August 2022
It is possible for Germany to have six operational nuclear power plants post-2022. Doing so could save 50 million tonnes of CO2 emissions and billions in energy costs. No insurmountable hurdles have been identified. However, quick action at the administrative and political levels are required.
Introduction
Germany once operated one of the largest nuclear power plant fleets in the world. The country was also a leading provider of reactors and services. But decades of public opposition first halted expansion of nuclear energy by the time of reunification in 1990, and then secured a phaseout agreement by 2002, to remove all reactors by year 2022. In 2009, a new coalition extended the operating times of all German nuclear plants by either eight or fourteen years. Then, the accident at Fukushima Daiichi in Japan in March, 2011 led Chancellor Angela Merkel, previously a supporter of a slow nuclear phaseout, to back a fast phaseout to be completed by December 31st, 2022.
Instead of nuclear energy, Germany’s plan was to keep its coal power plants, build large amounts of wind and solar power, and then mix in natural gas power to make up for daily and seasonal shifts in the energy coming from wind and solar. This mix of wind, solar, and natural gas would then gradually replace coal. The problem is that natural gas is not produced in Germany, and its costs are often quite high on global markets. Germany’s way around this was to build large pipelines to get the natural gas cheaply from Russia.
Russia’s full-scale invasion of Ukraine on February 24th, 2022, revealed a serious flaw in Germany’s policy of relying on Russia for crucial energy supplies. Unfortunately Germany had spent many years planning its energy system and heavy industries around a peaceful future of inexpensive natural gas from pipelines, and until this year also purchased much of its oil and hard coal from Russia.
Germany was planning to import up to 110 billion cubic meters (BCM) of natural gas directly from Russia through the Nord Stream 1 and Nord Stream 2 pipelines. But in the days prior to the invasion, under intense political pressure, Germany canceled the already-completed Nord Stream 2. By mid-July, Russia had sharply reduced gas flows on Nord Stream 1. German leaders are now having to reconsider some of their most deeply-held beliefs: is Russia really a reliable long-term partner for energy supplies?
It’s not just long-standing natural gas policy that is getting a fresh look. On February 27th, the German Economy and Climate Minister Robert Habeck was asked by German broadcaster ARD whether he could imagine letting nuclear plants run longer than planned under Germany's exit plan. Habeck responded, “I would not reject it on ideological grounds.” Then, Lars Feld, chief advisor to German Finance Minister Christian Lindner of the Liberal coalition partner, said “Nuclear and coal must be back on the table.”
Indeed, the three political parties in Germany’s governing coalition did indeed come to an agreement by late spring on reactivating coal plants. Nuclear power, in contrast, has become a polarizing issue for the cabinet, with leaders of the co-ruling Green Party most opposed to keeping the final three reactors. Yet the German public has markedly warmed on nuclear power since the beginning of the crisis, and at least one plant operating company is now openly supportive of life extension.
Two out of the three German energy suppliers operating nuclear energy plants, E.ON and EnBW, are now reportedly open to the idea and ready to discuss the possible extension of German nuclear power plants. Only energy supplier RWE, which produces most of its power from coal and natural gas, says it is not interested in sparing its nuclear plant.
The most immediate question for policymakers, press, and public alike is whether a lifetime extension of the existing three nuclear power plants is feasible. A second question is whether the three nuclear power plants closed on December 31st, 2021 are able to be restored to operating condition for a return to electricity production.
The answer to both questions is yes. This report identifies the obstacles to life extension and restoration, and the key required steps to overcome these obstacles.
Restoring the three recently closed reactors and extending the operating lives of the remaining nuclear power plants would save up to 50 million tons of CO2 emissions every year.
The two most urgent actions are: a halt to decommissioning activities at the three recently closed reactors and ordering fuel for the three operating reactors. Each hour that passes without an interruption to decommissioning procedures could be the hour that eliminates the reactors from service. A fresh fuel delivery for the three existing reactors could arrive as soon as July 2023, which would open the option to operate at full power through January 2025; however, fast and decisive action is needed to ensure this timely delivery.
