Author Archives: Nuclear Transparency Watch

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

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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.


9:00 – 9:15
Welcome coffee served inside the room

9:15 – 9:30
Introduction and state of play
Rebecca Harms, Green MEP

First Panel 9:30 – 10:30
Moderated by Rebecca Harms

Overview of Espoo and Aarhus conventions obligations in the nuclear sector
Client Earth – TBC

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

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

10:30 – 10:45
Coffee break
Second Panel 10:45 – 11:50
Moderated by Bendek Javor

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

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

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

11:50 – 12:00
Concluding remarks
Benedek Javor, Green MEP


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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

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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.

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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”. 


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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

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 6 February 2017, Brussels, European Parliament

Download: The program


The urgent problem of nuclear installations decommissioning
The decommissioning of nuclear facilities is one of the major challenges of the coming decades for Europe. A precise agenda of decommissioning is not available yet, but Europe will face a large number of closed down facilities. It is inevitable that facilities will stop, either because their planned lifetime comes to an end, otherwise because of economic, industrial or security reasons. According to statistics from the World Nuclear Association (association gathering producers of energy coming from nuclear power), 14 reactors have stopped operating as a result of an accident or a serious incident, 22 were shut down because of political choices and 97 were closed for economical profitability reasons.
Preparations should be made immediately to manage the massive decommissioning coming. The European Union has currently 131 nuclear plants in operation, 75% run for over 27 years, while the technical lifetime of a reactor ranges from 30-40 years, even though some will be extended to 50-60 years of operation. Europe has already several closed down reactors, but none of these plants have been completely decommissioned. The International Atomic Energy Agency (IAEA) recognizes the final shutdown of 29 reactors in Britain, 28 in Germany, 12 in France, 4 in Bulgaria, four in Italy, two in Lithuania, one in the Netherlands, three in Slovakia, two in Spain, three in Sweden.

Decommissioning operations
When decision of shutting down a power plant is taken, there’s still a decision to make about the strategy to adopt: immediate dismantling (meaning starting the operations as soon as possible after a facilities’ shutdown), deferred dismantling (waiting for the natural radioactive decay) or an entombment (pouring concrete over the entire building). What are the strategies mainly chosen in Europe?
The term decommissioning covers the whole ranges of activities executed after the cessation of a facility: dismantling of structures, systems and components, soil remediation, recycling, confinement, removal and disposal of produced spent fuel and radioactive waste. Do European countries control the technical feasibility of such a process? What are the experience feedbacks? On which experiences can they rely on to face the massive decommissioning process to come?
The process of decommissioning is also confronted to territorial matters:
How can a territory be prepared for decommissioning? What are the possible projects of replacement? Will the European sites return to grass, a « green field » state which means to make the land available for a subsequent use, or to the status of « brown field », that allows an industrial reuse of the land? The final goal of decommissioning is a very important issue because it will have an impact on the general cost and on the quantity of waste to manage.
page1image24400 page1image24560
Safety matter
Decommissioning is a major safety issue. Decommissioning consists in deconstructing facilities that have been nuclear facilities and will remain so as long as they are not completely dismantled. This raises important issues in terms of safety and radioprotection of the workers of the sector as well as the whole population and the environment. Classical risks become significantly greater during decommissioning operations due notably of decommissioning operation of electrical installations as well as handling, carvings and deconstructions works carried out. How to evaluate the safety of the decommissioning process? What will be the immediate impact and long-term impacts on the health of workers? Will some epidemiological studies be considered?
The dismantling of a nuclear installation involves the creation of waste and effluents can be very different from those produced during the operational phase. The most harmful waste, spent fuel, has very strong safety issues. As for the waste of very low activity, which represents little danger, will be produced in much larger quantities. The decommissioning waste pose disposal, management and also of transport issues.

Financial matter
Moreover, apart from the technical, health and environmental related difficulties, cost and financing of such projects appear as essential elements. Large uncertainties exist about the costs and duration of a decommissioning that remain difficult to estimate. Several questions arise: how are achieved the assessments of decommissioning costs, and what are the results? Are the estimates made in Europe reliable and useful? Concerning financing, the “polluter pays” principle is the current basis; the funding responsibility leans primarily on the operator of the facility. What are the financing practices in Europe (co-financing, shared control, financial reserves)? Are the operators’ financial reserves sufficient? What happens in the case of an operator’s financial default, would the consequences fall upon the States, and thus on the taxpayers?

Transparency and public participation
Risk assessment related to decommissioning is mainly based on the operator’s techniques. It is therefore essential to have legal measures ensuring transparency of processes throughout the European Union. Are there control means independent from nuclear operators? Are the responsibilities of decommissioning clearly drawn and transparent?
Transparency is essential to involve the citizens to decommissioning projects. The social and environmental issues related to the decommissioning of nuclear plants pose many questions among people living nearby the sites. What are the conditions for effective information and public participation in decisions about a nuclear facility’s decommissioning?
Thanks to the European Union and the creation of the Aarhus Convention, it is possible to resort to participatory democracy to resolve some environmental issues, including those concerning nuclear installations. Will Environmental impact Assessment available for the public? Will public consultation be organized in the case of decommissioning process?

Objectives of this exploratory workshop

- To give participants a scientific background on decommissioning processes and challenges.
- To review the different practices in EU MS and give an overview of the situation in Europe.
- To assess the possibilities for public participation regarding policies responding to decommissioning.

