PLAN FOR THE ESTABLISHMENT OF A PERMANENT REPOSITORY FOR DANISH LOW AND INTERMEDIATE

Transcription

1 To Ministry of Health Document type Date Translated version of the non-technical summary of the Plan for the establishment of a permanent repository for Danish low and intermediate level radioactive waste Strategic Environmental Assessment report. If the translated version should not match the Danish version, the Danish version will take precedence. PLAN FOR THE ESTABLISHMENT OF A PERMANENT REPOSITORY FOR DANISH LOW AND INTERMEDIATE LEVEL RADIOACTIVE WASTE STRATEGIC ENVIRONMENTAL ASSESSMENT REPORT STRATEGIC ENVIRONMENTAL ASSESSMENT REPORT

2 PLAN FOR THE ESTABLISHMENT OF A PERMANENT REPOSITORY FOR DANISH LOW AND INTERMEDIATE LEVEL RADIOACTIVE WASTE STRATEGIC ENVIRONMENTAL ASSESSMENT REPORT Date 01/10/2014 Written by MJK, NLR, SSB, JAIP Checked by JAKK Approved by TFJ Contributions Danish Health and Medicines Authority (National Institute of from Radiation Protection) GEUS Geological Survey of Denmark and Greenland Danish Decommissioning and Danish Nature Agency Ref:

3 CONTENTS 1. Non-technical summary Background Content and purpose of the plan Production of Strategic Environmental Assessment Assessment of environmental impact Mitigation measures Monitoring programme Background Basis for decision International commitments Content and purpose of the plan Area delimitation Guidelines for establishing a permanent repository Production of Strategic Environmental Assessment Purpose and process description Potential impact of the plan Public meetings Scoping report Alternatives Method description Environmental status Assessment of impact Structure of the report Relationship to other plans and legislation The Executive Order on Habitats: Water management plans Planning Act National Planning Report Zero alternative Decommissioning of Risø Definition of the zero alternative Planning conditions Biodiversity Population, health and well-being Landscape and geology Climate Water Soil Tangible assets Cultural heritage Summary assessment 51

4 8. Østermarie-Paradisbakkerne Planning conditions Biodiversity Population and health Landscape and geology Climate Water Soil Tangible assets Cultural heritage Cumulative effects Summary assessment Rødbyhavn Planning conditions Biodiversity Population and health Landscape and geology Climate Water Soil Tangible assets Cultural heritage Cumulative effects Summary assessment Kertinge Mark Planning conditions Biodiversity Population and health Landscape and geology Climate Water Soil Tangible assets Cultural heritage Cumulative effects Summary assessment Thyholm Planning conditions Biodiversity Population and health Landscape and geology Climate Water Soil Tangible assets Cultural heritage Cumulative effects Summary assessment Thise, Salling Planning conditions Biodiversity Population and health Landscape and geology Climate 179

5 12.6 Water Soil Tangible assets Cultural heritage Cumulative effects Summary assessment Skive Vest Planning conditions Biodiversity Population and health Landscape and geology Climate Water Soil Tangible assets Cultural heritage Cumulative effects Summary assessment Summary Local impact Mitigation measures Biodiversity Population and health Water Monitoring programme General Population and health References 223 MAPS: Risø (zero alternative) Map 0.1 Biodiversity Map 0.2 Landscape and geology Map 0.3 Drinking water interests Map 0.4 Tangible assets Map 0.5 Cultural heritage Østermarie-Paradisbakkerne Map 1.1 Biodiversity Map 1.2 Landscape and geology Map 1.3 Drinking water interests Map 1.4 Tangible assets Map 1.5 Cultural heritage Rødbyhavn Map 2.1 Biodiversity Map 2.2 Landscape and geology Map 2.3 Drinking water interests Map 2.4 Tangible assets Map 2.5 Cultural heritage

6 Kertinge Mark Map 3.1 Biodiversity Map 3.2 Landscape and geology Map 3.3 Drinking water interests Map 3.4 Tangible assets Map 3.5 Cultural heritage Thyholm Map 4.1 Biodiversity Map 4.2 Landscape and geology Map 4.3 Drinking water interests Map 4.4 Tangible assets Map 4.5 Cultural heritage Thise Map 5.1 Biodiversity Map 5.2 Landscape and geology Map 5.3 Drinking water interests Map 5.4 Tangible assets Map 5.5 Cultural heritage Skive Vest Map 6.1 Biodiversity Map 6.2 Landscape and geology Map 6.3 Drinking water interests Map 6.4 Tangible assets Map 6.5 Cultural heritage

7 1 of NON-TECHNICAL SUMMARY An inter-ministerial working group is reviewing three possible solutions for the handling of Danish low and intermediate level radioactive waste: 1) A permanent repository for the waste; 2) Establishment of an intermediate storage facility for the waste; and 3) Exporting all the waste. This discusses the potential environmental effects of implementing a plan for the first solution, i.e. a Plan for the establishment of a permanent repository for Danish low and intermediate level radioactive waste ; cf. Danish Act on Environmental Assessment of Plans and Programmes (Consolidated Act No 939 of 3 July 2013). 1.1 Background Basis for decision ( Research report ), 2009 The proposal for a Plan for the establishment of a permanent repository for Danish low and intermediate level radioactive waste has been drawn up on the basis of feasibility studies and local area studies. These originate from a number of policy decisions, including the research report from 2009, which describes (among other things) the framework for decommissioning Risø the nuclear research facilities at the Risø peninsula (hereafter: Risø). Decommissioning of the nuclear facilities at Risø has started, and the state-owned enterprise Danish Decommissioning has been set up for this purpose. In parallel with the closure of the nuclear research facilities, the plan is to examine the possibility of setting up a permanent repository that is able to host the radioactive waste currently stored at Risø plus the waste generated elsewhere in the country for a number of years to come /15/ International commitments The basis for the decision includes a number of international commitments, such as the EURATOM Treaty, the IAEA Joint Convention, the Spent Fuel and Radioactive Waste Directive, the Århus Convention and the Espoo Protocol. This last requires the parties to carry out a strategic environmental impact assessment of certain plans that could have a significant impact on the environment, and to inform the relevant neighbouring countries if it is believed that the plan could have a significant transboundary impact on the environment. The fundamental safety and environmental principles for disposal of the radioactive waste are set out in the Research report and explain, among other things that: Radioactive waste shall be managed in such a way as to assure that possible effects on human health and the environment beyond national borders will be taken into account. It is based on the principle that a country is required to act responsibly and, as a minimum, prevent any effect on human health and the environment in other countries above what is acceptable inside the country s own borders. Implementing the plan must therefore not produce any significant transboundary effects. At this stage of the planning, no significant transboundary effects have been identified. The subsequent planning and project design phases will ensure that the project itself does not carry the risk of any significant transboundary effects. The definition of the contents of the Strategic Environmental Assessment (the scoping) was sent out in the Espoo consultations, and the plan for the establishment of a permanent repository with the associated SEA report will be as well.

8 2 of 234 In accordance with the Espoo Convention, specific assessments of transboundary effects can be produced at a later date when there are concrete projects in place in selected locations with a confirmed repository concept. The results of these studies will be communicated to all parties to the Espoo consultation procedure wishing to participate in further rounds of consultation. 1.2 Content and purpose of the plan Area delimitation Regional surveys from the feasibility studies identified 22 sites that were deemed suitable for a permanent repository. The sites were identified on the basis of existing information and data. Six areas that, based on geological criteria, were more suitable than the others were identified in the feasibility studies, with the recommendation that further studies should be conducted on these sites. The six sites are: Østermarie-Paradisbakkerne, Bornholm Regional Municipality; Rødbyhavn, Lolland Municipality; Kertinge Mark, Kerteminde Municipality; Hvidbjerg, Thyholm, Struer Municipality; Thise, Salling, Skive Municipality; Skive Vest, Skive Municipality. The Environmental Impact Assessment Act stipulates that the zero alternative should be described and assessed. This is the situation in which the plan is not implemented. In this context, the zero alternative is defined as continued storage at Risø. The six potential sites and the zero alternative are marked on Figure 1-1. Figure 1-1 Map illustrating the six potential sites for a permanent repository and the zero alternative at Risø marked in yellow. The repository should be able to hold all Danish low and intermediate level, short and long lived lived radioactive waste from operations, research activities and the decommissioning of the Risø research facilities, including the special waste such as irradiated experimental fuel if no other solution for this waste is found. The repository must also be able to host the other types of waste (including the potential waste described in the research report, e.g. radioactive waste from hospitals, industry etc.).

9 3 of 234 The following types of repository may be established after closer examination in a subsequent project design phase: A. A near-surface repository (on the ground and down to max. 30 m below ground). B. A near-surface repository in combination with a bore hole to some parts of the long lived waste. C. An intermediate depth repository ( m below ground). A B C Figure 1-2 The three general repository concepts. The purpose of the plan guidelines is both to provide the overall framework for a future project and to reduce or prevent a number of the potential environmental effects that have been identified. The guidelines deal with the following matters: 1. Waste types 2. Repository types 3. Geological requirements 4. Area requirements 5. Location 6. Radiation protection 7. Natural landscape 8. Cultural heritage 9. Building and protective lines 10. Groundwater 11. Climate 12. Designated low-lying areas and potential wetland areas 13. Security 14. Safeguarding against seepage of other harmful substances 1.3 Production of Strategic Environmental Assessment Purpose and process description According to the Environmental Assessment Act (Consolidated Act no 939 of 3 July 2013), the plans and programmes of public agencies establishing the framework for future facilities or landuse are subject to environmental assessment. In accordance with this, the Danish Ministry of Health will arrange for a Strategic Environmental Assessment (SEA) of the plan to establish a permanent repository.

10 4 of 234 The purpose of the SEA is to identify the potential effects on the environment from implementing the plan. The plan includes six equal alternatives in the form of six gross areas, as illustrated in section The purpose of the Strategic Environmental Assessment and this SEA report is thus to identify the potential effects on the environment from implementing the plan with the equal alternatives. The report therefore does not identify which of these sites is/are considered to be most suitable. The Strategic Environmental Assessment is carried out in the initial stages of planning. More detailed environmental studies and safety assessments will be produced at a later stage, provided that it is decided to move forward with the permanent repository solution. The process is outlined in Figure 1-3. Figure 1-3 Outline of the process from the initial planning stages to the final adoption and creation of a project Public meetings Six public meetings have been held, both to provide information on the process and to gather information on local conditions and potential environmental impacts. This information has formed part of the basis for defining the content of the Strategic Environmental Assessment. The major concerns raised by the stakeholders are also included in the Strategic Environmental Assessment as part of the basis for assessing the impact on the population and socio-economic aspects.

11 5 of Scoping report As part of the initial phase, a scoping report has been drawn up, in order to identify the potentially most significant environmental impacts inherent in the execution of the plan, thereby defining which environmental issues need to be examined in greater detail in the Strategic Environmental Assessment. As a result of the scoping and the subsequent official consultation procedure, the following topics were selected for discussion in the Strategic Environmental Assessment: Biodiversity, population and health, landscape and geology, climate, water, soil, tangible assets and cultural heritage. 1.4 Assessment of environmental impact The Strategic Environmental Assessment should cover fundamentally the same level of detail as the plan for a permanent repository. The plan sets out a number of high-level conditions for establishing a permanent repository within a few relatively large areas, referred to below as the planned sites. In a later EIA (Environmental Impact Assessment) phase it will be possible to examine in more detail the environmental impact of an actual project in a specific location. The overall guidelines in the plan may involve activities and measures to close off land which are comparable whatever the choice of location, which may have an impact related to e.g. radiation doses from the transport of the radioactive waste from Risø to a future repository. The sections below present a method description to analyse the existing conditions, called the environmental baseline, and for an assessment of the impact, followed by the general impact, the zero alternative and ending with a summary of the key issues at each of the planned sites which are considered relevant to the establishment of a permanent repository Method description Environmental status The analysis of the environmental status is limited to the environmental issues selected in the scoping. The description is based in existing material in the form of feasibility studies, local area studies and details of conservation interests and land use in the relevant municipalities. It also includes details of local issues from the public meetings that have been held. Assessment of impact In this context, an environmental impact is defined as a potential conflict between the plan and environmental concerns. This may take the form of conflicts with existing or planned land-use within the planned site, conservation interests or environmental goals. As part of the assessment of the overall scope and significance of the impact, it will be examined whether the impact can be reduced or averted simply by the choice of final location within the planned site, or whether the impact is independent of the positioning. This is followed by an assessment of the degree of impact, categorised as none, small, moderate or significant General impact Radiation protection The authorities set quantitative requirements for radiation protection for people in the form of principles and thresholds for radiation exposure of employees and members of the public in the different periods that a permanent repository will pass through. The requirements will be set by the National Institute of Radiation Protection (part of the Danish Health and Medicines Authority). These requirements can only be defined when there is an actual project. Securing the facility The likelihood of unwanted intrusion into the facility is considered to be small, but it depends on the type of repository that is established and whether people are aware of its existence. Apart from the unplanned intrusion from studies, there may also be a risk of intrusion in the form of

12 6 of 234 burglary and vandalism. This risk will be included in the requirements for securing a future facility, and it is at present not possible to evaluate further. Transport An assessment of the disruption to traffic in the construction phase, including the number of shipments, traffic routes, safety, noise and emissions, will be included in a detailed EIA study of two selected locations, provided that it is decided to go ahead with the assessment of a solution for a permanent repository. The National Institute of Radiation Protection (SIS part of the Danish Health and Medicines Authority) has carried out a feasibility study using model calculations to determine potential radiation doses from the transport of radioactive waste from the current storage at Risø to a future permanent repository for low and intermediate level waste. Calculations show that the estimated radiation doses from accident-free transport of the Danish radioactive waste from Risø to a future permanent repository do not place any restrictions on the location of this repository. The risks of an accident situation have also been calculated. The risks associated with the modelled accident scenarios are minor and hence acceptable. Changes in distance have no effect on doses in the event of an accident. The likelihood of an accident is dependent on the quality of the road, the volume of traffic etc., and is also proportional to the distance Zero alternative The zero alternative is defined as a situation where the existing and future radioactive waste remains stored at Risø in the buildings and facilities in existence today. It is a precondition that the official requirements on radiation protection and safety, including dose constraints, will remain unchanged after The zero alternative therefore does not cover the establishment of a permanent repository, but provides a basis for comparison in the Strategic Environmental Assessment. Figure 1-4 Outline map Risø.

13 7 of 234 Risø lies within both the designated coastal zone and the beach protection belt, and is also a designated low-lying area in the Roskilde Municipal Plan. It is possible that there could be a greater risk of seepage in the future, particularly with rising sea levels and extreme events, so there is a greater risk of impact on surface water and natural conditions than there is today. The highest water level recorded in the port of Roskilde during the storm Bodil on 5 December 2013 was 2.06 metres above mean sea level. During the night to 6 December 2013, water penetrated a low-lying basement of a Danish Decommissioning building. This part of the basement was not used to store radioactive material, so the flooding did not cause any radioactive emissions. A higher water level could cause flooding problems in parts of the Risø area Østermarie-Paradisbakkerne Østermarie-Paradisbakkerne is in the northeast of Bornholm close to the coast outside Bølshavn and Listed. The site covers an area of approx. 15 km 2. Figure 1-5 Outline map Bornholm.

14 8 of 234 The planned site is to the north of the elevated forest area of Paradisbakkerne. The land rises to 65 to 80 metres above sea level, and is made up of hillsides and river valleys. The area is near the coast, and half of the site is within the designated coastal zone. It borders the international Natura 2000 conservation zones of Gyldenså and Almindingen, Ølene and Paradisbakkerne. The latter contains one of Denmark s largest continuous areas of forest. There is a potential impact on groundwater as a result of leakage. The geographical extent of the impact is hard to predict because of limited knowledge of fracture systems in the bedrock and the resulting uncertainty surrounding details of the flow of groundwater. The risk of impact is greatest if a near-surface repository extending down to a depth of 30 metres is chosen. Given the misgivings among citizens about the contents of the plan and the subsequent process, it is felt that there could be indirect effects on the population, including local food production and the island s brand, tourism particularly the nearby Joboland and the social structure in terms of people leaving the area Rødbyhavn The planned site at Rødbyhavn is situated to the east of Rødby. The site covers an area of approx. 20 km 2. Figure 1-6 Outline map Rødbyhavn. The general impression of the landscape is a very flat terrain without much variation. Most of the site is between sea level and the 4 m contour. Along the south coast the land is protected against flooding from the sea by a dyke which is more than 4 metres high.

15 9 of 234 A small area of the south-western part of the planned site is covered by the designated coastal zone. The planned site also contains reserved areas for e.g. the Fehmarn Belt Fixed Link and a raw material area. Future changes in climate will have a limited effect on the area. Rising sea levels will not top the existing dykes, but in extreme situations with storm conditions there will be growing pressure on these dykes. The impact on groundwater depends on the location of the facility. If the facility is located in thick clay, this is expected to form a very effective geological barrier against seepage into the surroundings. Given the misgivings among citizens about the contents of the plan and the subsequent process, it is felt that there could be indirect effects on the population, tourism, including the nearby Lalandia, food production and the social structure in terms of a greater tendency for people to leave the area Kertinge Mark This site is located in the north-east of the island of Fyn (Funen). The Kertinge Mark peninsula is bordered to the west, north and north-east by Kerteminde Fjord and Kertinge Nor, with the villages of Kerteminde to the north-east and Munkebo to the north-west. The site covers approx. 7 km 2. Figure 1-7 Outline map Kertinge Mark. The whole of the planned site is inside the designated coastal zone. In the middle of the peninsula is a central hill running north/south and rising to between 15 and 20 metres above sea level. From the top of the hill, the land slopes gently away to the coast. With a future rise in sea

16 10 of 234 levels and more frequent storms, there will be a risk of flooding. This risk can be minimised by taking account of the position of the facility on the ground. If the facility is placed in the thick clay deposits that exist within the planned site, the clay is expected to form an effective geological barrier against seepage into the surrounding land. Given the misgivings among citizens about the contents of the plan and the subsequent process, it is felt that there could be indirect effects on the population and tourism, including the nearby Ladby Viking Museum, local food production and the social structure in terms of a possible tendency for people to leave the area Thyholm The site at Hvidbjerg is on Thyholm, which is a peninsula in the northern part of Struer Municipality on the south bank of Limfjord, south-west of Mors and east of Thy. The site covers an area of approx. 6.6 km 2. Figure 1-8 Outline map Thyholm. The landscape is uniform, with an even, undulating terrain reaching its highest point 25 metres above sea level. The boundary of the planned site follows the coastline to the west and east. The whole of Thyholm is situated within the designated coastal zone. The planned area borders the Natura 2000 area Agger Tange, Nissum Bredning, Skibsted Fjord and Agerø. This comprises several large marine segments, including Nissum Bredning. By far the biggest part of the site will not be affected by a possible future 80 cm rise in sea level, but it is important to provide for a future placement of the repository on the site that avoids any impact from future rises in sea level on the low-lying areas.

17 11 of 234 The clay deposits in the area are generally low-permeable. Bore holes on the site show that there are substantial faults in the strata. This may mean that the clay is not continuous throughout the area, although the bore holes reveal a clear preponderance of clay deposits down to greater depths. Given the misgivings among citizens about the contents of the plan and the subsequent process, it is felt that there could be indirect effects on the population, tourism and business, including fishing (e.g. exports of mussels), agriculture and the social structure in terms of a possible tendency for people to leave the area Thise The site is located in the eastern part of the Salling peninsula in Skive Municipality, in the central part of the Limfjord area. The site covers approx. 14 km 2. Figure 1-9 Outline map Thise. This area comprises a large, high and almost flat plateau which includes the majority of the central and south-eastern part of the planned site. The plateau is 25 to 40 metres above sea level. The landscape slopes gently from the plateau to the west and north-west and a little more steeply to the north-east. The eastern part of the planned site is inside the designated coastal zone. A small part of the coastal areas may be flooded, and we may expect increased erosion of the coastal cliffs. The areas near Gåsemose and along the banks of the stream at Eskær may be flooded, which will be taken into account in selecting a final location for the repository.

18 12 of 234 If the facility is placed in the thick clay deposits within the site, the clay is expected to form an effective geological barrier against seepage into the surroundings. If the facility is located closer to the surface, the geological/hydrological conditions in the area may have more difficulty holding back seepage compared to areas with fewer layers of sand. There is a catchment area for a public waterworks (Thise Waterworks) within the site. The groundwater in the Thise area is considered to be particularly vulnerable. Given the misgivings among citizens about the contents of the plan and the subsequent process, it is felt that there could be indirect effects on the population, tourism and business, including agriculture and food production (e.g. Thise Dairy) and the social structure in terms of a possible tendency for people to leave the area Skive Vest The site lies to the west of Skive on Skive Fjord (Limfjord) and is part of Skive municipality. The site covers an area of approx km 2. Figure 1-10 Outline map Skive Vest. This planned site includes of two different types of landscape. The northern half is high, hilly land, while the southern half of the site is a low-lying river valley which developed on a former flat moor. Most of the land is around 5 metres above sea level. Half of the area is located inside the planned Flynder Sø Sønder Lem Vig local park. Assuming a rise in sea levels around Denmark of max. 1.5 m (by 2100), flooding of the area is not expected. However, the southern part of the site is expected to become still wetter as (other things being equal) the water table will rise as a result of rising sea levels.

19 13 of 234 There are clay deposits within the site, which are low-permeable. The whole site also contains clayey till with fractures and layers of meltwater sand and gravel. If the facility is placed in thick clay deposits, the clay is expected to form an effective geological barrier against seepage into the surroundings. Given the misgivings among citizens about the contents of the plan and the subsequent process, it is felt that there could be indirect effects on the population, tourism and leisure, local food production and the social structure in terms of a possible tendency for people to leave the area. 1.5 Mitigation measures To limit the environmental impact of implementing the plan, restrictive guidelines have been included which are designed either to avert or reduce this impact. Mitigation measures may also be taken as work proceeds on more detailed planning for a possible future facility. Mitigation measures are therefore proposed, which can be implemented along with the plan for biodiversity, radiation and security, population, groundwater and drinking water interests and surface water. 1.6 Monitoring programme The purpose of the monitoring programme is to be able to assess whether implementing the plan will produce the expected effects on the environment, and whether it is necessary to mitigate any impact that has not been foreseen. Where possible, it is therefore proposed to monitor the expected significant effects of the plan on the environment. The plan contains a number of guidelines which not only provide the overall framework for establishing a permanent repository but are also intended to prevent or mitigate any potential impact on the environment. In the later planning and project design phases, the monitoring can then include an assurance that the plan guidelines are complied with. It will also be determined whether the guidelines in the plan and the proposed mitigation measures are sufficient to ensure that there will be no significant environmental impact from implementing the plan. A monitoring programme will also be drawn up for any future project, to be planned on the basis of the actual situation, i.e. the chosen repository type and the geology etc. in the area. This type of monitoring programme may be related to exposure to radiation and include measurements of the emissions and a comparison of these with the specified dose constraints and emission values derived from these. The programme can then specify the monitoring of water quality. These matters will be defined in a later phase when a specific project is at hand.

20 14 of BACKGROUND An inter-ministerial working group is reviewing three possible solutions for the handling of Danish low and intermediate level radioactive waste. The solutions are: a permanent repository in Denmark, intermediate storage in Denmark and export of all waste. This Strategic Environmental Assessment discusses the potential environmental effects of implementing a plan for a permanent repository for Danish low and intermediate level radioactive waste. This section presents the background to this plan. 2.1 Basis for decision The feasibility studies, local area studies and the proposal for a Plan for the establishment of a permanent repository for Danish low and intermediate level radioactive waste were preceded by a number of policy decisions which are outlined below Proposal no B 48 The purpose of the Proposal for a resolution of the Folketing (Danish Parliament) on the decommissioning of the nuclear facilities at the Risø Research Centre from 2002 was to provide a basis for starting the decommissioning of the nuclear facility at Risø under the auspices of the independent state-owned enterprise Danish Decommissioning. The proposal was adopted by the Folketing on 13 March Work also started on a research report as a basis for deciding on a Danish permanent repository for low and intermediate level radioactive waste /17/ Basis for decision The report from 2009 has been presented to the Folketing for decision, as suggested in Proposal no B 48. Decommissioning of the nuclear facilities at Risø has started, and the state-owned enterprise Danish Decommissioning has been set up for this purpose. In parallel with the closure of the nuclear research facilities, the plan is to examine the possibility of setting up a permanent repository that is able to host the radioactive waste currently stored at Risø plus the waste generated elsewhere in the country for a number of years to come /15/ Permanent repository for radioactive waste in Denmark, June 2005 This publication discusses why a repository for radioactive waste needs to be established in Denmark /16/. It also explains where the radioactive waste comes from and what quantities are involved. It describes where a permanent repository can be constructed and the safety requirements for human beings and the environment. Finally, it covers the subsequent process, including how it will ultimately be decided where in the country the repository should be located /16/. 2.2 International commitments The basis for the decision includes a number of international commitments, which are summarised below EURATOM Treaty Among other things, the Treaty states that the EU (the Council) will lay down basic safety standards for all use of ionising radiation, including nuclear facilities and control of radioactive material. The basic safety standards will normally take the form of Directives to be transposed subsequently into national law. According to Article 37 of the Treaty, each Member State must provide the Commission with such general data relating to any plan for the disposal of radioactive waste in whatever forms will make it possible to determine whether the implementation of such plan is liable to result in the radioactive contamination of the water, soil or airspace of another Member State. The Commission will deliver its opinion within six months, after consulting a group of experts /15/.

21 15 of IAEA Waste Convention The Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management entered into force on 18 June Denmark signed the Convention on 9 February 1998 and finally accepted it on 3 September Among other things, the Convention contains a declaration that, wherever possible, radioactive waste should be disposed of in the State in which it was generated. Review meetings are held every three years to assess whether the individual countries are complying with the Convention /15/ Council Directive 2011/70/Euratom of 19 July 2011 Council Directive 2011/70/Euratom of 19 July 2011 establishing a Community framework for the responsible and safe management of spent fuel and radioactive waste sets out the guidelines for handling all radioactive waste from civilian activities, from generation to disposal. It ensures that national arrangements are introduced to provide for a high level of safety in spent fuel and radioactive waste management. The purpose of the Directive is to protect workers and the general public against the dangers arising from ionising radiation, and to avoid imposing undue burdens on future generations Aarhus Convention The international Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters (the Aarhus Convention) is designed to safeguard citizens rights in the environmental field. The Convention, which was signed by 35 countries on 25 June 1998, entered into force on 30 October It was implemented in Denmark by Order No 447 of 31 May 2000 (Act amending certain environmental laws, implementing the Aarhus Convention etc.) as amended. It should be noted that no amendments have been made to the law relating to nuclear matters as a result of this Convention /15/ Espoo Protocol The Espoo Protocol ( Protocol on Strategic Environmental Assessment ) is a protocol to the UN Convention on Environmental Impact Assessment in a Transboundary Context, popularly known as the Espoo Convention. The protocol requires the parties to carry out a Strategic Environmental Assessment of certain plans and programmes that could have a significant impact on the environment, including health and wellbeing, and to inform the relevant neighbouring countries if it is believed that the plan or programme could have a significant transboundary impact on the environment. The scoping report, which is intended to identify the potential major effects on the environment from implementing the plan, was the subject of consultation in neighbouring countries in parallel with the official consultation procedure in Denmark. The SEA report itself will be sent for consultation in the countries that have expressed a wish to participate in further consultation Transboundary effects The fundamental safety and environmental principles for disposal of the radioactive waste are set out in the Research report and explain, among other things that: Radioactive waste must be handled in such a way as to ensure that the possible effects on people and the environment beyond the country s borders are considered /15/. It is based on the principle that a country is required to act responsibly and, as a minimum, prevent any effect on human health and the environment in other countries above what is acceptable inside the country s own borders. Implementing the plan must therefore not produce any significant transboundary effects. At this stage of the planning, no significant transboundary effects have been identified. The subsequent planning and project design phases will ensure that the project itself does not carry the risk of any significant transboundary effects.

22 16 of 234 In accordance with the Espoo Convention, specific assessments of possible transboundary effects can be produced at a later date when there are concrete projects in place in selected locations with a confirmed repository concept. The results of these studies will be communicated to all parties to the Espoo consultation procedure wishing to participate in further rounds of consultation.

23 17 of CONTENT AND PURPOSE OF THE PLAN 3.1 Area delimitation Regional surveys from the feasibility studies identified 22 sites that were deemed suitable for a permanent repository. The sites were identified on the basis of existing information and data. Criteria and methods followed the guidelines issued by the International Atomic Energy Agency (IAEA) in 1994 and 1999, which have now been consolidated into new guidelines dated 2009 and 2014, but with the same content /7/, /8/, /9/. Six areas that were more suitable than the others based on geological criteria were identified by the feasibility studies, with the recommendation that further studies be conducted on these sites. The six sites are: 1. Østermarie-Paradisbakkerne, Bornholm Regional Municipality 2. Rødbyhavn, Lolland Municipality 3. Kertinge Mark, Kerteminde Municipality 4. Hvidbjerg, Thyholm, Struer Municipality 5. Thise, Salling, Skive Municipality 6. Skive Vest, Skive Municipality. The Environmental Impact Assessment Act stipulates that the zero alternative should be described and assessed. This is the situation in which the plan is not implemented. The zero alternative thereby serves as a basis for comparison in the environmental assessment. In this context, the zero alternative is defined as continued storage at Risø, as described in section 7. Figure 3-1 Outline map illustrating the six potential sites for a permanent repository and the zero alternative at Risø marked in yellow. 3.2 Guidelines for establishing a permanent repository The planning phase (research report, feasibility and local area studies) and the present environmental impact assessment have resulted in the following guidelines for establishing a permanent repository within one of the six designated areas.

24 18 of Types of waste: The repository should be able to hold all Danish low and intermediate level, short and long lived radioactive waste from operations, research activities and the decommissioning of the Risø research facilities, including the special waste such as irradiated experimental fuel if no other solution for this waste is found. The repository should also be able to accommodate the waste category tailings and contaminated concrete if there is no other solution for this material, and waste from external users such as hospitals and universities. It must also be possible to accept and store potential waste, such as the production of radioactive waste from hospitals, industry etc., if it is decided to keep the repository open for a number of years; cf. also Basis for decision on a Danish permanent repository for low and intermediate level radioactive waste /15/. 2. Repository types: The following types of repositories may be established after closer examination in a subsequent project design phase: a. A near-surface repository (on the ground and down to max. 30 m below ground). b. A near-surface repository in combination with a bore hole for some parts of the long lived waste. c. An intermediate depth repository ( m below ground). 3. Geological requirements: a. The terrain within the repository site finally chosen should be predominantly flat, horizontal and stable. b. Deposits from the surface down to the greatest possible depth should be homogeneous and low-permeable. On the surface, clayey till should dominate, but this cover of clayey till should be as thin as possible over most of a site. It should be possible for the deposits to enclose or underlie a repository, which is best achieved if there are thick, low-permeable layers of great thickness and significant horizontal extension within the sites. c. A near-surface repository concept (0 30 m below ground) could be a combination of clayey till on top and more low-permeable strata immediately below. The aim is to be able to get down to the particularly low-permeable layers as quickly as possible. If the repository is placed at surface level, the clayey till should be as thin as possible. d. The intermediate depth repository concept ( m below ground) should always be in the low-permeable strata. e. If part of the waste is placed in a bore hole, it will always be located in the lowpermeable layers. The depth of the bore hole will depend on the depth and extension of the geological layers. 4. Area required: An area of around 2-3 ha (20,000-30,000 m 2 ) will be required. As such, the facility will occupy an area of approx. 150 x 150 m, or a corresponding total area within the much larger designated gross areas. 5. Location: The permanent repository should be located within one of the 6 designated areas: 1) Østermarie-Paradisbakkerne, Bornholm Regional Municipality; 2) Rødbyhavn, Lolland Municipality; 3) Kertinge Mark, Kerteminde Municipality; 4) Hvidbjerg, Thyholm, Struer Municipality; 5) Thise, Salling, Skive Municipality and 6) Skive Vest, Skive Municipality. 6. Radiation protection: The establishment of a permanent repository for radioactive waste in Denmark must comply with Council Directive 2013/59/Euratom of 5 December 2013 laying down basic safety standards for protection against the dangers arising from exposure to ionising radiation, Council Directive 2011/70/Euratom of 19 July 2011 establishing a Community framework for the responsible and safe management of spent fuel and radioactive waste, and the IAEA s Fundamental Safety Principles and related guides and standards, and other relevant Danish law. Among other things, the Directives ensure that radioactive waste is handled in a way that provides for an acceptable level of safety for

25 19 of 234 people and the environment, and protects future generations against undue burdens; cf. also Basis for decision on a Danish permanent repository for low and intermediate level radioactive waste /15/. These and other relevant considerations (including the possibility of transboundary impact) will be addressed by ensuring that any future facility is designed to be able to demonstrate compliance with the dose constraints specified when in operation and after closure at any time, for those periods and for potential incidents (accident scenarios). Documentation for this will be provided in the form of safety assessments for the facility and its use. 7. Natural landscape: The future facility cannot be located within Natura 2000 areas. Nor should the plan entail any significant impact on adjacent Natura 2000 areas. If possible, the location of the facility should take into account identified interconnected nature areas, wildlife corridors and the like, as identified in the respective municipal plans. 8. Cultural heritage: Protected areas and ancient monuments must be taken into account in the location of the repository. If possible, the facility should therefore be located outside protected areas and should not conflict with protected ancient monuments. During the construction phase, the provisions of the Museums Act will apply, ensuring that due consideration is given to finds of cultural and historical value. 9. Building and protective lines: It is assumed that the facility will not be situated within the beach protection belt and that, as far as possible, it will not be located within building and protection lines for churches, ancient monuments, forests, lakes or rivers. 10. Groundwater: The facility must not be located in an Area of Special Drinking Water Interests (OSD). The location should take account of the major groundwater and drinking water interests within Areas with Drinking Water Interests (ODs). Where groundwater lowering is required, consideration must be given to the water table and water quality in nearby watercourses and lakes. 11. Climate: The future facility must be designed to allow for expected climate change up to the year This will be based on calculations of future scenarios from the Danish Meteorological Institute (DMI), with the following results: a temperature increase of 1.2 C, +/- 0.2 C, by 2050 and an increase of 2.9 C, +/- 0.3 C, by 2100, with more precipitation in winter and more extreme rainfall and storms. Consideration should also be given to a possible rise in sea levels of max. 1.5 metres above normal up to 2100, and the conditions that can arise from flooding during extreme storms /15/. 12. Low-lying areas and potential wetland areas: To ensure that the facility is climate-proof, among other reasons, it is assumed that the facility will not be located within designated lowlying areas and potential wetland areas. 13. Security: The design and use of the future facility must prevent unauthorised access to the radioactive material stored there, including the prevention of damage, loss, theft or transfer of radioactive materials. 14. Safeguarding against seepage of other harmful substances: Parts of the radioactive waste will also be harmful to the environment in other ways, for instance due to the contents of hazardous waste such as heavy metals. This must be taken into account when constructing and operating the repository.

26 20 of PRODUCTION OF STRATEGIC ENVIRONMENTAL ASSESSMENT According to the Environmental Assessment Act (Consolidated Act no 939 of 3 July 2013), the plans and programmes of public agencies establishing the framework for future facilities or landuse are subject to environmental assessment. In accordance with this, the Danish Ministry of Health will arrange for a Strategic Environmental Assessment (SEA) of the plan to establish a permanent repository. 4.1 Purpose and process description The purpose of the SEA is to identify the potential effects on the environment from implementing the plan. The plan includes six equal alternatives in the form of six gross areas, as presented in section 3.1. The purpose of the Strategic Environmental Assessment and this SEA report is thus to identify the potential effects on the environment from implementing the plan for the equal alternatives. The report therefore does not identify which of these sites is/are considered to be most suitable, as there are a number of other factors that will be crucial in a final deliberation but which are not included in the SEA report. The strategic environmental impact assessment is carried out in the initial stages of planning and is based on the overall guidelines set out in the plan. More detailed environmental studies and safety assessments will be produced at a later stage, in connection with the Environmental Impact Assessment or EIA (Order No 764 of 23 June 2014) and the outline project design, when there is more knowledge of the actual project. The process is outlined in Figure 4-1. Figure 4-1 Outline of the process from the initial planning stages to the final adoption and creation of a project.

27 21 of Potential impact of the plan The plan defines the general framework for the establishment of a permanent repository for low and intermediate level radioactive waste within one of six potential sites in Denmark. According to the specifications in the plan, the facility to be established may occupy an area of approx. 150 x 150 metres. It is not specified in any more detail where the actual facility can be placed within the large gross areas. There is scope to establish one of three types of repository. These overall guidelines in the plan may involve activities and measures to close off land which are comparable whatever the choice of location. This section presents the general issues concerning radiation protection, including radiation doses from transporting the radioactive waste from Risø to a future repository. It then assesses the potential impact specific to each of the sites for each of the environmental factors identified in the scoping phase Radiation protection The high-level nature of the plan does not permit a specific assessment of safety and security (see fact box below), as this requires greater knowledge of the project itself. There is therefore no basis for evaluating specific safety-related matters in relation to the individual locations. If a decision is taken to proceed with two concrete projects, a series of studies will be developed to examine conditions relating to both safety and security. These analyses and subsequent official approvals are crucial prerequisites for the facility to be built:

28 22 of 234 Safety - Measures to protect the public and the environment against radiation risks from a permanent repository during operation and after closure, i.e. control of radiation sources. Safety analyses - Charting of potential hazards, i.e. factual investigations of specific problem areas. Safety assessments - Evaluation of all aspects of the facility relevant toprotection (exposure to radiation) and safety (radiation sources). This includes assessments of the location, design and operation (i.e. also safety analyses, such as how quickly various radioactive substances spread into the surrounding environment). Unlike the analysis, the safety assessment also includes an evaluation as to whether safety is acceptable, both in specific areas and overall. Security - Measures to prevent unauthorised access to radioactive materials (including prevention of damage, loss, theft or transfer of material). Radiation dose The biological effect of radiation (the dose) is expressed in sieverts (Sv). The doses people are exposed to are normally very low and are expressed in millisieverts (msv). A person living in Denmark receives an average annual dose of 3 msv from the natural background radiation (including radon). Risk of cancer If a group of 100,000 people are each exposed to a dose of 1 msv, five of them may be expected to develop some form of terminal cancer later in life. In this context, 30,000 of these people will die of cancer from other causes. Statistically, therefore, an extra dose of 1 msv per person will increase the number of deaths from cancer in the group from 30,000 to 30,005. Dose limit for the general public Nobody in Denmark should receive a dose greater than 1 msv per year. This does not include the contribution from background radiation. The dose limit does not apply to patients or persons working with radiation. Dose constraint for permanent repository Defines a contributed dose that should not be exceeded as a result of operations and emissions from a repository. The dose constraint is used to plan and approve a repository. The dose constraint is set by the National Institute of Radiation Protection and is much lower than the dose limit. The authorities set quantitative requirements for radiation protection for people in the form of principles and thresholds for radiation exposure of employees and members of the public in the different periods that a permanent repository will pass through. The requirements should be set by the National Institute of Radiation Protection, which is part of the Danish Health and Medicines Authority (and is the nuclear supervisory authority, together with the Danish Emergency Management Agency), based on the legislation on the establishment, operation and closure of a Danish repository in effect at any given time/15/. This section briefly describes the radiation risks that may arise in the different phases of construction and operation of a future project.

29 23 of 234 The construction phase There will be no radioactive waste on the site during the construction phase, and hence no risk of people being exposed to radiation. The specified principles and limits for the subsequent phases will however have a major bearing on the location, project design and associated approvals from the supervisory authorities /15/. The operational phase In the operational phase where the radioactive waste is received in the repository, individuals within the population may be exposed to radiation from emissions of radioactive substances into the atmosphere or into watercourses, lakes and the marine environment around the repository. The dose constraint for a repository in operation defines the limits for the dose contributed by these emissions. The dose constraint provides a basis for defining quantitative limits for annual emissions of radioactive substances into the air and water from a repository, to ensure that the calculated radiation dose does not exceed the dose constraint. The dose constraint for a Danish permanent repository in operation has been set by the National Institute of Radiation Protection at 0.1 msv per year, equal to the dose constraint for the activities of Danish Decommissioning in dismantling the nuclear facilities at Risø /15/. Period after closure A permanent repository for radioactive waste should be located, built, operated and closed in such a way: that the potential exposure to radiation in the period after closure takes account of social and economic factors. that rules of conduct are adopted to ensure that radiation doses or long-term risks to members of the population do not exceed the criteria applied to the construction and approval of the repository. In the period after closure, radioactive substances may spread into the surroundings as a result of the expected development of the repository s man-made and natural barriers, or from isolated less probable events. The annual dose constraint for emissions from a Danish permanent repository based on expected developments after closure is set at 0.01 msv, equivalent to the threshold below which materials from the current decommissioning work at Risø are no longer regarded as radioactive. For potential emissions of radioactive substances resulting from isolated events such as damage to one or more of the repository s barriers (e.g. malfunction, earthquake), the dose constraint is set at 1 msv per year, equal to the annual dose limit for people living in Denmark /15/. Dose constraints Table 4-1 shows a summary of the dose constraints that are expected to be defined for use in assessing and approving a Danish repository. Table 4-1 Summary of proposed dose constraints for a Danish repository. Period Scenario Dose constraint, msv/year Operational period Normal operation 0.1 Expected development 0.01 After closure Potential events Securing the facility Accidental intrusion may arise in connection with the study and exploitation of geological resources involving drilling or excavation. The likelihood of unwanted intrusion is considered to be small, but it depends on the type of repository that is established and whether people are aware of its existence. For repositories whose existence is not known, there will generally be a greater likelihood of accidental intrusion into a near-surface repository than one placed deeper underground. The likelihood will also depend on the barrier structures /15/.

30 24 of 234 The research report contains proposals for the design of the facility aimed at increasing awareness by making it more visible in the longer term by way of visible marking of the site. A view needs to be taken as to whether we want the repository to be noticeable visually and, if so, how it should blend into the landscape. Increased visibility may reduce the risk of intrusion in connection with exploration etc. Apart from the unplanned intrusion from studies, there may also be a risk of intrusion in the form of burglary and vandalism. This risk will be included in the requirements for securing the facility. Although the likelihood of unintentional intrusion is seen as very small, it is felt that there is such uncertainty in this area that it cannot be simply ruled out as a possible scenario Transport Facility construction The effect on traffic of establishing the facility will depend on the design of the final project and the location chosen. The choice of a final location within the planned sites will take account of the existing infrastructure, to ensure that the roads are sized to handle the heavy traffic. The choice of repository type may have a bearing on transport in the construction phase, as there will probably be a need to remove more material for an intermediate-depth repository compared to a near-surface design where material does not need to be dug out to the same depth. This will be included in the detailed planning and design of the project. An assessment of the disruption to traffic in the construction phase, including the number of shipments, traffic routes, safety, noise and emissions, will be included in a detailed EIA study of two selected locations, provided that it is decided to go ahead with the assessment of a solution for a permanent repository. Transport of waste from Risø The National Institute of Radiation Protection (SIS part of the Danish Health and Medicines Authority) has carried out a feasibility study using model calculations to determine potential radiation doses from the transport of radioactive waste from the current storage at Risø to a future permanent repository for low and intermediate level waste. The study focuses on modelling road and sea transport. Safety issues, practical considerations and the financial costs of rail and air transport militate against the use of these modes of transport /11/, /12/. All of the radioactive waste can be transported in 250 individual shipments, each with a truck and trailer. If filling continues over a period of one year, this will mean one transport per working day. In the case of transport by sea, it is assumed that the waste can be carried in 10 shiploads. The distance from Risø to any potential permanent repository was not known when the feasibility studies were produced. The estimated distances for transport by road were set at 400 km by motorway and 50 km by normal road. For sea transport, the distance was set at 650 km by sea and 25 km on land. These estimates represent a conservative assessment of the maximum distance. More details of the calculations and the models can be found in the feasibility study /11/. For road transport, the total collective radiation dose from all shipments, assuming there is no accident, will be on the order of 40 person-msv. The drivers will receive roughly half of this, while people along the route will receive the other half. The total collective dose from the 10 shipments by sea, including handling and subsequent transport by road from the port to the repository, is on the order of 20 person-msv. The crew

31 25 of 234 and drivers will receive around three-quarters of this, while people along the route will receive the other quarter /11/, /12/. With both road and sea transport, the people affected along the route make up a significant group. That means that, for each individual shipment, the radiation dose picked up by any individual will be small: around msv. Although the modelling is conservative, the calculated radiation doses show that both forms of transport can be used with a good margin below the Danish dose limits, which are 20 msv per year for workers and 1 msv per year for individual members of the public /12/. The calculated radiation doses from accident-free transport of the Danish radioactive waste from Risø to a future permanent repository do not place any restrictions on the location of this repository. Accident situation The highest individual doses calculated for an accident situation are of the order of 1 msv for road transport and 10 msv for sea transport, assuming that the persons concerned remain within 30 metres of the site of the accident for 24 hours. These radiation doses are 1 to 10 times the average dose a person receives each year from the background radiation in Denmark (excluding radon). The risks associated with the modelled accident scenarios are therefore deemed to be minor and hence acceptable /12/. Routine transport of radioactive waste The annual volume of waste from hospitals, industry etc. is expected to make up approximately 8 m 3. There have been no studies of the radiation risks from this transport. Based on the results from the feasibility study and the number of other shipments of radioactive material in Denmark each year (approx. 50,000), the routine transport of radioactive waste from hospitals, industry etc. to a future repository is judged to carry a very small risk with very limited potential for increasing the doses to a critical group. 4.3 Public meetings Six public meetings have been held, both to provide information on the process and to gather information on local conditions and potential environmental impacts. This information has formed part of the basis for defining the content of the Strategic Environmental Assessment. This section summarises the major concerns raised by stakeholders. It discusses whether these concerns can be addressed in the SEA report itself, and whether mitigation measures can be taken, or whether the matter should be dealt with in the subsequent phases, either in connection with the EIA and safety analyses or via general information to the stakeholders Stakeholder analysis The plan to establish a permanent repository has given rise to a whole series of misgivings and concerns among citizens, municipalities and other stakeholders, including local businesses around the potential sites for the repository. A review of minutes from the introductory public meetings held in connection with defining the contents of the Strategic Environmental Assessment, along with comments received and materials sent out for consultation on the actual scoping report, shows that there is still a need to inform people generally and that there are a number of actions that can usefully be taken to provide for an effective and open process in the future. There are also specific local conditions and needs that should be incorporated when the future process is planned and executed. The concerns and uncertainties of the stakeholders relate not only to the concrete issues surrounding the establishment and operation of a repository for radioactive waste. They also relate to the long-term social impact such a repository could have on the local community it is

32 26 of 234 placed in; e.g. whether tourism in the area will be affected, along with its attraction to potential residents, the effect on business in the area etc. Then there are concerns about the future decision-making process and the opportunities to influence and be consulted in the course of the process. These concerns can therefore be said to arise out of the plan to establish a repository but then to take off in different directions, depending on the stakeholders views of the future of the local area and the community in general and their expectations of the future process. An analysis of the comments from stakeholders shows that there are three related types of concern, cf. Figure 4-2. Establishment and operation of a repository Social consequences of a permanent repository solution The forthcoming process Figure 4-2 An analysis of the comments from stakeholders shows that there are three related types of concern. These concerns range from relatively specific issues arising out of the practical aspects of the direct effects that may come from the establishment and operation of a repository to more indirect consequences for the local communities. An analysis of the stakeholders concerns about the potential impact on the population has been carried out. The next section discusses the concerns raised by the stakeholders. Subsequent phases will focus especially on the concerns of stakeholders and on answering the questions raised, when there is more knowledge both of the selected sites and of the project itself.

33 27 of 234 Establishment and operation of a repository The plan for a permanent repository gives rise to a number of general uncertainties and concerns among stakeholders; this is true of all the areas identified as possible sites for a repository in the feasibility studies and local area studies. Nature and handling of the waste A lot of these relate to the general nature and properties of the waste, indicating a need for basic information. The stakeholders express the following concerns related to the nature and handling of the waste: They are worried about the precise amount of waste, the types and amounts of radioactivity from the waste and what these mean for safety. There is uncertainty about how the waste is categorised in terms of risk and degree of danger. People have asked why it has been decided to use the IAEA classification and threshold system when Sweden, for example, uses different standards. People ask how the waste will be divided up, whether different types of waste and radiation levels will be mixed together, and whether there is any high-level radioactive waste and how this will be handled. Concerns are expressed about the way the waste affects the containers and buildings used in connection with a repository and whether they become radioactive. How does the radioactivity develop over time? Will the repository give off gaseous emissions from radioactive waste coming into contact with water or decaying and, if so, when do such emissions pose a danger to people? The stakeholders express a need for detailed and exhaustive information and guidance on these matters. The Strategic Environmental Assessment is based on the available knowledge both of the sites and of the potential impact of establishing a permanent repository. The SEA report therefore takes more of an introductory, high-level approach, because it is based on the guidelines and level of detail in the plan. In a later process, if it is decided to proceed with the solution of a permanent repository, detailed studies will be made of two of the selected locations as part of an EIA (Environmental Impact Assessment) and safety analyses, where the specific questions will be answered in more depth than is possible at the present stage of planning. The general details of the type of waste are described in section 2.3 of the plan. Waste volume and repository size. A permanent repository as a viable solution At a more general level, the stakeholders express doubts about the repository as a whole.

34 28 of 234 The stakeholders express the following concerns related to the repository as a viable solution: There are concerns about the applicability of models when estimating the probability of e.g. earthquakes etc. There is a lack of clarity about experience from repositories elsewhere in the world. People express misgivings about the use of models and calculations in connection with the decisions that have to be taken. The stakeholders express concern as to whether it is possible to predict the future development of geological conditions over such a long period in which the repository has to contain the waste. There are concerns that a repository will hand a contamination problem down to future generations. How can we ensure that the repository can withstand unforeseen events such as earthquakes, plane crashes, pressure waves from explosions, accidental intrusion etc.? Taken together, these comments from stakeholders point to a need for the stakeholders to be presented with convincing arguments and documentation to show that a repository is a good and viable long-term solution to handling the waste. The plan, and this SEA report, are part of the overall basis for a policy decision on whether to proceed with a repository as a solution to handling the radioactive waste. In parallel with this process, work will be done on other solutions in the form of intermediate storage or export abroad. This SEA report is thus restricted to addressing the high-level potential environmental impact of implementing the plan for a repository, and it should be read in conjunction with the other studies being undertaken in this area. Establishment of a permanent repository The stakeholders also express doubts about the practical establishment of a repository. The stakeholders express the following concerns related to the establishment of the repository and the area occupied: They are concerned about the way the establishment will affect the local infrastructure in terms of the construction work and the arrival of the waste. How will the repository be made climate-proof, so it can withstand future changes in the climate in the period in which the waste is harmful to the environment including changes in precipitation levels, rising water levels, flooding etc.? How will the repository fit into its surroundings and the natural landscape around it? How large an area is needed for the repository, and will there be limits to the proximity to settlements and agriculture? What all these points share is that they relate both to the technical design and to the social impact. On the technical design side, action is needed to cover the specific load on the infrastructure from a future repository. The issue is a form of social impact because there is a risk of affecting the sense of security in the neighbouring community. People are also calling for a concrete plan defining how the repository should be constructed in relation to its surroundings, so that it fits into the landscape around it. This also indicates that it matters to the stakeholders in a social sense whether the repository will feel like a natural part of its surroundings or will stand

35 29 of 234 out as an alien presence in the countryside. All of these questions can only be answered when the specific repository type and location have been chosen. Apart from these points, the stakeholders express concerns about seepage from the repository. They are worried about concrete as a barrier, as this will erode over time, and that the containers to be used will also erode and leak material into the surroundings. In connection with this, there are also concerns about the possible impact on soil conditions, groundwater pollution or contamination of the marine environment where the facility is close to the sea, and the resulting impact on people, animals and plants. It must be demonstrated that a future facility can meet official requirements with regard to seepage, which will be defined in a later phase in connection with official approval for the facility. The potential impact of the plan on these aspects, including groundwater and surface water, will be addressed at a general level in this SEA report on the basis of a vulnerability assessment of the sites concerned, and at a more detailed level in the subsequent phases. Closely related to these matters, the stakeholders express concern about the effect of a repository on protected areas/natura 2000 zones and ancient monuments. One aim of the plan guidelines is to ensure that Natura 2000 areas are not affected, and it is assumed that a future facility will not be placed within the protected areas or in conflict with ancient monuments, and that the location will take account of ancient monument protection lines. A number of requirements have therefore been defined for a future facility. Operation of a repository The stakeholders have raised concerns about the operation of a repository. The stakeholders express the following concerns related to operation: Stakeholders raise concerns about the operation of the repository in terms of the filling process, both initially and during the filling-up period. The stakeholders also ask for clarification of the procedure in the event of accidental seepage of radioactive waste into the surroundings. A final assessment of the operational problems can only be made when a specific location and repository concept are known. Risk and safety analyses will be carried out when two sites have been selected. A contingency plan will also be drawn up for a future facility, including an assessment of different risk scenarios and guidelines for concrete action in the event of an accident. This is therefore not addressed in the SEA report. Social consequences of a permanent repository solution Apart from the concerns and needs analysed above, all directly related to the establishment and operation of a repository, the stakeholders express concerns about indirect social consequences of a repository. Concerns about the consequences for the surrounding community are varied and arise out of the general uncertainty about the safety aspects of a permanent repository for radioactive waste. The stakeholders are fundamentally unsure whether a repository will affect the environment in the immediate vicinity. This uncertainty causes widespread insecurity among the stakeholders in terms of the possible effect on their daily life and livelihood.

36 30 of 234 The questions raised by stakeholders are mainly: The stakeholders express the following concerns related to social consequences: There are concerns about the extent to which agriculture or other business will be affected by the establishment of a repository for radioactive waste in the vicinity and whether, for example, it will still be possible to practise organic farming. What will be the impact on tourism? What will be the effect on people moving into and out of the area? There are concerns that property values will fall and have a lock-in effect where people are tied to their houses and summer cottages and businesses are tied to their buildings, and that the project will affect employment opportunities. Concerns are expressed about the effect on the sense of security felt by the local inhabitants will there be added stress? How will a repository affect the use of recreational areas? All of these concerns are based on a fear of negative future scenarios becoming a reality. As described above, an EIA and risk and safety analyses will be produced before any facility can be established. These studies and analyses are intended to ensure that the facility complies with official environmental requirements, including health and wellbeing. Despite the number of restrictive requirements placed on the facility, there may still be a psychological mechanism in play that allows all of the negative effects described above to be generated simply through anxiety about the environmental impact. For example, if anxiety about an environmental impact is so great and so widespread that it becomes hard for farmers in the area to sell their produce, this will have an adverse effect even if there is no actual environmental impact associated with the repository. The same mechanism may apply to the other areas of concern. 4.4 Scoping report As part of the initial phase, a scoping report has been drawn up 1, in order to identify the potentially most significant environmental impacts inherent in the execution of the plan, thereby defining which environmental issues need to be examined in greater detail in the SEA report. The basis for the scoping was a very broad and comprehensive environmental concept, as defined in the Environmental Impact Assessment Act, which includes the following: biodiversity, population and human health, soil, water, air, climate factors, tangible assets, landscape, cultural heritage, including churches and their surrounding areas, as well as sites of architectural and archaeological importance. The base data for these assessments came mainly from the feasibility studies and local area studies produced as part of the initial analyses of the possibility of establishing a permanent repository in Denmark. The studies include analyses of the geological conditions, transport 1 The scoping report can be found at: /Plan%20for%20etablering%20af%20slutdepot%20for%20lav- %20og%20mellemaktivt%20affald/Plan%20for%20etablering%20af%20slutdepot%20for%20lav- %20og%20mellemaktivt%20affald.ashx

37 31 of 234 studies and descriptions of repository types. The feasibility studies have been updated with current information on e.g. conservation interests at both national and local level and details of public meetings addressing local interests, including concerns about agriculture, food production, fishing and tourism. As a result of the scoping, the following topics were selected for discussion in the SEA report: Biodiversity - Plant and animal life - Natura 2000 areas - National parks or local parks - Wildlife corridors/biological interest areas - Nature conservation; cf. Section 3 - Afforestation Population, health and well-being - Restrictions and disruptions affecting the population - Impact on social conditions - Impact on business - Health standards (including radiation protection, safety and security) - Outdoor/recreational stakeholders - Transport (including radiation during transport) - Traffic management/loads Landscape and geology - Landscape-related value - Geology Water - Surface water, including impact on watercourses and wetlands - Groundwater conditions Soil - Soil contamination Tangible assets - Products, materials, raw materials - Chemicals, pollutants Cultural heritage - Cultural and historical values Official hearing The draft scoping report has been the subject of consultation by authorities whose territory could be affected, and citizens groups and other stakeholders /7/. The consultation procedure will provide the opportunity to make proposals as to what additional measures should be addressed and evaluated in the SEA report. The scoping has also been the object of Espoo consultation according to the Espoo Protocol. A total of 36 responses have been received from consultation with the authorities and five from the Espoo consultation process. These have been processed by the Ministry of Health and can be viewed at Consultation on the scoping report has contributed input to the description of the existing conditions and focal areas for assessing the environmental impact. The consultation process has also caused the issue of climate to be added to the list of topics to be discussed in the SEA report.

