ASN Guide No. 23 presents the conditions of application of this resolution with regard to the drawing up and modification of the waste zoning plan. Further to a modification of the regulatory requirements of the Environment Code in 2019, the waste management study is no longer required as a specific document. The provisions it contained must now be carried over to the environmental impact assessment and the BNI RGEs. ASN resolution 2022-DC-0749 of 29 November 2022 amended ASN resolution 2015-DC-0508 of 21 April 2015 to take into account this regulatory change. 1.2.2 Legal framework for the management of radioactive waste produced by activities governed by the Public Health Code Article R. 1333-16(7) of the Public Health Code states that the management of effluents and waste contaminated by radioactive substances originating from all nuclear activities involving a risk of exposure to ionising radiation must be examined and approved by the public authorities. This is the case in particular for activities using radioactive substances intended for medicine, human biology or biomedical research. ASN resolution 2008-DC-0095 of 29 January 2008 lays out the technical rules applicable for the disposal of effluents and waste contaminated or potentially contaminated by radionuclides owing to a nuclear activity. ASN published a guide (Guide No. 18) to the application of this resolution in January 2012. Management of disused sealed sources Under the PNGMDR 2016-2018, Andra submitted a report in mid2018 presenting a review of the situation regarding the acceptance of disused sealed sources considered as waste in the existing and planned disposal facilities. Furthermore, Decree 2015-231 of 27 February 2015 enables holders of disused sealed sources to call upon not only the initial source supplier but also any licensed supplier or – as a last resort – Andra, to manage these sources. The holders are moreover no longer obliged to provide proof that they have contacted all the suppliers before turning to Andra. These provisions aimed to bring a reduction in the costs of collecting disused sources and provide a recovery route in all situations. ASN issued a position statement on 11 May 2021 on the management of disused sealed sources that could not be recycled. It considers that disused sealed sources which cannot be accepted in aboveground disposal facilities must be included in the inventories of projected disposal facilities, and that a complete inventory of the existing management routes must be established, indicating the responsibilities of the various actors. Moreover, ASN recommends that the notion of “last resort” mentioned in Decree 2015-231 must be specified. Management by Andra of waste from small-scale nuclear activities Article L. 542-12 of the Environment Code entrusts Andra with a public service mission for the management of waste produced by small-scale nuclear activities. Since 2012, Andra operates Cires, a facility situated in the municipalities of Morvilliers and La Chaise in the Aube département, designed for the collection and storage of waste from small producers that are not in the nuclear power sector. ASN considers that Andra’s actions in this area are appropriate to fulfil its mission assigned under the above-mentioned Article L. 542-12 and that they must be continued. Nevertheless, the tritiated solid waste must be managed with the waste from ITER in a storage facility operated by the CEA (called 7. Formerly Article R. 1333‑12. the “Intermed project” at present). The delays in the ITER project schedule are impacting the Intermed project schedule and the management strategy for tritiated waste from small producers. In its report provided in response to Article 61 of the Order of 23 February 2017, Andra proposes storing this waste on the CEA Valduc site pending commissioning of the above-mentioned storage facilities. In its opinion 2021-AV-0379 of 11 May 2021, ASN gave a reminder that the storage of tritiated waste from small producers in a Defence Basic Nuclear Installation (DBNI) was not justified by a possible need to protect information for the purpose defence. As the commissioning of Intermed in about ten years’ time has become improbable due to the delays in its dimensioning and detailed design, ASN recommends that Andra puts in place, as soon as possible, the necessary storage capacities for the acceptance of highly tritiated waste and sources containing tritium from small producers, prior to their definitive management in a disposal facility or their possible subsequent storage in Intermed. 1.2.3 The National Inventory of radioactive materials and wastes Article L. 542-12 of the Environment Code assigns Andra the task of establishing, updating every three years and publishing the National Inventory of radioactive materials and waste. The last update was published in 2018. The Inventory presents information concerning the quantities, the nature and the location of radioactive material and waste by category and economic sector as at the end of 2016. A prospective exercise, more detailed than for the 2015 edition, was also conducted considering four contrasting scenarios for France’s energy policy, as envisaged in 2017. These scenarios were updated in 2021 and will be used for the next update of the National Inventory, planned to be published in 2023. This Inventory constitutes an input database for preparing the PNGMDR. In its opinion 2020-AV-0363 of 8 October 2020, ASN considers it necessary to plan ahead for the consequences of possible changes in the energy policy regarding the management of materials and waste, and points out that these projections must be based on various long-term hypotheses, consistent with the forecasts of the Multi-year Energy Programme (MEP) adopted by Decree of 21 April 2020. 1.2.4 The National Radioactive Material and Waste Management Plan Article L. 542-1-2 of the Environment Code, amended by the above-mentioned Ordinance 2016-128 of 10 February 2016, defines the objectives of the PNGMDR: ∙ draw up the inventory of the existing radioactive material and waste management methods and the chosen technical solutions; ∙ identify the foreseeable needs for storage or disposal facilities and specify their required capacities and the storage durations; ∙ set the general targets, the main deadlines and the schedules enabling these deadlines to be met while taking into account the priorities it defines; ∙ determine the objectives to be met for radioactive waste for which there is as yet no final management solution; ∙ organises research and studies into the management of radioactive materials and wastes, by setting deadlines for the implementation of new management modes, the creation of facilities or the modification of existing facilities. ASN Report on the state of nuclear safety and radiation protection in France in 2022 361 • 14 • Radioactive waste and contaminated sites and soils 14 01 07 08 13 AP 04 10 06 12 03 09 05 11 02
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