ASN Report 2020

Installations in operation Faced with the ageing of its facilities in operation and the uncertainty surrounding the projects to replace some of them, the CEA developed a medium/long-term strategy in 2019 concerning the utilisation of its experimental civil nuclear research facilities and its waste and material management facilities. The first conclusions show the need to streamline and optimise the existing facilities, along with significant renovation work and even the construction of new facilities. ASN considers that this prioritisation is legitimate from the safety standpoint and that the CEA must use it to identify clear action plans and precisely formalise the options it has taken (abandoning or optimising operation, work to be undertaken, etc.). Facilities undergoing decommissioning In 2019, ASN and the Defence Nuclear Safety Authority (ASND) underlined the in-depth and pertinent review by the CEA of its decommissioning and radioactive waste and materials management strategy, its prioritisation of operations, the human resources allocated and the efficiency of its organisation, while examining the resources devoted to these operations. In 2020, the Authorities found that this strategy had substan­ tially changed, with numerous postponements, scope reductions or even some projects being abandoned. Certain deadlines were pushed back by several decades, with no adequate justif ication, even though they concern ordinary decommissioning projects, based on sound operating experience feedback (notably the decommissioning of the research reactors). A number of responses to structural requests from ASN and ASND regarding this decommissioning strategy were sent belatedly in 2020. These responses will need to be clarified in 2021 and additional exchanges between the CEA and the Authorities will be needed in order to improve oversight of the management of decommissioning and RCD projects that are priorities in terms of safety. With regard to control of the processing of its effluents and the management of its waste, its spent fuels and its materials, along with the corresponding transport operations, implementation of the strategy is expected within the time-frame announced by the CEA; the Authorities drew the CEA’s attention to the need for particular vigilance on these points in 2019, in particular for the unique installations, the unavailability of which could weaken the process as a whole. Firm answers to the Authorities’ questions regarding the f inancial resources allocated to these cross-cutting projects, the credibility of the performance time- frames and the progress made have yet to be received. Radioactive waste management The operation of radioactive waste management support facilities is satisfactory. In 2020, ASN observed improvements in the zoning, signage and tidiness of the collection areas for these wastes. The CEAmust however remain vigilant as to compliance with the storage times for certain waste in its facilities. ASN also underlines the implementation of a new organisation in 2020 devoted to the management of radioactive waste which will eventually allow improved communication and greater sharing of resources, with harmonisation of practices among the CEA centres. Finally, ASN notes that the provisions of the protocol between the National Radioactive Waste Management Agency (Andra) and the CEA regarding Andra’s monitoring of the CEA waste packages liable to be disposed of in Cigéo are overly restrictive of Andra’s scope of action and therefore fail to fully meet the provisions of ASN resolution 2017-DC-0587. The conformity of the facilities As in 2019, ASN observes the efforts made to improve the conformity of the facilities during the periodic safety reviews, notably an improvement in the scheduling of the compliance work designed to secure the commitments made by the CEA. However, even if the CEA has supplied most of the additional studies for correct assessment of the conformity of its facilities, ASN notes that not all of the weaknesses identified in the safety review reports, submitted since the end of 2017, have as yet undergone compliance work. This situation is particularly noteworthy for facilities in which activities have ceased and with low potential safety implications. Even if the CEA attributes these delays to the health context in 2020, ASN observes that the postponements can be up to several years. Management of deviations The management of deviations within the CEA facilities is on the whole satisfactory. In 2020, the CEA continued to deploy a monitoring tool common to all the centres, and also modif ied its ranking of deviations, including a third level, to allow graded processing more compatible with the actual issues. No significant event exceeded level 1 on the INES scale. The analysis of their causes regularly reveals a technical deficiency (related to ageing or obsolescence) or an organisational or human cause (related to incorrect transposition of safety requirements in the operational documentation or to activity scheduling). ASN notes that the events are correctly dealt with in the facilities. The CEA must however modify its organisation so that the analysis of the generic nature of a signif icant event, carried out by the head office departments, is more robust and more operational (consultation of the CEA centres and top-down and bottom-up information). In addition, for the analysis of the organisational causes, improved traceability in the significant event reports is required. Finally, ASN underlines the quality of the experience feedback sheets produced by the head office departments for the centres and the nuclear facilities. It encourages the CEA to take measures to ensure that the actions def ined in these sheets are effectively applied in the BNIs. Change management For many years now, the CEA has applied a change man­ agement system that is on the whole satisfactory, particularly through the quality of the files submitted to ASN when applying for authorisations for noteworthy changes. ASN also observes that the changes made in the f ield do effectively correspond to the information provided by the CEA in its authorisation applications. Maintenance and the scheduling of periodic inspections and tests Maintenance work and the scheduling of the periodic inspections and tests, their performance and their monitoring within the CEA facilities are on the whole satisfactory. As these operations are generally subcontracted, the CEA must remain attentive to the level of technical competence. Moreover, ASN still observes disparities between the facilities on these two subjects. In addition, the traceability of the inspections performed must be further improved. ASN also expects the CEA to implement a harmonised ageing and obsolescence management strategy for all its facilities, because, for the facilities as a whole, ageing is often only managed through the periodic inspections and tests. Outside contractors ASN observes that the CEA’s monitoring of outside contractors has been stepped up over the last few years, particularly by 18 ASN Report on the state of nuclear safety and radiation protection in France in 2020 ASN ASSESSMENTS PER LICENSEE AND BY AREA OF ACTIVITY