38 32 of Alternatives The Environmental Impact Assessment Act requires the authority to identify, describe and evaluate reasonable alternatives. In this context, the six potential sites are treated as equal alternatives. The Strategic Environmental Assessment is broken down into a number of general issues that will arise whatever the choice of location and a description of each of the six sites. Along with possible alternatives, the zero alternative also has to be described and assessed. This is the situation in which the plan is not implemented and no other action is taken. The zero alternative thereby serves as a basis for comparison in the environmental assessment, which the potential impact or each alternative location is weighed against. The zero alternative is thus a tool used in a SEA report, and does not suggest that continued storage at Risø will be chosen as a solution if the plan for a repository is not implemented. In some situations, the zero alternative may actually prove to entail a greater environmental impact than if the plan is carried out. In this case, the zero alternative consists of a solution in which the existing and future waste from the healthcare sector and industry is stored at Risø in Roskilde. The zero alternative does not mean retaining the status quo, but constitutes a projection of the development which may be anticipated with continued storage at Risø. The zero alternative is described in chapter 7. In parallel with the process of planning a permanent repository, work is being done on two other solutions: intermediate storage and exporting all the waste, as described in section 2. This SEA report discusses only the potential environmental impact of implementing the plan for a permanent repository, so does not include the potential environmental impact of intermediate storage or export to a repository abroad, as the plan only contains guidelines for a repository solution in Denmark.

39 33 of METHOD DESCRIPTION This section describes the method of analysing the environmental status and assessing the impact. It ends with a note on the structure of the remainder of the report. The Strategic Environmental Assessment should cover fundamentally the same level of detail as the plan for a permanent repository. The plan sets out a number of high-level conditions for establishing a permanent repository within a few relatively large areas, referred to below as the planned sites. In a later EIA phase it will be possible to examine in more detail the environmental impact of an actual project in a specific location. 5.1 Environmental status The analysis of the environmental status is limited to the environmental issues selected in the scoping. The description is based on existing material in the form of feasibility studies, local area studies and details of conservation interests and land use. It looks at overarching environmental objectives in the form of goals and planning and legislative restrictions at the EU, national, regional or municipal levels with a bearing on the matters in question and with an overarching character in terms of the plan. These include EU directives and regulations, legislation, executive orders and government planning in the environmental area, along with regional and municipal identification of various conservation interests. Local plans are not looked at in this stage of planning, as the plan for a permanent repository is not sufficiently detailed when it comes to the actual location of the repository within each site or which repository concept has been chosen. It also includes details of local issues from the public meetings that have been held. 5.2 Assessment of impact Potential impact The assessment of the potential impact is based on the analysis of the overall conservation interests and environmental goals for the environmental aspects selected for the scoping; cf. section 4.4. In this context, an environmental impact is defined as a potential conflict between the location of the proposed facility and the environmental issues identified in the scoping phase. This may take the form of conflicts with existing or planned land-use within the planned site, conservation interests or environmental goals. Apart from assessing whether there is a potential conflict, it also evaluates the uncertainty in the basis for this assessment. In relation to assessing the impact on groundwater, for example, there may be varying degrees of uncertainty among the sites, because there are as yet no in-depth studies of the geological conditions. Apart from identifying direct conflicts, the aim of the environmental impact analysis is therefore to focus on environmental issues that demand particular attention in the subsequent phases, when greater knowledge will be gathered about both the project itself and the site in question Extent of the impact As part of the assessment of the overall scope and significance of the impact, it will be examined whether the impact can be reduced or averted simply by the choice of final location within the planned site, or whether the impact is independent of the positioning. An example of an impact that may be averted or reduced simply by the choice of location is conflict with the designated coastal zone. In some areas it will be possible to locate the repository outside the designated coastal zone and so avoid conflict with conservation interests. In a later phase, once there is a concrete project, the conservation interests will be weighed against other

40 34 of 234 factors that have a bearing on the repository including the geology in order to choose the final location for the repository. An example of an impact that probably cannot be avoided simply through the exact placing is the effect on drinking water interests. This is because any potential contamination of groundwater could spread, and is therefore partly independent on the positioning of the repository itself. Effects that cannot be reduced by the final choice of location within the planned site are considered to have a greater impact than those that can be reduced or averted. This is on the assumption that these issues are taken into account in the subsequent detailed planning and project design. A number of environmental concerns have already been incorporated into the plan guidelines, so they are not affected by the plan e.g. Natura 2000 areas, protected areas and low-lying areas. The impact assessment also considers whether the effect is direct, indirect or cumulative. Direct effects are typically things like the area occupied and the risk of radiation, while indirect effects may be the impact on health and socio-economic conditions. Cumulative effects reflect whether the plan could have an increased environmental impact in combination with other plans or programmes at the national, regional or municipal level. They also consider whether the impact is short- or long-term and whether there are both positive and negative effects. For each environmental factor, a template corresponding to Table 5-1 is used. Table 5-1 Examples of summary impact assessments. Environmental aspects Climate Environmental aspect Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments (Yes or no) (Yes or no) (Description of the nature of the impact) Assessment of degree of impact (Degree of impact) The template is used as a list of potential impacts for all environmental factors at each site. The assessment of the degree of impact uses the following scale: Table 5-2 Degree of impact. Degree of impact None: Minor: Moderate: Significant: There will be no impact on this environmental aspect. A minor impact will: in relation to the radiation dose, fall below the specified dose constraints not cause changes to connected structures in the area mainly affect things within the planned site or nearby transport routes A moderate impact may: cause changes to structures in the area have long-term effects that conflict with municipal concerns or interests mainly affect things within the planned site or nearby transport routes A significant impact may: in relation to the radiation dose, be above the specified dose constraints have long-term or permanent effects that conflict with international obligations and essential national interests significantly affect connected structures or general social conditions have a bearing outside the planned site itself

41 35 of 234 For a number of environmental aspects, the degree of impact will vary between e.g. none to minor and moderate to significant, depending on the location of the repository. Where relevant, the impact assessment will look at the difference between the different repository types. For example, the assessment will differentiate between a near-surface repository at ground level and one going down to 30 metres below ground, which may be with or without bore holes, or an intermediate-depth repository Socio-economic factors In preparation for the SEA report, an initial literature search was carried out for sources covering social effects of permanent repositories for radioactive waste, as determining this type of impact is considered to be an essential part of the report. The literature search took in sources in English and research literature in the area. The search involved two main search strategies. Above all, it focused on the agencies dealing with radioactive waste in the leading European countries and the USA the Netherlands (COVRA.nl), France (ANDRA.fr), Spain (ENRESA.es), the UK ( and finally the USA itself ( It then took in a wider search, mainly through Google Scholar, to pick up research literature that is not necessarily linked to the national agencies that handle radioactive waste. This search strategy used a number of keywords, including nuclear repository, landfill, social impact, nuclear social impact assessment, social impact assessment, and social impact issues. The search showed that the number of sources is extremely limited, and the few sources come up again and again in the different searches, indicating that the search is relatively exhaustive. It is a feature of the sources that their transferability to the current situation in Denmark is limited. The most relevant sources found are all theoretical in nature or take the form of prior analyses of projected impacts. Nothing has been found that covers the actual impact after the construction of a permanent repository. Other factors that make it difficult to use these sources are that they are up to 25 years old, deal with projects on a very large scale or projects to store mainly high-level waste, or work carried out under quite different geographical and cultural conditions. Based on two particular sources studied, however, it is possible to say that the establishment of permanent repositories for radioactive waste seems likely to be very controversial among the stakeholders whatever the time and place 2 which underlines the importance of targeted efforts to involve stakeholders in the processes of planning, establishing and operating a repository. The assessment of the impact on socio-economic conditions is therefore mainly based on the concerns found among stakeholders in the areas and experience from projects which were also controversial in nature. 5.3 Structure of the report The SEA report discusses all six possible sites, plus Risø as the zero alternative. It starts by describing other high-level plans and legislation that apply to all the sites. This is followed by an analysis of the environmental status and goals and an assessment of the potential impact or conflicts for each of the sites. These assessments are limited to the environmental issues selected in the scoping report. The report is structured in such a way that all the environmental issues are described for one site at a time, to arrive at the total impact for each site. Some general descriptions and assessments will therefore recur, because several of the assessments will be similar. 2 See e.g. Lennart Sjöberg and Britt-Marie Drottz-Sjöberg (2001) Fairness, risk and risk tolerance in the siting of a nuclear waste repository, Journal of Risk Research, 4:1, , DOI: / or State of Nevada Agency for Nuclear Projects/Nuclear Waste Project Office (1989) Executive Summary Yucca Mountain Socio-economic Project An Interim Report on the State of Nevada Socio-economic Studies.

42 36 of 234 The method description on this chapter (sections 5.1 and 5.2) and the description of other plans given in chapter 6 form the background for all six sites. The same applies to the general background to the work on a plan to establish a final repository, as can be seen in chapter 2.

43 37 of RELATIONSHIP TO OTHER PLANS AND LEGISLATION This section presents high-level plans and executive orders that are relevant to the present plan. The municipal plans for the different municipalities are presented under planning issues for each site. 6.1 The Executive Order on Habitats: Natura 2000 is a generic name for EC habitat areas, EC bird protection areas and Ramsar sites. Together, these areas make up an ecological network of protected nature areas throughout the EU. The aim is to maintain or restore a favourable conservation status for the species and habitat types these areas have been designated to safeguard. A key element in the protection of Natura 2000 areas is that, in their administration and planning, the authorities may not adopt plans, programmes etc. that damage the species or habitat types the areas are designated to safeguard. EC habitat areas and EC bird protection areas are covered by the EU Habitats Directive, which is implemented in Danish law by e.g. the Habitats Order /25/. The purpose of the Habitats Directive is to protect species and habitats that are characteristic, endangered, vulnerable or rare within the EU. Among other things, the Habitats Directive identifies areas that may help to maintain and safeguard habitats. The purpose of the Bird Protection Directive is to improve the conditions for wild bird species in Europe. This involves the Member States undertaking to designate bird protection areas with a view to conserving the habitats for species of birds that are rare, endangered or sensitive to changes in habitats within the EU. These may be areas where certain birds breed, or areas that the birds visit regularly to moult, rest during migration or overwinter. As well as designating habitat areas, the Danish Habitats Order extends to more general protection of a number of species listed in Annex IV to the Habitats Directive, which also applies beyond the boundaries of the Natura 2000 area. The wording of the Order is generally very restrictive and means that no permits may be granted or plans approved etc. that could damage or destroy breeding or resting sites for some species of birds /24/. Ramsar areas are wetlands of international importance that have to be protected if: at least 20,000 aquatic birds regularly stay in the area; one percent of the population of a species or sub-species of aquatic birds regularly stay in the area. The wetland areas include coastal meadows, marshes, lakes, fjords and shallow harbour areas with a depth of less than 6 metres. The specific designated areas that border on or are close to the planned sites are presented in the discussion of each site, under Biodiversity (sections 7.4, 8.2, 9.2, 10.2, 11.2, 12.2 and 13.2) Nature conservation plans As described above, the Natura 2000 areas have a special character that makes them habitat and bird protection areas, but they also represent the largest and most vulnerable nature areas in Denmark. The Natura 2000 areas are covered by national conservation plans which are intended to safeguard, improve or extend the natural environment and the habitats contained in the area. The Natura 2000 plans may therefore intervene with targeted action in specific areas.

44 38 of 234 The Natura 2000 plans consist of a specific plan for each Natura 2000 area. Each specific plan is derived from a baseline analysis, and the plan sets a long-term goal for nature in the area along with a programme of actions. 6.2 Water management plans Under the EU Water Framework Directive, which is implemented via the Danish Environmental Targets Act, Denmark is required to produce water management plans to achieve a good status in the Danish water areas. Each water management plan sets targets for the environmental status of the lakes, watercourses, coastal waters and groundwater in the area. The first water management plans run to the end of 2015 and have been drawn up in four phases: an ideas phase, a baseline phase, consultations and action plans. The proposed water management plans were the subject of six months public consultation from June to December Amendments to the proposed water management plans underwent a further eight weeks public consultation from 30 June to 26 August 2014 /23/. The specific targets for the environmental status of water areas within the planned sites are presented in the discussion of each site, under Water (sections 7.8, 8.6, 9.6, 10.6, 11.6, 12.6 and 13.6). 6.3 Planning Act The overall national goals and guidelines for municipal planning are set out in the Planning Act (Consolidated Act No 587 of 27/05/2013). The purpose of the Planning Act is to ensure that the overall planning brings together the social interests concerned in the land-use, and help to preserve the country s nature and environment, so that social development can proceed on a sustainable basis with respect for human living conditions and the conservation of fauna and flora. In particular, the Act is meant to ensure: that there is appropriate development in the whole country and in the individual regions and municipalities, that high-quality buildings, urban environments and landscapes are created and maintained, that the open coastlines continue to represent a key natural and landscape resource, that pollution of the air, water and soil, and any noise nuisance, is prevented, and that the public can be involved in the planning work as far as possible. The plan to establish a permanent repository may conflict with the Planning Act with regard to the designated coastal zone and designated areas of natural value in the municipal plans, which are presented under Landscape and geology (sections 7.6, 8.4, 9.4, 10.4, 11.4, 12.4 and 13.4). 6.4 National Planning Report The National Planning Report is the Government s policy statement on future spatial and functional development in the country, both in the big cities and in rural areas. It points to the need to use the limited space more efficiently, so there is room for nature and unspoilt landscapes /22/. In this connection, the visions for development in the rural districts are especially relevant, and this section presents selected focal areas from the National Planning Report: General political messages: Those who choose to settle and live in the country themselves emphasise values such as local community, identity and closeness to nature. These are values that we need to preserve

45 39 of 234 It is important to use local qualities to develop local industry, employment and housing, including local cultural tourism and increased investment in green tourism... It is government policy that there should be space in the countryside both for conservation to safeguard the unique assets in the landscape, nature, cultural environment and water, and for use to support housing, outdoor life and agricultural development. The countryside is also essential to the production of agricultural goods, the extraction of raw materials, forestry, the production of green energy, and tourism. Growth, green transformation and development throughout the country There is a tendency for the population to be increasingly concentrated in the big cities and for the population of rural districts (settlements of less than 1,000 inhabitants) to decline. An extrapolation of this trend out to 2030 is shown in Figure 6-1. On Bornholm and Lolland the population is expected to decrease by almost 5 % (Østermarie- Paradisbakkerne and Rødby). On Fyn and in Central Jutland, population growth of up to 5 % is projected (Kertinge Mark, Thyholm, Skive Vest and Thise) /22/. Figure 6-1 Changes in population broken down by National Plan areas. Source: Statistics Denmark and calculations from the Danish Nature Agency both presented in the National Planning Report for 2013 /22/. Developing rural districts Rural districts in the outlying areas of Denmark may face problems in e.g. maintaining local services, using redundant agricultural buildings or preserving access to nature conservation areas. The key is to use local qualities to develop local industry, employment and housing, including local tourism and increased investment in green tourism /22/. The countryside Sites in rural areas should generally kept free of buildings other than those needed for agriculture, forestry and fishing. The coastal areas have the potential to support outdoor activities and tourism, and the open stretches of coastline in particular form a topographical whole. It is therefore a matter of national interest to preserve the open stretches of coastline and maintain access for residents and tourists.

46 40 of Relationship between the National Planning Report and the plan to establish a permanent repository The plan to establish a permanent repository covers six potential sites, all in rural districts in the open countryside and many located close to the coast. This means that it must also take account of a number of aspects of the National Planning Report. There is a particular focus on safeguarding and developing the assets that are specific to the rural areas and which are major elements in maintaining smaller communities. It must therefore take account of natural and cultural values, landscape, outdoor life, tourism and agriculture. A conflict between the high-level goals in the National Planning Report and the present plan may be reflected in a reduction in the qualities of the site itself, including its natural, cultural or topographical character. This direct impact may bring indirect effects such as a drop in tourism, reduced revenues from agriculture and food production, or more people leaving the area. There could also be a conflict between the goals and visions described in the National Planning Report for the rural districts and the implementation of the plan for a permanent repository. The environmental impact assessment describes the general planning conflicts for each site in relation to the population, natural and cultural values, landscape and tangible assets. In the later phases of planning and project design for a possible future repository, it will be necessary to undertake more in-depth studies of local conditions in order to assess and mitigate potential impacts in more detail in connection with an EIA study.

47 41 of ZERO ALTERNATIVE The zero alternative is defined as a situation where the existing and future radioactive waste remains stored at Risø in the buildings and facilities where it is today. The zero alternative therefore does not cover the establishment of a permanent repository, but provides a basis for comparison in the environmental impact assessment, as described in section Decommissioning of Risø In September 2000, the board of the Risø National Laboratory (now DTU Risø Campus ) decided that the largest reactor, DR 3, would not be restarted after a shutdown due to a suspected leak in the reactor tank. In subsequent discussions on the forthcoming decommissioning, it was deemed appropriate to separate the decommissioning task from the forward-looking research activities of the Risø Research Centre, as the research results were no longer felt to match the expense of continued operation. Danish Decommissioning was established by Act No 58 of 22 November 2000 for the purpose of decommissioning the reactors and other nuclear research facilities at Risø. Danish Decommissioning (DD) is an independent agency under the Danish Ministry of Education and Research (then the Danish Ministry of Science, Technology and Development) /10/. DD s main objective is to decommission the nuclear facilities at Risø within a time frame of years (from 2003). DD is also tasked with: maintaining the facilities until they are decommissioned, in order to maintain their safety; continued receipt, handling and storage of radioactive waste from Danish users of radioactive materials until another solution has been found; participation in the process concerning a long-term solution for the low and intermediate level radioactive waste. 7.2 Definition of the zero alternative According to the Folketing resolution of 13 March 2003, decommissioning must be completed no later than 2023, after which the monitoring and operations for which Danish Decommissioning is responsible today will be continued if necessary until a long-term solution for handling Danish radioactive waste has been found. In the zero alternative, it is assumed that the official requirements on radiation protection and safety, including dose constraints, will remain unchanged after 2023.

48 42 of 234 Figure 7-1 Outline map Risø. 7.3 Planning conditions This section presents the overall planning framework and strategies for the site in the form of Roskilde municipality s Municipal Plan and planning strategy Finger Plan 2013 The national planning directive for the development of Greater Copenhagen the Finger Plan 2013 is drawn up according to the rules in Sections 3(1) and 5j(4) of the Planning Act. The purpose of the national planning directive is to future-proof the Finger Plan by providing a common forward-looking basis for the 34 municipalities in Copenhagen to plan from. The Finger Plan 2013 builds on and updates the Finger Plan The Finger Plan 2013 replaces the provisions of the Finger Plan 2007 /30/. Risø is situated in the outer area of Greater Copenhagen (the fingers ). The Finger Plan contains the following guidelines for the area: DTU Risø Campus (where the present stores are located) and the Research Park (to the east of Frederiksborgvej): Section 14. The Research Park at DTU Risø Campus (Roskilde Municipality) is reserved for production, research and development and the associated administration in the clean-tech field, with connections to DTU Risø Campus. Together, DTU Risø Campus and the Research Park may erect buildings with a total floor area of 230,000 square metres, including large office buildings of more than 1,500 square metres up to a maximum of 75,000 square metres for the specified purposes /30/ Roskilde Municipal Plan 2013 Roskilde City Council wants the town to remain a good place to live. It should therefore be able to offer efficient, lively and sustainable urban areas that can provide good conditions for daily life.

49 43 of 234 Roskilde s unique brand as a municipality with a strong cultural profile and educational - institutions at all levels should be exploited and enhanced. These goals are reflected in the municipality s three development strategies: Artistic Roskilde Education, research and knowledge Health and exercise The development strategies are the means by which Roskilde City Council intends to collaborate with the city s businesses, institutions, associations and citizens to exploit and develop Roskilde s unique position of strength to create growth and development in the area. The Municipal Plan contains the overall guidelines for towns and countryside. Roskilde City Council adopted the final Municipal Plan for 2013 at its meeting on 18 December A municipal plan is the City Council s proposal for how a municipality should develop in a number of areas over the next 12 years. It is often aligned with the spatial planning. The plan should therefore be seen as a long-term holistic strategy setting the priorities for urban development and the use and protection of the countryside /28/. Urban development strategy for the Risø and Ågerup area The existing research environment at Risø and its proximity to University of Roskilde (RUC) should be used as the starting point for developing a business and research park for clean-tech companies to support the municipality s development strategy for education and research. The area around Risø has great potential for development by virtue of the existing research environment and its proximity to RUC. An area of approx. 53 ha to the east of Frederiksborgvej has therefore been earmarked for a business and research park mainly for clean-tech industry, which needs to be close to research institutions /28/. 7.4 Biodiversity This section focuses on biodiversity, which in this context includes a description and assessment of the impact on Natura 2000, Section 3 of the Danish Nature Protection Act, wildlife corridors and national parks or nature reserves. These topics are illustrated on map 0.1: Biodiversity Environmental status and objectives Natura 2000 Risø borders on the Natura 2000 area of Roskilde Fjord: Roskilde Fjord, Habitat area no H120 and bird protection area no F105. The Natura 2000 area covers 14,810 ha and extends as shown in Annex 1. The fjord, with its many branches, was formed after the last Ice Age, when the sea broke in over the hilly moraine landscape and flooded the lowest parts. The landward part of the Natura 2000 area houses a number of habitat types which are of regional or national importance because of their size or rich flora. This is especially true of the large continuous coastal meadows along the fjord, calcium-rich lakes and pools, dry grassland and scrub /31/. Section 3 protected nature Under Section 3 of the Nature Protection Act, it is prohibited to interfere with protected natural habitats in a way that could cause a change to the state of these areas. However, the municipalities may derogate from this provision /11/, often on condition of establishing some natural replacement.

50 44 of 234 Natural habitats covered by Section 3 of the Nature Protection Act are: Lakes and ponds of at least 100 m 2. Marshes, meadows, heaths, dry grassland, coastal meadows and marshes which individually or together cover an area of at least 2,500 m 2. Marshes under 2,500 m 2 are also protected if they are next to protected streams or lakes. Most streams and rivers are also protected via a special Section 3 designation. Lakes include both natural and wholly or partly man-made pools, basins and dams. Along the coast around Risø there are Section 3 protected coastal meadows, dry grassland and a single protected lake. Low-lying areas Most of Risø is a designated low-lying area in the Roskilde Municipal Plan. The Municipal Plan identifies low-lying areas that can be reinstated as wetlands and other low-lying areas. The guidelines to the Municipal Plan are intended to ensure that planning permission for buildings, facilities and changes of use is always subject to a specific assessment of the possibility of reinstating the wetlands. Beach protection Part of the Risø peninsula is covered by the beach protection belt. Roskilde-Lejre national park The three municipalities of Roskilde, Lejre and Frederikssund have submitted a proposal for a new national park in Skjoldungelandet. The proposal has been under discussion in the Ministry of the Environment and has been cleared for public consultation in the autumn of Skjoldungelandet extends from just north of Eskilsø in Roskilde Fjord to the wooded high ground near Hvalsø; three types of measure are proposed: Improving and increasing the visibility of natural and historical attractions, e.g. reestablishing woodland lakes, improving dry grassland and rivers, making original elevations visible etc. Facilities, e.g. more paths, look-out towers, meeting rooms, car parks and disabled access. Communication and networking, e.g. website, books about the area, new visitor folders etc. /32/ Assessment of environmental impact Given that the facility is already established, the zero alternative will not have any further impact in terms of land used, transport in the construction phase etc. The effect of the facility on nature therefore includes the risk of seepage into nearby nature areas. The facility is now being monitored to ensure that any emissions into the surroundings do not exceed the specified thresholds. Risø is situated near the coast and is also a designated low-lying area. It is therefore possible that there could be a greater risk of seepage in the future, particularly with rising sea levels and extreme events, so there is a greater risk of impact on surface water and natural conditions than there is today. 7.5 Population, health and well-being This section describes the location of the planned site in relation to built-up areas, the number of inhabitants, commercial activity, tourism and recreation. It is mainly based on information from Statistics Denmark and the Municipal Plan. This section describes the potential impact on the population, based on available information from e.g. descriptions of transport and radiation in the feasibility studies.

51 45 of Environmental status and objectives Population Risø is located to the north of Roskilde in an area designated for public purposes. Apart from Risø DTU, which is situated on the peninsula, the site houses several departments of DTU Risø, particularly in the coastal area, and DCE Danish Centre for Environment and Energy at Århus University, which is both by the coast and further inland. Most of the area to the east is taken up by farms. Table 7-1 Distance from major built-up areas. Distance from settlements: Risø Huse: approx. 1.3 km Veddelev: approx. 1.6 km Store Valby: approx. 3 km Roskilde: approx. 3 km (Himmelev northern part of Roskilde) Industry Roskilde s Municipal Plan describes its location between Greater Copenhagen and the rest of Zealand, together with the space available for industry and offices, as Roskilde s particular strength. A lot of the premises for businesses employing a large workforce are within the areas close to DTU Risø Campus and the Research Park at Risø, totalling 75,000 m 2. The area is laid out for businesses in the clean-tech field /28/. Table 7-2 Breakdown of employment in Roskilde municipality within selected industries related to tourism and leisure, agriculture, fishing and food production, as of The total number of people employed in Roskilde Municipality is 40,847 (Statistics Denmark 2013). Tourism Roskilde is a well-known tourist destination, particularly in connection with its festival, cathedral and Viking ships. There are many musical, artistic, cultural and sporting events every year, which may be the occasion for an extended stay in Roskilde. The largest single event is the Roskilde Festival. The aim is for more tourists to stay overnight in the municipality, which calls for a range of different accommodation options as well as different activities and attractions.

52 46 of 234 The municipality intends to do more to strengthen tourism in connection with the countryside and nature. This will be done mainly through projects within the Green Blue Strategy, the Cyclists plan and under the auspices of the Skjoldungelandet national park. Recreational areas The countryside around Risø is dominated by arable land with medium-sized fields and scattered bodies of water. The Finger Plan 2013 proposes a new green wedge to the north of Roskilde and Trekroner to Roskilde Fjord. Part of this area is already in the green belt around Roskilde. The Risø peninsula itself is not in this designated area. A green link has been marked out along Frederiksborgvej. In the long term the intention is to construct a footpath from Trekroner to Risø /30/ Assessment of environmental impact Health The dose constraint for all of Danish Decommissioning s activities is 0.1 msv per year. The dose constraint provides a basis for defining quantitative limits for annual emissions of radioactive substances into the air and water from a repository, to ensure that the calculated dose does not exceed the dose constraint. Thresholds for emissions of radioactive substances from the nuclear facility at Risø are laid down in the Conditions for Operation and Decommissioning (BfDA) for Danish Decommissioning /18/. The current measured values for emissions are well below the specified emission thresholds /15/. Socio-economic factors As described above, emissions of radioactive substances are below the specified thresholds, and on this basis, there is not considered to be any impact on health from the zero alternative. Apart from the general issues mentioned in section 4.3, the stakeholders have drawn attention to a number of local matters that should be given special consideration in the choice of destination and in implementing the plan. In relation to Roskilde, these matters concern the possible choice of the zero alternative where the waste remains at Risø. The stakeholders express concern as to the suitability of Risø for continued storage. For example, they mention the storm-proofing of the area and the risk of flooding. The stakeholders also say that Risø will not be suitable for taking in other waste, and that the existing storage facility needs major structural improvements in the next few years as the buildings are only temporary. According to the stakeholders, more prolonged storage will require the material to be repackaged and buildings to be erected for this purpose. An analysis of comments from stakeholders shows that they have not been presented with a convincing argument or a practical solution that would allow the zero alternative to implemented safely. As described in the introduction to chapter 7, the zero alternative is a tool used in an SEA report as a basis for comparison and as a picture of an imaginary situation in which the plan is not implemented. The zero alternative therefore does not suggest that continued storage at Risø will be chosen as a solution if the plan for a repository is not implemented. Continued storage at Risø requires a number of longer-term actions which are not examined in this Strategic Environmental Assessment.

53 47 of Landscape and geology This section presents geographical and geological conditions within the planned site, which here encompass a high-level description of the landscape and any designated areas and a description of the geological conditions based on the feasibility studies, with any designated features. These topics are illustrated on map 0.2: Landscape and geology Environmental status and objectives Landscape Landscape description The site is located on Roskilde Fjord, approx. 2.5 km north of Roskilde. In the feasibility studies, the site is broken down into the peninsula, the coastal area and the inland area. The eastern part of the peninsula is low-lying from around sea-level and +1 m close to the fjord to about m further into the coastal area. There is also an elevated area in the far west of the peninsula, which reaches approx m, and a smaller area to the east of this, up to +5.5 m. Within the coastal area, the land rises gradually from west to east from sea level to approx m, after which there is steeply rising terrain in places, up to +13 m by Frederiksborgvej. The inland area, which is a continuation of the coastal area, goes up to +19 m in places, but there are several small hollows, some filled with water. Designated coastal zone The whole of Risø is covered by the 3 km wide designated coastal zone. Planning Act: Section 5b. The following shall apply to planning in the designated coastal zone: 1) It is prohibited to transfer land to an urban zone or to conduct planning for development in a rural zone unless there is a specific planning-related or functional justification for location near the coast. Designated areas Over the whole of the land area, special attention has to be given to the landscape where there is a visual connection to the coast, as there is at Risø. Sight lines should be kept free of buildings and facilities and changes of land-use as far as possible. To the north and south of Risø there are designated landscapes of special interest. Geology The uppermost (most recent) geological strata On the Risø peninsula and along the coast, the most recent freshwater deposits from post-glacial times are up to 4 m thick. They are mainly composed of peat, mud and sand. Underneath these are post-glacial marine deposits of mud, clay and sand, which may be 7 m thick. The uppermost layer of ground from the Ice Ages varies greatly in thickness from metres on the Risø peninsula and approx metres in the coastal area to metres on the land around and to the east of Frederiksborgvej. The strata are mainly composed of clayey till and meltwater clay, but layers of meltwater sand and gravel up to 4 metres thick are also present. The layers vary a lot from place to place and they are heterogeneous in both composition and structure.

54 48 of 234 The oldest geological strata The older pre-quaternary strata from the Danian and Selandian periods also vary in thickness and extent, sometimes because of faults cutting through the strata. The most recent Selandian strata range from 2 metres thick on the Risø peninsula to metres in the coastal and inland areas. They consist of fine-grained grey clay and limestone both in thicker layers and often in alternating thin layers too (called greensand-limestone and clay). These deposits are not present over the whole area. The limestone and alternating clay-limestone strata are permeable and form the basis for water supplies, mainly to Greater Copenhagen. The white Danian limestone strata can be found under all the other deposits throughout the area. Geological conservation Risø itself and the coastal stretches to the north and south are designated as geological conservation areas. Exceptions to this are the areas that have been built on. The guidelines to the Municipal Plan are intended to ensure that planning permission for buildings, facilities and changes of use is always subject to a specific assessment of the geological conservation interests. The public s ability to experience and gain access to areas of geological interest must also be assessed where relevant Assessment of environmental impact Landscape Under the zero alternative it is not planned to establish any more buildings and facilities, so there will be no further impact on the landscape and the designated coastal zone. Geology As it is not planned to establish any more buildings under the zero alternative, there will be no additional impact on the area of geological interest. The zero alternative is not expected to affect the geological conditions, but the geological conditions have a bearing on the effect of the zero alternative on groundwater and surface water. A number of geological and groundwater factors were highlighted for closer study when designating the six sites out of the list of 22 /19/. Based on these characteristics, the Risø area ranked among the least suitable sites, partly because of the thin layer of fine-grained clay in the area. 7.7 Climate Climate change could affect the future repository because of the increased risk of extreme events. This section describes the future scenarios that are being examined in Denmark and abroad, which serve as a basis for assessing whether the planned site is expected to be significantly affected by changes in the climate Environmental status and objectives Based on the latest Danish and European scenario analyses, the Danish Meteorological Institute (DMI) has described the expected future climate changes in Denmark out to The assessments are based on the scenarios used by the UN s International Panel on Climate Change (IPCC) /20/. The changes are expected to increase towards the year Considerations of climate change are relevant to the placing of the repository and an assessment of the zero alternative because of the risk of rising sea levels flooding the facility, which could lead to penetration by surface water and hence an increased risk of radioactive substances spreading into the environment. The DMI report suggests that Denmark will experience warmer and wetter weather in the future, with more extreme events such as longer periods of drought and heavier rainstorms, and temperature increases. It also projects a general rise in sea levels in the waters around Denmark /20/. More recent projections are now pointing to even greater rises in sea levels around

55 49 of 234 Denmark, ranging from 80 ±60 cm to max. 150 cm by There may be further increases towards 2200, but estimates are extremely difficult and fraught with very great uncertainty/20/ Assessment of environmental impact Changes in sea level Parts of the Risø site on the peninsula are just above the present-day sea level, from 0 m to +3.5 m, some of it just under +1 m, while the rest of the area is much higher, up to +19 m. Even if we project a rise of at least 80 cm in the seas around Denmark (by 2100), it is hard to predict the effect of an increase in Roskilde Fiord. With a rise of 80 cm, small parts of the peninsula will be flooded, and we may expect increased erosion of the coastal cliffs. As mentioned above, the vertical movement in the land in the area is estimated at between and mm per year, and if this continues, it will help to reduce the effect of rising sea levels. It should also be noted that there has been a modest net rise in sea levels within the last 100 years measured at stations on the outer coasts, with Risø and Roskilde Fjord experiencing a theoretical rise of between +0.1 and +0.3 mm per year /29/. Extreme events The Roskilde area is not especially exposed to storms and flooding because of its geographical location at the head of the fjord, even though it is on a west-facing coast where the most serious impacts generally occur. But Roskilde Fjord is affected by the very large build-ups that can occur and which manifest themselves as bottleneck problems in the exchange of water between the Kattegat/North Sea and the Baltic. With rising sea levels and more frequent storms, the area will be exposed to more destructive forces. The highest water level recorded in the port of Roskilde during storm Bodil on 5 December 2013 was 2.06 metres above mean sea level. During the night to 6 December 2013, water penetrated a low-lying basement of a Danish Decommissioning building. This part of the basement was not used to store radioactive material, so the flooding did not cause any radioactive emissions. A higher water level could cause flooding in parts of the Risø area. After the storm surge, Danish Decommissioning produced a note explaining that the storm had not caused significant damage or flooding either to the land or to buildings. The note also sets out the potential consequences of similar events in the future, with water levels higher than they were during Bodil. The need for possible mitigation measures in the future is currently under examination. 7.8 Water This section describes the issues relating to groundwater and surface water in the vicinity of Risø. It is based on information from local area studies and municipal designations. The impact assessment is based on the descriptions of the geological conditions (section 7.6), as the impact on groundwater and surface water depend largely in these. Drinking water interests are illustrated on map 0.3: Drinking water interests Environmental status and objectives Groundwater General On the peninsula, where the terrain is low-lying, the water table is very close to the surface (approx. 1 m below ground). In the coastal area the water table is also high, approx m below ground. In the inland area the water table is between 10 and 13 m below ground. Risø s own waterworks extracts water from the Selandian and Danian deposits, and there are details of soundings from the three water supply wells , and , which are in the

56 50 of 234 eastern part of the Risø site around the waterworks. Based on measurements taken, it is believed that there have been modest changes in the water table since the wells were drilled. The flow of groundwater is generally from east to west within the whole of the Risø site, which means towards the west from the sources near Marbjerg and Brokilde waterworks. It is not known how pumping could affect the flow of groundwater between the sources and the Risø peninsula. Along the coast within the site there are many springs from which the water flows out into the fjord. Drinking water interests Risø is in an area of drinking water interests. To the south and east of the site there is a large area of special drinking water interests, covering e.g. Veddelev and Gundsølille. This contains major well sites for Marbjerg and Brokilde waterworks which are part of HOFOR s water supply to Copenhagen. The well sites are based on pumping groundwater from sloping Danian limestone strata. The two well sites are approx km from the Risø peninsula and pump a total of million m 3 of groundwater per year. Surface water There are no watercourses at Risø, and the area is surrounded by Roskilde Fjord, which is covered by the water management plan for the Main catchment area of Isefjord and Roskilde Fjord. The marine water areas within this catchment area are assigned the environmental target of good ecological status. None of the coastal waters in the catchment area displays a status today that would justify a target of high quality. In relation to Natura 2000 areas there is no documented basis for tightening the requirements to a better status than good. The water management plan therefore does not set any stricter environmental targets for the coastal waters /33/ Assessment of environmental impact Groundwater It is not known whether there is an upward or downward flow of water through the covering layers under the Risø peninsula. We cannot therefore rule out the possibility of local impact on the groundwater beneath the peninsula as a result of seepage or leaks into the soil. The flow of groundwater towards Roskilde Fjord means that any impact on the groundwater would be limited in extent. Drinking water interests Risø is designated as an area of drinking water interests. Any impact on the groundwater beneath the Risø peninsula will therefore affect drinking water interests also. With the flow of groundwater from east to west and the presence of springs along the coast, there is not thought to be any risk of impact on the catchment areas for public water supplies, including the well sites at Brokilde and Marbjerg. Surface water Seepage from the facility or leaks into the ground could find its way to Roskilde Fjord across the surface, in drains or through the groundwater. 7.9 Soil Environmental status and objectives Contaminated land An analysis of contaminated land pursuant to the Soil Pollution Act may be carried out at either knowledge level 1 (V1 analysis based on reasonable suspicion) or knowledge level 2 (analysis based on actual studies). The two terms therefore only cover a description of whether the

57 51 of 234 property has been examined and give no indication of how contaminated a property might be and with what substances. All of Risø is a classified area and there is a V1 zone and two V2 zones close to the facility Assessment of environmental impact The zero alternative may have an impact on the soil resulting from discharges of substances via leakage or flooding, as described for surface water Tangible assets This section deals with tangible assets, which in this context means a presentation of interests associated with agriculture, raw materials and afforestation. These topics are illustrated on map 0.4: Tangible assets Environmental status and objectives The site contains no afforestation areas or areas of special agricultural value. There are no raw material interests in the area Assessment of environmental impact There is no conflict with tangible assets in relation to municipal designations Cultural heritage This section presents the cultural and historical interests illustrated on map 0.5 Cultural heritage Environmental status and objectives There are no protected finds or ancient monuments at Risø and no designated cultural heritage sites or cultural environments. The nearest cultural heritage site is between the peninsula and Frederiksborgvej Assessment of environmental impact There is no conflict with cultural and historical conservation interests Summary assessment The most significant impacts of the zero alternative are considered to be linked to the following factors: Risø is situated near the coast and is also a designated low-lying area. It is possible that there could be a greater risk of seepage in the future, particularly with rising sea levels and extreme events, so there is a greater risk of impact on surface water and natural conditions than there is today. Part of the Risø peninsula is covered by the beach protection belt. The highest water level recorded in the port of Roskilde during storm Bodil on 5 December 2013 was 2.06 metres above mean sea level. During the night to 6 December 2013, water penetrated a low-lying basement of a Danish Decommissioning building. This part of the basement was not used to store radioactive material, so the flooding did not cause any radioactive emissions. A higher water level could cause flooding in parts of the Risø area. The whole of Risø is situated within the designated coastal zone.

58 52 of ØSTERMARIE-PARADISBAKKERNE Østermarie-Paradisbakkerne is in the north-east of Bornholm close to the coast outside Bølshavn and Listed. The site covers an area of approx. 15 km 2. The general background to the work on a plan to establish a final repository can be found in section 2, the planning guidelines are in section 3, while the methods used to analyse and assess the degree of impact are described in section 5. Figure 8-1 Outline map Bornholm. 8.1 Planning conditions This section presents the overall planning framework and strategies for the site in the form of Bornholm Regional Municipality s Municipal Plan and planning strategy. The overall planning strategy for Bornholm Regional Municipality is implemented in the following plans: Business development strategy

59 53 of 234 Bornholm development plan including the regional development plan, the municipal planning strategy and the Agenda 21 strategy Municipal Plan Business development strategy The business development strategy is drawn up every five years by the Bornholm Growth Forum. This means that vocational training institutions, trade unions and management and the Municipal Executive Board together define goals and actions to promote business development. The strategy is drawn up in the first year of the Growth Forum s period in office. The growth partnership agreement covers the topics that the government and the Bornholm Growth Forum have agreed to focus on. The agreement is revised each year Bornholm development plan The Bornholm development plan is a high-level document that sets the direction for future planning and development in Bornholm Regional Municipality, both spatial and economic, regional and local. The plan governs both the political and the administrative decisions and is meant to ensure that there is coherence in prioritising resources, funding and tasks. The development plan covers the regional development plan, the municipal planning strategy and the Agenda 21 strategy. These three documents are revised/updated every four years, and the proposals are published in the middle of the electoral period. The Municipal Plan, which is also revised/updated every four years, is based on the municipal planning strategy and the regional development plan. The proposal is published immediately before the municipal elections, and it is typically the new Municipal Executive Board that adopts it. Vision a green sustainable island The development plan states that Bornholm is a green island, based on alternative energy. It exports alternative energy and related knowledge. This green awareness is omnipresent in Bornholm society, in political and economic life and among ordinary citizens Municipal Plan 2009 The Municipal Plan is the summary high-level plan to enable citizens, businesses, interest groups etc. to understand the overall goals and guidelines for the development of the municipality, both in the towns and in the countryside. The Municipal Plan consists of strategic discussions and deliberations on the type of development the City Council wants to see and what has to be done to make it happen. The Municipal Plan forms the link between the national and regional-municipal high-level plans, including the regional development plan and the other plans the regional municipality has for individual aspects and geographical areas. 8.2 Biodiversity This section focuses on biodiversity, which in this context includes a description and assessment of the impact on Natura 2000, protected nature under Section 3 of the Danish Nature Protection Act, wildlife corridors and national parks or nature reserves. It is assumed that the future facility will not be located in a Natura 2000 area, and that the plan will not have a significant impact on adjacent Natura 2000 areas; cf. plan guidelines. These topics are illustrated on map 1.1: Biodiversity. It is assumed that the local natural assets will be examined more closely in a later EIA study, which will include more detailed investigations of the specific site in the form of e.g. field studies.

60 54 of Environmental status and objectives Among other things, the Bornholm Development Strategy states that nature takes a high priority in planning at the municipal level: Nature Bornholm s unique nature and landscapes have to be protected and preserved so they can continue to be the basis for the good life on Bornholm. The Municipal Executive Board will work to maintain and safeguard biodiversity in nature, so we can comply with international and national standards while providing good opportunities for people to enjoy nature. The Municipal Executive Board will work to ensure that forests and green spaces play a major role, in the interests of the climate, wood production, biodiversity, clean water, outdoor life and public health, and a reliable supply of sustainable energy. /35/. Natura 2000 The planned site does not contain any Natura 2000 areas, but the following international conservation areas are nearby: Gyldenså, Natura 2000 area no 185 and habitat area no H161. The Natura 2000 area covers approx. 14 ha and extends as shown on map 1.1. The Natura 2000 area consists of habitat area no H161. The Natura 2000 area is in the east of Bornholm, on the coast between Bølshavn and Listed. The area extends over approx. 1.4 km and runs between Svanekevej and Bølshavn, where it touches the coast. The habitat area comprises mainly deciduous forest and streams, with a smaller area in rotation at the southern end. Most of the area is protected forest, and all of it is covered by a conservation order from The habitat area is in an area with a lot of intensive livestock production. There is a public footpath approx. 2 km long on the south side of the stream. The area has been designated with respect to three natural habitat types priority natural forest, alder and ash woods /26/. Almindingen, Ølene and Paradisbakkerne, Natura 2000 area no 186, habitat area no H160 and bird protection area F80. The site contains one of Denmark s largest continuous areas of forest and covers the well-known areas of Almindingen, Ølene and Paradisbakkerne. The area takes in the highest point on the island and is characterised by numerous rifts in the rocks and isolated large weathered diabase dykes, the most striking of which is Ekkodalen. The height of the landscape in combination with the dense woodland cover means that the area gets the most precipitation on the island, around 700 mm per year compared to less than 500 mm on the coast /27/. Section 3 protected nature Under Section 3 of the Nature Protection Act, it is prohibited to interfere with protected natural habitats in a way that could cause a change to the state of these areas. However, the municipalities may derogate from this provision /11/, often on condition of establishing some natural replacement. Habitats covered by Section 3 of the Nature Protection Act are: Lakes and ponds of at least 100 m 2. Marshes, meadows, heaths, dry grassland, coastal meadows and marshland which individually or together cover an area of at least 2,500 m 2. Marshes under 2,500 m 2 are also protected if they are next to protected streams or lakes. Most streams and rivers are also protected via a special Section 3 designation. Lakes include both natural and wholly or partly man-made pools, basins and dams.

61 55 of 234 The site contains few registered protected nature areas (cf. Section 3 of the Nature Protection Act) in the form of meadows, dry grassland, streams and lakes. The largest streams, Gyldenså and Vaseå, both run in a north-south direction to the coast. Altogether, the area contains: 5 meadows 2 areas of dry grassland 26 smaller pools 4 streams 2 managed forests Areas of special natural interest The Municipal Plan identifies areas of special natural interest within which nature conservation interests have to be respected by way of strict administration of legal provisions and by conservation, restoration, protection and information. Existing lawful general agriculture and forestry can normally be practised in these areas. However, agriculture and forestry may be restricted if these activities damage living, breeding or resting areas for animal and plant species that are protected under Danish law or Article 12 of the EU Habitats Directive /36/. In the areas of special natural interest, it is prohibited to establish: New large-scale raw material extraction. New technical facilities. Landfill sites. New urban expansion. Noisy recreational facilities. The facility that this plan concerns falls under New technical facilities and Landfill sites. The designated areas are illustrated on map 1.1. Areas of special natural interest are marked in the following areas: Designated areas of special natural interest and protected forest areas generally coincide. the stream and wooded area by Bølsbakke around Maglegård forest along Gyldenså around Lyrsby forest along Vaseå Areas of interest for nature conservation Areas of interest for nature conservation consist of continuous areas of natural value or geological interest and ecological corridors within which there are registered valuable landscape, geological and nature conservation interests. The Municipal Plan sets out areas of interest for nature conservation, where general agriculture and forestry can normally be practised without restrictions on use. Within the areas, efforts must be made to ensure that no new buildings, technical facilities, holiday or leisure facilities etc. are constructed or any changes made to the land, e.g. by earthmoving and other operations, that could compromise the living conditions for flora and fauna, recreational opportunities and/or the special topographical value of the area. The designated areas are illustrated on map 1.1. Areas of interest for nature conservation have been marked out in the following locations: around the stream and wooded area by Bølsbakke around Maglegård forest around Gyldenså around Lyrsby forest around Vaseå

62 56 of 234 Beach protection Along the coast there is a 300 m protection line that enters the planned site at Bølshavn in the northern part of the area. Protected forest The vast majority of private woods and all public woodland in Denmark have the status of protected forest (fredskov) and are safeguarded by the provisions of the Forests Act. The area contains continuous areas of protected forest, mainly in the river valleys but also spread across the open countryside. Large continuous areas of protected forest are Maglegård forest and Lyrsby forest in the western part of the area. National parks Not relevant to this area Assessment of environmental impact General It is impossible to define criteria for protecting the environment against radiation as there are no statistics covering the health impact of ionising radiation on animals and plants, as there are for people. Internationally, projects have been launched to determine the effect of ionising radiation on nature and, on this basis, to use reference animals and plants as a means of establishing criteria and producing subsequent safety analyses. The progress of these projects will be monitored and taken account of as far as possible in defining environmental protection criteria when the safety analyses are carried out in a later EIA phase /15/. Human beings are generally considered to be the organism that is most vulnerable to ionising radiation. Therefore, once criteria have been established to safeguard people, we may assume that animals and plants will be sufficiently protected against radiation. Exceptions to this assumption will mainly apply to a small population of a species in a restricted area around the repository /15/. The environmental protection criteria applicable to a given repository will be drawn up in conjunction with the mandatory EIA studies to be carried out for two selected sites if it is decided to proceed further with the repository plan. In this connection, detailed field studies will be carried out as part of the basis both for assessing potential effects and for defining environmental protection criteria. This will ensure that local conditions are taken into account in the form of sitespecific assessments concerned with protecting the environment. This section presents the general conflicts with nature conservation interests. Natura 2000 The guidelines to the plan for a repository explain that any future facility must not have any significant effect on adjacent Natura 2000 areas (guideline no 7, Nature). The future planning and project design must therefore ensure that a facility can comply with these provisions. This will be determined by a materiality assessment, which will consider whether there is a risk of significant impact on the Natura 2000 area. If it is considered that there is a risk of significant impact, an impact assessment will be carried out. The purpose of this is to examine the potential impact in relation to the conservation goals for the area, and to incorporate mitigation measures into the project in order to avert any serious impact. So it is important to note that the guidelines in the plan and the assessment that there is no significant impact on the Natura 2000 area place a number of restrictive requirements on a future project, and that the project cannot be implemented if there is a risk of significant impact on the Natura 2000 area; cf. Habitats Order, Section 7(24) (Executive Order on the designation and

63 57 of 234 administration of international nature conservation areas and the protection of certain species, Order No 408 of 01/05/2007.) Section 3 protected nature There is a risk of impact on Section 3 protected areas where the facility itself or the access roads are positioned in direct conflict with the protected areas. As the gross area is relatively large, there is every chance of positioning the facility so that it does not affect protected areas. This consideration should therefore be included in subsequent planning and project design. No guidelines have been included in the plan to guard against conflicts with Section 3 protected nature, as other factors determining the ideal positioning may result in conflicts with Section 3 protected nature. Areas of special natural interest The areas of special natural interest include e.g. protected forests, the stream and wooded area by Bølsbakke, areas around Maglegård forest, along Gyldenså, around Lyrsby forest and along Vaseå. These areas may be directly affected by the plan if the facility is located inside the designated areas. A specific guideline on nature has been defined in the plan (guideline no 7, Nature), which states that the positioning of the facility should take maximum account of adjacent designated nature areas etc. Areas of interest for nature conservation Nature conservation areas, which generally coincide with areas of special natural interest and could be affected in the same way; see description above. Beach protection It is assumed that the facility will be located outside the beach protection belt at Bølshavn in the northern part of the site. Protected forest There is a risk of impact on protected forest areas. The large continuous areas of protected forest coincide with designated nature conservation areas, which the plan guidelines say must be taken into account in the choice of location for a repository. National parks Not relevant to this area. Repository types The three types of repository take up the same area, so will result in the same risk of impact to natural conditions arising from any closing off of land and hence of a potential impact on Section 3 areas, special nature areas or areas of interest.

64 58 of 234 Table 8-1 Summary impact assessment. Environmental aspects Biodiversity Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Natura 2000 No - The guidelines to the plan state that a facility cannot be established under this plan if there is a risk of significant impact on Natura 2000 areas. The concrete assessment of whether the facility can meet this requirement will be made in a later EIA phase, when the location, repository type etc. are known. Section 3 protected nature Areas of special natural interest Areas of interest for nature conservation Beach protection belt Yes Yes Conflict with protected areas may be avoided by the choice of final location for the facility, as the gross areas are relatively large. Yes Yes The areas of special natural interest include e.g. protected forests, streams and wooded areas. Yes Yes Areas of interest for nature conservation have been marked out around streams and wooded areas. No - It is assumed that the facility will be located outside such protected areas. Plan guideline no 9, Building and protection lines, stipulates that the repository may not be located within the beach protection belt. Protected forest Yes Yes The area contains areas of protected forest, mainly in the river valleys but also spread across the open countryside. Assessment of impact None National parks No - Not relevant None None or minor The degree of impact depends on the positioning of the repository. None or minor Plan guideline no 7. Nature, ensures that the placement of the facility should take maximum account of adjacent designated nature areas, wildlife corridors etc. The degree of impact depends on the eventual positioning of the repository. None or minor (same assessment as above) None None or minor The degree of impact depends on the positioning of the repository.

65 59 of Population and health This section describes the location of the planned area in relation to settlements, the number of inhabitants, commercial activity, tourism and recreation. It is mainly based on information from Statistics Denmark and the Municipal Plan. The section then describes the potential impact on the population in terms of health risks and indirect environmental effects, including the risk of reduced revenue, relocation etc. It is assumed (cf. plan guidelines) that the facility will be designed to be able at any time to demonstrate compliance with the specified dose constraints when in operation and after closure, both for these periods and for potential incidents (accident scenarios). Documentation of this will be provided in the form of safety assessments for the facility and its use. The assessment of the impact is also based on available information from e.g. descriptions of transport and radiation in the feasibility studies. The assessment of the indirect environmental impact on the population and industry identifies potential effects based on an analysis of responses to consultation and comments from public meetings focusing on e.g. people s concerns about the effects of implementing the plan Environmental status and objectives Population The site is in the inland zone, apart from the most northerly part of the area by Bølshavn, which is an area of summer cottages under local plans. The planned site takes in scattered farms and smallholdings. The north-western part of the planned site also covers part of Bølshavn, which is right on the coast. Both Bølshavn and Listed to the east are popular destinations for tourists. The distance to large towns can be seen in Table 8-2. Table 8-2 Distance from major settlements. Distance from settlements: Svaneke: approx. 1.5 km. Østermarie: approx. 2 km. Nexø: approx. 3.2 km. Aakirkeby: approx. 10 km. Rønne: approx. 20 km. The population figures for the larger towns and for the whole of Bornholm can be seen in Table 8-3 (as of 2012). Table 8-3Breakdown and number of inhabitants on Bornholm. The breakdown and number of inhabitants is as follows: Svaneke: 1,067 inhabitants (2012) Østermarie: 470 inhabitants (2012) Nexø: 3,700 inhabitants (2012) Aakirkeby: 2,108 inhabitants (2012) Rønne: 13,887 inhabitants (2012) Total population of Bornholm (2012): 41,303

66 60 of 234 Industry The Bornholm development plan contains objectives for business development on Bornholm. Bornholm s economic structure has traditionally been dominated by raw material extraction, fishing and agriculture, and associated businesses engaged to a greater or lesser extent in processing. As part of the analysis of the commercial conditions, the numbers of people employed in the whole of Bornholm have been surveyed, broken down into tourism and leisure, agriculture, fishing and food production, as shown in Table 8-4. These industries are considered crucial in terms of the impact on the population and health and the indirect socio-economic effects of the plan for a permanent repository. The chart shows a selection of the key industries with an assessment of the socio-economic effects. The analysis of employment has been carried out for the whole of Bornholm Regional Municipality, as it is felt that implementing the plan may affect a large part of the local community and not just the planned site itself. Table 8-4 Breakdown of employment in Bornholm Regional Municipality within selected industries related to tourism and leisure, agriculture, fishing and food production, as of The total number of people employed on Bornholm is 17,224 (Statistics Denmark 2013). In 2007, 982 persons were employed in primary agriculture. Total employment including indirect employment is estimated at approx. 2,300 people, and according to Bornholms Landbrug there are now (in the Municipal Plan for 2009) 48 dairy producers, 160 pork producers, 7 poultry producers and approx. 20 arable farmers (all full-time) /36/. If we compare the figure of 982 employed in primary agriculture with details presented in Table 8-4, which shows the breakdown of employment in selected sectors in 2013, agriculture predominates over forestry and fishing. Tourism The Bornholm development plan includes high-level tourism policy objectives which focus on promoting tourism on Bornholm by: increasing and improving the capacity of overnight accommodation with new, tailored and high-quality offerings that cater for growing numbers of tourists and new requirements to address individual needs. promoting high-quality tourism-related activities, and improving and developing recreational leisure facilities.

