adverse impacts on Finland’s self- sufficiency in electricity production and the adequacy of electrical power, especially in the winter. According to the Swedish organisation Folkkampanjen mot Kärnkraft-Kärnvapen, the Loviisa power plant should be closed as soon as possible. In the organisation’s opinion, radioactive emissions are

10 (22) hazardous to humans and other organisms. The risks of ageing continue to increase. Moreover, the L/ILW repository should be moved away from the coast to prevent radioactive substances entering the sea. According to the organisation, the final disposal of spent fuel is not safe, in addition to which nuclear energy and the use of uranium have a negative impact on the climate. The Swedish organisation Miljövänner for kärnkraft considers that, based on the environmental impact assessment and other experiences, extending the operations of the Loviisa power plant units will not cause environmental impacts within Sweden’s borders. International experiences show that the service life of reactors that have been well maintained and designed in compliance with Western safety standards can be extended to at least 60 years. According to the organisation, the Loviisa nuclear power plant plays an important part in the achievement of Finland’s and the EU’s climate goals. According to the organisations Naiset Atomivoimaa Vastaan & Naiset Rauhan Puolesta, extending the plant’s service life does not promote the overall benefit of citizens, but is based on nuclear power companies’ pursuit of financial gains. The organisations are of the opinion that the Loviisa reactors do not comply with the standards for new reactors and their ageing poses additional risks. Several countries in Western Europe are shutting down nuclear energy, citing the safety risks and expenses involved, which is why Fortum should also give up its plans to extend the service life of the reactors. Nuclear energy use has a negative impact on Finland’s image as a country. The organisations demand that the ministry acquaints itself with, for example, the statements of German authorities and other reports dealing with nuclear energy and sustainability. According to the organisations, the ministry should consider nuclear energy at large instead of focusing only on extending the service life of the Loviisa reactors. The ministry must not permit the extension to the service life of the reactors. Instead of nuclear energy, assets should be allocated to renewable energy production, hydrogen technology and the decommissioning of reactors. The statements also take a stand on the safety of final disposal of nuclear waste. In the organisations’ view, the ministry should urge Fortum to address the ethical aspects of final disposal. In terms of environmental impacts, the organisations point to the impacts that water consumption and cooling water have on, for example, the oxygen concentration of water bodies. Emissions of tritium are also of concern to health and safety. According to the organisations, the plans for extending the plant’s service life do not take the EU’s BAT principle into consideration. Social-Ecological Union and nine other Russian non-governmental organisations have signed a statement opposing the extension of the plant’s service life. The organisations point out that extending the operations of the ageing plant, whose original service life was 30 years, poses a serious threat to countries around the Baltic Sea. The organisations refer to the flexRISK study and its findings that the impacts of an accident could extend to St Petersburg.

The Finnish Confederation of Professionals (STTK) observes that the radiation exposure of employees is the most significant environmental risk from nuclear energy. Employees’ health and safety must be ensured. STTK considers the assessment to be adequate and carefully prepared and the basis for supporting the extension of the plant’s service life. According to the Uusimaa district organisation of the Finnish Association for Nature Conservation, the environmental impact assessment report is deficient and needs to be supplemented. Under the Water Framework Directive, the project is not allowed to weaken the state of water bodies. The state of Klobbfjärden is bad. The organisation is therefore of the opinion that the plant violates the Water Framework Directive. The report should have included options for reducing the thermal load on the sea and mitigating other impacts on the state of water bodies. The organisation provides examples of mitigation measures specified in the conditions of environmental permits for bioproduct mills, which it believes should also be required of the Loviisa nuclear power plant. According to the organisation, the best available technology should also be employed to prevent fish and other organisms from ending up in the cooling system. A more severe accident should be included in the report’s analysis, and the assessment should be expanded concerning, for example, substances released into the sea and crisis situations. The impacts of nuclear fuel procurement, the final disposal of nuclear waste and waste cleared from regulatory

