ASN Report 2020

3.5  Information about ASN’s regulatory activity ASN attaches importance to coordinating Government departments and informs the other administration departments concerned of its inspection programme, the follow-up to its inspections, the penalties imposed on the licensees and any significant events. To ensure that its inspection work is transparent, ASN informs the public by placing the following on its website asn.fr : ∙ its resolutions and decisions; ∙ inspection follow-up letters for all the activities it inspects; ∙ approvals and accreditations it issues or rejects; ∙ incident notifications; ∙ reactor outage summaries; ∙ thematic publications. 4. Monitoring the impact of nuclear activities and radioactivity in the environment 4.1  Monitoring discharges and the environmental and health impact of nuclear activities 4.1.1 Monitoring of discharges The BNI Order of 7 February 2012 and amended ASN resolution 2013-DC-0360 of 16 July 2013, set the general requirements applicable to any BNI with regard to their water intake and discharges. In addition to these provisions, in its resolution 2017- DC-0588 of 6 April 2017, ASN defined the conditions for water intake and consumption, effluent discharge and environmental monitoring applicable specifically to PWRs. This resolution was approved by the Minister for Ecological and Solidarity-based Transition in an Order of 14 June 2017. Apart from the above-mentioned general provisions, ASN resolutions set specific requirements for each facility, more particularly the water intake and discharge limits. Monitoring discharges from BNIs The monitoring of discharges from an installation is essentially the responsibility of the licensee. The ASN requirements regulating discharges stipulate the minimum checks that the licensee is required to carry out. This monitoring focuses on the liquid and gaseous effluents (monitoring of the activity of discharges, characterisation of certain effluents prior to discharge, etc.) and on the environment around the facility (checks during discharge, samples of air, water, milk, grass, etc.). The results of this monitoring are recorded in registers transmitted to ASN every month. The BNI licensees also regularly transmit a certain number of discharge samples to an independent laboratory for cross- analysis. The results of these “cross-checks” are sent to ASN. This programme of cross-checks defined by ASN is a way of ensuring that the accuracy of the measurements taken by the licensee laboratories is maintained over time. The inspections carried out by ASN Through dedicated inspections, ASN ensures that the licensees actually comply with the regulations binding on them with regard to the management of discharges and the environmental and health impact of their facilities. Every year, it carries out about 90 inspections of this type, split into three topics: ∙ prevention of pollution and management of detrimental effects; ∙ water intake and effluent discharge, monitoring of discharges and the environment; ∙ waste management. Each of these topics covers both radiological and non-radiological aspects. Every year, ASN carries out 10 to 20 inspections with sampling and measurement. They are generally unannounced and are run with the support of specialist, independent laboratories appointed by ASN. Effluent and environmental samples are taken for radiological and chemical analyses. Finally, every year, ASN carries out several reinforced inspections which aim to check the organisation put into place by the licensee to protect the environment; the scope of the inspection is then broadened to cover all of the above-mentioned topics. Within this context, Operating Experience Feedback Following the fire that occurred on 26 September 2019 in the Lubrizol facility in Rouen, ASN initiated a number of actions with the Basic Nuclear Installations (BNIs) in order to learn lessons from this accident and, if necessary, initiate reinforcement of the measures to prevent and control non-radiological risks in BNIs. More specifically, ASN sent a letter to all licensees on 28 October 2019, asking them to make a review of the adequacy and effectiveness of the various barriers in place inside their facilities to control risks related to the storage of hazardous substances, as well as their good knowledge of the nature and quantities of the hazardous substances present. In addition to examining the answers submitted by the licensees, ASN carried out inspections on this topic, notably involving simulation exercises for the intervention teams. All the inspections scheduled on this topic could not be performed in 2020 owing to the health crisis and this inspection campaign will continue in 2021. At the same time, ASN is examining the need to reinforce the regulatory requirements during the work to revise the BNI Order of 7 February 2012 and the transposition to BNIs of the European Parliament and Council Directive 2012/18/EU of 4 July 2012 on the control of major-accident hazards involving dangerous substances, known as the “Seveso 3” Directive. The reinforced provisions will notably concern the implementation of risk control measures and the data to be provided by the licensees in the safety case with regard to the control of non-radiological hazards. Finally, together with the Ministries that were involved in managing the fire at the Lubrizol facility, the Steering Committee for management of the post-accident phase (Codirpa) is examining what lessons can be learned. ASN Report on the state of nuclear safety and radiation protection in France in 2020 161 03 – REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION 03