These resolutions set the next steps required for the change of decommissioning strategy, notably the defining of a robust strategy for managing graphite waste that is independent of disposal outlet availability, the decommissioning operations to continue over the next few years and the information to be transmitted to ASN to check effective implementation of the strategy. ASN considers that it is appropriate for EDF to develop a graphite industrial demonstrator (commissioned in 2022 in Chinon) before decommissioning the reactor pressure vessels, but decommissioning of the various reactors must nevertheless begin within reasonable time frames in view of the obligation for dismantling to be carried out as rapidly as possible. Regarding the other shut down EDF facilities (notably Chooz A, AMI Chinon, EL4-D and Superphénix), their decommissioning is under way and on the whole is meeting the objective of achieving as short a time frame as possible. 4.2 Assessment of Orano’s decommissioning strategy The decommissioning of old installations is a major challenge for Orano, which has to conduct several large-scale decommissioning projects over variable time scales (UP2-400 facility at La Hague, Eurodif Production plant, Comurhex plant, individual facilities of the DBNI at Pierrelatte, etc.). Implementation of decommissioning is closely linked to the legacy radio- active waste management strategy, given the quantity and the non-standard and hard to characterise nature of the waste produced during the prior operations phase and during the ongoing decommissioning operations. Furthermore, Orano must carry out special WRP operations in old waste storage facilities. The deadlines for completion have been stipulated by ASN, particularly for the La Hague site. Completion of these WRP operations determines the progress of decommissioning on the UP2-400 plant, as WRP is one of the first steps of its decommissioning. The WRP work is of particular importance given the large inventory of radioactive substances present and the age of the facilities in which they are stored, which do not generally meet current safety standards. In addition, WRP projects are considerably complex owing to the interactions with the plants in operation on the site. Further to the difficulties observed in the examination of files relating to the WRP and decommissioning operations on the Orano La Hague site and failure to perform the operations within the prescribed deadlines, ASN and Orano agreed to set up regular monitoring in order to anticipate and address any blocking situations and determine practical measures to be put into place to accomplish the WRP and decommissioning operations in the shortest time frame possible. In June 2016, at the request of ASN and ASND – the Defence Nuclear Safety Authority – Orano submitted its decommissioning and waste management strategy. The file also includes the application of this strategy to the La Hague and Tricastin sites. In its position statement letter of 14 February 2022, ASN underlined the progress made by the licensee in taking on-board the decommissioning objectives prioritised according to the issues of the BNIs and the decommissioning phases and the Orano governance’s oversight of complex WRP and decommissioning projects. ASN conducted two inspections focusing on this strategy in 2024. However, ASN considers that Orano should continue to improve its knowledge of the current state of the facilities and notably the soils, with a view to future POCO, make progress in enhancing the industrial reliability of the waste retrieval processes. ASN considers that the methodology put in place by Orano for calculating schedule margins can guarantee better control of the time frames of the various WRP and decommissioning projects. Orano notably updated the forecast end-of-decommissioning dates for the UP2-400 plant BNIs in 2024. 4.3 Assessment of CEA’s decommissioning strategy Given the number and complexity of the operations to be carried out for all the nuclear facilities concerned, CEA is giving priority to reducing the “dispersible inventory” which is currently very high in certain facilities, particularly in some of the individual facilities of the Marcoule DBNI and in BNIs 56 and 72. In their Position Statement Letter of 27 May 2019, ASN and the ASND considered that, given the resources allocated by the State and the large number of facilities undergoing decommissioning for which legacy waste retrieval and storage capacity will need to be built, it was acceptable for CEA to envisage staggering the decommissioning operations and that priority be given to the facilities with the greatest safety risks. ASN however observes very significant drifts in the WRP schedules presented by CEA, particularly the pushing back of waste management deadlines, including for operations considered to be priorities. Some of these operations are effectively being reconsidered in depth after encountering deadlocks in the initially planned operations, or the late discovery of a facility state that is inconsistent with the expected state. ASN and CEA have set up regular monitoring of these operations, notably by means of progress indicators. ASN observes moreover that CEA’s decommissioning and materials and waste management strategies share certain vulnerabilities in particular relative to the availability of support facilities, which are often unique but are needed in order to run numerous projects. CEA’s strategies rely on sharing of the resources by its centres and are based on the use of facilities, some of which are simply planned, while others are undergoing commissioning, or being refurbished. Most of them are unique, with no obvious operational alternative in the event of failure. All of these aspects underline the vulnerability of CEA’s strategy. 368 ASN Report on the state of nuclear safety and radiation protection in France in 2024 Decommissioning of Basic Nuclear Installations
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