raport la studiul de evaluare a impactului asupra mediului ... filecernavoda 3 and 4 comments and...

CERNAVODA 3 and 4

Comments and reaction on

Raport la studiul de evaluare a impactului asupra mediului pentru CNE Cernavodă Unităţile 3 şi 4.

(în limba engleză)

Jan Haverkamp September 2007

Content

1. Introduction ......................................................................................................................2

2. General remarks on the EIA report .................................................................................5

3. Remarks on Chapter 1 of the EIA report ........................................................................6



6. Remarks on Chapter 4 of the EIA report ......................................................................10



9. Remarks on Annex B of the EIA report ........................................................................19

Annex 1A Ian Fairlie, Cernavoda 3 and 4: Environment Impact Analysis, Report for Greenpeace, London (2007) Greenpeace

Annex 1B Ian Fairlie, Tritium Hazard Report: Pollution and Radioation Risk from Canadian Nuclear Facilitaties, Toronto (2007) Greenpeace

Annex 2 Helga Kromp-Kolb, Andreas Molin (ed.), Nuclear Power, Climate Policy and Sustainability; An Assessment by the Austrian Nuclear Advisory Board, Vienna (2007) Austrian Federal Ministry of Agriculture and Forestry, Environment and Water Management

Annex 3 Antonia Wenisch, Erika Ganglberger, Heinz Högelsberger, NPP Cernavoda 2,Comments to the documents provided for the EIA, Vienna (2002) Austrian Institute for Applied Ecology

G CERNAVODA 3 and 4; Comments on the EIA documentation 1

ir. Jan HaverkampConsultant for nuclear energy in Central Europe

Greenpeace European UnitBeliardstraat 199

B – 1040 BrusselsBelgium

tel.: +420.603 569 243fax/tel.:+32.2 274 1910

e-mail: [email protected]

1. IntroductionThis report consists of an analysis of the documentation for the Environmental Impact Assessment (EIA) made available to the non-Romanian speaking public on the website of the Romanian Ministry of Environment on:

http://www.mmediu.ro/dep_mediu/cernavoda.htm

Ir. Jan Haverkamp is an independent consultant for nuclear energy issues in Central Europe for the organisations Greenpeace and WISE/NIRS Brno. He has 21 years experience in the field.

This report comes to the conclusion that:1. The EIA report is insufficient on crucial points.2. The EIA report is strongly biased by choice of focus and priorities and therefore

cannot be used as basis for decision processes around the project.3. The EIA report in its present form should be rejected by the Ministry of Environment

and Sustainable Development of Romania.

This report looks into the entire EIA documentation, though because of the limited capacity that Greenpeace has at its disposal for these kinds of assessments, it will not be completely comprehensive, nor was there time for an in-depth analysis of all aspects of the report.

Greenpeace nevertheless decided to commission an in-depth analysis on one particularly important issue concerning the used reactor design in Cernavoda: tritium emissions. The comments in this report on other aspects are to be seen as indications of where the weaknesses of the EIA report show, and which main reasons exist for not accepting the report in its current form.

Since the re-start of construction of Cernavoda Unit 2 and the EIA performed for this reactor, two issues have occurred that prevent a simple copy-and-paste of the situation of Cernavoda 2 planning to the project of construction of Cernavoda 3 and 4. The first one is the increased scientific certainty about human induced climate change and the role of energy policy in this. The second issue consists of the terrorist attacks on the USA on 11 September 2001. Neither of these issues are sufficiently incorporated into the EIA report for the Cernavoda 3,4 project.

With these comments, Greenpeace submits the following:

● Annex 1: Ian Fairlie, Tritium Hazard Report: Pollution and Radioation Risk from Canadian Nuclear Facilitaties, Toronto (2007) Greenpeace - which looks into the effects of tritium emissions from CANDU 6 reactors in general (Annex 1B) and: Ian Fairlie, Cernavoda 3 and 4: Environment Impact Analysis, Report for Greenpeace, London (2007) Greenpeace - which looks at tritium emissions from the Cernavoda NPP in particular (Annex 1A).These studies describe the much larger effect of tritium emissions from CANDU 6 reactors on public health and environment than described in the EIA report.

● Annex 2: Helga Kromp-Kolb, Andreas Molin (ed.), Nuclear Power, Climate Policy and Sustainability; An Assessment by the Austrian Nuclear Advisory Board, Vienna (2007) Austrian Federal Ministry of Agriculture and Forestry, Environment and


http://www.mmediu.ro/dep_mediu/cernavoda.htm

Water ManagementChapter 5 of this report gives a more state of the art description of the risks posed by war and terrorist threat than the one in the EIA report.

● Annex 3: Antonia Wenisch, Erika Ganglberger, Heinz Högelsberger, NPP Cernavoda 2,Comments to the documents provided for the EIA, Vienna (2002) Austrian Institute for Applied EcologyMost of the issues raised in this report, prepared for the Cernavoda 2 reactor, were not addressed in the final project, nor are they addressed in the Cernavoda 3,4 EIA report.

Greenpeace already submitted comments on the Project Description in the EIA scoping phase. The EIA team (as we presume, because no other authors were mentioned) answered on these comments in some detail in Annex B, but failed to address the main points of critique expressed in the comments on the Project Description:

● The risk of terrorist attack is not at all addressed. The response in Annex B is completely insufficient and is not conform today's stand of scientific knowledge. As a consequence, Cernavoda 3 and 4 will at least double the chance on large emissions of radioactive isotopes as a result of terrorist activities.

● The impact of earthquakes has not been sufficiently addressed and needs to include a far wider set of data as already pointed out during the EIA process for Cernavoda 2 by the Austrian Institute for Applied Ecology. (Copy of assessment added in this comment as Annex 3).

● A meteorological analysis of the spread of radioactivity in the case of severe accidents has not been added.

● The request for a more in-depth analysis of possible health effects was not sufficiently taken up. Greenpeace therefore commissioned a study on effects of tritium in the case of Cernavoda to Dr. Ian Fairlie (assessment added in this comment as Annex 1).

● The cost analysis in the social-economic paragraphs is completely inadequate and does not reflect reality. The cost analysis continues to give a distorted picture of the situation, heavily biasing it towards the project. On this basis no proper analysis can be made whether proper alternatives would exist that would have a lower impact on the environment against comparable or lower cost.

