ASN REPORT on the state of nuclear safety and radiation protection in France in 2023
The French Nuclear Safety Authority presents its Report on the state of nuclear safety and radiation protection in France in 2023. This Report is required by Article L. 592-31 of the Environment Code. It was submitted to the President of the Republic, the Prime Minister and the Presidents of the Senate and the National Assembly and transmitted to the Parliamentary Office for the Evaluation of Scientific and Technological Choices, pursuant to the above-mentioned Article.
reated by the 13 June 2006 Nuclear Transparency and Security Act, ASN is an independent administrative Authority responsible for regulating civil nuclear activities in France. On behalf of the State, ASN ensures the oversight of nuclear safety and radiation protection to protect people and the environment. It informs the public and contributes to enlightened societal choices. ASN decides and acts with rigour and discernment: its aim is to exercise oversight that is recognised by the citizens and regarded internationally as a benchmark for good practice. C 2023 THE FRENCH NUCLEAR SAFETY AUTHORITY ROLES OPERATIONS KEY FIGURES ASN ORGANISATION CHART ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2023
REGULATING ASN contributes to drafting regulations, by submitting its opinion to the Government on draft decrees and Ministerial Orders, and by issuing technical regulations. It ensures that the regulations are clear, accessible and proportionate to the safety issues. AUTHORISING ASN examines all individual license applications for nuclear facilities. It grants licenses and authorisations, with the exception of major authorisations for Basic Nuclear Installations (BNIs), such as creation and decommissioning. ASN also issues the licenses provided for in the Public Health Code concerning small-scale nuclear activities and issues licenses or approvals for radioactive substances transport operations. MONITORING ASN is responsible for ensuring compliance with the rules and requirements applicable to the facilities and activities within its field of competence. Since the Act of 17 August 2015 on energy transition for green growth, known as the “TECV Act”, ASN’s roles now include protecting ionising radioactive sources against malicious acts. Inspection is ASN’s primary monitoring activity. In 2023, 1,790 inspections were thus performed by ASN in the fields of nuclear safety and radiation protection. ASN has graded enforcement and penalty powers (formal notice, administrative fines, daily fines, ability to carry out seizure, take samples or require payment of a guarantee, etc.). The administrative fine is the competence of the ASN Administrative Enforcement Committee, which complies with the principle of the separation of the examination and sentencing functions. INFORMING ASN reports on its activities to Parliament. It informs the public and the stakeholders (environmental protection associations, Local Information Committees, media, etc.) about its activities and the state of nuclear safety and radiation protection in France. ASN enables all members of the public to take part in the drafting of its decisions with an impact on the environment. It supports the actions of the Local Information Committees set up around the nuclear installations. The asn.fr website is ASN’s main information channel. IN EMERGENCY SITUATIONS ASN monitors the steps taken by the licensee to make the facility safe. It informs the public and its foreign counterparts of the situation. ASN assists the Government. More particularly, it sends the competent Authorities its recommendations regarding the civil security measures to be taken. REGULATION AND MONITORING OF DIVERSIFIED ACTIVITIES AND FACILITIES Nuclear power plants, radioactive waste management, fabrication and reprocessing of nuclear fuel, packages of radioactive substances, medical facilities, research laboratories, industrial activities, etc. ASN monitors and regulates an extremely varied range of activities and installations. This regulation covers: ∙ 56 nuclear reactors producing 70% of the electricity consumed in France, as well as the Flamanville EPR reactor under construction; ∙ about 80 other facilities participating in civil research activities, radioactive waste management activities or “fuel cycle” activities; ∙ 36 facilities which have been finally shut down or are being decommissioned; ∙ several thousand facilities or activities using sources of ionising radiation for medical, industrial or research purposes; ∙ several hundred thousand shipments of radioactive substances performed annually in France. EXPERT SUPPORT When drawing up its decisions, ASN calls on outside technical expertise, in particular that of the French Institute for Radiation Protection and Nuclear Safety (IRSN). The ASN Chairman is a member of the IRSN Board. ASN also calls on the opinions and recommendations of seven Advisory Committees of Experts (GPEs), from a variety of scientific and technical backgrounds. THE FRENCH NUCLEAR SAFETY AUTHORITY Roles
THE COMMISSION The Commission defines ASN’s general policy regarding nuclear safety and radiation protection. It consists of five Commissioners, including the ASN Chairman, appointed for a term of 6 years(*). APPOINTED BY the President of the Republic APPOINTED BY the President of the Senate APPOINTED BY the President of the National Assembly THE DEPARTMENTS ASN comprises departments placed under the authority of its Chairman. The departments are headed by a Director General, appointed by the ASN Chairman. They carry out ASN’s day-to-day duties and prepare draft opinions and decisions for the ASN Commission. They comprise: ∙ head office departments organised according to topics, which oversee their field of activity at a national level, for both technical and transverse matters (international action, preparedness for emergency situations, information of the public, legal affairs, human resources and other support functions). They more specifically prepare draft doctrines and texts of a general scope, examine the more complex technical files and the “generic” files, in other words those which concern several similar facilities; ∙ 11 regional divisions, with competence for one or more administrative regions, so as to cover the entire country and the overseas territories. The regional divisions conduct most of the oversight in the field on the nuclear facilities, radioactive substances transport