ASN REPORT on the state of nuclear safety and radiation protection in France in 2021
The French Nuclear Safety Authority presents its report on the state of nuclear safety and radiation protection in France in 2021. This report is required by Article L. 592-31 of the Environment Code. It was submitted to the President of the Republic, the Prime Minister and the Presidents of the Senate and the National Assembly and transmitted to the Parliamentary Office for the Evaluation of Scientific and Technological Choices, pursuant to the above-mentioned Article.
THE FRENCH NUCLEAR SAFETY AUTHORITY ROLES OPERATIONS KEY FIGURES ASN ORGANISATION CHART ASN was created by the 13 June 2006 Nuclear Security and Transparency Act. It is an independent administrative Authority responsible for regulating civil nuclear activities in France. On behalf of the State, ASN ensures the oversight of nuclear safety and radiation protection to protect people and the environment. It informs the public and contributes to enlightened societal choices. ASN decides and acts with rigour and discernment: its aim is to exercise oversight that is recognised by the citizens and regarded internationally as a benchmark for good practice. 15 YEARS 2006 2021 ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2021
REGULATING ASN contributes to drafting regulations, by submitting its opinion to the Government on draft Decrees and Ministerial Orders, and by issuing technical regulations. It ensures that the regulations are clear, accessible and proportionate to the safety issues. AUTHORISING ASN examines all individual authorisation applications for nuclear facilities. It can grant all licenses and authorisations, with the exception of major authorisations for Basic Nuclear Installations (BNIs), such as creation and decommissioning. ASN also issues the licenses provided for in the Public Health Code concerning small-scale nuclear activities and issues licenses or approvals for radioactive substances transport operations. MONITORING ASN is responsible for ensuring compliance with the rules and requirements applicable to the facilities and activities within its f ield of competence. Since the Energy Transition for Green Growth Act of 17 August 2015, ASN’s roles now include protecting ionising radioactive sources against malicious acts. Inspection is ASN’s primary monitoring activity. More than 1,900 inspections were thus performed in 2021 in the f ields of nuclear safety and radiation protection. ASN has graded enforcement and penalty powers (formal notice, administrative f ines, daily f ines, ability to carry out seizure, take samples or require payment of a guarantee, etc.). The administrative f ine is the competence of the ASN Administrative Enforcement Committee, which complies with the principle of the separation of the examination and sentencing functions. INFORMING ASN reports on its activities to Parliament. It informs the public and the stakeholders (environmental protection associations, Local Information Committees, media, etc.) about its activities and the state of nuclear safety and radiation protection in France. ASN enables all members of the public to take part in the drafting of its decisions with an impact on the environment. It supports the actions of the Local Information Committees of the nuclear facilities. The asn.fr website is ASN’s main information channel. IN EMERGENCY SITUATIONS ASN monitors the steps taken by the licensee to make the facility safe. It informs the public and its foreign counterparts of the situation. ASN assists the Government. More particularly, it sends the competent Authorities its recommendations regarding the civil security measures to be taken. REGULATION AND MONITORING OF DIVERSIFIED ACTIVITIES AND FACILITIES Nuclear power plants, radioactive waste management, fabrication and reprocessing of nuclear fuel, packages of radioactive substances, medical facilities, research laboratories, industrial activities, etc. ASN monitors and regulates an extremely varied range of activities and facilities. This regulation covers: ∙ 56 nuclear reactors producing 70% of the electricity consumed in France, as well as the Flamanville EPR reactor under construction; ∙ about 80 other facilities participating in civil research activities, radioactive waste management activities or “fuel cycle” activities; ∙ 35 facilities which have been f inally shut down or are being decommissioned; ∙ several thousand facilities or activities using sources of ionising radiation for medical, industrial or research purposes; ∙ several hundred thousand shipments of radioactive substances performed annually in France. EXPERT SUPPORT When drawing up its decisions and regulations, ASN calls on outside technical expertise, in particular that of the French Institute for Radiation Protection and Nuclear Safety (IRSN). The ASN Chairman is a member of the IRSN Board. ASN also calls on the opinions and recommendations of its eight Advisory Committees of Experts, who come from a variety of scientific and technical backgrounds. THE FRENCH NUCLEAR SAFETY AUTHORITY ROLES
THE COMMISSION The Commission def ines ASN’s general policy regarding nuclear safety and radiation protection. It consists of f ive Commissioners, including the ASN Chairman, appointed for a term of 6 years(*). APPOINTED BY the President of the Republic APPOINTED BY the President of the Senate APPOINTED BY the President of the National Assembly (*) The Environment Code, modif ied by Act 2017-55 of 20 January 2017, introducing the general status of the independent administrative Authorities and the independent public Authorities, provides for the renewal of half of the ASN Commission, other than its Chairman, every three years. Decree 2019-190 of 14 March 2019 (codifying the provisions applicable to BNIs, the transport of radioactive substances and transparency in the nuclear f ield) sets out the relevant interim provisions and modif ies the duration of the mandates of three Commissioners. (**) By Decree of the President of the Republic dated 21 April 2021, Laure Tourjansky was appointed Commissioner for the remainder of the mandate of Lydie Évrard, called to other duties. (***) Administrative region headed by a Prefect. Impartiality The Commissioners perform their duties in complete impartiality and receive no