Transparency and Public participation

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.