● The two alternatives given for Cernavoda 3 (and per default also used for Cernavoda 4), though being realistic options, completely exclude scenarios that might come to lower environmental impacts and costs, including a scenario based on the premises of the EREC / Greenpeace commissioned scenario study 'energy [r]evolution'. With this, the EIA report is strongly and wrongly biased towards the project.

● The used Romanian Energy Strategy is the still outdated old strategy, which does not include any logical alternative pathways for comparison. As the proposal for a new Romanian Energy Strategy is currently undergoing a Strategic Environmental Analysis, it would have been wise to delay this EIA procedure for Cernavoda 3 and 4 until the results of the SEA of the Romanian Energy Policy have become public.

We gratefully assessed that the last main point of criticism that we had, a paragraph with the title “Romania's Policy in Nuclear Power Field”, has been removed from the report.

More detailed answers on the EIA author team's response to our earlier concerns can be found in chapter 9. Remarks on Annex B of the EIA report.


On top of the critical points already mentioned in the comments on the Project Description and that were not addressed in this EIA report, several other points should be added:

● The health risks of tritium exposure were not adequately addressed and are a lot larger than described. The analysis committed by Greenpeace concludes amongst others that pregnant women and young children should be advised to leave the town of Cernavoda, and that other inhabitants of the town should be advised not to use any local produce – a situation that will severely aggravate when the amount of reactors of the CANDU 6 type will double.

● The EIA does not include a full list of environmental impacts caused by the full fuel chain of Cernavoda 3 and 4 operation. Uranium mining, fuel production, heavy water production, fuel transport, spent fuel processing and temporary and final storage all have considerable influences on the environment – influences that, for instance, renewable energy sources don't have. The fact that these are not included in this study gives a distorted picture of reality in the advantage of the project.

● There is no analysis of amounts of radioactive isotopes that could get into the environment after large beyond design accidents, nor of their spread and consequences.

● The paragraphs on social-economic impacts (par. 4.7 and 4.8) are not a serious analysis and of abominable quality. There is no way that this can form a basis for proper comparison of possibilities and should be re-done by other authors.

● The quality of the analysis of alternative scenarios is far below the level that proper comparisons can be made and therefore cannot be used for decision procedures around this project. This includes an insufficient vision on the possibilities of energy efficiency, a completely outdated picture of the possibilities of renewable energy sources, severe overestimation of prices of renewable energy sources, a time-horizon (2025) of only 10 years, whereas the NPP is to have a 30 year operational time, no analysis of the uranium market developments over the life time of the reactors and many more.

● The EIA is based for a large part on Romanian literature and includes too little international literature. Therefore in many instances it is behind on the current stand of knowledge.

● The EIA describes that for the storage of HLW (High Level radioactive Waste), current storage capacity needs to be expanded, but fails completely to describe the risks that are related to interim high radioactive waste storage (in the form of human and technical error as well as terrorist risk), nor does it describe possible environmental impacts in case of a large accident in the interim waste storage.


2. General remarks on the EIA report

The English version of the EIA report can be found on the website of the Romanian Ministry for Environment and Sustainable Development, but only over Romanian language web pages. With this, equal access for citizens in possibly affected countries to procedures and materials as secured under the Espoo and Aarhus conventions is not provided. Access to these materials should be provided minimally over English accessible web-pages.

The EIA report is extensive in the description of the “is” situation, but in general remains extremely vague about the “to be” situation. We have been able to see this happen in virtually all chapters, including those about hydrology, the radiological situation and especially tritium emissions (see comment Dr. Fairlie in Annex 1), the nuclear waste situation etc.

Demand: Greenpeace demands that every chapter of the EIA be concluded with a short quantitative and qualitative summary of the situation to be expected after the blocks 3 and 4 will be constructed and put into operation in comparison with the situation they will not be constructed.

Where the EIA report does describe influence of the Cernavoda NPP, it fails to compare these influences with a group of sensible alternative scenarios. With that, the construction of Cernavoda Units 3 and 4 is more or less precluded and no reasonable comparative assessment can be made as to whether the project indeed fulfils the needs most optimally or whether another – less environmentally negative – alternative would not be better.

Demand: Greenpeace demands that for the sake of proper comparison a full set of alternatives is worked out, including one on the basis of the conditions as described in the energy [r]evolution scenario published by EREC and Greenpeace in 20071.

The EIA report mentions in several occasions the conditions the Cernavoda NPP legally has to fulfil – however, it does not calculate on the basis of available data from Cernavoda 1 and foreign CANDU 6 reactors what the chances are that these legal conditions will not be met. This leads to the situation that it appears according to the EIA that the Cernavoda NPP will fulfil the legal requirements, where in reality this has not been calculated. It is not sufficient, as for instance in Table 4.1.14.5, that the output data of Cernavoda 1 are given, without a more or less sensible estimate of the situation when four instead of one block are operational. (For a more detailed critique concerning tritium emissions in this case, also see Annex 1, the analysis of Dr. Fairlie).

Demand: Greenpeace demands that in those places in the report where a description of legal limits is not followed by a full calculation of likely real emissions, this latter omission is corrected with clearly comparative tables.

1 EREC, Greenpeace, energy [r]evolution - a sustainable world energy outlook, Amsterdam (2007) Greenpeace International; http://www.energyblueprint.info


http://www.energyblueprint.info/

3. Remarks on Chapter 1 of the EIA report

Ad 1.5 Design AlternativesGreenpeace applauds that different scenarios are calculated through. However, the offered scenarios are not sufficient. Greenpeace demands that at least one scenario is included that respects the need for CO2 emission reductions and excludes the need for new nuclear capacity. This scenario should include far more ambitious targets concerning renewable resources, following developments as seen in amongst others Germany and Spain after proper supportive legislative measures were taken, a further-reaching decentralisation of combined heat and power production and more ambitious targets in energy efficiency on the basis of realistic policy measures. A basis for such a scenario can be found in the European Renewable Energy Council / Greenpeace scenario titled “energy [r]evolution”2. The reason for inclusion of such a scenario is that experience has learned that this offers the least cost solution to the predicted demands of energy services, whereas it delivers optimal results in reduction of greenhouse gasses and reduction of negative effects of nuclear power (nuclear waste, tritium emissions, risks for technical or human failure, terrorist threat, others)3.