Life extension of operational reactors
Overview of operating reactors
The following three operating reactors are currently scheduled to close on December 31st of this year.
Emsland I, with a capacity of 1335 MW, is located in Lower Saxony and is owned by RWE.
Isar II, with a capacity of 1410 MW, is located in Bavaria and is owned by E.ON.
Neckarwestheim II, with a capacity of 1310 MW, is located in Baden-Wuerttemberg and is owned by EnBW.
Feasibility of life extensions
It is feasible. All three units are new by international standards, as Emsland I and Isar II are 34 years old, having entered service in 1988, and Neckarwestheim II is 33 years old, having entered service in 1989. For comparison, the median age of operating reactors in the USA is 41 years. Beznau Nuclear Plant in Aargau, Switzerland, just 350 kilometers from the site of Isar, is the oldest pressurized water reactor in the world having connected to the Swiss grid just under 53 years ago. Like these plants, the German reactors have already implemented all necessary upgrades and have conducted the necessary maintenance needed to continue operation until at least age 40.
One expert interviewee reports that Neckarwestheim II may require steam generator replacements, but only for operation past 2032. Steam generators are the part of the pressurized water reactor’s design that turns water into steam. These German plants were designed to make steam generator replacement a routine, several-week operation by including purpose-built hatches in the top of the reactor containment domes.
For long-term continued operation, other smaller components will have to be gradually replaced. However, these measures will not be urgent. All of these replacement costs should be self-financing through continued electricity sales.
Obstacles to life extensions, as of August 2022
Workforce
Utility managers say it takes around three years to train young engineers and technicians to be ready to take full responsibility for some key jobs in the plant. Furthermore, as the nuclear exit has been in law for a long period, there are worries that employees will keep their plans and want to retire or move.
Fortunately, interviews conducted with nuclear workers confirmed that they and their peers are not only willing to stay on, but will enthusiastically embrace an opportunity to save their facilities, towards which they frequently express pride. Many of those who have chosen early retirement upon upcoming plant closure have asserted their willingness to return to their job if operation is allowed to continue.
Much of the plants’ workforces is already contracted to stay on site for the decommissioning process. Experts affirmed that these staff could be reassigned to continue operational efforts. German nuclear energy regulatory law requires full technical staffing levels until all fuel has been moved out of cooling pools at the plant, hence workers would only have been laid off over time.
Plant managers report that motivation among workers is high and that retention is not considered a serious obstacle, as nuclear jobs are irreplaceable in Germany and those looking to stay in the industry presently must plan to emigrate, for example to one of the seven bordering countries of Germany with existing or emerging nuclear programs.
(Nuclear programs in France, Netherlands, Belgium, Switzerland, Sweden, and Czechia have recruited German nuclear experts as those experts have lost nuclear employment in Germany. Poland will likely draw on German nuclear employees as they begin their nuclear program in the next few years.)
Parts needed
Supply chains for certain parts and equipment needed for long-term extension of operations have been moving out of Germany. Domestic suppliers will need to reorient their business strategy in the event of a term extension if a return to previous levels of equipment sourcing from German companies is desired. In the immediate term, it may be necessary to approach foreign manufacturers as early as possible. However, manufacturers are accustomed to producing custom parts and equipment for specific plants they take on as clients. In other parts of the world, supply chains have moved between entire countries depending on business conditions and political considerations. so this is not considered a deal-breaker or even unprecedented for the global industry.
In general, German steam generators are considered to have been manufactured with higher materials quality than those of American and French reactors. Replacement will be necessary only far into the future, if at all.