11 (22) control have not been discussed adequately. Chemicals released into the sea and their impacts have not been handled in the report. According to the organisation’s statement, the consultants who prepared the report are not knowledgeable about the impacts of radioactive substances. In addition, the authorities should also contribute with their expertise in the field. The lack of competence in environmental science has caused problems in the licence procedures for nuclear power plants. VTT Technical Research Centre of Finland does not have any objections to the assessment, but it wishes to point out that VTT has a new operating licence for the FiR 1 research reactor granted by the government on 17 June 2021, which is valid until the end of 2030. Regarding waste generated elsewhere in Finland, the report takes into account the waste generated by the FiR 1 research reactor and the Otakaari 3 research laboratory, as well as waste generated during the operation and dismantling of the new VTT Centre for Nuclear Safety. VTT reiterates the observation expressed in the earlier statement that nuclear energy is free of carbon dioxide emissions. Therefore, it is good in terms of both national and international climate goals to consider an extension to the plant’s operations. VTT still considers it excellent that preparations are made to use the L/ILW repository for the final disposal of radioactive waste from other parts of Finland. This is very positive from the national perspective of radioactive waste management. Wiener Umweltanwaltschaft, from Austria, opposes the continued use of the power plant due to the outdated technology. A total of six statements were received from private individuals, one of which was signed by two people. The content of the first statement corresponded to the statement submitted by Ekoenergo Oy. The statement supported the extension of the Loviisa power plant’s operations citing Finland’s need for electricity and the goal of reducing carbon dioxide emissions. It also proposed using waste heat for heating in Helsinki. Another statement proposed specifications to the state of nutrients and algal growth in the sea as well as the impacts of the condensed water cycle. This topic was discussed at the public hearing, where the statement provider pointed out that condensed water extracted from deeper down contains more nutrients compared to surface waters, which might have an impact on eutrophication on the discharge side. As stated at the hearing, the question has been examined indirectly by comparing the properties of the discharge side with adjacent sea areas. No significant differences were observed between the areas. The statement provider adds that, due to the fast flow of condensed water, the impacts show up farther away from Hästholmsfjärden. Algal growth is substantial especially northwest and north of the islands on the western side of Hudö bay. Since the emissions from the Loviisa wastewater treatment plant also have an impact on the situation in the area, this is a case of combined effects. However, the impact of condensed water on this has not been examined. In the following statement, citizens 3 and 4 refer to the decision issued on 17 December 2020 by the Uusimaa Centre for Economic Development, Transport and the Environment, which requires Fortum to add and inspect monitoring points in areas where thermal emissions from the plant can justifiably be expected to increase eutrophication. This applies especially to the area bounded by the mainland, Kirmosund, Hästholmen, Åmusholmen and Abborrgrundsudden. According to the statement, the eutrophic impact of condensed water has not ended and continues to cause harm to real estate owners. The statement providers also refer to their statement concerning the impact assessment programme, where, among other things, they brought up the decision by the Supreme Administrative Court (508/2017) ordering Fortum to pay compensation for hindrances to recreational use to owners of beach properties in the area. The fifth statement signed by a private individual and submitted from Germany brought up many of the same considerations as the statements of, for example, the Atomstopp atomkraftfrei leben! organisation.

Citizen number 6 from Austria opposes the extended use of the Loviisa power plant and the use of all other nuclear power plants. They discuss the impacts of the Chernobyl nuclear power plant accident (also in Finland). Citizen number 7 discusses the embrittlement of reactor pressure vessels, which they consider a systematic error in plants of the kind built in Loviisa. Overall, they consider it impossible to

12 (22) extend the service life of the old power plant. According to the statement, the information provided on decommissioning is inadequate.

3 The adequacy and quality of the assessment report

As the coordinating authority for the EIA procedure, the Ministry of Economic Affairs and Employment has reviewed the adequacy and quality of the assessment report and is of the following opinion in this respect: The report on the environmental impact assessment of the Loviisa nuclear power plant prepared by Fortum meets the content requirements specified in section 19 of the EIA Act (252/2017) and in the EIA Decree (277/2017), and it has been handled in compliance with EIA legislation. The assessment report has been drawn up with consideration to the project’s assessment programme and the related statement issued by the coordinating authority. The project owner has had at its disposal adequate expertise for assessing environmental impacts and carrying out separate reviews. The assessment report is comprehensive and has been carefully prepared. An adequate number of options have been presented for the project. The assessment of environmental impacts came up with no aspects which could not be reduced to an acceptable level and which would prevent the implementation of any of the options. Comparisons of the project’s environmental impacts and the different options will be discussed in the following section. However, based on the analysis of the Ministry of Economic Affairs and Employment and the statements and opinions received, the assessment could have been more specific in certain respects. Some of the comments presented must be taken into account in further project planning.

3.1 Impacts on surface waters

The thermal load caused by the discharge of condensed water in the nearby sea area is one of the most significant environmental impacts of the nuclear power plant’s operations. The condensed water is taken from Hudöfjärden, located west of Hästholmen, and discharged into Hästholmsfjärden, east of the plant. The assessment programme proposed hydraulic works related to the continued use of the plant, which aimed at extracting cooler water than currently. This would lower the temperature of the discharged cooling water and increase the electrical power of the plant. Hydraulic works are not discussed in the assessment report, as the project owner decided to give up the plans, citing the results of technical and financial surveys carried out by it. In its statement, the Uusimaa Centre for Economic Development, Transport and the Environment was of the opinion that the topic should have been discussed as part of the assessment and that it should be specified during further planning. According to the Uusimaa Centre for Economic Development, Transport and the Environment, the impact that continued operations will have on the state of water bodies and the need to mitigate the adverse effects should have been examined in greater detail. The impacts of mitigation measures should have been compared to the water resources management plan. According to the centre, impacts on the state of water bodies could be mitigated by adopting measures to reduce diffuse pollution. A discussion of measures aimed at mitigating the impacts on fish and water bodies was also called for in the statement submitted by the Finnish Association for Nature Conservation. Two statements signed by private individuals raised the impact that thermal load can have on the eutrophication of water bodies. The Centre for Economic Development, Transport and the Environment also requires specifications to the assessment of impacts on the marine strategy and the state of the sea. The impacts of the different options on the state of surface waters should have been compared more clearly over the entire planned period. The Ministry of Economic Affairs and Employment finds that the assessment of impacts on surface waters and the discussion of the mitigating measures are adequate at this stage of project planning, but must be specified in the future. Under EIA legislation, the project owner is required to examine reasonable options for the project and propose measures to avoid, prevent, restrict or eliminate identified substantial and adverse

