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Nuclear Transparency Watch

Prevent and anticipate through transparency and participation

Nuclear power plants

Hybrid event on Small Modular Reactors (SMRs)

🚨Check out Nuclear Transparency Watch latest video on an hybrid event dedicated to cross-cutting views on Small Modular Reactors (SMRs)☢️:

Thanks to Alexis Geisler-Roblin who moderated this event, complementary contributions were shared by speakers from the French 🇫🇷 national agency for radioactive waste management l’ANDRA, from the new French 🇫🇷 regulator and technical support organisation l’ASNR, from the environmental NGO – member of NTW – Friends of the Earth Estonia 🇪🇪 and from the NGO based in the USA 🇺🇸 Nuclear Information and Resource Service.
The event address key questions such as perspectives on projects, waste management or regulations aspects. You will find below the presentations provided by the 4 speakers:
SMRs globally and in Estonia by Madis Vasser (FoE Estonia)
SMRs and waste in France by Virgine Wasselin (ANDRA)
Adaption to the regulatory framework in France by Philippe Dupuy (ASNR)
👉 for more info from ASNR on this click here (only in French for the moment)
US-Nuclear-Regulations by Tim Judson (NIRS)
👉 for more info from NRIS on this click here

Transboundary participation and safety concerns

In the frame of the Consultation on the 4th periodic review of France’s 1300 MWe nuclear reactors, NTW provided the following statement:

Insufficient transboundary participation and the risk of French Nuclear Power Plants (NPP) for European countries.

Note: ANCCLI being a founder member of NTW and a member of the HCTISN it didn’t associate to this statement for obvious deontological reasons.

Insufficient transboundary participation and the risk of French Nuclear Power Plants (NPP) for European countries

The safety objectives for the continued operation of 1300 MWe reactors is to move towards the safety levels of the latest reactors (EPR). To date, 1300 MWe reactors have not achieved the highest levels of safety, and concerns persist about corium and the ability to dissipate heat in the event of core meltdown, as well as the safety of fuel pools.

The ASN guidelines regulating protection against flooding are outdated for a possible extension[1]. There are remaining doubts whether the Hardened Safety Core’s design against flooding events considered adequately the effects of climate change. In fact, regarding impacts of climate change in general, Patrick Lejuste (IRSN) said during the consultation that he was “very pessimistic” adding that “there are a lot of unknowns”[2]. Also, design basis earthquakes need to be defined not only on deterministic methods as this is no longer state-of-the-art[3].

Nuclear risk resulting from the French NPP fleet should not be underestimated and could probably impact other country in Europe. Calculations from the project flexRISK show a contamination risk in consequence of a severe accident in the old French NPP fleet for all over Europe.

The extension of reactor operation and, more generally, the arrival of new reactors (EPR) cannot be achieved without a thorough review of waste and fuel management, some links of which are under strain.

The risk to humans and environment resulting from severe accidents and from nuclear waste management has to be assessed and presented to the public, also from other European countries in a transboundary Strategic Environmental Assessment (SEA). The lifetime extension program constitutes a prominent part of the French energy policy and therefore falls in the scope of SEA Directive 2001/42/EC; moreover, as the French Multi-Annual Energy Plan also was not subjected to a transboundary SEA but only to a voluntary consultation.

If transboundary comments are appreciated, an English version of the consultation website and of all documents should be offered, too. Furthermore, NTW is concerned by the absence of consultation guarantors reported several times in order to ensure a real participatory process agreed on[4].

To preserve the trust and fruitful consultations of the participatory process, much greater access to resources must be possible for members of civil society such as local residents, NGO volunteers or young people.

We demand a transboundary Environmental Impact Assessment (EIA) for every lifetime extension of an old NPP beyond the originally foreseen lifetime of 40 years, especially in the lights of the new developments in the framework of the Espoo and Aarhus Convention which clarified the EIA obligation for NPP life-time extensions.

[1] https://www.umweltbundesamt.at/fileadmin/site/publikationen/rep0915.pdf 4.4.3, p.39.

[2] https://concertation.suretenucleaire.fr/media/default/0001/01/89713121a30d81cd976bcbca2ed8f218b79cd88f.pdf

[3] Results from the expert statement of the Austrian Government to the consultation.

[4] https://concertation.suretenucleaire.fr/media/default/0001/01/89713121a30d81cd976bcbca2ed8f218b79cd88f.pdf

United-Kingdom: pressure over land at Moorside for SMRs

“A letter signed by more than 100 political, business and union leaders is calling for urgent action to resolve land issues at Moorside so that new nuclear power stations can be built.

Whitehaven and Workington MP Josh MacAlister wrote the letter, which has been signed by fellow Cumbrian MPs Julie Minns and Markus Campbell-Savours, local members of the House of Lords, Cumberland Council leader Mark Fryer, trade union leaders in the nuclear industry and dozens of local business leaders.”

Here is the News & Star journal introduced the letter below (source):

“In my first few weeks as an MP I’ve met with ministers, the NDA, Great British Nuclear and leading nuclear industry figures. It’s become clear that there’s been a conspiracy of silence for years over plans for new nuclear in our area. The last government told our community to wait in line and trust the process. But having looked in detail at the process, we’ve been set up to fail because of competing claims on land at Moorside.

The NDA want to use a large chunk of the land at Moorside for potential future decommissioning activity. If all of the land they want is taken out then there’s not enough land left to build the number of small modular reactors Great British Nuclear wants.

Today, over 100 local leaders are ringing the alarm on this. Our ask is simple – this is land designated for new nuclear use and it should be prioritised for new nuclear use. The NDA should develop contingency plans for their future land needs and buy alternative land for future decommissioning activity if and when the need arises.

West Cumbria has the land ready to go, the strong community consent, the skills and the nuclear infrastructure which make our area the perfect location for new nuclear. We do not want to miss out on another opportunity.”

In reaction to this letter, Colin Wales, Chair of Cumbria Trust and member of Nuclear Transparency Watch, wrote the published letter below:

“Your article on the Battle for New Nuclear was an interesting read, particularly the part about the “conspiracy of silence” as Mr. Mac Alister described it. Surely part of the truth is that if the Mid Copeland GDF Community Partnership progresses to borehole investigations, then all the “Moorside” land mentioned will be “needed” for GDF access and decommissioning work. That is the NDA’s priority and given the encouraging subsea geology results a Sellafield area the GDF looks the most likely outcome.

Another thing counting against the siting of Small Modular Reactors in that area are the International Atomic Energy Agency guidelines. While not specific, common sense raises some significant safety issues i.e., Would it be wise to site any operational nuclear power plant next door to what Europe’s largest stockpile of nuclear waste for the reason that an accident at one facility might well render the other inoperable. Do either the Office of Nuclear Regulation or CoRWM have a view on this?    

A less risky, less expensive, more productive, and safer alternative might be to spend such huge amounts of money on a Morecambe Bay/Duddon Estuary 3GW transport and power generation barrage. For comparison, this would :-

*Connect the 3 nuclear communities of Copeland, Barrow and Heysham.

*Provide easy access for West Cumbrians to the M6 southbound and increase tourism to the Western Lake District.

*Provide a flood defense for local communities against predicted rising sea levels.

*Provide 2 x the power output than 3 SMR’s    

*As part of a deal to host the GDF it could provide us with cheaper power, an attraction to business investors and provide west Cumbrian households with discounted electricity bills for decades to come.  

*Be built using a local workforce.

* Have a lifetime of 120 years as opposed to 60 years for nuclear power plants.

It is also important to note that Electricite de France (EDF) have abandoned their SMR programme and Rolls Royce are trying to sell their SMR business.

Given the new Chancellor’s ideas on using the Canadian approach to Pension Fund investment for major infrastructure projects, what is proposed above would work well since there would be guaranteed long term returns on investment. Other countries do strategic infrastructure programs, why can’t we?