“[...] in point of environmental criterion, irrespective of the value of the fee for greenhouse gas emissions, U4 finalization will increase the difference between Scenario B and Scenario C in favour of Scenario C”

This conclusion is unjustified, as the larger environmental effects caused by a larger chance on a large accident caused by technical or human failure or terrorist attack, the higher emissions of (4 instead of 3 reactors) and exposure to (larger emissions combined with a higher population due to higher need of personnel) tritium, the larger need of fuel (environmental effects of mining and fuel production) and the larger production of radioactive waste (for which there is no solution) will strongly influence the difference between the Scenarios A and B on one hand and C in an way that increases environmental damage. It will also strongly increase the gap between Scenario C and a sustainable scenario as proposed by us. Considering costs, the picture is similar. Given the current economic trends within the nuclear sector, a sustainable scenario as proposed by us would show increased feasibility in comparison to Scenario C. This quote can function as illustration of the fact that the EIA report in itself is strongly biased to one outcome: construction of Cernavoda units 3 and 4 has to be sold as most beneficial.

2 EREC, Greenpeace, energy [r]evolution; a sustainable world energy outlook, Brussels/Amsterdam (2007); http://www.greenpeace.org/international/press/reports/energyrevolutionreport

3 EREC, Greenpeace, futu[r]e investment; a sustainable investment plan for the power sector to save the climate, Amsterdam (2007); http://www.greenpeace.org/international/press/reports/future-investment


http://www.greenpeace.org/international/press/reports/future-investment

http://www.greenpeace.org/international/press/reports/energyrevolutionreport


Ad 2.2.1 Nuclear Safety Principles and General Design CriteriaThe use of the ALARA principle for ordinary operating nuclear safety opens the debate about what is considered “reasonable”. Given the fact that the EIA did not take the possible effects of tritium on the population into sufficient consideration, we conclude that the level of what is considered “reasonable” in this project is too low. In cases of possible exposure of the population to radiation – even where the industry has taken the ALARA approach as standard – an approach of 'as low as possible within the latest stand of technique' would be more adequate.

“accidents associated with serious consequences should be extremely improbable”A serious debate should be considered about what is considered “extremely improbable”. The fact that numbers here are missing, makes the discussion completely impossible.

“the radiation protection is optimized maintaining the radiation exposure as low as practical attainable, below the allowable dose limits and justified from both the economic and social point of view.”

This principle cannot be upheld. In the case of radioactivity, allowable dose limits are political decisions where the overwhelming scientific evidence is that there is no level of no-effect. When working on the basis of the above mentioned principle, the chance that economic or social reasons overshadow the need for protection of the population and environment is far too big. The threat from radiation is qualitatively different to the threat from substances or physical phenomena (like noise, air pressure etc.) in that respect that radiation is invisible and cannot be detected with human senses. 'As low as possible under present stand of technique' is a better lead, where economic considerations will have to follow the reality of stand of technique. If radiation security costs money, these costs have to be carried and expressed fully in the overall picture.

“(ICRP, 1977) no activity with radiation exposure should be developed unless a net positive benefit is produced;”

Because, as we have argued, more positive benefits can be produced with another energy policy and accompanying energy mix than described in the here presented scenarios – and faster and cheaper – it follows from the ICRP recommendations that Cernavoda units 3 and 4 should not be constructed.

IMPORTANT – In spite of the description of nuclear safety and more or less acceding that there is a rest-risk on a larger accident with large consequences, the study fails to mention that the CANDU 6 design is currently not any longer conforming with the safety regulations of the Canadian Nuclear Safety Commission (CNSC)4. This in itself should already be enough reason to abandon the idea of building two more CANDU 6 reactors in Cernavoda.

Ad Table 2.2.2-1. Design Characteristics of Cernavoda NPP for One UnitIt is mentioned that the plant lifetime is 30 years and that plant lifetime extension is envisioned. This is in spite of a complete lack of experience world-wide with plant lifetime extension of CANDU 6 reactors and severe doubts whether plant lifetime extension for CANDU 6 reactors is economically and safety-wise viable. Because of the risks related to nuclear power, and especially to the CANDU 6 reactor design, Greenpeace advices not to extend the lifetime of these reactors and limit the lifetime of Cernavoda unit 1 to 30 years

4 See amongst others: Tyler Hamilton, Could reactors withstand blast?, Toronto Star, January 19, 2007.


of operation and that of Cernavoda unit 2 to 20 years of operation.Whatever the vision of the EIA team or the operator of Cernavoda 3 and 4, lifetime extension may not be used as an argument in its economic viability as long as physical and safety viability of lifetime extension are 100% proven. Greenpeace is convinced that lifetime extension increases the risk for human or technical failure within the plant to an unacceptable degree.

In general, the CANDU 6 design does not provide latest stand of technology, which can be recognized in many parts of the description of the design. Later design generations like the French designed EPR currently under construction in Finland offer a large amount of advanced safety features that are not included in the CANDU 6 design. Examples include the quality of the secondary containment, the location of emergency power supply systems, secondary control area buildings and other emergency systems outside the secondary containment and others. With that, Cernavoda gets two outdated reactors that cannot deliver the safety level currently seen as acceptable in other EU countries, like for instance Finland.That said, even the EPR design is under criticism for problems in its safety concept and cannot promise a 100% exclusion of large accidents.

Ad 2.3 DecommissioningIt is not clear to us which of the described decommissioning strategies SAFESTORE or DECON is chosen for Cernavoda 3,4. We have found an extensive description of each process, but not a decision, which means that it is impossible to make an estimation of the total environmental impact of the project.



Ad 3. Nuclear wastes

The main objective of the national policy for radioactive wastes management is that of providing a theoretically null negative impact and respectively a minimum reasonably possible one, of the wastes management activities upon population and environment. The first step in this direction is provision of the conformity of management process with the principles recommended by IAEA by the document “Safety Series No.111-F, Fundamental principles of radioactive wastes management” (Ref. 3-4).

When the main objective of the national radioactive waste management policy is a zero negative impact, none of the IAEA principles can be a step towards this policy. Spent fuel and other HLW has to be kept out of the environment and out of contact with the biosphere for a period of over 100 000 years. There is no practical scientific way to guarantee such a seclusion from the biosphere over such a time. The only step towards zero impact of HLW and spent fuel is prevention of its production.In that framework it is unacceptable that the EIA authors only draw a limited amount of alternatives into the debate and explicitly exclude alternatives that can meet this issue while at the same time deliver faster, cleaner and cheaper solutions to the demand for energy services in Romania and the Balkan region. We demand that the principle of zero impact of HLW and spent fuel is taken seriously and leads to serious investigation of alternative solutions for the required energy service demands.