instructions from either the Government or any other person or institution. Independence The Commissioners perform their duties on a full‑time basis. Their mandate is for a six‑year term. It is not renewable. The duties of a Commissioner can only be terminated in the case of impediment or resignation duly conf irmed by a majority of the Commissioners. The President of the Republic may also terminate the duties of any member of the Commission in the event of serious breach of his or her obligations. Competencies The Commission takes decisions and issues opinions, which are published in ASN’s Off icial Bulletin. The Commission def ines ASN's oversight policy. The Chairman appoints the ASN inspectors. The Commission decides whether to open an inquiry following an incident or accident. Every year, it presents Parliament with the ASN Report on the state of nuclear safety and radiation protection in France. Its Chairman reports on ASN activities to the competent committees of the National Assembly and of the Senate and to the Parliamentary Off ice for the Evaluation of Scientif ic and Technological Choices. The Commission def ines ASN's external relations policy at national and international level. THE DEPARTMENTS ASN comprises departments placed under the authority of its Chairman. The departments are headed by a Director General, appointed by the ASN Chairman. They carry out ASN’s day-to-day duties and prepare draft opinions and decisions for the ASN Commission. They comprise: ∙ head office departments organised according to topics, which oversee their f ield of activity at a national level, for both technical and transverse matters (international action, preparedness for emergency situations, information of the public, legal affairs, human resources and other support functions). They more specif ically prepare draft doctrines and texts of a general scope, examine the more complex technical f iles and the “generic” f iles, in other words those which concern several similar facilities; ∙ 11 regional divisions, with competence for one or more administrative regions, covering the entire country and the overseas territories. The regional divisions conduct most of the oversight in the f ield of nuclear facilities, radioactive substances transport operations and small-scale nuclear activities. They represent ASN in the regions and contribute to public information within their geographical area. In emergency situations, the regional divisions assist the Prefect of the département(***) who is responsible for the protection of the population, and oversee the operations to safeguard the facility affected by the accident. Bernard DOROSZCZUK Chairman Sylvie CADET-MERCIER (*) Commissioner Géraldine PINA JOMIR Commissioner Laure TOURJANSKY (*)(**) Commissioner Jean-Luc LACHAUME (*) Commissioner from 13 November 2018 to 12 November 2024 from 21 December 2016 to 9 December 2023 from 15 December 2020 to 9 December 2026 from 21 April 2021 to 9 December 2023 from 21 December 2018 to 9 December 2026 THE FRENCH NUCLEAR SAFETY AUTHORITY OPERATIONS ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2021
85% management 48% women 317 inspectors PERSONNEL ASN ACTIONS 63 information notices 11 press conferences 1,917 individual licensing and registration resolutions issued 8 plenary meetings of the Advisory Committees 519 staff members 26,733 inspection follow-up letters available on asn.fr as at 31 December 2021 393 technical opinions sent to ASN by IRSN replies to queries from the public and stakeholders 550 inspections of which 5% were carried out remotely 1,881 BUDGET €83 M IRSN budget devoted to expert assessment work on behalf of ASN budget for ASN (programme 181) €67.15 M INFORMATION THE FRENCH NUCLEAR SAFETY AUTHORITY
NUMBER OF SIGNIFICANT EVENTS IN THE MEDICAL FIELD(*) NUMBER OF SIGNIFICANT EVENTS RATED ON THE INES SCALE(*) 1,172 events in the Basic Nuclear Installations 1,068 103 84 events in the transport of radioactive substances 80 4 210 events in small-scale nuclear facilities (medical and industrial) 176 1 34 Level 0 Level 1 Level 2 642 significant events per area of exposure 120 significant events in external beam radiotherapy and brachytherapy according to the rating on the ASN-SFRO scale Brachytherapy External beam radiotherapy Nuclear medicine Computed tomography Conventional and dental radiology Fluoroscopy guided interventional practices Hors échelle Niveau 0 Niveau 1 Niveau 2 87 226 186 11 23 109 (*) The INES scale (International Nuclear and Radiological Event Scale) was developed by IAEA to explain to the public the importance of an event in terms of safety or radiation protection. This scale applies to events occurring in BNIs and events with potential or actual consequences for the radiation protection of the public and workers. It does not apply to events with an impact on the radiation protection of patients, and the criteria normally used to rate events (notably the dose received) are not applicable in this case. As it was pertinent to be able to inform the public of radiotherapy events, ASN –in close collaboration with the French Society for Radiotherapy and Oncology– developed a scale specif ic to radiotherapy events (ASN-SFRO scale). These two scales cover a relatively wide range of radiation protection events, with the exception of imaging events. Out of scale Level 0 Level 1 Level 2 Level 3 Hors échelle Niveau 0 Niveau 1 Niveau 2 Niveau 3 63 35 17 4 1 THE FRENCH NUCLEAR SAFETY AUTHORITY KEY FIGURES 2021 ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2021
HEAD OF PRIVATE OFFICE Sylvie RODDE DEPUTY DIRECTORS GENERAL Julien COLLET Daniel DELALANDE Anne-Cécile RIGAIL CHIEF INSPECTOR Christophe QUINTIN DIRECTOR OF PRIVATE OFFICE Vincent CLOÎTRE DIRECTOR GENERAL Olivier GUPTA CHAIRMAN Bernard DOROSZCZUK ETHICS OFFICER Alain DORISON MANAGEMENT AND EXPERTISE OFFICE Adeline CLOS REGULATION AND OVERSIGHT SUPPORT MISSION Julien HUSSE NUCLEAR PRESSURE EQUIPMENT Corinne SILVESTRI WASTE, RESEARCH, FACILITIES AND FUEL CYCLE Cédric MESSIER NUCLEAR POWER PLANTS Rémy CATTEAU IONISING RADIATION AND HEALTH Carole ROUSSE ENVIRONMENT AND EMERGENCY SITUATIONS Olivier RIVIÈRE TRANSPORT AND SOURCES Fabien FÉRON INTERNATIONAL RELATIONS Luc CHANIAL LEGAL AFFAIRS Olivia LAHAYE INFORMATION, COMMUNICATION AND DIGITAL USAGES Céline ACHARIAN COMMISSION DEPARTMENTS COMMISSIONERS Sylvie CADET-MERCIER Jean-Luc LACHAUME Géraldine PINA JOMIR Laure TOURJANSKY CHAIRMAN Maurice MÉDA ADMINISTRATIVE ENFORCEMENT COMMITTEE GENERAL DIRECTORATE GENERAL SECRETARIAT Brigitte ROUÈDE THE FRENCH NUCLEAR SAFETY AUTHORITY
