Nuclear Transparency Watch made an assessment for the Environmental Impact Assessment (EIA) for the Life-Time Extension of Krsko Nuclear Power Plant. The document is here below :
Nuclear power plants
June 9th 2020
The ongoing debate whether or not to build new nuclear capacities in Czechia has become much more tangible following a new law and contracts with the energy company CEZ introduced by the Czech Government in the last few weeks. These actions are, however, very untransparent and avoiding any wider public discussion.
The Czech government, together with the majority state owned utility CEZ, for years have been keen to build a new nuclear unit. In 2019, CEZ got a positive decision on the Environmental Impact Assessment for two new 1200 MW units at the existing nuclear power plant Dukovany. The current plan is to start the construction of one unit in 2029 and have the plant operating from 2037. The biggest obstacle so far have been the costs and lack of clarity of how the state would financially support such a huge investment. The government is hoping to overcome this Gordian knot within the next weeks and months in a surprising initiative during the coronavirus crisis.
In a nutshell, the Minister of Trade and Industry, Karel Havlíček and Prime Minister, Andrej Babiš, introduced two concrete forms of state support which complement each other: firstly, the state will be purchasing electricity from the new unit for 30 years or more for a guaranteed price. Secondly, the state would grant a loan for CEZ for the construction, to ensure a much lower interest rate than a commercial loan. However, no quantification of the burden for the state budget and the consumers was published for either of the two support schemes.
On the guaranteed price, in May 2020 the state introduced a draft law which sets a scheme of financial support to nuclear power. Called “The law on measures for the Czech Republic’s transition to low-carbon energy”, it only deals with nuclear power, which in a NewSpeak twist is defined to equal low-carbon energy. It basically establishes a scheme, where the state is purchasing electricity from nuclear sources for a guaranteed price negotiated with the state. The agreed price should cover all the costs and insure an adequate profit to the investor. However the price is not set in law, it will be negotiated in due time with the Ministry of Industry and approved by the government. Also, the law suggests that the finances needed to pay for the extra guaranteed price will come from surcharges on distribution and transmission fees, paid for by consumers.
The original adoption plan presented by the Ministry was that the law should be passed by the Parliament in a so-called “accelerated proceeding” in first reading without any possibilities of amendments. However, after some criticism, the law will undergo regular process including Parliamentary committees handling it. The impact assessment does not contain any economic analyses suggesting how much the guaranteed price would be, although some figures were mentioned in public interviews. The investment is believed to be 160 billions of Czech Crowns (6 bln EUR) and including a state loan for the project, the electricity from the new reactor would cost only 50-60 euro/MWh. Therefore the guaranteed price that would cover the difference to the power market price is supposed to be negligible. However, this is extremely optimistic as all other nuclear projects in Europe have shown much higher costs, and Czech electricity prices already count as among the higher ones in the region.
As for the state loan, there were no more details available and it is not clear where the state money for the loan would come from. There are only statements of politicians saying that the state can organize finances with significantly lower interest rates.
Next to the new law, in April the Czech Government approved two draft contracts with the energy company CEZ , with the plan to finalize and sign the contracts by June 2020. The contracts are not public and according to the Ministry of Trade and Industry, these contracts deal with zoning issues, with tender procedures and also under which conditions the state would buy off the project from CEZ (in case of big delay, higher costs etc). Later in May, the Czech media reported that the government has also approved another document, classified as “secret”, setting rules for a nuclear tender, to minimize state security risks connected with foreign investors, especially Russia and China (1).
While Mr. Havlíček tweeted that negotiations with the European Commission about the approval of such state aid have already started, the public has no access to many of the documents and no idea of how much this project would cost the public budget nor their own pockets. The legislative process on the proposed law is an opportunity for non-governmental organizations and hopefully some opposition parties to push for more transparency and more concrete and realistic numbers on the table and extend the debate to alternatives to new nuclear power, which might in fact be much affordable.
Jiří Jeřábek, energy campaigner at Greenpeace Czech Republic
Edvard Sequens, CALLA
On Friday 12/10/2018, the Aarhus Convention Compliance Committee (ACCC) communicated its final findings to the parties involved in the complaint launched by Greenpeace in 2014 on the design lifetime extension of the Borssele Nuclear Power Plant. The findings will be submitted for confirmation to the 7th session of the Meeting of Parties in 2021.This decision represents a major step in the implementation of the Aarhus Convention in Nuclear.