13 (22) environmental impacts. The project owner gave up plans for hydraulic works soon after the programme stage. In the opinion of the Ministry of Economic Affairs and Employment, although a comprehensive treatment of mitigating measures is a crucial part of the EIA procedure, the project owner cannot be required to analyse an option that it is not seriously considering. However, the project owner explores other ways of obtaining colder cooling water in connection with its normal research concerning the power plant’s operations. Hästholmsfjärden is part of the Klobbfjärden body of water, the ecological status of which has been found to be bad in the third water resources management planning period (2022–2027). Owing to the status of the body of water, the project must not degrade the status or adversely affect factors influencing it. Given that the status of the water body is bad, it is important that Fortum takes part in planning measures to improve the state of waters jointly with the Uusimaa Centre for Economic Development, Transport and the Environment and the City of Loviisa. One example of such cooperation could be the preparation of a rehabilitation plan for the body of water and participation in its implementation.

3.2 Impacts on the soil, bedrock and groundwater

The decommissioning stage encompasses the final disposal of radioactive decommissioning waste in the L/ILW repository’s present facilities and any new facilities built as required. In its statement, Geological Survey of Finland remarks that the potential impact that the extension may have on local groundwater conditions should be explored in greater detail. Based on the information presented in the assessment programme, Geological Survey of Finland believes that the monitoring of the fresh-saline water interface should not have been discontinued in 2015. It also believes it is important to ensure that the project owner has a good understanding of the area’s groundwater system. However, the Uusimaa Centre for Economic Development, Transport and the Environment finds that the discussion of the soil, bedrock and groundwater is sufficient. The sources for soil, bedrock and groundwater models have been added appropriately to the report. In the opinion of the Ministry of Economic Affairs and Employment, Fortum must in its further project planning focus attention on any local groundwater impacts resulting from the extension of the L/ILW repository and take into account the role of waste in terms of safety.

3.3 Impacts on the climate

According to the assessment report, the positive impacts of continued use of the plant are reasonably significant, as nuclear power plant operations do not generate greenhouse gas emissions. In the case of decommissioning, the climate impacts were assessed to be reasonably significant, but negative. Emissions from traffic and stand-by generators have been taken into account in the assessment of direct climate impacts. The discussion of the lifecycle emissions of nuclear energy is based on international studies, and in connection with decommissioning, the replacement of nuclear energy has been discussed briefly. According to the Uusimaa Centre for Economic Development, Transport and the Environment, the conclusions of the analysis of climate impacts appear to be accurate, although the analysis is lacking in parts. The uncertainties related to the assessment and the mitigating measures should have been discussed in greater detail. The direct climate impacts from operations and decommissioning in the different options could have been discussed separately from indirect climate impacts related to electricity. For example, the report did not contain a detailed analysis of the climate impacts from the construction of new buildings or from the dismantling of the plant. According to the centre, research related to climate change must be followed in the future and the resulting information must be used to improve the safety of the plant, as described in the report. Many other statements highlighted the role of the Loviisa nuclear power plant in generating energy free from greenhouse gas emissions, but no additional remarks concerning the assessment were brought up. According to the organisations Naiset Atomivoimaa Vastaan and Naiset Rauhan Puolesta from Finland and Folkkampanjen mot Kärnkraft-Kärnvapen from Sweden, nuclear energy does not help curb climate change. The Ministry of Economic Affairs and Employment agrees with the observations that the Centre for Economic Development, Transport and the Environment has made concerning the assessment of

14 (22) impacts on the climate. Nevertheless, the conclusions drawn in the report are appropriate and adequate at this stage. The fact that the generated electricity is free from greenhouse gas emissions is clearly more significant than the project’s direct climate impacts.

3.4 Impacts of a severe reactor accident

The Swedish Board of Agriculture, the Estonian Environment Agency, the Austrian Ministry for the Environment, several non-governmental organisations and one private individual believe that a larger source term should have been used to model a severe reactor accident. The Estonian Environment Agency also found that the section on transboundary impacts and their mitigation should have indicated the party responsible for carrying out the measures. The Ministry of Economic Affairs and Employment states that in Finland, section 22b of the Nuclear Energy Decree (161/1988) sets the limit for a large emission at 100 TBq for Caesium-137 emissions, and this limit has generally been used as the source term for Finnish assessments of environmental impacts. In the report’s accident modelling, other radionuclides are expected to be released in the same proportion assumed for Caesium-137. The area examined in the modelling extends 1,000 kilometres from the power plant. The impacts of accidents at the plant reviewed have been compared to those of the severe reactor accidents at Fukushima and Chernobyl. At the EIA programme stage, the ministry required that a more realistic case of accident for the plant in question be included in the EIA report. As concerns the plant’s extended use (VE1), the report analyses an accident involving a large run-time leak from the primary circuit to the secondary circuit. This case covers a wide range of interference and accident situations related to nuclear power plants, with impacts that are either milder than or of the same size as the case analysed. In addition to reactor accidents, the report deals with other emergency situations, such as fires or transport-related risks, as well as conventional environmental and safety risks. The Ministry of Economic Affairs and Employment is of the opinion that the project owner has addressed the matters required at the programme stage. The analysis is comprehensive and adequate at this stage. The Radiation and Nuclear Safety Authority STUK will assess the nuclear power plant’s safety later, in connection with any application for an operating licence.

3.5 Other remarks expressed in the statements

In their statements, several international non-governmental organisations and one private individual expressed the wish that the presentations of the public event were translated into English or that another event were organised for an international audience. The statements cited the Espoo and Aarhus Conventions. According to the Ministry of Economic Affairs and Employment, in connection with EIA procedures, it has been common practice to organise public events targeted mainly for local residents. Based on feedback from the public, the participants at the event held on 7 October 2021 were prepared to also answer English-language questions, in addition to which the slides related to the hearing process, for example, were available in English. All the information disclosed at the event was based on the EIA report, which was also available in English. The website of the Ministry of Economic Affairs and Employment is also available in English. Everyone has had an equal opportunity to participate in the hearing by means of a statement. The ministry also points out that experts respond to any questions concerning the EIA procedure by email. The remarks expressed in the other statements and opinions received by the ministry mainly concerned further project planning, such as preparations for decommissioning or the general acceptability of nuclear energy. Ekoenergo Oy and one private individual brought up the possibility of utilising waste heat from the plant. The

Ministry of Economic Affairs and Employment notes that the company has informed it that it is not planning this option at the moment, which is why the question has not been handled in the report.

15 (22) Furthermore, several organisations offered their opinions on the extended use of nuclear energy, the safety of final disposal of nuclear waste and radioactive emissions. To this, the Ministry of Economic Affairs and Employment responds that the Radiation and Nuclear Safety Authority STUK will assess the project’s safety later in connection with any application for an operating licence. The safety of the final disposal of spent nuclear waste will be assessed in connection with the operating licence for Posiva’s final disposal facility.

4 The reasoned conclusion of the coordinating authority

The reasoned conclusion of the coordinating authority is based on the content requirements for the assessment report specified in section 19 of the Act on the Environmental Impact Assessment Procedure (252/2017) and section 4 of the Government Decree on the Environmental Impact Assessment Procedure (277/2017), the project description and surveys discussed in the assessment report, the survey results and their analysis, as well as the content of statements and opinions submitted. The coordinating authority’s reasoned conclusion must be included in the licence decision in accordance with section 26 of the EIA Act. The licence decision must indicate how the assessment report and the reasoned conclusion have been taken into consideration. In the opinion of the Ministry of Economic Affairs and Employment, the options presented do not pose the kind of harmful environmental impacts that would be impossible to accept, prevent or mitigate to an acceptable level. The ministry has organised its analysis of the impacts of the different options according to the potential licences required under the Nuclear Energy Act. In all the options, the L/ILW repository calls for an operating licence separate from the power plant units, which is why the repository’s impacts are discussed separately. The report provides an adequate comparison of the different options. Overall, the environmental impacts of continued operations (VE1) are larger than those resulting from decommissioning (VE0 or VE0+), as the plant must be ultimately decommissioned even if its operations are extended for now. However, when assessing the environmental impacts of the different project options, attention must also be focused on the project’s significance to the energy economy, which is considerable on a national level. The processing, storage and final disposal of waste generated elsewhere in Finland do not pose significant environmental impacts. However, the management of such waste would have a positive impact on the national management of radioactive waste overall, as it would contribute to the sustainable and safe final disposal of radioactive waste, regardless of the source of waste. The maximum volume of such waste handled at the Loviisa power plant is estimated to be 2,000 m3. The figure is small compared to the waste generated at the nuclear power plant.

4.1 Significant environmental impacts from extended operations (VE1)

Under this option, the use of the Loviisa nuclear power plant would be extended to around 2050. The impacts on the environment will remain mainly the same as currently. The thermal load to the nearby sea area resulting from the discharge of cooling water is the most significant environmental impact from the facility’s normal operations. Significant environmental impacts target surface waters, as well as fish and fishery, the climate, people’s living conditions and comfort, community structure and tangible property. Environmental impacts may also result from accidents. The plant’s extended use increases the overall volume of spent nuclear fuel and other nuclear waste. All the environmental impacts from decommissioning must also be taken into account in this option. If the operations are extended, the plant units will be decommissioned in 2050–2060.

4.1.1 Surface waters

In the case of extended plant operations, the impacts on surface waters resulting from the intake and discharge of cooling water will remain much the same as currently. The condensed water is taken from Hudöfjärden, located west of Hästholmen, and discharged into Hästholmsfjärden, east of the plant. In the assessment report, the project’s impact on Hästholmsfjärden has been estimated as being reasonably

