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Expert response to the pro nuclear report by the Joint Research Centre

Any major expansion of nuclear energy would delay the decommissioning of fossil-fired power plants, as the latter would have to remain in operation during this period and therefore make it hard to achieve the climate change mitigation objective. It is even possible to argue that nuclear energy hinders the use of other alternatives with low CO2 emissions because of its high capital intensity.  Otherwise this capital could be used to expand alternative energy sources like sun, wind and water

While nuclear power generation in the electricity generation phase has been associated with relatively low greenhouse gas emissions from a historical perspective, the lions’ share of greenhouse gas emissions in the nuclear fuel cycle is caused by the front-end and back-end processing stages. Based on estimates, the CO2 emissions can be broken down into the construction of nuclear power plants (18%), uranium mining and enrichment (38%), operations (17%), processing and storing nuclear fuel (15%) and decommissioning activities at the power plant (18%) (BMK, 2020, p.6)   

Generating huge quantities of dangerous waste is being continued for decades without any effective disposal solution being available. The JRC itself says that the primary and best waste management strategy is not to generate any radioactive waste in the first place. However, this assessment is not consistently applied within the report. 

The draft of the delegated legal act is based on the recommendations of the so-called Technical Expert Group (TEG). …..The TEG did not recommend that nuclear energy should be included in the EU taxonomy register at that time and recommended an in-depth study of the DNSH criteria (TEG, 2020b). 

It is clear that the JRC barely touched on some environment-related aspects of using nuclear energy or did not consider them in its assessment at all.

.…  Questions must also be raised about the ageing process and the brittleness of materials and therefore the long-term behaviour of nuclear power plants beyond the original design period. 

This very positive presentation of future prospects for nuclear energy, which is shown in the JRC Report, must be viewed critically………..this presentation by the JRC is suspect from a professional point of view and possibly indicates a lack of adequate independence .

  Expert response to the report by the Joint Research Centre entitled “Technical assessment of nuclear energy with respect to the ‛Do No Significant Harm’ criteria in Regulation (EU) 2020/852, the ‛Taxonomy Regulation’”    Particularly considering the suitability of criteria for including nuclear energy in EU taxonomy The Federal Office for the Safety of Nuclear Waste Management (BASE) with support from the Federal Office for Radiation Protection (BfS)  June 2021


Summary

The Federal Office for the Safety of Nuclear Waste Management (BASE) with support from the Federal Office for Radiation Protection (BfS), acting on behalf of the Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU), has examined the report by the Joint Research Centre (JRC) of the European Union (EU) entitled “Technical assessment of nuclear energy with respect to the ‘Do No Significant Harm’ criteria of Regulation (EU) 2020/852 (‘Taxonomy Regulation’)” to see whether the JRC has used expertise that is complete and comprehensible when determining whether the use of nuclear fission to generate energy can be included in the taxonomy register. 

The Taxonomy Regulation defines criteria that determine whether an economic activity (and therefore investments in this activity) can be viewed as ecologically sustainable. The JRC, the EU’s research centre, concludes in its report dated March 2021 that the conditions for including nuclear energy in EU taxonomy are met in terms of the “Do No Significant Harm” criteria (DNSH). Prior to this, the Technical Expert Group (TEG) had not yet recommended the inclusion of nuclear energy in EU taxonomy and advised the EU Commission to review the DNSH criteria more closely. 


This expert response finds that the JRC has drawn conclusions that are hard to deduce at numerous points. Subject areas that are very relevant to the environment have also only been presented very briefly or have been ignored. For example, the effects of severe accidents on the environment are not included when assessing whether to include nuclear energy in the taxonomy register – yet they have occurred several times over the last few decades. This raises the question of whether the JRC has selected too narrow a framework of observation. The aspects mentioned and others listed in this expert response suggest that this is true. 

