CEA’S DECOMMISSIONING AND MATERIALS AND WASTE MANAGEMENT STRATEGY In order to keep track of the progress of the projects with the highest priority for safety, the authorities and CEA set up regular and high-level monitoring of the deadlines with the greatest safety implications. For the period 2019-2022, ASN thus observes that the strategy defined by CEA and approved by ASN in 2019 is producing results. In recent years, CEA has notably removed a certain number of spent fuels from its definitively shut down reactors, which helps reduce the potential risks from the facilities it operates. ASN nonetheless finds that, despite CEA’s clear intention to carry out facilities decommissioning and RCD operations, this licensee is experiencing major difficulties in meeting the deadlines initially set. For many situations, these delays are caused by technical or contractual difficulties. The implementation of this strategy also remains at the mercy of the financial resources available to this licensee. MANAGEMENT OF COMPLEX DECOMMISSIONING PROJECTS In 2021 and 2022, CEA voluntarily embarked on the exploratory approach promoted by ASN for the oversight of complex projects. ASN’s inspection of the decommissioning project for BNI 37-B, the former effluent treatment plant on the Cadarache site, took place in good conditions. This approach was a catalyst for CEA’s development of improvements to its project management practices, which is satisfactory and should be pursued. In the particular case of BNI 37-B ASN identified three priority areas for improvements: ∙ contracts management, at a time when contractual difficulties were also observed on priority safety operations conducted in BNIs 72 and 166; ∙ evaluation of the maturity of the complex projects, in particular those with particular implications for engineering, buying, construction and the preparation for commissioning of equipment; ∙ the methods for evaluating human resources requirements, to substantiate the sustainability of the schedules. LONG TERM COSTS AND PROVISIONS FOR DECOMMISSIONING AND FOR WASTE MANAGEMENT In its opinion submitted to the DGEC on CEA’s three-year report on the creation of financial provisions to cover decommissioning and waste management for the period 2022-2024, ASN considers that this report reflects the significant changes resulting from the implementation of CEA’s decommissioning and materials and waste management strategy. It is of high quality, but should be supplemented by an improved evaluation of the costs of postoperational clean-out and the management of the resulting pollutions, as well as the uncertainties surrounding the estimates of waste volumes. This is notably the case for BNIs 37-B, 165 and 166. Clarifications are also expected regarding the costs linked to the management of the legacy waste repositories and those concerning the performance of R&D studies into the solutions for reprocessing some or all of the bituminous radioactive waste. THE SAFETY OF FACILITIES IN OPERATION AND UNDERGOING DECOMMISSIONING ASN considers that the safety of the facilities in operation is generally satisfactory. During the course of the inspections carried out in 2022, it nonetheless identified certain topics which require improvements. This mainly concerns management of the fire risk, but also waste management, safety commissions and on-site permits, periodic checks and tests, Human and Organisational Factors (HOF), as well as the prevention of pollution and management of detrimental effects. ASN’s opinion on each of these topics is detailed in the following sections. RADIOACTIVE WASTE MANAGEMENT ASN finds that the management of radioactive waste in the CEA facilities is satisfactory and an improvement on 2021, even though the situation differs from one facility to another. The traceability of waste monitoring could be improved, notably with regard to legacy waste which cannot be immediately removed from the facilities. The operations to characterise this waste also needs to continue, so that it can be removed through the appropriate routes. ASN considers that particular attention must be paid by CEA to the management of the storage areas for the waste produced by the facilities, notably with regard to aspects concerning monitoring of the inventories and compliance with the waste storage conditions, the justification of the storage durations, and the existence of storage areas not provided for in the baseline safety requirements of certain facilities. Finally, CEA must remain vigilant with regard to correct forward planning for and performance of very low-level (VLL) waste storage area extension projects, made necessary for the facilities producing large quantities of waste (notably the facilities undergoing decommissioning). THE CONFORMITY AND REASSESSMENT OF THE SAFETY OF THE FACILITIES ASN considers that the organisation put into place by CEA to evaluate the conformity of its facilities and reassess their safety during the periodic safety reviews, is appropriate. Generally speaking, ASN also underline’s the licensee’s satisfactory follow-up and performance of the actions identified during the reviews. The inspections carried out by ASN on the topic of the periodic safety reviews nonetheless identified some points for improvement which must be addressed by CEA, notably concerning the exhaustiveness of the conformity checks. CEA will also have to continue its efforts in the coming years in order to comply with the schedule for implementation of the compliance and safety improvement work defined by these periodic safety reviews, so that in all cases a review can be started once the deployment of the action plan from the previous review has been completed. MANAGEMENT OF DEVIATIONS ASN generally finds that the deviations management process has made progress at CEA. It must however continue its efforts, notably with regard to analysis of the causes or trends regarding the repetition of similar deviations, for example those linked to non-compliance with the periodic checks and tests. ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 23 ASN Assessments
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