10 9 8 7 5 4 3 2 1 (1) For BNIs oversight only, the Caen and Orléans divisions hold responsibility for the Bretagne and Île-de-France regions respectively. (2) The Paris division is responsible for Martinique, Guadeloupe, Guyane, Mayotte, La Réunion, Saint‑Pierre-et-Miquelon. (3) The Bordeaux and Marseille divisions jointly regulate nuclear safety, radiation protection and the transport of radioactive substances in the Occitanie region. (4) The Châlons-en-Champagne and Strasbourg divisions jointly regulate nuclear safety, radiation protection and the transport of radioactive substances in the Grand Est region. (*) As at 1 March 2022. DROM-COM (OVERSEAS FRANCE) 1 BORDEAUX REGIONAL REPRESENTATIVE Alice-AnneMÉDARD REGIONAL HEAD Simon GARNIER 2 CAEN REGIONAL REPRESENTATIVE Olivier MORZELLE REGIONAL HEAD AdrienMANCHON Lille Division Hauts-de-France Châlons-en-Champagne Division(4) Grand Est Strasbourg Division(4) Grand Est Lyon Division Auvergne-Rhône-Alpes Marseille Division(3) Corse, Occitanie, Provence-AlpesCôte d'Azur Bordeaux Division(3) Nouvelle-Aquitaine, Occitanie Nantes Division Bretagne, Pays de la Loire Caen Division(1) Normandie Paris Division(2) Île-de-France, DROM-COM (overseas France) Orléans Division(1) Centre-Val de Loire 10 REGIONAL DIVISIONS 4 DIJON REGIONAL REPRESENTATIVE Jean-Pierre LESTOILLE REGIONAL HEAD Marc CHAMPION 7 MARSEILLE REGIONAL REPRESENTATIVE Corinne TOURASSE REGIONAL HEAD Bastien LAURAS 5 LILLE REGIONAL REPRESENTATIVE Laurent TAPADINHAS REGIONAL HEAD Rémy ZMYSLONY 8 NANTES REGIONAL REPRESENTATIVE Anne BEAUVAL REGIONAL HEAD Émilie JAMBU 10 PARIS REGIONAL REPRESENTATIVE Emmanuelle GAY REGIONAL HEAD Agathe BALTZER 11 6 LYON REGIONAL REPRESENTATIVE Jean-Philippe DENEUVY REGIONAL HEAD Nour KHATER 9 ORLÉANS REGIONAL REPRESENTATIVE Hervé BRÛLÉ REGIONAL HEAD Arthur NEVEU 11 STRASBOURG REGIONAL REPRESENTATIVE Hervé VANLAER REGIONAL HEAD Pierre BOIS 3 CHÂLONS-EN-CHAMPAGNE REGIONAL REPRESENTATIVE Hervé VANLAER REGIONAL HEAD Mathieu RIQUART 6 Dijon Division Bourgogne-Franche-Comté THE FRENCH NUCLEAR SAFETY AUTHORITY ORGANISATION CHART(*) ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2021
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ADVICE TO THE READER i Editorial by the Commission p. 2 // Editorial by the Director General p. 8 // ASN assessments p. 12 // Notable events 2021 p. 22 // Regulatory news p. 30 // Regional overview of nuclear safety and radiation protection p. 38 // SUMMARY 01p. 98 Nuclear activities: ionising radiation and health and environmental risks 08p. 232 Sources of ionising radiation and their industrial, veterinary and research application 02p. 118 The principles of nuclear safety and radiation protection and the regulation and oversight stakeholders 09p. 260 Transport of radioactive substances 03p. 142 Regulation of nuclear activities and exposure to ionising radiation 10p. 278 EDF Nuclear Power Plants 06p. 190 International relations 13p. 326 Decommissioning of Basic Nuclear Installations 05p. 178 Informing the public and other audiences 12p. 320 Nuclear research and miscellaneous industrial facilities 04p. 166 Radiological emergency and post-accident situations 11 p. 310 “Nuclear fuel cycle” installations 07p. 202 Medical uses of ionising radiation 14p. 344 Radioactive waste and contaminated sites and soils APPENDIXp. 364 List of Basic Nuclear Installations as at 31 December 2021 • The control of small-scale nuclear facilities (medical, research and industry, transport) is presented in chapters 7, 8, 9. • Only regulatory news for the year 2021 is present in this report. All the regulations can be consulted on asn.fr, under the heading “Réglementer”. ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2021
EDITORIAL BY THE COMMISSION From left to right: Jean‑Luc LACHAUME, Commissioner; Laure TOURJANSKY, Commissioner; Bernard DOROSZCZUK, Chairman; Géraldine PINA JOMIR, Commissioner; Sylvie CADET‑MERCIER, Commissioner. Nuclear safety concerns must lie at the heart of energy policy decisions 2 ASN Report on the state of nuclear safety and radiation protection in France in 2021
Montrouge, 1 March 2022 In 2021, the safety of nuclear facilities and radiation protection in the medical, industrial and radioactive substances transport sectors remained at a satisfactory level, in line with the level observed in 2020. What are most striking about 2021, in particular its second part, are the industrial vulnerabilities affecting all nuclear facilities and the debate concerning energy policy choices and the position of nuclear power in these choices. On these subjects, ASN has four key messages: 1. The French electricity system today faces an unprecedented two-fold vulnerability in availability, affecting both the “fuel cycle” facilities and the fleet of nuclear power reactors. This vulnerability is compounded by the unexpected discovery of a stress corrosion phenomenon on several EDF reactors, which is a serious event from the viewpoint of safety. These situations and vulnerabilities, most of which stem from the lack of margins and inadequate anticipation, must serve as lessons for the entire nuclear sector and the public authorities. 2. Nuclear safety concerns must lie at the heart of energy policy decisions, in the same way as concerns regarding the decarbonisation of electricity production by 2050. In the coming 5 years, EDF will have to examine and individually justify the ability of the older reactors to continue to operate beyond 50, or even 60 years, so that lessons can be learned as soon as possible regarding any provision to be made for additional production capacity. At the same time, given the foreseeable growth in the electrif ication of usages, and given the need to maintain margins in the electricity system, the public authorities will have to carefully weigh its decision to shut down an additional 12 reactors by 2035, except of course for safety reasons. Finally, by the end of the decade at the latest, the Government will have to decide on whether or not to continue with the reprocessing of spent fuel after the 2040 time-frame, in order to anticipate the consequences, with regard either to the refurbishment of the existing facilities, or alternative solutions to be adopted for spent fuel management. 