Colin Wales – Cumbria Trust and Nuclear Transparency Watch”

Bulgaria: NPP Kozloduy and SLAPP case against citizen Natalia Stancheva

NTW is happy to inform about the unprecedented claim of 500,000 BGN (253,837 euro) – a SLAPP case filed by the Kozlody Nuclear Power Plant (NPP) against the nurse Nataliya Stancheva who revealed violations of the law at the Bulgarian nuclear power plant – has been withdrawn (see NTW’s position on the case below).

After Nuclear Transparency Watch, Dr. Petar Kardzilov reached out to the Bulgarian media and organized a protest in front of the Ministry of Energy in defense of Nataliya Stancheva. Publications in leading media and an invitation to Natalya and him on an evening talk show followed. All this contributed to putting pressure on the Kozloduy NPP to withdraw their shameful lawsuit against the woman who exposed the corruption scheme with the polyclinic operating at the NPP site using her right according to the Access to Public Information Act.
 
However, now, according to Natalia’s information, the illegal polyclinic continues to function and no one in the state is checking and taking action to eliminate it. Actions in this direction are also forthcoming with Dr. Petar Kardzilov’s colleagues from Bulgaria at NTW, Albena Simeonova and Borislav Sandov. According to Natalia’s information, a bank, pharmacy, shops and other illegal sites also operate at the site of the Kozloduy NPP. Below are the media publications in Bulgarian.
Publications after the position of NTW and the gathering in support of Natalia Stancheva before the Ministry of Energy:
 
An international organization calls on the Kozloduy NPP to withdraw a case against a citizen
Citizens protest in defense of the nurse fired from Kozloduy NPP
Kozloduy NPP to withdraw the claim against an employee who revealed violations, European organization called
Protest after an unprecedented claim for half a million BGN of Kozloduy NPP against a former employee
Protest in support of the nurse sued by the Kozloduy NPP for BGN 500,000 in a slap case. The case is an embarrassment to the management of the plant. Brutal, unheard of and unprecedented insolence, said the non-governmental organization Nuclear Transparency Watch
On the territory of the “Kozloduy” NPP there is also… a pharmacy, a restaurant, a bank This is what Petar Kardjilov from Nuclear Transparency Watch claims
In support of Natalia Stancheva – citizens protested in front of the Ministry of Energy
UNHEARD OF: “Kozloduy” NPP prosecuted its employee with a lawsuit for half a million BGN! The office of occupational medicine at the headquarters has been turned into an unregistered polyclinic, the woman reveals
A former employee of Kozloduy NPP is being sued for BGN 500,000, they defended her during a protest
Slavi Trifonov’s evening show, January 25, 2024.

 

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Article on Rosatom-show in COP28 and other issues

January 6, 2024

Source:Rosatom News

József Kóbor dr.

Pécs City Council, Hungary, European Committee of the Regions, NTW

Undoubtedly, it borders on the absurd that at the largest world environmental congress in 2023, COP28, the biggest appearance was presented by the Russian state nuclear giant ROSATOM. It is even more absurd when you consider that this company is theoretically being boycotted by the so-called “democratic world” due to Russia’s war against Ukraine. Or maybe not .

The Small Modular Reactors (SMR) have become so important for both Rosatom and the entire world that the Russian state-owned company recently dedicated a day to them at the United Nations Climate Change Conference (COP28) in Dubai – an SMR day. In addition, Rosatom conducts negotiations, concludes agreements, develops projects and prepares documentation related to the construction of small power reactors. Nuclear experts from other countries will also be familiarized with small power plants and their operating characteristics.

SMR Day was one of the most important events in Rosatom’s COP28 program. The event began with a vivid multimedia presentation covering the construction of a small, powerful onshore nuclear power plant in Yakutia that will be “carefully” integrated into the Arctic ecosystem.

Guests were able to virtually explore the Lomonosov floating nuclear power plant, which supplies electrical energy and heat to the town of Pevek on the Chukchi Peninsula, Russia’s northernmost city. “I am sure that Rosatom’s small powerful nuclear power plants represent an efficient and environmentally friendly choice for countries that, for various reasons, have not previously thought about their own nuclear energy production,” said Alexey Likhachev, the general director of Rosatom, in his video message to the Participants of the SMR day. The Russian small, powerful nuclear power plants are also interesting for other countries.”

