On the front

Is Belgium able to extend its Doel 1 & 2 reactors?

10 December 2015

On 30 November 2015, an agreement between Electrabel and the Federal Government was reached to extend by 10 years the nuclear reactors Doel 1 & 2 lifetime. But this decision breaks international rules for transparency and safety. Lifetime extension of power plants must take into account a high level of safety measures to protect the population, but also the environment. The right of the public to participate in an environmental impact assessment should be respected.

A denial of international obligations for transparency
To extend the lifetime of Doel 1 & 2 reactors, Belgium must carry out an environmental impact assessment (EIA) and a national and transboundary public participation, as prescribed by Aarhus and Espoo conventions that apply notably to all member countries of the European Union. In May 2015[1], NTW had contacted the Belgian energy minister Christine Marghem to emphasize the importance of respecting international obligations to organize large-scale EIA and a process of cross-border public participation before any final decision. But it seems that the minister, who has still not responded, has no knowledge of international standards of transparency.
These international obligations are essential for safety. Doel 1 & 2 have been designed on the knowledge and technology of the 1970s. The last past years, the understanding of accident scenarios and nuclear technology have evolved, but also the environment of the nuclear reactors and the society as a whole have changed drastically. Therefore, a decision to extend the lifetime of nuclear reactors should automatically involves a comprehensive and transparent environmental impact assessment and public participation process for Belgian citizens, but also Dutch citizens.
NTW strongly supports the complaint filed by Greenpeace Belgium on 30 November with the Council of State to challenge the decisions of the government and the Federal Agency for Nuclear Control (FANC) for approving the 10-year extension of Doel 1 and 2. NTW also welcomes the complaint filled by Benegora[2], a Dutch environmental organisation, with the Belgian State Court, because Dutch border municipalities and their citizens are not able to participate in a cross-border public participation and environmental impact assessment process. Meanwhile, the Dutch Province of Zeeland has also passed a motion in which they call upon the Belgian authorities to allow the citizens of Zeeland to participate in a consultation process concerning the lifetime extension of Doel1&2.

A flawed decision from a safety perspective
Questions in terms of safety arise in case of lifetime extension of nuclear plants designed initially for a period of 30 years. The FANC speaks of “the safest reactors in Belgium”, but are the highest-level safety criteria applied? Are preparedness and response measures to emergency situations suitable for this extension?
This issue is very important for the Doel nuclear power plant, which is the plant installed in most populous region in Europe. Considering a radius of 30 km, the population around the Doel plant (1,510,000) turns out to be 9 times greater than the population who lived around Fukushima, at the time of the accident (172,000 residents). In addition, a serious nuclear accident in Belgium will certainly have repercussions beyond its borders. The Netherlands is situated a less than 3 km from the Doel plant.
An example of EP&R failure is the issue of receptions places in case of a large-scale evacuation, which is not sufficiently studied by the Belgian authorities. Of the four planned reception centers in the preceding Antwerp emergency plan for the Doel plant (the Sports Palace, the civil protection in Brasschaat, the slaughterhouse of Antwerp and Haasdonk’s Fort), the last two are completely dilapidated buildings[3]. For the new response and emergency plan of the province of Antwerp, there is only one reception center that is mentioned: Campus Vesta in Ranst, whose capacity is not indicated. Providing a single reception center, for a nuclear plant in a densely populated area, is not consistent.
Lifetime extension of power plants must take into account a high level of safety measures to protect the population, but also the environment. It is high time that EP&R measures take into account the lessons learned from the Fukushima disaster. The environment around Doel has fundamentally changed over the last 30 years and the risk of reactors failure increases exponentially over time. Ten years of extra life adds 25% additional time in which these reactors are exposed to various risks.

The challenges of decommissioning
Extending the lifetime of Doel 1 &2 has halted preparations for decommissioning. An amount of € 24.7 million has already been spent for the preparation of Doel 1 & 2 decommissioning[4]. Indeed, as the nuclear phase-out law passed in 2003 provided the closure of Doel 1 and 2 plants for 2015, Synatom, branch of Electrabel specializing in the management of radioactive materials, had already begun preparing decommissioning for an amount of 24.7 million, when the parliament was finally given the green light last June to the extension. Will the results of this study be still valid in 10 years?

[1]https://www.nuclear-transparency-watch.eu/activities/nuclear-power-plants-ageing/nuclear-transparency-watch-warns-belgian-minister-to-respect-transparency-laws-in-lifetime-extension-of-doel-1-2-nuclear-power-reactors.html
[2]http://www.benegora.nl/28-levensduurverlening-doel-1-2
[3]Study commissioned by Greenpeace Belgium, “Insuffisances des plans d’urgence nucléaire belges :les leçons de la catastrophe de Fukushima n’ont pas été tirées”, David Boilley et Mylène Josset, Janvier 2015. http://www.greenpeace.org/belgium/Global/belgium/report/2015/RapportDavidBoilleyFR.pdf
[4] Response of the Energy Minister Marie-Christine Marghem to a written parliamentary question posed by the Member Jean-Marc Nollet

Overview of the EIA procedure for the Paks II nuclear project in Hungary

10 December 2015

The Paks Nuclear Power Plant is located on the right bank on the Danube, approximately 100 km south of Budapest. A new project with two reactor units from Rosatom (VVER1200) is planned as an addition to the existing four-block nuclear power plant, Paks-1 that currently generates some 40% of the Hungarian energy production.
The environmental impact assessment (EIA) procedure for this project is currently being conducted. It’s made under Hungarian law, implementing the Espoo Convention (the Convention on Environmental Impact Assessment in a Transboundary Context), the EU EIA Directive (Directive 2011/92/EU on the assessment of the effects of certain public and private projects on the environment) and the Aarhus Convention (the Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters).

THE EIA REPORT
In April 2015, Hungary submitted the EIA Report for the transboundary EIA procedure. This EIA Report was prepared in order to identify and evaluate the impact of the planned nuclear power plant technology on the environment. The study was prepared by the project company MVM Paks II Ltd[1], which has submitted its application for the development consent together with the EIA documentation to the competent Hungarian authority, South Transdanubian Regional Inspectorate for Environment and Nature. Today, The Paks EIA process belongs to the Baranya County Government Office.
A few months after the official documents for the EIA procedure have been published, Benedek Jávor, Member of the European Parliament and of NTW, obtained secret documents. On our website[2], he declared that the MVM documents contain fundamental mistakes. The grid integration was not modelled as would have been necessary. The construction was not budgeted and planned, as would be needed at this stage of implementation. The analysis completely ignored external factors like the application of the EU competition law. The thermal pollution of the Danube caused by the cooling water was miscalculated.

To better analyse the EIA report, several expert assessments have been published:

Download: Expert statement on the Environmental Impact Study (EIS) of the PAKS II NPP
by Oda Becker, commissioned by Greenpeace Germany, October 2015.
The independent nuclear expert Oda Becker was commissioned by Greenpeace Germany to prepare an Expert Statement on the EIA report. The objective of the assessment was to investigate whether the information presented in this study is reliable and sufficient to determine the potential risks for other countries, in particular Germany. This expert evaluation comes to the following conclusion: “The content of the EIS was found to not to be in line with the EIA Directive general requirements and IAEA specific recommendations. Much additional information is necessary to assess the possible consequences of the Paks II for Germany. However, the information at hand indicates that a severe accident with a major release and consequences for Germany cannot excluded.”

Download: summary of Expert analysis on the environmental impact assessment documentation (EIAD)
by experts commissioned by Benedek Javor, Member of the European Parliament and NTW, November 2015.
The conclusions of the expert analysis reveal that the EIAD is extremely low-quality; it is based on false data and false assumptions and has very little to do with reality.
Zsuzsanna Koritár, expert of Energiaklub and member of NTW, also pointed out the main deficiencies of the EIS, such as the unresolved problem of radioactive waste and spent nuclear fuel, the inadequate analyses regarding nuclear safety, the heating problems, as well as the lack of alternative energy scenarios.

PUBLIC HEARINGS
On 7 May 2015, public hearings were held in Hungary, Paks and in Autumn 2015 all over Europe (Germany, Ukraine and Austria).

Find feedbacks from NGO representatives:

Public hearing in Paks, Hungary
According to Jan Haverkamp, the Paks hearing did not fulfill EIA and Aarhus specification, some of the reasons being the restrictions for participation of citizens and NGOs and the fact that only short questions were allowed during the hearings.
Download: Comments on the environmental impact assessment implementation of new nuclear power plant units at the paks site made by MVM Paks II
By Ir. Jan Haverkamp, expert consultant on nuclear energy and energy policy for Greenpeace in central and eastern Europe, qualified member of NTW
+ Addendum

Public hearing in Vienna, Austria
On 23rd September 2015, a public hearing for the planned new reactors in Paks was held in Vienna, with 65 attended people opposing a podium of 20 hungarians delegates. The deadline for public participation for Austria has to be prolonged, as 7 additional official documents were published on the MVM website, without have been officially submitted to Austria. Therefore the public was not aware of their existence while participating in the hearing.
Download: Summary of the public hearing in Vienna, transboundary environmental impact assessment NPP Paks II
By Gabriele Mraz, Austrian institute of ecology, member of NTW, September 2015.

Public hearing in Munich, Germany
The public hearing for Germany was held in Munich on 20 and 21 October 2015.
According to Brigitte Artmann, member of NTW, “this public hearing didn’t answer to every raised question, questions still remain open. Further serious questions about the lack of rescue staff in the emergency case were raised. Moreover, 30.000 submissions from Germany demand that German public concerns must be included into the EIA procedure without discrimination. Hungarians will get technical information of the chosen reactor and another hearing with documents in Hungarian language. German NGOs demand the same for Germany.”
Download: Summary of the public hearing in Munich, transboundary environmental impact assessment NPP Paks
By Brigitte Artmann, Greens Fichtelgebirge, member of NTW, October 2015.

Oda Becker commented also that: “On the basis of the known factors and the formally issued, more than 2,000-page environmental impact study, the biggest problem with Paks-2 is that serious accidents involving large quantities of radioactive material emissions cannot be ruled out. From the received reactions of the Hungarian delegation, the picture emerges that they believe that if something is highly unlikely, then it doesn’t have to be, because it “cannot happen”. This is not a modern, not a responsible way of thinking.”

