ASN Report 2020

be assessed by ASN at the next periodic safety reviews. Lastly, there is no reason to perform stress tests on facilities which are nearing the end of decommissioning and will soon be delicensed. 3.3  The periodic safety reviews of facilities undergoing decommissioning The conformity check aims to ensure that the changes in the facility due to the decommissioning work or to ageing do not call into question its conformity with the provisions of the regulatory texts and its technical baseline requirements. Given the diversity of the facilities and the situations involved, each periodic safety review must be individually examined by ASN. ASN applies a method of examination that is adapted to the risks inherent to the facilities: some facilities warrant particular attention owing to the risks they present and may be reviewed by the Advisory Committee for Decommissioning (GPDEM) set up in 2018. For others presenting a lower level of risk, the extent of the inspections and examinations is adapted accordingly. When a facility has been finally shut down and its decom­ missioning file has to be transmitted to the Minister in charge of nuclear safety and ASN, simultaneous filing of the decom­ missioning file and the periodic safety review conclusions report is considered to be good practice. The two files can thus be reviewed at the same time on the basis of technically consistent scenarios. In 2020, ASN continued the examination of the safety review reports of some 20 facilities undergoing decommissioning that have been received since 2015. Inspections on the topic of the periodic safety review took place in 2020 on three facilities under­ going decommissioning. These inspections are used to check the means implemented by the licensee to carry out its review, as well as compliance with the action plan resulting from its conclusions. They led to several requests for corrective action and additional information. 3.4 F inancing decommissioning: ASN’s opinion on the triennial reports The regulatory framework for ring-fencing the funds necessary for management of the long-term decommissioning and waste management expenses is presented in point 1.4. On 13 August 2020, ASN published opinion CODEP-CLG- 2020- 040124 of 6 August 2020 relative to the examination of the three‑yearly reports submitted in 2019 by the licensees, concerning the accounts closed at the end of 2018. ASN notes that the scope of evaluation of the expenses remains incomplete and omits certain high-stake financial operations. More specifically, the licensees are vague about the financing of the decommissioning preparation operations, and do not take into account in their cost assessment the characterisation and management of pollution of soils and structures, the complete clean-out and remediation operations, or the costs of works to maintain the facilities over their entire lifetime. ASN also underlines that the assumptions adopted for evaluating the complete costs must be reassessed in order to show reasonable caution in the scheduling of the decommissioning projects and programmes, taking account of the risks related to the unavailability of storage, treatment and disposal facilities. Furthermore, ASN considers that the project costs at completion must be more detailed and better substantiated, particularly in the light of the observed state of progress of the projects, as falling behind in the decommissioning schedules can raise the costs at completion. Lastly, ASN considers that the proposed assumptions for evaluating the management of radioactive material and wastes are not sufficiently conservative. They do not systematically include either the management of legacy waste locations or the uncertainties regarding the management of LLW-LL waste. Similarly, the licensees tend to overestimate the prospects of reusing certain materials and to underestimate the actions necessary for bituminised waste. In 2020, ASN examined the update of these three-yearly reports and sent its observations to the Ministry responsible for the environment in 2021. 4. Assessment of the licensees’ decommissioning strategies Given that numerous facilities have been shut down for several decades, with partial loss of knowledge of their operating histories, ageing structures and in some cases large quantities of waste still present, the advancement of decommissioning projects is one of the major issues for the safety of shut down facilities. Yet ASN has noted that the majority of the decommissioning projects are falling significantly behind schedule. ASN therefore asks the CEA, EDF and Orano to periodically present their decommissioning and radioactive waste management strategies, thereby providing an integrated view of the decommissioning projects and the disposal routes that are available or to be created for the waste resulting from the decommissioning operations. As far as decommissioning is concerned, the licensees must jus­ tify the priority operations, principally through safety analyses. This prioritisation provides a means of checking that even if some projects are substantially behind schedule, the most significant resources will be devoted to operations with higher risk implications. With regard to radioactive waste management, ASN checks the consistency with the regulatory framework and the guidelines of the French National Radioactive Materials and Waste Management Plan (PNGMDR). ASN examines with particular attention the defences against unforeseen events on a waste management facility and the plausibility of the time frames announced by the licensees. It ensures that the licensees look ahead to the safety studies of packages and the feasibility of the packaging processes. ASN also checks the availability of the envisaged waste management routes and the support means (transport packages, treatment and storage facilities, etc.) which in practise govern the sustainability of the decommissioning strategy. In 2019, ASN issued a position statement on the CEA’s decom­ missioning and waste management strategy. In 2020, ASN issued a resolution requiring EDF to submit the decommissioning files for the GCRs and the framing of the operations to be carried out in the coming years (see Notable Events 2020 in the introduction to this report) given the examination of the change of 348 ASN Report on the state of nuclear safety and radiation protection in France in 2020 13 – DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS