Options for EU Treaty Change in the Energy Field.
The conference underscored the need to give renewables a favourable treatment in the EU Treaties, similar to the one granted to nuclear power in the Euratom Treaty.
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.
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 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.
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.
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.
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”.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Jan Haverkamp, senior nuclear expert and vice-chair of Nuclear Transparency Watch –
+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
NTW introduced its first Open Radiation project started in Cumbria thanks to its member Colin Wales from Cumbria Trust for the Open Radiation Community on Friday 8th April 2022 at IRSN in France.
The presentation is available here after:
On 23 March 2022 Nuclear Transparency Watch hold a webinar on Rolling Stewardship with the following speakers and program:
Being engaged in the field of Radioactive Waste Management with a particular focus regarding transparency on nuclear safety and radiation protection, Nuclear Transparency Watch took part as Civil Society participant in the EC EURAD Research Programme in
June 2019. This participation, understood in the perspective of the Aarhus Convention, implied some involvement in several research projects that are, for two of them, designed on a strategical perspective opening to a more comprehensive understanding of socio-technical aspects of Radioactive Waste Management. In this context, it was felt that NTW would take advantage to develop its own thinking on Rolling Stewardship while liaising with interested partners of EURAD. A specific cooperation with the SITEX network (gathering Technical Support Organizations of Regulators of RWM and Civil Society Experts in the field) is also considered.
First speaker: Niels Henrik Hooge
Master of Laws and Master of Arts in Philosophy. Interested in environmental and sustainability for a long time he has manifested itself in activism, cooperation with green NGOs in Denmark and abroad, as well as in many types of writing. In addition to editorial staff work in Danish environmental magazines, he has published several books, including most recently the novel “Kosova” (2016) and the poetry collections “Grøn nation” (Green Nation, 2015), “Miljødigte” (Environmental Poems, 2018) and “Miljødigte 2” (Environmental Poems 2, 2019).
Second speaker: Gordon Edwards
Ph.D. in Mathematics and Master of Arts in English Literature. Gordon Edwards has been a Professor of Mathematics and Science during all his career during which he did many publications in that field but not only. From 1970 to 1974, he was the editor of Survival magazine. In 1975 he co-founded the Canadian Coalition for Nuclear Responsibility and has been its president since 1978. Edwards has worked widely as a consultant on nuclear issues and has been qualified as a nuclear expert by courts in Canada and elsewhere.
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 :
The European Commission answered to NTW’s request for public participation before decision in the European Taxonomy process regarding the inclusion of nuclear (and gas) in it.
Reply to public participation
for Greenpeace and WISE International
1. Deep geological disposal of high-level waste does not fulfil the DNSH criterion
In order to circumvent the DNSH criterion, the EC has followed the further not justified conclusions from
the JRC that deep geological disposal would be a solution for the high-level and long-lived radioactive waste
fractions in the nuclear fuel chain. There is no consensus that deep geological disposal is practicable and
there is, not even in Finland, any deep geological disposal currently in operation that has a proven safety
case. There is furthermore definitely no scientific consensus about the fact that deep geological disposal
resolves all intergenerational problems around radioactive waste. Examples of this include the need for
retrievability of the waste (in case better solutions are found or problems in the disposal occur – see for
instance the recent problems in the low- and mid-level waste storages in Asse II and Morsleben in Germany),
the need for passing crucial information to future generations, the need for security overview for future
generations, the need for monitoring for future generations. The JRC report completely ignores these issues,
but the conclusions is very clear: deep geological disposal does not resolve the DNSH problem.
2. Also when deep geological disposals are available in 2050, high-level radioactive waste will
remain a multi-generational operational problem
Besides the issues mentioned above, when a geological disposal will come available for operation before
2050, it still will be 60 to 80 years in operation before it is filled, backfilled and closed. That means that in
that case two to three generations will be burdened with operational work and economic burdens from
decisions made in the current decade. This period will have to be prolonged, if it is decided that retrievability
needs to be secured for a longer period.
3. There are in the DA no clear criteria about the quality of a deep geological disposals
The Taxonomy is to promote sustainable, green financing. The currently operated criteria for radioactive
waste in the Euratom directive 2011/70/EURATOM on radioactive waste are not specific about to which
quality standards a deep geological disposal has to adhere. This is at the moment mainly organised in
national legislation of the few countries that are attempting to create a deep geological disposal: Finland,
In order to secure that the criterion of an operational deep geological disposal in 2050 indeed fits in a
Taxonomy for sustainable financing, the DA would have to contain minimal criteria for the quality of
such a deep geological disposal site, including criteria on long-term safety, security, retrievability of
deposed materials, status and preservation of information in strict adherence to the DNSH criterion.
These criteria are currently missing.
4. There are in the DA no clear criteria about the quality of the plans with detailed steps to
have in operation, by 2050, a disposal facility for high-level radioactive waste
In the current formulation, such a plan could consist of three lines. That is, of course, not what the
Commission has in mind. In order to fulfil the DNSH criterion, such plans should be of such quality that they
more or less guarantee that a high quality, safe deep geological disposal site is in operation in 2050.