THREE PROCEDURES LAUNCHED BY THE EUROPEAN COMMISSION
End of November 2015, the European Commission announced the launch of three procedures about the new nuclear power plant in Paks. First, an infringement procedure was launched by the Internal Market Commissioner on the violation of EU public procurement rules. Secondly, the DG Environment decided to further examine the classification of information contained in the Paks documents, as they might violate rules concerning the publicity of environmental information. And lastly, Margrethe Vestager, the Commissioner in charge of competition, drew the conclusion following her preliminary investigation that state aids by the Hungarian government cannot be excluded despite the contrary claims of the government. Therefore, she wishes to have a more thorough investigation on the question.

[1]http://www.mvmpaks2.hu/hu/Dokumentumtarolo/International%20chapter.pdf
[2]https://www.nuclear-transparency-watch.eu/a-la-une/recent-developments-on-paks2.html

How might climate change affect nuclear safety?

7 December 2015

CLIMATE CHANGE – NUCLEAR SAFETY

Nuclear power plants already faces issues that may be related to climate change: floods, heat waves, storms, invasion of jellyfish and seaweed, rising sea levels, etc. With global warming, some of these natural events may be more severe. Is the nuclear fleet ready to face those threats?

Nuclear power plants must be prepared to resist particular climatic hazards. Events like floods or heat waves can have a serious impact on their cooling system. Flooding is one of the major risks to which nuclear power plants must be prepared. To cool their reactors, these facilities use large amounts of water, 40 cubic meters per second and per reactor, which necessarily places them close to a river or the sea. This water dependence puts them at other risks: lack of available river water, blockage of access to cooling water by plant debris, jellyfish or sea weed bloom in the filter grids.

STORM SURGES
Safety checks following the Fukushima disaster in Japan in March 2011, when a 10 meter-high sea wall was overtopped by a tsunami, have shown that nuclear plants are at greater risk of catastrophic flooding as a result of climate change. Nuclear plants can be flooded and it happened several times.
In Bordeaux, on 27 December 1999, the Martin storm has made reached the seawater beyond the dikes oh the Blayais nuclear plant and the water has crept in utility tunnels. The reactors were immediately shut down by EDF, but the damage was done: electrical systems had to be shut down, including two of the four cooling circuits of reactor 1. As the plant still had electricity, pumping operations were started quickly, preventing a major accident. These operations lasted for weeks. The incident was rated level 2 on the INES scale[1].
In Britain, after discovering in May 2013 that one of their reactors at Dungeness would be at risk of inundation by seawater during a storm, the owners, EDF Energy, quietly shut it down. Dungeness is built on a shingle beach beside the English Channel. The company informed the Office for Nuclear Regulation that it was being shut down as a precaution. The reactor remained off-line five months in 2013 while a new sea wall was constructed.

HEAVY RAIN – SEA LEVEL RISE
Changes in rainfall regime may impact the behavior of cooling water supplies (rivers, streams, groundwater) and transmission lines. A change in the rain regime can in the long term change the bearing capacity of the underground. Even if the principal facilities (e.g. reactors) might not be concerned, related structures, piping and cabling can be.
Moreover, predicted increases in sea level may cause inundation of some sites. Many existing nuclear power stations are located on coastal sites because of the need for an isolated location with a plentiful supply of cooling water. Many are built at very low elevations, and are consequently highly vulnerable to the rising sea levels which global warming is expected to bring.This will be particularly true in the southeast of England[2].

HEAT WAVES
Nuclear power may face difficulties in working because of the heat. A rise in temperature may affect the performance of the cooling systems. During the brutal heat wave in 2003, a quarter of French reactors had to be shut down. Normally, the cooling system pumps water, uses it to cool the reactors and then rejects the heated water into the environment. But in case of a heat wave, cooling waters are collected in smaller quantities, they come out of the plant warmer than usual, with the possibility of damage to the flora and fauna. Each nuclear plant has standards for the tolerated heating of the water, which is of the order of one to several degrees. During the heat wave of 2003, EDF had obtained derogations to reject abnormally warm water in rivers. The proposed new nuclear power station in Paks is supposed to reduce capacity when cooling water emission temperature limits are reached. When this happens more frequently, this will influence the economic performance of the reactor.
In the face of climate change, heat peaks will still force to reduce nuclear power performance or to dump too hot water in natural environments. In France, over the last thirty years, the frequency and intensity of heat waves has increased. And that’s not all, since there are three in four chance that the number of days of heat waves will increase to 5 to 10 days in the southeast of France in the twenty-first century[3].

JELLYFISH AND SEAWEED BLOOM
Power plants in Europe do get closed down due to cooling water intake problems. Large amounts of jellyfish and seaweed more frequently block the cooling water inflows of nuclear reactors. In recent decades[4], dozens of cases were observed where jellyfish and seaweed caused the partial or complete shut down of coastal nuclear plants. In 2011, for example, in Scotland, two of the Torness reactors had to be shut down in the space of one week, when the seawater, used as a coolant, has been invaded by jellyfish. In France, the small ‘rose-de-mer’ jellyfish closed the Paluel nuclear plant, and in Sweden in the USA, plants have been closed down with massive influxes of larger umbrella- type jellyfish. Jellyfish are abundant in Europe coastal waters through the summer months and warmer conditions (often attributed to ‘global warming’) and exacerbate this risk.
To explain this phenomenon, there is a climate-related mechanism: it could be a combination of elevated temperatures in the oceans and some environmental changes, such as overfishing and ocean acidification. It could be that the rising acidity of the oceans – related to the increased level of carbon dioxide in the water- reduces the number of sea- shell animals (that need lots of calcium) but do not touch the jellyfish. In this new non-competition environment, jellyfish could take the opportunity to multiply.