Romania furthermore has no completely worked-out programme on the table, nor any chosen site for final storage of HLW. Experience in other countries shows that a process for choosing a possible site for investigation (no project with the exception of Yucca Mountain in the USA has ever come beyond that point) takes a period of several decades. Estimations show that building an actual final storage adds another few decades to the process. Starting a project like Cernavoda 3 and 4 without such a solution indisputably will shift the problem of final storage to next generations – not the generations that benefits from the produced electricity. This goes fundamentally against the principle of sustainability as defined in the UN Brundtland report.



Ad Chapter 4 - Potential Impact on Environment Components – Mitigation Measures

In the description of the hydrological circumstances, proposed changes in the form and flow of the Danube and Danube Black Sea Channel waterways have been mentioned, but should more explicitly be linked to the Cernavoda NPP, as this is the largest man-made reason for changes in the local hydrology. This means that these works also need to be included in the financial budget of the Cernavoda project and not – as is happening at present – as a separate project covered by the State budget.

In the description of water systems, in Chapter 4.1, Page 4.1 – 127, the English translation remarks that “The waters discharged into the sewage water system come not only from clean areas (non-contaminated areas).” It is unclear to us, whether this means that contaminated water can enter the sewage system, and if so, which measures are taken to prevent run-off into the sewage outlet into the Danube?

In the description of the hydrology of the Danube and Danube Black Sea Channel there is no assessment of what changing climate patterns as a result of climate change might have for effect on the availability of cooling water and the quality of water. As current trends will only become larger in the coming decades, there is sufficient reason to expect larger periods of lack of cooling water, larger fluctuations in the ground water levels and subsequent consequences for the underground stability, and larger risks of flooding. The given descriptions in chapter 4.1.15. and further are not sufficient within the current context of climate change – it can be expected that mentioned effects in these paragraphs will be exacerbated under influence of climate change. Recent periods of extreme drought in, for instance, France have already led to unforeseen high incidences of extremely low water, forcing nuclear power stations to temporary shut-down.

Paragraph 4.1.15.2 describes the situation of an extremely low water level in the Danube. The description fails to notice that in such cases increased release of cooling water from DBCS Race 2 will also result in the intake of higher temperature cooling water into the cooling circuit – which may, as described, have its advantage in times of cold (less freezing), but which will only lead to a needed increase of cooling water intake in times of extreme heat because of a higher intake temperature. This illustrates the fact that the EIA report has instances in which clearly troublesome situations are written in such a way that they look advantageous. The EIA report should be scanned for more such situations and these should be replaced with more objective descriptions.

In general, descriptions of the results of cooling water intake describe the situation with one block at Cernavoda operational and then conclude – without indicative calculations what a fourfold increase of water amounts and velocities and change of other parameters will effect in – that there are no problems to be expected. This leads to a structural underestimation of the effects of the total complex of the Cernavoda NPP.

Also in the description of the impacts of cooling water emissions on the Danube and the DBSC, too often cumulative impacts of four reactors instead of the observed impacts of one reactor are described in rough qualitative terms (no other impacts to be expected) instead of clearly estimated and put into perspective.

Dr. Fairlie remarks: “A second major difficulty with the planned expansion at Cernavoda


are the planned large increases in discharges of very hot water (> 32°) into the Danube river and the Danube-Black Sea Canal particularly in the summer months. These temperatures exceed the 30° limit imposed on cooling effluent from power stations in France. This is a major problem with only one reactor operating, and it will become extremely serious problem with 4 reactors in operation. This matter is flagged up but not discussed further here.” (see Annex 1)

Ad 4.4.2 Tectonic Structure, Neotectonic and Seismic Activity

Although the EIA report describes the risk of seismic activity in the area, it fails to describe what might happen under different scenarios – only referring to documentation that was not included in the EIA report. As the EIA report adequately described, the location is under influence from several geological faults, which in 1977 led to a major earthquake in the region with major damage. Recent events in Japan have shown that seismic events need to be taken very seriously in decisions regarding nuclear power construction. We therefore demand that the supporting documentation will be provided to the public, and that the report be extended with a paragraph relating the described seismic activity not only with the set standards, but also with a more concrete description of possible scenarios in case things go wrong. In the documentation, it does not get clear on which period of observation the EIA authors came to their conclusion. As one of the major critiques in the Cernavoda 2 EIA was that the seismic activity and possible consequences were underestimated5 This also should include the description of release and spread of radioactive substances in case there is damage caused by seismic activity and its influence on the environment.

Ad 4.5. Potential Impact on Biodiversity

In paragraph 4.5.5 it says: “During the Unit 1 operation (in the period 1996 - 2006), it was not observed any impact on flora or fauna in this area. Therefore, it is assessed that the Units 3 and 4 operation will not have an impact on fauna and flora in the Cernavoda NPP site.” This is an extremely unprofessional statement. First of all, in the study there is no investigation done to the impact of several operational issues related to the ordinary operation of Unit 1, as amongst other the releases of tritium. Secondly, although operation of Unit 1 did not go completely without problems, possible impacts of nuclear power stations on the surrounding environment are largest after incidents and accidents. As far as information is publicly available, there is no knowledge of any larger incident or accident at Unit 1 up to date. This means that the operational history of Unit 1 cannot be taken as basis for the estimation of environmental impacts of other units. Demand: We demand that the EIA report also will describe the possible impacts of incidents and accidents at Cernavoda on biodiversity, as well as impacts of normal operation that are not addressed in this study, e.g. the impacts of tritium emissions.

5 Antonia Wenisch, Erika Ganglberger, Heinz Högelsberger, NPP Cernavoda 2, Comments to the documents provided for the EIA, Vienna (2002), Austrian Institute for Applied Ecology – added to these comments in Annex 3


Ad 4.6. Potential Impact on Landscape

Although it is definitely true that continuation of construction will clean up some of the eyesores that the unfinished Cernavoda NPP is currently presenting in the landscape, the EIA report does not mention an important conclusion: The total complex of the Cernavoda NPP is plainly ugly and falls completely out of place in a largely agricultural landscape with natural slopes and views. It is not adequate to only describe the influence of the Units 3 and 4 on the landscape, but the totality of the introduction of heavy industry in the form of the complete Cernavoda NPP needs to be taken into account. Furthermore, the completion of construction of Cernavoda Units 3 and 4 will lead to a much longer operational period of the site – with as a consequence that the destruction of the landscape will also remain visible for a longer time.