Financial considerations
An estimate of the cost to extend the life of each reactor takes into account the unusual rush order for custom fuel, adjusting operating procedures to elongate the life of the current fuel, rehiring staff at short notice, and small necessary adjustments that may have been put off due to the approaching closure date. A reasonable estimate from an experienced senior manager put the cost of preparing for continued operation at €100 million each. This includes up to €50 million for the first batch of fuel. According to sources, no comprehensive accounting of costs has been done as of mid-Summer 2022 so these figures are necessarily estimates.
To put this amount in perspective, at current natural gas and carbon prices, Neckarwestheim II will need to run for about 12 days to make up the cost of continued operation. Another way to put this cost in context is that if Neckarwestheim II were extended for five years at a cost of €100 million, this would add €2 to current operating costs of about €20 per MWh, or about 10% of total production costs. By comparison, the median coal power plant in Germany is currently facing operation costs upwards of €150 per MWh.
(Compared against the cost of replacing the same amount of nuclear electricity by power from an efficient combined-cycle natural gas plant when including only the cost of the fuel and the associated carbon emissions certificates at prevailing rates: ETS price of €85 per tonne of carbon, natural gas at the Winter ‘22 price of €190 per MWh on July 29th of Dutch TTF, with a CCGT efficiency of 60%.)
Restoration of recently-closed reactors
Overview of recently-closed reactors
On December 31st, 2021, Germany closed three nuclear reactors.
Brokdorf I, with a capacity of 1410 MW, is located in Schleswig-Holstein and is owned by E.ON.
Grohnde I, with a capacity of 1360 MW, is located in Lower Saxony and is owned by E.ON.
Gundremmingen C, with a capacity of 1288 MW, is located in Bavaria and is owned by RWE.
Feasibility of restorations
All three reactors will need to undergo a thorough inspection conducted by the operators and regulators to ensure no damages have been incurred to the reactor vessel and parts during the two months of closure.
However, in a fortunate turn of events, neither Brokdorf nor Grohnde have yet started decommissioning. The dismantling of NPP Gundremmingen seems to be more advanced, but not so much as to make restoration infeasible, according to industry officials.
For long-term continued operation after restart, certain components would have to be gradually replaced, as in the case of the three still-operating reactors. However, these measures would not be urgent, and would be self-financing through electricity sales
Sources report that both Brokdorf and Grohnde are certainly revivable with timelines similar to those for keeping the three currently operating reactors in service. Experts agreed in principle with the July 2022 judgment of Joachim Bühler, executive board member of the TÜV, the German Technical Inspection Association, as reported in the mass-market "Bild" newspaper. Bühler said that closed reactors could return to service in a matter of months or even weeks. However, they expressed skepticism about the timeline stated by Bühler and believe Gundremmingen C would take more time than the others to restore to operation.
Obstacles to restorations, as of August 2022
Workforce
Even with the recent closures, plants are not allowed to substantially reduce staff in the first year after grid disconnection. As long as there is spent fuel onsite, a large complement of licensed staff is required to stay at the facility. All experts interviewed with knowledge of employee sentiment report the willingness of employees to return to active operation.
Plant personnel are prepared to replan their personal lives around enabling the continued operation of their respective power plants. Experts report that early retirement decisions and the onset of retirement age does not stand in the way of employees wishing to stay on in the case of plants being returned to service. In addition, operators expect to be able to look to other European nuclear programs for staffing needs as some workers have left the country in recent years in anticipation of closures.
Parts needed
Supply chains could be an issue as many smaller suppliers have adjusted to the phase-out and associated work. Many of these companies would need to reorient their business strategy in the event of a term extension. Where existing supply chains are no longer intact, it would be necessary to approach foreign manufacturers. This would take time and pose the greatest challenge.
Financial considerations
The estimated cost of restoring the three units to operation is considered more difficult, and uncertain, by experts we interviewed in comparison to retaining existing reactors. Restart costs are on the order of €100-300 million for Brokdorf and Grohde, according to expert sources, with fuel expected to be up to €50 million. Restart costs for Gundremmingen C are more difficult to estimate. If major parts need replacement or repair after decommissioning work has already begun, “up to €1 billion” was a number obtained from one source.
