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Radiation, nuclear wastes, transportation, uncertainties – extract from Expert response to pro nuclear JRC Report

The DNSH-related TSCs state, among other things, that the repository facility must guarantee that the waste is contained and isolated from the biosphere. This also applies if extreme natural phenomena occur such as earthquakes, tornadoes, floods or the loss of technical barriers. 

……  nuclear energy has been used for several decades, but there is still no repositoryfor high-level radioactive waste operating anywhere in the world. Responsibilities are therefore passed on to following generations and they are restricted in their freedom of choice. Section 6 of this expert response will deal with this matter in greater detail. 

General results of the reviewThe JRC Report contains unfounded generalisations at many points. Conclusions are drawn from individual, selected examples and their global validity is assumed. Readers without any detailed specialist expertise will find it hard or impossible to recognise this.


.……….  The JRC presents the disposal of high-level radioactive waste as a completely resolved problem by citing the example of the disposal projects in Finland and France. This largely ignores the fact that the Finnish repository is still under construction and the licence application from the operational company has already been delayed on several occasions. Both countries are still years away from starting to operate the facilities. 

The JRC Report does not mention the aspect of transportation in its presentation of the life cycle analysis. This would have been necessary for a conclusive overall presentation of all the aspects of nuclear power.

the JRC Report states that a closed fuel cycle provides the advantage of significantly reducing the space required for a deep geological repository for HLW. It is necessary to add here that not only the volume, but also the decay heat at the time of disposing of the waste is relevant for the size of the disposal facility (KOM, 2016, p. 227). Additional low- and intermediate-level waste would also be produced and this would increase the disposal volume.

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’” 2021

“”………… 4.6 Ionising radiation and its impacts on people’s health and the environment during all the life cycle phases (apart from disposal and transportation)The JRC Report largely restricts itself in Part A 3.4 to the “impact of ionizing radiation on human health” (JRC Report, Part A 3.4.1, p. 167ff) and the environment (JRC Report, Part A 3.4.2, p. 173ff). The impact of emissions of non-radioactive substances is only considered at one point (publication [3.4-1]). ……..


The figures quoted for the radiation exposure of human beings in Part A 3.4.1 of the JRC Report are plausible. It is correct that human exposure to radiation as a result of the civil use of radioactive materials and ionising radiation is low in comparison with radiation exposure from natural sources and its range of variation. However, the report does not match the latest findings in radiation protection when specifying average effective doses per head of the population for nuclear facilities and installations. According to the latest recommendations of the International Commission on Radiological Protection (ICRP), the so-called “representative person” in the sense of the ICRP has to be considered an individual in the population, who is exposed to higher levels of radiation because of his or her lifestyle habits. 

5 Criterion 2 in the Taxonomy Regulation – the DNSH criteria: disposal of radioactive waste, transportation, research and development The subject of disposing of radioactive waste is considered in this section. It professionally examines the scientific statements in the JRC Report about the topics of storage (section 5.1 of this expert response), disposing of low- and intermediate-level radioactive waste (section 5.2), disposing of high-level radioactive waste (section 5.3), transportation (section 5.4) and research and development (section 5.5). Sub-headlines have been used to interconnect the subsections 


……….. The JRC Report does not adequately consider the fact that no successful, deep geological disposal of high-level radioactive waste, including the permanent seal, has yet been introduced anywhere in the world. 


5.1 Interim storage of radioactive waste The JRC Report generally fails to provide any basis for the findings that are listed in the Executive Summary of the report related to storing radioactive waste. As a result, questions must be raised about the transparency of the conclusions that are drawn

…………..  the assessment of interim storage consistently takes place according to the standard adopted by the JRC, which, however, is inadequate from an expert point of view. For beyond design basis events it is impossible to exclude that uncontrolled discharges of radioactive substances and therefore considerable effects on the environment may occur through incidents and accidents or by some other intrusion involving third parties (e.g. terrorist attacks) when operating storage facilities; a risk therefore remains. A holistic assessment of using nuclear energy must therefore include a risk assessment related to these events too (cf. section 2.1 and 2.2.1 of this expert response). 


