European taxonomy : the JRC report : Technical assessment of nuclear energy with respect to the ‘do no significant harm’ criteria of Regulation

 Full report : https://lnkd.in/euD-fHb

Other informations of  interest

https://twitter.com/AStrochnis/status/1376834141384290304?s=09 ;https://nitter.tedomum.net/grunblatt/status/1376681091386445826#m

https://nitter.tedomum.net/fmbreon/status/1375744595980644352#m

Context : European taxonomy, Green deal, Nuclear waste, the DNSH Citeria, the TEG group, the JRC group

Inclusion or exclusion of nuclear energy in the EU taxonomy was a debated subject throughout the negotiations on the Taxonomy Regulation. While there are indirect references in the regulation to the issue of nuclear energy (including on radioactive waste), co-legislators ultimately left the assessment of nuclear energy to the Commission as part of its work on the delegated acts establishing the technical screening criteria.

The Technical Expert Group on Sustainable Finance (TEG), which was tasked with advising the Commission on the technical screening criteria for the climate change mitigation and adaptation objectives, did not provide a conclusive recommendation on nuclear energy and indicated that a further assessment of the ‘do no significant harm’ aspects of nuclear energy was necessary.

As the in-house science and knowledge service of the Commission with extensive technical expertise on nuclear energy and technology, the JRC was invited to carry out such analysis and to draft a technical assessment report on the ‘do no significant harm’ (DNSH) aspects of nuclear energy including aspects related to the long-term management of high-level radioactive waste and spent nuclear fuel, consistent with the specifications of Articles 17 and 19 of the Taxonomy Regulation.

Conclusion of of the TEG group : No problem for climate mitigation, data lacking on DNSH aspects

Nuclear energy generation has near to zero greenhouse gas emissions in the energy generation phase and can be a contributor to climate mitigation objectives. Consideration of nuclear energy by the TEG from a climate mitigation perspective was therefore warranted….

The proposed Taxonomy regulation and thus TEG’s methodology for including activities in the Taxonomy explicitly includes two equally important aspects, Substantial Contribution to one environmental objective and Do No Significant Harm (DNSH) to the other environmental objective…

Scientific, peer-reviewed evidence of the risk of significant harm to pollution and biodiversity objectives arising from the nuclear value chain was received and considered by the TEG. Evidence regarding advanced risk management procedures and regulations to limit harm to environmental objectives was also received. This included evidence of multiple engineered safeguards, designed to reduce the risks. Despite this evidence, there are still empirical data gaps on key DNSH issues.

For example, regarding the long-term management of High-Level Waste (HLW), there is an international consensus that a safe, long-term technical solution is needed to solve the present unsustainable situation. A combination of temporary storage plus permanent disposal in geological formation is the most promising, with some countries are leading the way in implementing those solutions. Yet nowhere in the world has a viable, safe and long-term underground repository been established. It was therefore infeasible for the TEG to undertake a robust DNSH assessment as no permanent, operational disposal site for HLW exists yet from which long-term empirical, in-situ data and evidence to inform such an evaluation for nuclear energy….

Given these limitations, it was not possible for TEG, nor its members, to conclude that the nuclear energy value chain does not cause significant harm to other environmental objectives on the time scales in question. The TEG has therefore not recommended the inclusion of nuclear energy in the Taxonomy at this stage. Further, the TEG recommends that more extensive technical work is undertaken on the DNSH aspects of nuclear energy in future and by a group with in-depth technical expertise on nuclear life cycle technologies and the existing and potential environmental impacts across all objectives

Comment : Exclusion of the taxonomy would deprive all nuclear project and companies of access to privileged green funding (and also companies working as providers of nuclear companies would be deprived of green financial label). Given the fact that capital cost is a most important part of the cost of new nuclear eg 66% in Hinkley Point), this would really hampers the financing of nuclear project.

Main conclusions of the JRC Group

Conclusion 1) The analyses did not reveal any science-based evidence that nuclear energy does more harm to human health or to the environment than other electricity production technologies already included in the Taxonomy as activities supporting climate change mitigation…

Conclusion 2 ) Presently, there is broad scientific and technical consensus that disposal of high-level, long-lived radioactive waste in deep geologic formations is, at the state of today’s knowledge, considered as an appropriate and safe means of isolating it from the biosphere for very long time scales….Similarly, carbon capture and sequestration (CCS) technology is based on the long-term disposal of waste in geological facilities and it has been included in the taxonomy and received a positive assessment. The Taxonomy Expert Group therefore considers that the challenges of safe long-term disposal of CO2 in geological facilities, which are similar to the challenges facing disposal of high-level radioactive waste, can be adequately managed.

Finland, Sweden and France are in an advanced stage of implementation of their national deep geological disposal facilities, which are expected to start operation within the present decade…

Specific Focus on Nuclear wastes Deep repositories

The fundamental safety objective applicable to all facilities and activities handling radioactive materials is to protect the people and the environment from the harmful effects of ionizing radiation. Thus, the basic and foremost goal of radioactive waste management is to ensure that the radioactive waste materials are contained and sequestered from the biosphere throughout all stages of waste management

For high-level radioactive waste and spent fuel, there is a broad consensus amongst the scientific, technological and regulatory communities that final disposal in deep geological repositories is the most effective and safest feasible solution which can ensure that no significant harm is caused to human life and the environment for the required timespan. The final disposal of spent fuel and radioactive waste in a repository foresees its emplacement in a multi-barrier (engineered and natural) system in a stable geologic formation several hundred metres below ground level. The specific configuration of the repository depends on the characteristics and radioactivity content of the waste. The multi-barrier configuration of the repository prevents radioactive species from reaching the biosphere over the time span required. In the absence of releases of radioactive species to the accessible biosphere, there is neither radiological pollution nor degradation of healthy ecosystems, including water and marine environments…

The safety of deep geological repositories during operation includes active monitoring and control. The long-term safety of radioactive waste in the geological repository, especially after its closure, must not depend on any institutional control and must be based on inherent passive features. Passive features include engineered and natural barriers that do not require continuous supplies to active systems (e.g. electricity), periodic maintenance, replacement of parts, or permanent surveillance. In the case of a deep geological repository for final disposal of spent fuel and high-level waste, the structures of the facility and the natural media must perform their containment functions without external interventions for as long as necessary.

The implementation of a deep geological repository to ensure that radioactive waste does not harm the public and the environment is a stepwise process, which includes a combination of technical solutions and a strong administrative, legal and regulatory framework. Each step is taken based on a documented decision-making process, in which relevant scientific and technical state of the art, operational experience, social aspects and updates in the legal and regulatory framework are incorporated… With the partial exception of the so-called natural analogues (i.e. sites where natural nuclear reactors occurred billions of years ago), there is no empirical evidence generated by a radioactive waste disposal facility that has gone through the pre-operational, operational, and post-closure stages for the entire timeframe foreseen (up to a hundred thousand years or more for a deep geological repository). For this reason the safety of the disposal during the post-closure phase is demonstrated by a robust and reliable process which confirms that dose or risk to the public are kept below the established limits under all circumstances during the time scales of interest and in the absence of direct human monitoring and control…

A variety of tools and approaches is used to provide scientific evidence in support to safe disposal of radioactive waste. Representative waste forms, including real spent fuel and vitrified high-level waste, are studied in hot laboratory facilities to determine the relevant properties and behaviour of the waste exposed to combinations of simulated environmental features. Tailor-made analogues are used to investigate single effects and reactions. The study of natural analogues can yield very valuable information, for example, on the migration of radionuclides across a geological formation. Experiments carried out in underground research laboratories allow acquiring knowledge and data on the properties of the host rock and their impact in the migration of radionuclides. All the experimental data and knowledge are used to develop and validate models using state of the art codes. Modelling is extensively used to understand behaviours and trends observed experimentally and to obtain prediction capabilities for complex systems.

The final disposal of spent fuel and HLW in a deep geological repository foresees its emplacement in a multibarrier (engineered and natural) system in a stable geologic formation several hundred metres below ground level. The multi-barrier configuration of the repository prevents radioactive species from reaching the biosphere over the time span required to fulfil the strict dose limits imposed by the relevant regulations. The individual properties and the combined behaviour of the barrier materials and of the repository environment contribute to delay, block and minimize the release of radionuclides from the waste package, to delay the transport across the engineered barriers, and eventually to reduce and further delay the migration through the geological media (natural barriers). Therefore, all stages of radioactive waste management, including final disposal, do not cause radiological pollution and do not degrade healthy ecosystems, including water and marine environments. The avoidance of significant harm to humans and to the environment is ultimately ensured by the compliance with the regulatory limits set for the radioactivity dose contribution to the nonprofessionally exposed population, which is a pre-condition for the authorization and licensing of any radioactive waste management facility

