Author Archives: Nuclear Transparency Watch

Capture d’écran 2017-04-03 à 17.01.59

Presentation of NTW activities at the joint ICTP-IAEA Workshop

Nadja Zeleznik presented NTW at the joint ICTP-IAEA Workshop on Environmental Mapping: Mobilising Trust in Measurements and Engaging Scientific Citizenry which took place three weeks in March 2017 at the Abdus Salam International Centre for Theoretical Physics (ICTP), Trieste, Italy.

The workshop was intended as a hands-on activity that provides an opportunity for participants to construct, test and use their own environmental radiation sensor. Participants develop skills in the use of open-source hardware and software tools and develop geographical information system (GIS) maps. Throughout the workshop participants discussed with decision makers, leading technology thinkers, scientists and journalists on issues surrounding the collection and use of quantitative and qualitative information in the public domain and the powerful role an active informed citizen can have in society.

The presentation of NTW made by Nadja Zeleznik provides information on the reasons why a whatchdog organisation was formed, the main activities of NTW and the principles we adopted for our work. The interest from participants and responses show that there is still lack of awareness on what transparency in nuclear projects means, what kind of international and national legal provisions exist and how they are implemented in practice. Participants, coming from 26 countries around the world, agreed that there should be more communication, public participation and justice in environmental issues as mentioned in the Aarhus convention, since open society needs to be aware, engaged and protected.

LUXEMBOURG : Institutions Europeennes + Ville

How much will it really cost to decommission the ageing French nuclear fleet ?

Dr Paul Dorfman
NTW Member
Honorary Senior Research Associate, Energy Institute, UCL
Founder, ncg

Faisabilité Technique et Financière du Démantèlement des Infrastructures Nucléaires
The issue of decommissioning costs is a key challenge in the nucear sector. Perhaps surprisingly, a recently published French Governmental report on Faisabilité technique et financière du démantèlement des infrastructures nucléaires, from Le Commission du Développement Durable et de l’Aménagement du Territoire, Assemblée Nationale, has just blown a significant hole in the French decommissioning strategy.

In late January this year, on the last day of the Commissions work, the Committee took evidence from the EDF head of decommissioning and me. Given the Commission had been working on this for months, and had listened to mounds of complex data, I decided to cut to the chase and make as clear an argument as I could. What follows is that evidence.

How much has France, Germany and UK set aside for decommissioning ?
Whereas Germany has set aside €38 billion to decommission 17 nuclear reactors, and the UK Nuclear Decommissioning Authority (NDA) estimates that clean-up of UK’s 17 nuclear sites will cost between €109 – €250 billion over the next 120 years – France has set aside only €23 billion for the decommissioning of its 58 reactors. To put this in context, according to the European Commission, France estimates it will cost €300 million per gigawatt (GW) of generating capacity to decommission a nuclear reactor – far below Germany’s assumption at €1.4 billion per GW and the UK of €2.7 billion per GW.

How can EDF decommission at such low cost?
EDF maintain that because of standardisation of some of the reactors and because there are multiple reactors located on single sites, they can decommissioning at a low cost. Does this claim stack up ? Well, probably not. Reactors are complex pieces of kit, and each has a differing operational and safety history. In other words, nuclear reactor decommissioning is essentially a
‘bespoke’ process.

Why has EDF underestimated the costs of decommissioning 
and waste storage ?
Even EDFs €23 billion limited provision for decommissioning and waste storage is a large sum of money for a company that has huge borrowings and enormous debt, which is currently running at €37 billion, Standard and Poor and Moodys (the two biggest international credit rating agencies) have already downgraded EDFs credit-worthiness over the corporations potentially ill-advised decision to go ahead with attempting to construct two more of the failing Areva reactor design (the EPR) at Hinkley Point, UK. And any significant change in the cost of decommissioning would have an immediate and disastrous impact on EDFs credit rating – something that the debt-ridden corporation can simply not afford.