……….  The JRC Report briefly mentions dry and wet storage as storage options for high-level radioactive waste. Whereas Germany is exclusively using dry storage for the purpose of storage of waste until it is taken to a repository, a large proportion of the spent fuel worldwide is stored in wet storage facilities (IAEA, 1999). However, the report fails to provide any detailed discussion of the specific safety features of these technologies. Wet storage facilities, for example, require active cooling systems. If any external factors influence the building structures, the safety level provided by the cask barrier is missing in external wet storage facilities when compared to dry storage. This applies not least to the wet storage of spent MOX fuel elements mentioned in the JRC Report which might be stored waiting for further developed reactor systems, the implementation of the so-called closed fuel cycle and transmutation. As the successful introduction of these technologies is uncertain, however, (cf. section 3.1.1. and 5.5), questions must be asked about the permanent storage of these high-level radioactive substances too. The detailed descriptions in Part B 4.1, p. 181f and 4.2, p. 182ff of the JRC R 

……………....  5.2 Disposing of low- and intermediate-level radioactive waste


  5.2 Disposing of low- and intermediate-level radioactive waste With regard to the final disposal of low and intermediate level radioactive waste, incomprehensible or incomplete technical statements by the JRC were noticed. The same applies to the technical evaluation criteria developed by the JRC……………


The need for deep geological repositories for LLW and institutional checks 

The statement (JRC Report, Part B 5.1, p. 244) that there is no need to emplace LLW in deep geological disposal facilities is incrompehensible. Near surface repositories are believed to be more susceptible to human intrusion than deep geological repositories (IAEA, 2012). Aspects like robustness, accessibility, protection, loss of knowledge etc. must also be taken into account when judging their safety. The institutional checks that are normally envisaged for near surface repositories for a period of 300 years cannot be generally guaranteed either. The reason for this is that no scientific basis exists to forecast human behaviour and social actions (NAS, 1995: AKS, 2008; Seitz et al., 2016). 


. The “Storage of High-Level Radioactive Waste” committee has concluded with regard to the disposal of this waste that long-term storage near surface disposal is not an acceptable option for handling radioactive waste in a verifiably safe manner in the long term because of the unreliable prediciton regarding social and political developments, the danger of accidents (e.g. caused by a lack of maintenance), and attacks caused by war or terrorism, the risk of proliferation, the huge organisational effort and financial expenditure for future generations and climate uncertainties (KOM, 2016). This conclusion on the long-term interim storage of high-level radioactive waste at or near the surface can in principle also be transferred to near surface repositories for low- and intermediate level waste with regard to the predictability of the development of a facility. 

……………………….  In the end, the example of Asse II underlines the importance of regular critical safety checks for nuclear disposal facilities and the need to place greater importance on safety than economic considerations. The example also illustrates the enormous financial and social follow-up costs of incorrect decisions that have been taken in the field of nuclear disposal. Nowadays the retrievability and recoverability of radioactive waste are a condition to fulfil the state-of-the-art of science and technology concerning the disposal of radioactive waste. This shows that these kinds of incorrect developments or decisions must be viewed as a risk factor when using nuclear energy 


Measures against human intrusion (HI) We can largely support the statements in the JRC Report about the measures to counter human intrusion into an enclosed repository (JRC Report, Part B 5.1, p. 246). However, the topic is not adequately treated with regard to the DNSH criteria (cf. section 2.2.5). 

Technical screening criteria Gap for VLLW and long-lived LLW and ILW …………..  very low-level waste (VLLW) and long-lived LLW and ILW. The JRC Report contains a gap in the TSCs for these waste classes. 


Differences between deep geological and near surface repositories ……………….  A separate consideration of the specific TSC for the near surface disposal and the geological disposal of radioactive waste therefore appears to be technically necessary. However, this was not considered by the JRC report. 

Compatibility of the TSCs for HLW with those for LLW The JRC Report (Part A 3.3.8.9, p. 165ff) states that activities, including those related to disposing of radioactive waste, do not cause any significant damage to people’s health or the environment. This is true, provided that the industrial activities associated with it meet the TSCs. 


The TSCs for storing and disposing of HLW and spent fuel elements are outlined in Annex 4 of the JRC Report. The DNSH-related TSCs state, among other things, that the repository facility must guarantee that the waste is contained and isolated from the biosphere. This also applies if extreme natural phenomena occur such as earthquakes, tornadoes, floods or the loss of technical barriers. 