Outside of this, the estimated marginal cost of continued operation is expected to be similar to costs in recent years of operation, which is estimated to be in the range of €16.9 - 17.9 MWh. With inflation and higher fuel and service costs, €20-22 is considered by experts to be a safe estimate for ongoing costs once one-time restart investments are made.
Common concerns for life extension and restoration
Political guarantees
Wholesale electricity market prices are currently many times higher than recent years. As of late July 2022, both France and Germany have seen their whole year forward electricity prices rise to approximately 10 times 2010-2020 trading averages.
In interviews conducted before these price increases, utility executives anticipated that ten years of legally assured operation would offer justification for nuclear plant life extension.
In current market conditions, each utility will need to decide for itself what guarantees are needed from the government. However, the large returns make certain that fewer years are needed to ensure tolerable levels of risk for plant owners.
Because essentially no physical work is needed to continue operations except for rush fuel fabrication, and securing adequate staffing levels should require little intervention aside from the possible implementation of critical employee retention bonuses, the operation costs of these reactors should not significantly increase. The cost of fuel is a relatively small part of the operational costs of nuclear reactors. Nuclear plants do not emit carbon and thus do not need to purchase carbon emission credits, which are also currently expensive.
As an illustration, if one of these reactors were able to stay in service for the whole year 2023 and sold its power at prevailing whole-year German prices as of late July 2022, a profit before taxes on the order of €3 billion would be achievable. If electricity prices continue to rise because of Russian action to further cut fossil fuel sales to Europe, these figures would be conservative.
Electricity prices increase sharply as supply and demand fall out of balance, so the return of reactors to the market could have a dramatic lowering effect on the price of electricity in Germany and nearby countries. Electricity markets are expected to be currently factoring in the possibility of German reactors staying in service. This would make the economic impact of the reactors staying online larger than merely fossil fuel savings or large profits for the operating utilities.
In conclusion, a combination of high profits or multi-year guarantees of operation would induce utility cooperation to retain reactors even if ten years were not acceptable to the sitting government. This is likely to be the final sticking point in any negotiations, but at least one expert believed that utilities would be open to stretch-out operation through early 2023 with no guarantees as a “door opener” to extended operation during shortages the following winter and beyond.
Fuel
The operating reactors have not ordered fuel for normal operations past December 2022. Nuclear fuel is carefully engineered for each specific reactor and are not generally interchangeable, although reactors fall into different classes with similar fuel in terms of shape or enrichment level.
New fuel elements would have to be reordered from a fuel fabricating company like Westinghouse or Framatome. There is sufficient capacity in their facilities around the world to accommodate new orders. For example, fuel supplier Westinghouse’s Springfield (UK) factory is at significant under-capacity and has reduced the range of services it offers, but could restore services if Russian competitors remain barred from Western markets.
Fuel fabricators often work on an 18-month turnaround for the new fuel elements from the time of the order, matching the typical 18-month refueling cycle of most reactors. However, the CEO of the French nuclear fuel giant Orano has stated that they are ready and willing to work to find rapid solutions to continue operation.
Indeed, one expert has reported that Westinghouse only spends 114 days making each fuel shipment under normal conditions, counting the time after uranium material arrives at the fabrication facility. The facility plans to reduce these fabrication times to 57 days by 2025.
In the meantime, there are ways to extend fuel life in reactors during operation. As seen in Grafenrheinfeld, which closed in 2015, German operators have experience running reactors using fuel elements for longer service, up to or beyond two years before a refueling as a way to avoid fuel tax which is levied per new fuel assembly loaded into a reactor in Germany. By rearranging the fuel rods in the reactor, operators can optimize fuel burn rate and keep the reactor safely operating on a partial power.
This experience could be transferred to the currently operating reactors. The crucial period for electricity from nuclear to displace natural gas especially is through the winter months of the beginning of 2023. After this, reactors can shut down as new rush-manufactured fuel arrives from suppliers. Transitional operation with older fuel assemblies would therefore be short-lived.
