ASN Report 2020

qualified personality and brings together, in addition to the legacy members of the pluralistic working group mentioned in chapter 2, elected officials and representatives of the regional authorities. ASN participates actively in the guidelines commission – albeit without voting rights – to provide its guidance on the safety and radiation protection issues. Implementation of the plan is then followed up at periodic meetings of the PNGMDR working group jointly chaired by ASN and the DGEC. In 2020, ASN moreover assessed the studies submitted for the PNGMDR 2016-2018. For the preparation of the 5th PNGMDR, ASN has thus issued its opinions on the radioactive material and waste management routes in which it sets out a number of recommendations. It will issue an opinion on the regulatory texts adopted in application of the plan in the light of the nuclear safety and radiation protection challenges. 1.3  Long-term management of waste – existing or projected disposal facilities 1.3.1 Very low-level waste Very low-level (VLL) waste comes essentially from the operation, maintenance and decommissioning of nuclear facilities. It consists mainly of inert waste (rubble, earth, sand) and metal waste. Its specific activity is usually less than 100 Bq/g (becquerels per gram) and can even be below the detection threshold of certain measuring devices. The Cires includes a VLL waste disposal facility. This facility, which has ICPE status, has been operational since August 2003. At end of 2020, Cires held 412,258 m 3 of VLL waste, which represents 63% of its authorised capacity. According to the national inventory produced by Andra, the quantity of VLL waste resulting from decommissioning of the existing nuclear facilities will be about 2,200,000 m 3 . According to current forecasts, the facility could be filled to maximum capacity around 2028. Andra is currently working on the Acaci project, which aims to increase the facility’s authorised capacity to more than 900,000 m 3 , without changing its ground surface area. In its opinion 2020-AV-0356 of 30 June 2020 on the management of VLL waste, ASN calls for the continuation and extension of the work undertaken in the 2016-2018 edition of the PNGMDR with the aim of improving current management methods and developing complementary management solutions which remain to be devised and implemented. ASN reaffirms that the foundations of VLL waste management must be based on the place of origin of the waste and guarantee its traceability from production through to disposal, with the exception of metallic VLL waste that is to be recycled, thanks to specific routes as stated in the abovementioned resolution of 21 February 2020. The recycling of certain types of waste which will be produced in large volumes, along with the setting up of a specific oversight framework for a metal recycling facility, is encouraged, consistently with the waste management hierarchy defined in the Environment Code. ASN recommends in particular the operational implementation of a rubble recycling route for use by the disposal facilities, and continuation of the metals recycling facility project, with the setting up of a specific oversight framework for this facility. Furthermore, ASN considers it necessary for all the stakeholders, particularly the representatives of the regions concerned or likely to be concerned, to be more closely involved in the defining of the VLL waste management solutions. Lastly, as saturation of the current disposal capacities for VLL waste could restrict the entire route and delay the decom­ missioning projects, ASN considers that solutions must be put forward to cater for the situation where a new centralised disposal facility is not available. It recommends that the studies for putting in place additional disposal facilities, whether centralised or decentralised, be continued and that the government should clarify Andra’s responsibility in this respect. 1.3.2 Low and intermediate-level, short-lived waste Low-level and intermediate-level short-lived waste (LL/ILW-SL) – in which the radioactivity comes primarily from radionuclides with a half-life of less than 31 years – comes essentially from the operation of nuclear facilities and more specifically as a result of maintenance work (clothing, tools, filters, etc.). It can also come from the post-operational clean-out and decommissioning of these facilities. The majority of LL/ILW-SL waste is placed in surface disposal facilities operated by Andra. Once these facilities are closed, they are monitored for a period set by convention at 300 years. The facility safety analysis reports – which are updated periodically, including during the monitoring phase – must show The role of ASN in waste management The public authorities, and ASN in particular, are attentive to the fact that there must be a management route for all waste and that each waste management step is carried out under safe conditions. ASN thus considers that the development of management routes appropriate to each waste category is fundamental and that any delay in the search for long-term waste disposal solutions will increase the volume and size of the storage areas in the facilities and the inherent risks. ASN takes care, particularly within the framework of the French National Radioactive Material and Waste Management Plan (PNGMDR) but also by inspecting the facilities and regularly assessing the licensees’ waste management strategy, to ensure that the systemmade up by all these routes is complete, safe and coherent. This approach must take into consideration all the issues of safety, radiation protection, minimising waste volume and toxicity, while ensuring satisfactory traceability. Finally, ASN considers that this management approach must be conducted in a manner that is transparent for the public and involves all the stakeholders, in a framework that fosters the expression of different opinions. The PNGMDR is drawn up by the Ministry of Ecological Transition. The Ministry has opted, in the light of the public debate of 2019, to rely on a pluralistic “guidance commission”, chaired by an independent qualified person, in which ASN participates. Monitoring of the technical and operational implementation of the PNGMDR is still ensured by a pluralistic working group co-chaired by ASN and the General Directorate for Energy and the Climate (DGEC), as described in chapter 2. ASN also publishes the PNGMDR, its synthesis, the minutes of the abovementioned working group’s meetings, the studies required by the plan and the associated ASN opinions on its website. 360 ASN Report on the state of nuclear safety and radiation protection in France in 2020 14 – RADIOACTIVE WASTE AND CONTAMINATED SITES AND SOILS