The JRC Report does not list any special TSCs for LLW and ILW and states that the TSCs developed for HLW and spent fuel elements are believed to be satisfactory (cf. JRC Report, Part A 5.7, p. 196f). The reasoning leading to this conclusion is not mentioned in the JRC Report and the statement is generally incorrect. If the TSCs for HLW are also used for LLW, there are doubts whether the aforementioned condition for complying with the TSCs, e.g. when considering extreme natural phenomena, is comprehensively met. The reason for this exists in possible differences about the robustness of the deep geological repositories envisaged for HLW and LLW in near surface repositories. The firm conclusion drawn in the JRC Report for disposing of low- and intermediate-level waste at near surface repositories – i.e. that no significant damage can occur to people’s health or the environment as a result – is therefore impossible to comprehend. 

5.3 Disposing of high-level radioactive waste Incomprehensible or incomplete statements made by the JRC regarding the disposal or low- and intermediatelevel radioactive waste are striking. The same applies to the technical assessment criteria developed by the JRC     


……  nuclear energy has been used for several decades, but there is still no repositoryfor high-level radioactive waste operating anywhere in the world. Responsibilities are therefore passed on to following generations and they are restricted in their freedom of choice. Section 6 of this expert response will deal with this matter in greater detail. 


Expert appraisal

 General results of the reviewThe JRC Report contains unfounded generalisations at many points. Conclusions are drawn from individual, selected examples and their global validity is assumed. Readers without any detailed specialist expertise will find it hard or impossible to recognise this. For example, the feasibility of disposing of other “waste” (CO2) in deep geological formations is transferred to the disposal of HLW in the report. However, the report does not mention the completely different risk potential, particularly over very long periods of time (more details available below). 


………..  The JRC presents the disposal of high-level radioactive waste as a completely resolved problem by citing the example of the disposal projects in Finland and France. This largely ignores the fact that the Finnish repository is still under construction and the licence application from the operational company has already been delayed on several occasions. Both countries are still years away from starting to operate the facilities. 

There is practically no successful operating experience for a repository for high-level radioactive waste anywhere. On the contrary, many countries have had experience with failed repository projects. 


Assessing the safety of a repository Based on selected results from safety assessments of repositories in Finland, Sweden and France, the JRC documents in Part B 5.2, p. 249ff of its report a fragmentary assessment of radiological safety at a deep geological repository. These countries have the technical and financial resources to complete the disposal of high-level radioactive waste in geological repositories. The capabilities and the needs of smaller countries, which possibly depend on outside help to resolve their repository issue, are not mentioned. The report also restricts itself to only two potential host rocks  (crystalline in Finland and Sweden and clay in France). Other possible host rocks like salt are missing. The report is also incomplete in the sense that, in contrast to storage, it only considers the time after the repository has been sealed: i.e. there is no discussion about assessing radiological safety during the operational phase. The safety criteria discussed only represent a selection of general requirements. Other potentially relevant requirements are not discussed.  

  A lack of empirical data

The JRC Report correctly states on page 243, Part B 5 that “…there is no empirical evidence generated by a radioactive waste disposal facility that has gone through all the three stages (preoperational, operational, and post-closure) for the entire time frame foreseen (up to a hundred thousand years for a deep geological repository)”. It should also be noted that only one repository for HLW is currently being built around the world. 


The JRC Report sketches a simplified and very optimistic picture of the process of introducing a national DGR (Deep Geological Repository) in Part B 5.2.3. The examples of programmes that have failed or been halted in the past (e.g. in Great Britain, Germany, Switzerland and the USA) are not mentioned. Ideally, this kind of report should also discuss that there are inherent risks that a disposal programme may completely fail because of social, technological, political or economic problems or can be greatly delayed. 

Part B 5 of the JRC Report states, “…the safety of 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 under all circumstances below the required limits”. As there is still no repository with an operational license for HLW, the use of the word “is” here is incorrect. The relevant assessments in the context of a safety case are currently still involved in various licensing processes, depending on the national regulations, even for the HLW repository projects that are more advanced (in Finland, Sweden and France). 


A focus on normal operations of disposal facilites and ignoring uncertainties The role of unexpected events is restricted in the JRC Report and not fully discussed. The report does not provide any analysis of consequences from potential accidents, particularly for the operating phase of geological disposal. This is surprising, since, when analysing the life cycle, one major aspect is whether an activity creates any threats that can be prevented or mitigated. This omission is viewed as an important shortcoming, as unexpected events cannot by definition be completely prevented and if they occur, accidents or incidents can trigger considerable radioactive contamination (cf. sections 2.1 and 2.2.1).      ………….