Waste
According to the IAEA, each German reactor produces 25 tonnes of spent nuclear fuel waste each year. That means that continued operation of all six reactors in question would produce an additional 150 tonnes of spent fuel per year. If the six reactors were to continue operation for 20 years, the amount of nuclear waste stored in Germany would grow from the current 11,000 tons to about 14,000 tons. This should be compensated for extra decommissioning fund revenue produced by continued operation.
Operating licenses
Before a life extension can be granted, the Atomic Energy Act must be amended. In 2011, legislators issued the 13th amendment to the act that prohibited the use of nuclear power for commercial electricity in Germany. Under current law, all nuclear plants must be phased out by the end of 2022.
Like the Act itself, operating plans can be amended. As utility experts noted, experience with nuclear operation is greater than with decommissioning and dismantling. With the permission of the German Parliament, operators would need to provide proof that all upgrades and maintenance have been completed. With the Atomic Energy Act amended and with the necessary operation planning documents, operators would be able to apply to submit their request to the Nuclear Commission Authority for a life extension.
Public acceptance
In December 2021, half of German respondents to a survey asking about continuing nuclear energy in the country expressed a positive opinion. After the Russian invasion, this sentiment increased, with an ongoing poll from the Germany company Civey by June 2022 finding about two-thirds of Germans expressing support for continued nuclear plant operation. However a vocal minority would still be opposed, and there could be a political cost for the backtrack for some politicians.
Conclusion
Next steps
The legal and statutory requirements would have to be met quickly in order to be able to continue using any of the nuclear power plants. Only a parliament member, political party, or the Federal Government may initiate a vote. When called upon, each political faction would elect a representative to speak on their behalf. For a revision or act to pass, there must be a majority within the parliament. Historically, these types of votes do take a number of months to come to a result. However, due to COVID-19, many votes have been expedited and have come to a conclusion within a month.
The Federal Ministry of Economics and Technology can and should initiate a ban on decommissioning as quickly as possible through administrative channels. The Bundestag (federal parliament of Germany) would have to amend the Atomic Energy Act, in particular paragraph 1, sentence 2ff; paragraphs 1a - 1d; paragraph 3, sentence 4ff in §7 AtG would have to be deleted.
Ideally, to assure operator cooperation, the Bundestag should pass a multiyear guarantee for the continued existence of the licensing requirements for nuclear power plants when amending the Atomic Energy Act. This would ensure that nuclear power plants could be licensed in principle, that operating licenses could only be withdrawn if operators were unreliable, and that operator investments in the plants would be recoverable over a longer period if currently high electricity prices drop from their record levels.
Recommendations
Immediate action must be taken to halt demolition activities at Gundremmingen C and to disallow the beginning of activities at Grohnde I and Brokdorf 1.
Negotiations should begin immediately with fuel fabricators to keep the option open of continuous or near-continuous operation of Emsland I, Isar II, and Neckarwestheim II.
Political and legal work like law changes, guarantees, and relicensing activities should begin and conclude as soon as practicable to minimize the gap in nuclear energy production following any decision to extend reactor operations.
Conclusion
Extending the lives of the nuclear power plants, and restoring closed plants to operation is possible. No insurmountable hurdles have been identified. Quick and consistent decisions at the political and administrative levels are needed, especially in halting demolition activities.
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To compile this report, the authors interviewed board members and executives of nuclear-operating utilities and of nuclear technology companies, in addition to drawing from German-language publications and media. Interviewees provided details on the condition of anonymity on the challenges of life extension and restoration to service of the six reactors in question. Their responses were largely consistent and are referenced at various parts of the report.
AKEN (Aktionskreis Energie & Naturschutz e.V. i.Gr.) is an independent action group focused on energy and nature conservation based in Frankfurt, Germany.
Radiant Energy Group is an independent consultancy based in Chicago, Illinois, USA.
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