4 Management of sites and soils contaminated by radioactive substances A site contaminated by radioactive substances is defined as a site which, due to the presence of old deposits of radioactive substances or waste, or to the utilisation or infiltration of radioactive substances or radiological activation of materials, presents radioactive contamination that could cause adverse effects or a lasting risk for people or the environment. Contamination by radioactive substances can result from industrial, craft, medical or research activities involving radioactive substances. It can concern the places where these activities are carried out, but also their immediate or more remote vicinity. The activities concerned are generally either nuclear activities as defined by the Public Health Code, or activities concerned by natural radioactivity. However, most of the sites contaminated by radioactive substances and today requiring management have been the seat of past industrial activities, dating back to a time when knowledge of the radioactivity-related risks was not what it is today. The main industrial sectors that generated the radioactive contamination identified today were radium extraction for medical and para-pharmaceutical needs, from the early 1900s until the end of the 1930s, the manufacture and application of luminescent radioactive paint for night vision, and the industries working ores such as monazite or zircons. Sites contaminated by radioactive substances are managed on a case-by-case basis, which necessitates having a precise diagnosis of the site. Several inventories of contaminated sites are available to the public and are complementary: Andra’s national inventory, updated every five years, which comprises the sites identified as contaminated by radioactive substances (the 2023 edition is available on andra.fr as is the publication of the National Inventory Essentials 2023), as well as the databases devoted to contaminated sites and soils managed by the Ministry responsible for the environment. ASN considers moreover that the stakeholders and audiences concerned must be involved as early as possible in the process to rehabilitate a site contaminated by radioactive substances. In application of the “polluter-pays” principle written into the Environment Code, those responsible for the contamination finance the operations to rehabilitate the contaminated site and to remove the waste resulting from these operations. If the responsible entities default, Andra, on account of its public service remit and by public requisition, ensures the rehabilitation of radioactive contaminated sites. In cases where contaminated sites and soils have no known responsible entity, the State finances their clean-up through a public subsidy provided for in Article L. 542-12-1 of the Environment Code. The French National Funding Commission for Radioactive Matters (CNAR) issues opinions on the utilisation of this subsidy, as much with respect to fund allocation priorities as to polluted site treatment strategies and the principles of assisted collection of waste. Under Article D. 542‑15 of the Environment Code, the composition of the CNAR is as follows: ∙ “members by right”: representatives of the Ministries responsible for the environment and energy, of Andra, the French Environment and Energy Management Agency (Ademe), IRSN, CEA, ASN and the Association of Mayors of France; ∙ members mandated for four years by the Ministries responsible for energy, nuclear safety and radiation protection (the CNAR chair, two representatives of environmental associations and one representative of a public land management corporation). The Commission met twice in 2023, in particular to address the files concerning the retrieval of radioactive objects in the possession of private individuals, the management of polluted sites and the management of soils from the clean-out of legacy sites. When contamination is caused by an installation that is subject to special policing (BNI, ICPE or nuclear activity governed by the Public Health Code), the sites are managed under the same oversight system. Otherwise, the Prefect oversees the measures taken regarding management of the contaminated site. Regarding the management of sites contaminated by radioactivity subject to the ICPE System and the Public Health Code, whether the responsible party is solvent or insolvent, in accordance with its validated doctrine regarding sites contaminated by radioactive substances (see chapter 14, point 1.2.2), ASN recalls that the clean-out practices must be implemented taking account of the best available methods and techniques, in economically acceptable conditions. The complete POCO scenario must always be envisaged as the reference scenario. This scenario, which leads to unconditional release of the buildings and sites, effectively enables the protection of people and the environment to be guaranteed over time by the removal of all contamination. In the event of identified technical, economic or financial difficulties, the party responsible for the contamination (if solvent) or the owner of the site may propose one or more appropriate POCO scenarios compatible with the site’s futures usages (confirmed, planned and possible) to the Prefect. In any case, elements proving that the reference scenario cannot be applied under acceptable technical and economic conditions and that the POCO operations envisaged constitute a technical and economic optimum shall be provided. In the event of incompatibility with the uses as a whole, usage restrictions or prohibitions and technical measures to limit exposure of the occupants, or prescribe surveillance measures may be adopted, through active institutional controls or a soil hazard information sector. In all cases, the Prefect may rely on the advice of the classified installations inspectorate, ASN and the Regional Health Agency (ARS) to validate the site rehabilitation project, and issues a prefectural order to govern implementation of the rehabilitation measures. ASN may thus be called upon by the services of the Prefect and the classified installation inspectors to give its opinion on the clean-out objectives of a site. 384 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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