Spent nuclear fuel build-up
Then there’s EDF’s existential problems at France’s high-level waste storage and reprocessing facility at La Hague, where spent nuclear fuel stores are reaching current cooling capacity limits. This means La Hague may now have to turn away spent fuel shipments from Frances reactor fleet. In any case, since ASN have identified safety problems with some spent fuel transport flasks, spent fuel transport to La Hague has substantially slowed. All this means the build-up of spent fuel at nuclear sites across France, with the associated problem of cooling the spent fuel at nuclear sites during dry summer periods, with all that means for further escalation of rad-waste management costs.

French National Assembly Commission Findings
Happily, and perhaps unexpectedly, when the Commission publishes it’s final key findings, they come down on the side of those who voiced concerns about EDFs provisioning for reactor decommissioning and waste management does not include “obvious under-provisioning” regarding “certain heavy expenses”, such as taxes and insurance, remediation of contaminated soil, the reprocessing of used fuel and the social impact of decommissioning. The Commission found that the clean-up of French reactors will take longer, be more challenging and cost much more than EDF anticipates.

The Commission reports that EDF showed “excessive optimism” in the decommissioning of its nuclear power plants. “Other countries have embarked on the dismantling of their power plants, and the feedback we have generally contradicts EDF’s optimism about both the financial and technical aspects of decommissioning… “The cost of decommissioning is likely to be greater than the provisions”, the technical feasibility is “not fully assured” and the dismantling work will take “presumably more time than expected”.

Critically, the Commissions report says that EDF arrived at its cost estimate by extrapolating to all sites the estimated costs for decommissioning a generic plant comprising four 900 MWe reactors, such as Dampierre, noting that: “The initial assumption according to which the dismantling of the whole fleet will be homogeneous is questioned by some specialists who argue that each reactor has a particular history with different incidents that have occurred during its history”.

So what now?
Soon EDF will have to start the biggest, most complex and costliest nuclear decommissioning and radioactive waste management programme on earth. It seems very likely that (for various reasons not unassociated with it’s current bank balance) EDF may have seriously underestimated the real challenges and costs, with serious consequences for its already unhealthy balance sheet. This will have profound consequences for the French State, who underwrite EDF.

Taken up in the Press:

China Dialogue:
Hinkley Point C pre-construction works May '15

The Espoo Convention Implementation Committee asks the UK to suspend work on the Hinkley Point C nuclear power station because of the government’s failure to consult with European countries.

Last year, the Espoo Convention Implementation Committee concluded that the UK had failed to meet its obligations under the Espoo Convention to discuss the possible impact of an accident at Hinkley on neighboring countries.
See the report of the Implementation Committee on its thirty-eighth session, page 21:

The Implementation Committee has now gone a step further and said the UK should consider refraining from further works on the site of the new reactors until an transboundary environmental impact assessment as been conducted. The UK followed the Committee’s suggestion to send out a notification of the project to potentially impacted countries. It even went the extra mile and notified all parties to the Espoo Convention. At date, at least the Netherlands, Norway and Germany have reacted positively on the invitation to participate in a transboundary environmental impact assessment.
See the report of the Implementation Committee on its thirty–fifth session, page 13:

 More information:

-       Bloomerg, “UN Asks U.K. to Pause Hinkley Nuclear Plant Work for Assessment”, 18 March 2017:

-       The Guardian, ” UN asks UK to suspend work on Hinkley Point”, 20 March 2017:–hinkley-point-c

-       Press release from StopHinkley “A United Nations body has asked the UK to suspend Hinkley Point C pending an environmental assessment ” from StopHinkley” :

-       A report for the Green MSPs by Pete Roche “Plant Life-Time Extensions for Scotland’s Ageing Reactors the Lack of Public Participation in the Decision-Making Process”:


Application of the Aarhus Convention in France – Contribution of ANCCLI

France is preparing to update its triennial report on the implementation of the Aarhus Convention. This Convention deals with access to information, participation in decision-making and access to justice in environmental matters. The application of the Convention notably concerns the nuclear sector.

Following the request of the Ministry of the Environment, Energy and the Sea, ANCCLI wishes to share its experience and proposals with the application of the Aarhus Convention to the nuclear sector.