The parties will examine the possibilities and study the location of the mainland SMR, the configuration of the power plant and the infrastructure required for construction and operation, and select the optimal implementation model for the project.

Hearing all this, an expert who has worked in the nuclear industry for decades remembers the old joke: For a newborn, every joke is new. Because what ROSATOM has presented here on the subject of SMR is a story from over 60 years ago that could only have been something new for the “newborn” and laypeople. The IAEA had been trying to “sell” this to the public since 1960. It is the civilian application of these small nuclear reactors developed by the nuclear powers to power their strategic nuclear submarines and aircraft carriers. (Also for icebreaking ships of the Soviet Union or Russia, this can be described as civilian use).

In reality, every previous project that has attempted to use SMRs for civilian economic purposes – where profitability, economy and the promised low operating costs mattered – has failed. The nuclear reactor was dismantled from the USA’s only nuclear-powered cargo ship 50 years ago and converted to diesel. Canadian nuclear heating plants were converted to gas and oil. Nothing came of the planned nuclear-powered locomotives, trucks, heavy commercial vehicles, seawater desalination plants, electrolysis plants and industrial heat generation units. Although a nuclear company came forward with such plans at least once every 10 years, they were never accepted by the business community.

So there is currently the lavishly presented Lomonosov floating nuclear power plant, whose towing through the Baltic Sea has sparked international protests – the others only belong to the category of visions, as was the case with the earlier ones.

IAEA also dreams – and unfortunately, EU plays with it

The IAEA published a report ahead of the COP28 conference entitled “Nuclear Technology Review – 2023”, which presents the main events and trends of 2022 and is considered by the agency’s experts as a pathfinder for the future development of the global nuclear industry.

We focus on the most significant and interesting ones.

Increase in nuclear capacity

The IAEA has increased its forecast for the development of the global nuclear industry in the last two years. According to the optimistic forecast, the installed capacity of nuclear power plants worldwide could reach 873 GW by 2050. This would be 10 percent higher than last year’s forecast. This could increase the share of nuclear energy in the global energy basket from the current 9.8 percent to 14 percent. (This was roughly the case before the Chernobyl meltdown   .) Realizing this forecast will require a major shift to long-term operation, which means extending the life of existing reactors and building about 600 GW of new nuclear production capacity over the next 30 years.

It is quite shocking that the UN organization, whose main task should be the protection of nuclear safety, supports the systematic extension of the operational life of old, expired nuclear reactors, which obviously means an increase in risk and, incidentally, contradicts the previous principles of the IAEA!

And of course, Rosatom contributes significantly to achieving this goal. The state-owned company is building 22 power plant blocks in seven countries. The project portfolio includes a total of 33 units in 10 countries. The state-owned company has built 18 high-performance units in 18 years, nine of which were outside Russia. This year, fuel was delivered to the Akkuyu nuclear power plant under construction in Turkey and the Ruppur nuclear power plant in Bangladesh.

It is interesting that the IAEA does not say a word about the Belarusian Astravets nuclear power plant, which is also in operation – perhaps not by chance, as there are serious technical problems with the new VVER-2000 reactors. These reactors are also to be taken over by the Hungarian Paks2 project.

Difficulties in financing nuclear projects are hindering the construction of new nuclear capacity, study finds. However, there are “positive” developments, with nuclear energy being included in the sustainable finance taxonomy of the European Union and other countries in 2022.

What is taxonomy? Taxonomy is a tax system, which in this case means that nuclear energy and natural gas are considered “green” to enable the complete phase-out of coal and oil while meeting carbon emissions reduction targets. This would be the basis for the EU program to develop a green economy, the Green Deal. Behind this was a formal nuclear coalition: France under Macron, Hungary under Orbán, the Czech Republic, Poland – but above all Russia under Putin, for which both nuclear energy and gas would have been huge business.

