Opinion of the French Academy of Sciences (8 May 2021): The contribution of nuclear energy in the energy transition, today and tomorrow

 French Academy of Science is the leading scientific authority in France

Texte intégral : https://www.academie-sciences.fr/pdf/rapport/20210614_avis_nucleaire.pdf

Extraits

1) The energy transition: "The energy transition, to be implemented to limit our greenhouse gas emissions and the global warming that results from it, must result in:

- a reduction in our energy consumption per person; - a reduction in our dependence on fossil fuels, primarily coal and oil, and secondly gas;

 - an increase in the share of low-carbon energy sources (renewable energies and nuclear energy); These developments will inevitably lead to a significant increase in the share of electricity in energy production and consumption, reaching a level of around 700 to 900 TWh (terawatts-hour) in 2050, almost double our current electricity production. This electricity must be as decarbonised as possible.

Comment: As the Academy of Technologies had already noticed, this level of 700 to 900 TW.h confirms that the Multiannual Energy Programmation Law  (PPE) must be seriously reviewed. (650 TW.h). As well as all the scenarios, eg @RTE that rely on it.

2) Renewable energies: "Intermittent and variable renewable energies, such as wind and solar photovoltaics, cannot, on their own, supply an electricity grid with power in a stable and controllable way if their random nature is not compensated. This requires massive energy storage capacities and/or controllable backup power generation units. The massive storage of energy, other than that already carried out by means of pumped-storage hydroelectric power stations, would require capacities that are not seen to exist in the coming decades. Pilotability, in the absence of the latter, can only be ensured by nuclear power stations, if we exclude thermal power stations using fossil fuels..

3) Nuclear and CO2  : "A conventional RNT (Thermal Neutron Reactor) massively injects, 24 hours a day, at least for some 300 days a year, decarbonized electricity into the grid. Nuclear power generation is, in fact, of all sources of electrical energy, the least emitter of greenhouse gases (about 6 grams of CO2 equivalent per kWh produced). »

4) Nuclear and environmental impacts :  "A comprehensive life cycle analysis of electrical systems shows that the non-radioactive environmental impacts of nuclear power are most often much lower than those of other systems. As far as radiological impacts are concerned, they remain, in normal working conditions, much lower than those associated with natural radioactivity. On the other hand, those linked to major nuclear accidents have necessitated the evacuation of large areas in order to avoid extraordinary radiological exposures and have had serious social and environmental consequences. Feedback from these accidents has led to successive improvements in reactor safety. Since 2011, EPR-type reactors, third generation pressurized water reactors (EPRs), have been designed to minimize the accidental release of radioactivity into the environment, thanks to technological provisions and more stringent safety regulations

5) Nuclear Waste: "Medium- and high-level waste with a long life, which is the most delicate to manage, has a volume of the order of 1.4 m3/TWh electric for the French fleet (the total volumes of this waste since the beginning of the nuclear era are respectively 42,700 m3 and 4,090 m3). The inventory of all the waste from the French nuclear fleet is regularly updated by the National Agency for the Management of Radioactive Waste (Andra)...

Deep geological storage, under conditions of safety and reversible management, controlled by the Nuclear Safety Authority (ASN), is well suited to long-lived waste. In this context, the application for the creation of Cigéo (Industrial Center for Geological Storage), after twenty years of research by the national scientific community, is ready to be filed with the Ministry of Ecological Transition to be examined by the ASN "

6) RNRs (breeder reactors): From the beginning of the program, the nuclear power policy aimed at the possibility of installing a fleet of fast neutron reactors (RNR) in order to make better use of uranium resources and thus extend the production of nuclear power... The most mature RNR model is a reactor using liquid sodium as the heat transfer fluid for energy: RNR-Na. The feedback from these reactors is important, especially in France, which operated Phoenix, Superphénix and led for 10 years the Astrid project foreshadowing the fourth generation RNR (RNR GenIV).

The Multiannual Energy Programming (PPE) has recently postponed to the next century a deployment of the RNR, leading to the abandonment of the ASTRID project of the CEA. As a standby strategy, it decided to move towards the multirecycling of plutonium from spent fuel in NTRs, particularly EPR reactors. This strategy is intended to maintain France's R&D expertise to move towards the RNRs. It can stabilize the quantities of spent fuel but does not lead to the energy autonomy as sought with the RNR. 