16 (22) significant and negative. According to the assessment, the overall impact on other parts of the sea area is minor and negative or negligible. The Ministry of Economic Affairs and Employment considers this assessment is likely to be accurate. The discharge of cooling water has a direct impact on, for example, water temperature, stratification and ice conditions. The assessment also addresses climate change, which may contribute to a temperature increase in the surface sea water in the coming decades. In addition to the thermal load from cooling water, the state of water bodies is also affected by the nutrient input mainly attributed to non-point source pollution carried by river waters. The sanitary wastewaters from the Loviisa power plant also carry small amounts of nutrients into the sea. As stated in the assessment report, the thermal load of cooling water has contributed to accelerated eutrophication in the area. The increase in eutrophication has been more notable in Hästholmsfjärden than at the nearby comparison station in Hudöfjärden. Several other chains of causation have also been assessed in the procedure. Thermal load further weakens the poor oxygenation conditions of the seabed and thus affects the benthic fauna, which has declined. Phytoplankton and aquatic flora are also affected, in addition to which warmer seawater may favour non-native species such as the dark false mussel. As observed by the Ministry of Economic Affairs and Employment, the impact of cooling water is particularly significant due to the sensitivity of the affected area. Hästholmsfjärden is part of the Klobbfjärden body of water, the ecological status of which has been found to be bad in the third water resources management planning period (2022–2027). The classification is based on the EU Water Framework Directive and the Act on the Organisation of River Basin Management and the Marine Strategy (1299/2004). The goal of legislation is to achieve a good environmental status for all water bodies. The project assessed must not weaken the ecological or chemical status of the bodies of surface water or endanger the achievement of a good status of surface waters. The report states that a continued thermal impact may contribute to a slower achievement of a good status for the water body. The Ministry of Economic Affairs and Employment requires this to be taken into account in further project planning. According to the report, the continued thermal impact from cooling water will continue to no later than 2050. The impact of the end to the thermal load caused by the power plant is discussed in connection with the impacts from decommissioning. Uncertainties concerning the assessment include those related to climate change and nutrient input and the complexity of interactions in the environment.

4.1.2 Fish and fishing

The impact of the power plant’s extended operations is assessed to be moderately negative on fish and minor and negative on fishing. Warmer sea water favours species that have adapted to it, including pike- perch and cyprinids. The round goby, a non-native species, is also likely to become more abundant. Moreover, warm water will prevent the formation of ice, hampering the reproduction of species spawning under ice, such as the burbot, and making winter fishing more difficult. Biomass carried to the power plant with the cooling water intake consists mainly of fish. The amount of fish carried to the plant has been 10–25 tonnes annually. The collection of this biomass can be seen as having a positive impact, as it also removes nutrients from the sea.

4.1.3 Greenhouse gas emissions and climate change

According to the assessment, the climate impacts of extended plant operations are moderate and positive. The direct greenhouse gas emissions are small compared to the impacts of carbon-free energy production, which are significant for all of Finland. Finland has set itself the goal of carbon neutrality by 2035, which requires an increased production of emissions-free energy.

4.1.4 People’s living conditions and comfort, community structure, tangible property

The project owner has assessed the project’s impacts on people’s living conditions and comfort, as well as on the energy market, security of supply and regional economy. While EIA legislation does not require

17 (22) the energy market, security of supply and regional economy to be assessed, the Ministry of Economic Affairs and Employment considers these as significant socio-economic impacts. The project’s impacts on the energy economy were also highlighted in the statements received and during the programme stage of the procedure, when several statement providers as well as the Ministry of Economic Affairs and Employment called for a review of developments in the electricity market. According to the assessment, the impact of extended operations on people’s living conditions and comfort is minor but negative. Residents in the nearby areas feel more negative about the nuclear power plant operations than people living farther away. Among other things, the power plant is considered as having negative impacts on the landscape and recreational use of water bodies. Risks related to nuclear power plant operations may be of concern farther away. The resident survey indicated a negative attitude to the reception of waste generated elsewhere in Finland. On the other hand, potential positive impacts on the region’s employment and demographics were also raised. The extension of operations is estimated to have a large and significant impact on the Finnish energy market and security of supply. This estimate is based on the increased demand for emissions-free electricity available regardless of weather conditions. In 2020, the output from the Loviisa nuclear power plant was 7.8 TWh, while the overall demand for electricity in Finland totalled 80.9 TWh. The impact on the regional economy is assessed to be very large and positive in the Loviisa sub-regional unit, moderately positive in Eastern Uusimaa and Kymenlaakso, and minor and positive for the entire country. The impact is based on, for example, the power plant’s direct impacts on employment and the multiplicative effects of maintenance investments and procurement during operations.

4.1.5 Radioactive waste and waste management

Extending the power plant’s service life will increase the accumulation of spent nuclear fuel and the overall volume of low and intermediate-level waste Nevertheless, the impacts of extended operations on waste management have been assessed to be minor and negative. This result is based on the number of fuel bundles expected to increase by approximately 3,700 if operations are continued for another 20 years. The accumulated volume of low-level waste is expected to total around 600 m3 and that of intermediate-level waste around 2,400 m3 packaged. The management of low and intermediate-level waste will continue in the same way as under the currently valid operating licences. The final disposal of accumulated spent nuclear fuel will be handled in accordance with the existing plans of Posiva Oy. The main change resulting from the power plant’s extended use comes from the increase in storage capacity for spent nuclear fuel, which would take place through an expansion of the interim stockpile or by placing nuclear fuel in intermediate storage tanks more frequently. The cooling need for spent nuclear fuel in the intermediate storage facility is not expected to increase significantly, despite the increasing amount of fuel, as the fuel thermal output is constantly decreasing during intermediate storage. However, it is possible to increase the cooling capacity if necessary.

