ASN has issued its opinion on the management of radioactive materials and waste

Pursuant to the 2016-2018 edition of the National Radioactive Materials and Waste Management Plan (PNGMDR) and in response to a request from the Ministry in charge of Energy, ASN issued seven opinions over the period 2020 to 2021 on the management of radioactive materials and waste produced in France. In these opinions, ASN notably underlines the fact that decisions will be needed in the very near future, so that safe management routes are available for all types of radioactive waste in the coming 15 to 20 years.

These opinions are based on an in-depth analysis of the studies submitted by the producers and managers of radioactive waste, pursuant to the order of 3 February 2017 ^[1], carried out on the conclusions of the public debate held for the first time in 2019, in preparation for the 5^th PNGMDR, and on the broad outlines decided on by the Minister for Ecological Transition and the ASN Chairman on 21 February 2020 following the public debate. Their purpose is to provide recommendations for concrete action on subjects for which decisions can be taken immediately or, failing which, during the course of the Plan.

ASN stresses the importance of planning ahead in making radioactive materials and waste management choices. More particularly, ASN considers that:

• the valorisable nature of the radioactive materials must be assessed, taking account of the time-frames within which industrial routes for using these materials will be available, and the volume of material concerned. The valorisation of a radioactive material could be considered to be plausible if the existence of an industrial route is realistic within a time-frame of about thirty years. For the more distant future, advance preparation must be made for storage over the corresponding time-frames, longer than about thirty years, in safe conditions, along with the possible management of the radioactive substance as waste. In any case, if there are no prospects for use within a time-frame of about a century, the substance shall be reclassified as waste. These principles shall notably be applied for a substantial quantity of depleted uranium currently being stored as a material;
• the next multi-year energy programme shall define the prospects beyond 2040 for reprocessing of spent fuels so that the necessary action for cessation or continuation of this policy can be planned for in advance;
• pending the creating of a disposal solution, storage needs must be anticipated. More specifically, the construction of additional spent fuel storage capacity is a strategic issue for the overall safety of the nuclear installations. EDF must submit a creation authorisation application for its chosen option of a centralised fuel storage pool, as soon as possible;
• long-term storage cannot be considered a final solution for the management of high level, long-lived waste. This implies maintaining oversight on the part of society and the retrieval of waste by future generations, which it would appear to be hard to guarantee over a time-frame of several centuries;
• the industrial scale transmutation of waste already conditioned in the Cigéo reference inventory is not a credible prospect. If studies were to continue on the subject, they would have to cover the transmutation of radioactive substances currently categorised as materials, or the transmutation of waste produced by a future fleet of reactors;
• the producers must implement an ambitious programme to characterise bituminous waste packages, which is essential to demonstrating that some or all of these packages could be disposed of with a high level of safety in the Cigéo repository, with no prior treatment;
• the licensees must implement all necessary resources to retrieve and condition legacy waste (RCD), both high level waste and intermediate level, long-lived waste (HLW-ILW/LL) produced before 2015 and, for which they are responsible in compliance with the 2030 deadline set by law,giving priority to those actions for which the safety implications are greatest;
• in order to plan ahead for the creation of repositories for very low level (VLL) waste to meet the identified needs, ANDRA must submit an application for an increase in the authorised capacity of CIRES at least six years before the foreseeable saturation and study the creation of additional disposal facilities for VLL waste, whether centralised or decentralised;
• the valorisation of certain types of VLL waste, large volumes of which will be produced, must be encouraged, notably through the creation of a specific framework of exemptions and oversight for the valorisation of low-level metal materials;
• efforts must be ramped up to allow the creation of disposal capacity for low level, long-lived waste (LLW-LL). On this point, ANDRA must submit a dossier by mid-2023 presenting the technical safety options for the sub-surface disposal of LLW-LL waste on the site of the Vendeuvre‑Soulaines association of municipalities (Aube).

In these opinions, ASN underlines the need to involve all the stakeholders, notably the representatives of the regions involved or liable to become involved, in the management choices for very low level (VLL) waste, low level, long-lived (LLW-LL) waste, legacy radioactive waste locations and the management of water from former uranium mining sites, in particular on the basis of pluralistic multi-criteria analyses ^[2].

The 5^th PNGMDR project, henceforth produced under the sole responsibility of the Ministry for Ecological Transition, will be submitted for consultation to the Environmental Authority and the public before the end of 2021. At the same time, ASN will issue a final opinion on the draft regulatory texts for the 5^th PNGMDR. The Plan, as finalised by the Government, will then be evaluated by Parliament.