This expert response also points out that the JRC mentions topics, but then fails to consider them further or in more detail, although they must be included in any assessment of the sustainability of using nuclear energy. The need to consider them is partly based on the fact that certain effects on the other environmental objectives in the Taxonomy Regulation must be expected if the matter is viewed more closely or at least cannot be excluded. In other cases, this need results from the fact that the Taxonomy Regulation refers to the UN approach in its 2030 Agenda in its understanding of sustainability – and the latter, for example, contains the goals of “considering future generations” and “participative decision-making”. Any sustainability, particularly for future generations, can only be guaranteed if attempts are made at an early stage to achieve acceptance in the population, enable future generations to handle the use of nuclear energy and its legacy or waste appropriately and ensure that information and knowledge are maintained in the long term. Generally speaking, it should be noted that the problem of disposing of radioactive waste has already been postponed by previous generations to today’s and it will ‘remain’ a problem for many future generations. The principle of “no undue burdens for future generations” (pp. 250ff) has therefore already been (irrevocably) infringed, while the DNSH-hurdle “significant[ly] harm” has also been infringed. 


Generating huge quantities of dangerous waste is being continued for decades without any effective disposal solution being available. The JRC itself says that the primary and best waste management strategy is not to generate any radioactive waste in the first place. However, this assessment is not consistently applied within the report. 

The JRC Report only provides an incomplete view of the consequences and risks of using nuclear energy for people and the environment or for future generations or does not even mention them in its assessment. Where it does mention them, some of the principles of scientific work are not correctly considered at some points. The JRC Report is therefore incomplete and therefore fails to comprehensively assess the sustainability of using nuclear energy. 
Reason and background, goal, approach and structure of the expert response 1.1 Reason for and background to the expert response 

The JRC Report provides only an incomplete view of the consequences and risks of using nuclear energy for people and the environment or for future generations or does not even mention them in its assessment. Where it does mention them, some of the principles of scientific work are not correctly considered at some points. The JRC Report is therefore incomplete and therefore fails to comprehensively assess the sustainability of using nuclear energy. 
Reason and background, goal, approach and structure of the expert response 1.1 Reason for and background to the expert response .

…………………..  The draft of the delegated legal act is based on the recommendations of the so-called Technical Expert Group (TEG). The Commission launched this group to obtain advice about implementing the “Action Plan: Financing Sustainable Growth” dated 8 March 2018 – partly to draw up the Taxonomy Regulation. In its report dated 9 March 2020 on “Taxonomy: Final Report of the TEG on Sustainable Finance” or in its annex, the TEG concludes that nuclear energy may make a contribution to the environmental objective of climate change mitigation, but significant adverse effects on other environmental objectives cannot be ruled out. The reasons for this are mainly the unresolved issues of disposing of radioactive waste, particularly the lack of any empirical data about safe disposal. The TEG therefore did not recommend that nuclear energy should be included in the EU taxonomy register at that time and recommended an in-depth study of the DNSH criteria (TEG, 2020b). 


The discussions taking place at a European level at this time on whether nuclear energy should be included in the taxonomy register must be viewed in this light ………………………

Main statements in the assessment of the JRC report in tabulated form It is clear that the JRC barely touched on some environment-related aspects of using nuclear energy or did not consider them in its assessment at all. The JRC does not explicitly state whether and how this procedure is supported by the Taxonomy Regulation. Ultimately, this raises the question of whether the JRC selected too narrow a framework for its observations. The assessment also shows that the expert rigour and sense of balance used in the JRC’s approach to the DNSH criteria must be questioned. Individual content items or stages in the life cycle for using nuclear energy have not been completely and adequately assessed    …………………………


2 A critical review of the JRC’s methodology – the DNSH criteria for the use of nuclear energy In its assessment of whether to add nuclear energy to the taxonomy register (cf. section 2.2 of this expert response below), the JRC Report does not include aspects of using nuclear energy, which could create considerable adverse effects on environmental objectives or could help prevent these effects. …………….


The Taxonomy Regulation therefore urges that all the risks of an economic activity require thorough, scientific consideration; uncertainties must be clearly stated and any non-consideration of risks when assessing an economic activity using the DNSH criteria require in-depth justification – not least to satisfy the precautionary principle. The JRC does not reflect these requirements. …………..

