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The ASN guidelines regulating protection against flooding are outdated for a possible extension[1].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