Ad 4.7. Potential Social and Economic Impact

In Paragraph 4.7.2, the report says: “A 10 km radius zone around the reactor is considered to be the area of concern because, in compliance with IAEA recommendations (Ref. 4.7-2), the economic objectives located at a greater distance than 10 km away from the NPP shall not affect/be affected the /by the plant.” Apologies for saying this, but this is completely ridiculous. A nuclear power plant has a considerable influence not only on the local economy, even the regional economy, but on a national and international scale. This goes from plant managers living in Constanta and buying their cars in Bucharest up to influence on the international electricity prices.It is of paramount importance that in the EIA report the social and economic impacts are described on all levels and compared with a serious and realistic set of alternatives. This requires proper scenario calculation. Only in that way it is possible to see whether the project is indeed the right project on the right place in the right moment.

Furthermore, this paragraph describes: “The existence of the nuclear power plant in this zone is a positive factor for the development of the economic activities in the vicinity.” and comes to this conclusion by listing only positive elements – not by comparing positive and negative considerations. Even the authors of the EIA study should be able to see that that indicates a rigged analysis! On top of this each of the mentioned positive elements is severely debatable:

“The main beneficial social and economic effects of the Units 3 and 4 completion and operation will be:

- positive return of important previously started investments;”

This is a non-argument. The previously started investments were already written off and do not need a positive return any longer. On top of this, it is still debatable whether the overall balance of the Cernavoda NPP will be economically positive or negative. This paper does not investigate this at all – direct and indirect costs caused by the construction, operation and decommissioning of the NPP might well be negative. Furthermore, the study does not put this into perspective by comparison with proper and realistic alternatives, which might easily lead to the situation that other options may give a nett far more positive return.


- generation of a large quantity of electric energy;This statement is made out of context. There is no proper comparison with other realistic alternatives. Furthermore, this remark only looks at electric energy and not at – for instance – heat. Investment into gas- or biomass-powered decentralised co-generation would not only deliver similar quantities of electric energy, but on top of that large amounts of usable heat. Ergo, this statement is a nonsense statement.

- avoidance of greenhouse gases emission increase and of other effects that would occur by fossil fuel burning in a comparable thermal power plant;

This precludes that the only alternative for the Cernavoda NPP would be fossil fuel burning in a comparable power plant. This is clearly nonsense and relates to the fact that no proper alternatives analysis has taken place. It also does not include the fact that nuclear power is emitting greenhouse gasses during its construction, production of fuel, decommissioning and processing of waste. An intelligent mix of decentralised heat-power co-generation on gas and biomass, energy efficiency measures and the use of renewable energy sources would according to our calculations deliver the same energy services or more against a lower price, already on shorter term, with substantial lower nett CO2 emissions.

- population employment and qualification;Although any industrial activity creates jobs, it also destroys jobs or prevents the creation of jobs. This analysis does not even look to that side of the picture – jobs will be lost because Cernavoda becomes less attractive for tourism, organic agricultural development will be severely hindered, and the production of “large quantities of electrical energy” will prevent the creation of a far higher amount of qualified jobs in the renewable energy sector and energy (efficiency) services sector. Stand-alone remarks like this one are in itself nonsense.

- stimulation of other economic activities;This follows the same logic as the one on employment and qualification. Whereas the Cernavoda NPP definitely will stimulate some other economic activities, it will also destroy others. And any alternative generation of energy services will also stimulate – and in the scenario that we propose even to a higher extent – other economic activities.

- financial sources for the population and the local administration;This remark is made without a clear analysis supporting it. Whereas there are cases in which construction of a nuclear power station indeed has led to larger availability of financial resources for the local population and administration, this is not inevitably the case. For instance in the Buglarian town of Kozloduy absolute poverty rates have not gone down since the construction of its NPP and, for instance, its health infrastructure at present is in an abominable state. In order to make this statement, a careful analysis needs to be made about economic advantages and disadvantages, as well as a comparison with realistic alternatives. Furthermore such an analysis should look at the larger picture on national and even international level in order to provide a basis for an overall assessment.


- development and improvement of local infrastructure.And next to that also development of complications in the local infrastructure and deteriorations. Apart from that, the development of local infrastructure is not depending on a nuclear power station, but on the development policy for the region. Also alternative solutions could bring development and improvement of local infrastructure. Again – a stand-alone remark of this kind is in itself pure nonsense.

Ad 4.8. Potential Impact on Culture and Patrimony

The EIA report writes: “At some kilometers, Cernavoda Town represents in itself a turistic attraction due to its national landscape and concentration of technical art works (i.e the bridges over the Danube River and over the Danube-Black sea Canal, the derivation canal, Valea Cismelei, Cooling water intake duct, the lock, viaducts, pump houses, ports, etc.).”

If the construction of a nuclear power station were not such a serious issue, such paragraph could be the source of a good laugh. It certainly delivers a good source for a comical TV programme like Monty Python's Flying Circus. However, it shows here that it would not be a bad idea to involve a consultancy in this EIA process that has some idea of what tourism is and what tourists like to see. Even in a country with such a large reverence for engineering, tourists do not come for a view of the “technical art works” per se, but for an experience. The fact that Cernavoda to day – with 10 years of operation of Cernavoda 1 and finalising testing of Cernavoda 2 – still has no proper visitors centre as many NPPs abroad makes clear that the management of Cernavoda and Nuclearelectrica indeed have no idea what tourists are looking for.Because of the presence of the NPP, Cernavoda has lost a lot of its appeal as town – the forced growth of the town in the 1980s has led to large areas of grey concrete. The town is simply no attractive tourist destination any longer.

It has to be remarked that the paragraphs 4.7 and 4.8 on socio-economic impacts are severely below standard – even far below the quality of the rest of the report – and cannot be accepted in this way.

Ad 4.9. Radiological Impact

For a comment on the impacts of tritium emissions of the Cernavoda NPP, I refer to the report of Dr. Ian Fairlie in Annex 16. Also there you will find a criticism on the determination of Derived Emission Levels (DELs).

The report fails to address radiological impacts of the fuel chain necessary for the operation of the NPP. With this it fails to mention the largest sources of radioactive contamination during normal operation – radiological impacts of uranium mining, fuel production, waste processing and decontamination. It also fails to mention the possible radiological impacts of long term storage of the largest source of radiation: spent fuel. By

6 Ian Fairlie, Cernavoda 3 and 4: Environment Impact Analysis, Report for Greenpeace, London / Bucharest (2007) Greenpeace; as well as: Ian Fairlie, Tritium Hazard Report: Pollution and Radioation Risk from Canadian Nuclear Facilitaties, Toronto (2007) Greenpeace; both available in Annex 1 of these comments.


not taking these into account, the total picture of the EIA is incomplete and cannot function as a tool for comparison with other possible alternatives. Indeed, as proper and realistic alternatives are not even analysed in this EIA, any comparison is made impossible.

