routes, for the preparation of the 5th PNGMDR. ASN also issued an opinion 2021-AV-0390 of 9 November 2021 on the draft 5th plan produced by the Ministry responsible for energy. 2.1.5 Developing the regulatory framework and issuing requirements to the licensees ASN can issue regulations. Thus, the provisions of the Order of 7 February 2012 which concern the management of radioactive waste have been set out in the ASN resolutions mentioned earlier relative to waste management in BNIs and the packaging of waste. To give an example, the resolution of 23 March 2017 addresses the packaging of radioactive waste and the conditions of acceptance of the radioactive waste packages in the disposal BNIs. Its aim is to specify the safety requirements at the various stages of a management route. This resolution has been applicable since 1 July 2018. Moreover, to ensure a consistent approach to the management of waste in BNIs and DBNIs, ASN and ASND signed an agreement in January 2021 coordinating their actions in this area. More broadly, ASN issues requirements relative to the management of waste coming from the BNIs. ASN indicates certain waste management requirements in two guides: Guide No. 18 relative to the management of radioactive effluents and waste produced by a nuclear activity licensed under the Public Health Code, and Guide No. 23 relative to the BNI waste zoning plan (see points 1.2.1 and 1.2.2). Lastly, ASN is consulted for its opinion on draft regulatory texts relative to radioactive waste management. 2.1.6 Evaluation of the nuclear financial costs The regulatory framework designed to ring-fence the financing of nuclear facility decommissioning costs or, for radioactive waste disposal facilities, the final shutdown, maintenance and monitoring costs, in addition to the cost of managing spent fuel and radioactive waste, is described in chapter 13 (see point 1.4). 2.2 Periodic safety reviews of radioactive waste management facilities BNI licensees, including for radioactive waste management facilities, carry out periodic safety reviews of their facilities in order to assess the situation of the facilities with respect to the rules applicable to them and to update the assessment of the risks or adverse effects, taking into account, more specifically, the state of the facility, the experience acquired during operation, and the development of knowledge and rules applicable to similar facilities. The diversity and frequently unique nature of each radioactive waste management facility lead ASN to adopt an examination procedure that is specific to each facility. In this context, ASN is currently examining seven safety reviews of radioactive waste management facilities. They concern: ∙ two BNIs operated by the CEA: the treatment and packaging facility (BNI 35) on the Saclay site and the research and development facility Chicade (BNI 156) on the Cadarache site; ∙ one BNI operated by Orano: BNI 118, the waste treatment, packaging and waste package storage facility on the La Hague site; ∙ two BNIs operated by Andra: the Aube radioactive waste repository –CSA (BNI 149), and the Manche radioactive waste repository– CSM (BNI 66); ∙ one BNI operated by EDF: BNI 74 comprising the SaintLaurent-des‑Eaux storage silos; ∙ one BNI operated by Cyclife France: the Centraco facility for waste treatment by melting or incineration (BNI 160). 2.2.1 Periodic safety reviews of radioactive waste management support facilities The periodic safety reviews of the oldest facilities such as BNIs 35, 74 and 118 present particular challenges. The SaintLaurent‑des‑Eaux silos (BNI 74) present safety risks, particularly regarding their inventories. These safety reviews must address the control of the waste storage conditions, including legacy waste, the retrieval and packaging of this waste with a view to removal via the dedicated route and scheduled post-operational clean-out of the buildings. In relation with these challenges, the safety reviews must ensure that the impacts of discharges into the environment (soils, groundwater, or seawater in the case of BNI 118) are controlled. For the most recent facilities, as is the case with Cedra and Chicade, the periodic safety reviews highlight more generic problems. The resistance of the buildings to internal and external hazards (earthquake, fire, lightning, flooding, aircraft crash) is one of the important aspects. ASN made its conclusions on the safety review of the Cedra storage facility known on 3 December 2021. 2.2.2 Periodic safety reviews of radioactive waste disposal facilities The safety reviews of the CSM (BNI 66) and the CSA (BNI 149) have the particularity of addressing control of the risks and adverse effects over the long term, in addition to reassessing their operational control. Their purpose is therefore to update, if necessary, the scenarios, models and long-term assumptions in order to confirm satisfactory control of the risks and adverse effects over time. The periodic safety reviews of these two facilities, although they are at different stages of progress (the CSM review report was submitted in April 2019, whereas ASN is finalising the CSA report), thus highlight the need for increased knowledge of the long-term impacts associated with the toxic chemicals contained in some waste and of the impacts of the radionuclides on the environment. The successive safety reviews must also serve to detail the technical measures planned by the licensee to control the adverse effects of the facility over the long term, notably for the cover which contributes to the final containment of the disposal concrete blocks. The durability of the CSM cover is, along with the preservation of the site memory for future generations, the predominant theme of the periodic safety review of a radioactive waste disposal facility. Furthermore, these safety reviews provide the opportunity of detailing, as time goes by, the measures the licensee plans implementing to ensure the long-term surveillance of the behaviour of the disposal facility. 2.3 The CEA’s waste management strategy and its assessment by ASN Types of waste produced by the CEA The CEA operates diverse types of facilities covering all the activities relating to the nuclear cycle: laboratories and plants associated with “fuel cycle” research, as well as experimental reactors. The CEA also carries out numerous decommissioning operations. Consequently, the types of waste produced by the CEA are varied and include more specifically: ∙ waste resulting from operation of the research facilities (protective garments, filters, metal parts and components, liquid waste, etc.); ∙ waste resulting from legacy waste retrieval and packaging operations (cement-, sodium-, magnesium- and mercury-bearing waste); 358 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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