In view of the conclusions of the public debate of 2019, ASN and the DGEC have decided to change the governance of the PNGMDR. The 5th PNGMDR is prepared by the Ministry of Ecological Transition, based in particular on the work of a “Guidelines Commission”. Introduced by the resolution of 21 February 2020, this Commission is chaired by an independent qualified personality and brings together, in addition to the legacy members of the pluralistic working group mentioned in chapter 2, elected officials and representatives of the regional authorities. This Commission gave opinions on various major subjects relating to the management of radioactive waste (management of very low level – VLL/LLW-LL waste, management of radioactive materials, etc.). ASN participates actively in the Guidelines Commission – albeit without voting rights – to provide its guidance on the safety and radiation protection issues. Implementation of the plan is then followed up at periodic meetings of the PNGMDR working group jointly chaired by ASN and the DGEC. In 2020 and 2021, ASN assessed the studies submitted for the PNGMDR 2016-2018. For the preparation of the 5th PNGMDR, ASN has thus issued seven opinions on the radioactive material and waste management routes in which it sets out a number of recommendations. In addition, on 9 November 2021, ASN issued a favourable opinion for the draft PNGMDR 2021-2025, on condition that it is supplemented with a study of worst-case operating scenarios for the “fuel cycle”, an assessment of the impact on the nuclear facilities of continuing the reprocessing of spent fuel beyond 2040 or not, the inclusion of measures relative to the safety of HL/ILW-LL waste management and the management of waste necessitating specific work, such as tritiated waste, and better assessing the recyclability of certain radioactive materials. Lastly, on 23 June 2022 ASN issued a favourable opinion on the draft Decree and Order establishing the requirements of the 5th PNGMDR, subject to the integration of the modifications proposed in this opinion. These texts and the 5th PNGMDR covering the 2022‑2026 period were published on 9 December 2022. 1.3 Long-term management of waste – existing or projected disposal facilities 1.3.1 Very low-level waste Very low-level waste (VLLW) comes essentially from the oper– ation, maintenance and decommissioning of nuclear facilities. It consists mainly of inert waste (rubble, earth, sand) and metal waste. Its specific activity is usually less than 100 becquerels per gram (Bq/g) and can even be below the detection threshold of certain measuring devices. The Cires includes a VLL waste disposal facility. This facility, which has ICPE status, has been operational since August 2003. At end of 2022, Cires held 429,869 m3 of VLL waste, which represents 66% of its authorised capacity. According to the national inventory produced by Andra, the quantity of VLL waste resulting from decommissioning of the existing nuclear facilities will be about 2,200,000 m3. According to current forecasts, the facility could be filled to maximum capacity around 2029. Andra is currently working on the Acaci project, which aims to increase the facility’s authorised capacity to more than 900,000 m3, without changing its ground surface area (compared with the 650,000 m3 currently authorised). In its opinion 2020-AV-0356 of 30 June 2020 on the management of VLL waste, ASN calls for the continuation and extension of the work undertaken in the 2016-2018 edition of the PNGMDR with the aim of improving current management methods and developing complementary management solutions which remain to be devised and implemented. ASN reaffirms that the foundations of VLL waste management must be based on the place of origin of the waste and guarantee its traceability from production through to disposal, with the exception of metallic VLL waste that is to be recycled, as stated in the resolution of 21 February 2020. The recycling of certain types of waste which will be produced in large volumes is encouraged, consistently with the waste management hierarchy defined in the Environment Code. ASN recommends more specifically continuation of the project for a metal materials recycling facility, with the setting up of a specific regulatory framework for this facility. In 2021, the Government worked on setting up this regulatory framework. In its opinion 2021-AV-0380 of 11 May 2021, ASN expressed its views on the draft regulations. In February 2022, the Government published the regulatory framework for authorising, as a waiver, the recycling of weakly radioactive metal substances after melting and decontamination. This type of waiver will be granted by Ministerial Order. In addition, ASN considers it necessary for all the stakeholders, especially the representatives of the localities actually or likely to be concerned, to be more actively involved in defining LLW waste management solutions. It recommends that the studies for putting in place additional disposal facilities, whether centralised or decentralised, be continued and that the government should clarify Andra’s responsibility in this respect. Consistently with the above-mentioned ASN opinion, the 5th PNGMDR contains the following objectives concerning the management of VLL waste: ∙ continue the studies aiming to deploy new centralised and decentralised storage capacities for VLL waste; ∙ continue looking into the recycling of VLL waste, particularly defining the conditions of implementation of metallic waste recycling; ∙ define VLL waste management scenarios, cast light upon their environmental, regional, health and safety issues, and use this to establish an overall management strategy; ∙ refine the perspectives for the production of VLL waste from the decommissioning of the nuclear installations, by explicitly identifying the waste associated with the clean-out of structures and contaminated soils. 1.3.2 Low and intermediate-level, short-lived waste Low-level and intermediate-level short-lived waste (LL/ILW-SL) – in which the radioactivity comes primarily from radionuclides with a half-life of less than 31 years – results essentially from the operation of nuclear facilities and more specifically from maintenance activities (clothing, tools, filters, etc.). It can also come from the post-operational clean-out and decommissioning of these facilities. The majority of LL/ILW-SL waste is placed in surface disposal facilities operated by Andra. Once these facilities are closed, they will be monitored for a period set at 300 years by Basic Safety Rule RFS-I.2. The facility safety analysis reports – which are updated periodically, including during the monitoring phase – must show that at the end of this phase, the residual activity contained in the waste will have reached a residual level such that human and environmental exposure levels are acceptable, even in the event of a significant loss of the containment properties of the facility. There are two facilities of ASN Report on the state of nuclear safety and radiation protection in France in 2022 363 • 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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