operations and small-scale nuclear activities. They represent ASN in the regions and contribute to public information within their geographical area. In emergency situations, the divisions assist the Prefect of the département(**) who is responsible for the protection of the population, and oversee the operations to safeguard the facility affected by the accident. Bernard DOROSZCZUK Chairman Stéphanie GUÉNOT BRESSON (*) Commissioner Géraldine PINA (*) Commissioner Olivier DUBOIS (*) Commissioner Jean-Luc LACHAUME (*) Commissioner from 13 November 2018 to 12 November 2024 from 10 December 2023 to 9 December 2029 from 15 December 2020 to 9 December 2026 from 29 January 2024 to 9 December 2029 from 21 December 2018 to 9 December 2026 IMPARTIALITY The Commissioners perform their duties in complete impartiality and receive no instructions from either the Government or any other person or institution. INDEPENDENCE The Commissioners perform their duties on a full-time basis. Their mandate is for a six-year term. It is not renewable. The duties of a Commissioner can only be terminated in the case of impediment or resignation duly confirmed by a majority of the Commissioners. The President of the Republic may terminate the duties of any member of the Commission in the event of a serious breach of his or her obligations. COMPETENCIES The Commission takes decisions and issues opinions, which are published in ASN’s Official Bulletin. The Commission defines ASN's oversight policy. The Chairman appoints the ASN inspectors. The Commission decides whether to open an inquiry following an incident or accident. Every year, it presents Parliament with the ASN Report on the state of nuclear safety and radiation protection in France. Its Chairman reports on ASN activities to the competent committees of the National Assembly and of the Senate and to the Parliamentary Office for the Evaluation of Scientific and Technological Choices. The Commission defines ASN's external relations policy at national and international level. * The Environment Code, modified by Act 2017-55 of 20 January 2017, introducing the general status of the independent administrative Authorities and the independent public Authorities, provides for the renewal of half of the ASN Commission, other than its Chairman, every three years. Decree 2019-190 of 14 March 2019 (codifying the provisions applicable to BNIs, the transport of radioactive substances and transparency in the nuclear field) sets out the relevant interim provisions and modifies the duration of the mandates of three Commissioners. ** Administrative region headed by a Prefect. THE FRENCH NUCLEAR SAFETY AUTHORITY Operations ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2023
THE FRENCH NUCLEAR SAFETY AUTHORITY PERSONNEL 521 48% women 86% management 307 inspectors staff members BUDGET €71.62 M €85.1 M IRSN budget devoted to expert assessment work on behalf of ASN budget for ASN (programme 181) INFORMING 656 11 press conferences 84 information notices replies to queries from the public and the stakeholders ASN in 2023 ASN ACTIONS 1,940 individual licensing and registration resolutions issued 26 plenary sessions of the Advisory Committees of Experts 30,022 inspection follow-up letters available on asn.fr as at 31 December 2023 398 IRSN deliverables submitted to ASN, including 183 expert assessment opinions inspections 1,790
IN THE MEDICAL FIELD RATED ON THE INES SCALE (*) * The INES scale (International Nuclear and Radiological Event Scale) was developed by the International Atomic Energy Agency (IAEA) to explain to the public the importance of an event in terms of safety or radiation protection. This scale applies to events occurring in BNIs and events with potential or actual consequences for the radiation protection of the public and workers. It does not apply to events with an impact on the radiation protection of patients, and the criteria normally used to rate events (notably the dose received) are not applicable in this case. As it was pertinent to be able to inform the public of radiotherapy events, ASN – in close collaboration with the French Society for Radiotherapy and Oncology – developed a scale specific to radiotherapy events (ASN-SFRO scale). These two scales cover a relatively wide range of radiation protection events, with the exception of imaging events. 1,098 events 1,010 86 86 events 2 201 events 2 25 Level 0 Level 1 Level 2 SMALL-SCALE NUCLEAR ACTIVITIES (medical and industry) TRANSPORT OF RADIOACTIVE SUBSTANCES BASIC NUCLEAR INSTALLATIONS 84 176 NUMBER OF SIGNIFICANT EVENTS IN 2023 658 significant events per area of exposure BRACHYTHERAPY EXTERNAL-BEAM RADIOTHERAPY NUCLEAR MEDICINE COMPUTED TOMOGRAPHY DENTAL RADIOLOGY CONVENTIONAL RADIOLOGY FLUOROSCOPY-GUIDED INTERVENTIONAL PRACTICES 4 237 205 96 28 10 78 THE FRENCH NUCLEAR SAFETY AUTHORITY Out of scale Level 0 Level 1 Level 2 106 significant events in external beam radiotherapy and brachytherapy according to the rating on the ASN-SFRO scale 7 51 34 14 ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2023
THE FRENCH NUCLEAR SAFETY AUTHORITY Organisation Chart(*) HEAD OF PRIVATE OFFICE Sylvie RODDE CHAIRMAN Bernard DOROSZCZUK ETHICS OFFICER Alain DORISON MANAGEMENT AND EXPERTISE OFFICE Adeline CLOS REGULATION AND OVERSIGHT SUPPORT MISSION Julien HUSSE INNOVATIVE REACTORS MISSION Philippe DUPUY NUCLEAR PRESSURE EQUIPMENT Flavien SIMON WASTE, RESEARCH FACILITIES AND FUEL CYCLE Cédric MESSIER NUCLEAR POWER PLANTS Rémy CATTEAU IONISING RADIATION AND HEALTH Carole ROUSSE ENVIRONMENT AND EMERGENCY SITUATIONS Olivier RIVIÈRE TRANSPORT AND SOURCES Fabien FÉRON INTERNATIONAL RELATIONS Luc CHANIAL LEGAL AFFAIRS Andy CONTESSO INFORMATION, COMMUNICATION AND DIGITAL USAGES Clémence PICART COMMISSION DEPARTMENTS COMMISSIONERS Olivier DUBOIS Stéphanie GUÉNOT BRESSON Jean-Luc LACHAUME Géraldine PINA CHAIRMAN Maurice MÉDA ADMINISTRATIVE ENFORCEMENT COMMITTEE GENERAL SECRETARIAT Jean-Patrick GOUDALLE DIRECTOR GENERAL Olivier GUPTA DEPUTY DIRECTORS GENERAL Pierre BOIS Julien COLLET Daniel DELALANDE CHIEF INSPECTOR Christophe QUINTIN TECHNICAL ADVISER Sylvie CADET-MERCIER DIRECTOR OF PRIVATE OFFICE Vincent CLOÎTRE GENERAL DIRECTORATE