It is interesting to see that the EIA report does pay attention to measures taken for personal and surrounding population in case of an accident, but does not look at further spreading of radioactive material during an accident – to be more precise, beyond design accidents are not included at all in this study, although these have the largest environmental effect. With that, the EIA report misses its prime goal of informing the public and authorities about the environmental impacts of the project completely.



Ad 5. Analysis of Alternatives

Romania's energy policy is at the moment in a full revision. It is understandable that the EIA is referring to the previous energy policy, but there have been since the formulation of that policy very large changes in the global and European political environment of energy policy. The main force behind these changes is the increasing certainty that climate change is happening, that it is happening fast and that it is man-made with a large part played by the energy sector. It is therefore to be expected that the energy policy currently under discussion will have considerably different lines into the future than the former one. Even if the EIA cannot use this still to be formulated energy policy, it should at least have incorporated important lines in current developments of energy policy.Another issue that is currently playing is a debate about the form in which in Romania the former – as well as the currently debated – energy policy has been, respectively is formed: it basically sets out trends based on a wish-list of Romania's larger energy companies and adds to that compulsory developments from the side of the European Union. In more advanced planning procedures within the EU and EU member states, policy makers make an inventory of policy goals they want to reach and policy options they want to study, have predictive scenarios worked out on each of these and come to a well balanced conclusion. Greenpeace is currently pleading with the Ministry of Economy and Finance of Romania also to include different scenarios in the energy policy debate, including one based on the criteria as used in the study by the German DLR (German Institute for Aeronautics and Space) commissioned by the European Renewable Energy Council and Greenpeace7.

This EIA study – if to be taken seriously – should also reflect the current discussions as well as the current practice in comparative analysis. That means that it is not sufficient that only two fossil fuel driven alternatives are investigated. It would be at least necessary to have also a scenario included that is based on a larger decentralised energy structure with a stress on heat-power co-generation, a focus on the increase of energy efficiency and the accelerated development of a mix of renewable generation sources. In the experience of Greenpeace, which worked out such scenarios on national level for many countries, as well as on European and global level, energy development scenarios based on these principles are inevitably cheaper, deliver faster, have a significantly lower impact on the environment and lack all the disadvantages that nuclear power has (releases of radionuclides (e.g. tritium), nuclear waste, technical and human failure risk, terrorist risk and others).

It is important to observe here, that the only new argumentation taken into consideration in this EIA in comparison with the EIA for Cernavoda 2 is indeed the Kyoto Protocol obligations of Romania. This EIA is not only meant to establish whether the submitted project is capable of reducing Romania's CO2 emissions – it should also establish whether it can so in the most optimal way from social, economic and environmental point of view. In general it has to be said that by choosing the alternatives mentioned in Chapter 5, the authors have consciously avoided also looking at options that might be more advantageous than the proposed project.

It has to be remarked that the currently valid energy policy in this EIA strongly underestimates the possibilities for energy efficiency in Romania as well as the potential

7 EREC, Greenpeace, energy [r]evolution - a sustainable world energy outlook, Amsterdam (2007) Greenpeace International; http://www.energyblueprint.info


http://www.energyblueprint.info/

for the development of renewable energy sources, as illustrated in the EREC / Greenpeace study. All numbers concerning renewable energy sources mentioned in Table 5.2.3-3. are heavily underestimating the current trend. When Romania will decide to follow more advanced countries in this respect like Germany, Spain, the Czech Republic and Bulgaria, and implement a new renewable energy support legislation that balances out incongruities in generation price with the instrument of long-term fixed feed-in prices, these trends will even see a sharp increase.

Demand: Greenpeace demands that at least another alternative scenario is taken up into the EIA, based on a mix of increased focus on energy efficiency – including accelerated increase of more decentralised heat-power co-generation installations – , and an accelerated development of renewable energy sources, as described in the EREC / Greenpeace energy [r]evolution scenario.

Another drawback of this study is that chapter 5 describes three alternative scenarios, but these are not taken at all into consideration within the other chapters. With that a proper comparison is not possible, let alone a proper assessment on whether Cernavoda 3 and 4 indeed deliver the best option with the least necessary environmental impact.

This chapter uses completely misleading graphs. Figure 5.2-1. shows only one NPP installed, whereas Cernavoda Unit 2 is to go on-line this year.

In the comparison between the scenarios that does take place in chapter 5, the generally negative consequences of nuclear power (tritium emissions, large accidents, terrorist risk) are conveniently missing.

For details on the tritium-emission discussion and its impacts on public health, we refer to the attached studies by Dr. Fairlie in Annex 1.

Because Cernavoda 4 was not included in the comparison between different scenarios, the lack of attention for the disadvantages of nuclear energy generation has an even stronger influence on the final conclusions.

It therefore must be concluded that chapter 5 is completely inadequate for a proper EIA.



Ad 7. Risk Situations Analysis

Events caused by meteorological phenomena: the EIA study fails to address what might happen in case climate change would increase the chance and intensity of flooding as well situations of extreme drought. Over the last years, nuclear reactors in France faced longer outage times because of too low water levels and too high water temperatures. At the same time, for instance the 2002 floodings of the Elbe river in Germany reached levels with a frequency of 10E3/annum. The Cernavoda NPP, because of its relatively low level in comparison with the Danube and DBSC will therefore face an increasing risk, not a stable one as presented in this EIA report.

The lack of seismic risk in the report – and certainly in this chapter – is shocking, given the fact that the 1977 earthquake illustrated quite strong possible effects in this region. Also the recent events in Japan point out that seismic activity is not to be underestimated as risk factor. Already in its reaction on the EIA for Cernavoda 2, Wenisch et al. from the Institute for Applied Ecology from Vienna8 concluded that the seismic data were insufficient and as a result risks strongly underestimated. This has not changed in this EIA.

Technical shortcomings of the design as mentioned by Wenisch et al. in the reaction of the Cernavoda 2 reactor have according this EIA study not been addressed in the Cernavoda 3 and 4 project.