67 61 of 234 Tourists favourite destinations for excursions on Bornholm are shown in Table 8-5, which lists a selection of the most-visited attractions on the island. Within the planned site is Joboland/Brændesgårdshaven, which receives 91,900 visitors a year. Table 8-5 Tourists favourite destinations for excursions on Bornholm /34/, /36/. Visitors to tourist attractions 2009 Attractions measured Historical attractions: - Hammershus castle ruin - Østerlar round church - Christiansø Natural attractions: - Almindingen (with Lilleborg, Ekkodalen) - Helligdom cliffs - Paradisbakkerne - Rytterknægten Museums/exhibitions: - Natur Bornholm - Bornholm Art Gallery - Oluf Høst Museum - Melstedgård museum of rural life - Hjorths Fabrik (ceramic museum) - Bornholm Museum, Rønne - Bornholm Technical Collection - Grønbechs Gård (manor house) - Svanekegården (cultural centre) Other tourist attractions: - Smokeries - Glass blowers - Art gallery/handicrafts - Joboland/Brændesgårdshaven - Bornholm Medieval Centre - Bornholm Summer Bird Park - Bornholm Bird of Prey Show Approx. no 325, ,000 70, , , , ,000 60,150 40,198 38,350 15,550 12,700 11,700 8,800 7,700 5, , , ,900 91,900 58,000 31,000 19,800 Recreational areas The development plan contains objectives for natural and cultural assets on the island that can provide a basis for outdoor life and a wide range of activities that can contribute to wellbeing, health and quality of life. It therefore focuses on maintaining and improving access to nature conservation and recreational areas. The planned site contains nature areas of recreational value, including the river valleys around Gyldenså and Vaseå, and the wooded areas of Maglegård forest, Lyrsby forest and Paradisbakkerne immediately to the south of the site. The ancient monuments at Louisenlund also have recreational value as a place to visit. There are no designated footpaths within the site, but established paths in the forests and along selected stretches of the streams combine with the other roads and paths in the area to form a network of recreational routes. The eastern part of the planned site contains the Joboland/Brændesgårdshaven amusement park, which includes a water park, zoo and various play areas Assessment of environmental impact The assessment of the impact on the population covers health (related to transport, risk of accidents and radiation, safety and security of the facility itself), and socio-economic factors, including the population, commercial interests, tourism and recreational activities.

68 62 of 234 Health Radiation protection The health impact of exposure to radiation from the facility itself and from potential events is described in section 4.2, as the same requirements apply to safety assessments and official approval regardless of the choice of site. Transport Based on the feasibility study, we conclude that both road and sea transport may be considered. The radiation doses estimated for transport of Danish radioactive waste from Risø to a future repository are calculated on the basis of the greatest possible distance to any repository. The estimated doses in the feasibility study are therefore upper limits, and doses from shorter transport routes will be proportionally lower. The study shows that the risk associated with road and sea transport does not restrict the future selection of a location for a repository in Denmark, and that the transport can be handled so that the dose is well below the national thresholds. Transport to Bornholm involves the shortest distance by road, but it will require sea transport. There are no alternatives to sea transport to Bornholm. Changes in distance have no effect on doses in the event of an accident. The likelihood of an accident is dependent on the quality of the road, the volume of traffic etc., and is also proportional to the distance. Compared to the zero alternative, the radiation dose is greater in the short term as a natural consequence of the fact that, in the zero alternative, the waste will not be processed as much, or transported from the location. In the longer term, it will be necessary to process and possibly transport the waste under the zero alternative too, as Risø does not have the status of a permanent repository. Socio-economic factors Apart from the general population-related issues mentioned in section 4.2, the stakeholders have drawn attention to a number of local matters that should be given special consideration in the choice of the two final locations. Table 8-6 summarises the major concerns raised by stakeholders on Bornholm. This is used as part of the background to the description of the potential impact on the population and the socio-economic factors, and also forms the basis for suggested mitigation measures (section 15.2). Table 8-6 Summary of the major concerns raised by stakeholders on Bornholm. Subject Radiation level Earthquakes Transport, operation and accidents Description The stakeholders point out that the background radiation on Bornholm is higher than in the rest of the country, and that Bornholm has proportionally more cases of cancer than the rest of Denmark. In light of this, the stakeholders express a need for assurance that any repository will not have an adverse effect on the already relatively high level of background radiation compared to the rest of the country. The stakeholders say that there are two faults on the island that move over time and raise the risk of earth tremors, and that the granite also contains fractures that could give rise to seepage from a future repository. Any specific solution must therefore explain how these challenges can be properly resolved so there is no seepage from the repository now or in the future. With regard to the granite on Bornholm, the stakeholders also express concern as to whether the blasting rules can be complied with something that has to be covered in the actual planning if a repository should be established in the area. The stakeholders also say that they have a general reservation about blasting in the unique natural phenomenon that is Bornholm granite. This is a local cultural feature which must be considered in the future process. Apart from these points, the stakeholders express concerns about a number of practical matters arising from the establishment and operation of a repository on Bornholm. First, it is questioned whether there are competent staff available to operate such a repository on Bornholm. Part of the planning should therefore be to determine whether this is the case, and to train such staff if they are not there. Secondly, there are concerns about safety in connection with the relatively long journey to the island from the rest of the country and for waste transport on the small roads in the area with their restricted width and poor load-bearing capacity. The

69 63 of 234 Subject Tourism, food production and business Bio-region Bornholm Description specific options for safe transport should therefore be included in the deliberations on the choice of location, and in the actual planning of a permanent repository. Thirdly, the stakeholders express concern about an evacuation plan and its viability in the event of leakage. The isolated location of the island especially needs to be taken into account. Given this concern, it seems sensible to inform the stakeholders of the risks associated with a repository, the extent and consequences of any seepage or other unforeseen event, and the rules of conduct to be followed in this regard. Fourthly, the stakeholders are worried about the process of cleaning up after such an unforeseen event. For example, they question how any surface or groundwater penetrating the facility will be removed and cleaned, or how contaminated extinguisher water will be treated in the event of a fire. The level of concern among stakeholders can be reduced by drawing up concrete plans for such events. The stakeholders express concern about the effect of a repository on the island s brand as a whole. They are concerned both about whether the island may be seen differently by tourists and whether the demand for goods could fall. For example, they mention the brand Skovgrisen fra Vasagaard (pork from Vasagaard) which emphasises sustainability and the fact that the pigs lead healthy lives. At a more general level, the stakeholders also express concern that investment in the island could decrease as a result of the project. It is thus very important for the stakeholders to be able to demonstrate that any future repository will not affect tourists and business in the area. A project concerning the bio-region Bornholm is currently under way. The bio-region concept is about creating sustainable local communities for the future, and this project aims to promote this in the local community on Bornholm. In relation to this, the stakeholders express concern about the future of this project if a repository should be established. It therefore seems sensible to enter into cooperation with the bio-region Bornholm project and hence find a way of enabling the two projects to benefit each other. *This description is extracted from minutes of the public meeting held in Rønne and from responses to consultation on the scoping report. Summary The questions relating to the establishment of the facility itself, and the practical problems that may arise as a consequence, are not dealt with in depth in this Strategic Environmental Assessment because of the level of detail in the plan. The project-specific issues with questionmarks against them will be addressed in a later phase, when risk assessments will be carried out in conjunction with the subsequent work by the authorities once there is an actual project. This will take account of local conditions, including the risk of earthquakes and accidents. If we look at the comments from stakeholders of both a general and a local nature, we see that they are marked by a high degree of concern. These concerns are directed at a broad and diffuse set of risks, which indicate a lack of knowledge of the real risks involved in implementing the plan and of the measures that have been and will be taken to avert these risks. The comments also show that the stakeholders do not have sufficient knowledge of the process to be followed in the future, leading to widespread uncertainty and mistrust. The stakeholders do not feel convinced that the future process will adequately examine and address the perceived risks and involve the stakeholders, to ensure that local interests are safeguarded. For these reasons, the analysis shows that the plan to establish a repository has received a very negative response from the stakeholders. This negative attitude, insecurity and mistrust of the plan and the projected process create the ideal conditions for a number of negative social effects to become reality. In this situation, it is not impossible that a repository could have indirect effects on tourism (both generally on the island and in relation to local attractions), people moving in and out, land and property prices, sales of food products (including the effect of Bornholm s brand ), the physical wellbeing of the inhabitants etc., purely because of insecurity and mistrust. There could also be cumulative effects, as the plan could help to speed the decrease in population that we are already seeing on Bornholm today. It is therefore crucial to the social effects of the plan that the insecurity and mistrust should be reduced.

70 64 of 234 Overall, there may be a risk of impact on socio-economic factors, including tourism and the food industry. The plan may thus conflict with the overall strategies and visions that exist for Bornholm, as described e.g. in Bornholm Regional Municipality s Municipal Plan. Table 8-7 Summary impact assessment. Environmental aspects Population Health Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Assessment of impact Radiation protection Securing the facility Yes Yes The impact in the immediate vicinity will depend on the final location. Yes Yes A vulnerability assessment should cover different scenarios and their consequences. These scenarios should be covered by security and contingency plans designed to assure the greatest possible, reasonably attainable reduction of risks and potential doses. Minor (below the dose constraintdose constraints) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraintdose constraint. As with the category of transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the dose constraintdose constraint) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraintdose constraint. As with the categories of radiation protection and transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses.

71 65 of 234 Environmental aspects Population Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Transport Yes Yes The impact in the immediate vicinity will depend on the final location. Noise, heavy traffic and emissions may have an impact in connection with transport within the planned area. Socioeconomic conditions Yes Yes/No. In recreational areas etc. the impact may be dependent on the final location, but the general concern about the impact on the population and industry is considered to be independent of the final location, and in many cases people expect an impact beyond the planned site itself. Implementing the plan may cause indirect effects on the population and socio-economic conditions. The stakeholders highlight a number of issues that cannot be addressed at this introductory stage of the planning process, but these issues will be examined more closely in an EIA phase and in conjunction with safety analyses and official approvals. Assessment of impact Minor (below the thresholds for exposure to radiation). Estimated doses for transport to the planned site are well below the maximum doses. There will be a need to plan transport routes, times etc. to achieve a reduction of risks and potential doses. Moderate to significant The impact is judged to be of moderate to significant importance because of the high level of concern and the uncertainty expressed among the stakeholders. This should therefore receive close attention in the later phases. 8.4 Landscape and geology This section presents geographical and geological conditions within the planned site, which here encompass a high-level description of the landscape and any designated areas and a description of the geological conditions based on the feasibility studies, with any designated features. These topics are illustrated on map 1.2: Landscape and geology. The assessment of the impact on the landscape is based solely on whether there is a risk of impact on valuable landscapes and the designated coastal zone. It is assumed that the real impact on the landscape and visual factors will be determined in a later EIA study, where landscape analyses, visualisations etc. can be based on the choice of a specific location and a concrete project proposal. The purpose of examining the geological conditions is to assess the degree of uncertainty as to the ability of the geological conditions to act as a physical barrier around a possible repository. It is assumed that the local geological conditions will be examined in more detail in a later EIA study Environmental status and objectives Landscape Landscape description The site is to the north of the elevated forest area of Paradisbakkerne. The general character of the landscape is a gently undulating terrain with few (but conspicuous) hills. Slopes are long and gradients only shallow. The highest areas are at +65 m to +80 m, and the hillsides slope m over 2 4 km, equivalent to approx. ½ 1 %. Most of the area is marked by such slopes. Steeper slopes (up to 5 %) can be found locally, e.g. at Bavnebakke and along the rivers.

72 66 of 234 The area is crossed by rivers running north-east to south-west and flowing into the Baltic. The rivers and streams are relatively alike, with narrow valleys. This area consists of Bornholm gneiss and Paradisbakke pegmatite and is bordered on the east by Svaneke granite. Designated coastal zone The designated coastal zone is defined in the Planning Act and is approx. 3 km wide. The rule is that the designated coastal zone must be kept free from buildings and facilities that are not dependent on proximity to the coast. More than half of the designated site is covered by the designated coastal zone. Planning Act: Section 5b. The following shall apply to planning in the coastal zone: 1) It is prohibited to transfer land to an urban zone or to conduct planning for development in a rural zone unless there is a specific planning-related or functional justification for location near the coast. Geology A detailed discussion of the geological conditions can be found in GEUS report no 1 /1/. The following description is a summary of the geological conditions described in the local area study. Rock and soil types The geology of the site is made up of Precambrian bedrock covered with thin layers of Quaternary clayey till and post-glacial freshwater deposits in the river valleys. The pre-quaternary rocks comprise approx. 1,450 million year-old Precambrian crystalline bedrock types. There are two main types: Paradisbakke migmatite and Bornholm gneiss. There are only a few places where the rocks are visible, so it is difficult to draw a boundary between them, but the gneiss is generally found in the west and the migmatite in the east. Paradisbakke migmatite can be seen on the edge of Paradisbakkerne and in several quarries outside the area, such as Præstebo and Bertelegaard. Both rocks can also be seen along the coast from Listed to Saltuna. Bornholm gneiss is a grey or brown, foliated, fine to medium-grained crystalline rock which often shows signs of having been folded. Paradisbakke migmatite is a medium-grained mixture of light and dark grey crystalline granitic material with a characteristic foliated, flamed appearance. The two rocks are normally hard and solid, but they may be weathered and crumbling in the coastal areas. Both rocks are cut through with younger, black fine-grained diabases and reddish-grey course-grained pegmatites /1/. The bedrocks were folded in the early stages of formation, and examples of this can be seen especially along the coast. A later phase produced large and small linear structures that cross the area. There are relatively few fracture zones (faults) in the area running from north-east to south-west compared to other parts of Bornholm, and no rift valleys. The diabase dykes generally run in the same direction and are related to fault zones and regional fracture systems /1/. Geophysical studies in the boreholes show that the rocks are full of fracture systems that extend from ground level to a depth of 90 m, and fractures have been found in all the boreholes examined. It is hard to determine the direction of the fractures, but there are signs that horisontal fractures at several levels can be followed over great distances, and they are cut through by vertical fractures from ground level.

73 67 of 234 The Precambrian rocks are covered with a thin, almost continuous layer of Quaternary clayey till (deposited in the Ice Ages) or post-glacial freshwater deposits (laid down after the last Ice Age) in the river valleys. The uppermost layers of clayey till consist of sandy, gravelly, yellowish brown or olive coloured calcareous clayey till up to approx. 3 m thick, on top of silty, slightly gravelly olive-grey calcareous clayey till that may be a few metres thick. The deposits vary in thickness from 0 m to 5 6 m over most of the area, but in the river valleys, the strata may be up to 17 m thick. The experience is, that thin deposits of clayey till contain fractures and sand lenses /1/. Mineralogy binding adsorption The mineralogical and geochemical conditions in the rocks and soil will affect the behaviour of the radioactive material if it should leak out of a repository into the surrounding geological strata. Some general observations are set out below. However, the content of the large number of radioactive components in the waste may behave differently in the surrounding rocks and deposits. A key element is that the radioactive material should be able to bind to the rock and soil types. The mineralogical composition of the deposits and the rocks is therefore important. There are no details of the uppermost layers, which consist of clayey till and meltwater sand and gravel. The Precambrian bedrock consists of various types of gneiss, migmatite, pegmatite, aplite and diabase. Typical mineralogical compositions of these rocks are described in /1/. The hard bedrock types weather under the influence of temperature changes and water seeping through, and around the fracture zones, the ferruginous minerals have become oxidised over time and turned into yellowish brown clayey iron compounds. The diabases can also weather and produce dark, clayey material with the minerals serpentine, sericite, chlorite, calcspar and many others. Clay minerals, especially smectite clay minerals, are well-suited to binding radioactive material. These minerals can be present where the bedrocks weather and are found especially in combination with weathered diabase. The hard bedrock types bind radioactive components less well /1/. Redox conditions There is oxygen present in the uppermost layer of soil (the oxidised zone), and this may for example mean that some radioactive components can be made mobile and hence transported more easily. Conversely, the conditions in the oxygen-free (reduced) zone, for example, will help to bind and hold other radioactive components. Judging from the change of colour in the Quaternary clayey till, the oxidised zone appears to reach down to around 3 m below the surface in the area. That means that the deeper Quaternary clayey till and bedrock types are in the reduced zone, but oxidised conditions may extend deeper around fractures. In areas of organic post-glacial deposits, the oxidised zone may be very thin or completely absent. Natural radioactive components in the deposits The bedrock under Bornholm has a relative low content of radioactive minerals, and measurements of the radioactive components potassium, uranium and thorium and the products of their radioactive decay, radium and radon, show average values similar to the bedrock in Norway, Sweden and Finland (between 3.8 and 4.2 ppm uranium), but lower values than in many other parts of the world. The youngest granites appear to have the highest values, while Paradisbakke migmatite and gneiss fall in the middle of the Bornholm rock types (radium content of 83 Bq/kg). Weathered diabase may contain up to 8.5 ppm uranium and 104 Bq/kg radium. There are only very few measurements of the radioactive content of the rocks. High radon values have been measured in the groundwater at Listed (up to 1070 Bq/l) and south of Østermarie (e.g. 434 Bq/l), indicating that radioactive components are present. Radon measurements in homes in the area, taken by

74 68 of 234 Bornholm Regional Municipality, show values up to 200 Bq/m3, but values between 200 and 400 Bq/m3 have also been observed. We may conclude that the level of radioactive components is relatively low or average for a bedrock zone, but higher than in most of the rest of Denmark. Assessment of geological conditions The geological conditions influence the impact of the repository on both surface water and groundwater. The geological conditions need to be uniform and stable within the site and they must contribute to the stability of the repository. The geological strata should help to isolate the waste from the surroundings by enclosing or underlying the repository. The rocks should be lowpermeable and help to bind the radioactive components from any discharge from a repository /15/. These issues are assessed in the table below. The geological conditions are assessed only in relation to a repository placed in the pre-quaternary rocks; in this case, the Precambrian bedrock. If the repository is located on Quaternary deposits, clayey till probably containing fractures and sand lenses will only partly isolate the waste from the surroundings. Table 8-8 Assessment of the geological conditions in terms of stability, low-permeable rocks and binding of radioactive components. Property Assessment Comments Uniform and stable geological conditions contribute to the stability of a repository. Yes The geological strata help to isolate the waste from its surroundings: Low-permeable rocks. The geological strata help to isolate the waste from its surroundings: Binding of radioactive components. Partial Limited The Precambrian bedrock is uniform and stable in the area. Stability will be addressed in any specific project proposal. The Precambrian bedrock is low-permeable, but as this bedrock is cut through with systems of fractures down to a depth of at least 90 m, it can only be described as partially low-permeable rock. The hard bedrock types bind radioactive components less well. Summary The most widespread rock types in the area, Paradisbakke migmatite and Bornholm gneiss, are stable and only slightly weathered. There have great horizontal extension and thickness. The rocks contain fracture systems that extend from ground level to a depth of 90 m, and fractures have been found in all the boreholes examined. It is hard to determine the direction of the fractures, but there are signs that horizontal fractures at several levels can be followed over great distances, and they are crossed with vertical fractures from ground level. The overlying deposits of clayey till may contain fractures and sand lenses. Areas of geological interest To the north of the site, one area, Listed, is designated both as an area of special geological interest and a national area of geological interest. This area is characterised by a coastline of Svaneke granite, gneiss, diabase and sandstone seams. The location is considered important because it is the only place where the interfaces between Svaneke granite and Bornholm gneiss can be studied in detail /36/. The south-eastern part of the area takes in a small part of Paradisbakkerne, which is designated as an area of special geological interest and a national area of geological interest. The terrain is shaped by fracture activity in the Precambrian bedrock and by glacial erosion and deposition in the Quaternary Ice Ages. The bedrock is split by many large fractures running north-north-east to south-south-west and north-west to south-east. The landscape shows how the subsurface has left its mark on the present-day landscape /36/.

75 69 of Assessment of environmental impact Landscape The integration of the facility into the landscape and its visual impact cannot be addressed in detail at this stage of the planning, but they will be included in a later EIA process when there is more knowledge of the location, the type of facility, materials and dimensions all crucial factors for the visual impact. If the facility is located within the designated coastal zone, then before any future project can be implemented, the provisions of the Planning Act require a study to determine whether there is a specific planning-related or functional reason for the coastal location. There should also be a description of the visual impact, which will depend on the repository concept and design. If it is decided to choose a design to make the facility recognisable and visible, e.g. for safety reasons, this will immediately make a greater visual impact than a repository concept that is more integrated into the landscape. The final assessment of the scale of the impact will be made as part of the EIA studies. Repository types It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location has been decided and there is a description of the repository type, dimensions, choice of materials and colours, planting, fencing etc. Geology The plan is not expected to affect the geological conditions, but the geological conditions have a major bearing on the suitability of the site for the establishment of a repository. The geological description will therefore be used as background material to any assessment of the impact on groundwater and surface water. The national area of geological interest at Listed will not be affected by the plan. The national area of geological interest in Paradisbakkerne has landscape value and could be permanently affected by things like terrain movements and a blurring of the original geological formations if the facility is located inside the designated area. The impact may be avoided by the choice of final location. Repository types The potential impact on the geological features is expected to be similar for each of the three repository types, as the total surface area required will be the same whichever repository type is chosen. Table 8-9 Summary impact assessment. Environmental aspects Landscape and geology Designated areas Designated coastal zone Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments No There is no conflict with landscape designations. Yes Yes Half of the site is within the designated coastal zone. The facility can therefore be placed so there is no conflict with this. The choice of final location requires a large number of factors to be taken into consideration, so it is not possible at the present time Assessment of impact None None if the repository is located outside the designated coastal zone. Moderate if the repository is located inside the designated coastal zone. A final assessment of the

76 70 of 234 Environmental aspects Landscape and geology Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments to decide whether or not the facility should be located within the designated coastal zone. Geology Yes Yes Any impact on the national area of geological interest can be avoided altogether if the facility is located outside the designated area. The designated area of interest covers a small part of the planned site and the facility is considered unlikely to have any such impact. Assessment of impact impact requires an actual project and visualisations to be produced in a future EIA phase. None if the repository is located outside the designated area. Minor to moderate if the facility is located inside the designated area. 8.5 Climate Climate change could affect the future repository because of the increased risk of extreme events. This section describes the future scenarios that are being examined in Denmark and abroad, to serve as a basis for assessing whether the planned site is expected to be significantly affected by changes in the climate. It is assumed that a future facility (see plan guidelines), via its design and placement in the landscape, will be adapted to any future climate change and thus less vulnerable to extreme events /1/ Environmental status and objectives Based on the latest Danish and European scenario analyses, the Danish Meteorological Institute (DMI) has described the expected future climate changes in Denmark out to The assessments are based on the scenarios used by the UN s International Panel on Climate Change (IPCC) /20/. The changes are expected to increase towards the year Considerations of climate change are relevant to the placing of the repository because of the risk of rising sea levels flooding the facility, which could lead to penetration by surface water and hence to an increased risk of radioactive substances spreading into the environment. The DMI report suggests that Denmark will experience warmer and wetter weather in the future, with more extreme events such as longer periods of drought and heavier rainstorms, and temperature increases. It also projects a general rise in sea levels in the waters around Denmark /20/. More recent projections are now pointing to even greater rises in sea levels around Denmark, ranging from 80 ±60 cm to max. 150 cm by There may be further increases towards 2200, but estimates are extremely difficult and fraught with very great uncertainty/20/. Most of the area towards Østermarie Paradisbakkerne is within the band from 25 to 80 metres above the current sea level; lowest closest to the coast and in the river valley Assessment of environmental impact Rising sea levels Even given the projected maximum sea level rise of 150 cm by 2100, no part of the site will be flooded. The nearby coast, both north and east of the site, is cliff-lined, which means that erosion and possible depletion of the coastline is very slow and will be insignificant in a 300-year perspective. The vertical movement in the land in the area is estimated to be close to 0, so it will neither increase nor reduce the effect of rising sea levels /1/.

77 71 of 234 Extreme events The area is not exposed to storms and flooding because of its geographical location in the Baltic. But the Baltic Sea is affected by the very large build-ups that may be caused by seiches, which are large standing waves. These may be generated after a period of strong and persistent westerly winds, when large bodies of water may pile up in the east and north of the Baltic. When the westerlies die down or the wind turns easterly, the water will rush back as a large wave through the Baltic, which may cause both very quick and very large changes in water levels. However, it is felt that this type of wave is unlikely to affect this elevated area. With rising sea levels and more frequent storms, the area will be exposed to more destructive forces, which may still be regarded as small and insignificant in a 300-year perspective /1/. Repository type The planning guidelines describe how the facility will be constructed to ensure that it can cope with sudden flooding (climate-proofing), whereby the surroundings will be safeguarded against emissions even in the case of climate change and extreme events. A near-surface repository is considered to be more vulnerable to rises in sea level and extreme events, as there will be a greater risk of flooding and hence spreading environmentally harmful substances into the surrounding area. In the project design for a future facility, contingency plans will be drawn up to allow for these risks. Table 8-10 Summary impact assessment. Environmental aspects Climate Rising sea levels Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments No - Even given the projected maximum sea level rise of 150 cm by 2100, no part of the site will be flooded. Extreme events Yes Yes With rising sea levels and more frequent storms, the area will be exposed to more destructive forces, which may still be regarded as small and insignificant in a 300-year perspective. Assessment of impact None Minor 8.6 Water This section describes the issues relating to groundwater and surface water within the planned site. It is based on information from local area studies and municipal designations. The impact assessment is based on the descriptions of the geological conditions (section 8.4), as the impact on groundwater and surface water depends largely on these. Drinking water interests are illustrated on map 1.3: Drinking water interests. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site Environmental status and objectives Groundwater The local area studies analysed eight bore holes to examine groundwater and drinking water conditions. The site may be described as an area with groundwater reservoirs close to the surface. These groundwater reservoirs are made of fractured bedrock, and the reservoirs are

78 72 of 234 assumed to be limited in extent, although they are also classed as regional. The general quality of the groundwater has been judged to be good. Bore holes In the period October November 2012, bore hole logging was undertaken in eight selected domestic and irrigation wells in the area to investigate fracturing in the bedrock. All the bore holes were open bedrock bores (granite and gneiss) lined at the top in the loose Quaternary deposits (highest approx m). The inflow was judged semi-quantitatively as either major or minor in relation to the individual bore holes. Major means that the fracture(s) account for a significant part of the flow into the individual bore hole, while minor simply means there means there are signs of small fractures in the bore hole. A more detailed description of the method and results of bore hole logging can be found in the local area study /1/. From the logging study, we can conclude that: There are fracture systems in all of the bore holes examined. The fractures go down at least 90 metres, and flow-logging and temperature/conductivity logging attest to the presence of deep circulating groundwater at this depth. There are indications that fracture systems can be found at the same level over several kilometres (e.g. at +10 m to +12 m). The fracture systems from ground level to a depth of 90 m make up a groundwater reservoir that holds modest quantities of water, but often enough for household and small-scale agricultural use. Not all fractures are water-bearing. The largest quantities of water enter at the bottom of the bore holes, where there is deep circulating groundwater at a depth of 90 m, but there is a minor inflow of water higher up in the bore holes too /1/. Soundings of the groundwater level in the bore holes indicate that the groundwater flows mostly towards the sea, but may also flow towards the watercourses in the area. The flow is partly governed by the topography of the area and partly by the fracture systems in the bedrock. Uncertainty about the fracture systems produces uncertainty about the detailed flow. There is probably an outflow of groundwater to the sea, into streams and possibly to springs in hollows or on slopes. Drinking water interests There is no extraction of water for public water supplies. Supplies to individual properties include approx. 20 wells and approx. 10 bore holes. Some of the non-public water supply facilities are in parts of the area that cannot expect to be fed from the public water supply plants. The reasons for this are that they are a long way from supply pipes and the waterworks cannot afford to reach them. Because of the distances and high cliffs it is very expensive to lay water pipes in this area /1/. The water supply in the area is based on individual water supplies and domestic bore holes, and there are no large waterworks. The groundwater reservoirs are based on groundwater flows in horizontal and vertical fractures, which can be hard to locate with drilling equipment. Water infiltrates into the reservoirs through the clayey till layers and fracture systems. Unlike other bedrock areas on Bornholm there are not linear valleys filled with meltwater sand and gravel, which make effective groundwater reservoirs. The water table is often just a few metres below ground, but pumping and limited reservoir capacity (particularly large distances between fractures) will quickly lower the water table to a greater depth /1/. The most important groundwater resources for drinking water supplies are designated as areas of special drinking water interests (Danish: OSD), which are meant to cover current and future needs for water of drinkable quality. In these areas, an extra effort will be made specifically to safeguard the groundwater, in order to prevent contamination and remove any existing pollution.

79 73 of 234 OSDs are the core areas for this targeted groundwater conservation. This means that such areas are regarded as strategic catchment areas and that the municipalities need to take account of the groundwater resources and catchment areas for public waterworks in their spatial planning. The Municipal Plan contains guidelines for protecting the groundwater, which has a high priority in areas of special drinking water interests in areas of drinking water interests and especially in the central parts of the groundwater-bearing catchment areas for the waterworks wells (nearby areas), which are constantly being identified in the ongoing groundwater mapping. The planned site is outside areas of drinking water interests and special drinking water interests, and outside general priority areas. Surface water The planned site is covered by the proposed water management plan for the main catchment area 3.1 Bornholm. The Bornholm main water catchment area has a land area of 588 km 2 and constitutes one water district covering Bornholm and the Ertholmene Archipelago and surrounding waters /37/. Sølyst Bæk (on the edge of the site at the north-west corner), Gyldenså and Vaseå and the Baltic Sea all have objectives to achieve a good ecological status Assessment of environmental impact Groundwater The feasibility studies show that the groundwater level may be lowered when a repository is established. Particularly wells, but also bore holes, will be susceptible to drying out if the water table drops in the fracture-based groundwater reservoirs. As the groundwater reservoirs have a small capacity, the pressure from a lowering of the groundwater level will have a limited horizontal spread, so only nearby wells and bore holes could be affected. Over time, it is possible that water could seep into the facility and polluted water could seep out in the longer term. Depending on the location and design of the facility, this could have varying degrees of negative impact on groundwater and surface water. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow across the surface to the sea or into streams, or infiltrate the groundwater reservoirs. The risk of surface leakage from a near-surface facility is considered to be minimal, as the plan guidelines assume both that the facility will be placed on a horizontal site and that surface water will be handled within the project site. With a near-surface repository going down to 30 metres below ground, or with an intermediate depth facility, there could instead be seepage directly into groundwater reservoirs. Hydraulically active fractures have been found down to a depth of at least 90 metres. It is important to ensure that a near-surface repository going down to 30 metres below ground, or an intermediate depth facility, is placed in an area and at a depth without significant fracture zones. Contaminated water seeping into or infiltrating the groundwater will find its way into the general flow of groundwater into the reservoirs. The water could flow into bore holes and wells supplying individual properties, or into the sea, watercourses or springs. As the public waterworks are upstream of the planned site, there is not felt to be any risk of contaminated water flowing into them.

80 74 of 234 Surface water As described under Groundwater, it is possible over time that water could seep into the facility and polluted water could seep out in the longer term, affecting the surface water. The plan guidelines stipulate that the facility should be constructed in such a way that there is no risk of contaminated water being discharged via the surface into the surrounding environment. There will then be no risk of discharging contaminated water into e.g. streams and lakes. Surface water within the repository site itself will be dealt with both as the repository is being filled and in the longer term, when it is closed, which will require monitoring as described in chapter 16. Repository types As described under Groundwater, both a near-surface repository down to a depth of 30 metres and an intermediate depth repository carry the risk of contaminated groundwater flowing into surface water, i.e. into the streams in the Vaseå, Sølyst Bæk and Gyldenså area. However, the plan guidelines ensure that surface water is handled within the repository site, whichever repository type is chosen. There is therefore no risk of contamination of surface water via surface run-off. Table 8-11 Summary impact assessment. Environmental aspects - Water Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Groundwater Yes Yes The potential conflict is linked to leakage. The geographical extent of the conflict is hard to predict because of limited knowledge of fracture systems in the bedrock and the resulting uncertainty surrounding details of the flow of groundwater. Assessment of impact Minor - Plan guideline no 3 (Requirements for geological conditions) ensures that any repository will be located in suitable geological formations, so the impact will be limited. Drinking water interests The risk of impact on groundwater can be reduced by the final choice of location in an area and at a depth without any significant fracture zones in the Precambrian bedrock. This needs be examined more closely in a future EIA phase. No Yes There are no designated drinking water interests or catchment areas for public water supplies within or in the immediate vicinity of the large gross area. Drinking water interests are therefore judged not to be affected. None

81 75 of 234 Environmental aspects - Water Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Surface water Yes Yes The potential conflict arises from potential leakage from a near-surface facility down to a depth of 30 m or an intermediate depth facility with seepage into the groundwater and thence into streams, lakes or the sea. The degree of impact depends on the eventual positioning and the geological barriers. The risk of seepage into the groundwater can be minimised by the choice of location in an area and at a depth without any significant fracture zones in the Precambrian bedrock. Assessment of impact None if a nearsurface repository is established on the ground. Minor if a nearsurface repository going down to a depth of 30 metres, or an intermediate depth repository, is established. Any leakage from a nearsurface facility onto the ground will be handled within the project site, so there is no surface run-off of contaminated water into streams, lakes or the sea. These matters will be examined more closely during the detailed field studies to be carried out under the Project Planning Act and possibly during the EIA study. 8.7 Soil The section describes the potential impact of the plan on the soil. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site, e.g. in relation to identified contaminated land Environmental status and objectives Contaminated land An analysis of contaminated land pursuant to the Soil Pollution Act may be carried out at either knowledge level 1 (V1 analysis based on reasonable suspicion) or knowledge level 2 (analysis based on actual studies). The two terms therefore only cover a description of whether the property has been examined and give no indication of how contaminated a property might be and with what substances. In this situation, no analysis of the known contaminated land on the site is being carried out, because the scoping found that the plan would not conflict with any existing soil contamination, as it would not prevent a future public clean-up effort. There may also be several pieces of contaminated land on the site which have not yet been analysed, so it is assumed that more detailed studies will be made of the soil in the relevant location in connection with a future EIA study.

82 76 of Assessment of environmental impact Handling of soil During the construction phase, soil will be handled in line with the municipality s guidelines on soil handling. Soil contamination As described in section 8.6.2, there may be an impact on surface water resulting from discharges of substances via seepage into the groundwater. In the same way, substances may be discharged into the soil on the surface. The extent of this impact and the likelihood of it occurring cannot be assessed from the information available at this time. An EIA study involving more detailed investigations of the actual location and a project to produce a detailed description of the barriers will be able to make a more differentiated assessment of the risk of impact on the soil. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could run off over the surface into the topsoil. Table 8-12 Summary impact assessment. Environmental aspects - Soil Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Soil Yes No The potential impact on the soil is linked to any leakage and seepage of contaminated substances via the groundwater. Assessment of impact Minor 8.8 Tangible assets This section deals with tangible assets, which in this context means a presentation of interests associated with agriculture, raw materials and afforestation. It focuses on potential conflicts with areas designated in the Municipal Plan as special agricultural, raw material or afforestation areas. These topics are illustrated on map 1.4: Tangible assets Environmental status and objectives Agriculture The Municipal Plan emphasises that farmland is a limited resource that must be protected by keeping the permanent use of farmland for non-agricultural purposes to a minimum and by maintaining appropriate production conditions so it is possible to plan production in the long term with respect for nature conservation and environmental interests. Special agricultural area The main use of special agricultural areas is agricultural production. General farming operations can usually take place without restrictions, subject to respect for the environmental rules for agriculture, livestock rearing etc. Through its planning and administration, the Municipal Executive Board aims to ensure that the use of farmland for non-agricultural purposes is kept to a minimum. In urban development, protected monuments, large non-agricultural facilities etc. must take the greatest possible account of the agricultural interests /36/. Most of the site is designated as a special agricultural area, except for the parts that are designated as areas of special natural interest, afforestation areas and protected forest areas, and smaller areas around buildings and the top of Bavnebanke.

83 77 of 234 Raw materials The site does not contain any raw material extraction areas. The topic is therefore not addressed further. Afforestation areas No forest wanted Areas where forest planting is not wanted are areas containing natural and landscape assets, geological features or historical remains that are incompatible with afforestation. No forests can be established within these areas. Within the site, no forest is wanted along the coast, at Louisenlund and around Ibskirke. Forest wanted Within the forest planting areas, Planning Act administration must take account of forest planting interests. Within the site, afforestation is wanted around the existing wooded areas, including Lyrsby forest in the south-western part of the site Assessment of environmental impact Agriculture The establishment of a repository in the area may conflict with the designation as an agricultural area of special value. The Municipal Plan requires that agricultural interests be taken into account as far as possible when establishing large facilities not linked to agricultural production. This must therefore be taken into account in the detailed project design for a possible future repository. The impact is not considered to be significant in relation to the overall municipal planning, as the facility is expected to occupy an area of approx. 150 x 150 metres. Raw materials No conflict. Afforestation The plan could potentially conflict with the designation of areas where forests are not wanted, in that part of the purpose of the designation is to safeguard the landscape assets that could be affected by the establishment of a facility of this type. The plan may conflict with designations of areas where forests are wanted, if a future facility is placed within the afforestation areas in the south-western part of the site. Repository types The conflicts are independent on the choice of repository type.

84 78 of 234 Table 8-13 Summary impact assessment. Environmental aspects - Tangible assets Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Agriculture Yes No Because most of the site is designated as an agricultural area of special value, a facility will very probably be placed within this designated area. Raw materials No - None Assessment of impact Minor A relatively small area will be used for the repository and, on this basis, the direct impact on agricultural interests is considered to be insignificant (see section on indirect effects on agriculture). Afforestation Yes Yes This conflict is considered to be insignificant and can be avoided by the choice of final location. None if the repository is located outside the afforestation areas. Minor if the repository is located inside afforestation areas. 8.9 Cultural heritage This section presents cultural and historical assets in the form of designated cultural environments, church surroundings and cultural heritage sites, on the assumption that the plan will not affect protected ancient sites and associated ancient monument protection lines; cf. plan guideline no 8. Cultural heritage. These topics are illustrated on map 1.5: Cultural heritage. Within the site, as well as the already registered protected ancient sites and monuments, there are also rock carvings/petroglyphs registered by Bornholm Museum that have not yet been listed for conservation. Most forests in the area also contain traces of ancient field boundaries, which are also protected. It is assumed that these assets will be examined more closely in a later EIA study, and that the museum will be contacted with a view to more detailed investigations on the actual site Environmental status and objectives Cultural environment The Municipal Plan contains guidelines for conserving the cultural and historical assets, including the fact that especially valuable cultural environments should be registered and marked out and that conservation measures should be taken. Special cultural environments are marked out, within which the historical assets should be preserved as far as possible. Building, construction and other activities likely to significantly reduce the experience or quality of the historical assets will be prohibited where the law allows. There are a number of defined cultural environments within the site: Bølshavn and the coastline towards Helligkvinde Around Saint Margaret s chapel on Maglegårdsvej A large area around Lyrsby forest and Louisenlund A large area bordering Joboland to the north of Ibskirke (St Ib s church in Svaneke) and stretching down to the coast between Årsdale and Svaneke

85 79 of 234 Church surroundings There are no designated church surroundings within the site, but there is a church building line around Ibskirke. Cultural heritage sites A cultural heritage site is an area of historical interest with hidden ancient sites and monuments. Cultural heritage sites may be of national or regional importance, and indicate that there are significant ancient sites in the relevant area. Cultural heritage sites are not in themselves protected, but they may contain protected ancient monuments. The areas are designated by the Danish Agency for Culture. The area includes cultural heritage sites around Maglegård and Lyrsby forests and Louisenlund and a small part of a larger cultural heritage site to the north of Joboland Assessment of environmental impact Cultural environments The plan allows for a facility to be located within one of the designated cultural environments. The extent of the impact on the cultural environment will depend on the specific project, including the choice of repository type and the final location of the facility. Church surroundings There is no impact on designated church surroundings, and it is assumed that the church building line around Ibskirke will be taken into account in fixing the location of the facility; cf. plan guideline no 9 Building and protection lines. Cultural heritage sites Within cultural heritage sites, any new buildings and facilities must be placed in a position that does not damage archaeologically sensitive remains from prehistoric and medieval times. They must also comply with Section 27(2) of the Museums Act: If traces of ancient relics or monuments are found during construction work, agriculture and forestry activities, the work must be suspended to the extent that it affects the ancient relic or monument. The Minister for Culture or the nearest cultural heritage museum owned or subsidised by the state shall immediately be notified of the ancient relic or monument. Within the cultural heritage sites, there is a high probability of coming across items of historical value, but it is considered that the impact of the plan on cultural heritage sites, and hence on new finds, will not be significant. This is due both to the limited area needed and to the fact that there will be constant supervision of the construction work; see provisions of the Museums Act. Repository types A near-surface facility will generally have a greater visual impact on the surrounding landscape and hence on the cultural environment. Other potential impacts are considered to be similar for any type of repository. Table 8-14 Summary impact assessment. Environmental aspects - Cultural heritage Cultural environments Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Yes Yes The site contains a number of cultural environments. The impact can be avoided by the choice of final location. Assessment of impact None if the repository is located outside the designated areas.

86 80 of 234 Environmental aspects - Cultural heritage Is there a risk of impact? Can the impact be prevented or reduced simply by the choice of location within the planned site? Comments Assessment of impact Minor to moderate if the repository is located inside the designated areas. Church surroundings Cultural heritage sites No/Yes Yes There is no impact on designated church surroundings, but there is a church building line around Ibskirke that may be affected. Yes Yes The area includes cultural heritage sites around Maglegård and Lyrsby forests and Louisenlund and a small part of a larger cultural heritage site to the north of Joboland. None if the repository is located outside the church building line. Moderate if the repository is located inside the church building line. None if the repository is located outside the cultural heritage sites. Moderate if the repository is located inside the cultural heritage sites Cumulative effects Cumulative effects are assessed by viewing the plan in conjunction with other plans or programmes, including previous, current and planned activities. Relevant plans and programmes may cover the same subject-matter, the same geographical area or a neighbouring area. The aim is to ensure that the plan is consistent with other relevant plans and programmes and to assess whether there is any risk of cumulative effects. As described in the preceding sections on the individual environmental aspects, potential conflicts have been identified on Bornholm with designated areas of special natural interest, cultural environments and afforestation areas. The planned site borders the international Natura 2000 conservation zones of Gyldenså and Almindingen, Ølene and Paradisbakkerne. The guidelines to the plan should ensure that any future facility does not carry the risk of significant impact on Natura 2000 areas. No higher-level plans or programmes have been identified within the site that might have an increased impact on the environment in combination with this plan Summary assessment The plan provides for the placement of a facility that may impact the environment in a number of ways, some of which are general effects regardless of the choice of location, as outlined in section 4.2. Implementing the plan on Bornholm could result in impacts that depend on local factors and need to be taken into account in a possible later planning and project design phase. Of these, the most significant are considered to be linked to the following factors:

87 81 of 234 The planned site borders on two Natura 2000 areas which must be given special attention in any project design phase. Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism (including the nearby Joboland ), food production and the social structure in terms of people leaving the area. There is a potential conflict linked to leakage. The geographical extent of the conflict is hard to predict because of limited knowledge of fracture systems in the bedrock and the resulting uncertainty surrounding details of the flow of groundwater. The risk of impact is greatest if a near-surface repository extending down to a depth of 30 metres is chosen. These matters need to be examined more closely in a future EIA study. Half of the site is within the designated coastal zone.

88 82 of RØDBYHAVN The planned site at Rødbyhavn is situated to the east of Rødby. The site covers an area of approx. 20 km 2. The general background to the work on a plan to establish a final repository can be found in section 2, the planning guidelines are in section 3, while the methods used to analyse and assess the degree of impact are described in section 5. Figure 9-1 Outline map Rødbyhavn. 9.1 Planning conditions This section presents the overall planning framework and strategies for the site in the form of Lolland municipality s Municipal Plan and planning strategy. The Lolland Municipal Plan was drawn up on the basis of: The plan strategy, The current municipal plans from the seven former municipalities The Regional Plan 2005 for Storstrøm county Municipal Plan The Municipal Plan is the summary high-level plan to enable citizens, businesses, interest groups etc. to understand the overall goals and guidelines for the development of the municipality, both in the towns and in the countryside. The Municipal Plan is in two parts. The first part (report 1) contains the main structure of the plan, with guidelines, figures and an environmental impact assessment. The main structure sets out the overall goals for development within the individual sectors, for the whole municipality and for the individual areas.

89 83 of 234 The second part (report 2) contains the framework for local planning. The framework describes the City Council s expectations for the local plans to be drawn up for the individual areas within the municipality. 9.2 Biodiversity This section focuses on biodiversity, which in this context includes a description and assessment of the impact on Natura 2000, Section 3 of the Danish Nature Protection Act, wildlife corridors and national parks or nature parks. It is assumed that the future facility will not be located in a Natura 2000 area, and that the plan will not have a significant impact on adjacent Natura 2000 areas; cf. plan guidelines. These topics are illustrated on map 2.1: Biodiversity. It is assumed that the local natural assets will be examined more closely in a later EIA study, which will include more detailed investigations of the specific site in the form of e.g. field studies Environmental status and objectives Lolland has drawn up a nature policy based partly on the work of the Green Council (Grønt Råd) on nature and conservation policy. The nature policy that has been adopted is consistent with Lolland municipality s plan strategy, which aims for the municipality to work for more and richer nature all over Lolland municipality. That means both big and small-scale nature. The nature policy includes general goals and options for improving nature and biodiversity /42/. In brief, the overall purpose of the nature policy is to: Create space for both the diverse and common species Protect, conserve and improve the existing natural environment Increase natural areas, e.g. via afforestation Make space for a dynamic natural world Work for small-scale nature and promote biodiversity Enhance health and wellbeing Areas in and around towns should allow people to experience nature and provide options for physical exercise Natura 2000 The planned site does not contain any Natura 2000 areas, but the following international conservation area is immediately to the south: The Smålandsfarvandet sea area north of Lolland, Guldborgsund, Bøtø Nor and Hyllekrog-Rødsand; Natura 2000 area no 173, habitat area H152, bird protection areas F82, F83, F85, F86. The site is a very large coastal and marine area with a long, flat, indented coastline. It covers a significant proportion of Smålandsfarvandet to the north of Lolland and Falster, which is connected via Guldborgsund with the waters down to the Rødsand and Hyllekrogtangen sandbanks towards the south. There are many islands and islets in the area; however, only the coastlines of the largest islands, Fejø and Femø, in Smålandsfarvandet are included. The shallow marine area is mostly characterised by a sandy bottom and scattered rocks; otherwise the marine areas are very varied. The area is designated for the protection of a large number of habitats and species, particularly coastal habitats, sea birds and seals. The area is especially sensitive to nutrient run-off, intensive pumping that can cause breeding grounds to dry out, disturbance from traffic, overgrowth, intensive forestry, invasive species etc. /43/. Section 3 protected nature Under Section 3 of the Nature Protection Act, it is prohibited to interfere with protected natural habitats in a way that could cause a change to the status of these areas. However, the municipalities may derogate from this provision /11/, often on condition of establishing some natural replacement.

90 84 of 234 Natural habitats covered by Section 3 of the Nature Protection Act are: Lakes and ponds of at least 100 m 2. Marshland, meadows, heaths, dry grassland, coastal meadows and tidal marshes which individually or together cover an area of at least 2,500 m 2. Marshes under 2,500 m 2 are also protected if they are next to protected streams or lakes. Most streams and rivers are also protected via a special Section 3 designation. Lakes include both natural and wholly or partly man-made pools, basins and dams. The site contains few protected areas of natural interest (cf. Section 3 of the Nature Protection Act) in the form of lakes and ponds and streams. There are is a single protected meadow within the site. Low-lying areas Low-lying areas are artificially drained areas that used to be meadows, marshland, shallow lakes and fjords. Lolland municipality has an objective to ensure that essential natural and culturalhistorical assets in low-lying areas are not lost. When planning and administering planning law for buildings and facilities that affect low-lying areas, future rises in water levels, intensity of rain and drainage must be assessed, along with the possibility of future restoration. If it is not possible to avoid locating buildings or facilities in low-lying areas, the low-lying area must be taken into account in the design of the building or facility, e.g. by adjustments to the terrain. The southern part of the site contains designated low-lying areas. There are no designated potential wetland areas within or near the planned site. Ecological corridors The Municipal Plan includes an objective that the conditions for animal and plant species to spread between Agricultural areas of special natural and landscape interest should be improved by means of ecological corridors. The natural component of the area in the ecological corridors should be increased. Ecological corridors are linear designated areas that follow river valleys and other topographical - features. The ecological corridors are meant to ensure that populations of plants and animals can spread across the landscape and exchange sufficient numbers of individuals and genes to maintain healthy development. The eastern part of the area is crossed by an ecological corridor along Bjergnæsvej. The corridor passes through the forest area at Lungholm towards the coastal nature areas. Beach protection The site does not touch the beach protection belt. Protected forest The vast majority of private woods and all public woodland in Denmark have the status of protected forest (fredskov) and are safeguarded by the provisions of the Forests Act. The area contains two small areas of protected forest next to the railway in the south-western part of the planned site. The north-eastern part of the site contains a large area of protected forest by Lungholm. National parks There are no national parks within or in the immediate vicinity of the planned site.

91 85 of 234 Nature parks Lolland municipality s nature policy includes designations of nature parks and areas that could be designated as such in the longer term. Nature parks are intended to safeguard and improve natural, cultural and landscape assets, and provide opportunities for education and outdoor life. Nature parks differ from national parks in that they are designated locally and are not covered by any specific legislation /42/. An area around Hyllekrog, to the east of the planned site, is described in Lolland municipality s nature policy as an area with the potential for later designation as a nature park. The potential nature park will be able to act as a base for outdoor pursuits and generally support and promote opportunities for outdoor activity communication will be a major concern for these nature parks and their guides Assessment of environmental impact It is impossible to define criteria for protecting the environment against radiation as there are no statistics covering the health impact of ionising radiation on animals and plants, as there are for people. Internationally, projects have been launched to determine the effect of ionising radiation on nature and, on this basis, to use reference animals and plants as a means of establishing criteria and producing subsequent safety analyses. The progress of these projects will be monitored and taken account of as far as possible in defining environmental protection criteria when the safety analyses are carried out in a later EIA phase /15/. Human beings are generally considered to be the organism that is most vulnerable to ionising radiation. Therefore, once criteria have been established to safeguard people, we may assume that animals and plants will be sufficiently protected against radiation. Exceptions to this assumption will mainly apply to a small population of a species in a restricted area around the repository/15/. The environmental protection criteria applicable to a given repository will be drawn up in conjunction with the mandatory EIA studies to be carried out for two selected sites if it is decided to proceed further with the repository plan. In this connection, detailed field studies will be carried out as part of the basis both for assessing potential effects and for defining environmental protection criteria. This will ensure that local conditions are taken into account in the form of sitespecific assessments concerned with protecting the environment. This section presents the general conflicts with nature conservation interests. Natura 2000 The guidelines to the plan for a repository explain that any future facility must not have any significant effect on adjacent Natura 2000 areas (guideline no 7, Nature). The future planning and project design must therefore ensure that a facility can comply with these provisions. This will be determined by a materiality assessment, which will consider whether there is a risk of significant impact on the Natura 2000 area. This type of assessment is usually carried out in the initial phases of an EIA study. If it is considered that there is a risk of significant impact, an impact assessment will be carried out. The purpose of this is to examine the potential impact in relation to the conservation goals for the area, and to incorporate mitigation measures into the project in order to avert any serious impact. Section 3 protected nature There is a risk of impact on Section 3 protected areas where the facility itself or the access roads are positioned in direct conflict with the protected area. As the gross area is relatively large, there is every chance of placing the facility so that it does not affect protected areas. This consideration should therefore be included in subsequent planning and project design. No guidelines have been included in the plan to guard against conflicts with Section 3 protected

92 86 of 234 areas, as other factors determining the ideal positioning may result in conflicts with Section 3 protected areas. Low-lying areas There are designated low-lying areas to the south of the site. It is assumed that the facility will be located so that it does not conflict with these areas. Ecological corridors The ecological corridor in the eastern part along Bjergnæsvej may be affected by the plan, depending on the final location of the facility. Plan guideline no 7, Nature, states that the positioning of the facility should take maximum account of interconnected designated nature areas, including ecological corridors. Beach protection No impact. Protected forest The protected forest areas may be affected, depending on the eventual positioning of the repository. National parks There is no impact. Nature parks The area around Hyllekrog is designated as a potential nature park. Whether there is any impact on the area depends on the actual positioning of a future repository and the final boundaries of a future nature park. Repository types The three types of repository take up the same area, so will result in the same risk of impact to nature arising from any closing off of land and hence of a potential impact on Section 3 areas, ecological corridors and protected forests. As mentioned above, it is assumed that Natura 2000 areas, low-lying areas and the beach protection belt will not be affected whatever the choice of repository. Table 9-1 Summary impact assessment. Environmental aspects Biodiversity Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Natura 2000 No - The guidelines to the plan state that a facility cannot be established under this plan if there is a risk of significant impact on Natura 2000 areas. The concrete assessment of whether the facility can meet this requirement will be made in a later EIA phase, when the location, repository type etc. are known. Section 3 protected nature Yes Yes Conflict with protected areas may be avoided by the choice of final location for the facility. Assessment of impact None None or minor The degree of impact depends on the positioning of the repository.

