2.1.4 Developing the regulatory framework and issuing prescriptions to the licensees ASN can issue resolutions of a regulatory nature. 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 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). Finally, ASN is consulted for its opinion on draft regulatory texts concerning radioactive waste management. Regarding the subject of the disposal of radioactive waste, in 2023, ASN continued its work to draft a resolution regulating the disposal facilities, as well as a guide on near surface disposal. These texts aim to consolidate the requirements associated with the radioactive waste disposal facilities. From 20 October to 20 November 2023, ASN held a consultation on the Guidance and Supporting Document (DOJ) for this work, which will continue into 2024. 2.1.5 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 14 (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, notably taking account of 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 four periodic safety reviews of radioactive waste management facilities. They concern: ∙ two BNIs operated by CEA: the treatment and packaging facility (BNI 35) on the Saclay site and the Cedra facility on the Cadarache site; ∙ one BNI operated by EDF: BNI 74 comprising the Saint-Laurentdes‑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 for some BNIs) 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 released its conclusions on the periodic safety review of the 37-A conditioning facility on 4 January 2023, and those for the BNI 118 safety review on 8 December 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. The periodic safety review of the CSM is currently being examined, following the review of this file by the Advisory Committee of Experts for Radioactive Waste (GPD) 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. 2.3 CEA’S WASTE MANAGEMENT STRATEGY AND ITS ASSESSMENT BY ASN Types of waste produced by CEA CEA operates diverse types of facilities covering all the activities relating to the nuclear cycle: laboratories and plants associated with fuel cycle research, as well as experimental reactors. CEA also carries out numerous decommissioning operations. 380 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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