In September 2021, the Ministry for Ecological Transition asked the Environmental Authority for its opinion on the draft fifth PNGMDR. It submitted its opinion 2021-96 on the draft plan on 18 November 2021. In addition, at the end of September 2021, the Ministry for Ecological Transition asked ASN for its opinion on this same draft plan. In response to this request, ASN’s opinion 2021-AV-0390 of 9 November 2021 considers that the PNGMDR 2021-2025 must, prior to its conclusion, enable the necessary decisions to be taken so that operational solutions are available within the coming 15 to 20 years for all types of radioactive waste. ASN considers that the draft PNGMDR 2021-2025 is in line with this approach, but that particular attention must be paid to compliance with the deadlines for each action it contains. It therefore issued a favourable opinion for the draft PNGMDR 2021‑2025 with the following provisos: • given the malfunctions observed in 2021 in certain facilities vital to the working of the “fuel cycle”, the licensees will have to study worst-case operating scenarios for this “cycle” in terms of quantities of materials and waste produced, and as applicable propose appropriate remedies. They will also have to regularly report on the anticipated time-frames for saturation of the spent fuel storage capacities. In any case, the estimated prospects for saturation of spent fuel storage capacities produced pursuant to the draft plan must not be based on the hypothesis of any longterm densification of the storage pools envisaged by Orano on its La Hague site. This is not a technical solution that meets current safety standards; • given the forward planning needed for the actions involved in a decision to cease or continue with reprocessing of spent fuels after 2040, studies of technical and safety options will have to be carried out by the industry with regard to the impact of such a decision on existing or future Basic Nuclear Installations; • with regard to actions concerning the safe management of high-level waste (HLW) and intermediate-level, long‑lived (ILW-LL) waste, the recommendations of the PNGMDR “Guidance Committee”, formulated in its opinion of 19 March 2021, must now be incorporated into the PNGMDR 2021-2025. This more particularly entails: – updating of the waste package delivery records at the very least at each new edition of the plan, with a first deadline for the end of 2023, – provision of a preliminary version of the Cigéo acceptance specifications, no later than the deadline for submission of the creation authorisation application, – explanation of the toxic, chemical and radiological substances inventories of the waste in the Cigéo reserve inventory, along with the conditioning methods adopted or, failing which, the ongoing or envisaged studies, – by mid-2023, the transmission of a progress report on the studies carried out on the processing of bituminised waste, explaining the health and environmental impacts of each of the processes studied; • the work aiming to implement specific management solutions for certain waste, in the light of its properties, must be continued and supported by the PNGMDR 2021-2025. This in particular concerns waste containing tritium, disused sealed sources, organic oils and liquids and activated waste from small producers. In this respect, ASN recalled the recommendations made in its opinion 2021-AV-0379 of 11 May 2021, aiming to improve the inventory of this waste and knowledge of its characteristics, as well as to identify and deploy appropriate management solutions. ASN also considers that the ambition of that part of the draft plan requiring the development of recovery plans from the owners of radioactive materials is insufficient with regard to certain materials, such as depleted uranium, or the heavily depleted uranium which could result from the re-enrichment of depleted uranium, spent fuel from reactor EL4 (Brennilis’ Nuclear Power Plant) and thorium-bearing substances. ASN stresses the need to assess the recoverable nature of the radioactive materials, taking account of the quantities concerned and the time-frames within which industrial solutions for using these materials will be available. In this respect, it recalls the analysis framework it proposed in its opinion 2020-AV-0363 of 8 October 2020, which includes the notion of a time-frame for the envisaged recovery. In this opinion, ASN also makes a number of recommendations concerning the management of low-level, long-lived waste (LLW-LL) and ILW-LL waste, as well as on how to involve the public. Following the submission of the above-mentioned opinions from the Environmental Authority and from ASN, the Ministry for Ecological Transition will submit an amended draft of the PNGMDR 2021-2025 for public consultation, along with draft regulatory texts issued pursuant to this plan, on which ASN will also issue an opinion. ASN Report on the state of nuclear safety and radiation protection in France in 2021 25 NOTABLE EVENTS 2021
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