ANNEX 1 Summary of Danish responses to consultation Page 1 ANNEX 1 A - Ministries 1 Danish Ministry of Ecclesiastical Affairs 2 Danish Ministry of Economic Affairs and the Interior B Agencies 1 Danish Emergency Management Agency 2 Danish Competition and Consumer Authority 3 Danish Road Directorate C State-authorised museums 1 Holstebro Museum Details of ancient monuments, remains etc. in the area. 2 Lolland-Falster Museum Impact on the coastal landscape Recommends a preliminary archaeological study. Any future construction work will be subject to Section 27 of the Museums Act. Refers to response to consultation dated 30 June 2014. 3 Roskilde Museum. 4 Viking Museum Ladby Psychological effects could have an impact on the museum and its transmission of the cultural heritage. The area around the museum is perceived as a cultural area. The museum is working to have the Ladby ship added to the UNESCO world heritage list. D - Diocesan authorities and parish councils 1 Diocese of Copenhagen 2 Diocese of Lolland-Falster 3 Diocese of Funen Assumes the facility will be located outside the church protection line and away from sight lines. E Regions Refer to response dated 3 July 2014. Refer to response dated 3 July 2014. 1 Capital Region of Denmark Socio-economic consequences are adequately described. The intermediate storage solution and export abroad should have been described as alternatives to a permanent repository. No description of the sustainability of the repository after a long period.
ANNEX 1 Summary of Danish responses to consultation Page 2 F Municipalities 1 Struer Municipality Shares citizens concern about the negative social consequences. Does not agree that these concerns are just a question of increased information and dialogue. Impact of exports of food products. Complex geological structures in the area are described. Points out that there is no thick continuous clay formation. Complex geological structures. Uncertainty about groundwater flows. Thyholm Private Fællesvandværk is designated as the primary waterworks for the future. Risk of seismic activity in the area. 2 Skive Municipality Does not agree that the uncertainty and mistrust are down to ignorance. There is a need for much greater openness about the process. Impact on the food production. Uncertainty as to the extent of the different reserves in the area and the geological strata. Need all of the groundwater resources that exist within the municipality. The groundwater in the Thise area is particularly vulnerable. There may be buried valleys with reserves of drinking water in the Skive area. Why is seismic activity not covered in the SEA report? 3 Kerteminde Municipality Suggests defining the planned site so it does not take in Section 3 areas and the beach protection belt. A location at Kertinge Mark will affect close to 180,000 people. The socio-economic aspects are not adequately covered. Negative effect on population and tourism. Radiation protection must be a factor in the choice of location. The groundwater conditions under Kertinge Mark are seriously under-evaluated. Risk of losing supplies for industry. The EIA is at too high a level. The assessment of a given topic is the same for all six sites. Does not support a permanent repository. Intermediate storage solution preferred. Prefers an intermediate storage solution. Expects an environmental assessment of the intermediate storage solution to be carried out. A permanent repository is an unacceptable solution. The intermediate storage and export solutions should be addressed in parallel. The hazard associated with the waste is not clearly stated. Should work on a deeper repository. Questions about the quantity and classification of the waste.
ANNEX 1 Summary of Danish responses to consultation Page 3 4 Lolland Municipality The EIA does not specifically refer to the Fehmarn Belt EIA, including the section on nature. Socio-economic aspects are not described in depth. Citizens do not want the repository. Implications for tourism, food production, business development and depopulation. Details of tourism based on out-of-date information. Lack of knowledge of geological conditions. Information about Paleocene clay strata incorrect. Climate change and increased pressure on the coast. Low-lying area Risk of rising sea levels, breaches of the dyke, pollution of groundwater and floodwater. Not interested in housing a permanent repository. Wants an intermediate repository to be established instead. 5 Bornholm Regional Municipality Lack on guidelines on nature conservation interests. The Randkløve Natura 2000 area is not mentioned. The planned site covers part of a Natura 2000 area. Risk of transport over water. Degree of detail on socio-economic effects, and mitigation measures. Determination of the number of inhabitants in summer time. Camp sites, amusements etc. in relation to industry. No details of impact on tourism. Securing the facility. Error in the size of the area that lies inside the designated coastal zone. Impact on landscape assets. Justification for the short time frame covered by the risk assessment in relation to climate change. Calculations of the concentrations of the stored materials that could end up in the sea (or the soil and the air). Subsurface fracture systems and unpredictable flow lines. Impact in terms of soil contamination. Most of the site is agricultural land. Sales of agricultural products. There are cultural assets buried in the area. The environmental assessment is superficial. Too much deferred to the EIA phase. Process not transparent. Should cover both permanent and intermediate storage and export solutions. Can the repository contain the materials for the whole period? Repository types are not deep enough. Lack of foreign experts. Waste Convention and Waste Directive not properly addressed. 6 Roskilde Municipality Greater risk of seepage than described in the SEA report. Agrees that climate should be included in the SEA report. Risk of rising sea levels and flooding. Seismic activity should be investigated, as it is a crucial factor in selecting the sites. Planning conditions are inadequate. G Others Inappropriate to process the waste several times over, so advocates investment in a permanent repository or export of the waste. Uncertainty as to whether there is a real risk of the waste staying at Risø.
