4. Monitoring the impact of nuclear activities and radioactivity in the environment 4.1 Monitoring discharges and the environmental and health impact of nuclear activities 4.1.1 Monitoring of discharges The BNI Order of 7 February 2012 and amended ASN resolution 2013‑DC‑0360 of 16 July 2013, set the general requirements applicable to any BNI with regard to their water intake and their discharges of radioactive or chemical substances. In addition to these provisions, in its resolution 2017‑DC‑0588 of 6 April 2017, ASN defined the conditions for water intake and consumption, effluent discharge and environmental monitoring applicable specifically to PWRs. This resolution was approved by the Minister for Ecological and Solidarity-based Transition in an Order of 14 June 2017. Apart from the above-mentioned general provisions, ASN resolutions set specific requirements for each facility, more particularly the limits for water intake and discharge of radioactive or chemical substances. Monitoring discharges from BNIs The monitoring of discharges from an installation is essentially the responsibility of the licensee. The ASN requirements regulating discharges stipulate the minimum checks that the licensee is required to carry out. This monitoring focuses on the liquid or gaseous effluents (monitoring of the activity of discharges or concentrations and flows of chemical substances discharged, characterisation of certain effluents prior to discharge, etc.) and on the environment around the facility (checks during discharge, samples of air, water, milk, grass, etc.) with regard to all pertinent parameters for characterising the impact of the facility on humans and the environment. The results of this monitoring are recorded in registers transmitted to ASN every month. The BNI licensees also regularly transmit a certain number of discharge samples to an independent laboratory for crossanalysis. The results of these “cross-analyses” are sent to ASN. This programme of cross-analyses defined by ASN is a way of ensuring that the accuracy of the measurements taken by the licensee laboratories is maintained over time. The inspections carried out by ASN Through dedicated inspections, ASN ensures that the licensees actually comply with the regulations binding on them with regard to the management of discharges and the environmental and health impact of their facilities. Every year, it carries out about 90 inspections of this type, split into three topics: ∙ prevention of pollution and management of detrimental effects; ∙ water intake and effluent discharge, monitoring of discharges and the environment; ∙ waste management. Each of these topics covers both radiological and non-radiological aspects. Every year, ASN carries out 10 to 20 inspections with sampling and measurement. They are generally unannounced and are run with the support of specialist, independent laboratories appointed by ASN. Effluent and environmental samples are taken for radiological and chemical analyses. Finally, every year, ASN carries out several reinforced inspections which aim to check the organisation put into place by the licensee to protect the environment; the scope of the inspection is then broadened to cover all of the above-mentioned topics. Within this context, situational exercises can be carried out to test the organisation implemented for pollution management (see chapter 10). Accounting of BNI discharges The rules for accounting of discharges, both radioactive and chemical, are set in the general regulations by amended ASN resolution 2013‑DC‑0360 of 16 July 2013 relative to control of the detrimental effects and the impact of BNIs on health and the environment. These rules were set so as to guarantee that the discharge values accounted by the licensees, notably those considered in the impact calculations, will in no case be under-estimated. For discharges of radioactive substances, accounting is not based on overall measurements, but on an analysis per radionuclide, introducing the notion of a “reference spectrum”, listing the radionuclides specific to the type of discharge in question. The principles underlying the accounting rules are as follows: ∙ radionuclides for which the measured activity exceeds the decision threshold for the measurement technique are all counted; ∙ the radionuclides of the “reference spectrum” for which the measured activity is below the decision threshold (see box page 161) are counted at the decision threshold level. For discharges of chemical substances with an emission limit value set by an ASN binding requirement, when the concentration values measured are below the quantification limit, the licensee is required by convention to declare a value equal to half the quantification limit concerned. Monitoring discharges in the medical sector Pursuant to ASN resolution 2008‑DC‑0095 of 29 January 2008, radioactivity measurements are taken on the effluents coming from the places that produce them. In hospitals that have a nuclear medicine department, these measurements chiefly concern iodine-131 and technetium-99m. In view of the difficulties encountered in putting in place the permits to discharge radionuclides into the public sewage networks, as provided for by the Public Health Code, ASN has created a working group involving administrations, “producers” (nuclear physicians, researchers) and sanitation professionals. The report from this working group formulating recommendations to improve the efficiency of the regulations was presented in October 2016 to the Advisory Committee for Radiation Protection of workers and the public (GPRADE, now called GPRP), for industrial and research applications of ionising radiation and the environment. ASN consulted the stakeholders in 2017 on this subject. The report from the working group and a circular letter intended for the professionals concerned and constituting the applicable doctrine on the subject were published on the ASN website on 14 June 2019. Since 2019, the CIDRRE tool (Calculation of the impact of radioactive spills into the networks) developed by IRSN, enables the licensees to evaluate the impact of their discharges. It is available on-line on the Internet. Moreover, additional work has been started concerning the use of new radiopharmaceutical drugs and their environmental impact, as well as the definition of guideline levels enabling the sewage network managers to regulate discharges into the sewage networks. In the small-scale industrial nuclear sector, few facilities discharge radioactive effluents apart from cyclotrons (see chapter 8). The discharge permits stipulate requirements for the discharges and their monitoring, which are subject to particular scrutiny during inspections. ASN Report on the state of nuclear safety and radiation protection in France in 2022 157 • 03 • Regulation of nuclear activities and exposure to ionising radiation 01 03 07 08 13 AP 04 10 06 12 14 09 05 11 02
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