- The protective function of the final repository against harm caused by radiations is set by relevant regulations. For instance, the time scale for the safety assessment of the Swedish final repository for spent nuclear fuel should cover a period of one million years after closure. The risk criterion set by SSM in Sweden in simplified terms says that people in the vicinity of the repository may not be exposed to greater risks than the equivalent of one-hundredth of the natural background radiation in Sweden today. The Finnish nuclear law states that a final repository under normal operations may not cause a dose to the most exposed member of the public higher than 0.01 mSv/year

- there is worldwide scientific consensus that disposal of spent fuel and HLW in stable geological formations including multiple engineered and natural barriers containing the radioactive waste is the most effective solution to achieve the required long term isolation of radiotoxic substances. The consensus among the experts extends to the conclusion that disposal in a deep geologic repository is technically feasible and that sufficient confidence in the overall safety of geological disposal of spent fuel and HLW has been reached to begin implementation.

- A significant research effort has been devoted to maximising the fraction of spent nuclear fuel that can be recycled in nuclear reactors and reducing the long-term radiotoxicity of HLW to be disposed of in the geological repository. Both aims are relevant to the environmental objective "Transition to a circular economy, waste prevention and recycling". Due to the fact that fast reactors allow multiple (re)cycling of the fractions of fuel/waste not consumed/burned, the final result of iterating this process would be an almost complete use of the fuel and an increasingly reduced fraction of long-lived species (mostly in terms of the minor actinides content) in the irradiated fuel. Although essentially all steps of this process, also known as partitioning and transmutation, have been demonstrated at laboratory scale, the Technology Readiness Level is not yet corresponding to industrial maturity.

Comment :  the problem of nuclear wastesand geological repositories has also been the topic of a very interesting NEA/OCDE report see https://vivrelarecherche.blogspot.com/2020/09/le-probleme-des-dechets-ultimes-du.html, https://www.oecd.org/publications/management-and-disposal-of-high-level-radioactive-waste-33f65af2-en.htm

Safety and health

Safety is ensured  ! The protection of people and the environment in countries with nuclear installations relies on the existence of a solid regulatory framework that oversees the safety and environmental impacts of these installations… The EU and its Member States have developed and established a comprehensive regulatory framework to ensure the safety of nuclear installations, in line with international requirements and recommendations for enhancing regulatory systems for the control of nuclear installations throughout their lifetime. As contracting parties to the Convention on Nuclear Safety and to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, the EU and its Member States commit to a set of obligations and safety on a global scale, including those relating to their legislative and regulatory framework and regulatory bodies….

Health and Security -Impact of ionizing radiation on human health and the environment

According to the LCIA (Life Cycle Impact Analysis) studies analysed in Chapter 3.4, the total impact on human health of both the radiological and non-radiological emissions from the nuclear energy chain are comparable with the human health impact from offshore wind energy.

The average annual exposure to a member of the public, due to effects attributable to nuclear energy based electricity production is about 0.2 microsievert, which is ten thousand times less than the average annual dose due to the natural background radiation.

The total impact on human health of these radiological emissions, as well as other, non-radiological emissions from the nuclear energy chain, are comparable with the human health impact from offshore wind energy, according to the LCIA …Natural background radiation is responsible for 2.4 mSv/year, or around 78% of the total average annual effective dose to the public of 3.05 mSv/year…

Furthermore, the additional effective doses to members of the public due to the nuclear energy lifecycle are also extremely small when compared to the variations in natural background radiation due to living in different geographic locations…The national averages range from around 1.5 mSv in The Netherlands, to around 6.2 mSv in Finland, a variation of almost 5 mSv/year….

After the Chernobyl accident, there were focused international and national efforts to develop Gen III nuclear power plants. These plants were designed according to extended requirements related to severe accident prevention and mitigation, for example they ensure the capability to mitigate the consequences of a severe degradation of the reactor core, if such an event ever happens. The main design objective was to ensure that even in the worst case, the impact of any radioactive releases to the environment would be limited to within a few kilometres of the site boundary. The deployment of various Gen III plant designs started in the last 15 years worldwide and now practically only Gen III reactors are constructed and commissioned.

These latest technology developments are reflected in the very low fatality rate for the Gen III EPR design10-10 fatalities/GWh,. The fatality rates characterizing state-of-the art Gen III NPPs are the lowest of all the electricity generation technologies.

Other environmental problematics DNSH and pollution : nuclear is better

In accordance with article 17 of the Taxonomy Regulation, an economic activity shall be considered to cause significant harm to pollution prevention and control where:(i) that activity leads to a significant increase in the emissions of pollutants into air, water or land, as compared with the situation before the activity started..