Here are some of the recommendations of ANCCLI:

ANCCLI recalls that free access to information is the norm and that secrecy, whether it is commercial, industrial or military, must be an exception. The appropriateness of the use of secrecy must be verifiable by an independent body. The ANCCLI considers that the difficulties encountered in determining what information can not be made public, in the absence of a clear process for determining whether information is protected by a form of confidentiality, should be mentioned in the obstacles encountered in the Implementation of Article 4 of the Aarhus Convention.
ANCCLI considers that work remains to be done in the provision of information in digital format. Files submitted for consultation or public inquiry are not always available on the Internet, or in a format that does not allow for thorough work. Access to files via the Internet allows the public to study the documents without having constraint of the opening time of the customer care desk.
ANCCLI considers that the provisions concerning public participation are only partially implemented in France. Local Information Commissions often lack time to work thoroughly on subjects on which they are consulted. In addition, public participation processes often arrive rather late, when the implementation of a project or important technical options have already been decided. For example, EDF is currently studying the construction of new storage capacities upon request of the ASN. The operator seems to consider only the option of one or more underwater and centralized storage facilities. In fact, other options exist. It appears that public participation will only occur at the time of the application for authorization to set up the facility or facilities, when the main technical options are already predetermined. Implementation of the Aarhus Convention would involve engaging a public participation process now, helping to discuss the various options for fuel storage.
See all recommendations of ANCCLI: Download

Capture d’écran 2017-03-20 à 09.46.26

CONFERENCE “Public participation in the nuclear sector” – The Espoo and Aarhus conventions

30 March 2017 – European Parliament Brussels

The Espoo convention on Environmental Impact Assessment in a Transboundary context lays down the obligation to assess the environmental impact of activities in the nuclear sector at an early stage of decision making. It also lays down the general obligation for parties to notify and consult each other on all major projects under consideration that are likely to have a significant adverse environmental impact across national borders.

The Aarhus Convention links human rights and environmental issues. The preamble of the Aarhus Convention states that: “In the field of environment, improved access to information and public participation in decision-making enhance the quality and the implementation of decisions…”.

In the context of the upcoming Meeting of Parties to the Espoo Convention in June 2017, the roundtable will analyze the legal provision of the two conventions and their implementation to cases of lifetime extension of nuclear units. The presentations and discussions on the case studies aim to map the progress since the last Meeting of Parties to the Espoo Convention and draw recommendations from civil society and MEPs prior to the Meeting of Parties in June this year.


Introduction and state of play
Rebecca Harms, Green MEP

First Panel - Moderated by Rebecca Harms

Overview of Espoo and Aarhus conventions obligations in the nuclear sector
Dr. Doerte Fouquet, Becker Büttner Held
Her presentation:

The Espoo and Aarhus conventions and the EU and Euratom Treaties
Georges Kremlis, DG Envrionemnt, European Commission
His presentation:


Importance of public participation in decisions making in the nuclear domain
Jan Haverkamp, Greenpeace International/Nuclear Transparency Watch
His presentation :

Second Panel - Moderated by Bendek Javor

The lifetime extensions of nuclear units in Ukraine
Iryna Holovko, CEE Bankwatch Network, Ukraine
Her presentation :

The lifetime extensions of nuclear units in Belgium
Eloi Glorieux, Greenpeace Belgium
His presentation:

The lifetime extensions of nuclear units in Bulgaria
Petar Kardjilov, Green Party, Bulgaria
His presentation

Concluding remarks
Benedek Javor, Green MEP



Capture d’écran 2017-02-27 à 17.42.46

NTW response on European Commission refusal to give access to information on grounds PAKSII non-tendering

On 8 December 2016, Christiana Mauro and NTW made a request access to the documents connected to the legal assessment of infringement proceeding 2015/4231 initiated by the Commission against Hungary with regard to the public procurement process for the Paks Nuclear Power Plant refurbishment and new reactor construction. In addition, they also request the Commission to provide any additional documentation related to the investigation that may be available under Regulation 1049/2001, including the legal analyses conducted by the Commission services, internal notes and documents, correspondence and reports.