4.1.1 Severe reactor accident and other exceptional situations and accidents

Although a reactor accident is highly unlikely, were such an accident to take place, it would have exceptionally wide and long-term impacts. The report contains modelling of an accident in which 100 TBq Cs-137 nuclides and other radionuclides in the same proportion are released into the atmosphere. Such a case would most likely not cause direct radiation impacts on humans, but the area within a five- kilometre radius would have to be evacuated or people would be required to seek shelter indoors. The impact of emergency measures has not been taken into account in the estimated doses. At the local and regional level, the use of soil, water bodies and foodstuffs may be restricted due to radioactive fallout. Such an accident and its management would also have very significant impacts on the national level. Long-term impacts would affect the population’s material and mental wellbeing, for example. A reactor accident of the kind modelled in the report would not lead to direct health impacts caused by radiation doses outside Finland. In addition to a severe reactor accident, the report examines less severe incidents, which may cause radioactive emissions, as well as conventional emergency situations and accidents. Preparations for climate change have been taken into account in the assessment.

18 (22) 4.2 Significant environmental impacts from decommissioning (VE0, VE0+)

Decommissioning comprises several stages. After the preparatory stage, which lasts for around three years, the radioactive parts of the plant units will be dismantled, and the resulting radioactive waste will be deposited in the I/ILW repository. The required waste management functions will be made independent of the rest. Their independent use will last for 20–35 years, after which they will be dismantled. Environmental impacts will result from the impacts of operations coming to an end, as well as from the direct impacts of decommissioning. The most significant environmental impacts are related to the elimination of the thermal load caused by cooling water. Negative impacts on the climate and energy markets will emerge at least if the power plant is decommissioned after the current operating period. The direct negative impacts of decommissioning include traffic and noise impacts and the generation of decommissioning waste. According to the company’s estimates, handling decommissioning according to the greenfield principle will have fewer long-term adverse environmental impacts on nature, the landscape and the comfort of living compared to the brownfield principle. However, decommissioning based on the greenfield principle will have more adverse impacts during dismantling. If the power plant’s operations are not extended after the currently valid licence periods, the units will be decommissioned in 2030–2040. If the operations are extended, the plant units will be decommissioned in 2050–2060.

4.2.1 Surface waters

Decommissioning would have a moderately positive impact on Hästholmsfjärden and a minor positive impact or negligible impact on the other nearby sea areas. Decommissioning will mean an end to the thermal load from cooling water, returning the temperature and stratification of the sea area back to normal and bringing an end to the negative impacts on water quality, phytoplankton, aquatic flora and benthic fauna. The positive impacts are surrounded by some uncertainty regarding the oxygenation conditions of deep basins. As stated in the assessment report, the rate of recovery is difficult to predict.

4.2.2 Fish and fishing

In the case of decommissioning, the thermal load from cooling water will end, enabling fish and fishing to recover and begin to resemble the conditions in the surrounding sea areas. In Lappomträsket lake, potential deregulation would enable the current dam structure to be replaced with a submerged weir, thus opening a migration route for fish. On the other hand, deregulation and the discontinuation of the lake’s oxygenation might have a negative impact on fish. The assessment involves uncertainties in this respect. The impact is assessed to be moderately positive on fish, and minor and positive on fishing.

4.2.3 Greenhouse gas emissions and climate change

According to the assessment, decommissioning that takes place after the current operating period will have a moderately negative impact on the climate. The assessment is based on the need to replace the electricity production in Loviisa with other forms of production, the emissions of which depend on the method of production. Alternative production methods are discussed at a general level. Decommissioning also generates greenhouse gas emissions, such as those due to increased traffic, but these are insignificant compared to the potential impact of electricity production.

4.2.4 People’s living conditions and comfort, community structure, tangible property

The project owner has assessed the project’s impacts on people’s living conditions and comfort, as well as on the energy market, security of supply and regional economy. During demolition, decommissioning is expected to have moderately negative impacts on people’s living conditions and comfort due to, for example, increased noise, vibration and traffic. In the long term, however, the impacts are expected to be minor and positive following the potential recovery of the water bodies and landscaping. Respondents to the resident survey had a negative attitude to the reception of waste generated elsewhere in Finland.

19 (22) According to the assessment, decommissioning has significant negative impacts on the energy market and security of supply. Electricity generated at the nuclear power plant must be replaced with new production, in addition to which more north-south transmission links will be needed. The positive impact of final decommissioning on the regional economy is assessed to be large in the Loviisa sub-regional unit. In Eastern Uusimaa, Kymenlaakso and at the level of all of Finland, the impact on the economy is minor and positive. This impact results from, for example, an increase in the demand for material recycling and dismantling services. However, the economic impacts generated during operations will end.

4.2.1 Landscape and cultural environment

The impacts of decommissioning on the landscape and cultural environment depend on whether the deregulated buildings are left in place or whether they are dismantled. If the buildings are not fully dismantled, the impact is minor and positive. The dismantling of high buildings will also mitigate landscape impacts in dismantling carried out on the basis of the brownfield principle. Dismantling based on the greenfield principle will leave the area as close as possible to its natural state, which will eliminate all long-term landscape impacts. In this case, the impact is assessed to be moderately positive. Before the buildings are dismantled, a historic building survey must be carried out on the area’s building stock.