3. The prospect of an energy policy comprising a long-term nuclear component must be accompanied by an exemplary policy for the management of waste and legacy nuclear facilities. A policy such as this implies that decisions be taken before the end of the next National Radioactive Materials and Waste Management Plan (PNGMDR), so that operational management solutions are available for all types of waste within the coming 15 to 20 years, and so that the nuclear licensees are more committed to meeting the specified deadlines for legacy nuclear waste retrieval and conditioning projects for which they are responsible. 4. ASN reaff irms that the new energy policies perspectives, whatever they are, imply a considerable industrial effort, in order to tackle the industrial and safety challenges. If nuclear power is among the choices made to ensure a decarbonised energy mix by the 2050 time-frame, the nuclear sector will have to implement its own “Marshall Plan” to make this perspective industrially sustainable and have the skills it needs to tackle the scale and duration of the projects concerned. Quality and rigour in the design, manufacture and oversight of nuclear facilities, which were not up to the required level in the latest major nuclear projects conducted in France, constitute the f irst level of “Defence in Depth” in terms of safety. ASN Report on the state of nuclear safety and radiation protection in France in 2021 3 EDITORIAL BY THE COMMISSION
A weakened fuel chain, putting pressure on the electricity system The “fuel cycle” industry consists of all the facilities contributing to the production of f resh fuel, the reprocessing of spent fuels and the reuse of products f rom reprocessing. These non-redundant facilities are the links in a chain, the operation of which can be disrupted if one of them experiences a long-term failure. A series of events is currently weakening the entire “fuel cycle” chain and is a major strategic concern for ASN requiring particularly close attention, in that an unanticipated build-up of radioactive materials or waste could lead to storage conditions that are unsatisfactory from the safety standpoint. Construction of the centralised spent fuel storage pool being planned by EDF to address the risk of saturation of the existing pools by 2030, the need for which was identified as of 2010, has not yet begun. This pool will not be available before 2034 at best. This delay will require interimmeasures to increase existing storage capacity. The solution chosen by Orano, which consists in increasing the storage density in the existing pools at the La Hague facility, cannot be considered a longterm one, given the required storage periods of about a hundred years, and in the light of the most recent safety standards. Furthermore, the operating issues experienced by the Orano Melox plant in recent years, which worsened in 2021, are leading to the saturation of plutoniumbearing materials storage capacity as of 2022, owing to the production of a large quantity of manufacturing scrap. These issues are already leading to the “demoxing” of some of the 900 MWe reactors, which used MOX as fuel. They could also lead to saturation of the spent fuel pools at the La Hague facility earlier than 2028-2029. Finally, the detection of corrosion in the existing evaporators in Orano’s La Hague facility earlier than expected in the design has reduced reprocessing capacity until new fission product evaporators-concentrators are commissioned and could further degrade the saturation margins of the pools at La Hague. Overall, these situations reflect a lack of anticipation and precaution owing to the absence of margins, which is weakening the entire “fuel cycle” chain and which could, in turn, have consequences on the operation of the Nuclear Power Plants (NPPs). Pressure on the availability of the NPP fleet, underscoring the need to maintain margins for safety The winter of 2021-2022 was marked by a lower than anticipated availability of the NPP fleet. This was for a number of reasons, some of which could be foreseen, others less so. The postponed commissioning of the Flamanville EPR, the 2020 shutdown of the two Fessenheim reactors and the schedule of heavy maintenance operations (“major overhaul”), as of 2018, were known. In addition to this lower availability –which was predictable as of 2018, there was the unexpected impact of the Covid-19 pandemic– notably the f irst lockdown, identified as of mid-2020. This lockdown led to reactor maintenance and refuelling operations being spread out over a longer period, with the consequence of reducing production capacity margins over several consecutive winters. Finally, this winter, the four N4 series reactors of Civaux and Chooz, plus one reactor at Penly were either shut down or kept shut down, for in-depth inspections and repairs, following the detection of stress corrosion anomalies on welds on the reactors’ safety injection system. An inspection program for the reactors of the NPP fleet likely to be the most severely affected, extending over several months, has been proposed by EDF. This build-up of events illustrates the absolute need –as ASN has pointed out to the public authorities and nuclear sector stakeholders numerous times– to maintain design-basis margins for the electricity system and the installations, in order to deal with unexpected events and avoid having to resort to a trade-off between the safety of installations and the availability of electricity supply. … 4 ASN Report on the state of nuclear safety and radiation protection in France in 2021 EDITORIAL BY THE COMMISSION