93 87 of 234 Environmental aspects Biodiversity Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Low-lying areas No - The facility must not be located in areas designated as low-lying areas as there is a high probability that the water level could rise. Ecological corridors Yes Yes The ecological corridor in the eastern part of the planned site along Bjergnæsvej may be affected by the plan. Assessment of impact None None or minor Plan guideline no 7, Nature, states that, if possible, the location of the facility should take into account identified interconnected nature areas, wildlife corridors and the like, as identified in the respective municipal plans. The degree of impact depends on the eventual positioning of the repository. Beach protection No - Not applicable None Protected forest Yes Yes There is a risk of impact on protected forest areas within the site. National parks No - Not applicable. None None or minor The degree of impact depends on the positioning of the repository. Nature parks Yes Yes The area around Hyllekrog is designated as a potential nature park. None or minor 9.3 Population and health This section describes the location of the planned area in relation to built-up areas, the number of inhabitants, commercial activity, tourism and recreation. It is mainly based on information from Statistics Denmark and the Municipal Plan. This section then describes the potential impact on the population in terms of health risks and indirect environmental effects, including the risk of reduced revenue, relocation etc. The assessment of the impact is based on available information from e.g. descriptions of transport and radiation in the feasibility studies. It is assumed (cf. plan guidelines) that the facility will be designed to be able at any time to demonstrate compliance with the specified dose constraintdose constraints when in operation and after closure for those periods and for potential incidents (accident scenarios). Documentation of this will be provided in the form of safety assessments for the facility and its use. The assessment of the indirect environmental impact on the population and industry identifies potential effects based on an analysis of responses to consultation and comments from public meetings focusing on e.g. people s concerns about the effects of implementing the plan.

94 88 of Environmental status and objectives Population Rødbyhavn is a port situated to the west of the planned site, while Rødby is to the north-west. The western part of the site is crossed by the railway. The rest of the site is on predominantly agricultural land. The breakdown and number of inhabitants and the distance to settlements in and around the Rødbyhavn area are shown below. Table 9-2 Distance from major settlements. Distance from settlements: Rødbyhavn: approx. 0.5 km from the site Rødby: approx. 1.5 km from the site Errindlev: approx. 0.6 km from the site Holeby: approx. 4 km. from the site The population figures for the larger towns on Lolland can be seen in Table 9-3 (as of 2011). Table 9-3 Breakdown and number of inhabitants on Lolland (2011). The breakdown and number of inhabitants is as follows: Rødbyhavn: 1,814 inhabitants (2011) Rødby: 2,185 inhabitants (2011) Errindlev: 309 inhabitants (2011) Holeby: 1,558 inhabitants (2011) Industry The economic structure in Lolland municipality is characterised by many small industrial and handicraft businesses with fewer than 10 employees, a few larger enterprises and a dominant agricultural sector with increasing farm sizes. Agriculture supports and is supported by a large number of business, of which Nordic Sugar A/S in Nakskov and Maribo Seed in Holeby are among the largest. 86 % of the land in Lolland municipality is farmed, and 25 % of the jobs are in agriculture. Lolland municipality is the fifth-largest tourist destination in the region in terms of the number of people employed. Tourism employs over 1,000 full-time staff in the municipality every year, accounting for 5.4 % of all employment.

95 89 of 234 Table 9-4 Breakdown of employment in Lolland municipality within selected industries related to tourism and leisure, agriculture, fishing and food production, as of The total number of people employed in Lolland municipality is 17,133 (Statistics Denmark 2013). Tourism The Municipal Plan contains objectives for tourism and leisure, including visitor centres and major outdoor facilities, areas with summer cottages, allotment houses, hotels and guest houses, camp sites, marinas, diving boards and landing stages and areas for outdoor pursuits. Tourism is a major business area for Lolland municipality as it can contribute to a rise in living standards in the rural areas and on the islands and to economic development in the municipality as a whole. Lolland municipality has a good basis for developing tourism, as the fifth-largest tourist destination in the whole of Region Zealand, and is easily the highest ranked in the whole region in terms of commercial overnight stays /40/. Lolland municipality has many permanent attractions to offer to tourists, apart from the two major attractions of Lalandia (to the west of the planned site) and Knuthenborg Safari Park, as can be seen from Region Zealand s list of attractions, Table 9-5. The existing hotels and holiday centres are visited by around 790,000 guests each year and account for 53 % of all overnight stays in Lolland municipality. The holiday centres and hotels provide significant job opportunities for the local inhabitants, particularly the Lalandia holiday centre with around 700,000 overnight stays and 350 staff. Table 9-5 Visitor centres and attractions in Lolland municipality by numbers of visitors, with position in Region Zealand. Attraction Position in Region Zealand No of visitors 2008 Lalandia 1 740,511 Knuthenborg Safari Park 4 238,000 Reventlow Park 23 32,000 Open-air museum 38 20,857 Maribo cathedral 41 20,000 Grøn Verden (Green World) 44 15,559 Maribo-Bandholm steam railway 48 14,262 U-boat 359 in Nakskov 50 12,678 Peter Hansen gardens 68 7,800 Reventlow Museum 71 5,502 Lolland-Falster county museum 75 4,755

96 90 of 234 Attraction Position in Region Zealand No of visitors 2008 Maribo Jazz 78 4,000 Påstbåden Vestra 82 3,329 Frederiksdal Nature Centre 85 2,900 Danish Sugar Museum 89 2,310 Polish Barracks 98 1,550 Femø Jazz Festival 109 1,200 Nakskov Maritime Museum Det Gamle Trykkeri (the old printworks) The Round Lolland bike ride Den Gamle Smedje (the old forge) The Historic Workshop The Municipal Plan states that 41,000 visitors in 2008 were people on sailing trips, equivalent to 2.3 % of all tourists in Lolland municipality. Development in sailing tourism is a golden opportunity for Lolland municipality, which is surrounded by sea and straits and has 19 harbours. The harbours and sailing also have a knock-on effect on tourism as a whole. Recreational areas Nature policy As well as targets for nature in itself, the municipality s nature policy also sets objectives for the interests associated with the experience and use of nature. The nature policy lays particular stress on direct access to nature for the population wherever they live, and the importance of nearby nature for outdoor life and public health. The nature policy is also discussed in section 9.2. Visitor areas and major outdoor facilities The Municipal Plan contains guidelines for visitor centres, which may provide information on specific topics and may be destinations in themselves in connection with education, tourism, holidays and leisure. There are also guidelines for large outdoor facilities such as golf courses, motor racing circuits and shooting ranges. There are no designated visitor areas or outdoor facilities within the site. Approx. 1 km to the west of the site is Lalandia, which, as we have seen, is the most-visited attraction in Region Zealand. Immediately to the south-west of the site is Rødby go-kart track, at Gammel Badevej 9, 4970 Rødbyhavn. Areas of summer cottages In 2009, there were approx. 3,700 summer cottages in Lolland municipality. To the east of the planned site, by the coast, is the Østersøbadet area of summer cottages. Marinas To the west of the planned site is Rødbyhavn, which has capacity for 35 berths. Outdoor areas and trails The Municipal Plan includes designations of outdoor areas, some of them areas of natural and landscape interest, some robust enough for recreational use. The planned site borders on a coastal outdoor area, which includes the Østersøbadet area of summer cottages. A regional cycle route runs along the coast, and there is also a proposal for a footpath along this route. There are plans to establish a regional network of footpaths, which will cross the planned site in an east-west direction. Lolland-Falster county is also working on plans to exploit the recreational assets in the area, including a pilgrimage route and cycle paths.

97 91 of Assessment of environmental impact The assessment of the impact on the population covers health (related to transport, risk of accidents and radiation, safety and security of the facility itself), and socio-economic factors, including the population, commercial interests, tourism and recreational activities. Health Radiation protection The health impact of radiation from the facility itself and from accidents is described in section 4.2, as the same requirements apply to safety assessments and official approval regardless of the choice of site. Transport Based on the feasibility study, we conclude that both road and sea transport may be considered. The radiation doses estimated for transport of Danish radioactive waste from Risø to a future repository in Denmark are calculated on the basis of the greatest possible distance to any repository. The estimated doses in the feasibility study are therefore upper limits, and doses from shorter transport routes will be proportionally lower. The study shows that the risk associated with road and sea transport does not restrict the future section of a location for a repository in Denmark, and that the transport can be handled so that the dose is well below the national limits. The distance from the site near Rødby to Risø is similar to that from Kertinge Mark. Changes in distance have no effect on doses in the event of an accident. The likelihood of an accident is dependent on things like the quality of the road and the volume of traffic, and is also proportional to the distance. Compared to the zero alternative, the radiation dose is greater in the short term as a natural consequence of the fact that, in the zero alternative, the waste will not be processed as much, or transported from the location. In the longer term, it will be necessary to process and possibly transport the waste under the zero alternative too, as Risø does not have the status of a final repository. Socio-economic factors Apart from the general issues mentioned in section 4.2, the stakeholders have drawn attention to a number of local matters that should be given special consideration in the choice of the two final locations. Table 9-6 summarises the major concerns raised by stakeholders on Lolland. This is used as part of the background to the description of the potential impact on the population and the socio-economic factors, and also forms the basis for suggested preventive measures (section 15.2). Table 9-6 Summary of the major concerns raised by stakeholders on Lolland*. Subject Nature Landscape Description At Rødbyhavn on Lolland, the stakeholders note especially that there are rare species of insects, plants and frogs in the area that need to be protected. They express concern about the effect on these species if an unforeseen event should occur in connection with a future repository. The stakeholders express concern that a repository could disfigure Rødby and Rødbyhavn and affect the special qualities of the area. The stakeholders say that the area has been largely unspoilt since the 16th century and shares some of the attributes of the Wadden Sea. The area is therefore a destination for cultural tourism, bird enthusiasts and botanists, and is used for retreats; there are also cycle paths and pilgrimage routes through the area. Work is in hand to establish a pilgrims centre in Maribo, and it is planned to develop the pilgrimage routes.

98 92 of 234 Subject Fehmarn Lalandia Rising sea levels and breached dykes Area of summer cottages Description The stakeholders also note that part of the designated site is earmarked for the construction of the Fehmarn Belt Fixed Link (a tunnel to Germany) in the coming decades. It is therefore important to ensure that the project does not hinder plans to establish a substitute nature area in connection with the tunnel project. Special attention thus needs to be given to the interplay with this project. In relation to this, Lalandia also has expansion plans in connection with the establishment of the new lagoon area resulting from the Fehmarn project. According to the stakeholders, the establishment of a repository for radioactive waste could have a bearing on tourism in general and this project in particular. So it is important for the project to take account of this. The stakeholders can usefully be involved in the process, to avert the negative consequences. Because the site is close to the sea, the stakeholders point to the risk of a dyke being breached and sea water flooding the area. Studies in connection with the Fehmarn project have also shown that there was a period around 4,000 years ago when sea levels in the area rose sharply, which probably cannot be attributed to meltwater from Ice Age glaciers and so could possibly happen again. A specific repository solution therefore needs to be able to handle such events. The stakeholders also point out that the Hyltofte Østersøbad area of summer cottages is only accessible through the designated site. Any actual project will therefore have to maintain access to the summer cottages. *This description is extracted from minutes of the public meeting held in Rødby and from responses to consultation on the scoping report. Summary The questions relating to the establishment of the facility itself, and the practical problems that may arise as a consequence, are not dealt with in depth in this Strategic Environmental Assessment because of the level of detail in the plan. The project-specific issues with questionmarks against them will be addressed in a later phase, when risk assessments and radiation protection work will be carried out in conjunction with the subsequent work by the authorities once there is an actual project. The following subjects are addressed at a high level in other sections of the SEA report: Natural conditions are discussed in section 9.2. The risk of rising sea levels is described in section 9.5 and will be examined in more detail in connection with the project design for a facility, in that the facility itself will be climate-proofed; see plan guidelines. The effects of the landscape factors are discussed in general in section 9.4, but an actual visual assessment will have to await a later EIA phase. The reserved area for the Fehmarn Belt Fixed Link is described in section 9.8. The plan is not considered to be an obstacle to plans for recreational footpaths etc., but it would be sensible to involve the stakeholders if a concrete project should be set up. If we look at the comments from stakeholders of both a general and a local nature, we see that they are marked by a high degree of concern. These concerns are directed at a broad and diffuse set of risks, which indicate a lack of knowledge of the real risks involved in implementing the plan and of the measures that have been and will be taken to minimise these risks. The comments also show that the stakeholders do not have sufficient knowledge of the process to be followed in the future, leading to widespread uncertainty and mistrust. The stakeholders do not feel convinced that the future process will adequately examine and address the perceived risks and involve the stakeholders, to ensure that local interests are safeguarded. For these reasons, the analysis shows that the plan to establish a repository has received a very negative response from the stakeholders. This negative attitude, insecurity and mistrust of the plan and the projected process create the ideal conditions for a number of negative social effects to become reality. In this situation, it is not impossible that a repository could have indirect effects in the form of people moving in and out, falling land and property prices, the impact on tourism (including the nearby Lalandia and recreational activities in general), and the physical wellbeing of the inhabitants etc., purely because of insecurity and mistrust. There could also be cumulative effects, as the plan could help

99 93 of 234 to speed the decrease in population that we are already seeing on Lolland today. It is therefore crucial to the social effects of the plan that the insecurity and mistrust should be reduced. Overall, there may be a risk of impact on socio-economic factors, including tourism and the food industry. The plan may thus conflict with the overall strategies and visions that exist for Lolland, as described e.g. in Lolland municipality s Municipal Plan. Table 9-7 Summary impact assessment. Environmental aspects Population Health Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Radiation protection Securing the facility Yes Yes The impact in the immediate vicinity will depend on the final location. Yes Yes A vulnerability assessment should cover different scenarios and their consequences. These scenarios should be covered by security and contingency plans designed to assure the greatest possible, reasonably attainable reduction of risks and potential doses. Minor (below the dose constraintdose constraints) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraintdose constraint. As with the category of transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the dose constraintdose constraint) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraintdose constraint. As with the categories of radiation protection and transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses.

100 94 of 234 Environmental aspects Population Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Transport Yes Yes The impact in the immediate vicinity will depend on the final location. Noise, heavy traffic and emissions may have an impact in connection with transport within the planned area. Socioeconomic conditions Yes Yes/No. In recreational areas etc. the impact may be dependent on the final location, but the general concern about the impact on the population and industry is considered to be independent of the final location and in many cases people expect an impact beyond the planned site itself. Implementing the plan may cause indirect effects on the population and socio-economic conditions. The stakeholders highlight a number of issues that cannot be addressed at this introductory stage of the planning process, but these issues will be examined more closely in an EIA phase and in conjunction with safety analyses and official approvals. Assessment of impact Minor (below the limits for exposure to radiation). Estimated doses for transport to the planned site are well below the dosage thresholds. There will be a need to plan transport routes, times etc. to achieve a reduction of risks and potential doses. Moderate to significant The impact is judged to be of moderate to significant importance because of the high level of concern and the uncertainty expressed among the stakeholders. This should therefore receive close attention in the later phases. 9.4 Landscape and geology This section presents geographical and geological conditions within the planned site, which here encompass a high-level description of the landscape and any designated areas and a description of the geological conditions based on the feasibility studies, with any designated features. These topics are illustrated on map 2.2: Landscape and geology. The assessment of the impact on the landscape is based solely on whether there is a risk of impact on valuable landscapes and the designated coastal zone. It is assumed that the direct impact on the landscape and visual factors will be determined in a later EIA study, where landscape analyses, visualisations etc. can be based on the choice of a specific location and a concrete project proposal. The purpose of examining the geological conditions is to assess the degree of uncertainty as to the ability of the geological conditions to act as a physical barrier around a possible repository. It is assumed that the local geological conditions will be examined in more detail in a later EIA study Environmental status and objectives Landscape Landscape description Most of the area is a flat ground moraine landscape, covered to the south with a marine foreland. A small area to the south-west is reclaimed land. The general impression of the landscape is a very flat terrain without much variation. Most of the area is between 0 m and 4 m above sea level, locally down to 0.5 m below. There are no lakes or watercourses, but there are drainage ditches in the eastern and south-western parts. A dyke that is more than 4 metres high runs along the south coast, protecting the land from flooding from the sea.

101 95 of 234 Designated coastal zone The designated coastal zone is defined in the Planning Act and is approx. 3 km wide. The rule is that the designated coastal zone must be kept free from buildings and facilities that are not dependent on proximity to the coast. A small area of the south-western part of the planned site is covered by the designated coastal zone. Planning Act: Section 5b. The following shall apply to planning in the designated coastal zone: 1) It is prohibited to transfer land to an urban zone or to conduct planning for development in a rural zone unless there is a specific planning-related or functional justification for location near the coast. The Municipal Plan contains guidelines for preserving and protecting landscape assets, large undisturbed landscapes, protected zones and areas of geological interest. The valuable landscapes in Lolland municipality must be conserved and enhanced, and any changes in the countryside must respect the character and quality associated with these landscapes. Landscape assets worthy of conservation are a subset of cultural or natural landscapes. Any designation of the landscapes of special value will stress the importance of the individual site for the way the relevant area is perceived. At the same time, consideration will be given to whether the area also has a major geological, cultural-historical or biological content. The Municipal Plan does not yet include any designated landscapes of special value, but the landscape values in the countryside should generally be taken into account when planning new facilities. Large undisturbed landscapes are defined as areas of at least 100 km² that are unaffected by major technical facilities fulfilling national or regional functions. The north-eastern part of the planned site lies within a designated large undisturbed landscape covering a large area in the eastern part of the municipality. Geology A detailed discussion of the geological conditions can be found in GEUS report no 2/2/. Under Ice Age deposits of varying thickness there are continuous, undisturbed layers of Paleocene clay up to 80 m thick. Under the Paleocene clay strata there is white chalk. The following description is a summary of the geological conditions described in the local area study. Deposits and soil types The deposits under the Ice Age deposits in the southern part of Lolland are from the Paleocene epoch. The deposits are known from raw material drilling in and around the area and from an exploratory excavation in the area. Two bore holes within the area, drilled in connection with feasibility studies for the Fehmarn Belt Fixed Link, extend down into the Holmehus formation. Two other bore holes just outside the site close to the south coast of Lolland show that Eocene deposits from the Røsnæs Clay and Ølst formations are resting on deposits from the Holmehus formation. In connection with raw material exploration to find bentonite, a core sample was taken in the western part of the area, and an analysis of the cores and bio-stratigraphic dating show that there is a sequence of strata from the late Paleocene epoch that includes the two formations. In the cores, the oldest strata are of Maastrichtian white chalk. These are overlaid with m of dark grey or grey, silty, fine-grained homogenous clay from the Æbelø formation and m of very fine-grained green or brown clay from the Holmehus formation.

102 96 of 234 The Quaternary (Ice Age) deposits covering the Paleocene clay consist mainly of clayey till with a few areas of moraine sand. The deposits are generally between 5 and 40 m thick, but reach greater thicknesses in places. The known thicknesses in the central western area are m. To the south, the thickness of the Paleocene clayey till increases to m. To the far south by the coast, the clayey till is overlaid with post-glacial marine deposits. To the north by Hyltofte, the thickness of the Quaternary deposits increases to at least 52 m, part of it made up of meltwater sand and gravel. Mineralogy binding adsorption The geochemical conditions in the deposits have a bearing on how radioactive material will behave if it should leak out of a repository into the surrounding geological strata. Some general observations are given below, as the large number of radioactive components can behave differently in the surrounding deposits. A key element is that the radioactive material should be able to bind to the deposits. The uppermost layer consists of clayey till. This clay contains % particles in the clay fraction, and has a high chalk content of %. The clay fraction contains 2 % smectite minerals. The underlying Holmehus clay contains approx. 1 % fine sand and varying proportions between clay and silt of around 60%/40%. The mineralogical content is approx. 20 % quartz and % clay minerals. The average smectite content is %. Clay minerals, especially smectite, are particularly well-suited to binding radioactive material. This means that the clay deposits have the potential to bind the radioactive components /1/. Redox conditions The behaviour of the radionuclides in relation to the oxygen content in the strata and groundwater (redox conditions) will depend on the types of chemical compounds and chemical properties involved. The concentration of these components in the strata and the water, and their ph, also have a bearing on the processes that will occur. There is oxygen present in the uppermost layer of soil (the oxidised zone), and this may for example mean that some radioactive components can be made mobile and hence transported more easily. Conversely, the conditions in the oxygen-free (reduced) zone, for example, will help to bind and hold other radioactive components. Judging from the change of colour in the Quaternary clayey till, the oxidised zone appears to reach down to around 5 m below the surface in the area. That means that most of the Quaternary clayey till and the Paleocene Holmehus and Æbelø formations are in the reduced zone. Natural radioactive components in the deposits There are few known values for clayey till and Holmehus clay in the area. Assessment of geological conditions The geological conditions influence the impact of the repository on both surface water and groundwater. The geological conditions need to be consistent and stable within the site and they must contribute to the stability of the repository. The geological strata should help to isolate the waste from the surroundings by enclosing or underpinning the repository. The rocks should be low-permeable and help to bind the radioactive components from any discharge from a repository /15/. These issues are assessed in Table 9-8. The geological conditions are assessed only in relation to a repository placed in the pre-quaternary rocks; in this case, the Paleocene clays. If

103 97 of 234 the repository is located on Quaternary deposits, clayey till probably containing fractures and sand lenses will only partly isolate the waste from the surroundings. Table 9-8 Assessment of the geological conditions in terms of stability, low-permeable rocks and binding of radioactive components. Property Assessment Comments Consistent and stable geological conditions contribute to the stability of a repository. Yes The geological strata help to isolate the waste from its surroundings: Low-permeable rocks. The geological strata help to isolate the waste from its surroundings: Binding of radioactive components. Yes Yes The Paleocene rocks are uniform and undisturbed in the area. Geotechnical stability will be addressed in any specific project proposal. The Holmehus formation in particular is extremely low-permeable. The formation can be classed as bentonite, which is used to plug the bore holes, for example. The Paleocene rocks have a high content of clay minerals, including high levels of smectite. Clay minerals, especially smectite, are particularly wellsuited to binding radioactive material. This means that the Paleocene clay has the potential to bind the radioactive components. Areas of geological interest Areas of geological interest show the history of geological development from the Ice Age right up to the present, which can be read from the landscape and the strata in these areas. The areas of geological interest cover both national and regional geological interests, with individual locations that are characteristic of the municipality. National areas of geological interest (NGIs) National areas of geological interest (NGIs) are state-designated areas of exceptional value for the understanding of Denmark s geology as a whole. Some of the areas are unique in the world and are of international importance. The site contains no designated areas of geological interest, but immediately to the east of the site is a large designated area of geological value and a national area of geological interest situated between Hyllekrog and Rødsand. The foreland consists of spits and barriers that are only dry at low tide /45/. Summary In the southern part of the site there are thick, continuous layers of early Paleocene clay up to 80 m thick, which are undisturbed. The properties of the clay deposits are expected to be able to hold back any discharge of radioactive material from a repository. The overlying late Quaternary deposits consist mainly of clayey till between 5 and 40 m thick. Experience shows that clayey till contains fractures and sand lenses Assessment of environmental impact Landscape The integration of the facility into the landscape and its visual impact are not being addressed at this stage of the planning, but they will be included in a later EIA process when there is more knowledge of the location, the type of facility, materials and dimensions all crucial factors for the visual impact. It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location and the repository type have been decided. If the facility is located within the designated coastal zone, then before any future project can be implemented, the provisions of the Planning Act require a study to determine whether there is a specific planning-related or functional reason for the coastal location. There should also be a description of the visual impact, which will depend on the repository concept and design. If it is decided to choose a design to make the facility recognisable and visible, e.g. for safety reasons,

104 98 of 234 this will immediately make a greater visual impact than a repository concept that is more integrated into the landscape. The final assessment of the scale of the impact will be made as part of the EIA studies. Repository types It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location has been decided and there is a description of the repository type, dimensions, choice of materials and colours, planting, fencing etc. Geology The plan is not expected to affect the general geological conditions significantly, but the geological conditions have a major bearing on the suitability of the site for the establishment of a repository. The geological description will therefore be used as background material to any assessment of the impact ion groundwater and surface water. The national area of geological interest between Hyllekrog and Rødsand will not be affected by the plan. Repository types The potential impact on the geological features is expected to be similar for each of the three repository types, as the total surface area required will be the same whichever repository type is chosen. Table 9-9 Summary impact assessment. Environmental aspects Landscape and geology Designated areas Designated coastal zone Geological designations Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments No - There is no conflict with landscape designations. Yes Yes A small part of the planned site is inside the designated coastal zone. The facility can therefore be placed so there is no conflict with this. The choice of final location requires a large number of factors to be taken into consideration, so it is not possible at the present time to decide whether or not the facility should be located within the designated coastal zone. No - The areas of geological interest are outside the planned site. Assessment of impact None None if the repository is located outside the designated coastal zone. Moderate if the repository is located inside the designated coastal zone. A final assessment of the impact requires an actual project and visualisations to be produced in a future EIA phase. None

105 99 of Climate Climate change could affect the future repository because of the increased risk of extreme events. This section describes the future scenarios that are being examined in Denmark and abroad, to serve as a basis for assessing whether the planned site is expected to be significantly affected by changes in the climate. It is assumed that a future facility (see plan guidelines), via its design and placement in the landscape, will be adapted to any future climate change and thus less vulnerable to extreme events /2/ Environmental status and objectives Based on the latest Danish and European scenario analyses, the Danish Meteorological Institute (DMI) has described the expected future climate changes in Denmark out to The assessments are based on the scenarios used by the UN s International Panel on Climate Change (IPCC) /20/. The changes are expected to increase towards the year Considerations of climate change are relevant to the placing of the repository because of the risk of rising sea levels flooding the facility, which could lead to penetration by surface water and hence an increased risk of radioactive substances spreading into the environment. The DMI report suggests that Denmark will experience warmer and wetter weather in the future, with more extreme events such as longer periods of drought and heavier rainstorms, and temperature increases. It also projects a general rise in sea levels in the waters around Denmark /20/. More recent projections are now pointing to even greater rises in sea levels around Denmark, ranging from 80 ±60 cm to max. 150 cm by There may be further increases towards 2200, but estimates are extremely difficult and fraught with very great uncertainty/20/. Large parts of the planned site are between sea level and the 4 m contour, and the terrain is flat. In the far south, by Hyldtofte Fæland, the terrain is below sea level. Before the extensive dykebuilding in the 1870s, the Rødbyhavn area was exposed to storms and flooding because of the low-lying terrain combined with its geographical location facing the Baltic. After major floods in the 1870s, large-scale coastal defence work was done in the area, including the construction of the present dyke up to 4 m above mean sea level /2/ Assessment of environmental impact Rise in sea level In the event of a rise of max. 1.5 m in sea levels around Denmark (by 2100), it is hard to predict the effect of such an increase along the south coast of Lolland. Along the south coast there is a dyke rising to a minimum of +4.0 m. With the estimated maximum rise of 1.5 m, the area will still not be flooded in calm weather. In storm situations, however, this rise of 1.5 m needs to be increased to allow for a build-up effect and a wave height that could mean a total increase in sea level close to 4 m and possibly more. It is assumed that the height of the dyke will be increased in line with any rise in sea levels, and that the dyke will probably be raised for reasons of safety in connection with the future Fehmarn Belt Fixed Link to Germany /2/. Extreme events The 4 m high dyke should protect against flooding by sea water. There are no Danish examples where a major storm flood of sea water has contaminated coastal bore holes and groundwater reservoirs over an extended period. There are a few foreign studies of such situations, including the 2004 tsunami on the east coast of Sri Lanka. Studies of wells and groundwater reservoirs showed that the top 2.5 m of the groundwater reservoirs had returned to freshwater conditions 1 to 1½ years after the flooding. Based on model calculations, the saline floodwater is expected to be flushed out of the groundwater reservoirs down to a great depth. In this connection, we should mention the low salinity of the Baltic Sea /2/.

106 100 of 234 Saline groundwater In the coastal zone, where there is a direct run-off of groundwater into the sea, there will normally be a fresh groundwater zone on top of heavier saline groundwater, i.e. the saline groundwater will extend in a wedge shape under the fresh groundwater. If the groundwater flows directly to the coast, the interface to the saline water will be characterised by a gradual transition from one layer to the other. This is because the position of the boundary is not stable but changes with e.g. variations in sea level (tides) and in the flow of groundwater. The 4 m high dyke should protect against flooding by sea water. Within the dyke on the landward side, there is an extensive drainage system in the form of ditches constructed 1 3 m below sea level to keep the land dry. Pumping stations within various catchment areas pump groundwater and surface water out into the sea. The water table nearest to the coast may therefore be lower than in the sea outside the dyke. In connection with rising sea levels, it will presumably be important for the drainage on the landward side to continue as before, as the position of the saline-fresh water boundary is expected to move closer to ground level if the sea rises while the water table on the landward side is unchanged. Conversely, the position of the saline-fresh water boundary will only be slightly affected if the water table is allowed to rise freely in line with any rise in sea level. The two scenarios outlined here should be worked through with quantitative models based on local hydrogeological conditions in the groundwater and sea water in the areas around Rødbyhavn /2/. These conditions should then be included as a parameter in the detailed planning for a permanent repository in this area. It is important to note that the site is situated in low-permeable sediments and that there will be a need for a more detailed description of the saline-fresh water boundary, taking account of these local hydrogeological conditions. There is therefore some uncertainty as to the real risk of salt water seeping into a future repository. Repository type The planning guidelines describe how the facility will be constructed to ensure that it can cope with sudden floods (climate-proofing), whereby the surroundings will be safeguarded against emissions even in the case of climate change and extreme events. Table 9-10 Summary impact assessment. Environmental aspects Climate Rising sea levels Is there a risk of impact? Yes Can the impact be averted or reduced simply by the choice of location within the planned site? No Comments A rise of 1.5 m in storm situations needs to be increased to allow for a build-up effect and a wave height that could mean a total increase in sea level close to 4 m and possibly more. Extreme events Yes No Future changes in climate will have a limited effect on the area. Assessment of impact Minor because it is assumed that the height of the dyke will be increased in line with any rise in sea levels, and that the dyke will probably be raised for reasons of safety in connection with the future Fehmarn Belt Fixed Link to Germany. Minor Rising sea levels will not top the existing dykes, but in extreme situations with storm conditions there will be growing pressure on these dykes.

107 101 of 234 Environmental aspects Climate Saline groundwater Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes No Rising sea levels will result in more saline groundwater under the land, but the low salinity of the Baltic Sea will reduce this effect. These matters need to be examined more closely in a future detailed planning phase Assessment of impact Minor 9.6 Water This section describes the issues relating to groundwater and surface water within the planned site. It is based on information from local area studies and municipal designations. The impact assessment is based on the descriptions of the geological conditions (section 9.4), as the impact on groundwater and surface water depend largely in these. Drinking water interests are illustrated on map 2.3: Drinking water interests. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site Environmental status and objectives Groundwater There are no deep or near-surface groundwater reservoirs in the Rødbyhavn area, but there is a small regional sand reservoir just to the east of Rødbyhavn, the precise extent of which is not known. There is no groundwater extraction in the area for public waterworks, irrigation and industry. To the north of the Rødbyhavn area there are several extraction bore holes in the regional sand reservoir. There are three permits to extract surface water in southern Lolland around Rødbyhavn, but only one permit just east of Rødbyhavn close to the coast. Deep saline groundwater is known from areas with elevated Permian salt structures (diapirs) e.g. from North Jutland, Zealand and Lolland-Falster. The high pore water pressure in the pre-tertiary strata may cause salt water to move upwards. The presence of impermeable Tertiary (Paleogene and Neogene) clay layers will help to ensure that the deep salt water does not move upwards. In the white chalk in south Lolland, deep groundwater has been found to be more or less saline. Drinking water interests Lolland municipality s City Council approved the Water supply plan for Lolland municipality 2010_2017 on 27 January The plan describes the municipality s groundwater resources and conservation, current extraction, public waterworks, security of supply and forecasts of future drinking water consumption etc. The plan contains a number of objectives and ways of attaining these objectives to secure good and plentiful drinking water in Lolland municipality in the future /41/. The most important groundwater resources for drinking water supplies are designated as areas of special drinking water interests (Danish: OSD), which are meant to cover current and future needs for water of drinkable quality. In these areas, an extra effort will be made specifically to safeguard the groundwater, in order to prevent contamination and remove any existing pollution. OSDs are the core areas for this targeted groundwater conservation. This means that such areas are regarded as strategic catchment areas and that the municipalities need to take account of the groundwater resources and catchment areas for public waterworks in their spatial planning.

108 102 of 234 There are no OSD areas in the Rødbyhavn area. Most of the site is classified as a zone with no or limited drinking water reserves, while the northern part includes an OD area (area of drinking water interests). At a distance of 3 5 km to the north of the Rødbyhavn area is a zone classified as an area of special drinking water interests (OSD). There is no groundwater extraction in the Rødbyhavn area for public waterworks, irrigation and industry. As mentioned above, there is a permit to extract surface water just to the east of Rødbyhavn close to the coast. The groundwater flow is believed to be towards the Baltic and the Fehmarn Belt. There is limited knowledge of changes in the chloride content of the groundwater in the Rødbyhavn area over time. Twenty-five year-old chloride analyses in extraction bores at Errindlev waterworks to the north of the site indicate rising chloride concentrations in the range from mg Cl/l. There are only very limited local groundwater reservoirs in the area, as there are no large sandgravel formations in the area. Deeper white chalk reservoirs contain saline groundwater. Surface water The planned site is covered by the water management plan for the Baltic Sea. The Hovedvandopland Østersøen catchment area covers a land area of approx. 1,083 km². The catchment area covers small parts of Lolland, Falster and South Zealand and most of Møn. The catchment area includes 6 stretches of coastline, 402 km of watercourses, 17 groundwater reservoirs and 23 lakes /44/. The watercourses in the planned site are restricted to a few managed streams resembling canals (heavily modified watercourses). They flow into the Baltic. The streams have no specific environmental targets in the water management plan, but the Baltic has a target of good ecological status /44/ Assessment of environmental impact Groundwater The feasibility studies show that the groundwater level may be lowered when a permanent repository is established. Particularly wells, but also bore holes, will be susceptible to drying out if the water table drops. In the very clay-dominated geology of the Rødbyhavn area with only sporadic sand reservoirs, drying out of bore holes and wells as a result of falling groundwater levels is not considered to be a real problem. Polluted water could seep out from the facility in the longer term. Depending on the location and design of the facility, this could have varying degrees of negative impact on groundwater and surface water. In practice, infiltration of the white chalk reservoir is considered to be very limited because of the layers of low-permeable Paleocene clay. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could run off across the surface or in drains to the sea or into streams. In theory, the water could also infiltrate the groundwater reservoirs. The risk of surface run-off from a near-surface facility is considered to be minimal, as the plan guidelines assume both that the facility will be placed on a horizontal site and that surface water will be handled within the project site. As mentioned above, infiltration of the white chalk reservoir is considered to be very limited because of the layers of low-permeable Paleocene clay. With a near-surface repository going down to 30 metres below ground, or with an intermediate depth facility, there could be seepage directly into groundwater reservoirs or into covering layers, depending on the placing of the facility. If the facility is located in Paleocene clay, the clay is

109 103 of 234 expected to form a very effective geological barrier which will prevent seepage or transport to groundwater reservoirs. Contaminated water seeping into or infiltrating a groundwater reservoir will find its way into the general flow of groundwater. The water could flow into bore holes and wells supplying individual properties, or into the sea, watercourses or springs. There is not felt to be any risk of contaminated water flowing into public waterworks. Surface water As described under Groundwater, it is possible over time that water could seep into the facility and polluted water could seep out in the longer term, affecting the surface water. There is also a risk of seepage on the surface which could spread to e.g. streams and lakes. The impact may occur both as the repository is being filled and in the longer term, when it is closed. The degree of impact will vary greatly depending on the repository type. Repository types Both a near-surface repository and an intermediate depth repository carry the risk of contaminated groundwater flowing into surface water, including the few regulated watercourses in the area which flow into the Baltic. With a near-surface repository there is also a risk of surface water, i.e. streams, lakes and the sea, being polluted in the event of an accident causing a leak or of other seepage from the facility. In the period in which the facility remains open, it will be possible to consider this impact and take the necessary mitigation measures, but the long-term effects are more uncertain as this plan does not lay down any guidelines in the event of the facility remaining in operation beyond the 30 years it is expected to stay open. Proposals for mitigation measures and monitoring can be found in sections 15 and 16. Table 9-11 Summary impact assessment. Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Groundwater Yes Yes The impact on groundwater depends on the location of the facility. If the facility is located in thick Paleocene clay, the clay is expected to form a very effective geological barrier. Assessment of impact Minor - Plan guideline no 3 (Requirements for geological conditions) ensures that any repository will be located in suitable geological formations, so the impact will be limited. Drinking water interests (Yes) Yes A small area in the north-east corner of the gross area is designated as an area of drinking water interests (OD). In the remaining parts of the gross area and downstream of it, there are no drinking water interests or catchment areas for public water supplies. Drinking water interests are therefore judged not to be affected if the facility is positioned outside the OD. None If the facility is located in thick Paleocene clay. None if the repository is located outside the area of drinking water interests.

110 104 of 234 Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Surface water Yes No The potential conflict arises from potential leakage from a near-surface or intermediate depth facility with seepage into the groundwater and thence into streams, lakes or the sea. An intermediate depth facility is not expected to carry any risk of direct impact on surface water. Any leakage from a nearsurface facility onto the ground will be handled within the repository site, so there is no surface run-off of contaminated water into streams, lakes or the sea. Assessment of impact Minor if a nearsurface repository going down to a depth of 30 metres is established, and not located in thick Paleocene clay. None if a nearsurface repository is established on the ground or the facility is located in thick Paleocene clay as in the description of the impact on groundwater above. These matters will be examined more closely during the detailed field studies to be carried out under the Project Planning Act and possibly during the EIA study. 9.7 Soil The section describes the potential impact of the plan on the soil. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site, e.g. in relation to identified contaminated land Environmental status and objectives Contaminated land An analysis of contaminated land pursuant to the Soil Pollution Act may be carried out at either knowledge level 1 (V1 analysis based on reasonable suspicion) or knowledge level 2 (analysis based on actual studies). The two terms therefore only cover a description of whether the property has been examined and give no indication of how contaminated a property might be and with what substances. In this situation, no analysis of the known contaminated land on the site is being carried out, because the scoping found that the plan would not conflict with any existing soil contamination, as it would not prevent a future public clean-up effort. There may also be several pieces of contaminated land on the site which have not yet been analysed, so it is assumed that more detailed studies will be made of the soil in the relevant location in connection with a future EIA study Assessment of environmental impact Handling of soil During the construction phase, soil will be handled in line with the municipality s guidelines on soil handling. Soil contamination As described in section 9.6.2, there may be an impact on surface water resulting from discharges of substances via seepage into the groundwater. In the same way, substances may be discharged into the soil on the surface. The extent of this impact and the likelihood of it occurring

111 105 of 234 cannot be assessed from the information available at this time. An EIA study involving more detailed investigations of the actual location and a project to produce a detailed description of the barriers, will be able to produce a more differentiated assessment of the risk of impact on the soil. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could run off over the surface into the topsoil. Table 9-12 Summary impact assessment. Environmental aspects - Soil Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Soil Yes No The potential impact on the soil is linked to any leakage and seepage of contaminated substances. Assessment of impact Minor 9.8 Tangible assets This section deals with tangible assets, which in this context means a presentation of interests associated with agriculture, raw materials and afforestation. It focuses on potential conflicts with areas designated in the Municipal Plan as special agricultural, raw material or afforestation areas. These topics are illustrated on map 2.4: Tangible assets Environmental status and objectives Reserved area for the Fehmarn Belt Fixed Link The western part of the site is reserved for the Fehmarn Belt Fixed Link. In connection with this project, Femern A/S has submitted a proposal, approved by Lolland municipality s City Council, to establish a new foreland along the coast which will form a large nature area, and with it a beach park on the eastern side of Rødbyhavn. The whole foreland will be linked to the hinterland with systems of paths. It is expected that the area could develop into a very valuable nature area. It is also expected that the new beach park will bring a large number of tourists to the Rødbyhavn area, from Denmark and abroad. Agriculture In the countryside in the inland zone, the municipality is responsible for maintaining areas for agricultural use, i.e. arable and livestock production, forestry and horticulture. The inland zone is basically reserved for agricultural use. Efforts will be made to avoid any environmental conflicts between existing agricultural operations, new buildings and facilities. New buildings and facilities mean both residential, holiday and recreational buildings and polluting industrial and landfill facilities etc. /40/. The planned site is within a designated agricultural area. Raw material areas The southernmost part of the site is earmarked as a raw material area, in which approx. 400 million m 3 of bentonite were found in These bentonite reserves have not so far been exploited. Some of the raw material area coincides with the reserved area for the Fehmarn Belt Fixed Link. Afforestation Areas where afforestation is not wanted

112 106 of 234 The Municipal Plan identifies areas where afforestation is not wanted. These areas are mainly designated to safeguard landscape and cultural-historical assets. There is an area around Hyldtofte where afforestation is not wanted. Areas where afforestation is wanted Lolland municipality is one of the least wooded parts of the country with just 8 % of forest, against the national average of 12 %. The national target is to double the area of forest in the next 80 years. Lolland municipality has therefore designated areas where afforestation is wanted /40/. A small area within the planned site, to the north of the motorway, is designated as an afforestation area Assessment of environmental impact Agriculture The establishment of a repository in the area may conflict with the designation as an agricultural area, as agricultural areas are primarily reserved for farming operations. However, efforts should be made where possible to place any facilities that have to be in open countryside in the agricultural areas. Consideration will therefore be given to possible environmental conflicts between existing agricultural operations and a possible future facility in the detailed project design. The overall impact is not considered to be significant in relation to municipal planning, as the facility is expected to occupy an area of approx. 150 x 150 metres, but the impact will be permanent and irreversible. Raw material areas The plan may conflict with raw material interests in the area, as the raw material area covers a relatively large part of the site. The extent of the conflict depends on where the eventual facility is located and whether it is positioned centrally or on the periphery of the raw material area. If the facility is located within the raw material area, this will mean that raw materials cannot be extracted from the planned site. The impact will be permanent. Afforestation The plan is not considered to conflict with designations of areas where forests are not wanted. The plan may conflict with areas where afforestation is wanted, but the area needed for the repository is limited. Repository types The conflicts are independent of the choice of repository type, as the area used is the same for all solutions. Table 9-13 Summary impact assessment. Environmental aspects - Tangible assets Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Agriculture Yes No The conflict cannot be directly avoided by the placement of the facility. Assessment of impact Minor A relatively small area will be used for the repository and, on this basis, the direct impact on agricultural interests is considered to be insignificant (see section on indirect effects on agriculture).

113 107 of 234 Environmental aspects - Tangible assets Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Raw materials Yes Yes Any conflict with raw material interests will depend on the placement of the actual facility. Afforestation Yes Yes This conflict is considered to be insignificant and can be avoided by the final positioning of the facility. Assessment of impact None if the repository is located outside the area of raw material interests. Minor to moderate if the repository is located inside the area of raw material interests. None if the repository is located outside the afforestation areas. Minor if the repository is located inside afforestation areas. 9.9 Cultural heritage This section presents cultural and historical assets in the form of designated cultural environments, church surroundings and cultural heritage sites, on the assumption that the plan will not affect protected ancient sites and associated ancient monument protection lines; cf. plan guideline no 8, Cultural heritage. These topics are illustrated on map 2.5: Cultural heritage. Within the area there are registered protected ancient sites and monuments, and there may be valuable archaeological finds and remains in the area that have not yet been registered. It is assumed that these assets will be examined more closely in a later EIA study, and that the museum will be contacted with a view to more detailed investigations on the actual site Environmental status and objectives The Municipal Plan will include guidelines to safeguard the essential parts of the cultural heritage. The cultural heritage in the country and in the town includes ancient monuments, buildings and cultural environments, and churches and their surroundings. Cultural environments A cultural environment is a delimited geographical area whose appearance reflects key features of the development of Danish society. The cultural-historical elements and cultural environments worthy of conservation in towns and villages, small harbours etc. should be safeguarded by future local conservation plans, which should take account of traditional ways of building and local building styles, preserving old structures and maintaining the connection between the cultural environment and the landscape. The area does not contain any designated cultural environments, manor houses or industrial remains. Church surroundings Church surroundings involve an assessment of the immediate and distant impact of the church. The distant impact refers to the part of the landscape from which the church can be seen as a conspicuous element, and from which the church forms a major part of the overall look of the landscape. The immediate impact is the part of the immediate surroundings of the church within which the church is perceived as a dominant element. Combining the immediate and distant impact produced whet are known as church surroundings. The municipality s future development will consider the protection of churches and church surroundings, to ensure that they are preserved as conspicuous landmarks in the countryside /40/.

114 108 of 234 The site contains designated church surroundings categorised as distant impact around Tågerup, Olstrup and Errindlev churches. None of the churches is within the planned site, but the designated surroundings are in the north-eastern part of the site. Cultural heritage sites A cultural heritage site is an area of historical interest with hidden ancient sites and monuments. Cultural heritage sites may be of national or regional importance, and indicate that there are significant ancient sites in the relevant area. Cultural heritage sites are not in themselves protected, but they may contain protected ancient monuments. The site contains no cultural heritage sites Assessment of environmental impact Cultural environments The plan will not impact any cultural environments. Church surroundings The plan may impact church surroundings around three churches. The impact is considered to be small, as these are designations of church surroundings with distant impact, which are considered to be less vulnerable than church surroundings with immediate impact. Cultural heritage sites The plan will not impact any cultural heritage sites. Repository types The conflicts are independent of the choice of repository type. Table 9-14 Summary impact assessment. Environmental aspects - Cultural heritage Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Cultural environments Church surroundings Cultural heritage sites No - Yes No - Yes The site contains designated church surroundings categorised as distant impact around Tågerup, Olstrup and Errindlev churches. None None or minor depending on the eventual positioning of the repository. None 9.10 Cumulative effects Cumulative effects are assessed by viewing the plan in conjunction with other plans or programmes, including previous, current and planned activities. Relevant plans and programmes may cover the same subject-matter, the same geographical area or a neighbouring area. The aim is to ensure that the plan is consistent with other relevant plans and programmes and to assess whether there is any risk of cumulative effects. As described in the preceding sections on the individual environmental aspects, potential conflicts have been identified at Rødbyhavn with designated zones such as low-lying areas and raw material areas. Any conflict with low-lying areas will be avoided by inserting a guideline into the

115 109 of 234 plan to prevent the placement of the facility inside this type of designated area. The conflict with the raw material area depends on the final placing of the facility. The planned site contains a reserved area for the Fehmarn Belt Fixed Link. This could have a cumulative impact on the area, primarily nuisance in the construction phase in the form of noise, traffic, vibration and temporary closures of land. Among other things, the degree of impact will depend on the timetables for the planned projects. No higher-level plans or programmes have been identified within the site that might have an increased impact on the environment in combination with this plan Summary assessment The plan provides for the placement of a facility that may impact the environmental in a number of ways, some of which are general effects regardless of the choice of location, as outlined in section 4.2. Implementing the plan at Rødbyhavn could result in impacts that depend on local factors and need to be taken into account in a possible later planning and project design phase. Of these, the most significant are considered to be linked to the following factors: Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism (including the nearby Lalandia holiday resort), food production and the social structure in terms of a possible tendency for people to leave the area. Future changes in climate will have a limited effect on the area. Rising sea levels will not top the existing dykes, but in extreme situations with storm conditions there will be growing pressure on these dykes (assuming that the height of the top of the dykes is raised in line with any rise in sea levels). The impact on groundwater depends on the location of the facility. If the facility is located in thick Paleocene clay, the clay is expected to form a very effective geological barrier. The planned site contains reserved areas for e.g. the Fehmarn Belt Fixed Link and a raw material area. A small area of the south-western part of the planned site is covered by the designated coastal zone.

116 110 of KERTINGE MARK This site is located in the north-east of the island of Fyn (Funen). The Kertinge Mark peninsula is bordered to the west, north and north-east by Kerteminde Fjord and Kertinge Nor, with the towns of Kerteminde to the north-east and Munkebo to the north-west. The site covers approx. 7 km 2. The general background to the work on a plan to establish a permanent repository can be found in section 2, the planning guidelines are in section 3, while the methods used to analyse and assess the degree of impact are described in section 5. Figure 10-1 Outline map Kertinge Mark Planning conditions This section presents the overall planning framework and strategies for the site in the form of Kerteminde municipality s Municipal Plan and planning strategy. Kerteminde municipality s high-level ambitions for municipal development are laid down in: Planning strategy 2011 Municipal Plan Planning strategy 2011 In the planning strategy for 2011, the town council presents its vision for the future development of Kerteminde municipality. The planning strategy presents the themes and activities which the town council wishes to prioritise and which should therefore be incorporated into the Municipal Plan.

117 111 of 234 The high-level vision for Kerteminde municipality is: Nature and Cultural Heritage Growth and Development. The vision sends a signal that we attach importance to being a dynamic municipality which constantly seeks to create conditions for growth and development for residents and businesses in the municipality. And that we will do so with respect for and in harmony with the magnificent natural areas surrounding us, which are based on a unique cultural heritage /46/ Kerteminde Municipal Plan 2013 The Municipal Plan comprises a main structure with overall development objectives and guidelines for the use of land and a framework section for local planning for the individual areas. The Municipal Plan is the town council s high-level plan for municipal development in the next 12 years. The Municipal Plan is updated and amended via revisions and supplements, e.g. in connection with a specific theme or geographical area or via minor amendments to the framework in the form of a local plan constituting a supplement to the Municipal Plan. The Municipal Plan is a practical planning tool which ensures that national and municipal objectives, policies and considerations are taken into account in day-to-day municipal planning and administration. In other words, the Municipal Plan lays down the overall objectives and guidelines for municipal development in towns and villages and in the countryside and ensures that national and socioeconomic interests are taken into account in municipal area planning. This also means that the Municipal Plan must state how the municipality will: create and preserve valuable settlements, urban environments and landscapes, preserve open coasts as significant natural and landscape resources, prevent pollution of air, water and soil as well as noise, and involve the public in the planning work Biodiversity This section focuses on biodiversity, which in this context includes a description and assessment of the impact on Natura 2000, Section 3 of the Danish Nature Protection Act, wildlife corridors and national parks or nature reserves. It is a precondition that the future facility should not be located in a Natura 2000 area, and that the plan will not have any significant impact on adjacent Natura 2000 areas; cf. plan guidelines. These topics are illustrated on map 3.1: Biodiversity. It is assumed that the local natural assets will be examined more closely in a later EIA study, which will include more detailed investigations of the specific site in the form of e.g. field studies Environmental status and objectives There are no Natura 2000 areas within the planned site, but the following international nature conservation area is located approx. 2 km from the site: Odense Fjord the Natura 2000 area, N110, comprises the western part of Odense Fjord, bordered on the east by a line between the Lindø Shipyard and the tip of Enebærodde. The fjord was created during the last Ice Age as a meltwater plain. To the north, the fjord is bordered by Enebærodde, which is Fyn s only large area of heathland. The Natura 2000 area comprises 4,136 ha of sea and 912 ha of land. The innermost part of Odense Fjord, Seden Strand, is a shallow bay with a mean depth of less than 1 m. The outer fjord is also shallow, but with a mean depth of 2.7 m. A narrow navigation channel is maintained from Odense harbour out through the fjord. Several small islands have emerged as a result of depositing dredging materials from the navigation channel. There are two inhabited islands and approx.

118 112 of small islets in the fjord. The Natura 2000 area is covered by the Odense Fjord water management plan. Section 3 protected nature Under Section 3 of the Nature Protection Act, it is prohibited to interfere with protected natural habitats in a way that could cause a change to the state of these areas. However, the local authorities may derogate from this provision /11/, often on condition of establishing some natural replacement. Natural habitats covered by Section 3 of the Nature Protection Act are: Lakes and ponds of at least 100 m 2. Marshes, meadows, heaths, dry grassland, coastal meadows and marshland which individually or together cover an area of at least 2,500 m 2. Marshes under 2,500 m 2 are also protected if they are next to protected streams or lakes. Most streams and rivers are also protected via a special Section 3 designation. Lakes include both natural and wholly or partly man-made pools, basins and dams. The site contains few protected areas of natural interest (cf. Section 3 of the Nature Protection Act) in the form of ponds and meadows. Along the coast (approx m) there are Section 3 coastal meadows and fringe areas. There are no protected streams within the area, but there are small unprotected ditches and streams as well as piped watercourses, including Ladbyafløbet. Ecological corridors and areas of special biological interest The existing areas of natural interest, woods and streams constitute an important part of the basis for ecological corridors. The ecological corridors are based on the following nature types: Watercourse systems: streams, lakes and fjords and their bank zones Wetlands: meadows, marshes, swamps and swamp forests Dry areas: heaths and dry grassland Tree-covered areas: woods and windbreaks Coastal areas: dunes, dune heaths and coastal meadows In its future high-level nature conservation plan, Kerteminde Municipality will designate potential ecological corridor areas that could in the long term contribute to creating better connections between these habitats and to creating diffusion corridors for animals and plants. Work with ecological corridors must be coordinated with the municipalities of Odense, Faaborg-Midtfyn and Nyborg to ensure initiatives across municipal borders /47/. The planned site contains no designated ecological corridors. Within the areas of special biological interest, buildings may only be erected and facilities established to a negligible extent, and only if this does not have any negative impact on conservation and nature improvement interests, including the diffusion opportunities for wild plants and animals /47/. Kertinge Nor and Kerteminde Fjord have been designated as areas of special biological interest. Beach protection There is a 300 m protection belt along the entire coastline of Kertinge Mark. Protected forest The vast majority of private woods and all public woodland in Denmark have the status of protected forest (fredskov) and are safeguarded by the provisions of the Forests Act. The site includes two small protected forests to the north-west of Kertinge and near Præstevænge in the southern part of the planned site.

