a “Guidelines Commission”. Introduced by the resolution of 21 February 2020, this Commission is chaired by an independent 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. This Commission gave opinions on various major subjects relating to the management of radioactive waste (management of VLL/LLW-LL waste, management of radioactive materials, etc.). 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 and 2021, ASN assessed the studies submitted for the PNGMDR 2016-2018. For the preparation of the 5th PNGMDR, ASN has thus issued seven opinions on the radioactive material and waste management routes in which it sets out a number of recommendations. In addition, on 9 November 2021, ASN issued a favourable opinion for the draft PNGMDR 2021-2025, on condition that it is supplemented with a study of worst-case operating scenarios for the “fuel cycle”, an assessment of the impact on the nuclear facilities of continuing the reprocessing of spent fuel beyond 2040 or not, the inclusion of measures relative to the safety of HL/ILW-LL waste management and the management of waste necessitating specific work, such as tritiated waste, and better assessing the recyclability of certain radioactive materials. 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 becquerels per gram (Bq/g) 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 m3 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 m3. According to current forecasts, the facility could be filled to maximum capacity around 2029. Andra is currently working on the Acaci project, which aims to increase the facility’s authorised capacity to more than 900,000 m3, 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. In 2021, the Government worked on setting up this regulatory framework. In its opinion 2021‑AV-0380 of 11 May 2021, ASN expressed its views on the draft regulations. In addition, ASN considers it necessary for all the stakeholders, especially the representatives of the localities actually or likely to be concerned, to be more actively involved in defining LLW waste management solutions. 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. 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 PNGMDR but also by inspecting the installations 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 of the operations performed. 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 DGEC, as described in chapter 2. ASN also publishes on its website the PNGMDR, its synthesis, the minutes of the abovementioned working group’s meetings, the studies required by the plan and the opinions it has issued on these studies. 350 ASN Report on the state of nuclear safety and radiation protection in France in 2021 14 – RADIOACTIVE WASTE AND CONTAMINATED SITES AND SOILS
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