On 19 January 2017, NTW and Christiana Mauro received a refusal informing that their application cannot be granted, as disclosure is prevented by exception to the right of access laid down in Article 4 of this Regulation.

On 22 February 2017, following this request for access to documents of 8 December 2016, NTW and Christiana Mauro submitted a confirmatory application in accordance with Article 7(2)[1] and 7(4)[2] of Regulation (EC) No 1049/2001 of the European Parliament and of the Council of 30 May 2001 regarding public access to European Parliament, Council and Commission documents. They ask to reconsider the position taken as regards the request for the legal basis of the conclusion of infringement procedure NIF 2015/4231, to which access has been refused.

Find this access to information on


Germany`s nuclear repository search – From the difficulties of the public to participate

Statement from NTW member Brigitte Artmann, councilor Greens Fichtelgebirge, district of Wunsiedel

There is within Germany from different sides still criticism on the operation of the Commission for the Storage of High Level Radioactive Waste, which did not permanently exclude the Gorleben site, that has been considered for final disposal of German high-level radioactive waste, from future siting decisions. The Commission instead refers this issue to the German Government that is to draft a legal regulation on siting during 2017. This includes issues of transparency, among others about role of a strategic environmental assessment and related public participation questions.

The German regions want to have a say in the search for a repository for high radioactive waste. A series of workshops of the competent Commission for the Storage of High Level Radioactive Waste from the Federal Governmentand the Federal Council of Germany ended up with an unusually broad consensus of the participants. The participants demanded from politics and Commission to involve the public as widely and as early as possible in the forthcoming, decades-long search. Unfortunately a lot of this broad consensus wasn`t taken into account by the Commission. In addition the 111 persons that had sent comments during the final public consulting phase of the Commission`s report were not incorporated.

Download the statement of Brigitte Artmann raising this issue: NTW_Germany_s_nuclear_repository_search

More information:

- Website “Aarhus Konvention”:

Statement of Dr. Roda Verheyen concerning the violation of the Aarhus Convention by German Law commissioned by the Aarhus Konvention Initiative., forwarded to the German Environmental Ministry in June 2016:

- Website of Friends of the Earth Germany BUND:  “the search process for a repository site for highly radioactive nuclear waste  - BUND’s criticism and demands”. 

- The English summary of the report of the German Commission on the Storage of High- Level Radioactive Waste: Donwload

Capture d’écran 2017-02-23 à 10.07.24

Joint Project conference on RWM in Budapest on 15 Deember 2016

A one-day conference with international experts has focused on the Euratom directive on management of spent fuel and radioactive waste (Council Directive 2011/70/Euratom) in Budapest on 15 December 2016.

The status of implementation in EU member states and whether this directive will „solve“ the issue of waste disposal have been analyzed.

To illustrate the effectiveness or non-effectiveness of this directive, national cases were observed. Hungary was an example of a country (not the only one) still considering the export of spent fuel to the Mayak facility in Russia.

This conference also provided up-to-date information on the situation at Mayak and the Hungarian plans for spent fuel from Paks I and Paks II.

A report of the conference and speakers presentations are available on the Joint Project Website.

Capture d’écran 2017-02-22 à 16.19.16

English summary of the Report of the German Commission on the Storage of High- Level Radioactive Waste

After more than two years of work the German commission on nuclear waste disposal (“Endlagerkommission”) in July 2016 released its final report. In February 2017 a translation of the summary of the report has been made available. The report focuses on the importance of the safety of a final repository and on siting issues as well as recommending a repository solution that is reversible. The report recognises the importance of transparency in information and public participation and ends by giving a number of political and social recommendations.

The English summary of the report of the German Commission on the Storage of High- Level Radioactive Waste: Donwload

There is within Germany from different sides still criticism on the operation of the Commission, which did not permanently exclude the Gorleben site, that has been considered for final disposal of German high-level radioactive waste, from future siting decisions. The Commission instead refers this issue to the German Government that is to draft a legal regulation on siting during 2017. This includes issues of transparency, among others about role of a strategic environmental assessment and related public participation questions.