Of course many people protested against it. Greens, professional associations. I – as a Hungarian city council member, member of the European Committee of the Regions and member of Nuclear Transparency Watch (NTW)   – presented the case for plenary debate in December 2021. The European Parliament rejected the taxonomy. Nevertheless, the European Commission pushed through the taxonomy on December 31, 2021, on New Year’s Eve (!!). At this point, Russian tanks were already massing on the Ukrainian border. Everyone knows what happened next.

Small nuclear power plants

A current trend identified by the IAEA is interest in small-scale nuclear energy production. “Small nuclear power plants, along with high-performance water-cooled reactors, are expected to account for the majority of capacity additions over the next three decades,” the report says. of course in cooperation with the promotion of Rosatom projects..

Rosatom has commissioned the world’s first floating nuclear power plant, the Lomonosov Academic Floating Power Plant, and has begun implementing three more small floating nuclear power plant projects. The first four floating nuclear power plants provide power to the Baimsky Mining and Processing Complex. The second will be a small mainland nuclear power plant in Yakutia.

In addition, Rosatom is working on the construction of a small-scale nuclear power plant based on the Shelf-M reactor to supply energy to the Sovetskaya Gavan and neighboring areas. In total, Rosatom has about a dozen plans for the development of small nuclear power plants at various stages of development. Rosatom is actively negotiating with various governments, particularly Mongolia and Myanmar, to build small nuclear power plants.

The report states that modernized versions of water-cooled reactors are increasingly being considered, studied and built to gradually become modern, more efficient, semi-closed or “closed” ! Introduce fuel cycles. (A closed fuel cycle without waste production does not exist!)

“In the Russian Federation, conceptual research is underway on innovative water-moderated reactors with supercritical coolant parameters, including fast neutronic applications. The latest developments focus on small modular variants with an emphasis on improved nuclear safety, nuclear protective equipment, economic efficiency and sustainability parameters.” In addition, the development of Rosatom’s spectrally controlled VVER-S reactor is at an advanced stage. Among the promising technologies are also called salt bath reactors.”

Rosatom is also developing in this area, but not for energy purposes. The aim of the research is to test the transmutation of minor actinides in order to produce lower-activity fissile substances. This salt bath reactor is scheduled to be commissioned in 2030.

Note: not lower-activity, but perhaps shorter-lived isotopes (and not fissile material, but waste) can be produced with transmutation, but only with very poor efficiency.

“The report devotes a separate chapter to fast neutronic reactors.”

There are five fast neutron-cooled sodium reactors worldwide. One in China, one in India and three in Russia. Rosatom also plans to build the BN-1200 fast neutron reactor with 1200 MW of electrical power. According to plans, the first concrete for the BN-1200 will be poured into the block body in 2027.

“Technologies that use liquid metal coolants are receiving increasing attention. Rosatom is a leader here and is the first in the world to build the BREST OD-300 experimental demonstration reactor with 300 MW of electrical power.”

The characteristic feature of fast neutron technology is that the reactors operate at high temperatures in the strained operating mode with a high risk. Cooling with liquid metals.   Most importantly, they produce plutonium, suitable for both nuclear weapons and nuclear fuel. Precisely for this reason they were not encouraged and even banned from spreading. Previous attempts in Germany, France, Sweden and even Czechoslovakia and Romania (!!) failed. It is truly shocking that this technology, which is extremely dangerous from a safety perspective, is now being promoted again.

The other applications of atomic energy

As mentioned in the report, the greatest interest in the non-electricity applications of reactor technologies is heat generation – alone or in conjunction with electricity (district heating and heat supply for industrial enterprises), seawater desalination and hydrogen production. Rosatom also deals with these areas and carries out developments. The Lomonosov floating nuclear power plant in Chukotka also supplies heat to the town of Pevek.

“A desalination plant designed and installed by Rosatom will be installed at the Akkuyu Nuclear Power Plant to serve the reactors and to meet the needs of drinking and fire-fighting water.”

