are on the whole satisfactory. Observations have been made and additional information was requested. The noteworthy modification authorisation application was transmitted by the licensee at the end of 2022 and will be the subject of an ASN position statement in 2024. Spent fuel dry storage project In November 2021, Orano submitted the first version of a DOS to ASN, which considers it to be insufficient at this stage to enable it to issue a ruling. Orano intends to transmit a new dossier in 2023. 2. ASN actions in the field of “fuel cycle” facilities: a graded approach 2.1 The graded approach according to the risks of the facilities At each step in the “fuel cycle”, the potential risks in the facilities are different: ∙ The conversion and enrichment facilities mainly entail toxic risks (owing to the chemical form of the radioactive substances they use), criticality risks (when they use enriched materials) and the risk of dissemination of radioactive substances (in powder, liquid or crystallised form). ∙ The fuel fabrication facilities mainly entail toxic risks (when they have conversion units), criticality, fire or explosion risks (processes using heating methods), as well as the risk of dissemination of radioactive substances (in powder form) and of exposure to ionising radiation (when they use reprocessed substances). ∙ The spent fuel reprocessing facilities mainly entail risks of dissemination of radioactive substances (the substances used are mainly liquids and powders), of criticality (the fissile substances employed change geometrical shape) and exposure to ionising radiation (the fuels contain highly irradiating substances). Their common point is that they never seek to create chain reactions (prevention of the criticality risk) and that they use dangerous substances, owing to their radiological or chemical properties, in industrial quantities. Conventional industrial risks are often preponderant; certain plants, such as Orano at Tricastin and La Hague or Framatome at Romans-sur-Isère, are in this respect subject to the Seveso Directive. ASN devotes efforts to applying oversight that is proportionate to the potential risks of each facility. These are thus classified by ASN in one of the three categories defined according to the scale of the risks and their impacts on safety, health and the environment. This BNI classification enables the oversight and monitoring of the facilities to be adapted, reinforcing the inspections and the scope of the reviews carried out by ASN for the higher risk facilities. When the installations are substantially modified or when they are finally shut down, ASN is in charge of examining these modifications, which are the subject of an amending decree from the Government, after prior consultation of ASN. ASN also establishes binding requirements for these main steps. Finally, ASN also reviews the safety files justifying the operation of each BNI. For each facility, ASN monitors the organisation and means chosen by the licensee to enable it to assume its responsibilities in terms of nuclear safety, radiation protection, emergency management in the event of an accident and protection of the environment and public health and safety. ASN monitors the working of the organisations put into place by the licensees mainly through inspections, more specifically those devoted to safety management. In this respect, Orano submitted applications for a change of licensee concerning all its BNIs, in February 2020. The “PEARL” project was authorised by the Decrees 20201593 and 2020-1594 of 15 December 2020. This project separated the group’s activities into three separate subsidiaries dealing with the “cycle” front-end, the “cycle” back-end and decommissioning. ASN’s examination of this application showed that it led to a change in organisation in the operation of the Orano group BNIs undergoing decommissioning, liable to compromise the principle set out in the regulations, whereby operational responsibility for a BNI lies with its nuclear licensee (III of Article R. 593-10 of the Environment Code). Orano thus submitted a request for a waiver to this principle. ASN granted this waiver in resolution 2022‑DC‑0746 of 6 December 2022, considering that it was necessary for activities notably characterised by particular technical complexity, such as process control, which require monitoring, surveillance or adjustment of parameters in real time, or when incident management or making equipment safe require a sequence of specific operations for which operators are specially qualified. This waiver concerns operation of the “HAPF” unit in BNI 33 of and silo 130 in BNI 38, located on the La Hague site. 2.2 Periodic safety reviews of “fuel cycle” facilities Since the publication of the Decree of 2 November 2007, all the BNI licensees must carry out periodic safety reviews of their facilities at least every ten years. These exercises were carried out gradually on the “fuel cycle” facilities. Defining the review procedures may be somewhat complex, because unlike nuclear power reactors, most of these facilities are in fact unique. There are thus few baseline requirements or other facilities with which a comparison can be easily made. The first reviews on facilities in the cycle concerned BNIs 151 (Melox) and 138 (IARU, formerly Socatri) and identified numerous points on which these facilities could be reinforced. Most of this work is now being carried out. Examination of these periodic safety reviews confirmed the pertinence of an upstream definition, in what is known as the “orientation” phase, of the priority subjects for examination by the licensee during the periodic safety review, along with the associated methodologies. In addition, probabilistic analyses must be added to the safety cases for all the BNIs. The periodic safety review of plant UP2-800 (BNI 117) is nearing completion, with finalisation of the examination of the improvement proposals concerning the NPH unit by the Advisory Committee of Experts for Laboratories and Plants (GPU) in February 2022. In 2023, ASN will regulate the continued operation of this BNI by means of prescriptions. For plant UP3-A (BNI 116), Orano transmitted its review concluding report at the end of 2020, and it will be examined by the GPU during the course of several meetings scheduled between 2023 and 2025. In November 2022, following examination of the review concluding report for STE3 (BNI 118) and considering that the provisions put into place or planned by the licensee on this point are appropriate, ASN validated continued operation of this facility. With regard to the fresh fuel fabrication plants, the licensee of the Melox plant submitted its review concluding report in September 2021. This report 326 ASN Report on the state of nuclear safety and radiation protection in France in 2022 • 11 • “Nuclear fuel cycle” facilities 11
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