Conclusion
All nuclear plants need large quantities of water for cooling so all must be built close to the sea, large rivers or lakes. This makes them vulnerable to sea level rise, storm surges and to the possible collapse of large dams upstream from poor construction, floodwater or seismic activity.
The vulnerability of power plants to risks of flooding and overwhelming heat raises the question of cooling systems of the nuclear reactors. Besides the issue of seismic risk and probability of flooding, it is important to ask how long time of autonomy have nuclear power plants to ensure cooling a reactor if it ever stops completely?
Since nuclear plants are designed to operate for as long as 60 years and need around a further century to decommission, accelerating sea level rise and more intense rainfall may present serious problems. The risk of a serious nuclear accident remains always above zero as a result of unexpected phenomena from climate change.

[1]Rapport sur l’inondation du site du Blayais survenue le 27 décembre 1999, Institute for Nuclear Protection and Safety (IRSN), 2000. http://www.irsn.fr/FR/expertise/rapports_expertise/Documents/surete/rapport_sur_l_inondation_du_site_du_blayais.pdf

[2]Greenpeace Study, “The impacts of climate change on nuclear power stations sites”, 2007. http://www.greenpeace.org.uk/files/pdfs/nuclear/8176.pdf

[3] Report lead by Jean Jouzel, “Le climat de la France au 21è siècle”, volume 4, 2014. http://www.developpement-durable.gouv.fr/Le-climat-de-la-France-au-21e.html

[4] British Environment Agency, “Cooling Water Options for the New Generation of Nuclear Power Stations in the UK”, 2010. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/291077/scho0610bsot-e-e.pdf

NTW supports the RICOMET’s appeal

29 October 2015

NTW supports the RICOMET’s appeal to address social, ethical and participatory dimensions in the nuclear field

NTW supports the RICOMET’s appeal “Appeal to implement Responsible Research and Innovation in Euratom nuclear research, development and activities”.During core scientific and nuclear research and development, NTW highly recommends the incorporation of activities to broaden the social, participatory and ethical dimensions.

The relationships between technology and society should evolve
Nuclear power is far from being solely a technical subject. In the debates and discussions around nuclear power development, there is considerable attention to technical questions such as design and cost, but attention is also needed to social issues such as safety, justice, public perception, risk assessment, ethics, political acceptability, and public accountability.

Addressing social, ethical and participatory aspects is a lesson learned from Fukushima
The Fukushima catastrophe has profoundly altered the nuclear debate, as did the accidents at Three Miles Island and Chernobyl. In the 30 years between Three Miles Island and Fukushima, nuclear technology itself has not fundamentally evolved, but the way societies approach it has changed. Today, faced with risks of nuclear energy and waste management uncertainties, nuclear operations have to be reframed along the lines of transparency, governance and public participatory.

We need social sciences to understand the nuclear world
We feel that the ethical and societal dimensions of nuclear technologies and applications are of high importance and need to be strengthened. Nuclear risk, for example, has been a specific focus point, studied from the standpoint of accidents and their consequences on popular perceptions of risk. We need associations, unions and collectives in framing national and local debates on nuclear policy and sites.

The inconstancy of legislators and governments
Social science research is needed and even often requested by legislators and governments. But a difficulty is the scarcity of funding for social sciences in nuclear research. For example, social sciences and humanities deserve a more prominent place in Horizon 2020 Euratom projects. They should have an equal place to technical and industrial research, which are highly supported by EU funds and by different national funds especially established for their purpose (like radioactive waste management funds, decommissioning funds, special resources devoted to finance public institutes, etc.). In order to fulfill the full range of targets identified, it is important that the upcoming Euratom Horizon 2020 calls ensure the continuity of a forum for different stakeholders and include social, governance and transparency topics to the extend necessary.

NTW supports RICOMET’s position and calls the European Commission to take actions now rather than wait for the next nuclear crisis.

What is Energoatom celebrating today? The suppression of public debate on Ukrainian nuclear plans?

29 October 2015

While Energoatom has his press conference “̈Powering Ukraine: Steps towards EU-Ukraine Energy Integration in 2015” today (October 29) in Brussels, a Kiev court is ruling in the defamation case against the Ukrainian NGO NECU. The lawsuit was filed earlier this summer by the state-owned nuclear power plant operator Energoatom, and it was later joined by the governmental nuclear watchdog (SNRIU). Bankwatch has been warning against the risk of the prolonged operation of Ukraine’s Soviet-era nuclear power plants beyond their design lifetime. Details are available in Bankwatch August 28 press release.

In December, Ukraine’s nuclear regulator will be deciding on lifetime extensions for two reactors – one of them located about 250 km from the frontlines of the conflict in the east of the country. In the meantime, the EBRD and Euratom are still financing the so-called safety upgrades in these units, despite a letter from 27 MEPs calling on them to suspend the loans until Ukraine complies with its legal obligation (under the Espoo and Aarhus conventions) to consult citizens in neighbouring countries who could be affected by this project.

It seems that Kiev is quite consistent in suppressing public debate on its nuclear plans both at home and abroad.