The commissioning of an experimental plant for hydrogen production through electrolysis is planned at the Kola nuclear power plant. In addition, Rosatom is developing a project for a plant with an annual hydrogen production capacity of about 110,000 tons, using a 200 MW high-temperature gas-cooled reactor and chemical technology. The first unit is expected to be operational in 2032.

Natural uranium

NAÜ experts – citing global forecasts – estimate that demand for uranium will rise from about 160 million pounds of uranium oxide annually to about 190 million pounds over the next five years. “Due to the expected further increase in spot prices for the uranium market, the procurement departments of nuclear power plants are expected to give preference to the early acquisition of uranium ore concentrate and again enter into long-term contracts with uranium suppliers. This could lead to a further increase in the immediate price of uranium, which is forecast to rise to $65/ton by 2027, compared to the previous price of $52/ton – the report said. Reality is already exceeding expectations: on December 4, 2023, the spot price for uranium was $81.45/pound.

“New uranium mines are expected to open in the next five to 10 years, including in Australia, Brazil, Canada, Mauritania and Namibia. “

And not just there. In Europe we know of at least ten new uranium mining projects. In southwest Hungary, uranium mining near the city of Pécs is to be reopened; in Germany there is the former Wismut project in the Elbe valley.

However, the planned production capacity of these new facilities will not be sufficient to meet the current shortage of supply, which is currently being met from secondary sources. In this regard, uranium exploration is expected to increase in the coming years, including both conventional and non-conventional sites,” state NAÜ experts.

“Rosatom is also developing sites and conducting exploration work in Russia and Kazakhstan and launching projects in Tanzania and Namibia.” (And in Hungary!)

Source:Rosatom News

József Kóbor dr.

Pécs City Council, Hungary, European Committee of the Regions, NTW

Link to the article in other languages: https://www.donauregion-atomkraftfrei.at/beitraege-ungarn/

Cross-border consultation on Lifetime extension of Doel-4 and Tihange-3 (Belgium)

Paris, 15 June 2023

Subject: Lifetime extension of Nuclear Power Plants Doel-4 and Tihange-3 in Belgium.

Link to the Cross-border consultation on Lifetime extension of Doel-4 and Tihange-3 (Belgium)

Nuclear Transparency Watch as citizen network on nuclear safety and transparency with organisation, elected and qualified members in the European region (including Belgium, Netherlands and Luxembourg) based in France has participated in the cross-border consultation regarding the Doel-4 and Tihange-3 nuclear power plants potentiel lifetime extension.

Participating to such consultation is not new for NTW, which as participated in the scope of the Environmental Impact Assessment to other consultation on Lifetime extension such as for Doel-1 & Doel-2 in Belgium as well but also abroad such as in Finland with Loviisa 1 & 2 or in Slovenia with Krsko.

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Lifetime Extension of the reactors of Doel 1&2

NTW’s position on the Lifetime Extension of the reactors of Doel 1&2.

Some reasons why the lifetime of the reactors should not be extended according to NTW.

1)     The Basic design is not satisfactory and cannot be sufficiently modified

In 2009, the Belgian TSO FANC (Federal Agency for Nuclear Control) requested in its advice on the Strategy Note for life extension of the Belgian nuclear power plants that the operator must prove that a plant has the highest possible safety level, and the reassessment should be done with respect to the most recent PWR nuclear power plants, i.e., third generation nuclear reactors, such as the EPRs under construction since 2002 in Olkiluoto (Finland) and Flamanville (France). The safety requirements for these reactors are stricter than for the second- generation nuclear reactors.

The four main problems in the design of Doel 1 and 2 that show the reactors do not meet current safety requirements and should not be extended are the following:

·      The Lack of a “core catcher” safety system

The reactors of Doel 1&2 are not equipped with a “core catcher”, a system that helps to prevent the very hot and extremely radioactive corium from penetrating into the soil and groundwater in the event of a core melt. Even if FANC considered a core catcher as a necessary condition for the lifetime extension, this is no longer included in the final long term operation action plan that they approved.