4.2.2 Traffic

Traffic will increase especially during the dismantling work related to decommissioning, and these impacts are assessed to be moderately negative. The smooth flow of traffic may occasionally suffer on Atomitie and Saaristotie, and the increase in traffic will raise the risk to traffic safety.

4.2.3 Noise

Noise disturbance may be felt especially during the dismantling phase. If the plant is decommissioned according to the greenfield principle, noise will be caused especially by conventional dismantling work. The occasional concrete crushing will make the loudest noise, which may be carried to the holiday homes on the nearby islands and the mainland. According to the assessment, the impact of noise disturbance is minor and negative. It is important to reduce disturbance from noise, for example, by timing the noisiest work appropriately.

4.2.4 Radioactive waste and waste management

The dismantling phase of decommissioning is expected to generate 3,300 m3 activated waste and 19,000 m3 of contaminated waste. An estimated 700 m3 of maintenance waste and other waste packaged in barrels, as well as 2,260 m3 of solidified liquid waste will be generated. According to the project owner’s assessment, the impacts of decommissioning on waste and waste treatment are minor and negative. The Ministry of Economic Affairs and Employment observes that the dismantling of the power plant will generate a considerable amount of radioactive waste. The final disposal of radioactive waste calls for a considerable extension of the L/ILW repository. Soil contamination must also be assessed in connection with dismantling and conventional waste must be treated appropriately.

4.2.5 Severe reactor accident and other exceptional situations and accidents

The nuclear power plant’s risk level will drop considerably when it is decommissioned. However, the risks related to the treatment, storage and transport of spent nuclear fuel and other radioactive substances will continue until all the waste has been deposited in final disposal. Dismantling also involves risks of radiation exposure. In addition, decommissioning involves risks of conventional accidents. The Radiation and Nuclear Safety Authority STUK will assess the safety of decommissioning later, when the company applies for a licence to decommission the nuclear power plant.

20 (22) 4.3 Significant environmental impacts from the expansion of the L/ILW repository (VE1, VE0,

VE0+)

The L/ILW repository will be used for the final disposal of low and intermediate-level nuclear waste generated during the nuclear power plant’s operations and decommissioning. According to estimates, the repository’s present capacity can also accommodate the low and intermediate-level waste generated during extended power plant operations, should this option be chosen. According to plans, the L/ILW repository will be expanded to accommodate decommissioning waste. The expansion is included in every option presented in the assessment report. If the operations of the power plant units are extended, the L/ILW repository will be closed by 2090. If the plants are decommissioned after the end of the current operating licence period, the repository will be closed by 2065. Prior to this, the L/ILW repository and the necessary auxiliary functions will be made independent along with other waste management functions. The most significant environmental impacts of the L/ILW repository’s expansion arise from the impacts of excavation on the bedrock and groundwater, as well as from the blasted rock and the noise caused by its crushing. The amount of waste generated elsewhere in Finland is small compared to the waste generated at the nuclear power plant, and the final disposal of such waste will not have a significant impact on the operations of the L/ILW repository.

4.3.1 Soil and bedrock

According to the assessment, the impact of the expansion of the L/ILW repository is minor and negative. However, the need for additional excavation is large in terms of volume. The volume of the expansion to the L/ILW repository, located at a depth of approximately 100 metres, is estimated at 71,000 m3. The overall volume will thus be approximately 188,000 m3. As stated in the assessment report, the expansion of the L/ILW repository will be planned to avoid disturbance to existing final disposal facilities.

4.3.2 Groundwater

The expansion of the L/ILW repository will temporarily increase the volume of seepage water. The explosives used during excavation may affect the quality of groundwater locally. According to the assessment, the impact on groundwater is minor and negative. The Ministry of Economic Affairs and Employment emphasises the importance of further project planning addressing any local impacts on groundwater caused by the expansion, also paying attention to the importance of the safety of waste.

4.3.3 Noise

The excavation of the L/ILW repository, the crushing of blasted rock and transports are sources of noise disturbance. The loudest noise is caused by any crushing of blasted rock above ground. Such noise may carry to the holiday homes on nearby islands and the mainland. According to the report, the impacts of noise are minor and negative. Taking into account the duration of the expansion, which will last for several years, and the location of holiday homes, it is important to reduce the noise disturbance from the expansion of the L/ILW repository. The noisiest work should be timed appropriately to mitigate the impacts.

4.3.4 Use of natural resources

According to plans, the blasted rock from the expansion of the L/ILW repository will be primarily used to fill the L/ILW repository. It can also be used for landscaping after the dismantling stage or possibly for earthworks outside the power plant site. According to estimates, the work will result in around 100,000 m3 of blasted rock. Its utilisation is considered to promote the circular economy, which is why the impact is assessed as being minor and positive. In the opinion of the Ministry of Economic Affairs and Employment, the amount of blasted rock is large and it is therefore important to carefully plan its use.