119 113 of 234 National parks Not relevant to this area Assessment of environmental impact General It is impossible to define criteria for protecting the environment against radiation as there are no statistics covering the health impact of ionising radiation on animals and plants, as there are for people. Internationally, projects have been launched to determine the effect of ionising radiation on nature and, on this basis, to use reference animals and plants as a means of establishing criteria and producing subsequent safety analyses. The progress of these projects will be monitored and taken account of as far as possible in defining environmental protection criteria when the safety analyses are carried out in a later EIA phase /15/. Human beings are generally considered to be the organism that is most vulnerable to ionising radiation. Therefore, once criteria have been established to safeguard people, we may assume that animals and plants will be sufficiently protected against radiation. Exceptions to this assumption will mainly apply to a small population of a species in a restricted area around the repository /15/. The environmental protection criteria applicable to a given repository will be drawn up in conjunction with the mandatory EIA studies to be carried out for two selected sites if it is decided to proceed further with the permanent repository concept. In this connection, detailed field studies will be carried out as part of the basis both for assessing potential effects and for defining environmental protection criteria. This will ensure that local conditions are taken into account in the form of site-specific assessments concerned with protecting the environment. This section presents the general conflicts with nature conservation interests. Natura 2000 The guidelines to the plan for a repository explain that any future facility must not have any significant effect on adjacent Natura 2000 areas (guideline no 7, Nature). The future planning and project design must therefore ensure that a facility can comply with these provisions. This will be determined by a materiality assessment, which will consider whether there is a risk of significant impact on the Natura 2000 area. If it is considered that there is a risk of significant impact, an impact assessment will be carried out. The purpose of this is to examine the potential impact in relation to the conservation goals for the area, and to incorporate preventive measures into the project in order to avert any serious impact. Section 3 protected nature There is a risk of impact on Section 3 protected areas where the facility itself or the access roads are positioned in direct conflict with the protected area. As the gross area is relatively large and there are few protected areas of natural interest, it is possible to place the facility so that it does not affect Section 3 protected nature. This consideration should therefore be included in subsequent planning and project design. No guidelines have been included in the plan to guard against conflicts with Section 3 protected areas, as other factors determining the ideal positioning may result in conflicts with Section 3 protected areas. It is a precondition that the Section 3 protected coastal meadows and dry grassland along the coast should not be affected as the facility cannot be placed within the beach protection belt, cf. plan guidelines. Ecological corridors and areas of special biological interest Kertinge Nor and Kerteminde Fjord have been designated as areas of special biological interest and are in fact located outside the planned site. The facility cannot be placed within beach

120 114 of 234 protection belts, and hence there is no conflict with the designated areas of special biological interest. Beach protection There is a beach protection belt along the entire coast. It is a precondition that the facility should be located outside this protected area. Protected forest In the area, there are two protected forests that may be affected. National parks There are no national parks in or near the planned site. Repository types The three types of repository take up the same area, so will result in the same risk of impact to nature arising from any closing off of land and hence of a potential impact on Section 3 areas and protected forests. As mentioned above, it is assumed that Natura 2000 areas, beach protection belts and low-lying areas will not be affected whatever the choice of repository. Table 10-1 Summary impact assessment. Environmental aspects Biodiversity Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Natura 2000 No - The plan guidelines state that a facility cannot be established under this plan if there is a risk of significant impact on Natura 2000 areas. The concrete assessment of whether the facility can meet this requirement will be made in a later EIA phase, when the location, repository type etc. are known. Section 3 protected nature Ecological corridors Beach protection Yes Yes Conflict with protected areas may be avoided by the choice of final location for the facility. No - The ecological corridors are within the beach protection belt, and the facility must be placed outside this protection zone, cf. plan guidelines. No - Plan guideline no 9, Building and protection lines, stipulates that the repository may not be located within the beach protection belt. Assessment of impact None None or minor The degree of impact depends on the positioning of the repository. None None Protected forest Yes Yes There is a risk of impact on protected forest areas. None or minor The degree of impact depends on the positioning of the repository. National parks No - Not relevant None

121 115 of Population and health This section describes the location of the planned site in relation to built-up areas, the number of inhabitants, commercial activity, tourism and recreation. It is mainly based on information from Statistics Denmark and the Municipal Plan. The section then describes the potential impact on the population in terms of health risks and indirect environmental effects, including the risk of reduced revenue, relocation etc. The assessment of the impact is based on available information from e.g. descriptions of transport and radiation in the feasibility studies. It is a precondition (cf. plan guidelines) that the facility should be designed to be able at any time to demonstrate compliance with the specified dose constraintdose constraints when in operation and after closure for those periods and for potential incidents (accident scenarios). The documentation of this is provided in the form of safety analyses for the facility and its use. The assessment of the indirect environmental impact on the population and industry identifies potential effects based on an analysis of responses to consultation and comments from public meetings focussing on e.g. people s concerns about the effects of implementing the plan Environmental status and objectives Population The area includes a built-up area at Kertinge as well as a few properties scattered across the countryside. The latter are mainly agricultural properties. Small roads run through the area, with a few houses. In general, roads in the area have limited capacity. In and around Kertinge Mark, the breakdown and number of inhabitants and the distance to built-up areas have been calculated. From Kertinge Mark to built-up areas, the distances are as follows: Table 10-2 Distance from major built-up areas. Distance from settlements: Kertinge: m Munkebo: 2.3 km to Snekkeled, 2.6 km to Noret Kerteminde: 2.6 km to Kerteminde Vest, 3.5 km to Søvangsparken Odense: 6.3 km to Seden/Bullerup, 13.8 km to Odense centre The breakdown and number of inhabitants is shown in Table 10-3 (figures from 2010): Table 10-3 Breakdown and number of inhabitants near the planned site on Fyn. The breakdown and number of inhabitants is as follows: Kertinge Mark (open land): 111 persons Kertinge + Kølstrup (northern part): approx. 150 persons Munkebo: 5,569 (2010) Kerteminde: 5,712 (2010) Odense: 166,305 (2010) Demographics Kerteminde municipality has seen a small increase in its population in recent decades, from 22,322 in 1993 to 23,787 as at 1 January 2013.

122 116 of 234 Industry The high-level vision for Kerteminde municipality is: Nature and Cultural Heritage Growth and Development. Importance is attached to Kerteminde being a dynamic municipality which constantly seeks to create conditions for growth and development for residents and businesses in the municipality /46/. The municipality s commercial profile is changing as many industrial jobs have disappeared following the closure of the Lindø Shipyard. On the other hand, tourism opportunities are good, and all-year activities are being developed within this sector. The food sector is also growing. One of the focal areas in the municipal planning strategy is the agricultural sector, which needs to expand its production and to develop through innovation. Kerteminde has one of the few active fishing ports and the municipality wishes to go on supporting the fisheries sector. Table 10-4 Breakdown of employment in Kerteminde municipality within selected industries related to tourism and leisure, agriculture, fishing and food production, as of The total number of people employed in Kerteminde municipality is 8,539 (Statistics Denmark 2013). Tourism In terms of tourism, the areas of natural interest in Kerteminde municipality are an invaluable asset for residents and tourists. Together with the well-preserved villages, manors, churches and many ancient site and monuments, they provide a basis for memorable visits to the municipality /46/. The town council wishes to support local initiatives and events to market Kerteminde municipality and strengthen both industry and tourism. Kerteminde municipality wishes to invest in tourism. Hence, there are plans to extend holiday and tourist facilities so that holiday visitors and elderly and disabled people have access on an equal footing with other visitors /47/. The town council expects tourism to be of major importance to future job creation in the municipality as more traditional jobs disappear /46/. Recreational areas Visitor centres, etc. The Viking Museum Ladby is located in the eastern part of the area at Vikingevej 123, 5300 Kerteminde /52/.

123 117 of 234 Summer cottage areas There are approx. 1,800 summer cottages in Kerteminde municipality, distributed over 23 summer cottage areas. The summer cottage areas are mainly concentrated at Fynshoved and Langø, at Dalby Bugten, in the northern part of Kerteminde town and at Kertinge Nor. Marinas There are five harbours in Kerteminde municipality. Closest to the site is Munkebo Havn, which is a small, municipally owned combined marina and fishing harbour in Kertinge Nor. Outdoor areas and trails The Municipal Plan contains visions for outdoor activities in the municipality, e.g. based on utilisation of the unique combination of history and nature so that everyone can enjoy the blue and green opportunities offered by Kerteminde municipality. The town council s vision is to improve the quality of life, health and enjoyment of life by creating opportunities for outdoor activities. improve access to nature by linking Kerteminde municipality via an easily accessible and attractive network of trails /47/. Kerteminde municipality has many recreational areas, including both small parks and grassy areas in towns and residential areas and less cultivated open nature. Munkebostien is a 20 km long footpath around Munkebo from Odense Fjord in the north to Kertinge Nor in the south. It links the town and the water and provides natural and cultural sights along hedgerows, railway tracks, via newly established trails, through areas of natural interest and in villages. Along the route there are 15 signs providing information about the history and nature of that specific area /47/. Kertingestien is a 3.5 km circular trail through the village of Kertinge, across fields and through woods. It was established at the initiative of the local parish association and is maintained by local plot owners /47/ Assessment of environmental impact The assessment of the impact on the population covers health (related to transport, risk of accidents and radiation, safety and security of the facility itself), and socio-economic factors, including the population, commercial interests, tourism and recreational activities. Health Radiation protection The health impact of radiation from the facility itself and from accidents is described in section 4.2, as the same requirements apply to safety assessments and official approval regardless of the choice of site. Transport Based on the feasibility study, we conclude that both road and sea transport may be considered. The radiation doses estimated for transport of Danish radioactive waste from Risø to a future repository in Denmark are calculated on the basis of the greatest possible distance to any repository. The estimated doses in the feasibility study are therefore upper limits, and doses from shorter transport routes will be proportionally lower. The study shows that the risk associated with road and sea transport does not restrict the future section of a location for a repository in Denmark, and that the transport can be handled so that the dose is well below the national thresholds. The area around Kertinge Mark is at a distance from Risø which is comparable to that of Rødbyhavn. Changes in distance have no effect on doses in the event of an accident. The

124 118 of 234 likelihood of an accident is dependent on factors such as the quality of the road and the volume of traffic, and is also proportional to the distance. Compared to the zero alternative, the radiation dose is greater in the short term as a natural consequence of the fact that, in the zero alternative, the waste will not be processed as much, or transported from the location. In the longer term, it will be necessary to process and possibly transport the waste under the zero alternative too, as Risø does not have the status of a permanent repository. Socio-economic factors Apart from the general issues mentioned above, the stakeholders have drawn attention to a number of local matters that should be given special consideration in the choice of destination and in implementing the plan if a repository should become a reality in their particular area. These are summarised in Table This is used as part of the background to the description of the potential impact on the population and the socio-economic factors, and also forms the basis for suggested mitigation measures (section 15.2). Table 10-5 Summary of the major concerns raised by stakeholders at Kertinge Mark*. Subject Drinking water Cultural heritage and Viking Museum Ancient monuments Protected areas Water quality Recreational aspects Description Stakeholders in relation to Kertinge Mark on Fyn state that drinking water is pumped up just south of Kertinge Mark, which is part of the designated site. This is part of the supply for Kerteminde town and the surrounding area. So special attention should be paid to ensuring that the project does not have any impact on these drinking water interests. Stakeholders also draw attention to the special cultural heritage of the area and the Viking Museum Ladby. The Museum houses the Ladby Ship a ship grave from Viking times. Stakeholders are concerned about how proximity to a repository for radioactive waste will affect the branding of the Museum and how it will affect the positive flow of visitors to the Museum seen in recent years. If the area were to be selected as the location for a permanent repository, it would therefore be expedient to involve the Museum at the planning stage so that the location and choice of solution etc. could take such interests into account. It has been pointed out that the chances of finding in situ ancient monuments are considerable as a large number of such monuments have been registered in the Kertinge Mark area in the form of small deposits of valuable objects as well as large settlements and grave sites. Such finds would be protected under Section 27 of the Museums Act. Stakeholders also draw attention to protected areas/villages close to the selected site and express concerns about the ability of the infrastructure to support transport, were a permanent repository to be established. Stakeholders express concerns that the proximity of the area to the sea may affect the coastal cultural heritage, the efforts to turn Kertinge Nor into a reference waterway, the Marine Biological Research Centre in Kerteminde and the ability of Kerteminde North and South beaches to retain their status as blue flag beaches, as well as having a concrete impact on the jellyfish population in Kertinge Nor. Misgivings are also expressed as to whether a permanent repository could affect Kerteminde camping site and its ability to retain its five stars, Kerteminde municipality s establishment of an exclusive golf course that might attract international golf tournaments to the municipality, and the Fjord & Bælt tourist attraction including the safety of employees and their research, visitors and animals. *This description is extracted from minutes of the public meeting held at Nymarksskolen near Kerteminde and from responses to consultation on the scoping report. Summary The questions relating to the establishment of the facility itself, and the practical problems that may arise as a consequence, are not dealt with in depth in this report because of the level of detail in the plan. The project-specific issues with question-marks against them will be addressed in a later phase, when risk assessments and radiation protection work will be carried out in conjunction with the subsequent work by the authorities once there is an actual project.

125 119 of 234 The following subjects are addressed at a high level in other sections of the environmental report: Groundwater, drinking water and surface water are discussed in section 10.6, The cultural heritage is discussed in section 10.9, but the plan guidelines assume that protected areas and ancient monuments will not be directly affected. Possible indirect implications of concerns with a bearing on the plan are described below. If we look at the comments from stakeholders of both a general and a local nature, we see that they are marked by a high degree of concern. These concerns are directed at a broad and diffuse set of risks, which indicate a lack of knowledge of the real risks involved in implementing the plan and of the measures that have been and will be taken to avert these risks. The comments also show that the stakeholders do not have sufficient knowledge of the process to be followed in the future, leading to widespread insecurity and mistrust. The stakeholders do not feel convinced that the future process will adequately examine and address the perceived risks and involve the stakeholders, to ensure that local interests are safeguarded. For these reasons, the analysis shows that the plan to establish a repository has received a very negative response from the stakeholders. This negative attitude, insecurity and mistrust of the plan and the projected process create the ideal conditions for a number of negative social effects to become reality. In this situation it is not inconceivable that a permanent repository could have indirect negative implications for the tourism sector, sales opportunities for local goods, including local organic produce, the mental wellbeing of residents in the area, etc. purely because of insecurity and mistrust. It is therefore crucial to the social effects of the plan that the insecurity and mistrust should be reduced. Overall, there could be a risk of affecting socio-economic conditions, including the local attractions mentioned by stakeholders, notably the Viking Museum Ladby, as well as Kerteminde municipality s general visions for outdoor activities in the municipality. The plan for the permanent depository could clash with the high-level strategies and visions for the area as described in e.g. Kerteminde Municipal Plan. Table 10-6 Summary impact assessment. Environmental aspects Population Health Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Radiation protection Yes Yes The impact in the immediate vicinity will depend on the final location. Minor (below the dose constraintdose constraints) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraintdose constraint. As with the category of transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of

126 120 of 234 Environmental aspects Population Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact risks and potential doses. Securing the facility Yes Yes A vulnerability assessment should cover different scenarios and their consequences. These scenarios should be covered by security and contingency plans designed to assure the greatest possible reasonably attainable reduction of risks and potential doses. Transport Yes Yes The impact in the immediate vicinity will depend on the final location. Noise, heavy traffic and emissions may have an impact in connection with transport within the planned area. Socioeconomic conditions Yes Yes/No. In recreational areas etc. the impact may be dependent on the final location, but the general concern about the impact on the population and industry is considered to be independent of the final location, and in many cases people expect an impact beyond the planned site itself. Implementing the plan may cause indirect effects on the population and socio-economic conditions. The stakeholders highlight a number of issues that cannot be addressed at this introductory stage of the planning process, but these issues will be examined more closely in an EIA phase and in conjunction with safety analyses and official approvals. Minor (below the dose constraintdose constraint) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraintdose constraint. As with the categories of radiation protection and transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the thresholds for exposure to radiation). Estimated doses for transport to the planned site are well below the dosage thresholds. There will be a need to plan transport routes, times etc. to achieve a reduction of risks and potential doses. Moderate to significant The impact is judged to be of moderate to significant importance because of the high level of concern and the uncertainty expressed among the stakeholders. This should therefore receive close attention in the later phases Landscape and geology This section presents geographical and geological conditions within the planned site, which here encompass a high-level description of the landscape and any designated areas and a description of the geological conditions based on the feasibility studies, with any designated features. These topics are illustrated on map 3.2: Landscape and geology.

127 121 of 234 The assessment of the impact on the landscape is based solely on whether there is a risk of impact on valuable landscapes and the designated coastal zone. It is assumed that the real impact on the landscape and visual factors will be determined in a later EIA study, where landscape analyses, visualisations etc. can be based on the choice of a specific location and a concrete project proposal. The purpose of examining the geological conditions is to assess the degree of uncertainty as to the ability of the geological conditions to act as a physical barrier around a possible repository. It is assumed that the local geological conditions will be examined in more detail in a later EIA study Environmental status and objectives Landscape Landscape description Kertinge Mark is a peninsula, bordered to the west, north and north-east by Kerteminde Fjord and Kertinge Nor. In the middle of the peninsula is a central hill running north/south and rising to between 15 and 20 m above sea level. The top of the hill is a plateau, from which the land slopes slightly towards the periphery, reaching a height of 5 m above sea level to the south-east and south. There are no coastal cliffs, wave energy is low along the coast and the coast develops slowly. Designated coastal zone The designated coastal zone is defined in the Planning Act and is approx. 3 km wide. The rule is that the designated coastal zone must be kept free from buildings and facilities that are not dependent on proximity to the coast. Kertinge Mark is situated within the designated coastal zone. Planning Act: Section 5b. The following shall apply to planning in the designated coastal zone: 1) It is prohibited to transfer land to an urban zone or to conduct planning for development in a rural zone unless there is a specific planning-related or functional justification for location near the coast. Designated areas Landscapes worthy of preservation are landscapes that are particularly characteristic due to their nature (terrain, soil type, etc.), cultivation (buildings/structures, forests, agriculture, etc.) or spatial or visual appearance. The Municipal Plan guidelines for conservation of landscape assets are based on mapping of the entire area of the municipality, broken down by characteristics, vulnerability and conservation value /47/. The planned site includes a landscape assessed to be vulnerable and referred to as Bovense- Kertinge Moræneflade. The southern part of the planned site is described as characteristic. In the landscape character analysis performed by the County of Fyn in 2006, Kertinge Mark is described as follows: The area north of Ladby and around Kertinge Mark differs from the rest of the character area in that there is an absence of woods and smallholdings, which makes the landscape appear more simple and open. Kertinge Mark is situated on a small hilltop, which also makes its delimitation more open, as well as providing a free view of Kertinge Nor, Kerteminde Fjord and the landscape on the other side. The area is characterised by visual impressions from Kerteminde, the town s red tile roofs standing out very clearly in the landscape. Buildings are mainly large farms located among fields. The landscape character of this area is assessed to be contrasting /50/.

128 122 of 234 Geology A detailed discussion of the geological conditions can be found in GEUS report no 3 /3/. The following description is a summary of the geological conditions described in the local area study. Deposits and soil types Within the site, there are Paleogene units of fine-grained clay belonging to the Æbelø formation (top) and Kerteminde Mergel formation (bottom), both from the Paleocene epoch. The Æbelø formation is not present throughout the area, but together the two units extend throughout the area, possibly with a thickness of more than 75 m. The Paleogene clay units rest on Danian chalk and are covered by up to approx. 40 m thick Quaternary deposits. The top height of the Paleogene clay units varies substantially within the area. In the higher part of the peninsula, the clay is reached at -7 m and in the lower part at -29 m, which points to considerable erosion of Ice Age glaciers. The Quaternary sedimentary complex is up to approx. 40 m thick (but often thinner) and consists mainly of clayey till, probably with sand lenses. No Quaternary sand reservoirs have been found within the area, but just south-east of the area there are Quaternary sand reservoirs from which Kerteminde Waterworks pumps up groundwater. Bore holes around Kertinge Mark contain Paleogene sheets in the Quaternary strata. Mineralogy binding adsorption The geochemical conditions in the deposits have a bearing on how radioactive material will behave if it should leak out of a repository into the surrounding geological strata. Some general observations are set out below. However, the large number of radioactive components in the waste may behave differently in the surrounding deposits. A key element is that the radioactive material should be able to bind to the deposits. The uppermost strata consist of clayey till. This clay contains 10 20% particles in the clay fraction and has a high chalk content. The underlying Kerteminde Mergel contains approx. 1% fine sand, around 30-40% silt and around 60-70% clay. The mineralogical content comprises approx. 50% CaCO 3, and the sand fraction consists of quarts, a little glauconite, pyrite and flint-like silicified material. The clay fraction predominantly contains smectite clay minerals. The Æbelø formation also has a very high content of smectite clay minerals. Clay minerals, especially smectite, are particularly well-suited to binding radioactive material. This means that the Paleogene clay units have the potential to bind the radioactive components. Redox conditions The behaviour of the radionuclides in relation to the oxygen content in the strata and groundwater (redox conditions) will depend on the types of chemical compounds and chemical properties involved. The concentrations of these components in the strata and the water, and their ph, also have a bearing on the processes that will occur. There is oxygen present in the uppermost layer of soil (the oxidised zone), and this may for example mean that some radioactive components can be made mobile and hence transported more easily. Conversely, the conditions in the oxygen-free (reduced) zone, for example, will help to bind and hold other radioactive components. In the Kertinge Mark area, the oxidised zone seems to continue to 5-7 m below ground level. In other words, most of the Quaternary clayey till and the Paleogene Kerteminde Mergel and Æbelø formation units are in the reduced zone.

129 123 of 234 Natural radioactive components in the deposits There are no known values for clayey till, the Æbelø formation and Kerteminde Mergel in the area. Black clay in the Limfjord area, which may be related to the black clay from the Æbelø formation, may have a high content of radioactive components. Assessment of geological conditions The geological conditions influence the impact of the repository on both surface water and groundwater. The geological conditions need to be consistent and stable within the site and they must contribute to the stability of the repository. The geological strata should help to isolate the waste from the surroundings by enclosing or underpinning the repository. The rocks should be low-permeable and help to bind the radioactive components from any discharge from a repository /15/. These issues are assessed in Table In the table, the geological conditions are assessed only in relation to a repository placed in the pre-quaternary rocks, in this case the Paleogene clay rocks. If the repository is located in Quaternary deposits, clayey till probably containing fractures and sand lenses will only partly isolate the waste from the surroundings. Table 10-7 Assessment of the geological conditions in terms of stability, low-permeable rocks and binding of radioactive components. Property Assessment Comments Consistent and stable geological conditions contribute to the stability of a repository. Yes The geological strata help to isolate the waste from its surroundings: low-permeable rocks. The geological strata help to isolate the waste from its surroundings: Binding of radioactive components. Yes Yes Geotechnical stability will be addressed in any specific project proposal. The Paleogene clay rocks are low-permeable. The Paleogene clay rocks have a high content of clay minerals, including a high content of smectite. Clay minerals, especially smectite, are particularly wellsuited to binding radioactive material. This means that the Paleogene clay rocks have the potential to bind the radioactive components. Areas of geological interest The Municipal Plan contains designations of geological conservation areas, including coastal landscapes and natural or man-made profiles whose geological structures and appearance document significant aspects of the geological formation of the country. Furthermore, there are locations that illustrate the geological processes that are still transforming the landscape. Kertinge Nor and Kerteminde Fjord have been designated as marine areas of special geological interest. The coastal strip around Kertinge Mark is a designated area of special geological interest. Summary Within the site, there are one or two early Paleogene units of fine-grained clay, which together cover the entire area and possibly have a thickness of more than 75 m. On top of the Paleogene clay deposits are up to 40 m thick late Quaternary clayey till deposits. This indicates that the Paleogene clay units are undisturbed, but glacial erosion and deformation of Ice Age glaciers may have affected the upper part of the clay deposits. Experience shows that clayey till contains fractures and sand lenses. The qualities of the Paleogene clay units indicate a good ability to retain any leaking radioactive material from a repository Assessment of environmental impact Landscape The integration of the facility into the landscape and its visual impact are not being addressed at this stage of the planning, but they will be included in a later EIA process when there is more knowledge of the location, the type of facility, materials and dimensions all crucial factors for

130 124 of 234 the visual impact. It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location and the repository type have been decided. If the facility is located within the designated coastal zone, then before any future project can be implemented, the provisions of the Planning Act require a study to determine whether there is a specific planning-related or functional reason for the coastal location. There should also be a description of the visual impact, which will depend on the repository concept and design. If it is decided to choose a design to make the facility recognisable and visible, e.g. for safety reasons, this will immediately make a greater visual impact than a repository concept that is more integrated into the landscape. The final assessment of the scale of the impact will be made as part of the EIA studies. Repository types It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location has been decided and there is a description of the repository type, dimensions, choice of materials and colours, planting, fencing etc. Geology The plan is not expected to affect the general geological conditions significantly, but the geological conditions have a major bearing on the suitability of the site for the establishment of a repository. The geological description will therefore be used as background material to any assessment of the impact on groundwater and surface water. The area of geological interest in Kertinge Nor and Kerteminde Fjord will not be affected by the plan since the area of geological interest is within the beach protection belt, where the repository cannot be located, cf. plan guideline no 9, Building and protection lines. Repository types The potential impact on the geological features is expected to be similar for each of the three repository types, as the total area required will be the same whatever repository type is chosen. Table 10-8 Summary impact assessment. Environmental aspects Landscape and geology Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Designated areas Designated coastal zone Yes No The planned site includes a landscape assessed to be vulnerable. The actual impact on the landscape will be assessed in more detail in a potential later EIA phase when a project exists. Yes No The whole of the planned site lies within the designated coastal zone, so this conflict cannot be avoided. Minor to moderate A final assessment of the impact requires an actual project and visualisations to be produced in a future EIA phase. Moderate A final assessment of the degree of impact requires an actual project and visualisations to be

131 125 of 234 Environmental aspects Landscape and geology Geological designations Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments No - The coastal strip around Kertinge Mark is a designated area of special geological interest. Assessment of impact produced in a future EIA phase. None The repository cannot be located within the designated area as this partly overlaps with the beach protection belt, within which the repository cannot be placed, cf. plan guideline no Climate Climate change could affect the future repository because of the increased risk of extreme events. This section describes the future scenarios that are being examined in Denmark and abroad, to serve as a basis for assessing whether the planned site is expected to be significantly affected by changes in the climate. It is assumed that a future facility (see plan guidelines), via its design and placement in the landscape, will be adapted to any future climate change and thus less vulnerable to extreme events /3/ Environmental status and objectives Based on the latest Danish and European scenario analyses, the Danish Meteorological Institute (DMI) has described the expected future climate changes in Denmark out to The assessments are based on the scenarios used by the UN s International Panel on Climate Change (IPCC) /20/. The changes are expected to increase towards the year Considerations of climate change are relevant to the placing of the permanent repository because of the risk of rising sea levels flooding the facility, which could lead to penetration by surface water and hence an increased risk of radioactive substances spreading into the environment. The DMI report suggests that Denmark will experience warmer and wetter weather in the future, with more extreme events such as longer periods of drought and heavier rainstorms, and temperature increases. It also projects a general rise in sea levels in the waters around Denmark /20/. More recent projections are now pointing to even greater rises in sea levels around Denmark, ranging from 80 ±60 cm to max. 150 cm by There may be further increases towards 2200, but estimates are extremely difficult and fraught with very great uncertainty /20/. The land at Kertinge Mark slopes evenly towards the coast all the way along Kertinge Nor and Kerteminde Fjord. It is a highly protected coastal strip, and the actual coastal zone is generally characterised by a narrow and stony strip of beach. To the north-west, a low, inactive coastal cliff has developed, and in several places, especially in the middle part of the western coast and furthest to the north-east, there are small areas of overgrown foreland. This means that the part of the coastal strip that can be expected to be flooded by 2100 if the predictions in the modelling of the sea level rise are correct is fairly modest, even in a worst case scenario.

132 126 of Assessment of environmental impact Rise in sea level Even if we assume a rise of at least 80 cm in Danish seas (by 2100), it is difficult to predict how such a rise will be reflected in Kertinge Nor and Kerteminde Fjord. If the sea rises by 80 cm, we can expect increased erosion of the coastal cliff, erosion will create cliffs where there have not previously been any, and most of the overgrown areas will be flooded. Based on the models, the size of the areas affected is assessed to be limited, and the peninsula on which the planned site is located will not be flooded. Vertical uplift in the area is assessed to be approx. 0.1 mm per year, and if this continues in future, it will made a modest contribution to reducing the impact of the sea level rise /3/. Extreme events Due to its geographical location at the bottom of the cove and the fjord, Kertinge Mark is not particularly exposed to storm surges and floods even though the coast faces west, which is where the strongest impacts are usually seen. Internal Danish waters are affected by the considerable damming that can occur and which manifests itself in bottleneck problems in the exchange of water between the Kattegat/North Sea and the Baltic /3/. Repository type The plan guidelines describe how the facility will be constructed to ensure that it can cope with sudden flooding (climate-proofing), whereby the surroundings will be safeguarded against emissions even in the case of climate change and extreme events. Any rise in the groundwater level should also be taken into account when climate proofing a future facility. Table 10-9 Summary impact assessment. Environmental aspects Climate Rising sea levels Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes With rising sea levels and more frequent storms, the planned site will be exposed to more destructive forces. Kerteminde municipality has a high-water model that can be accessed from the municipality s website. According to the model, the water level can rise to 3 m without any significant impact on Kertinge Mark if the repository is placed at a high level and away from the coast /3/. Extreme events Yes Yes Due to its geographical location at the head of the cove and the fjord, Kertinge Mark is not particularly exposed to storm surges and floods. Assessment of impact None or minor provided that account is taken of the placement of the facility on the land. Plan guideline no 11, Climate, also describes how allowance will be made for climate change in the design and placing of the repository. None or minor 10.6 Water This section describes the issues relating to groundwater and surface water within the planned site. It is based on information from local area studies and municipal designations. The impact assessment is based on the descriptions of the geological conditions (section 10.4), as the

133 127 of 234 impacts on groundwater and surface water depend largely on these. Drinking water interests are illustrated on map 3.3: Drinking water interests. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site Environmental status and objectives Groundwater Within the Kertinge Mark area, there are no deep or near-surface groundwater reservoirs, but there are small extractions from dug wells placed in clayey till. There is no extraction for public or private waterworks in the area. Just to the south-east of the area, there is a limited, vulnerable groundwater reservoir in meltwater sand and gravel, presumably split up into several smaller reservoirs. The reservoir(s) is/are used to supply Kerteminde town. Groundwater mapping has been performed in and around Kertinge Mark, and contingency plans have been drawn up, i.e. an action plan for groundwater /48/. Within this groundwater reservoir to the south-east of Kertinge Mark, groundwater flows towards the extraction bore holes in the reservoir. Model calculations show that in the Kertinge Mark area, where groundwater flows at all, it flows to the west, north and north-east towards Kertinge Nor and Kerteminde Fjord. So according to the groundwater model, there is no flow of groundwater from Kertinge Mark towards the groundwater reservoir to the south-east /48/. It has been discovered that there is generally a very high content of chloride in the groundwater, and that the groundwater will become unsuitable for drinking water if too much water is extracted from a few bore holes near Kerteminde Waterworks, so at present the volumes pumped up are balanced to ensure that the drinking water does not become salty. Drinking water interests The most important groundwater resources for drinking water supplies are designated as areas of special drinking water interests (Danish: OSD), which are meant to cover current and future needs for water of drinkable quality. In these areas, an extra effort will be made specifically to safeguard the groundwater, in order to prevent contamination and remove any existing pollution. OSDs are the core areas for this targeted groundwater conservation. This means that such areas are regarded as strategic catchment areas and that the municipalities need to take account of the groundwater resources and catchment areas for public waterworks in their physical planning. The feasibility studies did not include OSD areas in the mapping, but it was not possible completely to avoid areas of drinking water interests (Danish: OD). Kertinge Mark is located in an OD area. To the south-east of Kertinge Mark, there is an important groundwater reservoir which has been designated as an OSD area. This OSD area contains the primary groundwater resources for Kerteminde town. The distance between Kertinge Mark and the OSD area is 0 to approx. 1 km. For this area, a groundwater action plan was also prepared by the County of Fyn. Within the area there are no groundwater reservoirs, but near-surface extraction for households from wells in clayey till and a few bore holes for commercial use, e.g. horticulture. Just to the south-east of the area, there is an OSD area with a limited, vulnerable groundwater reservoir in meltwater sand and gravel, which is used to supply Kerteminde town.

134 128 of 234 Surface water The planned site is comprised by the water management plan for Hovedvandopland Storebælt /53/. The Hovedvandopland Storebælt catchment area covers a land area of approx. 540 km 2, i.e. approx. 18% of Fyn and the surrounding islands. It has 234 km of watercourses with environmental targets and 11 lakes greater than 5 ha in size. The most important coastal waters are the Great Belt with Langelandsbæltet, as well as Kertinge Nor, Kerteminde Fjord and Holckenhavn Fjord. The environmental target for marine wetlands in Hovedvandopland Storebælt is good ecological status. Within the planned site, there is a small stream at Lodhøj, flowing north into Kerteminde Fjord. In the water management plan, the target for Kertinge Nor and Kerteminde Fjord is good ecological status. There are no specific targets for the status of small streams in the area. A north/south watershed runs through the Kertinge Mark peninsula. Water from the western part of the peninsula runs into Kertinge Nor, water from the eastern part into Kerteminde Fjord Assessment of environmental impact Groundwater The feasibility studies show that the groundwater level may be lowered if a permanent repository is established. Particularly wells, but also bore holes, will be susceptible to drying out if the water table drops. In the heavily clay-dominated geology of the Kertinge Mark area, with only sporadic sand lenses, drying out of bore holes and wells as a result of a lower water table is not assessed to be a real problem. Furthermore, it is assessed that lowering of the groundwater level in the Kertinge Mark area will not have any impact on the groundwater level or water quality of the groundwater reservoir located to the south-east of Kertinge Mark, from which water is pumped up for Kerteminde town. Over time, it is possible that water could seep into the facility and polluted water could seep out in the longer term. Depending on the location and design of the facility, this could have varying degrees of negative impact on groundwater and surface water. Repository types Depending on the location and design of the facility, this could have various impacts on groundwater and surface water. With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow across the surface or in drains to the sea or into streams, or infiltrate the groundwater. The risk of surface run-off from a near-surface facility is considered to be minimal, as the plan guidelines assume both that the facility will be placed on a horizontal site and that surface water will be handled within the project site. With a near-surface repository going down to 30 m below ground, or with an intermediate depth facility, there could be seepage directly into groundwater reservoirs or covering layers. If the facility is placed in Paleogene clay rocks, this clay is considered to constitute an effective geological barrier that will prevent seeping or transport to groundwater reservoirs. Contaminated water seeping into or infiltrating the groundwater will find its way into the general flow of groundwater into the reservoirs (in this case, scattered sand lenses in clayey till). The water could flow into bore holes and wells supplying individual properties, or into the sea, watercourses or springs. There is not felt to be any risk of contaminated water flowing into public waterworks.

135 129 of 234 Surface water As described under Groundwater, it is possible over time that water could seep into the facility and polluted water could seep out in the longer term, affecting the surface water. There is also a risk of seepage on the surface which could spread to e.g. streams and lakes. The impact may occur both as the repository is being filled and in the longer term, when it is closed. The degree of impact will vary greatly depending on the repository type. Repository types Both a near-surface repository and an intermediate depth repository would entail a risk that contaminated groundwater could flow into the surface water, including the stream at Lodhøj, which flows north into Kerteminde Fjord. With a near-surface repository there is also a risk of surface water, i.e. streams, lakes and the sea, being polluted in the event of an accident causing a leak or of other seepage from the facility. In the period in which the facility remains open, it will be possible to monitor this impact and take the necessary preventive measures, but the long-term effects are more uncertain as this plan does not lay down any guidelines in the event of the facility remaining in operation beyond the 30 years it is expected to stay open. Proposals for mitigation measures and monitoring can be found in sections 15 and 16. Table Summary impact assessment. Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Groundwater Yes Yes The impact on groundwater depends on the location of the facility. If the facility is located in thick Paleogene clay deposits, the clay is expected to form an effective geological barrier. Assessment of impact Minor plan guideline no 3 (Requirements for geological conditions) ensures that any repository will be located in suitable geological formations, so the impact will be limited. Drinking water interests Yes Yes The area is designated as an area of drinking water interests. However, there are no catchment areas for public water supplies within the area. A potential conflict can be avoided by connecting any individual extractors downstream of the repository to the public water supply. None if the facility is placed in thick, Paleogene clay. Minor there are no catchment areas for public water supplies within the area.

136 130 of 234 Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Surface water Yes No/Yes The potential conflict arises from potential leakage from a near-surface or intermediate depth facility with seepage into the groundwater and from there into streams, lakes or the sea. An intermediate depth facility is not expected to carry any risk of direct impact on surface water. Any leakage from a nearsurface facility onto the ground will be handled within the repository site, so there is no surface run-off of contaminated water into streams, lakes or the sea. Assessment of impact Minor if a nearsurface repository going down to a depth of 30 m is established, and not located in thick Paleocene clay. None if a nearsurface repository is established on the ground or the facility is located in thick Paleocene clay; see the description of the impact on groundwater above. These matters will be examined more closely during the detailed field studies to be carried out under the Project Planning Act and possibly during the EIA study Soil The section describes the potential impact of the plan on the soil. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site, e.g. in relation to identified contaminated land Environmental status and objectives Contaminated land An analysis of contaminated land pursuant to the Soil Pollution Act may be carried out at either knowledge level 1 (V1 analysis based on reasonable suspicion) or knowledge level 2 (V2 analysis based on actual studies). The two terms therefore only cover a description of whether the property has been examined and give no indication of how contaminated a property might be and with what substances. In this situation, no analysis of the known contaminated land on the site is being carried out, because the scoping found that the plan would not conflict with any existing soil contamination, as it would not prevent a future public clean-up effort. There may also be several pieces of contaminated land on the site which have not yet been analysed, so it is assumed that more detailed studies will be made of the soil in the relevant location in connection with a future EIA study Assessment of environmental impact Handling of soil During the construction phase, soil will be handled in line with the municipality s guidelines on soil handling. Soil contamination As described in section , there may be an impact on surface water resulting from discharges of substances via seepage into the groundwater. In the same way, substances may be discharged into the soil on the surface. The extent of this impact and the likelihood of it occurring

137 131 of 234 cannot be assessed from the information available at this time. An EIA study involving more detailed investigations of the actual location and a project to produce a detailed description of the barriers will be able to make a more differentiated assessment of the risk of impact on the soil. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow over the surface into the topsoil. Table Summary impact assessment. Environmental aspects - Soil Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Soil Yes No The potential impact on the soil is linked to any leakage and seepage of pollutants via the groundwater. Assessment of impact Minor 10.8 Tangible assets This section deals with tangible assets, which in this context means a presentation of interests associated with agriculture, raw materials and afforestation. It focuses on potential conflicts with areas designated in the Municipal Plan as special agricultural, raw material or afforestation areas. These topics are illustrated on map 3.4: Tangible assets Environmental status and objectives Agriculture Special agricultural area Particularly valuable agricultural areas are areas of special interest to the agricultural sector. Within the particularly valuable agricultural areas, use of agricultural land for non-agricultural purposes must be limited. The incorporation of particularly valuable agricultural areas will be based on a thorough evaluation of whether alternative placement options would better satisfy agricultural interests while not ignoring other weighty considerations. The whole of the planned site is designated as a special agricultural area. Raw materials There are no raw material areas within the planned site. Afforestation Unwanted afforestation In areas where afforestation is not wanted, this is attributable to higher prioritisation of other interests, e.g. related to landscape, areas of natural interest, potential wetlands and wind turbine areas. The planned site includes areas where afforestation is not wanted around Hyldehøj in the north-eastern part of the site and south of Kertinge. Afforestation areas Designation of afforestation areas is based on the former County of Fyn s priorities, which attach particular importance to afforestation near urban areas in the interests of both outdoor activities and protection of groundwater. Since many water supplies are close to urban areas, there is a considerable overlap between afforestation areas close to urban areas and areas designated for protection of groundwater. This also applies in Kerteminde municipality, where practically all afforestation areas are in areas of special drinking water interests (OSD areas). The planned site includes no afforestation areas.

138 132 of Assessment of environmental impact Agriculture The establishment of a repository in the area will conflict with the designation as a particularly valuable agricultural area. The incorporation of particularly valuable agricultural areas will be based on a thorough evaluation of whether alternative placement options would better satisfy agricultural interests while not ignoring other weighty considerations. Since most of the area has been designated as an area of agricultural value, there are no alternative locations within the planned site, but in a subsequent project design phase it is possible to take agricultural interests in relation to division of fields etc. into account. The overall impact is not considered to be significant in relation to municipal planning, as the facility is expected to occupy an area of approx. 150 x 150 m, but the impact will be permanent. Raw materials There is no impact. Afforestation The plan is not in conflict with the designations of afforestation areas. The planned site includes areas where afforestation is not wanted, but the plan does not conflict with the primary purpose of the designation. Repository types The conflicts are independent of the choice of repository type. Table Summary impact assessment. Environmental aspects - Tangible assets Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Agriculture Yes No The conflict cannot be directly avoided by the placement of the facility. Raw materials No - None Assessment of impact Minor a relatively small area will be used for the repository and, on this basis, the direct impact on agricultural interests is considered to be insignificant (see section on indirect effects on agriculture). Afforestation No - There are no conflicts with afforestation areas. None 10.9 Cultural heritage This section presents cultural and historical assets in the form of designated cultural environments, church surroundings and cultural heritage sites, the assumption being that the plan will not affect protected ancient sites and associated ancient monument protection lines; cf. plan guideline no 8. Cultural heritage. These topics are illustrated on map 3.5: Cultural heritage. Within the area there are registered protected ancient sites and monuments, and there may be valuable archaeological finds and remains in the area which have not yet been registered. It is assumed that these assets will be examined more closely in a later EIA study, and that the museum will be contacted with a view to more detailed investigations on the actual site.

139 133 of Environmental status and objectives Cultural environment There are no cultural environments within the area. Protected church land Village churches are often significant elements of the cultural landscape, and in the case of many village churches, valuable views to and from the church have been preserved. The southern part of the site affects some of the surroundings of Kølstrup church. Cultural heritage sites A cultural heritage site is an area of historical interest with hidden ancient sites and monuments. Cultural heritage sites may be of national or regional importance, and indicate that there are significant ancient sites in the relevant area. Cultural heritage sites are not in themselves protected, but they may contain protected ancient monuments. The areas are designated by the Danish Agency for Culture. The site contains cultural heritage areas and facilities (designated as extent of facilities ) in the north-eastern part of the area east of Vikingevej, around the areas belonging to the Viking Museum Ladby. The Viking Museum Ladby The Viking Museum Ladby houses the Ladby Ship, which is currently Denmark s only known Viking Age ship grave and the only ship grave which can be seen in its authentic location. This is where the king of Ladby was buried, in a longship more than 20 m long and 3 m wide. The Viking Museum has prepared a strategic plan for aimed at formulating an overall vision for the further development of the Viking Museum Ladby over the next 10 years. The intention is to transform the Viking Museum Ladby into an even more active and living museum. The plan includes the following new initiatives, among others: New museum building Ladby Ship at the landing stage (new harbour for the Ladby Ship and the two smaller boats) The Viking Age from a child s perspective (establishment of a Viking Land for children) Assessment of environmental impact Cultural environments The cultural environment covers a small area in the southern part of the planned site, and the degree of impact is assessed to be small; presumably any impact can be avoided completely by choosing a final location for the facility outside the designated area. This designated area coincides with the one around Kølstrup church. Protected church land There is a risk of impact on the surroundings of Kølstrup church if the facility is placed within the designated protection zone. Cultural heritage sites Within cultural heritage sites, any new buildings and facilities must be placed in a position that does not damage archaeologically sensitive remains from prehistoric and medieval times. They must also comply with Section 27(2) of the Museums Act: If traces of ancient relics or monuments are found during construction work, agriculture and forestry activities, the work must be suspended to the extent that it affects the ancient relic or monument. The Minister for Culture or the nearest cultural heritage museum owned or subsidised by the state shall immediately be notified of the ancient relic or monument.

140 134 of 234 Within the cultural heritage sites, there is a high probability of coming across items of historical value, but it is considered that the impact of the plan on cultural heritage sites, and hence on new finds, will not be significant. This is partly because the area required is limited, partly because the construction work will regularly be supervised, cf. the provisions of the Museums Act. The Viking Museum Ladby The plan is not considered to have any direct impact on the Viking Museum as it is a precondition that the facility is not placed within the Museum area and hence it will not affect the protected Ladby Ship. The indirect effects on tourism from the location of a permanent repository close to the Museum are discussed in section Repository types A near-surface facility will generally have a greater visual impact on the surrounding landscape and hence on the cultural environment. Other potential impacts are considered to be similar for any type of repository. Table Summary impact assessment. Environmental aspects - Cultural heritage Cultural environments Church surroundings Cultural heritage sites The Viking Museum Ladby Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes The cultural environment covers a small area in the southern part of the planned site; any impact can probably be avoided completely by choosing a final location for the facility outside the designated area. Yes Yes Any impact on church surroundings can be avoided by choosing the right final location. Yes Yes Any impact on cultural heritage sites can be avoided by choosing the right final location. No - It is a precondition that the facility should not be placed within the Museum area so it will not directly affect the protected Ladby Ship, cf. plan guideline no 8, Cultural Heritage. Assessment of impact None if the repository is located outside the designated areas. Minor to moderate if the repository is located inside the designated areas. None if the repository is located outside the designated areas. Minor to moderate if the repository is located inside the designated areas. None if the repository is located outside the cultural heritage sites. Moderate if the repository is located inside the cultural heritage sites. None

141 135 of Cumulative effects Cumulative effects are assessed by viewing the plan in conjunction with other plans or programmes, including previous, current and planned activities. Relevant plans and programmes may cover the same subject-matter, the same geographical area or a neighbouring area. The aim is to ensure that the plan is consistent with other relevant plans and programmes and to assess whether there is any risk of cumulative effects. As described in the sections above on each environmental factor, potential designation conflicts have been identified near Kertinge Mark in the form of e.g. landscape designations, church surroundings and cultural heritage sites. No higher-level plans or programmes have been identified within the site that might have an increased impact on the environment in combination with this plan Summary assessment The plan provides for the placement of a facility that may impact the environment in a number of ways, some of which are general effects regardless of the choice of location, as outlined in section 4.2. Implementation of the plan at Kertinge Mark could have local implications that must be taken into account in any subsequent planning and project design phase. Of these, the most significant are considered to be linked to the following factors: Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism (including the nearby Viking Museum Ladby), food production and the social structure in terms of a possible tendency for people to leave the area. With rising sea levels and more frequent storms, the planned site will be exposed to more destructive forces. To minimise the risk of flooding, account must therefore be taken of the placement of the facility on the site. If the facility is located in thick Paleogene clay deposits, the clay is expected to form an effective geological barrier. Kertinge Mark is situated within the designated coastal zone.

142 136 of THYHOLM The area near Hvidbjerg is located on Thyholm, a peninsula in the northern part of Struer municipality, on the south side of Limfjord, south-west of Mors and east of Thy. The site covers an area of approx. 6.6 km 2. The general background to the work on a plan to establish a permanent repository can be found in section 2, the planning guidelines are in section 3, while the methods used to analyse and assess the degree of impact are described in section 5. Figure 11-1 Outline map Thyholm Planning conditions This section presents the overall planning framework and strategies for the site in the form of Struer municipality s Municipal Plan and planning strategy. Struer Municipal Plan is based on the high-level targets set in the municipal planning strategy Struer municipality s development strategy The development strategy is the town council s political strategy, laying down a broad long-term approach to the future development of Struer municipality. It is future-oriented, taking as its point of departure current challenges in relation to underpinning and strengthening opportunities for growth and higher levels of residency /55/. The development strategy lays down the framework for development in the coming years and determines the level of revision of the Municipal Plan; for example, it was the basis for Struer Municipal Plan The starting point is the challenges faced by the municipality, and the strategy seeks to create a common understanding of the municipality s future role. According to

143 137 of 234 the Planning Act, the town council must adopt and publish a planning strategy every 4 years /55/. One of the strategy focus areas is the future effort to attract more residents to the municipality. A key factor in this context is the potential for attracting residents to the municipality, which is primarily linked to being close to humans, technology and nature Struer Municipal Plan In Struer municipality, the Municipal Plan is the high-level plan laying down the framework for activities that can and should be physically implemented in Struer municipality over the next 12 years in continuation of the development strategy. The Municipal Plan comprises extensive statutory provisions on area planning and on what residents and municipal authorities can do where and why, both in urban areas and in the countryside /56/ Biodiversity This section focuses on biodiversity, which in this context includes a description and assessment of the impact on Natura 2000, Section 3 of the Danish Nature Protection Act, wildlife corridors and national parks or nature reserves. It is assumed that the future facility will not be located in a Natura 2000 area, and that the plan will not have any significant impact on adjacent Natura 2000 areas; cf. plan guidelines. These topics are illustrated on map 4.1: Biodiversity. It is assumed that the local natural assets will be examined more closely in a later EIA study, which will include more detailed investigations of the specific site in the form of e.g. field studies Environmental status and objectives In Struer Municipal Plan, nature policy is about values and about awareness of and agreement on the qualities offered by the countryside. After that, a strategy can be laid down for preserving and improving these qualities and securing them for future generations. Struer municipality has set up a Green Council with a view to strengthening public involvement and providing inspiration and advice to political decision-makers primarily in relation to issues concerning nature and environment in the countryside. The Green Council comprises politicians and representatives of various stakeholders /56/. Natura 2000 The planned site borders on the following Natura 2000 area (Natura 2000 habitat area and bird protection area): Agger Tange, Nissum Bredning, Skibsted Fjord and Agerø, Natura 2000 area no 28, habitat area H28, bird protection areas F23, F27, F28 and F39. The area comprises several large marine sub-areas, including Nissum Bredning, and consists of shallow waters to the west and the deepest part of Limfjord, Oddesund, to the east. In the middle of the area is the protected shallow Skibsted Fjord, and furthest to the north-east are the many branches of the waters around Agerø. Furthest to the west are Agger Tange and Harbøre Tange with a number of coastal lagoons that are very important bird habitats. Coastal meadows, beach ridges and dry grasslands dominate the terrestrial part of the area. The area s valuable springs and alkaline fens are found mainly along the foot of the cliff and in the Dover Kil area, while dune types are found at Agger Tange. Section 3 protected nature Under Section 3 of the Nature Protection Act, it is prohibited to interfere with protected natural habitats in a way that could cause a change to the state of these areas. However, the local authorities may derogate from this provision /11/, often on condition of establishing some natural replacement.

144 138 of 234 Natural habitats covered by Section 3 of the Nature Protection Act are: Lakes and ponds of at least 100 m 2. Marshes, meadows, heaths, dry grasslands, coastal meadows and tidal marshes which individually or together cover an area of at least 2,500 m 2. Marshes under 2,500 m 2 are also protected if they are next to protected streams or lakes. Most streams and rivers are also protected via a special Section 3 designation. Lakes include both natural and wholly or partly man-made pools, basins and dams. The site contains few protected areas of natural interest (cf. Section 3 of the Nature Protection Act) in the form of coastal and other meadows and lakes. There are no streams in the area. Natural networks a green structure In order to create interconnected nature areas and nature corridors, a green structure has been developed. The green structure comprises a network of areas of natural interest and locations which are the primary habitats of plants and animals, running along the municipality s coast, around Kilen, along river valleys and around the town of Struer and other towns in the municipality. The green structure also links open spaces to the valuable nature and landscapes of neighbouring municipalities /56/. The green structure is a natural network consisting of: International nature conservation areas Nature quality plan nature with environmental targets A, B and C and potential nature in connection with these target areas Potential ecological corridors Protected areas Watercourses, lakes and coastal waters Low-lying areas Particularly valuable landscapes Within the planned site, green structures (marked as ecological corridors on map 4.1.) have been designated along the entire coast. Low-lying areas Low-lying areas are areas such as river valleys or former seabed which has been reclaimed for agricultural use, as well as adjacent areas affected by the lowering of the water level. Low-lying areas often have a potential for development into interconnected nature areas. Within the planned site, there are designated low-lying areas on the west coast at Grønholme and on the east coast north of Nørregård and at Styvelgårde. Beach protection Along the whole coast of Thyholm is a 300 m protection belt, i.e. the eastern and western fringes of the site are within the beach protection belt. Protected forest The vast majority of private woods and all public woodland in Denmark have the status of protected forest (fredskov) and are safeguarded by the provisions of the Forestry Act. The site includes a small protected forest in the north-western part of the Grøndal area.

145 139 of 234 National parks Thy National Park is located approx. 20 km to the west. On 29 June 2007, it was chosen by the Minister for the Environment as the first national park in Denmark. The National Park is of great national and international significance due to the many large dune heaths in the area from Hanstholm to Agger Tange, and it offers many opportunities for creating interconnected nature areas to the benefit of flora and fauna Assessment of environmental impact General It is impossible to define criteria for protecting the environment against radiation as there are no statistics covering the health impact of ionising radiation on animals and plants, as there are for people. Internationally, projects have been launched to determine the effect of ionising radiation on nature and, on this basis, to use reference animals and plants as a means of establishing criteria and producing subsequent safety analyses. The progress of these projects will be monitored and taken account of as far as possible in defining environmental protection criteria when the safety analyses are carried out in a later EIA phase /15/. Human beings are generally considered to be the organism that is most vulnerable to ionising radiation. Therefore, once criteria have been established to safeguard people, we may assume that animals and plants will be sufficiently protected against radiation. Exceptions to this assumption will mainly apply to a small population of a species in a restricted area around the repository /15/. The environmental protection criteria applicable to a given repository will be drawn up in conjunction with the mandatory EIA studies to be carried out for two selected sites if it is decided to proceed further with the permanent repository concept. In this connection, detailed field studies will be carried out as part of the basis both for assessing potential effects and for defining environmental protection criteria. This will ensure that local conditions are taken into account in the form of site-specific assessments concerned with protecting the environment. This section presents the general conflicts with nature conservation interests. Natura 2000 The planned site borders the Natura 2000 area. The scoping states that the impact on the Natura 2000 area will be investigated in connection with an impact assessment. However, in connection with the preparation of the Strategic Environmental Assessment (SEA) it has been assessed that there is no risk of any significant impact from the plan on the international protection area as the plan guidelines specify that the future facility may not have any significant impact on adjacent Natura 2000 areas (guideline no 7, Nature). The future planning and project design must therefore ensure that a facility can comply with these provisions. This will be determined by a materiality assessment, which will consider whether there is a risk of significant impact on the Natura 2000 area. If it is considered that there is a risk of significant impact, an impact assessment will be carried out. The purpose of this is to examine the potential impact in relation to the conservation goals for the area, and to incorporate mitigation measures into the project in order to avert any serious impact. So it is important to note that the guidelines in the plan and the assessment that there is no significant impact on the Natura 2000 area place a number of restrictive requirements on a future project, and that the project cannot be implemented if there is a risk of significant impact on the Natura 2000 area; cf. Habitats Order, Section 7(2) 3. 3 Executive Order on the designation and administration of international nature conservation areas and the protection of certain species, Order No 408 of 01/05/2007.

146 140 of 234 Section 3 protected nature There is a risk of impact on Section 3 protected areas where the facility itself or the access roads are positioned in direct conflict with the protected area. As the gross area is relatively large, there is every chance of placing the facility so that it does not affect protected areas. This consideration should therefore be included in subsequent planning and project design. No guidelines have been included in the plan to guard against conflicts with Section 3 protected areas, as other factors determining the ideal positioning may result in conflicts with Section 3 protected areas. Natural networks a green structure Plan guideline no 7, Nature, specifies that the placement of the repository should take maximum account of interconnected designated nature areas, wildlife corridors etc. Furthermore, most of the green structure coincides with the beach protection belt, within which the repository cannot be established. Hence it is very unlikely that there will be an impact on the green structure. Low-lying areas The designated low-lying areas will not be affected by the plan, cf. plan guideline no 12, Designated low-lying areas and potential wetland areas. Beach protection There is a beach protection belt along the entire coast, and it is assumed that the facility is placed outside this belt, cf. plan guideline no 9. Protected forest The protected forest at Grøndal is within the beach protection belt so there is no risk of impact. National parks There are no national parks in the area. Thy National Park is located approx. 20 km to the west. Repository types The three types of repository take up the same area, so will result in the same risk of impact to nature arising from any closing off of land and hence of a potential impact on Section 3 areas, natural networks, potential nature and protected forests. As mentioned above, it is assumed that Natura 2000 areas, beach protection belts and low-lying areas will not be affected whatever the choice of repository.