·      A single-walled concrete reactor building

The reactor buildings of Doel 1 and 2 have a single-walled concrete shell with a metal lining a few millimeters thick on the inside. The possibility of an accident involving a passenger aircraft was only taken into account when designing the most recent European reactors such as the EPR (under construction since 2002). Thus, no Belgian reactor has taken into account the risk of a 9/11-type terrorist attack. The plant operator’s long term operation action plan did not provide for any strengthening of the walls of the Doel 1 and 2 reactor buildings, to the extent that this would be practically possible at all.

·      There is no bunkered storage of irradiated fuel

The long-term operation action plan didn’t call for improvements to the cooling basin where the spent fuel rods from Doel 1 and 2 are stored after they have been discharged from the nuclear reactor. The building is not bunkered and is therefore vulnerable to external attacks.

·      A limited earthquake resistance

The design of Doel 1 and 2 did not take earthquakes into account. The FANC states that they are not “considered as a factor influencing the design requirements, due to the weak seismic activity of the region”.

2)    Crucial safety standards will be lowered to save money

When the FANC approved the lifetime extension of Doel 1 and 2, the original standards were lowered in function of the “economic” feasibility for Electrabel, the plant operator. For example, the reactor vessel covers replacement removal was a condition for extending the operation. However, the need to replace the existing reactor vessel covers was identified during the stress tests in 2012 and confirmed by FANC in its analysis of Electrabel’s long-term operation file. It is important because the reactor vessel cover is subject to ageing and its integrity must be guaranteed at all times.

3)    The degradation of the reactors of Doel 1 and 2 reaches a critical point

In April 2018, a leak developed in the primary cooling circuit in the Upper Plenum Injection line (UPI) of Doel 1, which cannot be separated from the reactor. Similar degradation was observed in Doel 2. This serious incident demonstrates that the degradation of critical components increases seriously with life extension, leading to irresponsible risks.

4)   The nuclear disaster INES-7 has not been taken into account

In the event the containment would fail, very large quantities of radioactivity may be released. Such an accident is categorized as INES-7 in the IAEA’s International Nuclear Event Scale (INES). However, this scenario is not taken into account in SCK’s EIA report.

The English version of the Environmental Impact Assessment (EIA) by SCK does refer to the research work of the University of Vienna (BOKU, Flexrisk project) commissioned by the Austrian government for accidents in which the containment is breached and radioactivity is therefore discharged unfiltered into the atmosphere. It is strange that SCK does not elaborate on this and that it is not included in the Dutch version.

A simulation of a nuclear disaster at Doel 1 demonstrated that both the Netherlands and Germany would be seriously affected, and a large part of the countries would become uninhabitable for a long period of time.

·      The emergency planning is not adapted to a serious nuclear accident

Doel 1 and 2 are situated in a very densely populated area, at ten kilometers from the center of the city of Antwerp. In the event of a nuclear disaster, millions of people risk having to live for decades in a heavily contaminated area, lacking the financial means to start a new life elsewhere.

The Belgian nuclear emergency plans were drawn up to protect the population against the impact of a limited nuclear accident, in which only a small quantity of radioactive substances escapes from the affected nuclear reactor and in which the radioactive contamination outside the site of the nuclear power plant is minimal. The measures, provided for in the nuclear emergency plans, are totally inadequate to protect the population in the event of a major nuclear disaster.

The emergency plan zones are too minimalistic. The evacuation of a city located near a nuclear power plant – such as Antwerp, Liège or Namur – has never been evaluated nor prepared or simulated.

·      Very limited nuclear liability

In a report, Bart Martens estimated the economic damage cost of a serious nuclear accident in Doel at more than €1400 billion. The port of Antwerp alone would lose €300 billion.

The nuclear operator Electrabel is only liable for €1.2 billion, i.e. less than one thousandth of what the real damage could amount to. The burdens and costs of this risk are thus passed on to the population, while the profits from nuclear energy are made by the company Engie.

