2.1.4 Drafting of recommendations and prescriptions for sustainable waste management ASN issues opinions on the studies submitted under the PNGMDR. Between June 2020 and May 2021, ASN issued seven opinions on the radioactive material and waste management routes, for the preparation of the 5th PNGMDR. ASN also issued an opinion 2021-AV-0390 of 9 November 2021 on the draft 5th plan produced by the Ministry responsible for energy. 2.1.5 Developing the regulatory framework and issuing prescriptions to the licensees ASN can issue regulations. Thus, the provisions of the Order of 7 February 2012 which concern the management of radioactive waste have been set out in the ASN resolutions mentioned earlier relative to waste management in BNIs and the packaging of waste. To give an example, the resolution of 23 March 2017 addresses the packaging of radioactive waste and the conditions of acceptance of the radioactive waste packages in the disposal BNIs. Its aim is to specify the safety requirements at the various stages of a management route. This resolution has been applicable since 1 July 2018. Moreover, to ensure a consistent approach to the management of waste in BNIs and Defence BNIs (DBNIs), ASN and ASND signed an agreement in January 2021 coordinating their actions in this area. More broadly, ASN issues requirements relative to the management of waste coming from the BNIs. ASN indicates certain waste management requirements in two guides: Guide No .18 relative to the management of radioactive effluents and waste produced by a nuclear activity licensed under the Public Health Code, and Guide No. 23 relative to the BNI waste zoning plan (see points 1.2.1 and 1.2.2). Lastly, ASN is consulted for its opinion on draft regulatory texts relative to radioactive waste management. 2.1.6 Evaluation of the nuclear financial costs The regulatory framework designed to secure the financing of nuclear facility decommissioning costs or, for radioactive waste disposal facilities, the final shutdown, maintenance and surveillance costs, in addition to the cost of managing spent fuel and radioactive waste, is described in chapter 13 (see point 1.4) 2.2 Periodic safety reviews of radioactive waste management facilities BNI licensees, including for radioactive waste management facilities, carry out periodic safety reviews of their facilities in order to assess the situation of the facilities with respect to the rules applicable to them and to update the assessment of the risks or adverse effects, taking into account, more specifically, the state of the facility, the experience acquired during operation, and the development of knowledge and rules applicable to similar facilities. The diversity and frequently unique nature of each radioactive waste management facility lead ASN to adopt an examination procedure that is specific to each periodic safety review. In this context, ASN is currently examining six safety reviews of radioactive waste management facilities. They concern: ∙ two BNIs operated by the CEA: the treatment and packaging facility (BNI 35) on the Saclay site and the waste treatment station (BNI 37-A) on the Cadarache site; ∙ one BNI operated by Orano: BNI 118, the waste treatment, packaging and waste package storage facility on the La Hague site; ∙ one BNI operated by Andra: the Manche radioactive waste disposal centre (BNI 66); ∙ one BNI operated by EDF: BNI 74 comprising the SaintLaurent-des‑Eaux storage silos; ∙ one BNI operated by Cyclife France: the Centraco facility for waste treatment by melting or incineration (BNI 160). 2.2.1 Periodic safety reviews of radioactive waste management support facilities The periodic safety reviews of the oldest facilities such as BNIs 35, 37-A, 74 and 118 present particular challenges. The Saint‑Laurent‑des‑Eaux silos (BNI 74) present safety risks, particularly in view of their inventories. These safety reviews must address the control of the waste storage conditions, including legacy waste, the WRP of this waste with a view to removal via the dedicated route and scheduled post-operational clean-out of the buildings. In relation with these challenges, the safety reviews must ensure that the impacts of discharges into the environment (soils, groundwater, or seawater in the case of BNI 118) are controlled. For the most recent facilities, as is the case with Cedra and Chicade, the periodic safety reviews highlight more generic problems. The resistance of the buildings to internal and external hazards (earthquake, fire, lightning, flooding, aircraft crash) is one of the important aspects. ASN issued its conclusions on the periodic safety review of the Cedra storage facility on 3 December 2021 and those for the Chicade safety review on 29 August 2022. 2.2.2 Periodic safety reviews of radioactive waste disposal facilities The safety reviews of the CSM (BNI 66) and the CSA (BNI 149) have the particularity of addressing control of the risks and adverse effects over the long term, in addition to reassessing their operational control. Their purpose is therefore more specifically to update, if necessary, the scenarios, models and long-term assumptions in order to confirm satisfactory control of the risks and adverse effects over time. The periodic safety reviews of these two facilities thus highlight the need for increased knowledge of the long-term impacts associated with the toxic chemicals contained in some waste and of the impacts of the radionuclides on the environment (flora and fauna) ASN issued its conclusions on the second periodic safety review of the CSA on 25 July 2022, while examination of the second safety review of the CSM is currently in progress, following a review of this file by the Advisory Committee on Radioactive Waste on 1 February 2022. The successive safety reviews must also serve to detail the technical measures planned by the licensee to control the adverse effects of the facility over the long term, notably for the systems for covering these facilities which contributes to the final containment of the disposal concrete blocks. The durability of the CSM cover and the preservation of the site memory for future generations are the two predominant themes of the periodic safety review of a radioactive waste disposal facility. Lastly, these safety reviews provide the opportunity of detailing, as time goes by, the measures the licensee plans implementing to ensure the long-term surveillance of the behaviour of the disposal facility. ASN Report on the state of nuclear safety and radiation protection in France in 2022 371 • 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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