21 (22) 4.4 Other impacts

The assessment report also discusses other impacts of the project options. These have been assessed as being of minor or no significance. The Ministry of Economic Affairs and Employment considers this estimate to be accurate, provided that the mitigating measures described in the report are carried out. According to Fortum’s estimates, extended use would cause minor negative impacts on land use, land use planning and the built environment, the landscape and cultural environment, traffic, emissions of radioactive substances and radiation exposure. Minor positive impacts would affect the fauna. No significant impacts have been identified concerning noise, vibration, air quality, use of natural resources, soil and bedrock, groundwater, conservation areas and the health of people. The plant’s decommissioning is assessed to carry minor negative impacts in terms of vibration, air quality, emissions of radioactive substances and radiation exposure, surface water (Lappomträsket lake) and fauna. Minor positive impacts have been identified regarding land use, land use planning and the built environment. According to the assessment, the health of people will not be affected. The expansion of the L/ILW repository has a minor negative impact on the quality of surface water, vibration, air quality, traffic, waste and waste treatment, as well as the comfort and living conditions of people. The expansion is not considered to cause any other environmental impacts.

4.5 Up-to-dateness of the reasoned conclusion

When making decisions on licences, the licensing authority must ensure that the reasoned conclusion is up-to-date. If requested by the licensing authority, the coordinating authority must state whether the reasoned conclusion is up-to-date. The project owner can also request the coordinating authority’s view on the up-to-dateness of its reasoned conclusion before the licence application becomes pending. If required, the assessment procedure can be supplemented in accordance with section 27 of the EIA Act.

5 Announcement of the coordinating authority’s reasoned conclusion

The Ministry of Economic Affairs and Employment issues a public notice concerning its reasoned conclusion. Information about the notice is also published on the electronic noticeboards of the municipalities affected by the project. The ministry submits the reasoned conclusion and the statements and opinions received to the project owner. The reasoned conclusion is submitted to the authorities handling the project, to the municipalities affected by the project, as well as to the regional council and other relevant authorities. Moreover, the ministry must submit the reasoned conclusion and translations of the essential parts of it to the Ministry of the Environment, which submits them to the states that have participated in the environmental assessment procedure. The reasoned conclusion and the statements and opinions received are also available on the website of the Ministry of Economic Affairs and Employment at https://tem.fi/en/loviisa-eia-report.

6 Service fee, grounds for determining the fee and instructions for requesting an administrative review

Service fee EUR 47,630 The fee is based on the Act on Criteria for Charges Payable to the State (150/1992) and the Decree of the Ministry of Economic Affairs and Employment on the chargeable services of the Ministry of Economic Affairs and Employment related to the environmental impact assessment procedure for nuclear power plants (139/2021). As provided in the Decree, the fee charged for the coordinating authority’s reasoned conclusion in a demanding project (exceeding 30 person-days) is EUR 16,540 to which an hourly fee of EUR 90 is added for working hours exceeding 30 working days. However, the maximum total is EUR 47,630.

22 (22) An administrative review of this payment decision can be requested from the Ministry of Economic Affairs and Employment. A review must be requested within six months of the payment decision as laid down in the Administrative Procedure Act (434/2003). Instructions for requesting an administrative review are appended to the decision. A decision on the request for an administrative review may be appealed as laid down in the Administrative Judicial Procedure Act (808/2019).

Minister for Economic Affairs Mika Lintilä

Senior Specialist Jaakko Louvanto

Appendices Instructions for requesting an administrative review

Distribution Fortum Power and Heat Oy

For information

Recipients of request for statement

Paldiski mnt 96/ Tallinn 13522/ 626 2802/ [email protected]/ www.envir.ee/

Registrikood 70001231

Vastavalt nimekirjale

25.05.2022 nr 6-3/22/2230-2

Loviisa tuumaelektrijaama tegevusaja pikendamise

projektist

Piiriülese keskkonnamõju hindamise konventsiooni (Espoo konventsiooni) alusel teavitas Soome

2020. a Eestit Loviisa tuumaelektrijaama tegevusaja pikendamise projektist. Eesti osaleb projekti

piiriülese keskkonnamõju hindamise (KMH) menetluses. Projekti KMH programmi ja KMH

aruande materjalide avalikustamised leidsid aset vastavalt 2020. a ning 2021. a.

Nüüd on Soome informeerinud Eestit sellest, et arendaja Fortum Power and Heat Oy taotleb

Soome valitsuselt tegevuslubasid Loviisa tuumaelektrijaama tegevusaja pikendamiseks ning

madala ja keskmise aktiivsusega radioaktiivsete jäätmete lõppladustamiseks. Neid kavandatavaid

tegevusi käsitleti projekti KMH materjalides. Käesolevaga edastame ka Teile infoks Soome poolt

saadetud ingliskeelsed materjalid (arendaja tegevuslubade taotlused ning pädeva asutuse Soome

Tööhõive- ja Majandusministeeriumi põhjendatud järeldus KMH aruande kohta).

Lugupidamisega

(allkirjastatud digitaalselt)

Kaupo Heinma

asekantsler

Lisad: 1. Arendaja tuumaelektrijaama tegevusaja pikendamise tegevusloa taotlus;

2. Aarendaja radioaktiivsete jäätmete lõppladustamise tegevusloa taotlus;

3. Pädeva asutuse põhjendatud järeldus.

Rainer Persidski, 626 2973

[email protected]