Unintentional human intrusion The topic of unintentional human intrusion is not appropriately discussed in the JRC Report. The likelihood for this kind of event, which cannot be ruled out, and associated radiological consequences in the light of the long isolation periods that are required for the radioactive waste are neither treated nor appropriately considered when assessing the TSCs and the DNSH criteria. Cf. sections 2.2.2 and 2.2.5 of this expert response. 


Non-radiological effects The discussion of potentially damaging, non-radiological effects of geological disposal of spent fuel elements and HLW (JRC Report, Part A 3.3.8.6, p. 162f) is conducted on the basis of a selection of results from the Swedish environmental impact assessment. It is implicitly assumed that this document contains an assessment that is generally representative for each kind of repository at each place (e.g. climate, geography, biosphere etc.). No reason for this assumption is provided. For example, the possible effects on water resources also depend on the specific climate, land use and hydrological conditions (Öko, 2015). This is related to the problem that has already been described above – i.e. restricted practical experience in relation to operating a deep geological repository.     

The JRC provides a confusing comparison between carbon (dioxide) capture and storage (CCS) and disposing of radioactive waste in Part B 5, p. 336ff of the JRC Report. The comparison between CCS and disposing of radioactive material is only possible to a certain extent, as a different risk is caused by disposing of CO2 at a great depth. In other respects, the technical concepts for both types of disposal are completely different and are associated with very specific requirements and risks. The safety provisions for both types of disposal are therefore different too (cf. JRC Report, Executive Summary, p. 8, third indent). 


Barrier system 

The JRC Report contains oversimplified statements about the reliability of the barrier system, which can lead to fundamental misunderstandings, as complex expert knowledge is necessary to assess them. For example, Part B 5.2.2, p. 250 of the JRC Report simply states the following, “Chemical and mechanical interactions between natural and engineered barriers will occur”, while not explaining in greater detail the form that this interaction will take. 


The Executive Summary also contains a similarly simplified and significant statement, “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.” This is an oversimplified and generalised description. …………

Part A, 3.3.8.5, p. 162 of the JRC Report makes an oversimplified and final statement about the longterm reliability of the barrier system, “Long term post-closure safety will be achieved by means of a system of passive barriers…”. Statements about the long-term safety in the post-closure phase are made here without describing or questioning possible relevant developments, which have an effect on the reliability of a repository. As for the long-term safety of a repository, appropriate statements must always be considered in relation to the regulatory requirements and general conditions underlying them. It should be noted that, even in very favourable geological situations, uncertainties still exist and cannot be completely ruled out (NEA, 1995 and 2012). 


Discharge of radionuclides Imprecise statements are made about the possible discharge of radionuclides from the repository into the biosphere. For example, “No radiologically relevant release or impact to the public is expected…“ (JRC Report, Part A 3.3.8.5, p. 161 – operating phase) or “and [radionuclides] will never exceed the limit below which they can cause no harm” (JRC Report, Part B 5, p. 241 – phase after the closure of the repository). The first statement is incomplete and oversimplified – the risks associated with potential accidents (e.g. a canister drop, fire, criticality) or improper use of the fissionable material (e.g. a terror attack, theft etc.) – are not assessed or not finally assessed. The risk assessment here also seems to have been taken out of context, but the conclusions are included in the overall assessment. The reasoning here is not underpinned by references to sources either.      

……..   The statement in the JRC Report “and will never exceed the limit below which they can cause no harm” is therefore contradictory. The report at least discusses the impacts of low doses of radiation. However, the arguments should therefore be presented in a more careful manner. Damage to people’s health cannot be absolutely excluded (ICRP, 2013; DoReMi, 2016). 


An imprecise and incorrect statement is made in Part A, 3.3.8. p. 165 of the JRC Report. “The deep geological disposal facility aims at isolating and containing the radioactive waste until its radioactivity decays to harmless levels.” According to the relevant period in the rules in Sweden (100,000 years), the waste is still harmful (JRC Report, Figure 2.4-1). The report contradicts itself here


  Disposing of radioactive waste through dilution and discharge
 Part B 3, p. 224 of the JRC Report states, “For certain types of waste with a low concentration of activity, typically gaseous and liquid effluents the management strategy is its dilution and release to the environment”. The JRC Report does not deal with the subject matter any further and justifies this as follows: “This is carried out under regulatory control following strict procedures ensuring that releases are below authorised limits, and it is outside the scope of this section.“ (JRC Report, Part B 3, p. 224). The JRC overlooks the fact that this disposal method is excluded by law in Germany, for example. Section 61 Para. 3 of the Radiation Protection Act forbids the deliberate dilution of any radioactive waste. 