7) Recommendations:

- to maintain the nuclear power capacity of France's energy mix by extending the reactors in operation, when their operation is ensured under conditions of optimum safety, and by building third-generation reactors, the EPRs, in the immediate future. The latter are based on the best technology currently available and offer the best guarantees of safety;

- initiate and support an ambitious R&D program on the nuclear of the future in order to prepare for the emergence in France of innovative fourth generation fast neutron reactors (RNR), which constitute a solution for the future and whose study is actively continuing abroad;

- to take into account in this programme all the scientific aspects of fuel recycling associated with reactors, including the management of radioactive waste;

- maintain training courses to attract the best young talents in all fields of physics, chemistry, engineering and nuclear technologies to develop national skills at the highest level;

- inform the public in full transparency about the constraints of the various energy sources, the complete analysis of their life cycle and the contribution of nuclear power in the current energy transition.

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 :

Green taxonomy : European Consultation on Technical Expert Group (3)

In the previous blog, I explained the issue of green taxonomy (which, for now, but with a possibility of change), excluded nuclear power from access to privileged environmental financing, and I was pleased with the number of French and foreign  contributions showing the end of a certain nuclear bashing. 

(https://vivrelarecherche.blogspot.com/2019/09/urgence-nucleaire-et-climatique-alerte.html)

https://vivrelarecherche.blogspot.com/2020/04/taxonomie-verte-consultation-europeenne_22.html

In Part 3, I want to communicate extracts of a major French Trade Union (CFE-CGC Energie) contribution, one of the few trade unions that acknowledges and answered to the concerns provoked by the Green Taxonomy.

Sustainable Finance and "Green Taxonomy" - POSITION of CFE-CGC Energy on the report of the Technical Expert Group (TEG) April 2020)

The European Union, through the Green Deal, has confirmed its desire to achieve a carbon-neutral economy by 2050, and, to go beyond wishful thinking, to draw up a concrete and responsible roadmap to carry out this agenda. The Green Taxonomy Regulation is a way to put in place a framework that directs investors and facilitates significant investment flows to the most relevant innovations, technologies and projects to achieve this goal. As a representative organisation of employees of the energy sector, the second trade union of the branch in France, a member of the European trade unions EPSU and Industriall, the CFE_CGC Energy federation legitimately wishes to contribute to the Technical Expert Group's evaluation on taxonomy and to relay a number of criticisms or concerns expressed by its constituents.

The CFE-CGC Energy Federation supports the Commission's objectives and the sustainable financing initiative, which is an essential tool with important consequences that needs to be carefully evaluated and weighed. Our organization shares the international consensus on the technologies to be embarked on to succeed the Green Deal, and fully agrees with  the IEA calling on industrialized countries to focus on renewable energy, nuclear and gas, the latter as a substitute for more carbon-intensive fossil fuels such as oil and coal. As a result, we wish to clarify the following points.

1) Low-carbon technological neutrality has not been respected.

 Only an agnostic technological approach can properly identify the most effective and relevant outcomes. However, the TEG report does not follow this method ; in particular, it does not require all energy sources without exception to  be evaluated over their entire life cycle, and according to a methodology whose rigour is validated and internationally recognized (for example, ISO 14040 and 14044). Any choice that would not be supported by this type of analysis seriously undermines the credibility of this text.  The facts that Renewables Energies are exempted of this whole  life cycle analysis and that, for nuclear, it is not recognized that the low greenhouse gas emissions not only results from the exploitation phase, but also from the entire life cycle (12gCO2/kWh according to the 5th GIEC report) constitute flagrant violations of the principle of technological neutrality that need to be corrected.

Finally, the DSNH (Do Not Significantly Harm) criterion, if necessary, is rather vague and must also be considered according to the criterion of technological neutrality and the state of scientific knowledge, and not according to criteria depending on the desired result.

This obviously has not always been the case, especially for nuclear waste (see below).  This reflects the consideration of the non-technical and highly political agendas of certain countries or organisations that have no monopoly on scientific ecology and seriously undermines the very relevance of the TEG report.

2) Exclusion “at this stage” of nuclear energy from the “green” taxonomy.

While nuclear power is well identified as a highly decarbonised energy source (6g CO2/kWh in French industry, according to Ademe assessment), it is not sufficiently stressed that it is non-intermittent and flexible and does not need to be combined with other means of power generation or large-scale storage; its low impact on, among others, air pollution, consumption of raw materials, use of lands are not highlighted, and, in general, the lack of consideration of these criteria constitutes a general and important methodological weakness of the TEG work on taxonomy.

