Before this principle became a statutory requirement in France, several facilities had been shut down for an extended period of time. Knowledge of their operating histories has been partially lost and, in some cases, large quantities of radioactive waste are still present in ageing structures and buildings. As more nuclear fuel cycle facilities and nuclear power plants are being shut down, the decommissioning projects are becoming more complex and more numerous. The correct progress of decommissioning projects and legacy waste retrieval and conditioning projects is thus a major safety issue.
Over the last few years, ASN has set a number of project milestones, as a way of enforcing this principle of “immediate dismantling”. It should nevertheless be noted that the majority of the decommissioning projects are experiencing significant technical difficulties, and thus falling behind schedule.
To address this situation, ASN has been developing a new regulatory approach to complex decommissioning projects for a few years now. Its objective is to hold the licensees to account for the delivery of these safety outcomes. This regulatory approach consists mainly in:
- delivering inspections of complex decommissioning projects in order to assess the maturity of the project and the licensee’s ability to deliver their project in the shortest time-frame,
- engaging with the licensees in a more transparent and flexible manner, to monitor their progress, support solutions compatible with the most important priorities and build trust between stakeholders.
As for the inspections of complex decommissioning projects, ASN delivered an in-depth inspection at EDF in November 2020  regarding the management of two key projects for the gas-cooled reactor (GCR) decommissioning programme: the decommissioning of the Chinon A2 reactor, which will be the first to be decommissioned and is therefore a key driver in programme performance, and the graphite industrial demonstrator project, which will host key mock-up tests to reduce the technical risks of this decommissioning programme. Previously, in 2019, ASN delivered another in-depth inspection of a complex project at Orano La Hague concerning legacy waste retrieval and conditioning . These two inspections were a good opportunity to more precisely understand the organization of these licensees with regard to large project management. They revealed good practices and areas for improvement.
Regarding EDF inspection, ASN underlined the expertise and commitment of the project teams, the soundness of its industrial strategy and technical choices regarding GCR decommissioning, and found that project management processes were on the whole well implemented. ASN asked EDF to improve their schedule management arrangements. The improvements required by ASN are being progressively implemented by EDF.
ASN intends to deliver new in-depth inspections on project management in 2022 at CEA (concerning the decommissioning project of the former effluent treatment facility in Cadarache) and Andra (the Cigéo programme for final disposal of high level waste).
As for the new approach to technical dialog with licensees, ASN has been engaging with Orano La Hague in order to improve:
- safety case development and assessment,
- project progress reporting,
- issues escalation and resolution through key stakeholder meetings,
- consideration of strategic factors and a holistic ALARP argument to accelerate high hazard risk reduction.
These efforts are expected to facilitate the transition from a prescriptive regulatory approach to a more enabling one. EDF is also willing to support improvements and engage differently with ASN in order to secure its decommissioning strategy. For instance, an ASN/EDF task force is working to optimize the regulatory process leading to Dismantling Decrees for the GCR plants.
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Date of last update : 07/11/2022