Post-closure phase A summary is provided in Part A 3.3.8.9, p. 167 of the JRC Report, “In the light of the above analysis it can be concluded that activities related to the storage & disposal of technological & radioactive waste, as well as spent nuclear fuel do not pose significant harm to human health or to the environment.” This statement is not supported by the discussions presented in Part A 3 of the JRC Report (or the following chapters).    …….

   Technical screening criteria The process of developing the technical screening criteria (TSCs) has not been completed. Part A 5.1, p. 190f of the JRC Report, however, argues as if they were complete, but the relevant sources are missing, including those related to international experience. Any use of the TSCs for a final assessment of taxonomy criteria is not possible, or at least problematic ………

5.4 Transportation The JRC Report does not mention the aspect of transportation in its presentation of the life cycle analysis. This would have been necessary for a conclusive overall presentation of all the aspects of nuclear power. ………

this narrow analysis fails to do justice to the subject, as has been pointed out on several occasions above. Beyond design basis accidents or beyond-design threat interventions by third parties during transport cannot be completely ruled our; thus the corresponding risks cannot be excluded neither, even if international rules are followed. 


5.5 Research and development ..

General results of the review …………….  The JRC Report does not consider either that the enormous expenditure on research in the field of disposal underlines the associated uncertainties and casts doubt on whether using nuclear energy meets the taxonomy criteria (cf. section 2.2.3). Connection between storage, the operating phase and the post-closure phase The JRC Report fails to deal with one aspect that plays an important role in current research: the connection between storage, the operating phase and the post-closure phase (“integrated safety case”) and the relevance of this connection for safety within the time scale in question (IAEA, 2016a; IAEA 2016b; IGSC, 2008; NEA, 2016; GRS, 2020).    
….

Uncertainties Uncertainties are addressed in relation to the current focus of research and development. It should be pointed out in this connection that there will be a number of uncertainties that cannot be reduced or completely resolved (GRS, 2018). Research and development work needs to start at an early stage on how to handle these uncertainties or take them into account (cf. sections 2.2.2 and 2.2.3 of this expert response) 


Transferability of the functionality of the barriers to long periods of time ………


Scope of the research programme and pure research …

P&T and the so-called “closed fuel cycle” Research has been conducted for a long time on how to separate the existing and accruing radioactive waste into various waste streams using suitable procedures and transfer them to less long-lived radionuclides through nuclear physics conversion processes. This approach, which is called partitioning and transmutation (P&T), provides a number of benefits, according to the JRC Report. However, the underlying technologies still do not exist. Whether and when they could be available for use on a large scale is completely unknown. Giving less priority to disposal and transporting the waste to long-term storage sites near the surface until the P&T technology has developed far enough for large-scale use would be necessary for this.   …………..

  According to the state-of-the-art of science and technology, P&T programmes only seem practicable for treating spent fuel rods from power reactors, but not for waste that has already been vitrified.

 • A P&T concept requires a large number of nuclear facilities and long-term operations there. The safety risks caused by operating nuclear facilities in the long term would have to be accommodated in a P&T programme.

 • The nuclear facilities required for P&T are not available on such a large technical scale.

 • Many decades of research and development work would be necessary before introducing any P&T programme.

• It is still unclear whether it will be possible to achieve the necessary technical development stage for implementing a P&T programme on a large scale.

• Whatever happens, a repository for high-level radioactive waste will still be needed. Operating nuclear facilities within a P&T programme in the long term would give rise to proliferation risks.  

The list of critical comments illustrates that research into P&T is also associated with the possibility that the original intention or goal of this approach might fail. Even if this technology could be used in future, it gives rise to other risks, which would need to be considered in the light of the risks of disposal without allowing for P&T.


……………….. the JRC Report states that a closed fuel cycle provides the advantage of significantly reducing the space required for a deep geological repository for HLW. It is necessary to add here that not only the volume, but also the decay heat at the time of disposing of the waste is relevant for the size of the disposal facility (KOM, 2016, p. 227). Additional low- and intermediate-level waste would also be produced and this would increase the disposal volume. ……….…………….. https://www.base.bund.de/SharedDocs/Downloads/BASE/EN/reports/2021-06-30_base-expert-response-jrc-report.pdf.pdf?__blob=publicationFile&v=6

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September 13, 2021 - Posted by | Uncategorized

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