147 141 of 234 Table 11-1 Summary impact assessment. Environmental aspects Biodiversity Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Natura 2000 No - The guidelines to the plan state that a facility cannot be established under this plan if there is a risk of significant impact on Natura 2000 areas. The concrete assessment of whether the facility can meet this requirement will be made in a later EIA phase, when the location, repository type etc. are known. Section 3 protected nature Green structure Yes Yes Conflict with protected areas may be avoided by the choice of final location for the facility. Yes Yes Conflict with designated areas may be avoided by the choice of final location for the facility. Low-lying areas No - It is assumed that the facility will be located outside low-lying areas, cf. plan guidelines. Beach protection No - Plan guideline no 9, Building and protection lines, stipulates that the repository may not be located within the beach protection belt. Protected forest No - The protected forest is within the beach protection belt so it will not be affected. Assessment of impact None None or minor The degree of impact depends on the positioning of the repository. None or minor Plan guideline no 7, Nature, ensures that the placement of the facility should take maximum account of adjacent interconnected designated nature areas, wildlife corridors etc. Against this background, the impact is assessed to be little or none. None None None National parks No - Not relevant None 11.3 Population and health This section describes the location of the planned site in relation to built-up areas, the number of inhabitants, commercial activity, tourism and recreation. It is mainly based on information from Statistics Denmark and the Municipal Plan. The section then describes the potential impact on the population in terms of health risks and indirect environmental effects, including the risk of reduced revenue, relocation etc. The assessment of the impact is based on available information from e.g. descriptions of transport and radiation in the feasibility studies. It is assumed (cf. plan guidelines) that the facility will be designed to be able at any time to demonstrate compliance with the dose

148 142 of 234 constraints specified when in operation and after closure, both for these periods and for potential incidents (accident scenarios). Documentation of this will be provided in the form of safety assessments for the facility and its use. The assessment of the indirect environmental impact on the population and industry identifies potential effects based on an analysis of responses to consultation and comments from public meetings focussing on e.g. people s concerns about the effects of implementing the plan Environmental status and objectives Population The site is on predominantly agricultural land. Only 1-2% is covered by trees and bushes. Several small roads run through the area. There are a few houses along the roads. The distance to towns and villages can be seen in Table Table 11-2 Distance from major built-up areas. Distance from built-up area: Hvidbjerg: approx. 1.5 km Uglev: approx. 4 km Humlum: approx. 12 km Struer: approx. 15 km The population figures for the towns and villages and for Struer municipality can be seen in Table 11-3 (as of 2012). Table 11-3 Breakdown and number of inhabitants in Struer municipality (2012). The breakdown and number of inhabitants is as follows: Hvidbjerg: 1,181 inhabitants (2012) Uglev: 249 inhabitants (2012) Humlum: 845 inhabitants (2012) Struer: 10,544 inhabitants (2012) In recent years, rural areas and villages have seen a decline in population. Villages and open land make up a large part of Struer municipality approx. 40% of the population still lives in these areas. Nature contributes to making rural areas a different and attractive alternative to the opportunities offered by cities and towns with separate qualities and development opportunities including closeness to nature, local communities, houses and plots with unique locations. Consequently, a focal area in the development strategy is closeness to nature /55/. Struer Municipal Plan aims to incorporate amenity value and quality experiences into its planning and to support the physical framework of the Municipal Plan /56/. Industry As part of the analysis of the commercial conditions, the numbers of people employed in the whole of Struer municipality have been surveyed, broken down into tourism and leisure, agriculture, fishing and food production, as shown in Table These matters are considered crucial in terms of their impact on the population and health and the indirect socio-economic factors. The chart shows a selection of the key industries with an assessment of the socioeconomic factors, but in reality, employment will be greater because a number of other professions will be linked to these industries to a greater or lesser extent.

149 143 of 234 The analysis of employment has been carried out for the whole of Struer municipality, as it is felt that implementing the plan may affect a major part of the local community and not just the planned site itself. Struer is characterised by a relatively high number of jobs within the electronics industry and research and development, agriculture, building and construction, food industry, wood and paper industry, plastic, glass and concrete industries and transport /61/. Table 11-4 Breakdown of employment in Struer municipality within selected industries related to tourism and leisure, agriculture, fishing and food production, as of The total number of people employed in Struer municipality is 9,980 (Statistics Denmark 2013). The area is dominated by agriculture, and most of the site has been designated as a particularly valuable agricultural area, cf. section The local authorities wish to strengthen the position of businesses within the experience economy e.g. by promoting local produce, design and crafts /56/. Mussel fishing Danish waters have large, natural stocks of blue mussels, which makes many coastal areas particularly suitable for fishing blue mussels. The coastal areas are also suitable for cultivating blue mussels. Several of these attractive areas have been designated as Natura 2000 areas, and hence a distinction is made between fishing inside and outside Nature 2000 areas. Fishing for blue mussels takes place within a number of designated production areas. Today, blue mussels are caught in Isefjord, Limfjord and on the east coast of Jutland. The waters around Thyholm have been classified as production area no 23 in Limfjord West /60/. Tourism Struer Municipal Plan contains guidelines for development of the basis for tourism within the municipality. One way to boost the potential of the municipality is to further develop the qualities already existing. Nature should be the foundation and the point of departure, while access to coastal outdoor facilities and activities and the quality of such facilities should be made more attractive. Struer municipality attaches great importance to tourism in terms of industry and jobs and will work to support initiatives and collaboration with focus on tourism. This could also benefit rural areas within the municipality.

150 144 of 234 Recreational areas There are no summer cottage areas, camping sites or designated bathing beaches or trail systems within the area. In the Municipal Plan, the entire Limfjord is identified as a recreational area, and the aim is to promote broader cooperation across municipal and regional borders in relation to marketing of the Limfjord area and common themes such as Limfjord storytellers, boat building traditions, etc. /56/ Assessment of environmental impact The assessment of the impact on the population covers health (related to transport, risk of accidents and radiation, safety and security of the facility itself), and socio-economic factors, including the population, commercial interests, tourism and recreational activities. Health Radiation protection The health impact of radiation from the facility itself and from accidents is described in section 4.2, as the same requirements apply to safety assessments and official approval regardless of the choice of site. Transport Based on the feasibility study, we conclude that both road and sea transport may be considered. The radiation doses estimated for transport of Danish radioactive waste from Risø to a future permanent repository in Denmark are calculated on the basis of the greatest possible distance to any repository. The estimated doses in the feasibility study are therefore upper limits, and doses from shorter transport routes will be proportionally lower. The study shows that the risk associated with road and sea transport does not restrict the future selection of a location for a repository in Denmark, and that the transport can be handled so that the dose is well below the national thresholds. The three locations in Jutland Thyholm, Thise and Skive involve the longest transport routes from Risø, whether road or sea transport is chosen. Changes in distance have no effect on doses in the event of an accident. The likelihood of an accident is dependent on factors such as the quality of the road and the volume of traffic, and is also proportional to the distance. Compared to the zero alternative, the radiation dose is greater in the short term as a natural consequence of the fact that, in the zero alternative, the waste will not be processed as much, or transported from the location. In the longer term, it will be necessary to process and possibly transport the waste under the zero alternative too, as Risø does not have the status of a permanent repository. Socio-economic factors Apart from the general issues mentioned above, the stakeholders have drawn attention to a number of local matters that should be given special consideration in the choice of destination and in implementing the plan if a repository should become a reality in their particular area. These are summarised in Table This is used as part of the background to the description of the potential impact on the population and the socio-economic factors, and also forms the basis for suggested mitigation measures (section 15.2).

151 145 of 234 Table 11-5 Summary of the major concerns raised by stakeholders on Thyholm*. Subject Groundwater, surface water and climate change impact on fishing and agriculture Thy National Park and Grønholme Radon Access roads and accidents Description Stakeholders around Thyholm near Struer express particular concerns about the area s future water supply and groundwater as there are local waterworks that supply Thyholm and Jegindø. Furthermore, stakeholders point out that Thyholm is surrounded by water and likely to be covered by water in the future due to rising sea levels as a result of climate change. In this connection, stakeholders express concerns about fishing including whether the plan might have an impact on exports of mussels. At a more general level, stakeholders are afraid that the establishment of a permanent repository might damage the green image of the area and production of organic food and other goods such as oysters and malt barley. Specifically, it was mentioned whether the project could affect the Arlagården brand and whether Arlagården would thus be willing to receive produce from areas near the repository. Stakeholders also draw attention to a potential impact on Thy National Park and point out that Grønholme is a protected area for birds part of the year. Stakeholders are concerned about whether the Thy National Park concept can survive with a permanent repository in the area and whether a repository might affect biodiversity in the National Park especially birds and the crested newt. These factors all contribute to the local brand and to making the area attractive for tourists. Hence, development of the area is to a large extent based on experience tourism with focus on nature and locally grown food. Stakeholders also point out that there is radon in the ground and higher background radiation on Thyholm than in the rest of Denmark. So it is important for stakeholders that a repository does not contribute further to radiation. At a more practical level in relation to the establishment and operation of a permanent repository, stakeholders express concerns about transport to the repository along small, narrow municipal roads, which will increase the risk of accidents. There is also insecurity among inhabitants in Hvidbjerg, which is located on the expected transport route. *This description is extracted from minutes of the public meeting held in Hvidbjerg on Thyholm and from responses to consultation on the scoping report. Summary The questions relating to the establishment of the facility itself, and the practical problems that may arise as a consequence, are not dealt with in depth in this report because of the level of detail in the plan. The project-specific issues with question-marks against them will be addressed in a later phase, when risk assessments and radiation protection work will be carried out in conjunction with the subsequent work by the authorities once there is an actual project. This applies to e.g. exposure to radiation (including radon), access roads, traffic routes and risk of accidents. The following subjects are addressed at a high level in other sections of the environmental report: Groundwater and surface water are discussed in section 11.6, Climate is discussed in section Nature is discussed in section 11.2, but the plan is not assessed to have any direct impact on Thy National Park. The indirect implications of concerns with a bearing on the plan are described below. If we look at the comments from stakeholders of both a general and a local nature, we see that they are marked by a high degree of concern. These concerns are directed at a broad and diffuse set of risks, which indicate a lack of knowledge of the real risks involved in implementing the plan and of the measures that have been and will be taken to avert these risks. The comments also show that the stakeholders do not have sufficient knowledge of the process to be followed in the future, leading to widespread insecurity and mistrust. The stakeholders do not feel convinced that the future process will adequately examine and address the perceived risks and involve the stakeholders, to ensure that local interests are safeguarded. For these reasons, the analysis shows that the plan to establish a repository has received a very negative response from the stakeholders.

152 146 of 234 This negative attitude, insecurity and mistrust of the plan and the projected process create the ideal conditions for a number of negative social effects to become reality. In such a situation, it is not inconceivable that a permanent repository could have indirect negative effects on immigration to and emigration from the area, land and property prices, sales opportunities for goods, including exports of mussels and local organic food and produce, such as oysters and malt barley, due to the impact on the area s brand. In addition, the general mental well-being of residents in the area, etc. may be affected purely because of insecurity and mistrust. It is therefore crucial to the social effects of the plan that the insecurity and mistrust should be reduced. Overall, there may be a risk of impact on socio-economic factors, including tourism and the food industry. Hence the plan could clash with the high-level strategies and visions for the area as described in e.g. Struer Municipal Plan. Table 11-6 Summary impact assessment. Environmental aspects Population Health Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Radiation protection Securing the facility Yes Yes The impact in the immediate vicinity will depend on the final location. Yes Yes A vulnerability assessment should cover different scenarios and their consequences. These scenarios should be covered by security and contingency plans designed to assure the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the dose constraints) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraint. As with the category of transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the dose constraint) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraint. As with the categories of radiation protection and transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses.

153 147 of 234 Environmental aspects Population Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Transport Yes Yes The impact in the immediate vicinity will depend on the final location. Noise, heavy traffic and emissions may have an impact in connection with transport within the planned area. Socioeconomic conditions Yes Yes/No. In recreational areas etc. the impact may be dependent on the final location, but the general concern about the impact on the population and industry is considered to be independent of the final location and in many cases people expect an impact beyond the planned site itself. Implementing the plan may cause indirect effects on the population and socio-economic conditions. The stakeholders highlight a number of issues that cannot be addressed at this introductory stage of the planning process, but these issues will be examined more closely in an EIA phase and in conjunction with safety analyses and official approvals. Assessment of impact Minor (below the thresholds for exposure to radiation). Estimated doses for transport to the planned site are well below the dosage thresholds. There will be a need to plan transport routes, times etc. to achieve a reduction of risks and potential doses. Moderate to significant The impact is judged to be of moderate to significant importance because of the high level of concern and the uncertainty expressed among the stakeholders. This should therefore receive close attention in the later phases Landscape and geology This section presents geographical and geological conditions within the planned site, which here encompass a high-level description of the landscape and any designated areas and a description of the geological conditions based on the feasibility studies, with any designated features. These topics are illustrated on map 4.2: Landscape and geology. The assessment of the impact on the landscape is based solely on whether there is a risk of impact on valuable landscapes and designated coastal zones. It is assumed that the real impact on the landscape and visual factors will be determined in a later EIA study, where landscape analyses, visualisations etc. can be based on the choice of a specific location and a concrete project proposal. The purpose of examining the geological conditions is to assess the degree of uncertainty as to the ability of the geological conditions to act as a physical barrier around a possible repository. It is assumed that the local geological conditions will be examined in more detail in a later EIA study Environmental status and objectives Landscape Landscape description This site is located in the north-eastern part of Thyholm. The landscape is homogeneous, with regular undulations on top of the generally gentle slope from the highest terrain in the southwest (at an altitude of 25 m) to the north (sea level to +10 m) and north-west (sea level). There is a single hill to the east, close to the coastline. The boundary follows the coastline to the west and east and there is a narrow marine foreland along the west coast. The east-facing coast features the presence of a low coastal cliff, which is generally covered by vegetation with almost no erosion.

154 148 of 234 Due to the limited relief and intense cultivation, all surface processes are slow and undramatic. Greatest activity is seen along the coast, but at coastal locations the waters are generally calm and very narrow with limited possibilities of wave formation. Designated coastal zone The designated coastal zone is defined in the Planning Act and is approx. 3 km wide. The rule is that the designated coastal zone must be kept free from buildings and facilities that are not dependent on proximity to the coast. Thyholm is situated within the designated coastal zone. Planning Act: Section 5b. The following shall apply to planning in the designated coastal zone: 1) It is prohibited to transfer land to an urban zone or to conduct planning for development in a rural zone unless there is a specific planning-related or functional justification for location near the coast. Landscape character analysis Struer municipality has prepared a landscape analysis with a view to identifying areas requiring special attention and areas that are less vulnerable. The point of departure has been the landscape character methodology, which is the methodology that the central government encourages local authorities in Denmark to use when analysing the landscape. Struer municipality is divided into 10 landscape character areas. The site is located in landscape character area 9 Thyholm. In the analysis, the landscape on Thyholm is described as a landscape with large hills and undulating terrain, characterised by agricultural production. There are living hedges of Swedish whitebeam and dykes with sparse vegetation around medium-sized fields. In many places, there is an extensive view of the landscape, and especially in the coastal foreland there is a visual connection across the narrow waters to the opposite coasts. Technical installations, especially small and medium-sized wind turbines, are part of the landscape in many places, also within the planned site /62/. Most of the planned site is within an area described as characteristic, while a small area in the northern part of the site is described as particularly characteristic. Coastal landscapes are assessed potentially to offer special views and are also assessed to be particularly vulnerable. The coastal foreland is generally assessed to be particularly vulnerable to technical installations that could disturb the landscape or its tranquillity /62/. Major continuous landscapes Within the major continuous landscapes, the local authorities wish to strengthen efforts to develop more nature, improve the opportunities for versatile outdoor activities and promote recreational opportunities close to urban areas. The designated coastal areas on Thyholm are major continuous landscapes. Particularly valuable landscapes and other landscapes The purpose of splitting the landscape into particularly valuable landscapes and other landscapes is to protect the landscape from the impact of structures and installations that are contrary to its special character by laying down guidelines for each landscape category.

155 149 of 234 The coastal landscapes on Thyholm are designated as landscapes worthy of preservation; the western part of the coast is defined as a natural coastal landscape, while the eastern part is a man-made coastal landscape. Geology A detailed discussion of the geological conditions can be found in GEUS report no 4 /4/. Under Ice Age deposits with a thickness of up to 20 m, there are large, accumulated layers of earlier Paleogene and Neogene fine-grained clay deposits. However, the structural conditions seem to be complex and shifts in connection with fault movements and interruptions of sedimentation may have made the strata less undisturbed and coherent. The following description is a summary of the geological conditions described in the local area study. Deposits and soil types The deposits under the Ice Age deposits are relatively complex. Under the Ice Age deposits there are deposits from the upper Oligocene Brejning formation or the lower Miocene Vejle Fjord formation, consisting of fine-grained and silty, slightly micaceous clay and clayey micaceous silt, respectively. Under the Brejning formation, several other units can be found within the area. Fine-grained olive-green chalk-free clay of varying thickness is assumed to belong to the Oligocene Branden clay. Under this formation, diatomite (moler) has been found, as well as volcanic ash from the Eocene Fur formation, and in a new bore hole Palaeocene Kerteminde Mergel has been found below 4 m Brejning formation. To the south, the bore holes reach Danian chalk under 20 m Quaternary deposits. The finds of geological units in the bore holes point to significant faults in the strata, presumably due to tectonic movements during several Palaeogene and Neogene periods. These aspects do not indicate a thick continuous clay structure in the area, although the bore holes reveal a clear preponderance of clay deposits down to a great depth. The Quaternary deposits (Ice Age deposits) covering the Palaeogene and Neogene deposits are dominated by clayey till. The top stratum is 4-11 m clayey till, but meltwater sand and gravel layers are often found below this clayey till. Still further down, there are a few meters of clayey till in several places, and up to 8 m thick meltwater clay. Just outside the area, there are Quaternary deposits with a thickness of up to 67 m. Mineralogy binding adsorption The geochemical conditions in the deposits have a bearing on how radioactive material will behave if it should leak out of a repository into the surrounding geological strata. Some general observations are set out below. However, the large number of radioactive components in the waste may behave differently in the surrounding deposits. A key element is that the radioactive material should be able to bind to the deposits. There are no details of the uppermost layers, which consist of clayey till and meltwater sand and gravel. Heavy meltwater clay is found in many bore holes and exposed locations. Grain-size analyses of the clay show that it consists of 45% clay particles while the rest is silt (quartz), but presumably the clay content could be higher in some places. The clay mineralogy shows the following: 51% smectite, 25% illite and 24% kaolinite. In the reduced zone, the smectite content may be lower. The Vejle Fjord formation consists of silt with a lower clay content. There is 15-30% smectite, 40% illite and 30% kaolinite on average. Clay from the Brejning formation is made up of 50% clay fraction and 40% silt with very little coarse material such as glauconite and pyrite (10%). The clay mineralogy is 30-40% smectite,

156 150 of % illite and up to 30% kaolinite. The mineral composition may be different in East Jutland, for example. Branden clay comprises 50% clay fraction and 50% silt, and the mineralogy is 20-50% smectite, 30-60% illite and the rest kaolinite. Kerteminde Mergel comprises 61% clay fraction, 38% silt and 1% sand (glauconite and pyrite). There is a high CaCO 3 content of 40-60%, while the clay mineralogy is 80% smectite, 20% illite and no kaolinite. Clay minerals, especially smectite clay minerals, are particularly well-suited to binding radioactive material. They are present in relatively large but varying quantities in the deposits. This means that the clay deposits have the potential to bind the radioactive components. Redox conditions The behaviour of the radionuclides in relation to the oxygen content in the strata and groundwater (redox conditions) will depend on the types of chemical compounds and chemical properties involved. The concentrations of these components in the strata and the water, and their ph, also have a bearing on the processes that will occur. There is oxygen present in the uppermost layer of soil (the oxidised zone), and this may for example mean that some radioactive components can be made mobile and hence transported more easily. Conversely, the conditions in the oxygen-free (reduced) zone, for example, will help to bind and hold other radioactive components. In the Thyholm area, the oxidised zone seems to continue to between 4 and 11 m below ground level. In other words, some of the Quaternary clayey till, the meltwater clay and the Paleogene and Neogene clay deposits are in the reduced zone. Natural radioactive components in the deposits There are no measured values for the area, but measurements on black micaceous clay, black clay and diatomite in nearby areas show high uranium and radium contents: Micaceous clay, Vejle Fjord formation/brejning formation: Bq/kg radium Diatomite, Fur formation: Bq/kg radium Black clay, Palaeocene: up to 300 Bq/kg radium Assessment of geological conditions The geological conditions influence the impact of the repository on both surface water and groundwater. The geological conditions need to be consistent and stable within the site and they must contribute to the stability of the repository. The geological strata should help to isolate the waste from the surroundings by enclosing or underpinning the repository. The rocks should be low-permeable and help to bind the radioactive components from any discharge from a repository /15/. These issues are assessed in Table In the table, the geological conditions are assessed only in relation to a repository placed in the pre-quaternary rocks, in this case the Paleogene and Neogene clay rocks. If the repository is located in Quaternary deposits, clayey till probably containing fractures and sand lenses and occasional sand and gravel layers will only partly isolate the waste from the surroundings.

157 151 of 234 Table 11-7 Assessment of the geological conditions in terms of stability, low-permeable rocks and binding of radioactive components. Property Assessment Comments Consistent and stable geological conditions contribute to the stability of a repository. Yes There are large, accumulated layers of Paleogene and Neogene fine-grained clay deposits in the area. However, structural conditions appear to be complex and must be mapped in detail in connection with any specific project so as to ensure that geological conditions are consistent and stable in the project area. In addition, geotechnical stability must be The geological strata help to isolate the waste from its surroundings: Low-permeable rocks. The geological strata help to isolate the waste from its surroundings: Binding of radioactive components. Yes Yes addressed in any specific project proposal. The Paleogene and Neogene clay deposits are generally low-permeable. The Paleogene and Neogene clay rocks have a high content of clay minerals, including a high content of smectite. Clay minerals, especially smectite, are particularly well-suited to binding radioactive material. This means that the Paleogene and Neogene clay rocks have the potential to bind the radioactive components. Areas of geological interest In geological conservation areas, establishment of buildings/structures and technical facilities, as well as changes to the use of land that may reduce the character and characteristics of the geological landscapes and formations, must be assessed on the basis of the characteristics of the geological landscapes and formations, geological development and historical geological importance. Struer municipality seeks to preserve areas of geological interest, as such areas are of great importance in terms of experiencing and understanding how the landscape was originally created. The large geological differences within the municipality are reflected in the different living conditions for humans, animals and plants /56/. The whole coastline of the area has been designated as a valuable geological area and an area of national geological interest. The designated area is known as Kås Bredning-Skibsted Fjord. The entire location comprises the coasts around the north-western parts of Kås Bredning and Skibsted Fjord. These coasts give a good impression of the coastal landscapes of Limfjord, with varying open stretches and exposures. The marine foreland displays great variation and contains numerous form elements. Especially angular foreland and tongues of land jutting out at sharp bends in the coastline are common. Of particular value is the angular foreland embracing Nørskov Vig on the northern tip of Venø /59/. Summary There are large, accumulated layers of early Paleogene and Neogene fine-grain clay deposits (up to 100 m), and clay layers throughout the area. However, the structural conditions seem to be complex and shifts in connection with fault movements and interruptions of sedimentation may have made the layers less undisturbed and coherent. These clay deposits have good properties in relation to retaining any radioactive material leaking from a repository. The fine-grained clay deposits are overlaid by up to 20 m late Quaternary strata mostly made up of clayey till. Experience shows that clayey till contains fractures and sand lenses. But there are also layers of meltwater sand and gravel.

158 152 of Assessment of environmental impact Landscape The coastal areas on Thyholm are designated as major continuous landscapes and landscapes worthy of preservation; the western part of the coast is defined as a natural coastal landscape, while the eastern part is a man-made coastal landscape. A future facility may conflict with the designated status if it is found that it causes a significant change to the landscape which conflicts with its special character. It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location and the repository type have been decided. Conflict can be avoided by placing the facility outside the designated landscapes. Part of the site is within the designated coastal zone. Before a facility can be located in the designated coastal zone, the planning and functional justification for the designated coastal location must be stated. There should also be a description of the visual impact, which will depend on the repository concept and design. If it decided to choose a design to make the facility recognisable and visible, e.g. for safety reasons, this will immediately make a greater visual impact than a repository concept that is more integrated into the landscape. The final assessment of the scale of the impact will be made as part of the EIA studies. Repository types It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location has been decided and there is a description of the repository type, dimensions, choice of materials and colours, planting, fencing etc. Geology The plan is not expected to affect the general geological conditions significantly, but the geological conditions have a major bearing on the suitability of the site for the establishment of a repository. The geological description will therefore be used as background material to any assessment of the impact on groundwater and surface water. The plan may affect the national area of geological interest Kås Bredning-Skibsted Fjord as this area is of landscape value. Any impact will not be considered at this stage of the planning, but will be part of a subsequent EIA process. Repository types The potential impact on the geological features is expected to be similar for each of the three repository types, as the total surface area required will be the same whatever repository type is chosen.

159 153 of 234 Table 11-8 Summary impact assessment. Environmental aspects Landscape and geology Designated areas Designated coastal zone Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes The coastal areas on Thyholm are designated as major continuous landscapes. The coastal landscapes on Thyholm are designated as landscapes worthy of preservation; the western part of the coast is defined as a natural coastal landscape, while the eastern part is a manmade coastal landscape. Yes Yes Half of the site is within the designated coastal zone. Assessment of impact None if the repository is located outside the designated area. Minor to moderate if the repository is located inside the designated area. A final assessment of the impact requires an actual project and visualisations to be produced in a future EIA phase. None if the repository is located outside the designated coastal zone. Geological designations Yes Yes The whole coastline of the area has been designated as a valuable geological area and an area of national geological interest. Moderate if the repository is located inside the designated coastal zone. A final assessment of the impact requires an actual project and visualisations to be produced in a future EIA phase. None if the repository is located outside the designated areas. Moderate - if the repository is located inside the designated areas Climate Climate change could affect the future repository because of the increased risk of extreme events. This section describes the future scenarios that are being examined in Denmark and abroad, to serve as a basis for assessing whether the planned site is expected to be significantly affected by changes in the climate. It is assumed that a future facility (see plan guidelines), via its design and placement in the landscape, will be adapted to any future climate change and thus less vulnerable to extreme events /4/ Environmental status and objectives Based on the latest Danish and European scenario analyses, the Danish Meteorological Institute (DMI) has described the expected future climate changes in Denmark out to The assessments are based on the scenarios used by the UN s International Panel on Climate Change (IPCC) /20/. The changes are expected to increase towards the year Considerations of climate change are relevant to the placing of the repository because of the risk of rising sea levels flooding the facility, which could lead to penetration by surface water and hence an increased risk of radioactive substances spreading into the environment. The DMI report suggests that Denmark will experience warmer and wetter weather in the future, with more extreme events such as longer periods of drought and heavier rainstorms, and

160 154 of 234 temperature increases. It also projects a general rise in sea levels in the waters around Denmark /20/. More recent projections are now pointing to even greater rises in sea levels around Denmark, ranging from 80 ±60 cm to max. 150 cm by There may be further increases towards 2200, but estimates are extremely difficult and fraught with very great uncertainty /20/. The site is located on a peninsula bordered by the coast to the north-west and east. To the northwest, running inland from the coast, is an approx. 1 km 2 large area rising from sea level to +5 m. In this area there is a narrow bar of marine foreland. The rest of the area is at a considerably higher altitude, up to +25 m. The area appears as a slightly to moderately undulating landscape, without any streams or lakes. On the eastern coast is a low coastal cliff with vegetation and hardly any erosion Assessment of environmental impact Rise in sea level If the sea level rises as forecast, part of the narrow marine foreland can be expected to be flooded around the year 2100, and any erosion of the eastern coastal cliff will presumably intensify and spread to a larger area. Even if we project a rise of at least 80 cm in the seas around Denmark (in 2100), it is hard to predict the effect of an increase in Limfjord. With a rise of 80 cm, small parts of the peninsula will be flooded, and we may expect increased erosion of the coastal cliffs. Land uplift in the area is estimated at between and mm per year, and if this continues, it will help to reduce the effect of rising sea levels albeit to a modest extent /4/. Extreme events Northern Thyholm is affected by North Sea storm surges and floods due to its geographical location in the western part of Limfjord, which is connected to the North Sea via the 700 m wide Thyborøn Channel. As long as the Thyborøn Channel is open, storm surges and high water in this part of the North Sea will be reflected in the western part of Limfjord, including Thyholm /4/. Repository type The planning guidelines describe how the facility will be constructed to ensure that it can cope with sudden floods (climate-proofing), whereby the surroundings will be safeguarded against emissions even in the case of climate change and extreme rainfall. Table 11-9 Summary impact assessment. Environmental aspects Climate Rising sea levels Extreme events Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes By far the biggest part of the site will not be affected by an 80 cm rise in sea level, but it is important to allow for a future placement of the facility on the site that avoids any impact from future rises in sea level on the low-lying areas. Yes Yes Northern Thyholm is affected by North Sea storm surges and floods due to its geographical location in the western part of Limfjord. Assessment of impact None or minor provided that account is taken of the placement of the facility on the land. Plan guideline no 11, Climate, also describes how allowance will be made for climate change in the design and placing of the repository. None or minor

161 155 of Water This section describes the issues relating to groundwater and surface water within the planned site. It is based on information from local area studies and municipal designations. The impact assessment is based on the descriptions of the geological conditions (section 11.4), as the impacts on groundwater and surface water depend largely on these. Drinking water interests are illustrated on map 4.3: Drinking water interests. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site Environmental status and objectives Groundwater General In connection with the Danish Nature Agency s designation of bodies of groundwater in the Thyholm area, near-surface, regional and deep bodies of groundwater were located in the Hvidbjerg area. According to the Danish Nature Agency s baseline analysis, the near-surface and regional bodies of groundwater consist of meltwater sand, while the deep body is chalk. However, a review of the relatively few bore holes in the Hvidbjerg peninsula, combined with the fact that there is hardly any water supply on the peninsula, gives the impression that there are no regional or deep groundwater reservoirs on the Hvidbjerg peninsula /4/. Hence, there are only small nearsurface groundwater reservoirs on the peninsula. To the south is the local Hvidbjerg groundwater reservoir, which is located south and south-east of the village of Hvidbjerg. The reservoir consists of meltwater sand and gravel. The groundwater in the area is assessed to flow towards the north-east. In other words, the Hvidbjerg reservoir is upstream from the Hvidbjerg peninsula. However, the data supporting this assessment is extremely limited. Drinking water interests The most important groundwater resources for drinking water supplies are designated as areas of special drinking water interests (Danish: OSD), which are meant to cover current and future needs for water of drinkable quality. In these areas, an extra effort will be made specifically to safeguard the groundwater, in order to prevent contamination and remove any existing pollution. OSDs are the core areas for this targeted groundwater conservation. This means that such areas are regarded as strategic catchment areas and that the municipalities need to take account of the groundwater resources and catchment areas for public waterworks in their physical planning. In the feasibility studies, OSD areas were deselected as potential locations for a permanent repository, but it was not possible completely to avoid areas of drinking water interests (Danish: OD). Most of the designated site is in an area with no or limited drinking water interests (Danish: OBD). To the south, the site borders on an OD area. Furthermore, there is an OSD area further to the south, near the village of Hvidbjerg. The nearest waterworks is Thyholm Private Fælles Vandværk (TPFV), which is located at a minimum distance of 1,500 m from the southern border of the designated Thyholm site. Within the area, there is one individual well. There are no irrigation wells. Thyholm Private Fælles Vandværk is believed to be located upstream from the Hvidbjerg peninsula. Groundwater chemistry, based on in water chemistry data from TPFV, indicates that the water quality is good. This is in accordance with the water management plan prepared for the area.

162 156 of 234 Summary There are very small local near-surface groundwater reservoirs in the area. South of the area, just to the south of Hvidbjerg, is a groundwater reservoir consisting of meltwater sand and gravel that supplies Hvidbjerg with drinking water. Surface water The site is covered by the proposed water management plan for Limfjord. The water management plan covers approx. 7,600 km² and affects 18 municipalities: Brønderslev, Herning, Hjørring, Holstebro, Ikast-Brande, Jammerbugt, Lemvig, Mariagerfjord, Morsø, Randers, Silkeborg, Skive, Struer, Rebild, Thisted, Vesthimmerland, Viborg and Aalborg /64/. There are no streams within the area, but a few scattered lakes and ponds. South-east of the area, east of Hvidbjerg, is a stream running into Limfjord at Borregård. The water management plan does not include specific environmental targets for any of the small streams, but the target for Limfjord is good ecological status Assessment of environmental impact Groundwater The feasibility studies show that the groundwater level may have to be lowered if a repository is established. Particularly wells, but also bore holes, will be susceptible to drying out if the water table drops. On the Hvidbjerg peninsula, with its small local groundwater reservoirs in meltwater sand and gravel, it is judged that drying out of bore holes may occur locally, but that this is not a general problem due to the limited number of supplies (one individual well, no irrigation wells). It is assessed that lowering of the groundwater level on the Hvidbjerg peninsula will not have any impact on the groundwater level or water quality of the groundwater reservoir located to the south and south-east of the village of Hvidbjerg, from which water is pumped up for Thyholm Private Fælles Vandværk. Over time, it is possible that water could seep into the facility and polluted water could seep out in the longer term. Depending on the location and design of the facility, this could have varying degrees of negative impact on groundwater and surface water. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow across the surface or in drains to the sea or into streams, or infiltrate the groundwater. The risk of surface leakage from a near-surface facility is considered to be minimal, as the plan guidelines assume both that the facility will be placed on a horizontal site and that surface water will be handled within the project site. With a near-surface repository going down to 30 metres below ground, or an intermediate depth facility, there could be seepage directly into groundwater reservoirs or covering layers. If the facility is placed in thick Paleogene or Neogene clay rocks, this clay is assessed to constitute an efficient geological barrier that will prevent seeping or transport to groundwater reservoirs. Contaminated water seeping into or infiltrating the groundwater will find its way into the general flow of groundwater into the reservoirs (in this case, small local groundwater reservoirs in meltwater sand and gravel and sand lenses in clayey till). The water could flow into bore holes and wells supplying individual properties, or into the sea, watercourses or springs. There is not felt to be any risk of contaminated water flowing into public waterworks. Surface water As described under Groundwater, it is possible over time that water could seep into the facility and polluted water could seep out in the longer term, affecting the surface water.

163 157 of 234 In addition, there is a risk of seeping on the surface. There are no streams within the area, but a few scattered lakes and ponds which could potentially be affected. The nearest stream is southeast of the area, east of Hvidbjerg. The impact may occur both as the repository is being filled and in the longer term, when it is closed. The degree of impact will vary greatly depending on the repository type. Repository types Both a near-surface repository and an intermediate-depth repository would entail a risk that contaminated groundwater could flow into the surface water, i.e. the streams in the area: Vaseå, Sølyst Bæk and Gyldenså. With a near-surface repository there is also a risk of surface water, i.e. streams, lakes and the sea, being polluted in the event of an accident causing a leak or of other seepage from the facility. In the period in which the facility remains open, it will be possible to monitor this impact and take the necessary mitigation measures, but the long-term effects are more uncertain as this plan does not lay down any guidelines in the event of the facility remaining in operation beyond the 30 years it is expected to stay open. Proposals for mitigation measures and monitoring can be found in sections 15 and 16. Table Summary impact assessment. Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Groundwater Yes Yes The impact on groundwater depends on the location of the facility. If the facility is located in thick Paleogene and Neogene clay deposits, the clay is expected to form an effective geological barrier to the extent that the deposits are consistent and continuous. Drinking water interests No Yes A small area furthest to the south in the large gross area has been designated as an area of drinking water interests. In the rest of the gross area, there are no drinking water interests or catchment areas for public water supplies. Hence, drinking water interests are not found to be affected if the facility is placed outside the area of drinking water interests. Surface water Yes No/Yes The potential conflict arises from potential leakage from a near-surface or intermediate depth facility with seepage into the groundwater and from there into streams, lakes or the sea. An intermediate depth facility is not expected to carry any risk of direct impact on Assessment of impact Minor Plan guideline no 3 (Requirements for geological conditions) ensures that any repository will be located in suitable geological formations, so the impact will be limited. None If the facility is placed in thick, Paleogene and Neogene clay. None if the facility is located outside the area of drinking water interests. Minor if a nearsurface repository going down to a depth of 30 m is established, and not located in thick Paleogene and Neogene clay. None if a nearsurface repository is established on the

164 158 of 234 Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments surface water. Any leakage from a nearsurface facility onto the ground will be handled within the repository site, so there is no surface discharge of contaminated water running into streams, lakes or the sea. Assessment of impact ground or the facility is located in thick Paleogene and Neogene clay; see the description of the impact on groundwater above. These matters will be examined more closely during the detailed field studies to be carried out under the Project Planning Act and possibly during the EIA study Soil This section describes the potential impact of the plan on the soil. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site, e.g. in relation to identified contaminated land Environmental status and objectives Contaminated land An analysis of contaminated land pursuant to the Soil Pollution Act may be carried out at either knowledge level 1 (V1 analysis based on reasonable suspicion) or knowledge level 2 (V2 analysis based on actual studies). The two terms therefore only cover a description of whether the property has been examined and give no indication of how contaminated a property might be and with what substances. In this situation, no analysis of the known contaminated land on the site is being carried out, because the scoping found that the plan would not conflict with any existing soil contamination, as it would not prevent a future public clean-up effort. There may also be several pieces of contaminated land on the site which have not yet been analysed, so it is assumed that more detailed studies will be made of the soil in the relevant location in connection with a future EIA study Assessment of environmental impact Handling of soil During the construction phase, soil will be handled in line with the municipality s guidelines on soil handling. Soil contamination As described in section , there may be an impact on surface water resulting from discharges of substances via seepage into the groundwater. In the same way, substances may be discharged into the soil on the surface. The extent of this impact and the likelihood of it occurring cannot be assessed from the information available at this time. An EIA study involving more detailed investigations of the actual location and a project to produce a detailed description of the barriers will be able to produce a more differentiated assessment of the risk of impact on the soil. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow over the surface into the topsoil.

165 159 of 234 Table Summary impact assessment. Environmental aspects - Soil Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Soil Yes No The potential impact on the soil is linked to any leakage and seepage of contaminated substances via the groundwater. Minor 11.8 Tangible assets This section deals with tangible assets, which in this context means a presentation of interests associated with agriculture, raw materials and afforestation. It focuses on potential conflicts with areas designated in the Municipal Plan as special agricultural, raw material or afforestation areas. These topics are illustrated on map 4.4: Tangible assets Environmental status and objectives Agriculture Particularly valuable agricultural areas Within the Municipal Plan s agricultural areas, agricultural interests are given a high priority. Most of the areas delimited as agricultural land are intensively farmed. This is mainly where the development of intensive agricultural production takes place. Planning of agricultural areas is aimed at ensuring that the areas most suitable for cultivation are reserved for agriculture whenever possible /56/. Most of the site has been designated as particularly valuable agricultural areas, the areas near the coast being exceptions. Raw materials In the south-western part of the area near Grøndal, quarrying areas for raw materials have been designated. For a small area located close to the coast a digging permit has been issued. Afforestation Areas where afforestation is not wanted Areas where afforestation is not wanted are designated because forest can disturb landscape forms and hide views or be contrary to other area interests such as natural assets, cultural historical monuments, geological formations and raw material extraction. Much of the planned site has been designated as an area where afforestation is not wanted. Only the central part of the planned site is exempt from this designation. Areas where afforestation is wanted When designating afforestation areas, account is taken of protection of groundwater, the marine environment, nature, landscapes, agriculture, residents recreational opportunities and raw material extraction. Afforestation areas serve various purposes, including increased protection of groundwater in catchment areas (areas where drinking water can be pumped up). Areas where there is particularly strong and important groundwater formation and areas that are particularly sensitive to nitrate have been prioritised as areas where afforestation is wanted. The planned site includes no positive afforestation areas Assessment of environmental impact Agriculture If agricultural land is to be used for other purposes, this must either be because the land is of limited importance to the agricultural sector or because its new use is of major significance to the

166 160 of 234 development, etc. of the municipality. The overall impact is not considered to be significant in relation to municipal planning, as the facility is expected to occupy an area of approx. 150 x 150 m. Raw materials The plan may conflict with raw material interests in the area. The extent of the conflict depends on where the eventual facility is located and whether it is positioned centrally or on the periphery of the raw material area. If the facility is placed within the raw material area, this will have a permanent impact and prevent the extraction of raw materials at the location. Afforestation The plan is not in conflict with afforestation areas. Repository types The conflicts are independent of the choice of repository type. Table Summary impact assessment. Environmental aspects - Tangible assets Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Agriculture Yes No The conflict cannot be directly avoided by the choice of location for the facility as most of the planned site has been designated. Raw materials Yes Yes Any conflict with raw material interests will depend on the placement of the actual facility. Assessment of impact Minor A relatively small area will be used for the repository and, on this basis, the direct impact on agricultural interests is considered to be of little significance (see section on indirect effects on agriculture). None if the repository is located outside the area of raw material interests. Minor to moderate if the repository is located inside the area of raw material interests. Afforestation No - None

167 161 of Cultural heritage This section presents cultural and historical assets in the form of designated cultural environments, church surroundings and cultural heritage sites, the assumption being that the plan will not affect protected ancient sites and associated ancient monument protection lines; cf. plan guideline no 8, Cultural Heritage. These topics are illustrated on map 4.5: Cultural heritage. Within the site there are registered protected ancient sites and monuments, and there may be valuable archaeological finds and remains in the area that have not yet been registered. It is assumed that these assets will be examined more closely in a later EIA study, and that the museum will be contacted with a view to more detailed investigations on the actual site Environmental status and objectives Cultural environments The Municipal Plan includes designations of particularly valuable cultural environments with a view to ensuring a certain level of protection of cultural values against measures that could reduce the value of key assets of historical significance. There are no designated cultural environments within the site. Church surroundings In order to safeguard churches and their surroundings, protection zones have been established around churches in the municipality. These zones were agreed between the county, municipalities and church authorities in the 1980s. There are no designated church surroundings within the site. Cultural heritage sites A cultural heritage site is an area of historical interest with hidden ancient sites and monuments. Cultural heritage sites may be of national or regional importance, and indicate that there are significant ancient sites in the relevant area. Cultural heritage sites are not in themselves protected, but they may contain protected ancient monuments. There are no cultural heritage sites within the area Assessment of environmental impact Cultural environments No impact. Church surroundings No impact. Cultural heritage sites No impact. Repository types No impact. Table Summary impact assessment. Environmental aspects - Cultural heritage Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Cultural environments No None Church surroundings No None Cultural heritage sites No None

168 162 of Cumulative effects Cumulative effects are assessed by viewing the plan in conjunction with other plans or programmes, including previous, current and planned activities. Relevant plans and programmes may cover the same subject-matter, the same geographical area or a neighbouring area. The aim is to ensure that the plan is consistent with other relevant plans and programmes and to assess whether there is any risk of cumulative effects. As described in the preceding sections on the individual environmental aspects, potential conflicts have been identified on Thyholm with potential nature, a valuable geological area and an area of raw material interests. The conflict with potential nature has been reduced by incorporating a guideline into the plan to ensure that when the location of the facility is selected such designated areas are taken into account as far as possible. The planned site borders on the Natura 2000 area Agger Tange, Nissum Bredning, Skibsted Fjord and Agerø. The guidelines to the plan should ensure that any future facility does not carry the risk of significant impact on Natura 2000 areas. No higher-level plans or programmes have been identified within the site that might have an increased impact on the environment in combination with this plan Summary assessment The plan provides for the placement of a facility that may impact the environmental in a number of ways, some of which are general effects regardless of the choice of location, as outlined in section 4.2. Realisation of the plan at Thyholm could have local implications that must be taken into account in any subsequent planning and project design phase. Of these, the most significant are considered to be linked to the following factors: The planned site borders on a Natura 2000 area which must be given special attention in any project design phase. Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism, fishing (including exports of mussels), agriculture and the social structure in terms of a possible tendency for people to leave the area. By far the biggest part of the site will not be affected by an 80 cm rise in sea level, but it is important to allow for a future placement of the facility on the site that avoids any impact from future rises in sea level on the low-lying areas. The Paleogene and Neogene clay deposits are generally low-permeable. The units occur in the bore holes with significant faults in the strata. These aspects do not indicate a thick continuous clay structure in the area, although the bore holes reveal a clear preponderance of clay deposits down a great depth. The whole of Thyholm is situated within the designated coastal zone.

169 163 of THISE, SALLING The site is on the east side of the Salling peninsula in Skive municipality, the central part of the Limfjord area. The site covers approx. 14 km 2. The general background to the work on a plan to establish a permanent repository can be found in section 2, the planning guidelines are in section 3, while the methods used to analyse and assess the degree of impact are described in section 5. Figure 12-1 Outline map Thise Planning conditions This section presents the overall planning framework and strategies for the site in the form of Skive municipality s Municipal Plan and planning strategy. The Skive Municipal Plan is based on the Planning Strategy 2013 and building on this strategy, it continues to focus on: Skive as an even better place to live, work and go to school, with urban life, culture and nature. The good life in the villages and in the rural areas, and the balance between town and country. The unique location of Skive municipality on Limfjord /63/.

170 164 of Planning strategy 2013 The strategy is the town council s view of where investment should go in the coming years. It sets out the guidelines for the development of Skive municipality and so forms the basis for municipal planning. The planning strategy is based on seven priority areas, with particular focus on the following themes /67/: Skive a good place to live Campus New jobs Things to do around Limfjord Developing villages A changing landscape Skive Municipal Plan The Skive Municipal Plan is a plan for the future of Skive and an overall plan for its physical development over the next years. The Municipal Plan sets out the general framework for the whole municipality. The Municipal Plan contains the town council s objectives for development in a number of areas. Achieving these objectives requires essential input from citizens, as well as municipal initiatives in many fields. In future, action plans will regularly be prepared for how Skive municipality can contribute to development of local communities, and which initiatives the town council should launch in the coming years. Municipal planning is a dynamic process, and to ensure that the plan is kept up to date and does not end up being irrelevant, the status of development will be reported on a regular basis. The changing conditions will be evaluated here and constant thought will be given to the possible need to revise the plan /63/ Biodiversity This section focuses on biodiversity, which in this context includes a description and assessment of the impact on Natura 2000, Section 3 of the Danish Nature Protection Act, wildlife corridors and national parks or nature reserves. It is assumed that the future facility will not be located in a Natura 2000 area, and that the plan will not have any significant impact on adjacent Natura 2000 areas; cf. plan guidelines. These topics are illustrated on map 5.1: Biodiversity. It is assumed that the local natural assets will be examined more closely in a later EIA study, which will include more detailed investigations of the specific site in the form of e.g. field studies Environmental status and objectives Natura 2000 The planned site does not contain any Natura 2000 areas. The nearest areas are to the southeast, in the form of: Lovns Bredning, Hjarbæk Fjord and Skals, Simested and Nørre Ådal, Skravad Bæk, Natura 2000 area no 30, habitat area H30, bird protection areas F14 and F24: The area extends from Hjarbæk Fjord, Lovns Bredning and the Lovns peninsula in the west over the four large streams Lerkenfeld Å, Simested Å, Skals Å and Nørreå to the large marsh areas at Øster Bjerregrav and lakes Fussing and Glenstrup to the east. Especially the lower parts of the four large river valleys are characterised by drained and cultivated areas (previously meadows and marshes). In the upper parts of the river valleys there are many areas where cultivation and grazing has been discontinued because the areas are unsuitable for modern agriculture /66/. Section 3 protected nature Under Section 3 of the Nature Protection Act, it is prohibited to interfere with protected natural habitats in a way that could cause a change to the state of these areas. However, the

171 165 of 234 municipalities may derogate from this provision /11/, often on condition of establishing some natural replacement. Natural habitats covered by Section 3 of the Nature Protection Act are: Lakes and ponds of at least 100 m 2. Marshes, meadows, heaths, dry grassland, coastal meadows and tidal marshes which individually or together cover an area of at least 2,500 m 2. Marshes under 2,500 m 2 are also protected if they are next to protected streams or lakes. Most streams and rivers are also protected via a special Section 3 designation. Lakes include both natural and wholly or partly man-made pools, basins and dams. The site contains few protected areas of natural interest (cf. Section 3 of the Nature Protection Act) in the form of coastal and other meadows and lakes. There are no streams in the area. Nature conservation areas The maps show certain natural networks of special nature conservation areas and potential areas, and existing and potential ecological corridors. Natural assets and landscape features in these areas will be protected against any action that compromises nature and the landscape. Conservation should take priority over all other interests. Interference with natural assets of moderate quality may be allowed, provided that the activities bring about improved living conditions for the natural fauna and flora. Ecological corridors have been designated around Havbjerg Skov and Gåsemose and around Eskær Skov. Low-lying areas Low-lying areas should be kept free of buildings and facilities as far as possible. Low-lying areas have been reserved for restoration or establishment of wetland areas. These areas are referred to as potential wetland areas. Any necessary buildings or facilities should be designed in a way that permits the area to be restored to its natural state. Wetland areas have been designated around and north of Gåsemose, in Havbjerg Skov, north of Thisetorp, between Nørre Thisegård and the coast and north-east of Eskær Skov. Beach protection Along the coast, there is a 300 m protection belt. Protected forest The vast majority of private woods and all public woodland in Denmark have the status of protected forest (fredskov) and are safeguarded by the provisions of the Forestry Act. The site contains a number of protected forests, the largest of which are located at Havbjerg Skov in the central part of the site and at Eskær Skov in the south-eastern part of the site. National parks Not assessed to be relevant to this area Assessment of environmental impact General It is impossible to define criteria for protecting the environment against radiation as there are no statistics covering the health impact of ionising radiation on animals and plants, as there are for people. Internationally, projects have been launched to determine the effect of ionising radiation on nature and, on this basis, to use reference animals and plants as a means of establishing criteria and producing subsequent safety analyses. The progress of these projects will be

172 166 of 234 monitored and taken account of as far as possible in defining environmental protection criteria when the safety analyses are carried out in a later EIA phase /15/. Human beings are generally considered to be the organism that is most vulnerable to ionising radiation. Therefore, once criteria have been established to safeguard people, we may assume that animals and plants will be sufficiently protected against radiation. Exceptions to this assumption will mainly apply to a small population of a species in a restricted area around the repository /15/. The environmental protection criteria applicable to a given repository will be drawn up in conjunction with the mandatory EIA studies to be carried out for two selected sites if it is decided to proceed further with the permanent repository concept. In this connection, detailed field studies will be carried out as part of the basis both for assessing potential effects and for defining environmental protection criteria. This will ensure that local conditions are taken into account in the form of site-specific assessments concerned with protecting the environment. This section presents the general conflicts with nature conservation interests. Natura 2000 Owing to the distance to Natura 2000 area no 30 Lovns Bredning, Hjarbæk Fjord and Skals, Simested and Nørre Ådal, Skravad Bæk, the plan is judged to have no effect on this area. Furthermore, the guidelines to the plan explain that any future facility may not have any significant effect on adjacent Natura 2000 areas (guideline no 7, Nature). The future planning and project design must therefore ensure that a facility can comply with these provisions. If it is considered relevant despite the great distance from these areas, a materiality assessment will be carried out, which will consider whether there is a risk of significant impact to the Natura 2000 area. If it is considered that there is a risk of significant impact, an impact assessment will be carried out. The purpose of this is to examine the potential impact in relation to the conservation goals for the area, and to incorporate mitigation measures into the project in order to avert any serious impact. Section 3 protected nature There is a risk of impact on Section 3 protected areas where the facility itself or the access roads are positioned in direct conflict with the protected area. As the gross area is relatively large, there is every chance of placing the facility so that it does not affect protected areas. This consideration should therefore be included in subsequent planning and project design. No guidelines have been included in the plan to guard against conflicts with Section 3 protected areas, as other factors determining the ideal positioning may result in conflicts with Section 3 protected areas. Nature conservation areas The plan may affect nature conservation areas in the form of ecological corridors within the planned site. Plan guideline no 7, Nature, states that, whenever possible, the location of the facility should take into account factors such as nature conservation areas. The impact on interconnected nature areas depends on the eventual positioning of the repository. Low-lying areas There are several low-lying areas, including at Gåsemose and Havbjerg Skov, within the site. It is assumed that the facility is placed at a location which is not in conflict with low-lying areas, cf. plan guideline no 12, Designated low-lying areas and potential wetland areas. Beach protection There are beach protection belts in the north-eastern and south-eastern parts of the site.

173 167 of 234 Protected forest There are several protected forests within the site, e.g. Eskær Skov, which may be affected. National parks There are no national parks within the planned site or in the immediate vicinity. Repository types The three types of repository take up the same area, so will result in the same risk of impact to nature arising from any closing off of land and hence of a potential impact on Section 3 areas, nature conservation areas and protected forests. As mentioned above, it is assumed that Natura 2000 areas, beach protection belts and low-lying areas will not be affected whatever the choice of repository. Table 12-1 Summary impact assessment. Environmental aspects Biodiversity Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Natura 2000 No - The guidelines to the plan state that a facility cannot be established under this plan if there is a risk of significant impact on Natura 2000 areas. The concrete assessment of whether the facility can meet this requirement will be made in a later EIA phase, when the location, repository type etc. are known. Section 3 protected nature Nature conservation areas Yes Yes The facility can be located where it does not conflict with protected areas. Yes Yes There are nature conservation areas at Havbjerg Skov and Gåsemose and around Eskær Skov. Low-lying areas No - It is a precondition that the facility is not placed in areas designated as lowlying areas, cf. plan guideline no 12, Designated low-lying areas and potential wetland areas. Beach protection belt No - Plan guideline no 9, Building and protection lines, stipulates that the repository may not be located within the beach protection belt. Assessment of impact None None or minor The degree of impact depends on the positioning of the repository. None or minor Plan guideline no 7. Nature, ensures that the placement of the facility should take maximum account of interconnected designated nature areas, wildlife corridors etc. The degree of impact depends on the eventual positioning of the repository. None None

174 168 of 234 Environmental aspects Biodiversity Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Protected forest Yes Yes There is a risk of impact on protected forest areas. None or minor The degree of impact depends on the positioning of the repository. National parks No - Not relevant None 12.3 Population and health This section describes the location of the planned site in relation to built-up areas, the number of inhabitants, commercial activity, tourism and recreation. It is mainly based on information from Statistics Denmark and the Municipal Plan. The section then describes the potential impact on the population in terms of health risks and indirect environmental effects, including the risk of reduced revenue, relocation etc. The assessment of the impact is based on available information from e.g. descriptions of transport and radiation in the feasibility studies. It is assumed (cf. plan guidelines) that the facility will be designed to be able at any time to demonstrate compliance with the specified dose constraints when in operation and after closure, both for those periods and for potential incidents (accident scenarios). Documentation of this will be provided in the form of safety assessments for the facility and its use. The assessment of the indirect environmental impact on the population and industry identifies potential effects based on an analysis of responses to consultation and comments from public meetings focussing on e.g. people s concerns about the effects of implementing the plan Environmental status and objectives Population The site is on predominantly agricultural land. The largest settlement is Thise, but areas around Thisetorp and Nørre Thise are also relatively densely built up. In addition, there are scattered houses throughout the area. There is a network of small, well-maintained roads and a larger road going west from Thise. There are local/municipal plans for, inter alia, wind turbines, business and settlements west of Thise. The distance to towns can be seen in Table Table 12-2 Distance from major built-up areas. Distance from built-up area: Breum: approx. 2 km Jebjerg: approx. 6 km Roslev: approx. 6 km Skive municipality contains 18 towns (urban zones) and 30 villages. 25% of the population live outside built-up areas. The population figures for the larger towns and villages in Skive municipality can be seen in Table 12-3 (as of 2011). Table 12-3 Breakdown and number of inhabitants in Skive municipality (2012). The breakdown and number of inhabitants is as follows: Thise: fewer than 200 inhabitants Breum: 843 inhabitants (2011)

175 169 of 234 The breakdown and number of inhabitants is as follows: Jebjerg: 1,151 inhabitants (2011) Roslev: 1,396 inhabitants (2011) There is continued local development in the rural areas. The total population is expected to fall, but some of the local urban zones will experience a certain growth. The Municipal Plan does not propose any changes in the local pattern of towns and villages. Overall, capacity presumably exceeds the expected demand. Industry The Skive Municipal Plan reflects a business policy which aims to create growth and development. It is built around these six priority areas: Sustainable energy Education and training Business development and innovation Enterprise Attracting a qualified workforce Infrastructure As part of the analysis of the commercial conditions, the numbers of people employed in the whole of Skive municipality have been surveyed, broken down into tourism and leisure, agriculture, fishing and food production, as shown in Table These matters are considered crucial in terms of their impact on the population and health and the indirect socio-economic factors. The chart shows a selection of the key industries with an assessment of the socioeconomic factors, but in reality, employment will be greater because a number of other professions will be linked to these industries to a greater or lesser extent. The analysis of employment has been carried out for the whole of Skive municipality, as it is felt that implementing the plan may affect a major part of the local community and not just the planned site itself.

176 170 of 234 Table 12-4 Breakdown of employment in Skive municipality within selected industries related to tourism and leisure, agriculture, fishing and food production, as of The total number of people employed in Skive is 22,366 (Statistics Denmark 2013). Agriculture The Municipal Plan includes guidelines for farming, mainly agriculture but also covering horticulture and forestry. These uses of the land are jointly referred to as farming. Agricultural production has a major bearing on development in Skive municipality in terms of employment, income and housing. The designation of areas of special agricultural value is described in section Within the area is the dairy Thise Mejeri at Sundsørevej 62, Thise. This cooperative was founded in 1988 and has 155 employees. It exports to Sweden, Germany, the UK, the Netherlands, Belgium and France and has total annual revenue of DKK 700 million (2013). Tourism Skive municipality s tourism and leisure policy focuses more strongly on how tourism in the municipality can be increased. The options for tourism and leisure are described in the Municipal Plan as generally good. This is mainly down to its proximity to the coast, but also to improved information, accommodation and access. Tourism makes a positive contribution to the economy of the municipality, and in most places it is on a scale that allows it to operate in harmony with the local population and the natural world /63/. Recreational areas There are no summer cottages areas, camping sites or designated bathing beaches within the site, but just to the east of the planned site is a summer cottage area and a recreational area at Sundsøre. Within the planned site, there are recreational areas at Eskær Skov and Havbjerg Skov, including relational trails. In Havbjerg Skov there are also shelter facilities for camping out. Brokholm Nature Centre is located by the recreated lake Brokholm Sø and within walking distance from Havbjerg Skov. The Nature Centre is used primarily by schools and institutions in Skive municipality, but can also be rented by associations and other groups /64/.

177 171 of Assessment of environmental impact The assessment of the impact on the population covers health (related to transport, risk of accidents and radiation, safety and security of the facility itself), and socio-economic factors, including the population, commercial interests, tourism and recreational activities. Health Radiation protection The health impact of radiation from the facility itself and from accidents is described in section 4.2, as the same requirements apply to safety assessments and official approval regardless of the choice of site. Transport Based on the feasibility study, we conclude that both road and sea transport may be considered. The radiation doses estimated for transport of Danish radioactive waste from Risø to a future permanent repository in Denmark have been calculated on the basis of the greatest possible distance to any repository. The estimated doses in the feasibility study are therefore upper limits, and doses from shorter transport routes will be proportionally lower. The study shows that the risk associated with road and sea transport does not restrict the future selection of a location for a repository in Denmark, and that the transport can be handled so that the dose is well below the national thresholds. The three locations in Jutland Thyholm, Thise and Skive involve the longest transport routes from Risø whether road or sea transport is chosen. Changes in distance have no effect on doses in the event of an accident. The likelihood of an accident is dependent on factors such as the quality of the road and the volume of traffic, and is also proportional to the distance. Compared to the zero alternative, the radiation dose is greater in the short term as a natural consequence of the fact that, in the zero alternative, the waste will not be processed as much, or transported from the location. In the longer term, it will be necessary to process and possibly transport the waste under the zero alternative too, as Risø does not have the status of a permanent repository. Socio-economic factors Apart from the general issues mentioned above, the stakeholders have drawn attention to a number of local matters that should be given special consideration in the choice of destination and in implementing the plan if a repository should become a reality in their particular area. Table 12-5 presents the major concerns raised by stakeholders in the whole of Skive municipality. The table summarises local issues relating to both the planned sites in the municipality Thise, Salling and Skive Vest the assumption being that location of a permanent repository within one of these sites may have an impact on local conditions that extends beyond the planned site in question and is therefore relevant for the whole municipality. This local information is used as part of the background to the description of the potential impact on the population and the socio-economic factors, and also forms the basis for suggested mitigation measures (section 15.2). Table 12-5 Summary of the major concerns raised by stakeholders in Skive municipality applicable to both Thise, Salling and Skive Vest *. Subject A CLEAN LIFE Description Skive municipality has a master narrative defining the identity of the area, which can be summarised as a CLEAN LIFE. The central values in this narrative are to do with living an active and clean life in the natural and cultural environments that characterise the area. According to the stakeholders, this master narrative is a great asset, which is why the municipality has identified itself with the CLEAN LIFE brand ( RENT LIV ). In this connection, stakeholders express concern that a repository will have an adverse

178 172 of 234 Subject Recreational areas Cultural heritage Access roads and safety Hazardous waste Drinking water Description effect on the values and narrative of the area. The same narrative is also used to help create new jobs in the area, and products of local businesses often carry the CLEAN LIFE brand name. This includes organic products for human consumption such as milk, meat, eggs, vegetables etc. and the origin of the animal feed is often part of this positive story also. Concrete examples are Thise Mejeri, which uses the brand for its organic dairy products, and Glyngøre Shellfish, which supplies oysters from Limfjord. The stakeholders are sceptical as to how the idea of a repository can be reconciled with this. Skive municipality also contains a number of recreational areas. Examples are Flyndersø-Sønder Lem Vig nature reserve, which attracts tourists and biologists with its special fauna; Karup Å, which is known for its trout; the popular spot for anglers at the pumping station on Sønder Lem Vig; the recreational area around Skive harbour, which attracts sailors, divers, surfers, kayakers and others who enjoy the maritime facilities of the fjord; the Sundgården summer cottage area near Thise; and the Brokholm Nature Centre with associated facilities at Gåsemose. The stakeholders express concern about the adverse effect a repository could have on the attraction of these places to tourists, causing them to lose their value as recreational areas. Specifically, they call for an examination of the social consequences in this regard from any seepage from a repository. The stakeholders point to a high risk that there could be unknown archaeological remains and monuments inside the designated areas, which could be uncovered in any construction work. The establishment of a repository must therefore be subject to studies and planning to take account of this. The stakeholders point out that transport to and from a repository in these areas will involve driving on narrow roads and through built-up areas. Concerns are expressed about safety in this regard. The stakeholders express concern about the state s handling of hazardous waste. They cite previous cases in West Jutland relating to Cheminova s toxic waste repository, Høfde 42. They also express concern about the Skive area becoming a permanent centre for radioactive waste even after the repository closes 30 years after opening. It is therefore important for the stakeholders to feel comfortable with what the plan involves, how any seepage will be monitored and what will be done if it occurs. The stakeholders state that there is already a shortage of drinking water in Skive municipality and that the water table is close to the surface in Thise. There are therefore concerns about the risk of impact on already limited water reserves. *This description is extracted from minutes of the public meeting held in Skive and from responses to consultation on the scoping report. Summary The questions relating to the establishment of the facility itself, and the practical problems that may arise as a consequence, are not dealt with in depth in this report because of the level of detail in the plan. The project-specific issues with question-marks against them will be addressed in a later phase, when risk assessments and radiation protection work will be carried out in conjunction with the subsequent work by the authorities once there is an actual project. These concern things like access roads, traffic routes, the risk of accidents and the handling of hazardous waste. The following subjects are addressed at a high level in other sections of the environmental report: Groundwater, drinking water and surface water are discussed in section The cultural heritage is discussed in section 12.9, but the plan guidelines assume that protected areas and ancient monuments will not be directly affected. Possible indirect implications of concerns with a bearing on the plan are described below. If we look at the comments from stakeholders of both a general and a local nature, we see that they are marked by a high degree of concern. These concerns are directed at a broad and diffuse set of risks, which indicate a lack of knowledge of the real risks involved in implementing the plan and of the measures that have been and will be taken to avert these risks. The comments also show that the stakeholders do not have sufficient knowledge of the process to be followed in the future, leading to widespread insecurity and mistrust. The stakeholders do not feel convinced that the future process will adequately examine and address the perceived risks and involve the stakeholders, to ensure that local interests are safeguarded. For these reasons, the analysis

179 173 of 234 shows that the plan to establish a repository has received a very negative response from the stakeholders. This negative attitude, insecurity and mistrust of the plan and the projected process create the ideal conditions for a number of negative social effects to become reality. In this situation it is not inconceivable that a permanent repository could have indirect negative implications for sales opportunities for local food, including dairy products from Thise Mejeri, tourism, land and property prices and the mental wellbeing of residents in the area, etc. purely because of insecurity and mistrust. It is therefore crucial to the social effects of the plan that the insecurity and mistrust should be reduced. Overall, there may be a risk of impact on socio-economic factors, including tourism and the food industry. The plan may thus conflict with the overall strategies that exist for the area, as described e.g. in the Skive Municipal Plan including the overall vision of a CLEAN LIFE, which encompasses health aspects, nature, culture, food production etc. Table 12-6 Summary impact assessment. Environmental aspects Population Health Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Radiation protection Securing the facility Yes Yes The impact in the immediate vicinity will depend on the final location. Yes Yes A vulnerability assessment should cover different scenarios and their consequences. These scenarios should be covered by security and contingency plans designed to assure the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the dose constraints) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraint. As with the category of transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the dose constraint) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraint. As with the categories of radiation protection and transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and

180 174 of 234 Environmental aspects Population Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact potential doses. Transport Yes Yes The impact in the immediate vicinity will depend on the final location. Noise, heavy traffic and emissions may have an impact in connection with transport within the planned area. Socioeconomic conditions Yes Yes/No. In recreational areas etc. the impact may be dependent on the final location, but the general concern about the impact on the population and industry is considered to be independent of the final location and in many cases people expect an impact beyond the planned site itself. Implementing the plan may cause indirect effects on the population and socio-economic conditions. The stakeholders highlight a number of issues that cannot be addressed at this introductory stage of the planning process, but these issues will be examined more closely in an EIA phase and in conjunction with safety analyses and official approvals. Minor (below the thresholds for exposure to radiation). Estimated doses for transport to the planned site are well below the dosage thresholds. There will be a need to plan transport routes, times etc. to achieve a reduction of risks and potential doses. Moderate to significant The impact is judged to be of moderate to significant importance because of the high level of concern and the uncertainty expressed among the stakeholders. This should therefore receive close attention in the later phases Landscape and geology This section presents geographical and geological conditions within the planned site, which here encompass a high-level description of the landscape and any designated areas and a description of the geological conditions based on the feasibility studies, with any designated features. These topics are illustrated on map 5.2: Landscape and geology. The assessment of the impact on the landscape is based solely on whether there is a risk of impact on valuable landscapes and designated coastal zones. It is assumed that the real impact on the landscape and visual factors will be determined in a later EIA study, where landscape analyses, visualisations etc. can be based on the choice of a specific location and a concrete project proposal. The purpose of examining the geological conditions is to assess the degree of uncertainty as to the ability of the geological conditions to act as a physical barrier around a possible repository. It is assumed that the local geological conditions will be examined in more detail in a later EIA study Environmental status and objectives Landscape Landscape description This area comprises a large, high and almost flat plateau which includes most of the central and south-eastern part of the site. The plateau is between 25 and 40 m above sea level. The landscape slopes gently from the plateau to the west and north-west and a little more steeply to the north-east. Directly to the north is another, smaller plateau with a height of between 15 and

181 175 of m. Directly to the south, the slope between the plateau and river valley and coastal zone respectively is very steep and deeply intersected by small, steep slopes. The south-east coast appears to be characterised by an eroded cliff. The north-east coast appears to be stable. Further to the north, there is a narrow strip of marine foreland. The approx. 1 km 2 large Gåsemose (5-6 m above sea level) is found to the north-west, at the foot of the plateau slope. Designated coastal zone The designated coastal zone is defined in the Planning Act and is approx. 3 km wide. The rule is that the designated coastal zone must be kept free from buildings and facilities that are not dependent on proximity to the coast. The eastern part of the planned site is inside the designated coastal zone. Planning Act: Section 5b. The following shall apply to planning in the designated coastal zone: 1) It is prohibited to transfer land to an urban zone or to conduct planning for development in a rural zone unless there is a specific planning-related or functional justification for location near the coast. Areas of special landscape value Skive municipality has an objective to keep the countryside free of any building that is not commercially necessary for the farms and to prevent the unplanned, random spread of buildings and facilities in the countryside. In areas of special landscape value, the character and feel of the landscape should be preserved. Conservation should take priority over other interests. Actions that alter the character of the landscape in these areas may only be taken if the overall result is to improve the ways in which the public can experience the landscape /63/. The planned site includes landscapes worthy of preservation along the entire coast and around Havbjerg Skov and Gåsemose. Coastal landscapes In Skive Municipal Plan, the coastal landscapes are divided into three zones: the beach zone, the protection zone and the planning zone. All three zones must be kept entirely clear of buildings and facilities that do not require a coastal location for planning-related or functional reasons. The beach zone is a prohibition zone and is identical to the beach protection belt defined by the Nature Protection Act. This zone must be kept free of buildings, facilities, planting and other interference. In the protection zone, buildings and facilities that require a coastal location may be erected only if this does not reduce the landscape, natural, geological or historical values on which the designation is based. In the planning zone, buildings and large technical facilities may be planned which require a coastal location or which are required in order to benefit from economic investments already made /63/. As previously stated, the eastern part of the planned site is located within the designated coastal zone and includes the three municipal protection zones. The 300 m wide zone along the coast is comprised by the beach zone and beach protection belt, while a few small areas further inland have been designated as protection zones. The remaining, and largest, part of the area has been designated as a planning zone.

182 176 of 234 Geology A detailed discussion of the geological conditions can be found in GEUS report no 5 /5/. Beneath Ice Age deposits with a thickness of up to approx. 20 m there are fine-grained Oligocene clay deposits of up to 140 m, but limited by buried valleys with other deposits to the north, west and south-east. The following description is a summary of the geological conditions described in the local area study. Deposits and soil types Several bore holes in the area reach marine Oligocene deposits beneath 5-20 m of Quaternary deposits (Ice Age deposits). The Oligocene Brejning formation consists of brown and black micaceous, sandy and silty marine clay, often containing glauconite. It seems to be homogeneous, but there are occasional thin silt and sand layers. In one bore hole, sandstone/claystone was found. The deposits are generally not chalky, but slightly chalky strata contain shells and foraminifera. A new bore hole confirms the presence of the geological deposits. This formation is up to 140 m thick. In three bore holes, the micaceous clay rests on fine-grained blackish-green and green chalky clay. This up to 100 m thick unit may belong to the Oligocene Branden clay unit. Clay from the two units is deposited in the sea and presumably covers a large horizontal area. Surface geology comprises Quaternary deposits. Most of the area is dominated by clayey till, but there are scattered, relatively large areas of meltwater sand and gravel. Post-glacial freshwater deposits are found to the west, especially in the drained Brokholm Sø and in Gåsemose, but freshwater deposits are also found in the narrow river valleys. Bore holes show that the Quaternary deposits can be up to 19 m thick. The dominant deposit type in the area is clayey till, which may contain layers of fine to coarse gravelly meltwater sand. Often the sand layers are thin, but some are up to 3-4 m thick. To the east, just outside the site, there are Quaternary strata of up to 90 m in thickness with clayey till and meltwater deposits, and to the west there are also thick Quaternary strata. In both cases, the thick Quaternary strata are found in buried valleys. The Quaternary and Oligocene deposits can be found in coastal cliffs at Mogenstrup and Knuds beaches just south of the site. Mineralogy binding adsorption The geochemical conditions in the deposits have a bearing on how radioactive material will behave if it should leak out of a repository into the surrounding geological strata. Some general observations are set out below. However, the large number of radioactive components in the waste may behave differently in the surrounding deposits. A key element is that the radioactive material should be able to bind to the deposits. The uppermost layer consists of clayey till and meltwater sand deposits, but we know of no analyses of these. Clay from the Brejning formation is made up of 50% clay fraction and 40% silt with fairly little coarse material such as glauconite and pyrite (10%). The clay mineralogy is 30-40% smectite, 36-40% illite and up to 30% kaolinite. The mineralogical composition may be different in East Jutland, for example. Branden clay comprises 50% clay fraction and 50% silt, and the mineralogy is 20-50% smectite, 30-60% illite and the rest kaolinite.

183 177 of 234 Clay minerals, especially smectite clay minerals, are particularly well-suited to binding radioactive material. They are present in relatively large but varying quantities in the deposits. This means that the clay deposits have the potential to bind the radioactive components. Redox conditions The behaviour of the radionuclides in relation to the oxygen content in the strata and groundwater (redox conditions) will depend on the types of chemical compounds and chemical properties involved. The concentrations of these components in the strata and the water, and their ph, also have a bearing on the processes that will occur. There is oxygen present in the uppermost layer of soil (the oxidised zone), and this may for example mean that some radioactive components can be made mobile and hence transported more easily. Conversely, the conditions in the oxygen-free (reduced) zone, for example, will help to bind and hold other radioactive components. In the area, the oxidised zone seems to continue to 2-4 m below ground level. This means that most of the Quaternary clayey till and the Palaeocene deposits from the Brejning formation and Branden clay are in the reduced zone. Natural radioactive components in the deposits Where monitoring is to be carried out around an established repository, it is important to know the baseline radioactivity. There are few known values for the area 39 Bq/kg radium in micaceous clay and Bq/kg in the Brejning formation. Assessment of geological conditions The geological conditions influence the impact of the repository on both surface water and groundwater. The geological conditions need to be consistent and stable within the site and they must contribute to the stability of the repository. The geological strata should help to isolate the waste from the surroundings by enclosing or underpinning the repository. The rocks should be low-permeable and help to bind the radioactive components from any discharge from a repository /15/. These issues are assessed in Table In the table, the geological conditions are assessed only in relation to a repository placed in the pre-quaternary rocks, in this case in Oligocene clay. If the repository is placed in Quaternary deposits, clayey till probably containing fractures and sand lenses and occasional sand layers will only partly isolate the waste from the surroundings. Table 12-7 Assessment of the geological conditions in terms of stability, low-permeable rocks and binding of radioactive components. Property Assessment Comments Consistent and stable geological conditions contribute to the stability of a repository. Yes The geological strata help to isolate the waste from its surroundings: Low-permeable rocks. The geological strata help to isolate the waste from its surroundings: Binding of radioactive components. Yes Yes The Oligocene clay deposits appear to be consistent and very thick in the area. Geotechnical stability will be addressed in any specific project proposal. The Oligocene clay deposits are low-permeable. The Oligocene clay rocks have a high content of clay minerals, including a high content of smectite. Clay minerals, especially smectite, are particularly wellsuited to binding radioactive material. This means that the Oligocene clay rocks have the potential to bind the radioactive components. Summary The fine-grained early Oligocene clay deposits are expected to cover much of the area with a thickness of up to 140 m, but are limited by the buried valleys with other deposits to the north, west and south-east.

184 178 of 234 The deposits are undisturbed except for erosion along the edge of the area. Late Quaternary deposits, especially clayey till, overlie the Oligocene clay. The clayey till contains up to 3-4 m thick, but generally thinner, sand layers. Thicker sand layers can be found to the south, while clayey till with a thickness of up to 18 m can be found to the north. Experience shows that clayey till contains fractures and sand lenses. The properties of the Oligocene clay deposits make them well-suited to preventing the spread of any leaking radioactive material from a repository. Areas of geological interest In Skive municipality there are five areas of National Geological Interest; none of them are located within or border the planned site Assessment of environmental impact Landscape According to the guidelines to the Municipal Plan, the landscapes worthy of preservation along the entire coast and around Havbjerg Skov and Gåsemose should be protected so that the character and feel of the landscape is preserved. A future facility may conflict with the designated status if it is found that it causes a significant change to the landscape which conflicts with its special character. It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location and the repository type have been decided. Conflict can be avoided by placing the facility outside the designated landscapes. The eastern part of the site is within the designated coastal zone. Before a facility can be located in the designated coastal zone, the planning and functional justification for the coastal location must be stated. There should also be a description of the visual impact, which will depend on the repository concept and design. If it decided to choose a design to make the facility recognisable and visible, e.g. for safety reasons, this will immediately make a greater visual impact than a repository concept that is more integrated into the landscape. The final assessment of the scale of the impact will be made as part of the EIA studies. Repository types It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location has been decided and there is a description of the repository type, dimensions, choice of materials and colours, planting, fencing etc. Geology The plan is not expected to affect the general geological conditions significantly, but the geological conditions have a major bearing on the suitability of the site for the establishment of a repository. The geological description will therefore be used as background material to any assessment of the impact on groundwater and surface water. The plan does not affect the areas of geological interest. Repository types The potential impact on the geological features is expected to be similar for each of the three repository types, as the total surface area required will be the same whatever repository type is chosen.

185 179 of 234 Table 12-8 Summary impact assessment. Environmental aspects Landscape and geology Designated areas Designated coastal zone Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes There are landscapes worthy of preservation along the entire coast and around Havbjerg Skov and Gåsemose. Yes Yes The eastern part of the site is within the designated coastal zone. Assessment of impact None if the repository is located outside the designated area. Minor to moderate if the repository is located inside the designated area. A final assessment of the impact requires an actual project and visualisations to be produced in a future EIA phase. None if the repository is located outside the designated coastal zone. Geological designations Moderate if the repository is located inside the designated coastal zone. A final assessment of the impact requires an actual project and visualisations to be produced in a future EIA phase. No - None 12.5 Climate Climate change could affect the future repository because of the increased risk of extreme events. This section describes the future scenarios that are being examined in Denmark and abroad, to serve as a basis for assessing whether the planned site is expected to be significantly affected by changes in the climate. It is assumed that a future facility (see plan guidelines), via its design and placement in the landscape, will be adapted to any future climate change and thus less vulnerable to extreme events /5/ Environmental status and objectives Based on the latest Danish and European scenario analyses, the Danish Meteorological Institute (DMI) has described the expected future climate changes in Denmark out to The assessments are based on the scenarios used by the UN s International Panel on Climate Change (IPCC) /20/. The changes are expected to increase towards the year Considerations of climate change are relevant to the placing of the repository because of the risk of rising sea levels flooding the facility, which could lead to penetration by surface water and hence an increased risk of radioactive substances spreading into the environment. The DMI report suggests that Denmark will experience warmer and wetter weather in the future, with more extreme events such as longer periods of drought and heavier rainstorms, and temperature increases. It also projects a general rise in sea levels in the waters around Denmark /20/. More recent projections are now pointing to even greater rises in sea levels around Denmark, ranging from 80 ±60 cm to max. 150 cm by There may be further increases towards 2200, but estimates are extremely difficult and fraught with very great uncertainty /20/.

186 180 of 234 The Thise area is bordered to the north-east and south-east by the Risgårde Bredning and Hvalpsund coastlines and hence the lowest land is found in these areas. Along the coast to the north-east, there is a small wedge of land characterised by, inter alia, marine foreland located 0-5 m above sea level. Along the south-eastern coast is a steep eroded coastal cliff. In the northwestern part of the area is Gåsemose, a marsh which is approx. 1 km 2 in size and located approx. 6 m above sea level. The remaining, and by far the largest, part of the approx. 14 km 2 large Thise area is located well above sea level, at m /5/ Assessment of environmental impact Rise in sea level Part of the designated coastal area can be expected to be flooded around the year 2100 if the sea level rises as forecast. A rise in the sea level is expected to lead to increased erosion in this part of the coast. Even if we project a rise of at least 80 cm in the seas around Denmark (by 2100), it is hard to predict how this will affect the innermost part of Limfjord. With a rise of 80 cm, small parts of the designated coastal areas will be flooded, and we may expect increased erosion of the coastal cliffs. Land uplift in the area is assessed to be approx mm per year, and if this continues in future, it will make a (modest) contribution to reducing the impact of the sea level rise /5/. Extreme events The Thise area is not particularly exposed to storm surges and flooding due to its geographical location inside Limfjord and because most of the area is at a relatively high altitude. However, some parts of the area, especially along the north-eastern coast, may be affected by fluctuating water levels in the fjord. Increased precipitation could transform Gåsemose into a lake, and increased precipitation intensity can also be expected to increase erosion along the banks of the stream between Eskær and the coast /5/. Repository type The planning guidelines describe how the facility will be constructed to ensure that it can cope with sudden floods (climate-proofing), whereby the surroundings will be safeguarded against emissions even in the case of climate change and extreme rainfall. Table 12-9 Summary impact assessment. Environmental aspects Climate Rising sea levels Extreme events Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes By far the biggest part of the site will not be affected by an 80 cm rise in sea level, but it is important to allow for a future placement of the facility on the site that avoids any impact from future rises in sea level on the low-lying areas. Yes Yes Some parts of the area, especially along the northeastern coast, may be affected by fluctuating water levels in the fjord. Assessment of impact None or minor provided that account is taken of the placement of the facility on the land. Plan guideline no 11, Climate, also describes how allowance will be made for climate change in the design and placing of the repository. None or minor

187 181 of Water This section describes the issues relating to groundwater and surface water within the planned site. It is based on information from local area studies and municipal designations. The impact assessment is based on the descriptions of the geological conditions (section 12.4), as the impacts on groundwater and surface water depend largely on these. Drinking water interests are illustrated on map 5.3: Drinking water interests. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site Environmental status and objectives Groundwater General Several bodies of groundwater in Salling are threatened by rising levels of sulphate and nitrate, and in a few places pesticides have been found, which is also an increasing problem. Hence, Skive is unable to find new groundwater reservoirs within the municipality. The overall reservoir system on Salling is characterised by buried valley structures. There is a secondary groundwater reservoir from ground level down to a depth of approx m. Below this is an intermediate depth groundwater reservoir (upper primary), varying in thickness from approx. 25 to 75 m. In a few places, e.g. the buried valley at Breum, there are deeper groundwater reservoirs (lower primary) at depths of m. Several large waterworks extract water from the lower reservoir, including those at Breum and Vihøj. The secondary and upper primary reservoirs are found in practically all of Salling. In the Thise area, the groundwater flows from Stouby and Thise to the buried valley at Breum to the south-west and the buried valley to the east near Thise, where the bore hole for Thise waterworks is located. At the same time, some of the groundwater flows north-west to Brokholm Sø and some south-east to Skive Fjord. In the worst case, leaks from a repository could affect the groundwater reservoirs at both Breum and Thise. Especially the buried valley at Breum is of major regional significance in relation to future drinking water resources in Salling, and hence the quality of the water must not be jeopardised. In the northern part of the area, groundwater flows north-east into Limfjord. Drinking water interests The most important groundwater resources for drinking water supplies are designated as areas of special drinking water interests (Danish: OSD), which are meant to cover current and future needs for water of drinkable quality. In these areas, an extra effort will be made specifically to safeguard the groundwater, in order to prevent contamination and remove any existing pollution. OSDs are the core areas for this targeted groundwater conservation. This means that such areas are regarded as strategic catchment areas and that the municipalities need to take account of the groundwater resources and catchment areas for public waterworks in their physical planning. Along the coast of the area there are limited or no drinking water interests, while the rest of the area has drinking water interests (Danish: OD). However, there is a catchment area for public waterworks outside the OSD, but within the planned site, i.e. the catchment area for Thise waterworks. Catchment areas for public waterworks outside areas of special drinking water interests have the same status in terms of groundwater protection as the OSDs themselves. The catchment area for Thise waterworks is defined as a nitrate-sensitive catchment area and a priority area, as the groundwater in the Thise area especially is particularly vulnerable. Besides Thise waterworks, there are a number of individual extractions across the area.

188 182 of 234 The former County of Viborg prepared an action plan for protection of groundwater in the area around Thise. This area covers OSD-Breum and the nitrate-sensitive catchment area (IO/NFI) for Thise waterworks. The waterworks, which together with Vihøj waterworks supplies the diary Thise Mejeri, has extracted an average of 75,000 m 3 p.a. over the last three years, some of which is used by the dairy. Vihøj waterworks supplies approx. 100,000 m 3 p.a. to Thise Mejeri. Since its production started, Thise Mejeri has increased its extraction requirement to approx. 150,000 m 3 p.a. Groundwater extraction in OSD-Breum totals 650,000 m 3 p.a. (for Breum, Vihøj, Jebjerg, Roslev, Lyby, Øster Grønning and Thise waterworks); the total permitted volume in the area is 775,000 m 3 groundwater p.a. Summary The area has limited groundwater reservoirs, but there are a number of local individual supplies and water supply bore holes, especially to the east and at Nørre Thise, which utilise local sandgravel reservoirs. Several of the bore holes for Thise waterworks use a groundwater reservoir located on the edge of the area and forming part of the buried valley. Groundwater in the area flows from a south-west/north-east oriented groundwater boundary both into the sea and inland. Surface water The site is covered by the proposed water management plan for Limfjord. The water management plan covers approx. 7,600 km² and affects 18 municipalities: Brønderslev, Herning, Hjørring, Holstebro, Ikast-Brande, Jammerbugt, Lemvig, Mariagerfjord, Morsø, Randers, Silkeborg, Skive, Struer, Rebild, Thisted, Vesthimmerland, Viborg and Aalborg /64/. There are few streams in the area, e.g. one from Gåsemose running into Brokholm Sø and a couple of small streams at Eskær running into Hvalpsund, part of the Limfjord, which also comprises Risgårde Bredning to the north-east of the planned site. In general, the streams, Brokholm Sø and this part of Limfjord are in poor to bad condition (Brokholm Sø). In the water management plan, the environmental target for the streams, the lake and Limfjord is good ecological status Assessment of environmental impact Groundwater The feasibility studies show that the groundwater level may have to be lowered if a repository is established. Particularly wells, but also bore holes, will be susceptible to drying out if the water table drops. In the Thise area, with local groundwater reservoirs in meltwater sand and gravel, it is assessed that drying out of bore holes may occur locally. It is assessed that lowering of the groundwater level in the Thise area will not have any serious impact on the groundwater level or water quality in the groundwater reservoirs from which Thise waterworks is supplied or the groundwater reservoirs in OSD-Breum. Over time, it is possible that water could seep into the facility and polluted water could seep out in the longer term. Depending on the location and design of the facility, this could have varying degrees of negative impact on groundwater and surface water. Repository types With a near-surface facility placed on the surface, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow across the surface or in drains to the sea or into streams, or infiltrate the groundwater. The risk of surface leakage from a near-surface facility is considered to be minimal, as the plan guidelines assume both that the facility will be placed on a horizontal site and that surface water will be handled within the project site.

189 183 of 234 With a near-surface repository going down to 30 metres below ground, or with an intermediate depth facility, there could be seepage directly into groundwater reservoirs or covering layers. If the facility is placed in thick Oligocene clay deposits, these deposits are assessed to constitute an efficient geological barrier that will prevent seeping or transport to groundwater reservoirs. If the facility is placed in the Quaternary strata, the same barrier effect will not be achieved. Contaminated water seeping into or infiltrating the groundwater will find its way into the general flow of groundwater into the reservoirs (in this case, local groundwater reservoirs in meltwater sand and gravel). The water could flow into bore holes supplying Thise waterworks, bore holes and wells supplying individual properties, or into the sea, watercourses or springs. As there is a groundwater boundary in the Thise area, contaminated groundwater may flow in many directions, depending on the location of the facility. Surface water As described under Groundwater, it is possible over time that water could seep into the facility and polluted water could seep out in the longer term, affecting the surface water. There is also a risk of seepage on the surface which could spread to e.g. streams and lakes. The impact may occur both as the repository is being filled and in the longer term, when it is closed. The degree of impact will vary greatly depending on the repository type. Repository types Both a near-surface repository and an intermediate depth repository carry the risk of contaminated groundwater flowing into surface water, including Gåsemose, which runs into Brokholm Sø, and a few small streams near Eskær, which run into Hvalpsund, part of Limfjord. With a near-surface repository there is also a risk of surface water, i.e. streams, lakes and the sea, being polluted in the event of an accident causing a leak or of other seepage from the facility. In the period in which the facility remains open, it will be possible to monitor this impact and take the necessary mitigation measures, but the long-term effects are more uncertain as this plan does not lay down any guidelines in the event of the facility remaining in operation beyond the 30 years it is expected to stay open. Proposals for mitigation measures and monitoring can be found in sections 15 and 16. Table Summary impact assessment. Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Groundwater Yes Yes/No Drinking water interests Comments The impact on groundwater depends on the location of the facility. If the facility is placed in thick Oligocene clay deposits, the clay is expected to form an effective geological barrier. If the facility is located closer to the surface, the geological/ hydrological conditions in the area may have more difficulty averting seepage compared to areas with fewer layers of sand in the Quaternary deposits. Yes Yes Most of the site is designated as an area of drinking water interests. In addition, the Assessment of impact Minor Plan guideline no 3 (Requirements for geological conditions) ensures that any repository will be located in suitable geological formations, so the impact will be limited. None If the facility is placed in thick Oligocene clay. Significant if the facility is placed within the

190 184 of 234 Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments catchment area for Thise waterworks is located within the site. Conflicts in relation to extraction for Thise waterworks can be avoided by choosing a location downstream from its catchment area. Conflicts in relation to individual supplies can be avoided by connecting any individuals extracting water downstream from the repository to the public water supply. Surface water Yes No/Yes The potential conflict arises from potential leakage from a near-surface or intermediate depth facility with seepage into the groundwater and from there into streams, lakes or the sea. An intermediate depth facility is not expected to carry any risk of direct impact on surface water. Any leakage from a nearsurface facility onto the ground will be handled within the repository site, so there is no surface discharge of contaminated water running into streams, lakes or the sea. These matters will be examined more closely during the detailed field studies to be carried out under the Project Planning Act and possibly during the EIA study. Assessment of impact catchment area for Thise waterworks. Minor if the facility is placed downstream from the catchment area for Thise waterworks. Minor if a nearsurface repository going down to a depth of 30 m is established, and not located in thick Oligocene clay. None if a nearsurface repository is established on the ground or the facility is located in thick Oligocene clay deposits; see the description of the impact on groundwater above Soil The section describes the potential impact of the plan on the soil. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site, e.g. in relation to identified contaminated land Environmental status and objectives Contaminated land An analysis of contaminated land pursuant to the Soil Pollution Act may be carried out at either knowledge level 1 (V1 analysis based on reasonable suspicion) or knowledge level 2 (V2 analysis based on actual studies). The two terms therefore only cover a description of whether the property has been examined and give no indication of how contaminated a property might be and with what substances. In this situation, no analysis of the known contaminated land on the site is being carried out, because the scoping found that the plan would not conflict with any existing soil contamination, as it would not prevent a future public clean-up effort. There may also be several pieces of contaminated land on the site which have not yet been analysed, so it is assumed that more detailed studies will be made of the soil in the relevant location in connection with a future EIA study.

191 185 of Assessment of environmental impact Handling of soil During the construction phase, soil will be handled in line with the municipality s guidelines on soil handling. Soil contamination As described in section , there may be an impact on surface water resulting from discharges of substances via seepage into the groundwater. In the same way, substances may be discharged into the soil on the surface. The extent of this impact and the likelihood of it occurring cannot be assessed from the information available at this time. An EIA study involving more detailed investigations of the actual location and a project to produce a detailed description of the barriers will be able to produce a more differentiated assessment of the risk of impact on the soil. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow over the surface into the topsoil. Table Summary impact assessment. Environmental aspects - Soil Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Soil Yes No The potential impact on the soil is linked to any leakage and seepage of contaminated substances via the groundwater. Assessment of impact Minor 12.8 Tangible assets This section deals with tangible assets, which in this context means a presentation of interests associated with agriculture, raw materials and afforestation. It focuses on potential conflicts with areas designated in the Municipal Plan as special agricultural, raw material or afforestation areas. These topics are illustrated on map 5.4: Tangible assets Environmental status and objectives Agriculture Particularly valuable agricultural areas The Municipal Plan designates particularly valuable agricultural areas. Permanent use of these areas for other purposes should be kept to a minimum. Protection of the arable land should not prevent the conservation of nature and the environment. There may therefore be areas within the primary agricultural areas where the town council and other authorities will assume or lay down requirements for various forms of extensive land use when handling specific cases /63/. Most of the planned site is designated as an agricultural area of special value. Exceptions to this are part of the coastal areas and the forested areas. Raw materials Skive municipality contains 21 quarrying areas and 3 areas of interest. Skive municipality is an authority required by the Raw Materials Act to administer in a way that ensures that raw materials on its land are exploited subject to an overall weighing of interests and an assessment of social considerations. The planned site contains no quarrying areas or areas of interest.

192 186 of 234 Afforestation Areas where afforestation is not wanted These areas often contain natural and landscape assets or historical remains that are incompatible with afforestation. There may also be a wish not to disturb a view or the experience of buildings of architectural or cultural historical value. The planned site contains areas where afforestation is not wanted along the northern and eastern coasts and at Thise. Areas where afforestation is wanted Afforestation areas are designated with a view to protecting groundwater and drinking water resources, promoting leisure interests close to towns and improving the ecological corridors within the landscape. Forests are well-suited to protecting drinking water resources from contamination. The planned site contains designated afforestation areas around the existing forest Havbjerg Skov and around Gåsemose Assessment of environmental impact Agriculture The establishment of a repository in the area may conflict with the designation as an agricultural area of special value. A subsequent project design phase may take account of agricultural interests in relation to the division of fields etc. The overall impact is not considered to be significant in relation to municipal planning, as the facility is expected to occupy an area of approx. 150 x 150 m, but the impact will be permanent. Raw materials There is no impact. Afforestation The plan is not assessed to conflict with designated areas where afforestation is not wanted, but may conflict with designated afforestation areas if a future repository is placed within the designated areas around Havbjerg Skov. Repository types The conflicts are independent of the choice of repository type. Table Summary impact assessment. Environmental aspects - Tangible assets Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Agriculture Yes No The conflict cannot be directly avoided by the choice of location for the facility as most of the planned site has been designated or is comprised by other conservation interests. Raw materials No None Assessment of impact Minor A relatively small area will be used for the repository and, on this basis, the direct impact on agricultural interests is considered to be of little significance (see section on indirect effects on agriculture).

193 187 of 234 Environmental aspects - Tangible assets Is there a risk of impact? Afforestation Yes Yes Can the impact be averted or reduced simply by the choice of location within the planned site? Comments The afforestation area (forest wanted) covers a relatively large part of the planned site. Assessment of impact None Areas were afforestation is not wanted are not affected. Minor if the repository is located inside afforestation areas (only where forest wanted ) Cultural heritage This section presents cultural and historical assets in the form of designated cultural environments, church surroundings and cultural heritage sites, the assumption being that the plan will not affect protected ancient sites and associated ancient monument protection lines; cf. plan guideline no 8, Cultural heritage. These topics are illustrated on map 5.5: Cultural heritage. Within the site there are registered protected ancient sites and monuments, and there may be valuable archaeological finds and remains in the area that have not yet been registered. It is assumed that these assets will be examined more closely in a later EIA study, and that the museum will be contacted with a view to more detailed investigations on the actual site Environmental status and objectives Cultural environments In Skive Municipal Plan, 10 cultural environments worthy of preservation have been designated and guidelines laid down for protection of these areas and dissemination of their cultural value. A cultural environment is a geographically defined area that reflects significant elements of the historical and social development of Skive municipality. Cultural environments may include both individual elements and larger entities such as buildings and landscapes. Within the valuable cultural environments, the historical assets should be preserved as far as possible. Building, construction and other activities likely to significantly reduce the experience or quality of the historical assets may not take place /63/. The southern part of the planned site is within the cultural environment Eskær-Grinderslev Kloster. Church surroundings The Municipal Plan also identifies church surroundings within which consideration of the monumental value of the churches in the landscape and villages may not be overlooked when erecting buildings and technical facilities etc. There are designated church surroundings at Thise church. Cultural heritage sites A cultural heritage site is an area of historical interest with hidden ancient sites and monuments. Cultural heritage sites may be of national or regional importance, and indicate that there are significant ancient sites in the relevant area. Cultural heritage sites are not in themselves protected, but they may contain protected ancient monuments. The areas are designated by the Danish Agency for Culture. Part of Havbjerg Skov has been designated as a cultural heritage site Assessment of environmental impact Cultural environments The plan allows for a facility to be located within the designated cultural environment. No building work likely to significantly reduce the experience or quality of the historical assets (the reason for the designation) may take place. The extent of the impact on the cultural environment will

194 188 of 234 depend on the specific project, including the choice of repository type. The impact can be avoided altogether if the facility is located outside the area. Church surroundings The church surroundings of Thise church cover a small part of the planned site and to some extent overlap with the church building line. Plan guideline no 9, Building and protection lines, stipulates that, as far as possible, the repository should not be located within the church building line. Against this background, is it assessed that there is little risk of affecting either the church building line or the church surroundings. Cultural heritage sites Placing the facility inside the cultural heritage site may carry the risk of impact on objects of historical value, as the area is expected to contain protected ancient sites and monuments. If the actual facility is placed inside the cultural heritage site, more detailed studies will be carried out by the museum in the form of archive checks and preliminary investigations. Repository types A near-surface repository will generally have a greater impact on the cultural environment, as this type of facility will have a greater visual impact on the surrounding landscape. The conflicts are otherwise independent of the choice of repository type. Table Summary impact assessment. Environmental aspects - Cultural heritage Cultural environments Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes The cultural environment covers much of the southern part of the planned site. Assessment of impact None if the repository is located north of Thisetorp. Minor to moderate if the repository is located inside the designated area. Church surroundings Cultural heritage sites Yes Yes There are designated church surroundings and a church building line around Thise church, which may be affected. None if the repository is located outside the church surroundings and the building line. Moderate if the repository is located inside the church surroundings and the building line. Yes Yes None if the repository is located outside the cultural heritage area around Havbjerg Skov. Moderate if the repository is located inside the cultural heritage site Cumulative effects Cumulative effects are assessed by viewing the plan in conjunction with other plans or programmes, including previous, current and planned activities. Relevant plans and programmes may cover the same subject-matter, the same geographical area or a neighbouring area. The aim is to ensure that the plan is consistent with other relevant plans and programmes and to assess whether there is any risk of cumulative effects.

195 189 of 234 As described in the preceding sections on the individual environmental aspects, potential conflicts have been identified at Thise with designated zones such as ecological corridors, low-lying areas and cultural environments. Any conflict with low-lying areas will be avoided by inserting a guideline into the plan to prevent the placement of the facility inside this type of designated area. The conflict with other designated objects within the area depends on the final placing of the facility. No higher-level plans or programmes have been identified within the site that might have an increased impact on the environment in combination with this plan Summary assessment The plan provides for the placement of a facility that may impact the environmental in a number of ways, some of which are general effects regardless of the choice of location, as outlined in section 4.2. Implementing the plan at Thise could have local implications that must be taken into account in a possible later planning and project design phase. Of these, the most significant are considered to be linked to the following factors: ecause of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism, agriculture and food production (e.g. Thise Mejeri) and the social structure in terms of a possible tendency for people to leave the area. A small part of the coastal areas may be flooded, and we may expect increased erosion of the coastal cliffs. The areas near Gåsemose and along the banks of the stream around Eskær may be flooded, which will be taken into account in any final placing of the facility. If the facility is placed in thick Oligocene clay deposits, the clay is expected to form an effective geological barrier. If the facility is located closer to the surface, the geological/hydrological conditions in the area may have more difficulty averting seepage compared to areas with fewer layers of sand in the Quaternary deposits. There is a catchment area for a public waterworks (Thise waterworks) within the site. Catchment areas for public waterworks outside areas of special drinking water interests (OSDs) have the same status in terms of groundwater protection as the OSDs themselves. The catchment area for Thise waterworks is defined as a nitrate-sensitive catchment (NFI) area and a priority area (IO), as the groundwater in the Thise area especially is particularly vulnerable. The eastern part of the planned site is located within the designated coastal zone.

196 190 of SKIVE VEST The site lies to the west of Skive on Skive Fjord (Limfjord) and is part of Skive municipality. The site covers an area of approx km 2. The general background to the work on a plan to establish a permanent repository can be found in section 2, the planning guidelines are in section 3, while the methods used to analyse and assess the degree of impact are described in section 5. Figure 13-1 Outline map Skive Vest Planning conditions This section presents the overall planning framework and strategies for the site in the form of Skive municipality s Municipal Plan and planning strategy. The Skive Municipal Plan is based on the Planning Strategy 2013, and building on this strategy, it continues to focus on: Skive as an even better place to live, work and go to school, with urban life, culture and nature. The good life in the villages and in the rural areas, and the balance between town and country. The unique location of Skive municipality on Limfjord /63/ Planning strategy 2013 The strategy is the town council s view of where investment should go in the coming years. It sets out the guidelines for the development of Skive municipality and so forms the basis for municipal planning.

197 191 of 234 The planning strategy is based on seven priority areas, with particular focus on the following themes /67/: Skive a good place to live Campus New jobs Things to do around Limfjord Developing villages A changing landscape Skive Municipal Plan The Skive Municipal Plan is a plan for the future of Skive and an overall plan for its physical development over the next years. The Municipal Plan sets out the general framework for the whole municipality. The Municipal Plan contains the town council s objectives for development in a number of areas. Achieving these objectives requires essential input from citizens, as well as municipal initiatives in many fields. Municipal planning is a dynamic process, and to ensure that the plan is kept up to date and does not end up being irrelevant, the status of development will be reported on a regular basis. The changing conditions will be evaluated here and constant thought will be given to the possible need to revise the plan /63/ Biodiversity This section focuses on biodiversity, which in this context includes a description and assessment of the impact on Natura 2000, Section 3 of the Danish Nature Protection Act, wildlife corridors and national parks or nature reserves. It is assumed that the future facility will not be located in a Natura 2000 area, and that the plan will not have any significant impact on adjacent Natura 2000 areas; cf. plan guidelines. These topics are illustrated on map 6.1: Biodiversity. It is assumed that the local natural assets will be examined more closely in a later EIA study, which will include more detailed investigations of the specific site in the form of e.g. field studies Environmental status and objectives Natura 2000 The planned site does not contain any Natura 2000 areas. The nearest areas are to the southeast, in the form of: Karup Å, Kongenshus Hede and Hessellund Hede, Natura 2000 area no 40, habitat areas H40, H226 and H227. The Natura 2000 area consists of two large moors, Kongenshus Hede and Hessellund Hede, connected by a river valley, Karup Ådal. The area extends all the way from Karup to Skive. Kongenshus Hede mainly comprises the protected Kongenshus Mindepark and is a very large, dry, flat moor. The moor is intersected by several valleys, with Resen Bæk running through one of them, surrounded by low, moist areas with very diverse flora. Hessellund Hede is close to Karup Airport and comprises part of a large military training area. This area is also mainly made up of large, relatively dry areas of flat moor. Karup Å and its valley are protected from Karup town and downstream to Hagebro, and large sections of this part of the river valley are currently meadows and marshes. Throughout the area there are lots of small areas with springs and alkaline fens /69/. Hjelm Hede, Flyndersø and Stubbergård Sø, Natura 2000 area no 41, habitat area H41, bird protection area F29. The Natura 2000 area Hjelm Hede, Flyndersø and Stubbergård Sø covers approx. 2,170 ha and the whole area is a habitat area, large parts of which are also a bird protection area. The area is located between Holstebro and Skive. This large area is a varied, naturally oligotrophic area of natural interest with original nature in the form of raised bogs, springs and oak copses alternating with cultural landscape elements of long standing

198 192 of 234 such as acid dry grasslands and alkaline fens. Large sections are dry moors, reflecting the cultural history of the area. The large lakes in the area are important feeding places for many bird species and for pond bats. Important otter habitats are also found in the area. The biodiversity is considerable, with a number of rare species and sizeable populations of several species characteristic of this type of habitat /70/. Section 3 protected nature Under Section 3 of the Nature Protection Act, it is prohibited to interfere with protected natural habitats in a way that could cause a change to the state of these areas. However, the municipalities may derogate from this provision /11/, often on condition of establishing some natural replacement. Habitats covered by Section 3 of the Nature Protection Act are: Lakes and ponds of at least 100 m 2. Marshes, meadows, heaths, dry grasslands, coastal meadows and tidal marshes which individually or together cover an area of at least 2,500 m 2. Marshes under 2,500 m 2 are also protected if they are next to protected streams or lakes. Most streams and rivers are also protected via a special Section 3 designation. Lakes include both natural and wholly or partly man-made pools, basins and dams. The site contains few protected areas of natural interest (cf. Section 3 of the Nature Protection Act) in the form of meadows, ponds and lakes (including the fairly large Rettrupkær Sø in the south-western part of the area), marshes and a few areas of dry grassland. There are several streams in the area, of which the largest Rettrup Bæk, Kærsgaard Bæk and Krarup Møllebæk flow north/south across the site. Nature conservation areas The maps show certain natural networks of special nature conservation areas and potential areas, and existing and potential ecological corridors. Natural assets and landscape features in these areas will be protected against any action that compromises nature and the landscape. Conservation should take priority over all other interests. Interference with natural assets of moderate quality may be allowed, provided that the activities bring about improved living conditions for the natural fauna and flora. Ecological corridors have been designated along the large streams, around Rettrupkær Sø and Brøndum-Hvidbjerg Plantage. Low-lying areas Low-lying areas should be kept free of buildings and facilities as far as possible. Sections of the low-lying areas are designated for restoration or establishment of wetland areas. These areas are referred to as potential wetland areas. Any necessary buildings or facilities should be designed in a way that permits the area to be restored to its natural state. Low-lying areas and potential wetland areas have been designated in a large interconnected area in the southern part of the planned site, comprising, inter alia, Rettrupkær Sø and Brøndum- Hvidbjerg Plantage. Beach protection Not relevant to this area. Protected forest The vast majority of private woods and all public woodland in Denmark have the status of protected forest (fredskov) and are safeguarded by the provisions of the Forestry Act. The site is

199 193 of 234 dotted with protected forests, including Brøndum-Hvidbjerg Plantage and small planted areas in the open countryside. National or local parks There are no national parks within the planned site or in the immediate vicinity. Efforts are being made in Skive municipality to identify small local parks or nature parks. There is currently a proposal for a Flyndersø Sønder Lem Vig local park. The area extends from Venø Bugt in the west towards Sønder Lem Vig, Gammel Rønbjerg, Flyndersø to Karup Ådal and comprises large interconnected nature areas and agricultural areas. Part of the planned site is within the planned local park. Figure 13-2 The local park Flyndersø Sønder Lem Vig (planned site shown in blue) /71/ Assessment of environmental impact General It is impossible to define criteria for protecting the environment against radiation as there are no statistics covering the health impact of ionising radiation on animals and plants, as there are for people. Internationally, projects have been launched to determine the effect of ionising radiation on nature and, on this basis, to use reference animals and plants as a means of establishing criteria and producing subsequent safety analyses. The progress of these projects will be monitored and taken account of as far as possible in defining environmental protection criteria when the safety analyses are carried out in a later EIA phase /15/. Human beings are generally considered to be the organism that is most vulnerable to ionising radiation. Therefore, once criteria have been established to safeguard people, we may assume that animals and plants will be sufficiently protected against radiation. Exceptions to this assumption will mainly apply to a small population of a species in a restricted area around the repository /15/.

200 194 of 234 The environmental protection criteria applicable to a given repository will be drawn up in conjunction with the mandatory EIA studies to be carried out for two selected sites if it is decided to proceed further with the permanent repository concept. In this connection, detailed field studies will be carried out as part of the basis both for assessing potential effects and for defining environmental protection criteria. This will ensure that local conditions are taken into account in the form of site-specific assessments concerned with protecting the environment. This section presents the general conflicts with nature conservation interests. Natura 2000 Due to the distance to Natura 2000 area no 40, Karup Å, Kongenshus Hede and Hessellund Hede, and Natura 2000 area no 41, Hjelm Hede, Flyndersø and Stubbergård Sø, the plan is not judged to have any impact on these areas. Furthermore, the guidelines to the plan explain that any future facility may not have any significant effect on adjacent Natura 2000 areas (guideline no 7, Nature). The future planning and project design must therefore ensure that a facility can comply with these provisions. If it is considered relevant despite the great distance from these areas, a materiality assessment will be carried out, which will consider whether there is a risk of significant impact on the Natura 2000 area. If it is considered that there is a risk of significant impact, an impact assessment will be carried out. The purpose of this is to examine the potential impact in relation to the conservation goals for the area, and to incorporate mitigation measures into the project in order to avert any serious impact. Section 3 protected nature There is a risk of impact on Section 3 protected areas where the facility itself or the access roads are positioned in direct conflict with the protected area. As the gross area is relatively large, there is every chance of placing the facility so that it does not affect protected areas. This consideration should therefore be included in subsequent planning and project design. No guidelines have been included in the plan to guard against conflicts with Section 3 protected areas, as other factors determining the ideal positioning may result in conflicts with Section 3 protected areas. Nature conservation areas The plan may affect nature conservation areas in the form of ecological corridors within the site. Plan guideline no 7, Nature, states that the positioning chosen for the facility should take maximum account of, inter alia, ecological corridors. The impact depends on the eventual positioning of the repository. Low-lying areas It is assumed that the facility is placed at a location which is not in conflict with the potential wetland areas, cf. plan guideline no 12, Designated low-lying areas and potential wetland areas. Beach protection No impact. Protected forest Within the site, there are small areas of protected forest that may be affected. National or local parks The plan may be in conflict with the planned Flyndersø Sønder Lem Vig local park. Direct conflict between the repository and this area can be averted by the choice of final location. If the repository is placed within the planned local park, this will be in conflict with the designation. Relative to the total size of the local park, the direct impact in the form of closing off of land is

201 195 of 234 found to be of little significance, and hence the impact on nature depends on whether the repository will affect protected nature. The potential indirect effects of placing a repository within the planned local park in terms of population, tourism, recreational opportunities, etc. are described in section Repository types The three types of repository take up the same area, so will result in the same risk of impact to nature arising from any closing off of land and hence of a potential impact on Section 3 areas, nature conservation areas and protected forests. As mentioned above, it is assumed that Natura 2000 areas, beach protection belts and low-lying areas will not be affected whatever the choice of repository. Table 13-1 Summary impact assessment. Environmental aspects Biodiversity Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Natura 2000 No - The guidelines to the plan state that a facility cannot be established under this plan if there is a risk of significant impact on Natura 2000 areas. The concrete assessment of whether the facility can meet this requirement will be made in a later EIA phase, when the location, repository type etc. are known. Section 3 protected nature Nature conservation areas Low-lying areas Beach protection belt Yes Yes The facility can be located where it does not conflict with protected areas. Yes Yes There is a risk of conflict with nature conservation areas. No - It is a precondition that the facility is not placed in areas designated as lowlying areas, cf. plan guideline no 12, Designated low-lying areas and potential wetland areas. Assessment of impact None No - Not relevant here None None or minor The degree of impact depends on the positioning of the repository. None or minor Plan guideline no 7. Nature, ensures that the placement of the facility should take maximum account of interconnected designated nature areas, wildlife corridors etc. The degree of impact depends on the eventual positioning of the repository. None

202 196 of 234 Environmental aspects Biodiversity Protected forest National or local parks Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes There is a risk of impact on protected forest areas. Yes Yes There is currently a proposal for a Flyndersø Sønder Lem Vig local park. The local park covers approx. half of the planned site. Assessment of impact None or minor The degree of impact depends on the positioning of the repository. None if the repository is located outside the planned local park. Minor to moderate if the repository is located inside the local park Population and health This section describes the location of the planned site in relation to built-up areas, the number of inhabitants, commercial activity, tourism and recreation. It is mainly based on information from Statistics Denmark and the Municipal Plan. The section then describes the potential impact on the population in terms of health risks and indirect environmental effects, including the risk of reduced revenue, relocation etc. The assessment of the impact is based on available information from e.g. descriptions of transport and radiation in the feasibility studies. It is assumed (cf. plan guidelines) that the facility will be designed to be able at any time to demonstrate compliance with the specified dose constraints when in operation and after closure for those periods and for potential incidents (accident scenarios). Documentation of this will be provided in the form of safety assessments for the facility and its use. The assessment of the indirect environmental impact on the population and industry identifies potential effects based on an analysis of responses to consultation and comments from public meetings focussing on e.g. people s concerns about the effects of implementing the plan Environmental status and objectives Population Within the planned site there are a number of villages such as Hvidbjerg and Rettrup along Holstebrovej, where there are also a few properties. Furthermore, individual properties are spread across the area, especially in the northern part. From Holstebro there is a network of small, but well-maintained roads; however, there are not so many in the southern part of the area. The distance to towns and villages can be seen in Table Table 13-2 Distance from major built-up areas. Distance from built-up area: Skive: approx. 1 km Højslev Stationsby: approx. 8 km Hem: approx. 1.5 km Rønbjerg Stationsby: approx. 1.5 km

203 197 of 234 Skive municipality contains 18 towns (urban zones) and 30 villages. 25% of the population live outside built-up areas. The population figures for the larger towns and villages in Skive municipality can be seen in Table 13-3 (as of 2012). Table 13-3 Breakdown and number of inhabitants in Skive municipality (2012) The breakdown and number of inhabitants is as follows: Skive: 20,562 inhabitants (2012) Højslev Stationsby: 2,728 inhabitants (2012) Hem: 596 inhabitants (2011) Rønbjerg Stationsby: 375 inhabitants (2011) Hvidbjerg 356 inhabitants (2011) Rettrup: Fewer than 200 inhabitants There is continued local development in the rural areas. The total population is expected to fall, but some of the local urban zones will experience a certain growth. The Municipal Plan does not propose any changes in the local pattern of towns and villages. Overall, capacity presumably exceeds the expected demand, but the town council has only to a limited extent wished to reduce planned residential areas, which have in most cases already been developed and to some extent also built up. Industry The Skive Municipal Plan reflects a business policy which aims to create growth and development. It is built around these six priority areas: Sustainable energy Education and training Business development and innovation Enterprise Attracting a qualified workforce Infrastructure As part of the analysis of the commercial conditions, the numbers of people employed in the whole of Skive municipality have been surveyed, broken down into tourism and leisure, agriculture, fishing and food production, as shown in Table These matters are considered crucial in terms of the impact on the population and health and the indirect socio-economic factors. The chart shows a selection of the key industries with an assessment of the socioeconomic factors, but in reality, employment will be greater because a number of other professions will be linked to these industries to a greater or lesser extent. The analysis of employment has been carried out for the whole of Skive municipality, as it is felt that implementing the plan may affect a major part of the local community and not just the planned site itself.

