ASN has thus more specifically examined the reports submitted by Andra in 2005 and 2009. It issued opinions on these reports on 1 February 2006 and 26 July 2011. Andra subsequently submitted various files to ASN presenting the progress of the studies and work carried out. ASN thus issued a position statement: ∙ in 2013, on the documents produced between 2009 and 2013, the year of the public debate, and on the intermediate design milestone at the outline stage presented by Andra in 2012; ∙ in 2014, on the safety components of the closure structures and the expected content of the Safety Options Dossier (DOS) for the facility; ∙ in 2015, on the control of operating risks and the cost of the project; ∙ in 2016, on the components development plan; ∙ in 2018 on the Cigéo DOS; ∙ in 2022, on the seismic hazard to be considered in the design of the facility. The Cigéo Safety Options Dossier The filing of a DOS marks the start of a regulatory process(7). ASN received the Cigéo DOS in April 2016. At the end of the technical review phase, the ASN draft opinion underwent public consultation, and ASN issued its opinion on 11 January 2018. ASN also sent a follow-up letter giving recommendations on the safety options to prevent or limit the risks and asked Andra for additional studies and justifications (corrosion phenomena, low-pH concretes, representativeness of the hydrogeological model, surveillance strategy, etc.). The demands made in this letter took account of the suggestions and comments received through the public consultation. The examination of the Cigéo DOS highlighted several issues relating to specific aspects (architecture, definition of hazards, post-accident management, etc.). Among these issues, ASN pointed out that the management of bituminised waste required special attention. Particular case of bituminised waste The management of bituminised waste is moreover monitored under the PNGMDR, which demands several studies relative to the characterisation of these packages, their conditions of transport and the treatment possibilities (Articles 46, 47 and 48 of the Order of 23 February 2017). In 2019, ASN requested additional information(8) from the waste producers and Andra, following the review of the study submitted pursuant to Article 46. These requests notably concern the effect of self-irradiation on the thermal behaviour of the bituminised waste packages, on the thermal reactivity of the bituminised coatings, on the swelling in the context of long-term behaviour of the Cigéo repository, and on the design development aimed at ensuring control of risks associated with the disposal of packages of bituminised waste. The Minister responsible for energy and ASN moreover wanted an independent multidisciplinary assessment drawing on international practices to be conducted on this issue. 7. Article R. 593‑14 of the Environment Code stipulates that “any person who plans operating a BNI can, before initiating the creation authorisation procedure, ask ASN for an opinion on all or part of the options it has chosen to protect the interests mentioned in Article L. 593-1. In an opinion issued and published in the conditions and forms it so determines, clarifies to what extent the safety options presented by the applicant as such as to prevent or limit the risks to the interests mentioned in Article L. 593.1, taking account of the technical and economic conditions of the time. ASN may define the additional studies and justifications that will be required for a prospective creation authorisation application. It can set a validity period for its opinion. This opinion is communicated to the applicant and to the Minister responsible for nuclear safety”. 8. The follow-up letters are available on the ASN website under the heading “ASN informs”, “Educational files”, “Management of radioactive waste”, “French National Radioactive Material and Waste Management Plan”, “PNGMDR 2016-2018”. The conclusions of this assessment were presented to the working group tasked with monitoring the PNGMDR in September 2019. ASN issued opinion 2020-AV-0369 on 1 December 2020 regarding the conclusions of the third-party review on the management of bituminised waste and the studies on the design development of the Cigéo ILW-LL waste disposal cells, which highlight new technical factors since the publication of the opinion of 11 January 2018. ASN therefore considers it essential for the waste producers to implement an ambitious characterisation programme for bituminised waste packages. This programme is essential to demonstrate that all or part of these packages could be emplaced with a high level of safety in the projected Cigéo facility without prior treatment. ASN considers moreover that the bituminised waste packages whose safety once emplaced in the disposal facility could not be demonstrated must undergo further investigations. The CEA informed ASN of the launch in 2021 of a new “quadripartite” studies programme (grouping Andra and the three major licensees), aiming to enrich reflections on the methods of managing bituminised waste by contributing elements stemming from the research and development work. ASN welcomed this initiative, on which it made remarks in 2022, and will follow the progress of this programme which will span five years. From the Safety Options Dossier to the creation authorisation application The Cigéo project was declared of public utility by Decree 2022‑993 of 7 July 2022, published in the Official Journal of the French Republic on 8 July. During this process, ASN answered questions from the inquiry Commissioners concerning certain technical aspects of the Cigéo project. In accordance with the resolution by the Minister responsible for energy and the ASN Chairman of 21 February 2020, following the public debate on the 5th edition of the PNGMDR, and through its “HAMAVL.6” (HLW/ILW-LL 6 action), this specifies the conditions for implementing disposal reversibility, particularly regarding the retrievability of packages, the Cigéo project’s decision milestones, and the governance to be adopted, needed to periodically review the choices made. It is also planned to define the objectives and success criteria of the pilot industrial phase, the procedures for informing the public between two successive updates of the master operating plan as provided in Article L. 542‑10-1 of the Environmental Code, and the procedures for involving the public in the key stages of the Cigéo project development. The review process for the Creation Authorisation Application filed in early 2023 Further to the filing of the Cigéo creation authorisation application on 16 January 2023, ASN initiated the DAC review process for this deep geological disposal facility, which is regulated by Section 4 of Chapter III of Title IX of Book V of the Environment Code and by Article L. 542‑10‑1 of the Environment Code, specific to this type of facility. 376 ASN Report on the state of nuclear safety and radiation protection in France in 2023 • 15 • Radioactive waste and contaminated sites and soils
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