ASN resolution 2008-DC-0095 of 29 January 2008 lays out the technical rules applicable for the disposal of effluents and waste contaminated or potentially contaminated by radionuclides owing to a nuclear activity. ASN published a guide (Guide No. 18) for the application of this resolution in January 2012. Management of disused sealed sources Under the PNGMDR 2016-2018, Andra submitted a report in mid2018 presenting a review of the situation regarding the acceptance of disused sealed sources considered as waste in the existing and planned disposal facilities. Furthermore, Decree 2015-231 of 27 February 2015 enables holders of disused sealed sources to call upon not only the initial source supplier but also any licensed supplier or – as a last resort – Andra, to manage these sources. The holders are moreover no longer obliged to provide proof that they have contacted all the suppliers before turning to Andra. These provisions aimed to bring a reduction in the costs of collecting disused sources and provide a recovery route in all situations. ASN issued a position statement on 11 May 2021 on the management of disused sealed sources that could not be recycled. It considers that disused sealed sources which cannot be accepted in aboveground disposal facilities must be included in the inventories of projected disposal facilities, and that a complete inventory of the existing management routes must be established, indicating the responsibilities of the various actors. Moreover, ASN recommends that the notion of “last resort” mentioned in Decree 2015-231 be clarified. The “DECPAR.4” action of the PNGMDR 2022-2026 states that producers should conduct an inventory of sealed sources with ownership issues and that a work programme should be drawn up with Andra to develop management solutions. The volume of sealed sources awaiting management in a definitive disposal facility has been introduced as a new monitoring indicator in the PNGMDR 2022-2026. Management by Andra of waste from small-scale nuclear activities Article L. 542-12 of the Environment Code entrusts Andra with a public service mission for the management of waste produced by small-scale nuclear activities. Since 2012, Andra operates Cires, a facility situated in the municipalities of Morvilliers and La Chaise in the Aube département, designed for the collection and storage of waste from small producers that are not in the nuclear power sector. ASN considers that Andra’s actions in this area are appropriate to fulfil its mission assigned under the abovementioned Article L. 542-12 and that they must be continued. Nevertheless, the tritiated solid waste must be managed with the waste from International Thermonuclear Experimental Reactor (ITER) – in a storage facility operated by the CEA (called the “Intermed project” at present). The delays in the ITER project schedule are impacting the Intermed project schedule and the management strategy for tritiated waste from small producers. In its report provided in response to Article 61 of the Order of 23 February 2017, Andra proposes storing this waste on the CEA Valduc site pending commissioning of the abovementioned storage facilities. In its opinion 2021-AV-0379 of 11 May 2021, ASN reiterated that the storage of tritiated waste from small producers in a Defence Basic Nuclear Installation (DNBI) was not justified by a potential need to protect information in the interests of national defence. As the commissioning of Intermed in about ten years’ time has become improbable due to the delays in its dimensioning and detailed design, ASN recommends that Andra puts in place, as soon as possible, the necessary storage capacities for the acceptance of highly tritiated waste and sources containing tritium from small producers, prior to their definitive management in a disposal facility or their possible subsequent storage in Intermed. 1.2.3 The National Inventory of radioactive materials and waste Article L. 542-12 of the Environment Code assigns Andra the task of establishing, updating every five years and publishing the National Inventory of radioactive materials and waste. This Inventory constitutes an input database for preparing the PNGMDR. The last update was published in December 2023. The inventory provides information concerning the quantities, nature, and location of radioactive materials and waste at the end of 2021, categorised by type and economic sector. A prospective exercise was also conducted, based on four contrasting scenarios for France’s energy policy, as envisioned in the 2019-2028 Multiyear Energy Plan (PPE). 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 (MTE). 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. On its website, ASN also publishes the PNGMDR, its summary, the minutes of the abovementioned working group’s meetings, the studies required by the plan and the opinions it has issued on these studies. THE ROLE OF ASN IN WASTE MANAGEMENT ASN Report on the state of nuclear safety and radiation protection in France in 2023 371 • 15 • Radioactive waste and contaminated sites and soils 15 05 08 11 04 14 06 07 13 AP 03 10 02 09 12 01
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