PARTICIPATION OF CIVIL SOCIETY IS ESSENTIAL

20 July 2015

10^th EUROPEAN NUCLEAR ENERGY FORUM, PRAGUE – MINUTES FROM OUR CHAIR

NTW is concerned about the reduction of ENEF to a single-interest group of industry experts

On 26-27 May 2015, the 10th European Nuclear Energy Forum (ENEF) meeting took place in Prague. ENEF was created in November 2007. It was initiated by the March 2007 European Council, when Member States suggested “that broad discussion should take place among all relevant stakeholders on the opportunities and risks of nuclear energy.” But difficulty was encountered in bringing all the key actors together. Indeed, civil society wasn’t always consulted as required. Since the beginning of ENEF, over 50% of the participants are from the industry and only two NGOs were initially invited. The rest of the participants are European Commission and national government representatives.

During the last five years, this restriction has affected the quality of debate and the credibility of ENEF as a place for discussion among all stakeholders. ENEF is facing challenges to be taken seriously and to shed its image as a pro-nuclear industry forum. ENEF is promoting nuclear energy while there are many related issues to consider: transparency, emergency preparedness and response, radioactive waste, ageing reactors, etc. At the 5^th plenary session of ENEF, all NGOs and nuclear-critical members of the European Parliament decided to leave the Forum. This was due to the lack of taking into consideration of civil society’s views in the Forum. Although NGOs got a lot of interesting information and networking opportunities, and got their voices heard by people who normally are not confronted in this way, inputs from NGOs were structurally marginalised. NGOs inputs were not reflected on their merits in papers produced by ENEF working groups, in conclusions from ENEF meetings and in the media coverage.

The conditions for participation of civil society

This year, Michèle Rivasi, President of NTW, was invited as a speaker for the 10^th plenary of ENEF. This invitation shows a willingness to open dialogue with civil society and to debate the future of nuclear energy without taboos. For this, it is necessary to allow a broad participation of civil society: elected officials, academics, NGOs and citizens. NTW, alone, cannot fully represent all these fundamental actors. It is NTW’s strong view that it is essential that more actors from civil society are involved at all levels in ENEF operations and that for NTW to continue to participate a restructuring on this basis is required:

1) It is essential to clarify the objectives of ENEF.
There is a lack of transparency and clarity about the Forum’s objectives: What are the objectives? Is it about promoting nuclear or about creating the conditions for a proper application of EU legislation to the nuclear sector? NTW is not established to promote or eject nuclear energy, but rather to promote quality and transparency of EU decision-making processes and thereby increase safety in nuclear matters.

2) Furthermore, it is necessary to clarify the rules concerning the governance of ENEF.
The Forum is still very opaque: How are agendas fixed? Who chooses the stakeholders and ensures plurality? Who appoints the moderators of ENEF meetings and working groups? How are the conclusions and decisions of the meetings made, and communicated? For NTW, a fair balance of power for communication with the media is essential. It is necessary to introduce transparency and to include civil society representatives in the Forum’s governance bodies, which need to be pluralistic. Civil society representatives should be included – on the same terms as all the other stakeholders – at all levels of the ENEF structure and be entitled to participate in the organization, agenda-setting, conclusions and communications of ENEF.

3) Finally, it is necessary to create conditions for effective participation of civil society.
It isn’t right that representatives of civil society must fund their travel and do not have access to translations. It is necessary to release resources to finance participatory and equitable governance.

These conditions are necessary to ensure that ENEF stays within its original mandate: to be a platform for discussion on the future of nuclear power, without taboos and open to ALL players. It is the only way for ENEF to play a credible role in shaping EU energy policy towards more sustainability.

Numerous examples demonstrate that such participation is possible

The approach adopted by NTW to organize round tables in the Emergency Preparedness and Response (EP&R) field is one example. It helps to mobilize civil society and the authorities together and to put on the agenda an update of EP&R arrangements. For example in Ukraine, organizing a roundtable on post-accident emergency has gathered scientists, representatives of Energoatom, the Minister of Health and NGOs around the same table.

Another example of the effectiveness of public participation is France where participation is based on local information committees (CLIs). The CLIs guarantee access to information and participation of stakeholders such as elected officials, NGOs and trade unions in discussions with operators and regulators. During the stress test process, the public via the CLIs could speak before the release of the French nuclear safety authority report (2012). Proposals and recommendations were supported by civil society. This participation has led to an investment of 10 billion euro in safety.

Moreover, these same CLIs are launching working groups on decommissioning and are themselves very pleasantly surprised by the interest of the public on this issue. Concerns vary from one territory to another. Some local actors are interested in safety, environment, waste, issues related to decommissioning, others are focusing on economic and social transition, what decommissioning generates. The local character of these issues has to be taken into account and could be easily supported by civil society.

Whatever the field, better debates and decision-making require broad participation. This participation is highly essential today for the European institutions given the growing distrust of the people toward Europe. On the issues of nuclear safety, civil society and local representatives have a fundamental legitimacy and right to participate in the debate.

As demonstrated during all nuclear accidents with consequences outside of the fence, ordinary citizens take in the end a large part of the burden of the consequences of safety flaws. “Civil society is indispensable to prevent political and economical reasons and short term industrial interests overshadowing the priority of safety.”

Michèle Rivasi, Chair of Nuclear transparency Watch

Recent developments on Paks2

20 July 2015

by Benedek Jávor

A new nuclear power plant with two blocks from Rosatom (VVER1200) is planned as an addition to the existing four-block nuclear power plant, Paks-1 that currently generates some 40% of the Hungarian energy production. According to the contract, Hungary signed with Russian Federation, the two reactors of the new plant will be operational by 2025 and will cost 12,5 billion EUR. 80% of the foreseeable capital cost is financed by an intergovernmental loan from Russia.

Although the Hungarian government states that everything is perfectly planned, the project is fiercely contested by experts, political stakeholders and the public both on the Hungarian and the European level. Some are infuriated by the lack of preliminary investigations, impact assessments, public consultation, lack of transparency and alternative scenarios and the centralization of the decision and the energy systems. From Europe, there are concerned voices due to lack of tendering, the obstacle the plant poses to restructure the Hungarian energy mix and to add renewables and also due to risk of corruption and illegal state aid. I organized a hearing together with Energiaklub and NTW on the issue in late March. You can find the summary here.

Since, I have been working on several issues related to the new nuclear power plant and I would like to share the latest developments:

STATE AID CASE

The NGO Energiaklub of Hungary submitted a complaint to the European Commission to start a non-notified state aid procedure in 2014. Recently Commissioner Vestager replied to our joint letter with Energiaklub and she states that the HU government formally notified the Paks 2 project to the Commission on 22/05/2015.The Hungarian government claims that financing Paks-2 is not a state aid, as they think the return of investment is more than favourable. The EC is currently waiting for further explanation from the Hungarian government and after receiving all the relevant data, the EC have 2 months to come up with its position.

Energiaklub has recently made an analysis, which claims exactly the opposite.

LEAKED PRELIMINARY DOCUMENTS FOR FEASIBILITY STUDY

Despite the fact that the District Court of Budapest ruled in a decision that Energiaklub could not have been given access to the preliminary and background docs for the new NPP as they did not exist according to the Hungarian government, I published a series of short documents that were given to me from the electricity management company MVM and from academia that indirectly prove the existence of the above mentioned documents and give also some insight to the weak points that have been raised by many people, some of whom are specifically connected to the International Atomic Energy Agency (IAEA).

The opinion from MVM states that there are elementary mistakes and out-dated data in the modelling and no appropriate modelling of the system integration. The grid integration is not modelled as needed. The work is not budgeted and planned, as would be needed at this stage of implementation. The documents affirm our hypothesis that the promoters do not actually know costs, they just have estimates. The costs are underestimated and exclude a series of additional investments needed for the operation of the NPP. External factors like the EU competition law are totally ignored in the analysis.

The first document from academia says that when Paks2 will operate with both blocks, it will be necessary to cut operation time for Paks 1. The document actually estimates that block 4 will be able to run for only 1000h/year, in other words 30-35% less production. It also states that a pumped storage facility will be needed for the grid system regulation and this has not been budgeted for.

The second is specifically about cooling water and highlights mistakes committed for the cold-water channel of Paks1. It states that the new NPP will cause serious nature protection problems and that excess heat will call for (partial) capacity reduction which will in itself hinder the 95% planned use of the new NPP and the financial prospective won’t be achieved. Furthermore, it is likely that nature protection standards are likely to rise in the coming 60 years and might lead to new situations like the one in the Rhône where drought threatens the cooling of nuclear plants.

The authenticity of the documents has been confirmed by both MVM and the Hungarian Academy of sciences.

PUBLIC HEARINGS ALL OVER EUROPE

Over the summer the international phase of the Environmental Impact assessment for Paks-2 is running and we expect public hearing in the concerned countries in the early autumn. So far dates for Germany (16/09), Ukraine (17/10) and Autria (23/09) have been fixed.

Benedek Jávor is a member of NTW and member of the European Parliament for Together – Dialogue for Hungary Alliance. He is first vice-chair of the Committee for Environment, Public Health and Food Safety and is a substitute member of the Committee of Industry, Research and Energy. Furthermore, Benedek is a founding member of the environmental NGO Védegylet (Protect the Future!) and holds a PhD. in biology.

THE FEDERAL NUCLEAR KINGDOM OF BELGIUM

20 July 2015

OR HOW TO UNDERMINE NUCLEAR TRANSPARENCY

When Belgium decided in 2003 that it wanted to change direction towards a clean energy future and phase out its nuclear fleet after 40 years of operation, it probably had not expected the mess it is currently facing. Or maybe it did. Politics in the kingdom can be messy.

Belgium followed France in building nuclear capacity when it noticed its coal mines could not be operated economically in the late 1960s. The oil crisis in the early 1970 further paved the way for a nuclear option. Seven reactors were built on two sites. Four of them in Doel, on the doorstep of the port town of Antwerp. The other three in Tihange on the Meuse river bank between Namur and Liège. But when the date of the first shut-downs was nearing, Belgium’s nuclear operators Electrabel / ENGIE and EdF together with their political fan-club indicated the government that switching off the oldest three reactors, Tihange 1, and Doel 1 and 2 in one year might lead to shortages on extreme winter days. Despite the existence of alternatives strategies, the Belgian government decided in 2013 to give Tihange 1 a life-time extension of another 10 years, while confirming the limited lifetime of 40 years for the others.