New energy policy prospects which must address safety concerns at once Five of the six scenarios presented in the Réseau de transport d’électricité (RTE) report, produced at the request of the Government, on “Energies of the future”, aiming to achieve a decarbonised economy by 2050, are based on continued operation of the existing NPP fleet. At this stage, no conclusion on the continued operation of all these reactors beyond 50 years can be drawn from the information available to ASN during the generic examination of the fourth periodic safety review of the 900 MWe reactors, for which it issued its decision in February 2021. Due to the specific features of some reactors, it might not be possible, with the current methods, to demonstrate their ability to operate up to 60 years. Furthermore, over the longer term, one of the scenarios envisaged by RTE presents an electricity mix with a nuclear electricity share close to 50% in 2050. Consultation with industry revealed that the rate of construction of new nuclear reactors in order to achieve such a level would be hard to sustain, which led RTE also to base this scenario on the operation of some reactors beyond 60 years and the continued operation of the others until 60 years. This scenario, which is based on fundamental hypotheses of an operating lifetime which cannot at present be confirmed with regard to safety, also entails the risk of leading the electricity system into a dead-end, if the number of reactors able to operate until or indeed beyond 60 years proves to be insuff icient, and if this were only known belatedly. Moreover, the shutdown in a few years of a large number of reactors built during a short period of time in the 80s, could have “cliff-edge” consequences for electricity production capacity. ASN considers that the energy policy choices for the 2050 time-frame must be based on hypotheses that are robust and which can be justified in terms of safety. The choice of operating the current NPP fleet beyond 50 years and up to 60 years should include a step to justify this possibility, with sufficient margins for dealing with major or generic unexpected scenarios. In any case, if the hypothesis of continued operation of certain reactors beyond 60 years were to be an option, this should involve an examination, in advance, so that there is enough time –at least 15 years– to be able to adjust the energy policy choices in the light of its conclusions and avoid a situation in which the lack of forward planning leads to continued operation of the nuclear reactors based on a decision dictated purely by electricity needs or which is hazardous in terms of safety. The strong mobilisation of EDF must continue with a view to commissioning of the Flamanville EPR reactor The activities concerning weld repairs on the secondary systems (main steamlines and steam generator feedwater lines) of the Flamanville EPR, involved considerable efforts of EDF. Because of the deviations observed, about a hundred secondary system welds needed to be repaired. EDF produced specif ic mock‑ups and tests to qualify the repair processes. ASN carried out reinforced oversight of these worksites to ensure the quality of the new welds. According to the EDF schedule, repair of the welds on the secondary systems will continue until August 2022. Other work to correct deviations still has to be carried out ahead of commissioning, in particular concerning the primary system set-in nozzles. Moreover, ahead of the reactor commissioning authorisation, considerable work is still to be done on numerous topics with major safety implications, already identif ied several years ago. In particular, EDF must carry out numerous analyses, including tests, to justify the design of certain equipment, notably the reliability of the pressuriser valves and the performance of the f ilters for the water reinjected f rom the bottom of the reactor building in an accident situation. In some cases, this could require modif ications being made ahead of commissioning. EDF must also complete the required test programme for reactor commissioning and supplement it, in order to carry out requalif ication of the installation after the modif ications and repairs. ASN Report on the state of nuclear safety and radiation protection in France in 2021 5 EDITORIAL BY THE COMMISSION
Finally, ASN is paying close attention to how EDF learns the lessons gained f rom the EPRs commissioned in Finland and China. In particular and in addition to the in-depth technical dialogue initiated with EDF, anomalies on fuel, in particular those affecting the Taishan reactor core, are the subject of experience feedback exchanges between ASN and its Chinese counterpart. Management of waste and materials which must, more than ever, be exemplary Following the public debate in 2019, a draft PNGMDR covering the period 2021-2025 has been produced. Further to its opinions on each of the waste management routes, ASN issued an opinion on this draft. It considers that on the whole it meets the main goal: to allow the necessary decisions to be taken before its end, so that safe management routes are operational within the coming 15 to 20 years, for all types of radioactive waste. Within the framework of the oversight committee which it jointly chairs, ASN will pay particular attention to compliance with the strategic milestones. ASN underlines the simultaneous occurrence of shortterm safety issues, related to the malfunctions observed in certain “cycle” facilities, and longer-term issues. At this stage, the multi-year energy plan has not determined that reprocessing policy will continue beyond 2040. Whatever the option chosen, either cessation or continued reprocessing of spent fuels, the design and examination of the resulting facilities requires extensive forward planning. At ASN’s request, CEA and Orano have drawn up strategies to conduct several major decommissioning projects on old facilities. These are part of a prioritisation effort to address the safety issues. ASN therefore underlined the need to prioritise retrieval of waste and decommissioning of the facilities representing the greatest risk for people and the environment, and to comply with the defined scheduled. The retrieval and conditioning of legacy waste are preliminary but complex steps, because they require that appropriate techniques be developed. They more specifically entail a risk of delay. When the feasibility of final conditioning cannot be demonstrated within the planned time-frame, ASN requests that an alternative solution be developed, with safe retrieval of the waste, regardless of its conditioning. With the possibility of a new nuclear future, the entire sector must be mobilised in order to implement concrete solutions to manage the situations inherited from the past, as rapidly as possible. In the medical field, the