ANNEX 1 Summary of Danish responses to consultation Page 4 1 Citizens Group against Nuclear Waste on Thyholm Finds the SEA report inadequate and full of errors. Refers to material submitted earlier. Endorses the response from Struer Municipality and requests a copy of BOMA s list of concerns. Refers to Høfde 42 (Groyne 42). 2 MORADS The process is not regarded as impartial or adequate. All three options should be examined at the same level. Refers to a number of studies and articles. 3 BOMA Safeguarding nature conservation interests. Long-term risks to health. Implications for tourism, business development and migration to the area. Population not to blame for the socio-economic effects. Concerns about transport of the waste by sea. Can the local road network handle the shipments? Complains of lack of public involvement. The granite in the area is full of fractures, so one cannot guard against water penetration. Within the designated coastal zone. Seawater penetration. Implications for food production. Safeguarding of cultural-historical interests. Risk of an earthquake 4 Lolland against Nuclear Waste Future generations should not be left with the responsibility for preventing flooding by raising the dyke. Seepage into drinking water and seawater. We do not want to have waste from Risø forced on us. Independent experts should be involved. Comparable evaluation of export, permanent and intermediate storage solutions. Prefers a common EU-wide solution. Waste of different types mixed together. Clarity about the design of the repository, its reversibility and how long it will remain open. Endorses comments from Lolland Municipality about the socio-economic aspects. Cannot accept the establishment of a permanent repository Export option and an intermediate storage solution should be examined. A modernised Risø facility is an alternative. Involvement of external experts. 5 Citizens Group against Nuclear Waste in Kerteminde Municipality 6 Danish Society for Nature Conservation The Natura 2000 are around Romsø and Hindsholm should be included in the assessment. Location close to Odense, with 160,000 inhabitants. Impact on tourism. Do not agree on the direction of the groundwater flows. Kertinge fjord is designated as a scientific reference area. Impact on groundwater borders on an OSD. Possibility of the Ladby Viking ship being added to the UNESCO world heritage list. It is not possible to evaluate the impact on nature when there is no specific location. Safety of nature and the population is crucial. Protected monuments, the beach protection belt and landscapes of special value are also crucial. Prefers an intermediate storage or an export solution. The repository concept should be defined before the location is chosen. Also wants to see a process in which intermediate storage is looked at in parallel with and at the same level as the permanent repository. Not an option to export the waste. Wants a broad debate on the choice of solution. The classification of the waste is deficient and not restrictive enough.
ANNEX 1 Summary of Danish responses to consultation Page 5 7 Association of Waterworks in Denmark Lead, cadmium, beryllium and uranium pose a major risk to health and the environment for many generations to come. Everything possible should be done to safeguard groundwater resources. Recommends intermediate storage. 8 NOAH - Renewable Energy Risk of discharge into the sea. Does not believe the repository can protect people and the environment against hazardous substances. Should be placed 300-800 metres down in stable geological strata. Recommends halting the whole process. Suggests a broader commission with representatives of national and international stakeholders. Questions about the types of waste, suitability of the repository etc. Refers to experience abroad. 9 Danish Centre for Environmental Assessment, Department of Social Development and Planning, Aalborg University 10 Ren Energi Oplysning (Clean Energy Information REO) 11 Kirsten Vestergaard Andersen, Aalborg The assessment of the socio-economic effects is too general. There are no concrete mitigation measures to address the socio-economic effects. The SEA report should address the guidelines. The scope of the SEA report means that one cannot compare and evaluate the three options. Recommends keeping the waste at Risø until there is a better solution. Proposes exporting the 233 kg of irradiated waste. Suggests that material from Kvanefjeld should be used as building material. Possible use in radon therapy. Burying the waste is risky. An export solution just passes the problem on. Intermediate storage is the only solution. 12 Lalandia Implications for visitor numbers and future development of Lalandia. Effect on the number of jobs in the municipality. 13 Kaj Jensen, Thyholm Limited depth of water in the production areas surrounding Thyholm. Seepage of toxic heavy metals into the groundwater or Limfjord. Seismic activity in the area. Refers to experience from Høfde 42 (Groyne 42). Prefers intermediate storage. Wants to see expert opinions. 14 Knuthenborg Safari Park 15 NÆRSAMFUND Association 16 Østersøbadet Landowners Association Implications for visitor numbers and revenues in the surrounding economy. Risk of running down rather than developing the area. Impact on nature. Development and future prospects of the municipality. Tourists will avoid the area. Depopulation and fall in house prices. Endorses response from Lolland Municipality. Wants to see an intermediate storage solution at Risø. Inappropriate to establish a permanent repository. 17 Fehmarn Belt Development Negative effects on the development future of the area. Endorses response from Lolland Municipality. There is scepticism towards a possible permanent repository on the German side of the Fehmarn Belt. Should investigate intermediate storage.
ANNEX 1 Summary of Danish responses to consultation Page 6 18 Association of Cottage Owners in Lolland Municipality 19 Jørgen C. Marcussen 20 Anne Marie Marcussen 21 John Clausen Implications for the development and future prospects of the municipality. Endorses response from Lolland Municipality. Why have no possible sites been identified on Zealand? Wants to see an intermediate repository at Risø. Does not want nuclear waste on Lolland. Prefers export abroad. Does not want nuclear waste on Lolland. Prefers export abroad. Endorses the response from DN.