Co-hosted by
Benedek Javor (Greens/ALE) Rebecca Harms (Greens/ALE) Jo Leinen (S&D)


Introduction: Benedek Javor, Member of the European Parliament

Opening speech Benedek Javor par nucleartransparencywatch

SESSION 1: European Landscape and overview of the process of decommissioning Moderator: Rebecca HARMS, member of the European Parliament

Rebecca Harms, opening speech of panel 1:

Rebecca Harms: Opening speech of panel 1… par nucleartransparencywatch

“Overview of European nuclear decommissioning activities”
by Paolo PEERANI, Head of the Nuclear Decommissioning Unit, JRC, European Commission
Download his presentation : 1.1 P.PEERANI

“Overview of European nuclear decommissioning… par nucleartransparencywatch

 “Technical Aspects and management of risks”
by Dr. Veronika USTOHALOVA, senior researcher, Ökoinstitut
Download her presentation: 1.2-V_Ustohalova

“Technical Aspects and management of risks ” by… par nucleartransparencywatch

“Experience from Sweden”
by Johan ANDERBERG, Director of Radioactive Materials Dept., Swedish Radiation Safety Authority, Sweden
Download 1.3 J. Anderberg

“Experience from Sweden” by Johan ANDERBERG par nucleartransparencywatch

“Experience from Italy”
by Lamberto MATTEOCCI, Head-control of Nuclear activities, ISPRA, Italy
Download his presentation: L.MATEOCCI

“Experience from Italy” by Lamberto MATTEOCCI par nucleartransparencywatch

“Decommissioning and transparency. Blackout in the oldest Spanish nuclear Power Plant: Santa María de Garoña”
by Ramiro GONZALEZ VINCENTE, Minister of Government of Alava, Basque Country
Download his presentation

“Decommissioning and transparency… par nucleartransparencywatch

SESSION 2: Decommissioning costs: What are the costs? Who is responsible? 

“Funding requirements for decommissioning and costs evaluation in Europe, figures of the PINC”
by Gerassimos THOMAS, Deputy Director-General, DG energy, European Commission
Download his presentation: G.Thomas

“Funding requirements for decommissioning and… par nucleartransparencywatch

” The cost aspects of decommissioning: its estimation and examples.”
by Dr. Paul DORFMAN, Honorary Senior Research Fellow at the University College of London
Download his presentation: 2.2-P. Dorfman

” The cost aspects of decommissioning: its… par nucleartransparencywatch

” Legislation on the financing of the decommissioning”
by Dr. Dörte FOUQUET, Head of BBH’s Brussels office, Becker Büttner Held
Download her presentation: 2.3 D. Fouquet

“Legislation on the financing of the… par nucleartransparencywatch

” Decommissioning costs and risks in France”
by Yves MARIGNAC, Director of Wise Paris, France
Downloads presentation: 2.4 Y.Marignac

“Decommissioning costs and risks in France” by… par nucleartransparencywatch

“Nuclear decommissioning costs in Lithuania, Bulgaria, Slovakia”
by Phil WYNN OWEN, Member of the European Court of Auditors
Download his presentation: 2.5 – P. WYNN OWEN

“Nuclear decommissioning costs in Lithuania… par

SESSION 3: Control and transparency devices Moderator

” Key principles and use of international tools in Austria’s policy”
by Andreas MOLIN, Director of Directorate of General Coordination of Nuclear Affairs, Austrian Ministry of Environment
Download his presentation: 3.1-A.Molin

” Key principles and use of international tools… par nucleartransparencywatch

“Public participation in the decommissioning process in France”
by Philippe BIETRIX, CLI des Monts d’Arrée
Download 3.4-P.Bietrix

“The role of the European Union”
by Ioanna METAXOPOULOU, Head of unit, Dg energy, European Commission

“The role of the European Union” by Ioanna… par nucleartransparencywatch

“Transparency from the point of view of civil society”
by Jan HAVERKAMP, member of Nuclear Transparency Watch
Download 3-3 J.Haverkamp

” Transparency from the point of view of civil… par nucleartransparencywatch
Closing remarks: Jo Leinen (S&D)

Closing remarks by Jo Leinen, Member of the… par nucleartransparencywatch



Concerns on transparency and regulatory independence in Hungary

A letter of NTW to the IAEA and the Convention on Nuclear Safety concerning the law changes in Hungary

On 9 February 2017, Nadja Zeleznik, Chair of Nuclear Trasparency Watch wrote to Mr. Ramzi Jammal (President of the 7th Review Meeting of the Convention on Nuclear Safety (CNS) ) and Mr. Yukiya Amano (Secretary General of the IAEA) about NTW concerns on the law changes in Hungary and the issue of regulatory independence.

NTW was informed about changes in the Hungarian energy legislation that undermine the independent position of the nuclear regulator, the Hungarian Atomic Energy Agency (HAEA). This situation could seriously compromise transparency during the construction of nuclear projects and nuclear waste management, as well as fundamentally impair nuclear safety.

This letter recommend to discuss this matter during the 7th Review Meeting of the Convention on Nuclear Safety.

Letter of Nadja Zeleznik, Chair of Nuclear Transparency Watch:  download

Letter of Mr Jammal, President of the 7th Review Meeting of the Convention on Nuclear Safety (CNS) : download