level of radiation protection is maintained despite the Covid-19 pandemic In 2021, medical exposure still represents the f irst cause of exposure to artif icial ionising radiation, with the particularity of providing benef its for the patient, provided that prescription of the procedure is justified. Justification is thus a fundamental principle of radiation protection, hence the importance of implementing and overseeing it. When, for example, a new technique or procedure emerges, good collaboration is needed between the various medical and institutional actors. When a long-duration, unexpected crisis appears and exerts pressure on the health care structures, as was the case during the Covid-19 pandemic, mastering the fundamentals of radiation protection culture becomes the best guarantee of the high level of radiation protection expected in the medical f ield. With this in mind, ASN’s decisions and inspections aim to implement a quality management system increasing the accountability of each individual, from decision-maker to actor, that is proportionate to the radiation protection issues for all the diagnostic, interventional and therapeutic f ields. Eventually, this system should incorporate the methods for performing external peer reviews and, for radiotherapy, if a new technology or new type of practice is used, the recording and analysis of data concerning the expected benefits to the patient and the corresponding risks. ASN stresses the importance of learning lessons from undesirable events (Significant Radiation protection Events –ESR), which enhance the study of potential risks and contributes to continuous improvement of the safety of practices by looking for the root causes of the ESRs, regardless of origin (material, human, organisational, etc.). … 6 ASN Report on the state of nuclear safety and radiation protection in France in 2021 EDITORIAL BY THE COMMISSION
Faced with growing technical complexity in a f ield where innovations are major and rapid, compliance with the principle of optimisation in radiation protection constitutes a major concern. ASN recalls the importance of forward planning for change and compliance with the learning curve when new equipment arrives or when new techniques are adopted. In therapeutic nuclear medicine, the growth of internal targeted radiotherapy requires anticipation of the arrival of newmolecules and the increase in the number of patients treated. Preparation for post-accident management based on innovative partnership-based approaches The work done in 2021 by the the Steering Committee for the management of the post-accident phase (Codirpa), under the mandate given to ASN by the Prime Minister on 18 June 2020, led to a number of tangible advances, built around listening to and involving the stakeholders concerned. The “Q&A for health professionals” regarding the consequences of an accident was prepared with the health professionals, both locally and nationally, as they were identified as trusted third parties in the event of an emergency. This method ensures that the questions dealt with are pertinent and the answers given are of high quality, thus fostering a good level of assimilation. Along the same lines, the drafting of guidelines regarding foodstuffs in a post-accident situation relied on the work done by a pluralistic expert group, followed by a debate with four panels of citizens living near the NPPs. This was an initial trial to test the understanding of the subjects and the pertinence of the areas of work, and to collect the opinions of the populations concerned. Finally, the work done on the necessary information and awareness-raising in order to reinforce the safety and radiation protection culture focused on target public. Given the extensive work already done, an inventory of good practices will form the basis of the Codirpa report. It will enable to identify how to mobilise the various actors to implement the most effective measures in each area. These partnership-based approaches will help to inform decisions and adopt a pragmatic approach to the essential development of the safety and radiation protection culture. The Codirpa recommendations to the Prime Minister will be based on all of this feedback collection and expert work. n ASN Report on the state of nuclear safety and radiation protection in France in 2021 7 EDITORIAL BY THE COMMISSION
Over and above the cycles in which nuclear power falls into or out of favour and regardless of those who say that there is too much or too little safety, ASN has always sought to adapt its oversight to the challenges of the moment, without ever deviating from its fundamental principles. These fundamental principles are unwavering, because they correspond to convictions about how to exercise oversight and because nuclear power, in which time‑scales are very long, requires a stable framework: stop and go and a lack of visibility are hardly the best guarantors of safety. Adaptability is needed because the installations, licensees and network of subcontractors change, whether in technical, human resources, f inancial or industrial terms. In 2017, ASN therefore def ined a strategic plan to exercise oversight that was as efficient as possible in a context where the nuclear industry was faced with colossal investments, at a time when the licensees were also faced with budgetary or f inancial difficulties. Five years later, as ASN is drafting a new strategic plan, what changes have been made in the f ield of oversight? What are the new challenges? ASN has consolidated the fundamental principles of its oversight Oversight promoting more accountability ASN’s conviction has always been that a good level of nuclear safety and radiation protection can only be achieved if the nuclear licensees fully assume their The last decade has been marked by the follow-up to the Fukushima Daiichi accident and the problems experienced by the french nuclear industry. During this period, the stakeholders asked that safety and inspections be reinforced. Today, the security of electricity supply is the focus of everyone’s attention, raising questions about the cost of safety or the potentially excessive nature of the regulations. Montrouge, 1 March 2022 Responsible oversight, combining consistency with adaptability prime responsibility for it. ASN’s action