204 198 of 234 Table 13-4 Breakdown of employment in Skive municipality within selected industries related to tourism and leisure, agriculture, fishing and food production, as of The total number of people employed in Skive is 22,366 (Statistics Denmark 2013). Agriculture The Municipal Plan includes guidelines for farming, mainly agriculture but also covering horticulture and forestry. Agricultural production has a major bearing on development in Skive municipality in terms of employment, income and housing. The designation of areas of special agricultural value is described in section Tourism Skive municipality s tourism and leisure policy focuses more strongly on how tourism in the municipality can be increased. The options for tourism and leisure are described in the Municipal Plan as generally good. This is mainly down to its proximity to the coast, but also to improved information, accommodation and access. Tourism makes a positive contribution to the economy of the municipality, and in most places it is on a scale that allows it to operate in harmony with the local population and the natural world /63/. Recreational areas There are no summer cottage areas, camping sites or designated trail systems within the site, but there are recreational areas in the form of Rettrupkær Sø and small streams. Outside the area, there are recreational values linked to e.g. Karup Å, and as previously mentioned, the planned site is also part of the planned Flyndersø Sønder Lem Vig local park Assessment of environmental impact The assessment of the impact on the population covers health (related to transport, risk of accidents and radiation, safety and security of the facility itself), and socio-economic factors, including the population, commercial interests, tourism and recreational activities. Health Radiation protection The health impact of radiation from the facility itself and from accidents is described in section 4.2, as the same requirements apply to safety assessments and official approval regardless of the choice of site.

205 199 of 234 Transport Based on the feasibility study, we conclude that both road and sea transport may be considered. The radiation doses estimated for transport of Danish radioactive waste from Risø to a future permanent repository in Denmark have been calculated on the basis of the greatest possible distance to any repository. The estimated doses in the feasibility study are therefore upper limits, and doses from shorter transport routes will be proportionally lower. The study shows that the risk associated with road and sea transport does not restrict the future selection of a location for a repository in Denmark, and that the transport can be handled so that the dose is well below the national thresholds. The three locations in Jutland Thyholm, Thise and Skive involve the longest transport routes from Risø whether road or sea transport is chosen. Changes in distance have no effect on doses in the event of an accident. The likelihood of an accident is dependent on things like the quality of the road and the volume of traffic, and is also proportional to the distance. Compared to the zero alternative, the radiation dose is greater in the short term as a natural consequence of the fact that, in the zero alternative, the waste will not be processed as much, or transported from the location. In the longer term, it will be necessary to process and possibly transport the waste under the zero alternative too, as Risø does not have the status of a permanent repository. Socio-economic factors Apart from the general issues mentioned above, the stakeholders have drawn attention to a number of local matters that should be given special consideration in the choice of destination and in implementing the plan if a repository should become a reality in their particular area. Table 13-5 presents the major concerns raised by stakeholders in the whole of Skive municipality. The table summarises local issues relating to both planned sites in the municipality Thise, Salling and Skive Vest the assumption being that location of a permanent repository within one of these sites may have an impact on local conditions that extends beyond the planned site in question and is therefore relevant for the whole municipality. This local information is used as part of the background to the description of the potential impact on the population and the socio-economic factors, and also forms the basis for suggested mitigation measures (section 15.2). Table 13-5 Summary of the major concerns raised by stakeholders in Skive municipality applicable to both Thise, Salling and Skive Vest *. Subject A CLEAN LIFE Description Skive municipality has a master narrative defining the identity of the area, which can be summarised as a CLEAN LIFE. The central values in this narrative are to do with living an active and clean life in the natural and cultural environments that characterise the area. According to the stakeholders, this master narrative is a great asset, which is why the municipality has identified itself with the CLEAN LIFE brand ( RENT LIV ). In this connection, stakeholders express concern that a repository will have an adverse effect on the values and narrative of the area. The same narrative is also used to help create new jobs in the area, and products of local businesses often carry the CLEAN LIFE brand name. This includes organic products for human consumption such as milk, meat, eggs, vegetables etc. and the origin of the animal feed is often part of this positive story also. Concrete examples are Thise Mejeri, which uses the brand for its organic dairy products, and Glyngøre Shellfish, which supplies oysters from Limfjord. The stakeholders are sceptical as to how the idea of a repository can be reconciled with this.

206 200 of 234 Subject Recreational areas Cultural heritage Access roads and safety Hazardous waste Drinking water Description Skive municipality also contains a number of recreational areas. Examples are Flyndersø Sønder Lem Vig nature reserve, which attracts tourists and biologists with its special fauna; Karup Å, which is known for its trout; the popular spot for anglers at the pumping station on Sønder Lem Vig; the recreational area around Skive harbour, which attracts sailors, divers, surfers, kayakers and others who enjoy the maritime facilities of the fjord; the Sundgården summer cottage area near Thise; and the Brokholm Nature Centre with associated facilities at Gåsemose. The stakeholders express concern about the adverse effect a repository could have on the attraction of these places to tourists, causing them to lose their value as recreational areas. Specifically, they call for an examination of the social consequences in this regard from any seepage from a repository. The stakeholders point to a high risk that there could be unknown archaeological remains and monuments inside the designated areas, which could be uncovered in any construction work. The establishment of a repository must therefore be subject to studies and planning to take account of this. The stakeholders point out that transport to and from a repository in these areas will involve driving on narrow roads and through built-up areas. Concerns are expressed about safety in this regard. The stakeholders express concern about the state s handling of hazardous waste. They cite previous cases in West Jutland relating to Cheminova s toxic waste repository, Høfde 42. They also express concern about the Skive area becoming a permanent centre for radioactive waste even after the repository closes 30 years after opening. It is therefore important for the stakeholders to feel comfortable with what the plan involves, how any seepage will be monitored and what will be done if it occurs. The stakeholders state that there is already a shortage of drinking water in Skive municipality and that the water table is close to the surface in Thise. There are therefore concerns about the risk of impact on already limited water reserves. *This description is extracted from minutes of the public meeting held in Skive and from responses to consultation on the scoping report. Summary The questions relating to the establishment of the facility itself, and the practical problems that may arise as a consequence, are not dealt with in depth in this report because of the level of detail in the plan. The project-specific issues with question-marks against them will be addressed in a later phase, when risk assessments and radiation protection work will be carried out in conjunction with the subsequent work by the authorities once there is an actual project. These concern things like access roads, traffic routes, the risk of accidents and the handling of hazardous waste. The following subjects are addressed at a high level in other sections of the environmental report: Groundwater, drinking water and surface water are discussed in section 13.6 The cultural heritage is discussed in section 13.9, but the plan guidelines assume that protected areas and ancient monuments will not be directly affected. Possible indirect implications of concerns with a bearing on the plan are described below. If we look at the comments from stakeholders of both a general and a local nature, we see that they are marked by a high degree of concern. These concerns are directed at a broad and diffuse set of risks, which indicate a lack of knowledge of the real risks involved in implementing the plan and of the measures that have been and will be taken to avert these risks. The comments also show that the stakeholders do not have sufficient knowledge of the process to be followed in the future, leading to widespread insecurity and mistrust. The stakeholders do not feel convinced that the future process will adequately examine and address the perceived risks and involve the stakeholders, to ensure that local interests are safeguarded. For these reasons, the analysis shows that the plan to establish a repository has received a very negative response from the stakeholders. This negative attitude, insecurity and mistrust of the plan and the projected process create the ideal conditions for a number of negative social effects to become reality. In such a situation, it is not inconceivable that a permanent repository could have derived negative effects on tourism

207 201 of 234 and outdoor activities, such as the planned local park at Flyndersø Sønder Lem Vig, land and property prices, sales opportunities for local agricultural produce, and the mental wellbeing of residents in the area, etc. purely because of insecurity and mistrust. It is therefore crucial to the social effects of the plan that the insecurity and mistrust should be reduced. Overall, there may be a risk of impact on socio-economic factors, including tourism and the food industry. The plan may thus conflict with the overall strategies that exist for the area, as described e.g. in the Skive Municipal Plan including the overall vision of a CLEAN LIFE, which encompasses health aspects, nature, culture, food production etc. Table 13-6 Summary impact assessment. Environmental aspects Population Health Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Radiation protection Securing the facility Yes Yes The impact in the immediate vicinity will depend on the final location. Yes Yes A vulnerability assessment should cover different scenarios and their consequences. These scenarios should be covered by security and contingency plans designed to assure the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the dose constraints) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraint. As with the category of transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses. Minor (below the dose constraint) It is a condition for implementing any future project that it should be possible to provide documentation of compliance with safety requirements expressed in terms of the dose constraint. As with the categories of radiation protection and transport, there will be a requirement to optimise facilities and practice to achieve the greatest possible reasonably attainable reduction of risks and potential doses.

208 202 of 234 Environmental aspects Population Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Transport Yes Yes The impact in the immediate vicinity will depend on the final location. Noise, heavy traffic and emissions may have an impact in connection with transport within the planned area. Socioeconomic conditions Yes Yes/No. In recreational areas etc. the impact may be dependent on the final location, but the general concern about the impact on the population and industry is considered to be independent of the final location and in many cases people expect an impact beyond the planned site itself. Implementing the plan may cause indirect effects on the population and socio-economic conditions. The stakeholders highlight a number of issues that cannot be addressed at this introductory stage of the planning process, but these issues will be examined more closely in an EIA phase and in conjunction with safety analyses and official approvals. Assessment of impact Minor (below the thresholds for exposure to radiation). Estimated doses for transport to the planned site are well below the dosage thresholds. There will be a need to plan transport routes, times etc. to achieve a reduction of risks and potential doses. Moderate to significant The impact is judged to be of moderate to significant importance because of the high level of concern and the uncertainty expressed among the stakeholders. This should therefore receive close attention in the later phases Landscape and geology This section presents geographical and geological conditions within the planned site, which here encompass a high-level description of the landscape and any designated areas and a description of the geological conditions based on the feasibility studies, with any designated features. These topics are illustrated on map 6.2: Landscape and geology. The assessment of the impact on the landscape is based solely on whether there is a risk of impact on valuable landscapes and designated coastal zones. It is assumed that the real impact on the landscape and visual factors will be determined in a later EIA study, where landscape analyses, visualisations etc. can be based on the choice of a specific location and a concrete project proposal. The purpose of examining the geological conditions is to assess the degree of uncertainty as to the ability of the geological conditions to act as a physical barrier around a possible repository. It is assumed that the local geological conditions will be examined in more detail in a later EIA study Environmental status and objectives Landscape Landscape description This site comprises two different types of landscape. The northern half is a high, rolling moraine landscape with meltwater sand and gravel deposits. The terrain lies at an approximate altitude of between 10 and 40 m above sea level. There are no lakes, but several streams run through the area. The two parts of the site are separated by an inactive, overgrown, gentle slope. The southern half of the site is a low-lying river valley which developed on an east-west oriented former flat

209 203 of 234 moor. Most of the land is around 5 m above sea level. Parts of this area are waterlogged, with lots of small ponds and waterlogged meadows. Due to the intense cultivation, all surface processes are slow and undramatic. The most dynamic places are around the streams /6/. Designated coastal zone The designated coastal zone is defined in the Planning Act and is approx. 3 km wide. The rule is that the designated coastal zone must be kept free from buildings and facilities that are not dependent on proximity to the coast. The planned site is outside the designated coastal zone. Planning Act: Section 5b. The following shall apply to planning in the designated coastal zone: 1) It is prohibited to transfer land to an urban zone or to conduct planning for development in a rural zone unless there is a specific planning-related or functional justification for location near the coast. Areas of special landscape value Skive municipality has an objective to keep the countryside free of any building other than what is commercially necessary for the farms and to prevent the unplanned, random spread of buildings and facilities in the countryside. In areas of special landscape value, the character and feel of the landscape should be preserved. Conservation should take priority over other interests. Actions that alter the character of the landscape in these areas may only be taken if the overall result is to improve the ways in which the public can experience the landscape /63/. The southern part of the planned site has been designated as a landscape worthy of preservation. Geology A detailed discussion of the geological conditions can be found in GEUS report no 6 /6/. Under Ice Age deposits of varying thickness there are earlier, fine-grained Paleogene and Neogene clay deposits up to 100 m in thickness. The following description is a summary of the geological conditions described in the local area study. Deposits and soil types The deposits on the pre-quaternary surfaces are expected to be from the Oligocene and Miocene epochs. Several bore holes reach Oligocene or Miocene deposits beneath 5-10 m thick Quaternary deposits. In the south-western outskirts of Skive, in the clay quarry at Hesselbjerg, Oligocene clay has been dug for several years, and the area is still an area of raw material interests. The clay, known as Skive clay and dating from the Upper Oligocene sub-epoch, is finegrained and silty, greyish-green, in places chalky, with mica, glauconite and pyrite. Bore holes show that Skive clay is found in the eastern part of the area, where a few bore holes reach a depth of 100 m. In bore holes in the central part of the area, to around Hvidbjerg, clay from the Upper Oligocene Brejning formation dominates. This is black, blackish-brown or dark brown micaceous, layered, silty, relatively heavy or heavy clay. It also contains silt and sand lenses, as well as thin sandstone layers. The formation is at least 20 m thick in this area. Clay from the Brejning formation can be seen at Lyby Klint north of the site. To the west there are deposits of micaceous clay and micaceous sand from the Lower Miocene Vejle Fjord formation. This formation consists of dark brown and black micaceous clay and clayey silt. The clay is often layered. The formation is at least 34 m thick in this area.

210 204 of 234 Deposits from the three formations were formed in the sea and hence they can be expected to cover a large horizontal area. Surface geology is dominated by Quaternary deposits. Clayey till dominates in the northern part of the area, while in the river valley and on its banks in the south, from Skive and west to Sønder Lem, there is meltwater sand and gravel. Post-glacial freshwater deposits cover the meltwater deposits in the central part of the valley. The mouth of Karup Å is near Skive, and here marine post-glacial deposits are found on top of the freshwater deposits. Bore holes show that the Quaternary deposits are often up to 10 m thick, but greater thicknesses are seen locally, and on the fringe of the site Quaternary deposits can reach a much greater thickness. The dominant deposit type in the bore holes is clayey till. In the clayey till, there are up to 3.5 m thick layers and lenses of meltwater sand and gravel. At some places in the periphery of the site (Hem, Krarup, Hesselbjerg) there are up to 37 m thick layers of meltwater sand and gravel. The post-glacial deposits consist of thin marine layers and up to 3 m thick layers of freshwater peat and clay. Mineralogy binding adsorption The geochemical conditions in the deposits have a bearing on how radioactive material will behave if it should leak out of a repository into the surrounding geological strata. Some general observations are set out below. However, the large number of radioactive components in the waste may behave differently in the surrounding deposits. A key element is that the radioactive material should be able to bind to the deposits. The uppermost layer consists of clayey till and meltwater sand deposits, but we know of no analyses of these. The Vejle Fjord formation consists of silt with a lower clay content. There is 15-30% smectite, 40% illite and 30% kaolinite on average. Clay from the Brejning formation is made up of 50% clay fraction and 40% silt with fairly little coarse material such as glauconite and pyrite (10%). The clay mineralogy is 30-40% smectite, 36-40% illite and up to 30% kaolinite. The mineralogical composition may be different in East Jutland, for example. In the Skive clay, the clay mineralogy is: 53% smectite, 26% illite and 21% kaolinite. Branden clay comprises 50% clay fraction and 50% silt, and the mineralogy is 20-50% smectite, 30-60% illite and the rest kaolinite. Clay minerals, especially smectite clay minerals, are particularly wellsuited to binding radioactive material. They are present in relatively large but varying quantities in the deposits. This means that the clay deposits have the potential to bind the radioactive components. Redox conditions The behaviour of the radionuclides in relation to the oxygen content in the strata and groundwater (redox conditions) will depend on the types of chemical compounds and chemical properties involved. The concentrations of these components in the strata and the water, and their ph, also have a bearing on the processes that will occur. There is oxygen present in the uppermost layer of soil (the oxidised zone), and this may for example mean that some radioactive components can be made mobile and hence transported more easily. Conversely, the conditions in the oxygen-free (reduced) zone, for example, will help to bind and hold other radioactive components. In the area, the oxidised zone seems to continue to 9 m below ground level. That means that some of the Quaternary clayey till and the Palaeocene deposits from the Vejle Fjord formation, the Brejning formation and Skive and Branden clay are in the reduced zone.

211 205 of 234 Natural radioactive components in the deposits Where monitoring is to be carried out around an established repository, it is important to know the baseline radioactivity. There are few known values for the area 39 Bq/kg radium in micaceous clay and Bq/kg in the Brejning formation s clay. Assessment of geological conditions The geological conditions influence the impact of the repository on both surface water and groundwater. The geological conditions need to be consistent and stable within the site and they must contribute to the stability of the repository. The geological strata should help to isolate the waste from the surroundings by enclosing or underpinning the repository. The rocks should be low-permeable and help to bind the radioactive components from any discharge from a repository /15/. These issues are assessed in Table In the table, the geological conditions are assessed only in relation to a repository placed in the pre-quaternary rocks, in this case the Oligocene and Miocene clay rocks. If the repository is located in Quaternary deposits, clayey till probably containing fractures and sand lenses and occasional sand and gravel layers will only partly isolate the waste from the surroundings. Table 13-7 Assessment of the geological conditions in terms of stability, low-permeable rocks and binding of radioactive components. Property Assessment Comments Consistent and stable geological conditions contribute to the stability of a repository. Yes The Oligocene and Miocene clay deposits appear to be consistent and very thick in the area. Geotechnical stability will be addressed in any specific project The geological strata help to isolate the waste from its surroundings: Low-permeable rocks. The geological strata help to isolate the waste from its surroundings: Binding of radioactive components. Yes Yes proposal. The Oligocene and Miocene clay deposits are lowpermeable. The Oligocene and Miocene clay rocks have a high content of clay minerals, including a high content of smectite. Clay minerals, especially smectite, are particularly well-suited to binding radioactive material. This means that the Oligocene and Miocene clay rocks have the potential to bind the radioactive components. Summary There are early, thick, fine-grained clay deposits from three or four Paleogene-Neogene formations (up to 100 m thick) covering a large horizontal area. These layers appear to be undisturbed within the area. The properties of these clay types will be able to hold back any discharge of radioactive material from a repository. The early deposits are covered by later, Quaternary deposits, particularly of clayey till, but also meltwater sand and gravel. Experience shows that clayey till contains fractures and sand lenses. Areas of geological interest In Skive municipality there are five areas of National Geological Interest. There are no areas of geological interest within the planned site. The nearest designated area is west of the planned site at Hesselbjerg Lergrav Assessment of environmental impact Landscape According to the guidelines to the Municipal Plan, the landscapes worthy of preservation in the southern part of the site should be protected so that the character and feel of the landscape is preserved. A future facility may conflict with the designated status if it is found that it causes a significant change to the landscape which conflicts with its special character. It is felt that a nearsurface repository will have a greater impact on the landscape than an intermediate depth

212 206 of 234 repository, but this can only be properly assessed when the location and the repository type have been decided. Conflict can be avoided by placing the facility outside the designated landscapes. The visual impact will depend on the repository concept and design. If it decided to choose a design to make the facility recognisable and visible, e.g. for safety reasons, this will immediately make a greater visual impact than a repository concept that is more integrated into the landscape. The final assessment of the scale of the impact will be made as part of the EIA studies. Repository types It is felt that a near-surface repository will have a greater impact on the landscape than an intermediate depth repository, but this can only be properly assessed when the location has been decided and there is a description of the repository type, dimensions, choice of materials and colours, planting, fencing etc. Geology The plan is not expected to affect the general geological conditions significantly, but the geological conditions have a major bearing on the suitability of the site for the establishment of a repository. The geological description will therefore be used as background material to any assessment of the impact on groundwater and surface water. There are no areas of geological interest within the planned site. Repository types The potential impact on the geological features is expected to be similar for each of the three repository types, as the total surface area required will be the same whatever repository type is chosen. Table 13-8 Summary impact assessment. Environmental aspects Landscape and geology Designated areas Designated coastal zone Geological designations Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes The southern part of the site has been designated as a landscape worthy of preservation. No - None No - None Assessment of impact None if the repository is located outside the designated area. Minor to moderate if the repository is located inside the designated area. A final assessment of the impact requires an actual project and visualisations to be produced in a future EIA phase Climate Climate change could affect the future repository because of the increased risk of extreme events. This section describes the future scenarios that are being examined in Denmark and abroad, to serve as a basis for assessing whether the planned site is expected to be significantly affected by changes in the climate.

213 207 of 234 It is assumed that a future facility (see plan guidelines), via its design and placement in the landscape, will be adapted to any future climate change and thus less vulnerable to extreme events /6/ Environmental status and objectives Based on the latest Danish and European scenario analyses, the Danish Meteorological Institute (DMI) has described the expected future climate changes in Denmark out to The assessments are based on the scenarios used by the UN s International Panel on Climate Change (IPCC) /20/. The changes are expected to increase towards the year Considerations of climate change are relevant to the placing of the repository because of the risk of rising sea levels flooding the facility, which could lead to penetration by surface water and hence an increased risk of radioactive substances spreading into the environment. The DMI report suggests that Denmark will experience warmer and wetter weather in the future, with more extreme events such as longer periods of drought and heavier rainstorms, and temperature increases. It also projects a general rise in sea levels in the waters around Denmark /20/. More recent projections are now pointing to even greater rises in sea levels around Denmark, ranging from 80 ±60 cm to max. 150 cm by There may be further increases towards 2200, but estimates are extremely difficult and fraught with very great uncertainty /20/. The planned site consists of two very different main landscape types to the north and south. The northern area, which is a hilly landscape with several streams, is approx m above sea level. The southern area is a very flat landscape characterised by a river valley which developed on a former flat moor. Throughout most of the area, the land is around 5 m above sea level. At places it is fairly moist, with several water meadows/marshes and one lake, Rettrupkær Sø. The two main landscape elements are separated by an inactive, overgrown cliff /6/ Assessment of environmental impact Rise in sea level If we assume a rise in water levels of max. 1.5 m in the seas around Denmark (by 2100), this is not expected to flood the area. However, the southern part of the site is expected to become still wetter as (other things being equal) the water table will rise as a result of rising sea levels. Land uplift in the area is estimated at around 0.50 mm per year, and if this continues, it will help to reduce the effect of rising sea levels albeit to a very modest extent /6/. Extreme events The site is not exposed to storm surges and flooding from the sea due to its geographical location away from the sea as well as its altitude. Extreme precipitation may affect the flow of water in the streams, and increased precipitation volumes combined with a higher water table will presumably increase the waterlogged areas, not least in the southern part of the planned site/6/. Repository type The planning guidelines describe how the facility will be constructed to ensure that it can cope with sudden floods (climate-proofing), whereby the surroundings will be safeguarded against emissions even in the case of climate change and extreme rainfall.

214 208 of 234 Table 13-9 Summary impact assessment. Environmental aspects Climate Rising sea levels Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes The southern part of the site is expected to become wetter, which should be taken into account if it is decided to place the facility in this area. Extreme events Yes Yes Extreme precipitation may affect the flow of water in the streams, and increased precipitation volumes combined with a higher water table will presumably increase waterlogging in the southern part of the Skive site. Assessment of impact None or minor provided that the location of the facility within the area is taken into account, as the southern part of the site is expected to become wetter. Plan guideline no 11, Climate, also describes how allowance will be made for climate change in the design and placing of the repository. None or minor 13.6 Water This section describes the issues relating to groundwater and surface water within the planned site. It is based on information from local area studies and municipal designations. The impact assessment is based on the descriptions of the geological conditions (section 13.4), as the impacts on groundwater and surface water depend largely on these. Drinking water interests are illustrated on map 6.3: Drinking water interests. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site Environmental status and objectives Groundwater General The overall reservoir system on Salling is characterised by buried valley structures. There is a secondary groundwater reservoir from ground level down to a depth of approx m. Beneath this is an upper primary deeper groundwater reservoir with a thickness of approx m /6/. The secondary and upper primary reservoirs, consisting of meltwater sand, are found in practically all of Salling. At the Skive Vest site, there are small, local near-surface groundwater reservoirs in the form of thin deposits of meltwater sand and gravel. Deeper groundwater reservoirs of sand and gravel have not been found in the area. There is a groundwater boundary in the area, running northsouth through Hvidbjerg. This location means that any contaminated substances seeping out of a permanent repository could flow either west or east. Streams in the area drain the groundwater, but contact between groundwater and streams has not been investigated. Model calculations show that there is fairly substantial groundwater formation ( mm/year) in Skive Vest. This is not reflected in the median minimum water flow in streams in the area.

215 209 of 234 Drinking water interests The most important groundwater resources for drinking water supplies are designated as areas of special drinking water interests (Danish: OSD), which are meant to cover current and future needs for water of drinkable quality. In these areas, an extra effort will be made specifically to safeguard the groundwater, in order to prevent contamination and remove any existing pollution. OSDs are the core areas for this targeted groundwater conservation. This means that such areas are regarded as strategic catchment areas and that the municipalities need to take account of the groundwater resources and catchment areas for public waterworks in their physical planning. Most of the site is located within an area of drinking water interests (Danish: OD). In the eastern part of the area near Lundbro, there are no drinking water interests. There is no extraction for public waterworks in the area, but the small, near-surface groundwater reservoirs are used for individual supplies etc. Surface water The site is covered by the proposed water management plan for Limfjord. The water management plan covers approx. 7,600 km² and affects 18 municipalities: Brønderslev, Herning, Hjørring, Holstebro, Ikast-Brande, Jammerbugt, Lemvig, Mariagerfjord, Morsø, Randers, Silkeborg, Skive, Struer, Rebild, Thisted, Vesthimmerland, Viborg and Aalborg /64/. Streams in the area include Krarup Møllebæk and Rettrup Bæk, as well as several minor tributaries. As mentioned above, there is a groundwater boundary in the area, running northsouth through Hvidbjerg. This location means that streams flow either west (Rettrup Bæk) to Sønder Lem Vig or east (Krarup Møllebæk) via Skive Å to Skive Fjord. In the water management plan, the environmental target for streams and for Sønder Lem Vig and Skive Fjord is good ecological status Assessment of environmental impact Groundwater The feasibility studies show that the groundwater level may have to be lowered in connection with the establishment of a repository. Particularly wells, but also bore holes, will be susceptible to drying out if the water table drops. In the Skive Vest area, with local groundwater reservoirs in meltwater sand and gravel, it is assessed that drying-out of bore holes may occur locally. Over time, it is possible that water could seep into the facility and polluted water could seep out in the longer term. Depending on the location and design of the facility, this could have varying degrees of negative impact on groundwater and surface water. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow across the surface or in drains to the sea or into streams, or infiltrate the groundwater. The risk of surface run-off from a near-surface facility is considered to be minimal, as the plan guidelines assume both that the facility will be placed on a horizontal site and that surface water will be handled within the project site. With a near-surface repository going down to 30 metres below ground, or with an intermediate depth facility, there could be seepage directly into groundwater reservoirs or into covering layers, depending on the placing of the facility. If the facility is placed in thick Oligocene or Miocene clay deposits, these deposits are assessed to constitute an efficient geological barrier that will prevent seeping or transport to groundwater reservoirs. If the facility is placed in the Quaternary strata, there will be no such barrier.

216 210 of 234 Contaminated water seeping into or infiltrating the groundwater will find its way into the general flow of groundwater into the reservoirs (in this case, local groundwater reservoirs in meltwater sand and gravel). The water could flow into bore holes and wells supplying individual properties, or into the sea, watercourses or springs. Since there is a groundwater boundary in the Skive Vest area, contaminated groundwater may flow in several directions, depending on the location of the facility. Surface water As described under Groundwater, it is possible over time that water could seep into the facility and polluted water could seep out in the longer term, affecting the surface water. There is also a risk of seepage on the surface which could spread to e.g. streams and lakes. The impact may occur both as the repository is being filled and in the longer term, when it is closed. The degree of impact will vary greatly depending on the repository type. Repository types Both a near-surface repository and an intermediate-depth repository would entail a risk that contaminated groundwater could flow into the surface water, i.e. Krarup Møllebæk, Rettrup Bæk and several minor tributaries. Via Krarup Møllebæk and Skive Å, the water may flow into Skive Fjord. With a near-surface repository there is also a risk of surface water, i.e. streams, lakes and the sea, being polluted in the event of an accident causing a leak or of other seepage from the facility. In the period in which the facility remains open, it will be possible to monitor this impact and take the necessary mitigation measures, but the long-term effects are more uncertain as this plan does not lay down any guidelines in the event of the facility remaining in operation beyond the 30 years it is expected to stay open. Proposals for mitigation measures and monitoring can be found in sections 15 and 16. Table Summary impact assessment. Environmental aspects - Water Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Groundwater Yes Yes The impact on groundwater depends on the location of the facility. If the facility is located in thick Oligocene or Miocene clay deposits, the clay is expected to form an effective geological barrier. If the facility is located closer to the surface, the geological/hydrological conditions in the area may have more difficulty averting seepage compared to areas with fewer layers of sand in the Quaternary deposits. Assessment of impact Minor Plan guideline no 3 (Requirements for geological conditions) ensures that any repository will be located in suitable geological formations, so the impact will be limited. None If the facility is placed in thick Oligocene or Miocene clay deposits.

217 211 of 234 Environmental aspects - Water Drinking water interests Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes Most of the site is designated as an area of drinking water interests. There are no catchment areas for public water supplies within the site. Any conflicts in relation to individual supplies can be avoided by connecting any individuals extracting water downstream from the repository to the public water supply. Surface water Yes No/Yes The potential conflict arises from potential leakage from a near-surface or intermediate depth facility with seepage into the groundwater and from there into streams, lakes or the sea. An intermediate depth facility is not expected to carry any risk of direct impact on surface water. Any leakage from a nearsurface facility onto the ground will be handled within the repository site, so there is no surface discharge of contaminated water running into streams, lakes or the sea. Assessment of impact Minor No catchment areas for public water supplies. Minor if a nearsurface repository going down to a depth of 30 m is established, and not located in thick Oligocene or Miocene clay deposits. None if a nearsurface repository is established on the ground or the facility is located in thick Oligocene or Miocene clay deposits; see the description of the impact on groundwater above. These matters will be examined more closely during the detailed field studies to be carried out under the Project Planning Act and possibly during the EIA study Soil The section describes the potential impact of the plan on the soil. It is assumed that the local conditions will be examined more closely in a later EIA study, which will include more detailed investigations on the actual project site, e.g. in relation to identified contaminated land Environmental status and objectives Contaminated land An analysis of contaminated land pursuant to the Soil Pollution Act may be carried out at either knowledge level 1 (V1 analysis based on reasonable suspicion) or knowledge level 2 (V2 analysis based on actual studies). The two terms therefore only cover a description of whether the property has been examined and give no indication of how contaminated a property might be and with what substances. In this situation, no analysis of the known contaminated land on the site is being carried out, because the scoping found that the plan would not conflict with any existing soil contamination, as it would not prevent a future public clean-up effort. There may also be several pieces of contaminated land on the site which have not yet been analysed, so it is assumed that more detailed studies will be made of the soil in the relevant location in connection with a future EIA study.

218 212 of Assessment of environmental impact Handling of soil During the construction phase, soil will be handled in line with the municipality s guidelines on soil handling. Soil contamination As described in section , there may be an impact on surface water resulting from discharges of substances via seepage into the groundwater. In the same way, substances may be discharged into the soil on the surface. The extent of this impact and the likelihood of it occurring cannot be assessed from the information available at this time. An EIA study involving more detailed investigations of the actual location and a project to produce a detailed description of the barriers will be able to produce a more differentiated assessment of the risk of impact on the soil. Repository types With a near-surface facility, water could seep into the unsaturated zone and/or the top layer of the saturated zone. From here the water could flow over the surface into the topsoil. Table Summary impact assessment. Environmental aspects - Soil Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Soil Yes No The potential impact on the soil is linked to any leakage and seepage of contaminated substances via the groundwater. Assessment of impact Minor 13.8 Tangible assets This section deals with tangible assets, which in this context means a presentation of interests associated with agriculture, raw materials and afforestation. It focuses on potential conflicts with areas designated in the Municipal Plan as special agricultural, raw material or afforestation areas. These topics are illustrated on map 6.4: Tangible assets Environmental status and objectives Agriculture Particularly valuable agricultural areas The Municipal Plan designates particularly valuable agricultural areas. Permanent use of these areas for other purposes should be kept to a minimum. Protection of the arable land should not prevent the conservation of nature and the environment. There may therefore be areas within the primary agricultural areas where the town council and other authorities will assume or lay down requirements for various forms of extensive land use when handling specific cases /63/. Most of the planned site is designated as an agricultural area of special value. Exceptions to this are part of the coastal areas and the forested areas. Raw materials Skive municipality contains 21 quarrying areas and three areas of interest. Skive municipality is an authority required by the Raw Materials Act to administer in a way that ensures that raw materials on its land are exploited subject to an overall weighing of interests and an assessment of social considerations. The planned site contains two areas of raw material interests, to the south-west of Rettrup and at Lundbro, respectively.

219 213 of 234 Afforestation Areas where afforestation is not wanted The areas often contain natural and landscape assets or historical remains that are incompatible with afforestation. There may also be a wish not to disturb a view or the experience of buildings of architectural or cultural historical value. The planned site includes areas where afforestation is not wanted around Hvidbjerg church and along the southern border of the site around Rettrup Sø and Skelbæk. Areas where afforestation is wanted Afforestation areas are designated with a view to protecting groundwater and drinking water resources, promoting leisure interests close to towns and improving the ecological corridors within the landscape. Forests are well-suited to protecting drinking water resources from contamination. The planned site contains two afforestation areas, north of Rettrup and east of Hvidbjerg church Assessment of environmental impact Agriculture The establishment of a repository in the area may conflict with the designation as an agricultural area of special value. A subsequent project design phase may take account of agricultural interests in relation to the division of fields etc. The overall impact is not considered to be significant in relation to municipal planning, as the facility is expected to occupy an area of approx. 150 x 150 m. Raw materials The plan may conflict with raw material interests in the area. This conflict is found to be of minor significance as the raw material areas are limited in size so that the facility can be placed outside the designated areas. Afforestation The plan is not assessed to conflict with designated areas where afforestation is not wanted, but may conflict with designated afforestation areas if a future repository is placed within the designated areas at Rettrup and east of Hvidbjerg church. Repository types The conflicts are independent of the choice of repository type. Table Summary impact assessment. Environmental aspects - Tangible assets Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Agriculture Yes Yes The conflict can be avoided by the choice of location for the facility, but much of the planned site has been designated or is comprised by other conservation interests. Assessment of impact Minor A relatively small area will be used for the repository and, on this basis, the direct impact on agricultural interests is considered to be of little significance (see section on indirect effects on agriculture).

220 214 of 234 Environmental aspects - Tangible assets Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Raw materials Yes Yes Any conflict with raw material interests will depend on the placement of the actual facility. Afforestation Yes Yes The conflict can be avoided in connection with the final choice of location. Assessment of impact None if the repository is located outside the area of raw material interests. Minor if the repository is located inside the area of raw material interests. None if the repository is located outside the afforestation areas. Minor if the repository is located inside afforestation areas (only where forest wanted ) Cultural heritage This section presents cultural and historical assets in the form of designated cultural environments, church surroundings and cultural heritage sites, the assumption being that the plan will not affect protected ancient sites and associated ancient monument protection lines; cf. plan guideline no 8, Cultural Heritage. These topics are illustrated on map 6.5: Cultural heritage. Within the site there are registered protected ancient sites and monuments, and there may be valuable archaeological finds and remains in the area that have not yet been registered. It is assumed that these assets will be examined more closely in a later EIA study, and that the museum will be contacted with a view to more detailed investigations on the actual site Environmental status and objectives Cultural environments In Skive Municipal Plan, 10 cultural environments worthy of preservation have been designated and guidelines laid down for protection of these areas and dissemination of their cultural value. A cultural environment is a geographically defined area that reflects significant elements of the historical and social development of Skive municipality. Cultural environments may include both individual elements and larger entities such as buildings and landscapes. Within the valuable cultural environments, the historical assets should be preserved as far as possible. Building, construction and other activities likely to significantly reduce the experience or quality of the historical assets may not take place /63/. In the southern part of the planned site there is a large designated cultural environment: Cultural Environment Flyndersø Sønder Lem Vig. Church surroundings The Municipal Plan also identifies church surroundings within which consideration of the monumental value of the churches in the landscape and villages may not be overlooked when erecting buildings and technical facilities etc. Church surroundings and a church building line have been designated around Hvidbjerg church. Cultural heritage sites A cultural heritage site is an area of historical interest with hidden ancient sites and monuments. Cultural heritage sites may be of national or regional importance, and indicate that there are significant ancient sites in the relevant area. Cultural heritage sites are not in themselves

221 215 of 234 protected, but they may contain protected ancient monuments. In the centre of Hvidbjerg there is a designated cultural heritage site Assessment of environmental impact Cultural environments The plan allows for a facility to be located within the designated cultural environment. Any building work likely to significantly reduce the experience or quality of the historical assets (the reason for the designation) may not take place. The extent of the impact on the cultural environment will depend on the specific project, including the choice of repository type. The impact can be avoided altogether if the facility is located outside the area. Church surroundings It is assumed that the repository is placed outside the church building line to the extent that this is possible, cf. plan guideline no 9, Building and protection lines. Since most of the church surroundings are within the church building line, the probability that they will be affected is small. Cultural heritage sites Placing the facility inside the cultural heritage site may carry the risk of impact on objects of historical value, as the area is expected to contain protected ancient sites and monuments. If the actual facility is placed inside the cultural heritage site, more detailed studies will be carried out by the museum in the form of archive checks and preliminary investigations. Repository types A near-surface repository will generally have a greater impact on the cultural environment, as this type of facility will have a greater visual impact on the surrounding landscape. The conflicts are otherwise independent of the choice of repository type. Table Summary impact assessment. Environmental aspects - Cultural heritage Cultural environments Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Yes Yes The cultural environment covers much of the southeastern part of the planned site. Assessment of impact None if the repository is located outside the designated area west of Kisum Kær. Church surroundings Cultural heritage sites Yes Yes There are designated church surroundings and a church building line around Hvidbjerg church, which may be affected. Yes Yes In the centre of Hvidbjerg there is a designated cultural heritage site. Minor to moderate if the repository is located inside the designated area. None if the repository is located outside the church surroundings and the building line. Moderate if the repository is located inside the church surroundings and the building line. None if the repository is located outside the cultural heritage site in Hvidbjerg. Moderate if the repository is located inside the cultural heritage site.

222 216 of 234 Environmental aspects - Cultural heritage Is there a risk of impact? Can the impact be averted or reduced simply by the choice of location within the planned site? Comments Assessment of impact Cumulative effects Cumulative effects are assessed by viewing the plan in conjunction with other plans or programmes, including previous, current and planned activities. Relevant plans and programmes may cover the same subject-matter, the same geographical area or a neighbouring area. The aim is to ensure that the plan is consistent with other relevant plans and programmes and to assess whether there is any risk of cumulative effects. As described in the preceding sections on the individual environmental aspects, potential conflicts have been identified at Skive Vest with designated zones such as potential wetland areas, ecological corridors and cultural environments. Any conflict with potential wetland areas will be avoided by inserting a guideline into the plan to prevent the placement of the facility inside this type of designated area. The conflict with other designated objects within the area depends on the final placing of the facility. No higher-level plans or programmes have been identified within the site that might have an increased impact on the environment in combination with this plan Summary assessment The plan provides for the placement of a facility that may impact the environment in a number of ways, some of which are general effects regardless of the choice of location, as outlined in section 4.2. Implementing the plan at Skive Vest could have local implications that must be taken into account in a possible later planning and project design phase. Of these, the most significant are considered to be linked to the following factors: Half of the area is located inside the planned Flyndersø Sønder Lem Vig local park. Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism, agriculture and food production and the social structure in terms of a possible tendency for people to leave the area. The Oligocene and Miocene clay deposits are low-permeable. Most of the Quaternary clayey till is low-permeable, but the likely incidence of fractures and sand lenses means that it is less low-permeable in some places. Layers of meltwater sand and gravel are not low-permeable. If the facility is located in thick Oligocene or Miocene clay deposits, the clay is expected to form an effective geological barrier. If we assume a rise in water levels of max. 1.5 m in the seas around Denmark (by 2100), this is not expected to flood the area. However, the southern part of the site is expected to become still wetter as (other things being equal) the water table will rise as a result of rising sea levels.

223 217 of SUMMARY The main impacts on each site and the principal differences between the three repository types are summarised below Local impact The plan provides for the placement of a facility that may impact the environment in a number of ways, some of which are general effects regardless of the choice of location, as outlined in section 4.2. Implementing the plan could result in impacts that depend on local factors and need to be taken into account in a possible later planning and project design phase. Of these, the most significant are considered to be linked to the following factors: Risø (zero alternative) Risø is situated near the coast and is also a designated low-lying area. It is possible that there could be a greater risk of seepage in the future, particularly with rising sea levels and extreme events, so there is a greater risk of impact on surface water and natural conditions than there is today. Risø is within the 300 m wide beach protection belt. The highest water level recorded in the port of Roskilde during storm Bodil on 5 December 2013 was 2.06 metres above mean sea level. During the night to 6 December 2013, water penetrated a low-lying basement of a Danish Decommissioning building. This part of the basement was not used to store radioactive material, so the flood did not cause any radioactive emissions. A higher water level could cause flooding in parts of the Risø area. The whole of Risø is situated within the designated coastal zone. Østermarie-Paradisbakkerne The planned site borders on two Natura 2000 areas which must be given special attention in any project design phase. Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism (including the nearby Joboland ), food production and the social structure in terms of people leaving the area. There is a parallel conflict linked to leakage. The geographical extent of the conflict is hard to predict because of limited knowledge of fracture systems in the bedrock and the resulting uncertainty surrounding details of the flow of groundwater. The risk of impact is greatest if a near-surface repository going down to a depth of 30 metres is chosen. These matters need to be examined more closely in a future EIA study. Half of the site is within the designated coastal zone. Rødbyhavn Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism (including the nearby Lalandia holiday resort), food production and the social structure in terms of a possible tendency for people to leave the area. Future changes in climate will have a limited effect on the area. Rising sea levels will not top the existing dykes, but in extreme situations with storm conditions there will be growing pressure on these dykes (assuming that the height of the top of the dykes is raised in line with any rise in sea levels). The impact on groundwater depends on the location of the facility. If the facility is located in thick Paleocene clay, the clay is expected to form a very effective geological barrier. The planned site contains reserved areas for e.g. the Fehmarn Belt Fixed Link and a raw material area. A small area of the south-western part of the planned site is covered by the designated coastal zone.

224 218 of 234 Kertinge Mark Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism (including the nearby Ladby Viking Museum ), food production and the social structure in terms of a possible tendency for people to leave the area. With rising sea levels and more frequent storms, the planned site will be exposed to more destructive forces. To minimise the risk of flooding, account must therefore be taken of the placement of the facility on the site. If the facility is located in thick Paleogene clay deposits, the clay is expected to form an effective geological barrier. Kertinge Mark is situated within the designated coastal zone. Thyholm The planned site borders on a Natura 2000 area which must be given special attention in any project design phase. Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism, fishing (including exports of shellfish), agriculture and the social structure in terms of a possible tendency for people to leave the area. By far the biggest part of the site will not be affected by an 80 cm rise in sea level, but it is important to allow for a future placement of the facility on the site that avoids any impact from future rises in sea level on the low-lying areas. The Paleogene and Neogene clay deposits are generally low-permeable. The units occur in the bore holes with significant faults in the strata. These aspects do not indicate a thick continuous clay structure in the area, although the bore holes reveal a clear preponderance of clay deposits down a great depth. The whole of Thyholm is situated within the designated coastal zone. Thise Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism, agriculture and food production (e.g. Thise Dairy) and the social structure in terms of a possible tendency for people to leave the area. A small part of the coastal areas may be flooded, and we may expect increased erosion of the coastal cliffs. The areas near Gåsemose and along the banks of the stream around Eskær may be flooded, which will be taken into account in any final placing of the facility. If the facility is placed in thick Oligocene clay deposits, the clay is expected to form an effective geological barrier. If the facility is located closer to the surface, the geological/hydrological conditions in the area may have more difficulty averting seepage compared to areas with fewer layers of sand in the Quaternary deposits. There is a catchment area for a public waterworks (Thise waterworks) within the site. Catchment areas for public waterworks outside areas of special drinking water interests (OSDs) have the same status in terms of groundwater protection as the OSDs themselves. The catchment area for Thise waterworks is defined as a nitrate-sensitive catchment area and a priority area, as the groundwater in the Thise area especially is particularly vulnerable. The eastern part of the planned site is inside the designated coastal zone. Skive West Half of the area is located inside the planned Sønder Lem Vig - Flynder Sø local park. Because of uncertainty about the plan and the process, there may be possible indirect effects on the population, tourism, agriculture and food production and the social structure in terms of a possible tendency for people to leave the area. The Oligocene and Miocene clay deposits are generally low-permeable. Most of the Quaternary clayey till is low-permeable, but the likely incidence of fractures means that it is less low-permeable in some places. Layers of meltwater sand and gravel are not lowpermeable.

225 219 of 234 If the facility is located in thick Oligocene or Miocene clay deposits, the clay is expected to form an effective geological barrier. If we assume a rise in water levels of max. 1.5 m in the seas around Denmark (by 2100), this is not expected to flood the area. However, the southern part of the site is expected to become still wetter as (other things being equal) the water table will rise as a result of rising sea levels.

226 220 of MITIGATION MEASURES To limit the environmental impact of implementing the plan, restrictive guidelines have been included which are designed either to avert or reduce this impact. Mitigation measures may also be taken as work proceeds on more detailed planning for a possible future facility. This section describes the mitigation measures which can be implemented along with the plan Biodiversity By placing the facility outside nature areas that are either protected under the Nature Protection Act or designated in the municipal plans as wildlife corridors, nature areas etc., the risk of impact on these areas can be restricted Population and health Radiation and security Mitigation measures related to radiation and security will be closely tied to the concrete project and not to the plan itself. The specified principles, dose constraints and derived thresholds set out in the introductory section of this SEA report, together with other radiation protection considerations, will govern the requirements for mitigation measures related to a specific facility and its use. The radiation protection considerations will dictate the need for any further mitigation measures in the form of e.g. a modified design or plans and regulations for use, but any change in these matters will not have a determining influence on the definition of radiation protection requirements. Population It is very important for the stakeholders to be able to follow the decision-making process and understand why, how and on what basis the decisions on the choice of concept for handling the waste are taken. It is crucial to the future process that the stakeholders should feel that transparency has been enhanced and that they are suitably involved in creating a mutually acceptable basis for the eventual implementation of the plan. Two matters need to be addressed in order to mitigate any negative social effect. First, the forward-looking process must ensure that the solution chosen is an environmentally safe solution, so there is no negative impact on the surrounding environment. This will be assured via the statutory work on the approval and environmental impact assessment of any future concrete solution. Secondly, it is essential to address the concerns raised by the stakeholders. A mere concern about a negative environmental impact could have far-reaching social consequences. If the stakeholders are sufficiently concerned about possible contamination of the surrounding areas, this could have a bearing on the chances of selling agricultural products from the area, selling houses etc. whether or not there is any actual impact, as long as this concern is shared by customers and buyers. The crucial point here is that the individual stakeholder groups should have the opportunity to ask questions, that these should be answered in a way that meets the stakeholders interests and needs, and that, in the process of dialogue, the answer is felt to be exhaustive and adequate by the individual stakeholder 4. 4 Such a dialogue can therefore be usefully directed at the individual stakeholder groups by way of separate stakeholder meetings to which a defined group of stakeholders are invited. This will ensure that stakeholders with common interests are involved together, so the dialogue is focused. The process can also be supported by supplying information material, producing newsletters and following up on any specific unresolved issues. It may also be helpful to have a project website to gather together relevant material (documentation, schedules, factual information etc.), so the stakeholders have easy access to all relevant details of the project.

227 221 of 234 There is a widespread need among the stakeholders to be offered close discussion, in which the individual stakeholders concerns are listened to and they are informed of issues that are already known and decisions taken, and the basis for these. An overview of the process going forward should be presented, telling when answers to unknown issues and unanswered questions will be available and how concrete agreements will be concluded with the stakeholders on their subsequent involvement at relevant times in the future process. Such a dialogue could help to provide the necessary insight into the decision-making process, the work to be performed, what is being done to resolve the unanswered questions and examine relevant issues, and how the risks associated with a permanent repository will be covered or actively avoided. This will contribute to increased security and reduced mistrust among the stakeholders Water Groundwater and drinking water interests The potential impact on groundwater and drinking water interests can be reduced with the aid of barriers that can hold back any seepage. These barriers comprise the geological formations, the design of the facility itself and the containers the material is stored in. This type of mitigation measure is a key part of the future project and the repository design. Surface water There must not be any leakage onto the ground from a future repository. A concrete technical solution to handling surface water within the repository site will be incorporated into the subsequent detail phases, and may include the following solutions: Building: To avert the risk of seepage from any leaks in the building, the building itself can be designed as a closed drainage system (sump) in which any leakage or water penetration can be detected, collected and controlled. Repository site: Surface water from the rest of the facility (outdoors) can be collected in tanks within the site and checked before it is released into the public drainage system or diverted into containers.

228 222 of MONITORING PROGRAMME The purpose of the monitoring programme is to be able to assess whether implementing the plan will produce the expected effects on the environment, and whether it is necessary to mitigate any impact that has not been foreseen. Where possible, it is therefore proposed to monitor the expected significant effects of the plan on the environment. A monitoring programme will also be drawn up for any future project, to be planned on the basis of the actual situation and the chosen repository type and the geology etc. in the area. It has therefore not been defined at this time how the project itself will be monitored and exactly what this will involve General The plan contains a number of guidelines which not only provide the overall framework for establishing a permanent repository but are also intended to prevent or mitigate any potential impact on the environment. In the later planning and project design phases, action will therefore be taken to ensure that the plan guidelines are complied with. It will also be determined whether the guidelines in the plan and the proposed mitigation measures are sufficient to ensure that there will be no significant environmental impact from implementing the plan Population and health Safety criteria and analyses The dose constraint will be used, together with model calculations, to set quantitative limits for annual emissions of radioactive substances into the air and water from a repository, to ensure that the calculated radiation dose for the critical group does not exceed the dose constraint. Measurements of the current emissions and a comparison of these with the specified emission limits will constitute the actual check that the operation of a permanent repository in the operational period complies with the dose criterion /15/. The period after closure includes an initial monitoring phase. It will subsequently be decided how long the repository should be actively monitored by the regulatory authorities. It will therefore be natural to define a dose constraint for emissions for the projected development of the repository, corresponding to the dose criterion that currently applies to checks on the release of materials from the nuclear facilities at Risø. Release of such materials means that they are regarded as non-radioactive material which is no longer regulatory control. It is therefore suggested that the dose constraint for the projected development of the repository be set at 0.01 msv per year, in line with the current dose criterion for release from regulatory control laid down in Ministry of Health Order No 192 of 2 April 2002 on exceptions from the Act on the use etc. of radioactive substances.

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233 MAPS: RISØ (ZERO ALTERNATIVE) MAP 0.1 BIODIVERSITY Map 0.2 LANDSCAPE AND GEOLOGY MAP 0.3 DRINKING WATER INTERESTS MAP 0.4 TANGIBLE ASSETS MAP 0.5 CULTURAL HERITAGE ØSTERMARIE-PARADISBAKKERNE MAP 1.1 BIODIVERSITY Map 1.2 LANDSCAPE AND GEOLOGY MAP 1.3 DRINKING WATER INTERESTS MAP 1.4 TANGIBLE ASSETS MAP 1.5 CULTURAL HERITAGE RØDBYHAVN MAP 2.1 BIODIVERSITY Map 2.2 LANDSCAPE AND GEOLOGY MAP 2.3 DRINKING WATER INTERESTS MAP 2.4 TANGIBLE ASSETS MAP 2.5 CULTURAL HERITAGE KERTINGE MARK MAP 3.1 BIODIVERSITY Map 3.2 LANDSCAPE AND GEOLOGY MAP 3.3 DRINKING WATER INTERESTS MAP 3.4 TANGIBLE ASSETS MAP 3.5 CULTURAL HERITAGE THYHOLM MAP 4.1 BIODIVERSITY Map 4.2 LANDSCAPE AND GEOLOGY MAP 4.3 DRINKING WATER INTERESTS

234 MAP 4.4 TANGIBLE ASSETS MAP 4.5 CULTURAL HERITAGE THISE MAP 5.1 BIODIVERSITY Map 5.2 LANDSCAPE AND GEOLOGY MAP 5.3 DRINKING WATER INTERESTS MAP 5.4 TANGIBLE ASSETS MAP 5.5 CULTURAL HERITAGE SKIVE VEST MAP 6.1 BIODIVERSITY Map 6.2 LANDSCAPE AND GEOLOGY MAP 6.3 DRINKING WATER INTERESTS MAP 6.4 TANGIBLE ASSETS MAP 6.5 CULTURAL HERITAGE