Find here the full analysis by Jan Haverkamp, vice-chair of Nuclear Transparency Watch, nuclear energy and energy policy expert for Greenpeace, who filed the complaint for Greenpeace Netherlands.
The findings in short:
The ACCC came to the conclusion that the Netherlands are in non-compliance with the Convention because they did not carry out proper public participation as obliged under art. 6(10) of the Convention. (point 82)
The ACCC concluded: “The Committee considers that the permitted duration of an activity is clearly an operating condition for that activity, and an important one at that. Accordingly, any change to the permitted duration of an activity, be it a reduction or an extension, is a reconsideration or update of that activity’s operating conditions. It follows that any decision permitting the NPP to operate beyond 2014 amounted to an update of the operating conditions.” (point 65)
The ACCC “considers it inconceivable that the operation of a nuclear power plant could be extended from 40 years to 60 years without the potential for significant environmental effects. The Committee accordingly concludes that it was “appropriate”, and thus required, to apply the provisions of article 6, paragraphs 2-9, to the 2013 decision amending the licence for the Borssele NPP to extend its design lifetime until 2033.” (point 71)This means that it can no longer be argued that nuclear life-time extensions or Long Term Operation has no environmental effects.
The Dutch government could not have made the covenant with the operator in 2006, that included the obligation for compensation payments in case of closure earlier than 2033, without previously having carried out public participation concerning environmental issues. That earlier closure is still possible because of nuclear safety is not sufficient. (point 76 – 78)
The authorities “must as a minimum provide the public concerned with access to the information listed in subparagraphs (a)-(f) of [art. 6(6)].” The authorities should have made “information on the environmental effects of such longer operation […] available to the public concerned.” An attachment submitted to parliament in 2006 does not amount to access to all available information for a procedure carried out in 2012-2013, i.e. more than six years later. (point 85)
The Netherlands must “take the necessary legislative, regulatory and administrative measures to ensure that, when a public authority reconsiders or updates the duration of any nuclear-related activity within the scope of article 6 of the Convention, the provisions of paragraph 2 to 9 of article 6 will be applied.” (Recommendations, point 89) This means that for every coming decision, this decision needs to be informed by public participation that concerns also the environmental impacts of longer operation of the NPP.
During the third panel in the ENSREG meeting held on 29 June in Brussels, Jan Haverkamp presented the position of NTW concerning the life-time extension of nuclear power plants in Europe.
As the lack of fund for decommissioning is used as a justification for life-time extension of nuclear power plants, our concern is that economic arguments interfere with risk management.
NTW stand is that citizens have a natural, legal, moral and logical right to be consulted in the decisions concerning life time extension of NPPS. The logical instruments for their consultation and participation are the Espoo and Aarhus Conventions and (transboundary) environmental impact assessment.
Download the full presentation of Jan Haverkamp here.
CEE Bankwatch Network and Nuclear Transparency Watch with Members of Parliament asked the European Commission, as an opinion-making party of relevant international conventions, to provide leadership and express its clear support for the findings of relevant committees during the upcoming Meetings of Parties of Espoo Convention in June and of the Aarhus Convention in September, in favour of a coherent application of the Espoo and Aarhus Conventions to nuclear lifetime extensions.
Attached please find a joint letter of 18 members of the European Parliament, Nuclear Transparency Watch and the CEE Bankwatch Network, which is calling for a firm position leading to more nuclear transparency, public engagement and safety across Europe.
Downolad the joint letter.
Honorary Senior Research Associate, Energy Institute, UCL
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
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:
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.
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.
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.
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.