aims to ensure that they do so effectively. Before issuing a ruling on the restart of nuclear reactors following maintenance outages, ASN used to examine numerous documents in which EDF justif ied maintaining the equipment as-is, despite the anomalies observed. In recent years, ASN made changes to its oversight of reactor outages by replacing this systematic documentary review with targeted on-site inspections, while at the same time, EDF has placed emphasis on rectifying the anomalies as early as possible, rather than justifying their acceptability. This approach illustrates a more responsible attitude on the part of the licensee, as encouraged by ASN’s oversight, with safety being the winner. Oversight that is more proportionate to the stakes The internationally recognised principle of the proportionality of the resources to the issues means that licensees and professionals are focusing their resources, which are by def inition f inite, on subjects with the greatest nuclear safety or radiation protection implications. Application of this principle is a constant concern in that ASN directs the allocation of the licensee’s resources through the requests it makes or the questions it poses. ASN has ramped up its efforts in favour of a “graded approach” to oversight. In the f ield of small-scale nuclear activities, the overhaul of the administrative regimes carried out in recent years has thus reduced the burden in terms of the f iles requested and the examinations carried out for those activities with lower radiation protection implications. Similarly, ASN has EDITORIAL BY THE DIRECTOR GENERAL 8 ASN Report on the state of nuclear safety and radiation protection in France in 2021
Without ever deviating from its fundamental principles, ASN has always sought to adapt its oversight to the challenges of the moment. refocused its inspections on the activities with greater implications. This necessary proportionality with the stakes is not always understood with respect to the large nuclear installations, as any subject concerning a Nuclear Power Plant (NPP) could be seen as being important: this sometimes creates a distortion between the actual issues and the media coverage. However, in the interests of safety, realism and pragmatism dictate that the proportionate approach should continue to be used and that it should even be taken further in the coming years. Reinforced technical dialogue Contrary to popular belief, f rench nuclear safety regulations are not particularly voluminous and are focused on the objectives to be achieved: only rarely do they specify means requirements. They have the advantage of allowing each licensee to define the most appropriate provisions and do not stand in the way of innovation. Nuclear safety is not therefore built around the regulations, but more on an in-depth technical dialogue between the licensee and ASN, with the support of its Advisory Committees of Experts and the Institute for Radiation Protection and Nuclear Safety (IRSN). Between 2018 and 2022, ASN deployed a plan to reinforce its control of technical examinations and its involvement in this dialogue, placing technical considerations at the heart of its decisions and resolutions. However, it is clear that over the years, the way in which the regulations are applied has become more complex, and the technical dialogue has led to a multiplication of the internal rules drafted by the licensees, to the extent that they have become hard to apply or have even lost part of their meaning for the operatives in the f ield. One of the challenges for the coming years will be to control this inflation in the number of rules. Public participation in the drafting of decisions Public involvement in the process of drafting decisions and resolutions opens up an area for dialogue, not only on the protection objectives but also on how they are to be technically achieved by the licensee. This involvement must lead to a lasting improvement in the understanding of the issues, increase trust in the decision-making process and, whenever possible, enhance it by making it possible to comprehend the questions considered to be priorities by the stakeholders and provide answers to them. Together with IRSN, ASN thus set up technical dialogue and consultation sessions on key subjects such as the fourth periodic safety reviews for the NPPs, or the densif ication project for the spent fuel storage pools at La Hague. Olivier GUPTA ASN Report on the state of nuclear safety and radiation protection in France in 2021 9 EDITORIAL BY THE DIRECTOR GENERAL
ASN has deployed new means of oversight Experience feedback from the Creusot affair Following the discovery – starting in 2016 – of irregularities in the manufacturing f i les (sometimes dating back some time) for certain nuclear reactor parts at Framatome’s Le Creusot plant, ASN implemented a system for the prevention, detection and handling of f raud and falsif ication, in line with its undertaking to Parliament: creation of an on-line form to facilitate whistle-blowing; creation of a unit for systematic analysis of these reports, leading to investigations whenever necessary; performance of inspections targeted on f raud, with a specif ic investigation methodology enabling information to be cross-checked. Oversight of the security of radioactive sources An Ordinance of 2016 entrusted ASN with oversight of protection against malicious acts concerning the radioactive sources used outside the installations monitored by other authorities. An Order, published in 2019, def ines the provisions to be followed by those in possession of sources and acts as a f ramework for inspections. On this basis, ASN was thus able to incorporate source security into the inspections it carries out in the small-scale nuclear activities. This oversight complies with the rules applicable to protection of the confidentiality of sensitive information. Oversight of complex projects ASN wished to overhaul its oversight of decommissioning and legacy waste retrieval projects, which suffer from repeated delays on the part of the licensees, partly owing to their complexity and the need to constantly adapt the operations to the new situations discovered. Rather than reinforce the level of technical detail of the inspections, and drawing inspiration from the practices