THE ROLE OF ASN IN WASTE MANAGEMENT The public authorities, and ASN in particular, are attentive to the fact that there must be a management route for all waste and that each waste management step is carried out under safe conditions. ASN thus considers that the development of management routes appropriate to each waste category is fundamental and that any delay in the search for long-term waste disposal solutions will increase the volume and size of the storage areas in the facilities and the inherent risks. ASN takes care, particularly within the framework of the PNGMDR but also by inspecting the installations and regularly assessing the licensees’ waste management strategy, to ensure that the system made up by all these routes is complete, safe and coherent. This approach must take into consideration all the issues of safety, radiation protection, minimising waste volume and toxicity, while ensuring satisfactory traceability of the operations performed. Finally, ASN considers that this management approach must be conducted in a manner that is transparent for the public and involves all the stakeholders, in a framework that fosters the expression of different opinions. The PNGMDR is drawn up by the Ministry of Ecological Transition. The Ministry has opted, in the light of the public debate of 2019, to rely on a pluralistic “Guidance Commission”, in which ASN participates. This Commission is chaired by an independent qualified person. Monitoring of the technical and operational implementation of the PNGMDR is still ensured by a pluralistic working group co-chaired by ASN and the General Directorate for Energy and the Climate (DGEC), as described in chapter 2. ASN also publishes on its website the PNGMDR, its synthesis, the minutes of the above-mentioned working group’s meetings, the studies required by the plan and the opinions it has issued on these studies. PUBLICATION OF THE 5TH NATIONAL RADIOACTIVE MATERIALS AND WASTE MANAGEMENT PLAN (PNGMDR) Radioactive materials and wastes must be managed sustainably and responsibly, to protect individual health, safety and the environment, including in the long and very-long term. Instituted by the Act of 28 June 2006 on the sustainable management of radioactive materials and waste, the PNGMDR is a management tool of choice for the sustainable implementation of these principles. The PNGMDR covers the ultimate waste and the reusable radioactive materials alike, the existing management routes and those that are planned, under development or to be defined; it also concerns all categories of radioactive waste, whatever their origin. The PNGMDR takes account of the French energy policy and the management solutions it sets out are compatible with the Multi-year Energy Programme (MEP). For the first time ever, the preparation of the 5th PNGMDR was preceded by a public debate held in 2019. On 21 February 2020, further to this public debate, the Ministry for Energy Transition (MTE) and ASN published a joint resolution setting out the broad lines of the plan. In 2020 and 2021, ASN subsequently issued seven technical opinions on the management of radioactive materials and waste with a view to drafting the 5th PNGMDR. In the course of preparation of the 5th plan by the MTE, ASN issued general opinions 2021-AV-0390 and 2022-AV-0403 on 9 November 2021 and 23 June 2022 respectively. ASN issued a favourable opinion on the draft PNGMDR 2022‑2026 and the associated draft decree and order, subject to some reservations concerning the consideration in particular of: ■ pessimistic operating scenarios for the “fuel cycle” and the forecast dates of saturation of the spent fuel storage capacities; ■ the required forward planning of the actions associated with a decision to either stop or continue reprocessing spent fuels beyond 2040; ■ its opinion of 19 March 2021 on the safety of management of HL/ILW-LL waste; ■ the continuation of the work to establish specific management routes for certain types of waste, and in particular those containing tritium, disused sealed sources, organic oils and liquids and activated waste from small producers (hospital, laboratories, etc.). Alongside this, ASN has insisted on the need to assess the recyclable nature of radioactive materials taking into account the quantities in question and the time frames for the possible development of industrial processes that could use these materials – failing which the administrative authority will have to requalify them for management as waste. Decree 2022‑1547 of 9 December 2022 provided for by Article L. 542‑1‑2 of the Environment Code and establishing the requirements of the PNGMDR and the Order issued in application of the said Decree were published in the Official Journal of the French Republic on 10 December 2022. The MTE took ASN’s recommendations concerning prevention of saturation of the spent fuel storage areas, the management of tritiated waste and of activated waste from the accelerators, and ensuring the reliability of the LLW-LL into account in the final versions of the said Decree and Order. Some recommendations however were not retained, such as that concerning the assessment of the radioactive waste recyclability. ASN considers that the PNGMDR 2022‑2026 and the associated regulatory texts must allow the necessary decisions to be made, before it reaches term, so that safe management routes are operational in the 15 to 20 years to come for all types of radioactive waste. 362 ASN Report on the state of nuclear safety and radiation protection in France in 2022 • 14 • Radioactive waste and contaminated sites and soils 14
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