In the summer of 2012, two of the “newer” reactors, Tihange 2 and Doel 3, were found to have thousands of cracks in the form of hydrogen flakes in their reactor vessel. There was no documentation to explain this phenomenon and several tests remain inconclusive about the question whether these cracks have been there from the start or could have grown over time. As a result, both reactors are off-line and kept off-line until further investigations give more clarity.

Doel 1 and 2 were slated for closure in February 2015 and December 2015 respectively and Engie/Electrabel and the new pro-nuclear Belgian energy Minister Marie-Christine Marghem saw their chances. They saw non-availability of Tihange 2 and Doel 3 as a good excuse to grant also Doel 1 and 2 an extra life of 10 more years. Official reason was again a potential shortage in unprecedented cold periods in the coming winter.

For Tihange 1, a secret agreement was made in which Engie/Electrabel and EdF will have to give the state 70% of their windfall profits from this move. In return, the state guarantees that whatever happens politically, Engie/Electrabel and EdF will be able to run those reactors up to the final date in October 2025. If not, the state will pay them all lost profits. Of course, technical malperformance or radioactive risks can lead to a shutdown without payments. But whenever there is an accident elsewhere in the world and the Belgian government would like to follow Germany’s wise lead and shut down all reactors older than 32 years, this agreement could become very costly indeed. This political guarantee is the same trick that EdF also smuggled into its agreement with the British government for the construction of the Hinkley Point C power station. The people carry the financial risks for politicians that make choices involving nuclear risks. The Belgian government declared the whole agreement as confidential and thus opposed its publication. Even against the ruling of Belgium’s independent Commission on Access to Information, and against valid Belgian and European laws and the Aarhus Convention on access to environmental information, which give the public interest prevalence over limited commercial ones – apart from the fact that there is no real commercial information in this agreement anyway. A few courageous parliamentarians from the Greens then decided to quote the entire agreement in a resolution, and thus we were able to have a look at it.

One important thing that the government forgot is the fact that for a life-time extension also an environmental impact assessment (EIA) needs to be made under the same Aarhus Convention and the Espoo Convention on transboundary EIAs as well as European and Belgian law. If the Belgian minister would take into account this obligation, that could mean that Tihange 1 would not be able to operate until such an EIA would have been carried out – with Belgian and transboundary public participation, that can easily take a year. In this case, according to the terms of the agreement, the Belgian state has to pay the missed profits to Engie/Electrabel and EdF.

It explains why the Belgian government is fighting the legal obligation of an EIA with all means available, despite the legal opinions from the country’s highest legal institution, the Council of State. The legal advice that the Belgian government quotes comes from Engie/Electrabel and the Dutch nuclear lawyers office Stibbe. Those acknowledge the obligations, but give tips to the Belgian government to help it to escape its obligations.

In the Energy Union discussions, Belgium supports the European aim of having the safest nuclear fleet in the world. Everywhere it states that nuclear safety always will be priority number one. However, the recent developments give us serious concern that financial objectives may have predominance over safety objectives.

Tihange 1 and Doel 1 and 2 are already 40 years old, while their design lifetime was only 30 years. A recent study commissioned by Greenpeace [1] shows that they faced many issues in the EU stress tests and many others were conveniently moved under the carpet. Another [2] shows that they are situated next to large populations and their emergency preparedness and response provisions in case of large accidents are fully inadequate

Instead of continuing to flog these old horses to work, it is essential to respect transparency laws and to focus on nuclear safety. Belgium is not a Banana Kingdom.

[1] Critical Review of the Updated National Action Plans (NAcP) of the EU Stress Tests on Nuclear Power Plants, June 2015, Greenpeace

[2] David Boley’s study of the Belgian emergency and response situation , Janvier 2015, ACRO

OVERVIEW OF ISSUES AROUND BELGIAN NUCLEAR REACTORS

Belgium decided for a nuclear phase-out after 40 years of operation of its reactors in 2003. In 2013 it decided to grant Tihange 1 an extra 10 years to prevent generation shortages in case of extreme cold weather periods in the winters of 2015 / 2017.
The Belgian government made a secret agreement with operators Engie/Electrabel and EdF to cover the 10 years life-time extension. In this agreement, the nuclear operators receive a quasi profit guarantee, as well as the assurance that the life-time extension decision will not be reversed by another government.
In the summer of 2012, Electrabel discovered thousands of cracks in the reactor pressure vessels of the Tihange 2 and Doel 3 reactors. An initial assumption that these hydrogen flakes were caused during production and did not increase over time is still under debate. Currently the reactors are off-line, waiting more investigations, and it is not sure that they will ever restart.
In June 2015, with wired-up fears for generation shortages during extreme cold periods, the Belgian parliament passed a law granting also Doel 1 and 2 ten years life-time extension.
Few days after that decision, the Belgian grid operator published an assessment concluding that Belgium is well incorporated in the European electricity grid structure and has spare gas capacity available so there will be no risks for black-outs even in winter.
Under the Espoo Convention, the EU EIA Directive and Belgian law, an environmental impact assessment should be made for a nuclear plant life-time extension. The country’s highest legal body, the Council of State, confirmed this position in an advice to the Minister. Last April, NTW sent a letter 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. The Minister did not respond to NTW’s request, but continues to refuse an EIA on the basis of legal assessments from operator Electrabel and the Dutch nuclear lawyers firm Stibbe.