Chapter 7 does not analyse the risk of terrorist attack or sabotage. Especially in the world after 9/11, this is an unacceptable omission. It is not sufficient to answer these issues in an Annex and the answer in Annex B is far from satisfactory itself (see Chapter 9 of these remarks).

The report writes: “The technical and administrative protective measures of Cernavoda NPP Unit 3 and Unit 4 design ensure that the risk, in the case of accidents will not be greater than the maximum admissible risk which, conforming to the requirements of (Ref. 7-12), will be defined by the Regulatory Body.” If the requirements have not been defined yet by the Regulatory Body, how can the authors be so certain that protective measures will be sufficient? This is wishful thinking, not science.

Considering international notification, it will be important that Romania also signs Agreements for Early Notification of Nuclear Accidents with Serbia, Macedonia and Croatia before the project is to be started.

8 Antonia Wenisch, Erika Ganglberger, Heinz Högelsberger, NPP Cernavoda 2, Comments to the documents provided for the EIA, Vienna (2002), Austrian Institute for Applied Ecology – added to these comments in Annex 3


9. Remarks on Annex B of the EIA report

Ad ANNEX B – Answers to Mr. Jan Howerkamp questions

On behalf of Greenpeace and WISE, I already sent remarks on the Project Presentation as presented to the public in the scoping phase of the Environmental Impact Assessment. As a matter of form – my name is Haverkamp and not Howerkamp. As the key dangers of nuclear power are in the detail, such a simple mistake is a bad indication.

It is interesting that the reaction of the EIA authors on our concerns expressed on 23 October 2006 is included in the EIA report as Annex. It would have been more comprehensible if the original concerns were included as well, so that the reader could understand what the response was to. It would have been even more important if they would have been sufficiently addressed. The following detail remarks show that our main concerns have not been addressed at all in the answers from the EIA authors, but that they merely take defensive positions. If these answers are a pre-view of what we can expect in the EIA procedure, the procedure is useless.

Ad 1.1 – Adequacy of nuclear power for Romania and Southern Balkans. The authors quite rightly quote the European Commission Communication: “[...] It is for each Member State to decide whether or not to rely on nuclear electricity”. The European Commission in its Communication only states the fact that the use of nuclear power has been defined in the Euratom Treaty of 1957 as national sovereignty and is operated as such. This means that every Member State of the EU has to make its own decision on whether or not to use nuclear power. The preparation procedures for nuclear projects like the Cernavoda 3,4 reactors, including the Environmental Impact Assessment are instruments for all involved stakeholders to come to the right decision in this respect. The fact that both the Project Presentation as this EIA report show large gaps makes a proper decision virtually impossible. We argued in our previous comments as well as argue in this paper that there are ample reasons to abandon this project. There is no obligation from the EU whatsoever for Romania to decide in favour of nuclear power – there are many reasons not to rely on nuclear power. The quoted Communication of the European Commission therefore says nothing about the adequacy of nuclear power for Romania or the Southern Balkans. Given the inherent dangers of nuclear power, the seismic activity of the area in which this project is to be situated, the economic situation of the region and the abundant availability of proper alternatives for energy provision for the region, no other conclusion can be reached than that nuclear power is not the right choice. The reaction of the EIA team only shows that it is incapable of an overview of the matter and severely biased.

Ad 1.2 and 1.3 – The availability of English language materialsEspoo Convention, art. 2, par. (6), “[...] and shall ensure that the opportunity provided to the public of the affected Party is equivalent to that provided to the public of the Party of origin.” This directly contradicts the claim from the authors of the EIA that the process can only be conducted in the Romanian language, nor, as stated in 1.3 that it is sufficient to provide English language material only when the Romanian Authorities are starting the public consultations. When Romanian citizens get the chance to give their comments in the scoping procedure of the EIA, like here, on the basis of the Espoo and Aarhus Conventions as well as the respective European Directives, non-Romanian citizens and


interested parties have the right on access to the provided materials. The Aarhus Convention states that this information has to be provided in the form requested, unless there are valid reasons not to do so. We are happy that the Romanian authorities indeed made the materials available in the English language, but pointed out that when that happens over only Romanian language web-sites, this does not provide for non-Romanians equivalent access to the procedures in comparison with Romanians.Concerning the quality of translation: it is advisable to have English translations of EIA materials edited on readability in order to prevent misunderstanding. Whether or not the authors of Annex B agree with the comments on the quality of English, the quality of English in both the Project Presentation and in the EIA material gives in certain moments way to lack of clarity and possible misinterpretation.It has to be noticed that answers 1.2 and 1.3 are defensive reactions and not in any way helpful in meeting the justified concerns as expressed by us in our previous comments.

Ad 2.1 Content of the EIA ReportQuoting the list of what an EIA Report according to the Espoo Convention should include, does not answer the concern that the Project Description does not include several issues:

● It did not address the risks and consequences of terrorist attack;● It addressed the risk of impacts of earthquakes insufficiently;● It missed a meteorological analysis of the spread of radioactivity in case of severe

accidents;● It missed mentioning possible health effects of ongoing radioactive emissions as

well as a proper base-line description;● It described the issue of nuclear waste inadequately and could not give a solution

for final storage of nuclear waste;● It did not describe full costs of the project;● It did not indicate all viable alternatives to the Cernavoda 3,4 project;● It could not refer to an up-to-date energy policy for Romania.

It did refer to a “Romania's Policy in Nuclear Power Field” that appeared to be nothing but a copy-and-paste from a text from a nuclear lobbying conference.We have to remark that some of our concerns have been partially addressed (see comments on the respective chapters from the EIA report), though none of them up to a satisfying level.

Ad 2.2 Reactor SecurityParagraph 2.2.1, a quote from the IAEA website without indicating its source, describes the rough outlines of what needs to be done. It does not address the concern, however, that there is no adequate description of measures taken and that those measures taken are not adequate to meet these goals. The CANDU 6 reactor is not designed for earthquake areas, it cannot withstand the impact of a larger aircraft or several other forms of wilful sabotage (see under). In spite of all the measures described under 2.2, the nuclear industry has been subject to thousands of minor and hundreds of major events over its 60 year history. In spite of barriers and security zones, there are many cases in literature describing incidents in which people were able to enter these zones – more often than not non-organised individuals. In 2006, Greenpeace activists entered amongst several other NPPs the premises of the Sizewell NPP in Great Britain and the Borssele NPP in the Netherlands.The EIA team quotes one single study from EPRI (without mentioning its source, which is: EPRI, DETERRING TERRORISM: Aircraft Crash Impact Analyses Demonstrate Nuclear Power Plant’s Structural Strength, Palo Alto (2002)), from which detail analyses were not released because of security considerations, and which does not constitute at present scientific consensus on the possible effects of aircraft impact on nuclear installations. As


one example, the German Government commissioned in 2002 the institute GRS (Gesellschaft for Anlagen- und Reaktorsicherheit mbH) with a study that came to on many issues with contrary conclusions as the EPRI study9. In a more recent example, Hirsch et.al10 illustrate in a compilation of scientific research on the matter that this rest-risk continues to exist. The EIA team furthermore does not indicate that by adding two more reactors to the Cernavoda complex, the hit-chance by an aircraft (one of the key arguments in the EPRI study) would double. It would be more adequate to reflect the wider spectrum of scientific opinion on this matter and take an conservative approach which accepts the fact that a risk exists and determines the possible environmental impacts of such an event instead of dismissing the possibility on the basis of one study.