OVERSEAS DÉPARTEMENTS AND REGIONS 10 Lille Division Hauts-de-France Châlons-en-Champagne Division (4) Grand Est Strasbourg Division (4) Grand Est Lyon Division Auvergne-Rhône-Alpes Marseille Division (3) Corse, Occitanie, Provence-Alpes-Côte d'Azur Bordeaux Division (3) Nouvelle-Aquitaine, Occitanie Nantes Division Brittany, Pays de la Loire Caen Division (1) Normandie Paris Division (2) Île-de-France, DROM-COM (overseas France) Orleans Division (1) Centre-Val de Loire 11 Dijon Division Bourgogne-Franche-Comté 2 8 9 10 5 3 4 6 7 1 THE FRENCH NUCLEAR SAFETY AUTHORITY (1) For BNI oversight only, the Caen and Orléans divisions hold responsibility for the Bretagne and Île-de-France regions respectively. (2) The Paris division is responsible for Martinique, Guadeloupe, Guyane, Mayotte, La Réunion, Saint-Pierre-et-Miquelon. (3) The Bordeaux and Marseille divisions jointly regulate nuclear safety, radiation protection and the transport of radioactive substances in the Occitanie region. (4) The Châlons-en-Champagne and Strasbourg divisions jointly regulate nuclear safety, radiation protection and the transport of radioactive substances in the Grand Est region. * As at 1 March 2024. 1 BORDEAUX REGIONAL REPRESENTATIVE Vincent JECHOUX REGIONAL HEAD Paul de GUIBERT 2 CAEN REGIONAL REPRESENTATIVE Olivier MORZELLE REGIONAL HEAD Gaëtan LAFFORGUE REGIONAL DIVISIONS 4 DIJON REGIONAL REPRESENTATIVE Olivier DAVID REGIONAL HEAD Marc CHAMPION 7 MARSEILLE REGIONAL REPRESENTATIVE Sébastien FOREST REGIONAL HEAD Mathieu RASSON 5 LILLE REGIONAL REPRESENTATIVE Julien LABIT REGIONAL HEAD Rémy ZMYSLONY 8 NANTES REGIONAL REPRESENTATIVE Anne BEAUVAL REGIONAL HEAD Émilie JAMBU 10 PARIS REGIONAL REPRESENTATIVE Emmanuelle GAY REGIONAL HEAD Agathe BALTZER 6 LYON REGIONAL REPRESENTATIVE Jean-Philippe DENEUVY REGIONAL HEAD Nour KHATER 9 ORLÉANS REGIONAL REPRESENTATIVE Hervé BRÛLÉ REGIONAL HEAD Albane FONTAINE 11 STRASBOURG REGIONAL REPRESENTATIVE Hervé VANLAER REGIONAL HEAD Camille PERIER 3 CHÂLONS-EN-CHAMPAGNE REGIONAL REPRESENTATIVE Hervé VANLAER REGIONAL HEAD Mathieu RIQUART ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2023
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ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2023 EDITORIAL BY THE COMMISSION p. 2 • EDITORIAL BY THE DIRECTOR GENERAL p. 8 NOTABLE EVENTS 2023 p. 11 • ASN ASSESSMENTS p. 20 • REGULATORY NEWS p. 30 REGIONAL OVERVIEW OF NUCLEAR SAFETY AND RADIATION PROTECTION p. 34 Nuclear activities: ionising radiation and health and environmental risks p. 98 01 Transport of radioactive substances p. 270 09 The principles of nuclear safety and radiation protection and the regulation and oversight stakeholders p. 120 02 The EDF Nuclear Power Plants p. 288 10 Regulation of nuclear activities and exposure to ionising radiation p. 144 03 “Nuclear fuel cycle” facilities p. 328 12 Radiological emergency and post-accident situations p. 168 04 Informing the public p. 180 05 Decommissioning of Basic Nuclear Installations p. 344 14 International relations p. 190 06 Radioactive waste and contaminated sites and soils p. 366 15 Medical uses of ionising radiation p. 204 07 The emergence of small modular reactor projects p. 320 11 Sources of ionising radiation and their industrial, veterinary and research applications p. 240 08 ADVICE TO THE READER i The control of small-scale nuclear facilities (medical, research and industry, transport) is presented in chapters 7, 8, 9. Only regulatory news for the year 2021 is present in this report. All the regulations can be consulted on asn.fr, under the heading “L’ASN réglemente”. SUMMARY Nuclear research and miscellaneous industrial facilities p. 338 13 Overview of Basic Nuclear Installations as at 31 December 2023 p. 386 APPENDIX
2023, a key year marked by new nuclear ambitions Montrouge, 1 March 2024 2 ASN Report on the state of nuclear safety and radiation protection in France in 2023 EDITORIAL BY THE COMMISSION he safety level of the nuclear facilities was satisfactory in 2023, with less pressure on the “fuel cycle” facilities than in 2022 and with implementation by EDF of a strategy that ASN considered to be appropriate for dealing with and remedying the stress corrosion phenomenon that had appeared on some of its reactors. Radiation protection performance remained at a good level despite an increase in the number of level 2 significant events in the medical sector. This mixed picture recalls the importance of conducting radiotherapy risk assessments. At a time of new nuclear ambitions, ASN underlines three topics that deserve particular attention: 1. The more ambitious aims by the licensees, for the continued operation of the existing nuclear facilities, requires that the measures to be implemented without delay in order to safely achieve these new objectives be identified. They also require that forward planning for the long-term issues regarding the reactors must be continued and reinforced with a view to operation beyond 60 years, in coordination with the new “fuel cycle” facilities being envisaged, while clarifying future reprocessing solutions. 2. The enthusiasm for the Small Modular Reactors (SMRs) and Advanced Modular Reactors (AMRs) which have potentially promising intrinsic safety characteristics, should not eclipse the technical and societal issues that they raise. These issues are notably linked to the preliminary work to be done to demonstrate their dependability, to all the safety/security and non-proliferation issues to be considered upstream, and to the acceptability of the siting of these reactors outside dedicated nuclear sites. 3. The numerous new nuclear projects require an exceptional effort in terms of expertise, project management and industrial rigour, which concerns the entire sector. Despite the progress made in technical expertise and management of activities, the checks carried out by ASN along the procurement chain for the equipment intended for nuclear facilities still highlight a recurring lack of industrial rigour. Over and above these shortfalls, against the backdrop of a significant increase in workload, preventing falsification and counterfeiting at all levels along the subcontracting chain must remain a major point of focus across the sector. T
ANTICIPATING TECHNICAL QUESTIONS RAISED BY THE OPERATING LIFE OF THE REACTORS REMAINS A PRIORITY The law requires that every ten years, following the periodic safety review, ASN issue a position statement regarding the conditions for the continued operation of the nuclear facilities. Concerning the reactors, the fourth periodic safety review for each individual reactor is underway for the 900 Megawatts electric (MWe) reactors, and the generic review phase for the 1,300 MWe reactors has been started. As the fifth periodic safety review is too far into the future for any fundamental operating lifetime hypotheses to be incorporated into the energy policy for the 2040 time-frame and beyond, ASN asked EDF to conduct preliminary analyses of the ability of the reactors to continue to function beyond 50 years. At the Government’s request, ASN issued an opinion on June 2023 on the conclusions of EDF’s analysis, underlining the major technical subjects associated with an operating life of up to 60 years, along with the subjects to be addressed as priorities. Finally, going beyond this time-frame and on the basis of the work initiated by EDF, the main technical subjects requiring particular analysis, or even research and development, ahead of the periodic safety reviews, were identified in 2023, enabling continued reactor operations beyond 60 years to be envisaged. In 2026, ASN will issue a position statement on the conclusions of these EDF analyses which are expected at the end of 2024. ASN Report on the state of nuclear safety and radiation protection in France in 2023 3 Editorial by the Commission From left to right: Stéphanie GUÉNOT BRESSON, Commissioner Olivier DUBOIS, Commissioner Géraldine PINA, Commissioner Bernard DOROSZCZUK, Chairman Jean‑Luc LACHAUME, Commissioner
SATISFACTORY DEPLOYMENT OF THE STRESS CORROSION TREATMENT STRATEGY Following the discovery of stress corrosion cracking on the safety injection system of the main primary systems of some reactors at the end of 2021, EDF proposed a strategy involving the systematic replacement in 2023 of the lines considered to be susceptible to the phenomenon on those reactors liable to be the most severely affected, with inspection of all reactors by 2025. In 2023, EDF implemented the proposed replacement strategy. The inspections carried out revealed the fact that certain weld repair processes during manufacturing were a factor liable to influence the appearance of stress corrosion, even on lines considered not to be susceptible to the problem. This enabled EDF to revise its inspection strategy, giving priority to the welds which had been repaired during manufacturing. EDF also decided to extend its spot-check inspection programme to all stainless steel lines connected to the primary system. ASN considered this strategy to be appropriate, while pointing out that it might need to be revised in the light of the lessons learned from the ongoing programme of investigations. ASN also asked EDF to already take account of these lessons in the design of new reactors. ASN is working in close collaboration with its foreign counterparts on this subject. Following the presentation of the findings made in France on the EDF fleet, the Western European Nuclear Regulators’ Association (WENRA) issued recommendations concerning monitoring of the stress corrosion phenomenon for the reactors in operation, along with prevention of this phenomenon at the design stage. PRESSURE ON THE “FUEL CYCLE” FACILITIES IS EASING BUT THIS SHOULD NOT MASK THE NEED TO PREPARE FOR THE FUTURE The pressure identified in recent years in the “fuel cycle” eased in 2023, in particular due to improved Melox plant production. These improvements and the prospect of a new Multi- year Energy Programme (PPE) could lead to the saturation time-frame for the Orano pools at La Hague being reconsidered. ASN nonetheless considers that new safe storage capacity will eventually be needed, in compliance with current standards, to ensure margins to deal with any contingencies affecting the facilities. Generally speaking, ASN considers that the entire chain of back-end fuel management facilities and units must urgently be made more resilient so that the 2040 target set in the current PPE can be reached in safe conditions. This entails measures to be implemented without delay in order to meet this target, such as consolidation of MOX fuel production, developing interoperability between the reprocessing lines, the performance of considerable renovation and safety improvement works identified during the periodic safety reviews. The work undertaken on densification of the existing pools at the La Hague plant, along with dry storage, as means of dealing with the saturation risk, shall be continued. ASN FINALISES THE TECHNICAL EXAMINATION PROCESS AND CHECKS THE LICENSEE’S PREPAREDNESS FOR EPR COMMISSIONING The year 2023 was devoted to finalising the examination of technical subjects still open (design of primary system safety valves and performance of the internal water tank filtration system in particular), incorporating the latest modifications, and the performance of hot tests to ensure the overall qualification of the installation. In May 2023, ASN carried out an in-depth inspection involving a large number of inspectors and experts, to check the licensee’s preparedness for commissioning of the installation. ASN noted that the overall level of preparedness was good but it did underline that significant work was still required to ensure that the operational documentation was available and had been assimilated by the operating and maintenance personnel. In 2023, ASN continued with its technical examination of certain topics, notably those linked to Operating Experience Feedback (OEF) from EPR reactors abroad, as well as the conformity assessments of the nuclear pressure equipment. THE EPR 2 PROGRAMME MUST TAKE ADVANTAGE OF LESSONS LEARNED FROM THE EPR In August 2023, EDF submitted the creation authorisation application for two EPR 2 reactors in Penly, for which the safety options had been the subject of an ASN opinion in 2019. The Penly reactors are the first ones in the EPR 2 programme, the aim of which is to incorporate the lessons learned from the design, construction and operation of the EPR reactors in France and abroad, along with feedback from operation of the existing reactors. The lessons learned by ASN and the French Institute for Radiation Protection and Nuclear Safety (IRSN) on the Flamanville EPR project led to reinforced oversight being adopted for the examination of the creation authorisation application. ASN and the IRSN defined their examination strategy, identifying the schedule, 4 ASN Report on the state of nuclear safety and radiation protection in France in 2023 Editorial by the Commission
the milestones and the deliverables required of EDF. ASN underlined the points requiring particular attention in the light of the operating lifetime envisaged for these new reactors, such as taking into account the effects of climate change between now and the end of the century. ASN STRESSES THE ISSUES RELATED TO THE SMR AND AMR PROJECTS AND TAKES INITIATIVES TO ANTICIPATE THE EXAMINATION PROCESS In the context of decarbonised industrial production targets, there is considerable enthusiasm for SMRs and AMRs and many start-ups are developing such projects. This will lead to the arrival of new players, new reactor technologies and new uses for nuclear power (production of steam, heat, or hydrogen) which will entail siting of reactors near the user industrial installations, potentially close to densely populated areas. For ASN, this means that the safety objectives associated with these reactors will have to be adapted in order to guarantee negligible releases, even in the event of a major accident. In 2023, ASN expanded its discussions with several French companies developing these projects. Faced with these innovations, ASN modified its organisation and its working methods, notably with new types of technical dialogue, which are more interactive than at present and better-suited to the needs of start-ups while their projects are maturing and the envisaged technological options are being validated. ASN thus defined project maturity criteria to be met before entering the pre-authorisation process, in order to optimise its resources. ASN recalls how important it is for project sponsors to develop a systemic approach including the industrial chain, the supply of nuclear fuel, spent fuel management, management of the risks of malicious acts and the proliferation of nuclear materials. Mitigating the consequences of accidents within the perimeter around these reactors and the management of waste will be essential pre-conditions for the deployment of these new reactors and for their acceptability. In 2023, the French, Finnish and Czech nuclear regulators concluded the preliminary examination of the main safety options of the Nuward project sponsored by EDF. This examination enabled the regulators to identify the safety advantages of SMRs, as well as some issues they raise, while helping the project sponsor identify ways of developing a more standardised design. It also enabled the various requirements, practices and experiences of the regulators to be compared. In 2024, the joint review of the Nuward reactor project will continue and cover new topics, expanding it to include three other European safety regulators (Netherlands, Poland, Sweden). This initiative confirms ASN’s position regarding the benefits to be gained from multilateral cooperation when reviewing sufficiently mature reactor projects, in an international context of standardisation. INDUSTRIAL RIGOUR IS STILL A CHALLENGE FOR THE NUCLEAR INDUSTRY’S SUPPLY CHAIN France’s nuclear ambitions, both for reactors and for the “cycle” industry and waste management, will require an exceptional effort in terms of skills, industrial rigour and project management. ASN considers that it will take at least a generation to address the sector’s attractiveness challenge, notably given the dwindling interest in France for technological and scientific training and for the industrial professions. This challenge also concerns the nuclear safety and radiation protection inspection professions. The difficulties and the occurrences of non-quality observed in the projects over the past twenty years are mainly the result of a lack of experience and professional rigour. The steps taken by the French Nuclear Energy Industry Players Group (GIFEN) and the deployment of EDF’s nuclear sector Excellence plan (EXCELL) reflect active collective mobilisation around these challenges, with the aim of “getting it right first time”. ASN considers that these are steps in the right direction and are to be encouraged. From the safety viewpoint, and as of the moment of project launch, the ordering customers must ensure that the chain of contractors is competent to manage the technical, regulatory, standards-based and contractual requirements resulting from the detailed design studies. In this context, ASN has in recent years strengthened its oversight of the procurement chain for equipment intended for nuclear facilities, through inspections of suppliers and of their subcontractors. The lessons learned from these inspections were sent out to the licensees in mid-2023. On the whole, the inspections demonstrated technical competence in the activities carried out by the suppliers, but revealed recurring shortfalls in industrial rigour across the nuclear sector, which must be corrected. These shortfalls primarily result from supplier unfamiliarity with requirements specified as being important for safety, competence in certain special processes, and monitoring rigour and performance. Over and above these shortfalls, it also appears that the lessons learned from irregularities detected in the nuclear sector and in its supply chain in France and ASN Report on the state of nuclear safety and radiation protection in France in 2023 5 Editorial by the Commission
abroad, need to be better taken into account. ASN considers this situation to be unacceptable. At a time of an unprecedented increase in workload, the sector must meet a major challenge in the fight against falsification and counterfeiting, at all levels along the subcontracting chain, involving prevention, detection and dealing with the cases identified. RADIATION PROTECTION CULTURE MUST BE MAINTAINED IN THE MEDICAL SECTOR In 2023, the level of radiation protection in this sector is satisfactory, but prior weaknesses still persist with no notable improvement. For a number of years now, ASN has observed that the radiation protection culture for fluoroscopy-guided interventional practices in the operating theatre has been improving too slowly. In 2023, this led ASN to enforce measures to ensure the compliance of premises and the radiation protection training of personnel. ASN notes the efforts made by the professionals to provide training appropriate to the specific issues of each discipline, which must continue to guarantee that skills further improve and that these issues are correctly understood. In addition, and even if the radiation protection culture appears to be mature, implementation of the quality assurance approach needs to be re-examined and fully taken on board. This is the case in radiotherapy, where an unprecedented number of undesirable target error events occurred in 2023 (wrong-side or positioning errors). ASN recalls the importance of an advance risk assessment, evaluation of the effectiveness of the barriers put in place and consideration of both local and national OEF. In this respect, the principles of a risk assessment methodology were presented in the “Patient safety” bulletin in October 2023. ASN also observes weak signals which, although not directly linked to significant or serious undesirable events, indicate conditions that are prejudicial to radiation protection. By means of inspections and the whistle-blower system, ASN thus notes an increase in reports of internal conflict situations. The “radiation safety culture trait talk” in medicine proposed by the International Atomic Energy Agency (IAEA) include a respectful work environment, that is necessary for effective communication and guaranteeing that all personnel are able to report their concerns, question a decision or organisation and thus exercise their individual responsibility. Furthermore, the lack of resources, shortness of staff and resorting to temporary workers or outside contractors, the rising use of teleradiology, or the sharing of resources, against a backdrop of healthcare authorisation reforms, are leading to new and often complex organisations, which can result in a certain dilution of responsibilities. In the face of these organisational changes, ASN is remaining attentive – whether during oversight activity, inspections or the issue of licenses and authorisations – to compliance with the regulatory obligations. It draws the attention of the decision-makers to the need to evaluate the impact of these changes on the organisation and on the work of individuals and the need for a precise definition of the roles and responsibilities of all players in order to guarantee that the radiation protection culture is maintained and indeed developed. THE PROTECTION OF RADIOACTIVE SOURCES AGAINST MALICIOUS ACTS NEEDS TO BE IMPROVED The protection of radioactive sources against malicious acts was an unregulated subject in France just a few years ago. Increased awareness of this aspect is required on the part of all those concerned. It also requires the adoption of technical, organisational and human measures designed to protect sources of ionising radiation, but also the “sensitive information” concerning them. In addition to these specific means, this above all implies that their potentially malicious use must be considered, which is sometimes hard to reconcile with the culture of establishments that are public access and/or devoted to health care. ASN has been monitoring source security since 2019, and in 2023 it reviewed the results achieved. These results show that the level of competence of the players and implementation of the measures have progressed but remain insufficient. Many challenges are still to be met in order to guarantee the security of sources, in particular when they are being moved, which can then create points of vulnerability at the interfaces. ASN recalls the importance of progress in the security culture, which implies better information, especially in distributing OEF to the users (increased threat awareness, dissemination of event reports, participation in anti-malicious acts networks, etc.). 6 ASN Report on the state of nuclear safety and radiation protection in France in 2023 Editorial by the Commission
THE QUESTION OF WASTE, WHICH LIES AT THE HEART OF PUBLIC CONCERNS, IS THE SUBJECT OF SPECIFIC DISCUSSIONS Radioactive waste management remains the most controversial subject with regard to risk management, as shown by the latest survey conducted in 2023 by the Kantar company, at ASN’s request. At present, there is a management solution for 90% of the volume of the waste, although this represents only 10% of the radioactivity contained. Pending the arrival of dedicated management routes, this means that there must be safe storage solutions for significant periods of time. Radioactive waste management in France does however benefit from internationally recognised advantages such as the National Radioactive Materials and Waste Management Plan (PNGMDR), an agency dedicated to waste management (Andra), well-operated disposal facilities and the Cigéo geological disposal project, now recognised as being in the public interest. For the purposes of examining this project, ASN launched a specific and voluntary consultation process in 2023, designed to ensure participation by the stakeholders. Two workshops were thus held in preparation for referral to the IRSN and then to the advisory committee, in order to enrich the content of these referrals and structure the public information process. ASN RAMPS UP ITS INTERNATIONAL ACTIVITIES At a time of renewed enthusiasm for nuclear energy, international relations are continuing at a steady pace, leading to the signing of a large number of cooperation agreements between ASN and its counterparts, leading to the development of exchange programmes on high-stakes issues. This intense international activity was also an opportunity to go into greater depth on subjects of common interest for the safety regulators, such as the continued operation of reactors beyond their envisaged design lifetimes, or the management of radioactive waste. This intensification also allowed the definition of common international positions. For example, various initiatives were launched internationally to promote the standardisation and harmonisation of regulatory approaches for the SMRs. ASN participates actively in this, notably by promoting cooperation between regulators. ASN considers that international harmonisation of the authorisation processes, often underlined by the developers of these projects as a pre-requisite for the deployment of SMRs, is in fact an illusion, given the specific nature of each country. On the other hand, ASN does consider that the joint review by several regulators of the design options for a given project, upstream of the authorisation process, would be such as to facilitate the development of a standardised design. The conflict in Ukraine, which is one of the topics dealt with by WENRA and by the Heads of the European Radiological Protection Competent Authorities (HERCA), remains a subject of concern and of particular vigilance for the regulators. In this respect, WENRA issued a position statement in June 2023 indicating that the destruction of the Khakovka dam did not represent a threat to the safety of the reactors of the Zaporizhzhia Nuclear Power Plant (NPP). HERCA continued its work to harmonise the population protection measures for Ukraine’s European neighbours in the event of an accident in the Zaporizhzhia NPP. ASN is also continuing its involvement in the international bodies. It is acting as HERCA Chair for three years, with the aim of helping to achieve a high level of radiation protection in Europe. n ASN Report on the state of nuclear safety and radiation protection in France in 2023 7 Editorial by the Commission
Montrouge, 1 March 2024 Maintaining a high level of regulation and oversight in an unprecedented context EDITORIAL BY THE DIRECTOR GENERAL 8 ASN Report on the state of nuclear safety and radiation protection in France in 2023 he context in which ASN performs its regulation and oversight is unprecedented in more than one respect. The combination of continued operation of older installations and the construction of new installations at a pace not seen for several decades is creating pressure on the resources available in the nuclear industry. The medical nuclear sector is also experiencing pressure on its workforce. Finally, innovations are emerging, both in the industrial field, with Advanced Modular Reactors (AMRs) and in the medical use of ionising radiation with new treatment techniques. ASN is preparing to deal with this new context: it is maintaining a high level of oversight, adapting it to the priority issues; it is preparing to support a significant workload on a long-term basis; it is relying on its in-house culture to ensure the robustness of its examination work and the pertinence of its oversight and decisions. At the same time, further to the Government’s submission of a bill reforming the organisation of regulation and oversight, ASN – together with the French Institute for Radiation Protection and Nuclear Safety (IRSN) – has initiated preparatory work to ensure the implementation of this bill if enacted. T
MAINTAINING A HIGH LEVEL OF OVERSIGHT Throughout the year 2023, the ASN teams remained fully mobilised in the performance of their duties to protect people and the environment. They maintained both the level of rigour and the level of oversight, while adapting priorities. ASN identifies and reassesses its regulation and oversight priorities on the basis of the challenges defined on the one hand by the risks for people and the environment inherent in nuclear activities and, on the other, by the behaviour of those in charge of the activities, in particular through the means they deploy to manage these risks. The following example illustrates this point. The present context of the nuclear industry is characterised by pressure on the energy markets, by the need for investment in infrastructure and thus large-scale financing, and by the fact that the nuclear sector needs to further consolidate its ability to support the needed revival process. This context is a challenge for the licensees and industrial firms, with the resulting increased risk regarding the quality of project performance. • 03 • Editorial by the Director General The lessons learned from the building of the Flamanville EPR also highlighted these construction quality issues. To address this situation, ASN has in recent years reinforced its oversight of the procurement chain for equipment intended for nuclear facilities: 53 inspections were thus performed on this topic in 2023. These inspections will be increased in the coming years, to keep pace with the development of new nuclear projects. HANDLING A GROWING WORKLOAD The nuclear sector revival is resulting in an increasing number of new projects on which ASN must adopt a stance, with the support of the IRSN, as well as in the appearance of new players. Examination of the creation authorisation applications for the three pairs of EPR 2 planned for Penly, Gravelines and Bugey, monitoring of the manufacture of their large components (reactor vessel, steam generators, piping, etc.) and then oversight of the corresponding worksites will thus gradually increase ASN’s workload in the coming years. To this can be added the projects to replace or expand the fuel fabrication and reprocessing plants, as well as the technical questions raised by the continued operation of the existing installations and the corresponding periodic safety reviews. Finally, technical dialogue with the sponsors of AMR projects, some of which include projects for specific fuel plants, is intensifying and will continue to do so in the coming years. This will demand far more resources than are currently available. ASN Report on the state of nuclear safety and radiation protection in France in 2023 9 Olivier GUPTA
To be able to handle this workload, ASN has received authorisation to increase its workforce by 12 staff for 2024, and is also relying on internal redeployments that will be made possible by the end of construction of the Flamanville EPR. Further increases in staffing and budget will nonetheless still be needed in the coming years. In the medical nuclear sector, the persistence of events – with seven events rated level 2 on the ASN-SFRO scale in 2023 – underlines the fact that the challenges remain high and justifies maintaining ASN’s level of oversight. The development of innovative high-stakes medical techniques, for nuclear medicine, or flash radiotherapy, is extensively mobilising the ASN teams in contact with the departments sponsoring the projects. PROMOTING AND DEVELOPING ASN’S SAFETY CULTURE The competence of the ASN personnel, as well as the rigour and collective nature of its decision-making process, are key factors in enabling ASN to correctly carry out its duties and are the focus of permanent attention. However, the pertinence of oversight is also heavily dependent on the “safety culture”. In 2023, ASN started work to identify which practices, which working and organisational methods and which attitudes enable ASN to effectively monitor nuclear safety and radiation protection, and then subsequently enhance and develop them. This work, entrusted to a researcher, consists in identifying the formal frameworks governing oversight actions and the managerial communications guiding these actions and then in observing the practices actually implemented, in order to determine the fundamental principles which encourage or impede the correct exercise of oversight aimed at protecting people and the environment. The interim results highlight a number of key aspects of ASN’s internal culture, which promote correct prioritisation and appropriate handling of high-stakes nuclear safety and radiation protection subjects: the importance of the collective, the benefits of comparing well-argumented opinions, respect for the responsibilities and scope of the duties of each party, intellectual curiosity, listening to different points of view, the sense of public service and rigour. The robustness of the examination process and the pertinence of oversight and decisions owe more to these practices and attitudes than to organisational methods. This culture thus constitutes a solid foundation for meeting the current challenges and it must be promoted and developed. PREPARING FOR A POSSIBLE GRAND AUTHORITY The Government has decided to change how the governance of nuclear safety and radiation protection is organised, by merging ASN and most of the IRSN in a new authority, which would then have its own expert assessment capability, as well as the research roles that underpin it. The two organisational options, with or without integrated technical support, are possible and have proven themselves. It is now up to Parliament to make a decision regarding the corresponding Bill. The responsibility of the teams at ASN and IRSN is to perform their duties within the specified framework, both before and after the date on which the new group is created, if such is the decision. They have therefore started working together to define the possible functioning and organisation of the future authority, in which the personnel will become involved as and when the general frameworks are defined. This work is being carried out with the common goal of ensuring that the new group works, that the personnel find their place in it and that the future authority makes the most of the potential created by the merger, with a more efficient and more attractive organisation preserving the values of excellence and transparency of the two existing entities. In addition, a specific social dialogue body bringing together the management and trades union organisations of ASN and IRSN is holding monthly meetings. To make time for the preparation and then implementation of the oversight organisation reforms, if passed, while preserving the resources assigned to operational duties, ASN has postponed those actions which can be put off and which do not affect its core duties. Whatever the regulatory organisation finally chosen, the personnel at ASN at IRSN will continue to work together, in pursuit of the same goal of protecting people and the environment. I know that I will be able to count on their commitment to continuing the mission our fellow citizens expect of them. n * 10 ASN Report on the state of nuclear safety and radiation protection in France in 2023 Editorial by the Director General
NOTABLE EVENTS 2023 PAGE 12 The safety challenges for the new nuclear programme PAGE 14 Flamanville EPR reactor Conclusion of examination of the commissioning authorisation application PAGE 16 Prospects for continued operation of EDF’s nuclear reactors PAGE 18 Cigéo A review involving all the stakeholders ASN Report on the state of nuclear safety and radiation protection in France in 2023 11 NOTABLE EVENTS 2023
NOTABLE EVENTS 2023 THE EPR 2 PROGRAMME he design of the EPR 2 reactor differs from that of the EPR, with a number of simplifications to facilitate construction and operation. With regard to safety, it is a thirdgeneration pressurised water reactor, which takes account of Operating Experience Feedback (OEF) from the EPR. The plan is for these reactors still to be in service at the end of the 21st century, a time-frame by when the effects of climate change should be far more significant than today. Major uncertainties persist, notably regarding the temperatures to be considered when designing the equipment. Given this situation, ASN considers that quite apart from ambitious climatic resilience objectives, a certain level of adaptability should be designed into the facilities, so that certain critical equipment can be resized if necessary. Controlling the quality of construction and manufacturing remains the main challenge EDF has to face. The EPR 2 programme is starting at the rate of one pair of reactors every three years. This situation is creating considerable pressure on the industrial stakeholders, with the risk being that faced with unrealistic objectives, deadlines compliance takes precedence over quality. ASN observes that for several years now, the sector has been preparing for the arrival of this new nuclear power programme. The question of skills, considered by ASN to be primordial, is the subject of multiple actions together with the State and the regional authorities. In this context, ASN adapts its oversight to these new challenges. Since 2016, legislation has expanded its competence to activities performed outside nuclear installations, in particular in the plants of the suppliers and subcontractors. ASN is gradually expanding its checks beyond the manufacture of Nuclear Steam Supply System (NSSS) equipment alone, with 53 supplier inspections performed in 2023. ASN observes that although the tier 1 suppliers are closely involved, considerable work remains to be done with regard to The safety challenges for the new nuclear programme T Penly (Seine-Maritime département(1)) site on which EDF intends to build two EPR 2 type reactors. 12 ASN Report on the state of nuclear safety and radiation protection in France in 2023 Launching a new large-scale nuclear programme is a challenge for the French nuclear industry, which needs to rebuild its capacity, notably in terms of skills and expertise. ASN draws attention to the need to control the quality of construction and manufacturing given the rapid start-up of the EPR 2 nuclear power programme and takes account of this in its regulation and oversight. At the same time, Small Modular Reactor (SMR) projects are multiplying, with ambitious objectives, including with regard to nuclear safety. Most of these innovative reactor projects, sponsored by new players, require the construction of experimental mock-ups before an industrial product can be envisaged. It will also be necessary to design new “fuel cycle” facilities, suited to the needs of these new technologies. Given the number and diversity of these projects, which raise new questions or require a fresh look at the safety doctrines currently in force, ASN is adapting, without in any way reducing its demands in terms of safety, and has set up procedures for exchanges and for work appropriate to these new players.
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