commissioned. These complex projects meet with technical difficulties which can make it necessary to adjust deadlines set by ASN (see chapter 13). In addition, the on-site radioactive waste storage capacities must be planned for with conservative margins in order to prevent them reaching saturation. The legacy waste stored on the Tricastin site necessitates a large amount of work to characterise it and find management solutions. The storage conditions in some of the Tricastin site facilities do not meet current safety requirements and must be improved. ∙ The defining of solutions for waste packaging, in particular the legacy waste. The methods of packaging the radioactive waste require the prior approval of ASN in accordance with Article 6.7 of the Order of 7 February 2012 (see point 2.2.2). Keeping control of the packaging deadlines is a particularly important aspect, which requires the development of characterisation programmes to demonstrate the feasibility of the chosen packaging processes and to identify sufficiently early the risks that could significantly affect the project. If necessary, when the feasibility of the defined packaging cannot be determined within times compatible with the prescribed deadlines, the licensee must plan for an alternative solution, including in particular interim storage areas allowing the retrieval and characterisation of the legacy waste as rapidly as possible, while guaranteeing the absence of any counter-action that could jeopardise final packaging. For information, Article L. 542‑1‑3 of the Environment Code requires that the ILW-LL waste produced before 2015 be packaged by the end of 2030 at the latest. Within the framework of the WRP operations, Orano is examining packaging solutions that necessitate the development of new processes, particularly for the following ILW-LL waste: ∙ the radioactive sludge from the La Hague STE2 facility; ∙ the alpha-emitting technological waste which comes primarily from the La Hague and Melox plants (Gard département) and is not suitable for above-ground disposal. For other types of ILW-LL waste resulting from the WRP operations, Orano is examining the possibility of adapting existing processes (compaction, cementation, vitrification). Some of the associated packaging baseline requirements are currently being examined by ASN. 2.5 EDF’s waste management strategy and its assessment by ASN The radioactive waste produced by EDF comes from several distinct activities. It mainly comprises waste from the operation of the NPPs, which consists of activated waste from the reactor cores, and waste from their operation and maintenance. Some legacy waste and waste resulting from ongoing decommissioning operations can be added to this. EDF is also the owner, for the share attributed to it, of HLW and ILW-LL waste resulting from spent fuel reprocessing in the Orano La Hague plant. Activated waste This waste notably comprises control rod assemblies and poison rod assemblies used for reactor operation. This is ILW-LL waste that is produced in small quantities. At present this waste is stored in the NPP fuel storage pools pending transfer to the Iceda facility. Operational and maintenance waste Some of the waste is processed by melting or incineration in the Centraco facility, in order to reduce the volume of ultimate waste. The other types of operational and maintenance waste are packaged on the production site then shipped to the CSA or Cires repositories for disposal (see points and 1.3.2). This waste contains beta and gamma emitters, and few or no alpha emitters. At the end of 2013, EDF submitted a file presenting its waste management strategy. After examining this file, ASN in 2017 asked EDF to continue its measures to reduce the uncertainties concerning the activity of the waste sent to the CSA, to improve its organisational arrangements to guarantee the allocation of sufficient resources to radioactive waste management, and to present the most appropriate process for the treatment of used steam generators. Lastly, the spent control rod cluster guide tubes of the EDF fleet could be either: ∙ processed by Cyclife France in the Centraco facility with the aim of reducing the waste volume; ∙ or emplaced directly in the CSA. EDF is studying both options. The issues and challenges The main issues relating to the EDF waste management strategy concern: ∙ The management of legacy waste. This mainly concerns structural waste (graphite sleeves) from the GCR fuels. This waste could be disposed of in a repository for LLW-LL waste (see point 1.3.4). It is stored primarily in semi-buried silos at Saint-Laurent-des-Eaux. Graphite waste is also present in the form of stacks in the GCRs currently being decommissioned. In the context of the PNGMDR 2016-2018, EDF conducted a study of the reliability of the activity predictions for this waste and submitted its conclusions in December 2019. This report is being examined by ASN. ∙ The changes linked to the “fuel cycle”. EDF’s fuel use policy (see chapter 10) has consequences for the “fuel cycle” installations (see chapter 11) and for the quantity and nature of the waste produced. ASN issued an opinion on the coherence of the nuclear fuel cycle in October 2018 (see chapter 11). ASN Report on the state of nuclear safety and radiation protection in France in 2022 373 • 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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