Ad 3. Analysis of emissions, fuel chain and radioactive wasteRemarks on the answers referring to the EIA study can be found in our comments on the respective chapters, though it would have helped when chapter numbers would have been indicated in the response from the EIA authors team.The description here concerning radioactive waste does not comment at all on the factual reality that Romania, like all other countries operating nuclear power stations world-wide, has no solution for the HLW (high level radioactive waste) that is produced by nuclear reactors. Reality is that no country can guarantee that HLW can be kept out of the environment for as long as needed to make it harmless. On top of this, Romania is far behind in addressing this issue in comparison with its neighbours, let alone with countries like the UK, Finland, Sweden or the US. Producing more of this kind of waste is plainly irresponsible behaviour from the point of view of sustainability.

Ad 4. Economics of the Cernavoda units 3 and 4The EIA team bases its argumentation on a study from the International Energy Agency. It does not include critique on this study, which amongst others points out that not the full costs of nuclear power are included in the mentioned pricing (direct and indirect subsidies, fiscal advantages not shared by other generation methods, low reservations for decommissioning and waste processing, etc.), that production prices are based on predictions by reactor builders (e.g. a price of 2000 USD / kWh construction costs for new build – against currently well over 3 500 USD / kWh (current budget instead of a planned budget of 2 500 USD / kWh) for the Finnish EPR plant in Olkiluoto) and that there have been critiques that the prices for CHP, wind and hydro were inflated. It has to be noted that the EIA team in its answer refers to completely outdated numbers in a cost study from the year 2000 for the Finnish EPR reactor in Olkiluoto. Where the construction budget for this reactor was 3 Billion EUR, current estimates after a two year delay in construction speak about 4,5 Billion EUR. It is of uttermost importance that price calculations are based on real figures and include all cost. A study commissioned by Greenpeace and the European Renewable Energy Council (EREC) and carried out by DLR, Institute of Technical Thermodynamics, Department of Systems Analysis and Technology Assessment, Stuttgart, Germany, on alternatives comes to the conclusion that the introduction of a mix of decentralised solutions, energy efficiency and renewable energy sources is already on the shorter term cheaper than business as usual including nuclear power11. It is typical that the EIA team only compares the costs of Cernavoda 3 and 4

9 GRS, Protection of German nuclear power plants against the background of the terrorist attack in the USA on 11 September 2001, Bonn (2002) Federal Ministry for the Environment, Nature Conservation and Nuclear Safety

10 Helmuth Hirsch, Oda Becker, Terrorism and War – Chapter 5 in Helga Kromp-Kolb, Andreas Molin (ed.), Nuclear Power, Climate Policy and Sustainability; An Assessment by the Austrian Nuclear Advisory Board, Vienna (2007) Austrian Federal Ministry of Agriculture and Forestry, Environment and Water Management; http://umwelt.lebensministerium.at/article/articleview/58420/1/13788/ - Added as Annex 2.

11 EREC, Greenpeace, futu[r]e investment; a sustainable investment plan for the power sector to save the climate,


http://umwelt.lebensministerium.at/article/articleview/58420/1/13788/

with fossil fuels and not with other options.

Ad 5. The Energy PolicyIt is refreshing to see that at least the EIA team has noticed in its answer that abatement of climate change has become an important goal in the EU energy policy. Unfortunately, the Romanian energy policy has not included this12. The EIA team is, however, wrong in postulating that nuclear power would be a logical answer to meet this goal. Investments in nuclear power are – per ton CO2 prevented – considerably higher, the needed CO2 emission reductions come considerably later and in total would be only a tiny part of total CO2 emissions, compared to an active policy in energy efficiency, decentralisation of electricity and heat generation and the introduction of renewable energy sources. Such a policy can be implemented faster than new nuclear power stations, against lower cost and yield more sustainable long term CO2 reductions13. We therefore strongly demand that a scenario along the lines of Greenpeace / EREC”s energy [r]evolution scenario14 is worked out and taken up within the EIA.The Romanian energy policy on which the EIA is based is completely outdated. For that reason, the Romanian government is currently working on a new energy policy. Recently it became clear that it would have to run through a Strategic Environmental Assessment procedure for this strategy. Greenpeace also demands that a full set of different scenarios, including one on the basis of the above mentioned energy [r]evolution scenario, will be taken up into the considerations.Greenpeace is convinced that when such scenario studies are done properly (and not only on the basis of an “we have to get to a nuclear solution” attitude as done within this EIA), the nuclear option will not come out as least-cost, nor as most agreeable for the development of Romania.

Amsterdam (2007); http://www.greenpeace.org/international/press/reports/future-investment12 Ministerul Economiei si Finantelor, Proiect Strategia Energetică a României în Perioada 2007 – 2020; Varianta 5

iulie 2007, Bucharest (2007); http://www.minind.ro/presa_2007/iulie/Strategia_9_iulie.pdf 13 See EREC, Greenpeace, futu[r]e investment; a sustainable investment plan for the power sector to save the climate,

Amsterdam (2007) – and – EREC, Greenpeace, energy [r]evolution; a sustainable world energy outlook, Brussels/Amsterdam (2007); http://www.greenpeace.org/international/press/reports/energyrevolutionreport

14 EREC, Greenpeace, energy [r]evolution; a sustainable world energy outlook, Brussels/Amsterdam (2007)


http://www.greenpeace.org/international/press/reports/energyrevolutionreport

http://www.minind.ro/presa_2007/iulie/Strategia_9_iulie.pdf

http://www.greenpeace.org/international/press/reports/future-investment

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