of its british counterpart, ASN developed an inspection methodology for these projects designed to identify any potential drifts early on and to urge the licensees to take corrective measures in good time. Inspections were thus conducted at Orano and EDF accordingly. They will soon be extended to projects managed by CEA and the French National Radioactive Waste Management Agency (Andra). ASN has changed how it works in-house Skills reinforcement ASN observes that, year after year, it is faced with increasingly complex subjects. This can be the analysis of physical phenomena not anticipated in the design, or the use by the licensees of increasingly sophisticated calculations to prove the safety of their facilities. At a different level, this can also concern ASN’s ability to monitor the supply chain. These issues require specif ic skills which take a long time to acquire, along with growth in the cumulative experience of ASN’s personnel in the hazards and nuclear f ields. In recent years, ASN thus developed its career paths, to ensure that it has personnel who have worked for a greater number of years in the oversight of nuclear safety and radiation protection. In addition to simply the question of numbers, it also devotes efforts to recruiting staff with more experience than previously for the “senior” positions. These approaches must be continued. A well-advanced digital transformation As early as 2017, ASN launched an ambitious digital transformation programme. It won a number of calls for project proposals from the State’s Digital Division, which enabled it to benefit from support in developing data processing: for example, a data mining tool used for more than 26,000 follow-up letters now enables the inspection findings on a given topic to be collated, with identif ication of the early warning signs which were hitherto hard to detect. The digital transformation also aims to simplify the procedures for the licensees: ASN has thus developed an online services portal to make it easier to submit notification or registration files for small-scale nuclear activities. The Covid-19 pandemic crisis accelerated this process and led to the development of new practices, such as remote inspections, which do not aim to replace on-site inspection, but simply complement it. … 10 ASN Report on the state of nuclear safety and radiation protection in France in 2021 EDITORIAL BY THE DIRECTOR GENERAL
ASN has begun to consider the future challenges and the changes for which it must begin to prepare In conjunction with the internal analysis work, ASN conducted an “external consultation” to collect the viewpoints of its main interlocutors. Four main issues were identified by this preliminary work. First of all, ASN will have to oversee a fleet of installations and nuclear activities undergoing a period of transition, given that many of them are faced with the question of their continued operation and consequently the need to plan ahead for their shutdown. Projects for new facilities to replace some of the older ones, in addition to the construction work already in progress, means that ASN will have to oversee a number of new facilities (under design or under construction) unlike anything that has been seen for some considerable time: the Jules Horowitz research reactor, ITER, the Cigéo waste disposal repository, the spent fuel centralised storage pool, and possibly a number of EPR2 reactors or Small Modular Reactors (SMRs). ASN must prepare for this, so that it can examine the corresponding requests without delay and without compromising on safety. In the medical field, the major challenges are linked to questions of organisation and competence in a context of pressure in terms of staffing levels: as in the nuclear installations, social, organisational and human factors issues are predominant and ASN must further reinforce its skills and its oversight methods in this field. A new challenge is the demand from our fellow citizens for the State to be more willing to listen and to explain. In the fields of risk management, it is clear that better results are obtained when the State encourages everyone to be a contributor to their own safety. This implies good understanding of the measures taken: strict policing alone is no longer suff icient and the activity managers, decision-makers and local players must truly take on board the nuclear safety and radiation protection issues. At an international level, a key aspect of the coming period is geopolitical change. On the one hand, the nuclear centre of gravity is shifting towards Asia. On the other, some countries are preferring a national approach and the Covid-19 pandemic made international exchanges more diff icult. ASN, together with its European partners, will have to redouble its efforts to ensure that there is an ambitious vision for nuclear safety internationally. Finally, ASN must continue to adapt its operating methods in order to remain attractive, and acquire skills to address the new challenges. * Many changes have been made in recent years to adapt both ASN and its oversight to the context, itself in a constant state of flux. The Covid-19 pandemic crisis, which weighed heavily on the ASN personnel in the same way as all our fellow citizens over the past two years, did not stop ASN f rom issuing the most urgent decisions in good time, nor from conducting examinations and inspections which attracted less media coverage, but which constitute the basis of its work and underpin the credibility of its oversight. I wish to thank all the ASN personnel for their commitment and indeed al l the personnel of IRSN and the members of ASN’s Advisory Committees of Experts, whose expertise is of valuable assistance during our examination work. Preparing ASN for the oversight of new installations, ensuring that the nuclear safety and radiation protection challenges are addressed with suff icient forward planning and that all the actors involved take them on board, guaranteeing a high level of safety in Europe and worldwide, attracting the talents we need: the ASN teams will be capable of stepping up and tackling all these new challenges. n ASN Report on the state of nuclear safety and radiation protection in France in 2021 11 EDITORIAL BY THE DIRECTOR GENERAL
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