Refusal to extend nuclear power plant operations in Germany: government review challenged

Despite the need for European energy independence in respect to Russian gas, the German government reaffirmed its intention to close the country’s last three reactors by the end of 2022. The government invoked regulatory, technological, and practical reasons for its decision, despite the questionable nature of its reasoning.

Amid the Russian gas crisis, questions have been raised regarding the extension of German nuclear reactor operations, which are supposed to be shut down at the end of 2022. When asked about the timeline for phasing out nuclear power during a special parliamentary session on February 27th, the German Economy Minister Robert Habeck replied: “It is part of my ministry’s tasks to answer this question. I would not reject it on ideological grounds”. Just days later, Steffi Lemke, Minister for the Environment (BMUV), and Robert Habeck, Minister for the Economy (BMWI) – both members of the German Green Party Die Grünen – published an “evaluation report”opposed to any extension of the nuclear power plant operations.

The report contains several regulatory and technical arguments. These assertions are debatable and have obviously not been verified by specialists or stakeholders, whether they be security organizations or industrialists. On March 15th, the German nuclear association KernD (Kerntechnik Deutschland e.V.)  published a detailed commentary  in which they question numerous findings outlined in the government report.

 The interest in extending reactor operations beyond January 1st, 2023

There are currently three nuclear reactors in official operation until December 31st, 2022, with a total capacity of 4GW: Emsland (Konvoi PWR, 1,300 MW, RWE, 1988 or 34 years), Neckarwestheim-2 (Konvoi PWR, 1,300 MW, EnBW, 1989 or 33 years) and Isar-2 (Konvoi PWR, 1,400 MW, E.on, 1988 or 34 years). Three nuclear reactors were already shut down on December 31st, 2021, again with a total capacity of 4 GW:  Gundremmingen (1,300 MW), Grohnde (1,300 MW) and Brokdorf (1,400 MW).

Their combined capacity (8 GW) is modest compared to 64 GW of wind, 60 GW of solar, 30 GW of gas or 40 GW of coal. However, these six nuclear reactors produced nearly 70 TWh of electricity in 2021, or 12% of Germany’s gross electricity production. Both low-carbon and controllable, nuclear reactors can sometimes play a key role in the security of Germany’s energy supply. On March 15th, 2022, at 5 p.m., on a particularly windy and sunny day, the remaining 4 GW of nuclear power in Germany produced more than the 120 GW of solar and wind power. Meanwhile, the electricity mix was dominated by coal and gas.

Potential regulatory difficulties

The federal government argues that a new license would be required to operate the reactors. It added that this new authorization should be made to an “EPR safety standard.” KernD denies these two legal analyses. In Germany, operating permits are given without time limits and are legally valid as long as a dismantle permit has not been issued.

On the other hand, since the implementation of the 2002 Amendment to the German Atomic Energy Act (“Phase-Out Act”), each operator has been allotted a limited amount of electricity production over time. In 2010, these quantities were increased, and later revised downwards after the 2011 Fukushima accident. At the same time, an amendment added the nuclear operation deadline of December 31st, 2022. To operate the plants beyond 2022, the Bundestag would simply have to amend Article 7 of the Phase-Out Act concerning the deadline and electricity quantity and do so with a parliamentary majority.

Regarding safety controls, Germany does not currently have an “EPR standard.”  The remaining German reactors, which are between 33 and 34 years old, are subject to the Safety Requirements for Nuclear Power Plants (SiAnf). This regulation includes “the requirement to prevent damage according to state-of-the-art science and technology” whether due to facility modifications or periodic safety controls. These regulations were updated in 2015.

Potential practical difficulties 

The government review raises several practical impossibilities. However, KernD argues that these issues are far from insurmountable.

The government claims the three reactors still in operation would not have enough fuel after December 31st, 2022, which would not allow for “any additional electricity production” for next winter. According to KernD, there are two ways in which a nuclear power plant would be able to produce electricity for a few more months. First, reactors could save fuel this summer by reducing their power in periods of heavy solar and wind production.

Second, reactors could use current fuel stores beyond the planned cycle, or even have fuel elements delivered in an emergency. The European nuclear energy industry is committed to prioritising its fuel deliveries to support the German sector. Significant quantities of fuel would not be needed until the summer of 2023, which is sufficient time for normal supply. The availability of German power plants during the winter of 2023 would save gas during times of low electricity production from wind and solar sources, and when gas-fired power plants are in high demand.

Concerning the issue of spare parts, several power plants built by the former Krafwerk Union (KWU), and similar technology are currently in operation worldwide: Angra 2 (Brazil), Trillo (Spain), Gösgen (Switzerland) and Borssele (Netherlands). There is no shortage of stock for spare parts, and solutions are available industry wide.

In regard to limited personnel and operating teams, KernD noted that in the short and medium term, operators can cover the needs and can retrain staff from other nuclear power plants within one year. Qualified personnel also exist abroad. To continue operations over the long-term, which is not currently on the agenda, several years of specialized training would then be required.

The question of facility safety 

According to the ministries, the facilities currently in operation have not been subject to the ten-year safety review normally planned for 2019 and have been exempt due to their end-of-operation status. Therefore, security deficits cannot be excluded in the light of the 2015 SiAnf, and investment is surely necessary.

For KernD, several reactors – including two of the reactors shut down last December – successfully passed these checks, which suggests that theoretically no cross-cutting issues exist. The association also argues that the reactors were stress-tested after the Fukushima accident. On this occasion, additional equipment was requested. It should be noted that the Konvoi are particularly well-designed reactors, with significant redundancy and diversified safety systems, and they have an excellent reputation at the international level.

KernD concluded its analysis by recalling that nuclear power plants” could provide a crucial contribution to energy security without incurring disproportionate expenditure “.