In summary, there is no evidence that nuclear energy does more harm to the transition to a circular economy, including waste prevention and recycling, than other energy technologies included in the Taxonomy.

 Average lifecycle GHG emissions determined for electricity production from nuclear energy arecomparable to the values characteristic to hydropower and wind

 Nuclear energy has very low NOx (nitrous oxides), SO2 (sulphur dioxide), PM (particulate matter) and NMVOC (non-methane volatile organic compounds) emissions, the values are comparable to the emissions of solar PV and wind

 If other impact categories are considered (e.g. acidification and eutrophication potentials), then nuclear energy is again comparable to solar PV and wind ; The same is true for freshwater and marine eco-toxicity; ozone depletion and POCP (photochemical oxidant creation potential

However, with regard to radioactive wastes specifically, clearly nuclear energy produces larger quantities than other generation technologies. For  Radioactive waste and its management –see previous section

water consumption : “While water consumption is very low for once-through cooling, technologies using recirculation cooling, evaporative cooling towers or pond cooling usually consume a significant amount of water to compensate for losses due to evaporation. Water consumption characterizing these cooling technologies remains comparable to concentrating solar power and coal, for both recirculation and pond cooling

General Conclusion

 It can therefore be concluded that all potentially harmful impacts of the various nuclear energy lifecycle phases on human health and the environment can be duly prevented or avoided. The nuclear energy-based electricity production and the associated activities in the whole nuclear fuel cycle (e.g. uranium mining, nuclear fuel fabrication, etc.) do not represent significant harm to any of the TEG objectives, provided that all specific industrial activities involved fulfil the related Technical Screening Criteria.

…The nuclear energy-based electricity generation can be considered as an activity significantly contributing to the climate change mitigation objective. Other associated industrial activities in the nuclear fuel cycle (uranium mining & milling, fabrication of nuclear fuel, reprocessing of spent nuclear fuel, final disposal of high-level radioactive waste, etc.) can be treated as activities enabling the safe and sustainable utilization of nuclear energy.

Other considerations :

Influence of mining  : If the whole nuclear life cycle is considered, then uranium mining has large contribution 32%) to the total GHG emission and dominates the following impacts: SOx 88%, NOx 78%, water pollution 91% and land use 68%. Mining is almost exclusively  99% responsible for the potential eco-toxicity and human toxicity impacts and also dominates the acidification, 82%), ozone creation 86% and eutrofication  53%) potentials. Mining does not have significant share in the water consumption, water withdrawal and production of technological waste impacts….Due to the emission of radon, uranium mining is responsible for about 55% of the total gaseous radioactive emissions during the total nuclear lifecycle?

“The final part listed industrial processes and best practices which are regularly used to eliminate or mitigate the potentially harmful impacts of uranium mining and milling. It is demonstrated by the best available technologies of today that by the application of adequate practices the impacts can be controlled and their magnitude can be kept well below the applicable regulatory limits.”

Influence of enrichment  : In general the enrichment phase has moderate contribution to the various impact indicators and it is not adominant contributor to any impact indicator …If the whole nuclear lifecycle is considered, then enrichment has negligible contribution ( <1%) to the water pollution, land use, water withdrawal, eco-toxicity and human toxicity. It has some contribution to the SOx  3% and NOx emission 4%, water consumption, 2% , technological waste 2%, acidification potential 4%, It has larger than 210% cotribition only to the total GHG emission GNH relase  12%) and the eutrophication potential 18%).

Reprocessing of spent nuclear fuel : Commercial scale reprocessing of spent nuclear fuel for civil purposes is now a mature technology that has been practised for several decades….. In the light of the above analysis it can be concluded that industrial activities associated with reprocessing of spent nuclear fuel do not represent significant harm to human health or to the environment. They do not represent significant harm to any of the TEG objectives, provided that the associated industrial activities satisfy appropriate Technical Screening Criteria

Operation of power plants : Provided that nuclear power plants are built, operated and decommissioned within the limits set by existing regulations, they do not pose a significant harm to any of the TEG objectives. In the light of the above analysis it can be concluded that NPP operation activities do not represent unavertable harm to human health or to the environment. They do not represent significant harm to any of the TEG objectives, provided that the associated industrial activities satisfy appropriate Technical Screening Criteria.

Final repository : No radiologically relevant release or impact to the public is expected during the construction and the operation of the final repository.

Impact of severe accidents :