Uniform decommissioning standards for all EnBW nuclear power plants
EnBW has obtained all necessary decommissioning permits for the five nuclear power plants it operates and has already begun the actual decommissioning of each facility. We are the first operator in Germany to have achieved this status. Uniform standards and framework conditions apply to the decommissioning of these five plants in Obrigheim, Neckarwestheim, and Philippsburg. Many of these stem from government regulations and requirements that are independent of the operator.
For several years now, the Atomic Energy Act (§7) has stipulated that “facilities […] whose operational life has been definitively ended […] must be shut down and dismantled without delay.” Even before this was codified in law, we had decided to pursue this so-called “direct decommissioning” of our nuclear power plants rather than putting the issue on the back burner.
This is because direct decommissioning has many advantages:
- The company’s own employees working at the facilities, as well as those from partner companies, can be utilized. They are familiar with the facilities and possess the necessary qualifications.
- The infrastructure and systems technology on the power plant site are largely in place and usable.
- The power plant site becomes available for reuse sooner.
- The site remains an uninterrupted regional economic factor.
A prerequisite for decommissioning is a government decommissioning permit. This requires a comprehensive application that must already include the decommissioning plan, and preparing it can take up to two years. The approval process itself takes an additional three to four years on average. Within this framework, the concerns of the public are appropriately addressed through comprehensive public participation, and environmental protection is ensured through an environmental impact assessment.
Before individual decommissioning activities can begin following the issuance and utilization of a decommissioning and dismantling permit, further formal steps are required - in addition to the technical preparations at the facility itself:
- First, the Baden-Württemberg Ministry of the Environment, as the competent supervisory authority, reviews each individual dismantling plan. A dismantling plan is a detailed description of what is to happen on-site during each specific dismantling step. A dismantling step can only be carried out once the Ministry of the Environment has approved the corresponding plan.
- Second, the Ministry of the Environment and the expert it has commissioned may also conduct on-site inspections to verify that the decommissioning activities comply with the requirements set forth in the permit.
Thus, even after the decommissioning and dismantling permit has been issued, monitoring by the regulatory authority and experts continues - just as was the practice during the plant’s earlier operational phase.
EnBW has already received all necessary permits for the decommissioning of its five nuclear power plants and has carried out all public participation processes within this framework. It provides information on the status of decommissioning on its website and, together with the regulatory authority, also does so regularly at public events (“Info Forum”).
Laws, regulations, technical standards, and the provisions of the decommissioning permit provide a clear framework, compliance with which is monitored by the state nuclear regulatory authority. In particular, radiological monitoring of the facility, personnel, and the surrounding area continues, including through government measurements. In addition to nuclear safety and radiation protection requirements, fire safety, occupational safety, and environmental protection are also top priorities for us in the planning and execution of the decommissioning. Diligence and precision are essential in all aspects.
Many nuclear power plants have been decommissioned in the past, both worldwide and in Germany. EnBW also benefits from this experience: When decommissioning our facilities, we use only industry-proven methods, with a focus on reliability. For example, the internal components of the reactor pressure vessels are dismantled and disassembled using band saws, circular saws, and various screwdrivers - remotely operated and mostly underwater. Milling machines, reciprocating saws, and wire saws are also used - the latter, for example, for dismantling massive concrete structures or large plant components. Proven thermal cutting methods, such as oxy-fuel or plasma cutting, are also employed in the decommissioning process. Overall, from a technical standpoint, decommissioning is not uncharted territory.
The technical facilities (e.g., systems, components, piping) of the power plants are the focus of decommissioning. The majority of the work therefore takes place inside buildings. The building structures themselves remain largely intact - so the decommissioning is generally not visible from the outside. Once the “nuclear” decommissioning is complete and the facility has been released from nuclear regulatory oversight, the buildings can either be repurposed or demolished.
Planning and implementing a decommissioning project requires extensive expertise regarding the facilities, working in controlled areas, and handling radioactive materials, as well as knowledge of the legal framework and permitting procedures. We therefore decided as early as 2011 to rely on our own experienced staff, at our nuclear power plant sites, for decommissioning, who meet the strict technical competence requirements set by the state and regularly complete relevant training and qualification programs. Detailed information can be found in the Federal Guideline on Qualification Requirements for Nuclear Power Plant Personnel. Our approach also offers our staff long-term career prospects.
Our staff’s expertise is needed not only for the planning and execution of the decommissioning work itself, but also for the safe continued operation of the plant systems that remain necessary during decommissioning. The same applies to fields such as logistics, the recycling of materials, the proper disposal of waste, as well as support tasks such as radiation protection and IT.
With a planning and implementation period of around 20 years, the decommissioning of a plant has an extremely long time horizon. In terms of complexity, the construction and decommissioning of a plant are similarly demanding. The scale of the overall project is also reflected in the budget: The total costs for the decommissioning and disposal of our five EnBW nuclear power plants are in the high single-digit billion range.