5)    There is still no solution envisioned for nuclear waste

The production of highly radioactive spent fuel is more or less linear with the production of electricity, thus with the extending the operation of Doel 1 and 2 would generate more fuel elements and more irradiated fuel.

In April last year, ONDRAF/NIRAS presented a plan on long-term management of the long-lived nuclear waste, but it does not provide any concrete answers to the most pertinent questions, such as at what depth the nuclear waste would be stored, the nature of the soil layer or the exact location. Despite forty years of research by ONDRAF/NIRAS, there is still no concept for the proposed geological disposal.

It is hardly acceptable to produce more irradiated nuclear fuel, without any plan for what to do with it.

6)    Assessment of alternatives

With the argument of the need to maintain supply security, the Doel 1&2 reactors are allowed to operate even after the Belgium Constitutional Court has annulled the 2015 life-time extension permit. An analysis undertaken by the German Umweltinstitut in 2020 however showed that even the immediate shut-down of the reactors Doel 1&2 would not have negative impacts on supply security in Belgium.

Without the argument of maintaining supply security there is no valid justification left to keep Doel 1&2 operating until 2025; both reactors could be shut down immediately.

7)    Changes in the environment of the Doel NPP

The NPP Doel went into operation in 1975. At this time, there was no legislation on Environmental Impact Assessments in force. Therefore, the Doel plant has never undergone such an assessment.

Doel lies in one of the most densely populated regions in Europe. In an article in Nature from 2011, Doel was labelled as the European NPP site with most population living in a 75 km circle. In about 30 km distance is the agglomeration area of Antwerp, where about 1.2 million people live today. When Doel went into operation, population density was lower.

An analysis of the changes in the environment which have occurred since the NPP’s start of operation until the end of the planned 40-years lifetime has not been undertaken. It is not sufficient to limit the EIA on changes in the environment which have occurred since 2015.

According to the Espoo Convention’s 2020 Guidance on the applicability of the Convention to the lifetime extension of nuclear power plants changes in the environment can count as major changes in the meaning of the Espoo Convention.

It has to be assessed if such an increase in population density has to result in changes in emergency preparedness and response.

Russian aggression towards Ukrainian nuclear installations and safety

A few months ago, the European Environmental Bureau (EEB) together with Nuclear Transparency Watch (NTW) sent a joint letter – attached – to the European Commission and nuclear regulators calling to learn the lessons from the Russian aggression towards Ukrainian nuclear installations and carry out similar stress tests for all European nuclear installations as were carried out after the nuclear catastrophe in Fukushima.

Acknowledging the relevance of this issue, the letter has finally been included on the agenda of this week’s ENSREG meeting.

Attacks on the Zaporizhzhia nuclear power plant and the Nord Stream II gas pipeline are a stark reminder of the risk posed by energy infrastructure on EU citizens and the environment in times of military conflict. If the Commission and ENSREG decide to co-ordinate a series of stress tests on nuclear power plants, all installations shall be upgraded to include the lessons learned or shut down accordingly.

More information:
Jan Haverkamp, senior nuclear expert and vice-chair of Nuclear Transparency Watch –
jan.haverkamp@greenpeace.org
+31 6 21334619

20220519 Letter post-Ukraine nuclear stress tests NTW EEB
See also: https://www.nuclear-transparency-watch.eu/non-classe/open-letter-from-ntw-eeb-calling-for-reviewed-stress-tests-after-the-attacks-on-ukrainian-npp.html

Open letter from NTW & EEB calling for reviewed stress tests after the attacks on Ukrainian NPP

20220519 Letter post-Ukraine nuclear stress tests NTW EEB

Last Month, the 19th May 2022, Nuclear Transparency Watch jointly with the European Environnemental Bureau wrote an open letter (here attached) to the European Commission and to ENSREG to point out the need for a stress test on safety related issues during nuclear security events, including acts of war.

As the ENSREG conference is taking place today, 20th June 2022, NTW wants to underline again the importance of this issue while some diversion could very well make it forget while last week again the news showed how crucial it was.

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