(see point 2.2.2). Keeping control of the packaging deadlines is a particularly important aspect, which requires the development of characterisation programmes to demonstrate the feasibility of the chosen packaging processes and to identify sufficiently early the risks that could significantly affect the project. If necessary, when the feasibility of the defined packaging cannot be determined within times compatible with the prescribed deadlines, the licensee must plan for an alternative solution, including in particular interim storage areas allowing the retrieval and characterisation of the legacy waste as rapidly as possible. For information, Article L. 542‑1‑3 of the Environment Code requires that the ILW-LL waste produced before 2015 be packaged by the end of 2030 at the latest. Within the framework of the WRP operations, Orano is examining packaging solutions that necessitate the development of new processes, particularly for the following ILW-LL waste: ∙ the radioactive sludge from the La Hague STE2 facility; ∙ the alpha-emitting technological waste which comes primarily from the La Hague and Melox plants (Gard département) and is not suitable for above-ground disposal. For other types of ILW-LL waste resulting from the WRP operations, Orano is examining the possibility of adapting existing processes (compaction, cementation, vitrification). Some of the associated packaging baseline requirements are currently being examined by ASN. 2.5 EDF’s waste management strategy and its assessment by ASN The radioactive waste produced by EDF comes from several distinct activities. It mainly comprises waste from the operation of the NPPs, which consists of activated waste from the reactor cores, and waste from their operation and maintenance. Some legacy waste and waste resulting from ongoing decommissioning operations can be added to this. EDF is also the owner, for the share attributed to it, of HLW and ILW-LL waste resulting from spent fuel reprocessing in the Orano La Hague plan. Activated waste This waste notably comprises control rod assemblies and poison rod assemblies used for reactor operation. This is ILW-LL waste 9. The Fuel Cluster Guide Tubes (TGGs), currently stored in the pools of the NPPs, guide the control rod clusters inside the reactors These parts are significantly activated, especially in their bottom section. EDF considers the removed TGGs to be radioactive waste, to be processed via dedicated disposal or treatment routes. that is produced in small quantities. At present this waste is stored in the NPP fuel storage pools pending transfer to the Iceda facility. Operational and maintenance waste Some of the waste is processed by melting or incineration in the Centraco facility, in order to reduce the volume of ultimate waste. The other types of operational and maintenance waste are packaged on the production site then shipped to the CSA or Cires repositories for disposal (see points 1.3.1 and 1.3.2). This waste contains beta and gamma emitters, and few or no alpha emitters. At the end of 2013, EDF submitted a file presenting its waste management strategy. After examining this file, ASN in 2017 asked EDF to continue its measures to reduce the uncertainties concerning the activity of the waste sent to the CSA, to improve its organisational arrangements to guarantee the allocation of sufficient resources to radioactive waste management, and to present the most appropriate process for the treatment of used steam generators. Lastly, the treatment of the spent Fuel Cluster Guide Tubes (TGG(9)) from the EDF fleet (about 2,000) could be carried out by Cyclife France in the Centraco facility. The various license applications relative to this project are currently being examined by ASN. The issues and implications The main issues relating to the EDF waste management strategy concern: ∙ The management of legacy waste. This mainly concerns structural waste (graphite sleeves) from the graphite-moderated GCR fuels. This waste could be disposed of in a repository for LLW-LL waste (see point 1.3.4). It is stored primarily in semi-buried silos at Saint-Laurent-des-Eaux. Graphite waste is also present in the form of stacks in the GCRs currently being decommissioned. In the context of the PNGMDR 20162018, EDF conducted a study of the reliability of the activity predictions for this waste and submitted its conclusions in December 2019. This report is being examined by ASN. ∙ The changes linked to the “fuel cycle”. EDF’s fuel use policy (see chapter 10) has consequences for the fuel cycle installations (see chapter 11) and for the quantity and nature of the waste produced. ASN issued an opinion on the coherence of the “nuclear fuel cycle” in October 2018 (see chapter 11). 3 // Management of mining residues and mining waste rock from former uranium mines Uranium mines were worked in France between 1948 and 2001, producing 76,000 tons of uranium. Some 250 sites in France were involved in exploration, extraction and processing activities. The sites were spread over 27 départements in the eight regions: Auvergne-Rhône-Alpes, Bourgogne-Franche-Comté, Bretagne, Grand Est, Nouvelle-Aquitaine, Occitanie, Pays de la Loire and Provence-Alpes-Côte d’Azur. Ore processing was carried out in eight plants. The former uranium mines are now almost all under the responsibility of Orano. The working of uranium mines produced two categories of products: ∙ mining waste rock, that is to say the rocks excavated to gain access to the ore. The quantity of mining waste rock extracted is estimated at about 170 million tonnes; ∙ static or dynamic processing tailings, which are the products remaining after extraction of the uranium from the ore. In France, these tailings represent 50 million tonnes distributed among 17 disposal sites. These sites are ICPEs and their environmental impact is monitored. Redevelopment of the uranium processing tailings disposal sites consisted notably in placing a solid cover over the tailings to provide a geochemical and radiological protective barrier to limit the risks of intrusion, erosion, dispersion of the stored products and the risks of external and internal exposure of the neighbouring populations. The regulatory context The uranium mines, their annexes and their conditions of closure are covered by the Mining Code. The disposal facilities for radioactive mining tailings are governed by section 1735 of the ICPE classification system. The mines and the mine tailings disposal sites are not subject to ASN oversight. In the specific case of the former uranium mines, an action plan was defined by Circular 2009-132 of 22 July 2009 of the Minister responsible for the environment and the Chairman of ASN, along the following work lines: ∙ monitor the former mining sites; 360 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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