The Cigéo Safety Options Dossier The filing of a DOS marks the start of a regulatory process(7). ASN received the DOS for Cigéo in April 2016. At the end of the technical examination phase, the ASN draft opinion underwent public consultation, which took place from 1 August to 15 September 2017. After analysing the resulting contributions, ASN issued its opinion on 11 January 2018. ASN also sent a follow-up letter giving recommendations on the safety options to prevent or limit the risks and asked Andra for additional studies and justifications (corrosion phenomena, low-pH concretes, representativeness of the hydrogeological model, surveillance strategy, etc.). The demands made in this letter take into account the suggestions and comments received through the public consultation. The examination of the Cigéo DOS highlighted several issues relating to specific aspects (architecture, defining of hazards, postaccident management, etc.). Among these issues ASN pointed out that the management of bituminised waste required special attention. The management of bituminised waste is moreover monitored under the PNGMDR, which demands several studies relative to the characterisation of these packages, their conditions of transport and the treatment possibilities (Articles 46, 47 and 48 of the Order of 23 February 2017). In 2019, ASN made additional information requests(8) to the waste producers and to Andra further to the examination of the study submitted under Article 46. They focus more specifically on the effect of self-irradiation on the thermal behaviour of the bituminised waste packages, on the thermal reactivity of the bituminised coatings, on the long-term swelling considering the long-term behaviour of the Cigéo repository and on the design changes to control the risks associated with the disposal of packages of bituminised waste. The Minister responsible for energy and ASN moreover wanted an independent multidisciplinary assessment drawing on international practices to be conducted on this issue. The conclusions of this assessment were presented to the working group tasked with monitoring the PNGMDR in September 2019. ASN considers in this respect in its opinion 2020-AV-0369 of 1 December 2020 that in view of the conclusions of the third-party review of the management of bituminised waste and the studies on the changes in design of the Cigéo ILW-LL waste disposal cells, which highlight new technical factors since the publication of the opinion of 11 January 2018, it is essential for the waste producers to conduct an ambitious programme to characterise the bituminised waste packages in order to demonstrate that all or part of these packages could be emplaced with a high level of safety in the projected Cigéo facility without prior treatment. ASN considers moreover that the bituminised waste packages whose safety once emplaced in the disposal facility could not be demonstrated must undergo further investigations. The CEA informed ASN of the launching in 2021 of a new “quadripartite” studies programme (grouping Andra and the three major licensees), aiming to enrich reflections on the methods of managing bituminised waste by contributing elements stemming from the research and development work. ASN welcomed this initiative and will follow the progress of this programme which will span five years. 7. Article R. 593‑14 of the Environment Code stipulates that “any person planning to operate a BNI can, before initiating the creation authorisation procedure, ask ASN for an opinion on all or part of the options it has retained to ensure protection of the interests mentioned in Article L. 593‑1. ASN, in an opinion issued and published in the conditions and forms determined by itself, specifies to what extent the safety options presented by the applicant are such as to prevent or limit the risks for the interests mentioned in Article L. 593.1 in view of the technical and economic conditions prevailing at the time. ASN may indicate the additional studies and justifications that will be required for a prospective creation authorisation application. It can set a validity period for its opinion. This opinion is communicated to the applicant and to the Minister responsible for nuclear safety”. 8. The follow-up letters are available on the ASN website under the heading “ASN informs”, “Educational files”, “Management of radioactive waste”, “French National Radioactive Material and Waste Management Plan”, “PNGMDR 2016-2018”. From the Safety Options Dossier to the creation authorisation application At present, Andra is continuing the Cigéo project design and preparing the requisite authorisation applications. Andra filed a Declaration of Public Utility (DUP) application in August 2020. The public inquiry relative to the DUP ran from 15 September to 23 October 2021. The reasoned opinion, the general conclusions and the inquiry commission report were published on 20 December 2021. Prior to this inquiry, ASN answered questions from the inquiry commissioners concerning certain technical aspects of the Cigéo project. Andra will acquire the status of nuclear licensee as soon as the creation authorisation application is filed. In 2021, ASN and IRSN discussed the matter of defining the in-service seismic hazard level with Andra, and started discussions with a view to preparing the examination of the creation authorisation application. Andra must also integrate the results of the bituminised waste review in its creation authorisation application file, particularly with regard to the architecture of the ILW-LL waste disposal cells. In the public debate relative to the 5th edition of the PNGMDR, the question of Cigéo governance was identified as requiring closer examination, particularly with regard to the implementation of reversibility and the objectives of the industrial pilot phase. The Special Public Debate Committee (CPDP) concludes in particular that civil society must be involved in the governance of Cigéo, particularly during the industrial pilot phase. Furthermore, the CPDP considers that the public must also be involved in the steps that have an impact on the reversibility of the facility, particularly package retrievability. The resolution of 21 February 2020 of the Minister of Ecological Transition and Solidarity and of the ASN Chairman further to the public debate provides in this respect that the PNGMDR will specify the conditions of reversibility of the facility, particularly regarding package retrievability, the decision-making milestones of the Cigéo project and the required method of governance in order to be able to review the choices made. It also specifies that the PNGMDR shall define the objectives and success criteria for the industrial pilot phase provided for in Article L. 542‑10-1 of the Environment Code, the methods of informing the public between two successive updates of the operations master plan provided for in Article L. 542-10-1 of the Environment Code and the methods of involving the public in the decisive development steps of the Cigéo project. Provisions that meet the requirements set out in this opinion have been integrated in the draft PNGMDR 2021-2025. The cost of the project On 15 January 2016, in accordance with the procedure stipulated in Article L. 542-12 of the Environment Code and after consideration of ASN’s opinion of February 2015 and the comments of the radioactive waste producers, the Minister responsible for energy issued an Order setting the reference cost of the Cigéo disposal project “at €25 billion under the economic conditions prevailing on 31 December 2011, the year in which the cost evaluation work began”. This Order also specifies that the cost must be updated regularly and at least at the key stages of project development (creation authorisation, commissioning, end of “industrial pilot phase”, periodic safety reviews). ASN Report on the state of nuclear safety and radiation protection in France in 2021 355 14 – RADIOACTIVE WASTE AND CONTAMINATED SITES AND SOILS 08 07 13 04 10 06 12 14 03 09 05 11 02 AP 01
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