Therefore, the DA should contain concrete criteria for these plans – and timelines – in order to minimise the
chance that such deep geological disposals will not be of sufficient quality and not in operation in 2050.
These criteria should include issues like transparency, public participation, engineering quality criteria,
criteria on BAT (Best Available Technology), criteria on BRP (Best Regulatory Practice) and checkpoints
during the timeline where the Commission can conclude whether these criteria are met, and if not, withdraw
the project from approval under the Taxonomy. In order to fulfil the spirit of the Taxonomy on Sustainable
Finance, such criteria should go beyond Business as Usual criteria as set out in 2011/70/EURATOM and
5. The DA is not technology neutral: like with gas, the use of finance for nuclear should also be
part of a clear energy development plan consistent with 1.5° C
In the gas-part of the DA, criteria are introduced to basically guarantee that use of gas as an intermediate
source of energy has to be in line with a pathway keeping within Paris goals of 1.5° C. This includes an
obligation that the gas facilities need to replace existing facilities on solid or liquid fossil fuels and the
obligation for the Member State to have committed to a phase-out of the use of energy generation from coal.
For nuclear energy, similar criteria should be developed and incorporated that secure a pathway in line with
the Paris goals of 1.5° C. The use of nuclear power should not unnecessary delay phase-out of fossil fuels,
especially solid and liquid ones – nor by diversion of capital, nor by timely delay waiting for the introduction
of nuclear capacity.
6. The DA locks in fossil fuel use beyond 2050
The criterion that a construction permit has to be issued by 2045 de facto means that the DA allows the
construction of nuclear capacity that will not be able to replace solid or liquid or gaseous fossil fuels before
2050, ergo will allow for fossil fuel use to beyond 2050. This is not in line with the EU’s goal of full
decarbonisation in 2050. It has to be assumed that the construction time of a nuclear power plant is at least a
decade, which means that when the Commission is foreseeing use of coal or oil until 2045, only nuclear
power plants with a construction license before 2035 will be able to replace coal or oil – if the Commission
wishes a reduction of coal and oil in the electricity sector before that date, also the limit for when a
construction permit must be granted has to be moved forward, with at least a decade of space for
7. Stricter criteria for export of radioactive waste
In a Taxonomy for Sustainable Finance, practices that carry the risk that material is exported outside the
Union ending up as waste have to be excluded. Therefore the criteria for export of nuclear material labelled
as resource have to exclude such exports in which there is the slightest chance that it will not be fully used as
resource and may result in (partially or full) waste dumping in third countries.
8. Emergency preparedness and response to severe nuclear accidents is insufficient. There
need to be criteria that secure emergency preparedness and response is sufficient to meet
severe (INES 7) accident challenges
The post-Fukushima nuclear stress tests carried out in the EU did not include emergency preparedness and
response. The European Commission has tried to start up a debate about the issue, but it has not resulted in a
systematic improvement of emergency preparedness and response concerning severe (INES 7) nuclear
accidents anywhere in the Union. It needs to be kept in mind that the severity of these accidents (with
potential damage in excess of 400 Bln€) is far larger than the potential damage of any accident with the
technologies currently covered by the Taxonomy. If nuclear is accepted for financing towards the climate
targets set out by the EU, any gap in emergency preparedness and response needs to be filled to prevent
backlashes in case one or more severe accidents would happen on the territory of the Union.
9. IAEA and WENRA standards are voluntary – they need to be made compulsory in the
The IAEA and WENRA safety guidelines are detail guidelines to improve safety of nuclear power plants.
They are, however, not obligatory, but only advisory guidelines with no compliance mechanism to secure
their adherence. Some Member States have included the WENRA guidelines as compulsory in their national
legislation. For inclusion in the Taxonomy, adherence to the IAEA and WENRA guidelines should be more
clearly compulsory in the DA criteria, including compliance mechanisms.
A delegated regulation from the European Union on the ‘Taxonomy’ related to nuclear & gas leaked very recently
(cf. Germany hits out at Brussels plan to label nuclear and gas ‘green’ – POLITICO & LEAK: EU drafts plan to label gas and nuclear investments as green – EURACTIV.com).
Nuclear Transparency Watch has decided to publish it as well in the name of Transparency:
After the open letter sent by Nuclear Transparency Watch the 20th of July 2021 in the context of the debates around Nuclear Energy and European Taxonomy – see article – an answer was given on the 29th of November by the European Commission – here – that was not answering how and when this Public Participation will take place.
Therefore, Nuclear Transparency Watch asked the Commission in a CONFIRMATORY REQUEST on the 30th of November under the
EU Aarhus Regulation 1367/2006/EC reminding its obligation regarding it.
In addition to the previous article on the subject and aside all the political statements made on this issue, Nuclear Transparency Watch produced a cross-cutting analysis of different reviews made of the JRC report. This document can help understand how the scientific basis used by the European Commission is not going without any criticism.