ASN endeavours to apply oversight that is proportionate to the potential risks of each facility, classified by ASN in one of three categories defined on the basis of the scale of the risks and detrimental effects it represents. This BNI classification enables the oversight and monitoring of the facilities to be adapted, reinforcing the inspections and the scope of the reviews carried out by ASN for the higher risk facilities. When the installations are substantially modified or when they are finally shut down, ASN is in charge of examining these modifications, which are the subject of an amending decree from the Government, after prior consultation of ASN. ASN also establishes binding requirements for these main steps. Finally, ASN also reviews the safety files justifying the operation of each BNI. For each facility, ASN monitors the organisation and means chosen by the licensee to enable it to assume its responsibilities in terms of nuclear safety, radiation protection, emergency management in the event of an accident and protection of nature, the environment and public health and safety. ASN monitors the working of the organisations put into place by the licensees mainly through inspections, more specifically those devoted to safety management. In this respect, Orano submitted applications for a change of licensee concerning all its BNIs, in February 2020. The purpose of this project, called “PEARL” –authorised by Decrees of 15 December 2021– is to separate the group’s activities into three separate subsidiaries dealing with the “cycle” front-end, the “cycle” back-end and decommissioning. ASN’s examination of this application showed that it led to a change in organisation in the Orano group BNIs undergoing decommissioning, liable to compromise the principle set out in the Environment Code, whereby operational responsibility for a BNI lies with its nuclear licensee. Orano thus submitted a request for a waiver to this principle in December 2020. This request was examined by ASN, which will issue a position statement in 2022. 2.2 Periodic safety reviews of “fuel cycle” facilities Since the publication of the Decree of 2 November 2007, all the BNI licensees must carry out periodic safety reviews of their facilities at least every ten years. These exercises were carried out gradually on the fuel cycle facilities. The first reviews concerned BNIs 151 (Melox) and 138 (IARU, formerly Socatri) and identified numerous points on which these facilities could be reinforced. Most of this work has today been completed. The examination of these periodic safety reviews confirmed that the subjects to be examined by the licensee during the periodic safety reviews, along with the required methodologies, should be defined during what is referred to as the orientation phase. In addition, probabilistic analyses must be added to the safety cases for all the BNIs. The periodic safety review of the UP2-800 plant (BNI 117) is nearing completion, with finalisation of the examination of the improvement proposals concerning the NPH unit, scheduled for early 2022. For the UP3-A plant (BNI 116), Orano transmitted its review concluding report at the end of 2020 and it will be examined by the Advisory Committee for plants during the course of several meetings scheduled between 2023 and 2025. Finally, ASN will issue a position statement shortly on the continued operation of STE3 (BNI 118). The periodic safety review of FBFC (BNI 98) comprises safety improvements to the facility, notably with regard to controlling fire risks, controlling criticality and reinforced civil engineering. However, it demonstrated the need for improved incorporation of the hazards linked to dangerous substances into the safety case of the “fuel cycle” facilities, while ensuring a level of stringency at least equivalent to that of Seveso classified upper-tier facilities. In 2020, ASN therefore issued a binding requirement in its resolution associated with this periodic safety review, for updating of the safety case with regard to the risks resulting from dangerous substances. In October 2021, following the examination of the review concluding report for TU5 (BNI 155), ASN validated continued operation of BNI 155. The periodic safety reviews show the importance of an in situ verification of the conformity of the Protection Important Component (PIC) that is as exhaustive as possible, or as representative as possible of the PIC that are not accessible. They also illustrate the need for a robust approach to the control of the ageing of “fuel cycle” facilities. It may be complex to develop these approaches because most of the fuel cycle facilities are unique. In the context of the faster-than-anticipated corrosion of the fission products evaporators-concentrators and other equipment in the La Hague plant, the management of ageing is a priority issue for ASN with regard to the “cycle” back-end facilities, which are the subject of dedicated inspections and increased vigilance in the examination of the ongoing periodic safety reviews. 318 ASN Report on the state of nuclear safety and radiation protection in France in 2021 11 – “NUCLEAR FUEL CYCLE” INSTALLATIONS
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