The exclusion of nuclear power at this stage is claimed to come from the fact that the management of its waste would not meet the DNSH criterion. CFE-CGC Energy disagrees  with this claim, which clearly ignores the technological realities and the state of science. Radioactive waste is managed according to strict protocols and its management is supervised by national security authorities and is subject to numerous Euratom Treaty specifications; it would be appropriate that taxonomy  do not ignore the existing European treaties!

With regard to low-level radioactive waste, there is a European consensus to define a threshold for release from which these materials can be considered as ordinary materials: IAEA (RS-G-1.7 guide), directive 2013/59/ Euratom. Recycling of nuclear fuel can be expanded to make better use of uranium resources and reduce waste. The volume of high-activity waste, after reprocessing, represents 3% of all  radioactive waste in France, i.e. the equivalent of an Olympic swimming pool for the entire French nuclear  park since its creation. For those ultimate waste, deep burial in geological deposits (stability greater than 150 million years against a detectable radioactivity of 15,000 years for waste) is a solution validated by the security authorities of many countries (France, Finland, Switzerland for Europe, but also USA, Japan, Canada, Russia, China). In France,  CFE-CGC  Energy supports the Cigéo project.

It should be noted that the TEG, after its principled position on the exclusion of nuclear power, nevertheless acknowledges its lack of competence on the subject and opens the door to a specific international expertise. CFE-CGG Energy calls for this recommendation to be followed and to appoint an expert group to assess the sustainability and the DNSH aspect of known solutions for the treatment of nuclear waste, respecting technological neutrality.  This group should be made up of experts from national security authorities, public agencies in charge of radioactive waste management, representatives of research organizations active in nuclear science and technology, and radiation protection.

CFE-CGC Energy  stresses the importance of dealing with this problem rationally and quickly. The TEG report does not treat with due importance an abundant, competitive, highly contributor to GDP energy, which is currently the main source of decarbonised energy in Europe ! It is necessary to eliminate the current uncertainty about nuclear power: firstly, for its own importance in the climate challenge (remember that electricity is also bound to replace massively some uses of fossil fuels); and secondly, because the exclusion of nuclear power from green taxonomy would also have a strong impact on all user industries that would be denied access to preferred financing to optimize their energy transition processes….

4) Responsibility of Member-States in their energy mix

 CFE-CGC Energy recalls that energy policy mix are the responsibility of Member-States that have very different geographical, economic and historical contexts and constraints, and which must be able to choose their range of low-carbon tools and make their own technological choices to succeed in their energy transition. Again, respect for technological neutrality is essential, for if States were to be denied access to green financing for important and structuring projects according to technologically unjustified criteria (for example in the case of nuclear projects in Finland, Czech Republic, Slovakia, Romania, Bulgaria, Hungary), this could simply cause the explosion of institutional Europe at a time when it is facing multifaceted and unprecedented crises and tensions.

5) The DSNH criteria must take into account social and strategic aspects

 A green investment cannot be an investment that would violate the minimum social guarantees recognised by the Member-States, or that would cause serious employment difficulties, even temporary ones, without offering satisfactory solutions for retraining.

Moreover, the current sanitary Covid crisis obliges us to review our dependence on foreign countries and industries and to embark on a policy of re-industrialisation. Green investments must take into account the negative aspects of an excessive and uncontrolled globalization, as well as strategic aspects. European green funding should not lead to an increase in dependence on states outside the EU, which everyone can now see as dangerous, nor should they be used to finance value chains almost exclusively established outside the EU.

Finally, it would be absurd to label green funding which would simply outsource the negative impacts (CO2 emissions, pollution, health consequences, costs and negative externalities of transport) outside Europe. The lessons of the financing of wind and especially solar industries  by Europe and Member-States resulting in the massive creation of value and jobs in China must not be forgotten.

Green taxonomy is an important tool for the success of a climate-efficient, economically favourable and socially just energy transition. Its potential is immense, its consequences must be carefully evaluated. CFE-CGC Energy considers it essential to respect technological neutrality in all its aspects, otherwise this tool will lose all legitimacy and will face the refusal of Member States and their citizens and employees.  It hopes that future discussions on taxonomy will include social and strategic aspects, be transparent and open to stakeholders, and will enable the development of a European model of more environmentally and socially responsible companies.

These are essential conditions for taxonomy to achieve its objectives and be indeed useful in directing investments towards a successful and Green Deal-compliant energy transition.