Preliminary formal Response to the SKB Environmental Impact Statement of December 2009 relating to the proposed radioactive waste repository at Forsmark, Sweden

Alla svar på SKB AB:s preliminär MKB 200912


Updated 2010-04-21 with version from

See attached PDF (199 KB), in English with covering letter in Swedish. Press release (34 KB), also below.

See also: Baltic Sea regional office of the ECRR.  2010-02-04.  EIS of the final nuclear waste repository in Sweden - ECRR, Video Statement by Professor Chris Busby.

European Committee on Radiation Risk Website (


ECRR Baltic Sea Regional Office Press Release, Immediate
Stockholm, 5th Feb 2010

ECRR scientist rubbishes the draft of the SKB:s Forsmark
Environmental Impact Statement

In a 21 page report published today and to be presented to SKB on 6th Feb as part of the stakeholder dialogue relating to the Environmental Impact of the proposed Forsmark waste repository, Prof. Chris Busby, Scientific Secretary of the European Committee on Radiation Risk based in Brussels made serious criticisms of the SKB EIS. His report mainly draws attention to the lack of any modelling of radioactive dispersion or exposures to humans and ecosystems from radioactivity emerging from the proposed repository. The report draws attention to the fact that the SKB employs the obsolete and erroneous radiation risk model of the International Commission on Radiological Protection ICRP, an organisation that was based in Sweden but which has now moved to the UK. Prof Busby argues that this risk model, which predicted no harm from the Chernobyl accident and no problems associated with living near nuclear sites has now been overtaken by experimental and epidemiological evidence, which is presented in some detail in the paper.

Prof Busby, an international expert on the health effects of radiation was dismissive:

You cannot present an Environment Impact Statement without some kind of credible mathematical modelling. There is none in this report nor any of the documents added. I don’t know what these people think they are doing, but the report itself is meaningless. It is stuffed full of coloured pictures of wildlife, ducks, flowers, frogs, as if this colourful wildlife and happiness is what SKB are bringing to Sweden, rather than a very large amount of dangerous radioactive waste and hundreds of tons of uranium which they will put under the already seriously polluted Baltic Sea where they hope it won’t get out. Of course, eventually it will and will poison the sea, its creatures and all the people living on its shores. This just won’t do.

Astonishingly, the EIS barely mentions radiation risk. There is one section (3.4, page 37) where the document refers to the ICRP model: however no modelling of dose or exposure is to be found anywhere in any of the documents examined. Even where the radiation exposures are discussed, the EIS makes very erroneous statements and gives misleading information. For example, on p 37 we are told that after 100,000 years all that will remain is natural uranium minerals. This is not true: there will be massively enhanced levels of both U-238 and also the more radioactive U-235 and U-234. The bar graph on p 38 appears to show that the radioactivity will decay to 0.0005% of its initial value after 100,000 years; however, most of the material is uranium. Since this has a half life of billions of years, there will be virtually no change in its quantity over the 100,000 years of the graph on p 38.

The report recommends that the SKB develop credible mathematical risk models for their project and in doing so, employ the radiation risk model of the ECRR published in 2003 and being updated in 2010 (

Chris Busby +44 7989 4288 33
Ditta Rietuma +46 709 5466 16

busby20100205skb_eis.pdf198.68 KB
busby20100205skb_eis_press.pdf33.72 KB