Ir. Jan Haverkamp (1959) is board member of Nuclear Transparency Watch and expert consultant on nuclear energy and energy strategy for Greenpeace Central and Eastern Europe and the World Information Service on Energy (WISE).

Speeches made by NTW’s members at the third ENSREG conference

10 July 2015

On 29-30 June 2015, the European Nuclear Safety Regulators Group (ENSREG) has organised its third conference on nuclear safety, which took place at the European Commission in Brussels. The role of ENSREG is to help to establish conditions for continuous improvement and common understanding in nuclear safety and radioactive waste management.

This year, NTW’s members have been invited as speakers. Discover the videos of Michèle Rivasi, Jan Haverkamp, Nadja Zeleznik and the EU Commissioner, Miguel Arias Canete, who welcomed the EP&R report of NTW and stated the European Commission’s willingness to work closely with the civil society.

Introduction by Michèle Rivasi of the panel “Public engagement – the benefits and challenges of openness and transparency”

Michèle Rivasi at ENSREG par nucleartransparencywatch

Speech of Jan Haverkamp: “Vital lessons from Fukushima not learned”

Jan Haverkamp at ENSREG par nucleartransparencywatch

Speech of Nadja Zeleznik: “One year of investigation on emergency preparedness and response in Europe”

Nadja Zeleznik at ENSREG par nucleartransparencywatch

Closing speech of European Commissioner for Climate Action and Energy, Miguel Arias Canete: “EU Strategy – the role of nuclear safety”

Miguel Arias Canete, EU commissioner at ENSREG par nucleartransparencywatch

MEPs and NGOs contest EU financial support for lifetime extension of Ukraine’s nuclear reactors

2 July 2015

27 Members of the European Parliament have signed a joint letter warning the European Bank for Reconstruction and Development (EBRD) and Euratom to suspend the loan proceedings for nuclear units lifetime extension until a full transboundary Environmental Impact Assessment (EIA) and a public consultation are launched and carried out in accordance with international treaties to which Ukraine is a party.

Lifetime extension of nuclear reactors in Ukraine – The EBRD and Euratom are co-financing the EUR 600 million Nuclear Power Plant Safety Upgrade Program to modernise all 15 of the country’s operating nuclear reactors. The reactors 1 & 2 at Rivne have already received a lifetime extension of 20 years beyond their 30 years design lifetime without the implementation of a proper environmental impact assessment (EIA) and a transboundary public consultation process in Ukraine and in neighbouring countries, as prescribed by the Espoo and Aarhus conventions, both signed and ratified by Ukraine and all EU countries. Although such conduct has been assessed by the Espoo Convention implementation committee as a violation of this international treaty, Ukraine does not seem to be approaching the upcoming lifetime extensions differently.

“Spending millions of EU tax payer’s money on keeping open high risk and out-of-date nuclear power stations in Ukraine is utter madness. Ukraine’s nuclear authority (the SNRIU) has a record of ignoring safety risks and cannot be trusted. In 2013, the SNRIU extended the life of a reactor in the South Ukraine Power Plant until 2023, despite independent studies showing that safety limits have been breached by up to 10 times the acceptable levels! With war still raging in Ukraine, the EU approach to extending the lifetime of nuclear power plants in the country is like having a sword of Damocles hang over the heads of all European citizens”, said Dario Tamburrano, Member of the European Parliament (EFDD, Italy).

A joint letter from MEPs – Since this is the matter of European safety, adherence to EU, international rules and transparency, Members of the European Parliament (MEPs) are convinced that all EU policy makers should be informed and take action. At a meeting with campaigners from CEE Bankwatch Network and Nuclear Transparency Watch (NTW) yesterday in the European Parliament, MEPs from six political groups have decided to join the call for freezing the loan proceedings until a proper transboundary EIA and public consultation are carried out. The joint letter signed by 27 MEPs has been sent today to the representatives of EBRD and Euratom.

“Euratom and the EBRD are also committed to apply the principles, standards and procedures established by international and European laws, namely the Aarhus Convention, the EU Environmental Impact Assessment Directive and the Espoo Convention. When tax-payers’ money is not used as it should have been, we must suspend payments. EU institutions should make sure that rights of its citizens are fully respected. The prolonged operation of nuclear reactors implies an increased risk of a severe nuclear accident with potentially devastating impacts on the environment and the people “, said Michèle Rivasi, Chair of NTW and Member of the European Parliament (Greens/ALE, France).

“Nuclear energy requires the highest levels of safety, and civil society plays an essential role in ensuring this. International rules for transparency should be respected”, added Jo Leinen, Member of the European Parliament (S&D, Germany) and of NTW

Ukraine is not the only country in this situation – Several European examples show that more has to be done to promote increased transparency and strengthen international rules on subsidies in Europe. In Belgium, the legislative proposal of the Energy minister to extend the lifetime of two 40 years old nuclear power reactors breaks the Espoo and Aarhus Conventions by ignoring the right of the public to participate in an environmental impact assessment and a public consultation involving also the neighbouring countries. Another example is Austria, where the government has the intention to take the commission to the European court of justice over state subsidies for UK-based two nuclear reactors at Hinkley Point. These subsidies – which Austria considers to be competition distorting, illegal state aid – are to be funded through levies on consumer bills.

Download the joint letter