The JRC study also falls short of the mark when it comes to the harmful consequences of a severe nuclear accident, because it ignores all the ensuing non-radiological effects. They not only involve psycho-social secondary illnesses, which are clearly verifiable (Hayakawa, 2016) – in the numbers of fatalities too – but also the social impact such as the massive loss in the quality of life, social cohesion and economic prosperity – and the lack of prospects of a return to normal in the affected regions within the near future. (Bromet und Havenaar, 2007; Hawegawa et al., 2015; Shigemura et al., 2020) 


Overall, the social costs, for instance in Germany, arising from the intense social discussions about the risks of nuclear technology and the risks associated with storing and disposing of radioactive waste in comparison with other energy generation technologies have been high – and the JRC Report fails to mention them.      ……………….

2.2.2 Uncertainties Due to the review standards of the JRC in assessing the DNSH-criteria, uncertainties which cannot be eliminated even in view of the specified regulatory requirements – i.e. the legal and sub-statutory regulations, are not taken into account. The issue of uncertainties plays a major role in conjunction with the safety statements about repositories. However, the JRC Report does not adequately cover this topic, …………..


Alongside the uncertainties e.g. about future climate developments, the uncertainties associated with future human actions and society and social behaviour must be mentioned here too. The possibility of unintentional human intrusion into a repository, which cannot be ruled out, illustrates the limits of any safety assessment over long periods of time (cf. the remarks about maintaining information and knowledge in the long term below, particularly with a view to human intrusion). Uncertainties also relate to the possible adverse effects on environmental objectives, e.g. in the context of to disposal, …………………….

  The approach of providing a general statement that the question of safe disposal for high-level radioactive waste has been resolved in terms of sustainability if the relevant, underlying national and international regulatory safety provisions are followed and that this will continue to be valid in future is not supported by the necessary scientific diligence. …………

 2.2.4 Nuclear Security. Simply referring to the regulatory requirements falls short of the mark in terms of the nuclear security regime too. ……………………


2.3 The JRC’s methodology What is also striking when reviewing the JRC Report is the fact that the JRC’s approach is not always rigorous and comprehensible – and is also unbalanced at times. ……………


The key findings in the “Executive Summary” only partially relate to the analyses and assessments in Part A and the knowledge base in Part B. It is therefore not possible to trace their source and they appear as a collection of isolated statements without adequate links to the report. ……………..


Overall, the data or reference basis used in the JRC Report seems unbalanced. For example, the share of nuclear energy in electricity generation within the EU, which is used as the starting point for analysis by the JRC, both for the taxonomy criterion of contributing to climate protection and the DNSH criteria, is overestimated ………………………

3 Criterion 1 in the Taxonomy Regulation – making a contribution to climate change mitigation This section examines the contribution made to climate protection by nuclear energy (objectives 1 and 2 in the Taxonomy Regulation). It involves a critical review of the expert statements in the JRC Report with regard to electricity generation at nuclear power plants (cf. section 3.1) and when using technologies that are being developed like small modular reactors (cf. section 3.2). …………


It should be noted, inter alia, that the JRC Report presents the contribution of nuclear power plants to greenhouse gas emissions in a very positive light. The forecast for the ongoing development of using nuclear energy for power generation in the EU, as presented in the JRC Report, is also clearly far too optimistic. 


With regards to the contribution to climate protection that could be made by so-called small modular reactors, the JRC Report does not discuss the fact that they are not yet ready for market introduction – nor does it cover the unresolved issues about safety, transportation, dismantling and disposal connected with this type of reactor  .

1 Nuclear power plants,…………………


  3.1.1 The contribution of nuclear power plants to climate change mitigation in the JRC Report   


  Part A 3.2.2 of the JRC Report provides an assessment of the contribution made to climate protection by using nuclear energy. Many special cases are presented to back up the statements made about low greenhouse gas emissions when generating electricity with nuclear energy and this creates a distorted view.    The JRC Report is imprecise at many points and abbreviates or omits statements that are made in the sources used. As a result, the contribution to greenhouse gas emissions made by using nuclear energy is presented in a very favourable light, particularly in relation to the threshold value that is currently set at 100 g of CO2eg/kWh by the Technical Expert Group (TEG) in the Taxonomy Report Technical Annex (TEG, 2020b). However, the TEG clearly indicates, in contrast to the JRC Report, that this threshold value will be reduced every five years to achieve net zero emissions by 2050 – in accordance with the political goals to reach zweo net emission by 2050 (TEG, 2020b). The JRC Report conveys the impression that the threshold value of 100 g of CO2eg/kWh will remain constant during the next 50 years (JRC Report, Part A 3.2.2, p. 40). 