Benedek Javor (Greens/ALE) Rebecca Harms (Greens/ALE) Jo Leinen (S&D)
Introduction: Benedek Javor, Member of the European Parliament
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:
“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
“Technical Aspects and management of risks”
by Dr. Veronika USTOHALOVA, senior researcher, Ökoinstitut
Download her presentation: 1.2-V_Ustohalova
“Experience from Sweden”
by Johan ANDERBERG, Director of Radioactive Materials Dept., Swedish Radiation Safety Authority, Sweden
Download 1.3 J. Anderberg
“Experience from Italy”
by Lamberto MATTEOCCI, Head-control of Nuclear activities, ISPRA, Italy
Download his presentation: L.MATEOCCI
“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
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
” 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-Paul-Dorfman
” 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
” Decommissioning costs and risks in France”
by Yves MARIGNAC, Director of Wise Paris, France
“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
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
“Public participation in the decommissioning process in France”
by Philippe BIETRIX, CLI des Monts d’Arrée
“The role of the European Union”
by Ioanna METAXOPOULOU, Head of unit, Dg energy, European Commission
“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)
The European watchdog organisation Nuclear Transparency Watch(NTW) warned today the Belgian federal minister of Energy Marie-Christine Marghem, that her legislative proposal to extend the lifetime of the 40 years old Doel 1 and Doel 2 nuclear power reactors threatens to break international rules for transparency. If the right of the public to participate in an environmental impact assessment will not be respected, NTW will seek advice on initiating a formal complaint to the Compliance Committee of the Aarhus Convention.
End February 2015, the Belgian Council of State warned the Belgian Energy minister that lifetime extension of old nuclear power reactors cannot be decided without organising an Environmental Impact Assessment (EIA) and a national and transboundary public consultation process, as prescribed by the European Directive 2011/92/EU and the Aarhus and Espoo conventions, both signed and ratified by Belgium.
On 5 and 6 May 2015, the final discussions before the vote on the Doel 1 & 2 lifetime extension will take place in the Economy Commission of the federal parliament. Before these discussions, NTW chair, Michèle Rivasi, sent today a letter to the energy minister to stress the importance of respecting international obligations to organise a full scale EIA and a cross border public participation process in advance of any final decision.
Ms. Rivasi commented: “The environment around Doel has fundamentally changed over the last 40 years and the risk of failure of the reactors increases exponentially over time. Ten years extra lifetime also adds 25% more time in which they are exposed to the risk of terrorist attack. This all on 12 km from the centre of Antwerp. It is important and legally prescribed that citizens get the chance to make sure all environmental concerns are taken into account when such a decision is taken. It would be completely inappropriate to look for loopholes to circumvent this obligation.”
The letter from NTW Chair, Michèle Rivasi to belgian minister of Environment, Marie-Christine Marghem: click here
A half-day conference was organized in the European Parliament in Brussels to address the issue of the ageing of nuclear power plants in Europe and its impact on nuclear safety.
19th March 2014 in the European Parliament.
Download the minutes of the workshop.
Presentations of the speakers and video:
Session 1: Ageing processes
Technical characteritics of ageing processes and their impacts on nuclear safety, Simone Mohr, Senior Researcher, Okoinstintut (EN)
Simone Mohr, Okoinstitut – Nuclear plants… par nucleartransparencywatch
Related issues : ageing of human know-how, design and technology. What does the JRC do in this respect ?, Peter Haehner, Head of unit, Joint Research Center (EN)
Ageing of nuclear plants – Peter Haehner, JRC par nucleartransparencywatch
Session 2: Measuring the risk
GDF Suez/ Electrabel approach of the Long Term Operation in Belgium by Pierre Doumont, Group Senior Vice President, Nuclear Safety & Radiation Protection, GDF Suez (FR)
Ageing of Nuclear power Plants seminar – Pierre… par nucleartransparencywatch
Controls methods across Europe and recent developments by Noël Camarcat, Special Advisor for Nuclear R&D and international issues, EDF (EN)
Ageing of Nuclear power Plants seminar – Noël… par nucleartransparencywatch
Regulation and supervision of aging management in Swedish NPP by Lars Skanberg, head of the section for Reactor Technology and Structural Integrity, Swedish Radiation Safety Authority(EN)
Ageing of Nuclear power Plants seminar – Lars… par nucleartransparencywatch
Control of “Time-Dependent” safety, the role of ASN by Philippe Jamet, Commissioner, French Nuclear Safety Authority (EN)
Ageing of Nuclear power Plants seminar… par nucleartransparencywatch
Session 3: Policy responses to Nuclear Power Plants ageing
Public participation in Plant Life EXtension discussions: Ecoclub experience by Andriy Martynyuk, Chair of the Board of the Eco Club Rivne (EN)
Ageing of nuclear power Plants seminar – Andriy… par nucleartransparencywatch
Long-term operation of NPPs: what to do at EU level? by Massimo Garribba, Head of Unit, European Commission DG ENER (EN)