More information is available on:

- Website “Aarhus Konvention”:
Statement of Dr. Roda Verheyen concerning the violation of the Aarhus Convention by German Law commissioned by the Aarhus Konvention Initiative., forwarded to the German Environmental Ministry in June 2016:

- Website of Friends of the Earth Germany BUND:  “the search process for a repository site for highly radioactive nuclear waste  - BUND’s criticism and demands”. 


Capture d’écran 2017-01-26 à 17.22.13


7 February 2017, European Parliament, room 8F388, 9:00- 12:30
Co-hosted by:
- Victor Boştinaru (S&D)
- Rebecca Harms (Greens/ALE)
- Bendek Javor (Greens/ALE)
- Sirpa Pietikäinen (EPP)

Download: the program

An EU legal framework for waste management in Europe was created in 2011 with the adoption of the Council Directive on the management of radioactive waste and spent fuel (2011/70/Euratom). The Directive provides for close monitoring of national programmes for the management and final disposal of radioactive wastes. Member States have submitted their first report on the implementation of their national programmes in August 2015. The programmes need to include all waste management steps as well as financing measures. The goal is the safe and responsible radioactive waste management to protect workers and the general public against the dangers arising from ionizing radiation. Any undue burden on future generations should be avoided. The relevance of transparency and public participation is also reflected in the RWM Directive: “Every state has to include a transparency concept in its national programme. “

The aim of this conference is to give a real picture of the challenges in Europe for radioactive waste management. The conference will be the opportunity to have the perspectives of environmental NGOs by presenting the BEPPER report of Nuclear Transparency Watch1 and the Joint Project Report which describe an effective transparency and public participation regimes in the area of spent fuel and radioactive waste management and its real application. The conference will also analyse national cases and the future of research on radioactive waste management.



“Opening speech”
- Victor BOŞTINARU, Member of the European Parliament (S&D)

Opening speech by Victor BOŞTINARU par nucleartransparencywatch

“Overview European of policy – results reporting under 2011/70/Euratom”
- Ioanna METAXOPOULOU, Head of unit, Dg energy, European Commission
Download I.Metxoupoulou

“Overview European of policy – results… par nucleartransparencywatch


“Presentation of the NTW BEPPER project on transparency in RWM”
- Johan SWAHN, Director of MKG, member of NTW
Download: J.Swahn

“Presentation of the NTW BEPPER project on… par nucleartransparencywatch

“The Joint Project’s evaluation of the implementation of the waste directive”
- Gabriele MRAZ, Austrian Institute of Ecology

“The Joint Project’s evaluation of the… par nucleartransparencywatch


  “Status of projects for high level waste – example of Bure in France”
- Benoit JAQUET, General Secretary of the CLIs of Bure

“Status of projects for high level waste… par nucleartransparencywatch

“Radioactive waste transport between Hungary and Russia”
- Benedek JAVOR, Member of the European Parliament and NTW
Download: B.Javor

“Radioactive waste transport between Hungary… par nucleartransparencywatch


“The Research and Training Programme of the European Atomic Energy Community:   contribution to the development of safe, long-term solutions for the management of ultimate nuclear waste”
- Rita LECBYCHOVA, Fission Energy Unit in DG RTD, European Commission
Download: R.Lecbychova

“The Research and Training Programme of the… par nucleartransparencywatch

“Transparency and civil society interaction in European research on radioactive waste issues ”
- Gilles HÉRIARD-DUBREUIL, Mutadis
Download: G.Hériard-Dubreuil

“Transparency and civil society interaction in… par nucleartransparencywatch


“Transparency from the point of view of civil society ”
- Jan HAVERKAMP, Greenpeace
Download: J.Haverkamp

“Transparency from the point of view of civil… par nucleartransparencywatch

“Political consequences ” & concluding remarks
- Rebecca HARMS, Member of the European Parliament (Greens/ALE)

“Political consequences ” & concluding remarks… par nucleartransparencywatch