Another example of shortened statements in the JRC Report and the resultant optimistic presentation of the life-cycle-based greenhouse gas emissions when using nuclear energy is Figure 3.2-6 (JRC Report, Part A 3.2.2, p. 40). The JRC Report does not mention that the literature used for the figure (WNA, 2011) cites many factors that contribute to the discrepancies in the greenhouse gas emissions that are presented. One important factor according to WNA (WNA, 2011) is the different definition of “life cycle” in the publications consulted. Some of the publications included waste management and waste treatment in the life cycle, while others did not (WNA, 2011). In addition the WNA publication that is cited dates back to 2011 and is therefore already relatively old. It points out, for example, that the great discrepancies in greenhouse gas emissions with solar energy are based on the rapid developments in solar panel units, which have already taken place, and further increases in efficiency can be expected. 


3.1.2 Forecast about using nuclear energy in the JRC Report …………………..  . The forecast that the share of nuclear energy of 22% will continue until the year 2050, while overall electricity production increases, presupposes a massive expansion of nuclear power plants in Europe. This expected massive expansion cannot be deduced given that just four nuclear power plants are being built in the EU and it normally takes more than 10 years to construct a new nuclear power plant (IAEA, 2020, p. 13). 

……….  The forecast presented in the JRC Report not only presupposes new construction of nuclear power plants, but also extensive retrofitting of the ageing nuclear power plants in the EU: the first cases of decommissioning of nuclear power plants in Figure 2.3-4 of the JRC Report are not envisaged until the year 2040. This would imply a lifetime for all the nuclear power plants within the EU of about 60 years, although this is unlikely because of shut-downs that have already been announced, including those in Germany 


……….  Most of the nuclear power plants currently operating in the EU are more than 30 years old, 66 of the 106 currently in service in the EU are between 30 and 40 years old and 26 are actually more than 40 years old. Only two new nuclear power plants have been connected to the grid during the last 20 years (IAEA, 2021). 

The nuclear power plants were originally designed for a lifetime between 30 and 40 years. The degree to which national authorities will actually approve a lifetime extension to the service life of old units in accordance with the current safety requirements is uncertain – ….  Questions must also be raised about the ageing process and the brittleness of materials and therefore the long-term behaviour of nuclear power plants beyond the original design period. 


This very positive presentation of future prospects for nuclear energy, which is shown in the JRC Report, must be viewed critically. Even if these forecasts cannot play a role when assessing nuclear energy according to the specific environmental objectives of the EU taxonomy, this presentation by the JRC is suspect from a professional point of view and possibly indicates a lack of adequate independence .

Large parts of society struggle to accept nuclear energy and it is accompanied by long development periods (10-19 years for each power plant in democratic societies) (BMK, 2020, p. 4). Any major expansion of nuclear energy would delay the decommissioning of fossil-fired power plants, as the latter would have to remain in operation during this period and therefore make it hard to achieve the climate change mitigation objective. It is even possible to argue that nuclear energy hinders the use of other alternatives with low CO2 emissions because of its high capital intensity.  Otherwise this capital could be used to expand alternative energy sources like sun, wind and water (BMK, 2020, p. 4-5). 

While nuclear power generation in the electricity generation phase has been associated with relatively low greenhouse gas emissions from a historical perspective, the lions’ share of greenhouse gas emissions in the nuclear fuel cycle is caused by the front-end and back-end processing stages. Based on estimates, the CO2 emissions can be broken down into the construction of nuclear power plants (18%), uranium mining and enrichment (38%), operations (17%), processing and storing nuclear fuel (15%) and decommissioning activities at the power plant (18%) (BMK, 2020, p.6)     ……. https://www.base.bund.de/SharedDocs/Downloads/BASE/EN/reports/2021-06-30_base-expert-response-jrc-report.pdf.pdf?__blob=publicationFile&v=6

September 13, 2021 - Posted by | climate change, EUROPE, politics international, Reference, spinbuster

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