- 10 - These facilities have been divided into three categories, depending on their vulnerability to the phenomena which caused the Fukushima accident and on the importance and scale of the consequences of any accident affecting them. For the 79 facilities felt to be a priority, including the 59 power reactors in operation or under construction, the licensees (AREVA, CEA, EDF, Laue-Langevin Institute) submitted their reports to ASN on 15th September 2011. Given the time available, ASN asked the licensees of the priority nuclear facilities to present their conclusions according to the data at their disposal and based on existing safety studies and the expert opinions of the engineers. The licensees were also to propose complementary studies, to be carried out in particular on the weak points and the "cliff-edge" effects identified, as well as an appropriate calendar for these studies. For the facilities of lower priority, the licensees are required to submit their reports before 15th September 2012. Finally, the other facilities will be dealt with through appropriate ASN requests, in particular on the occasion of their next ten-yearly periodic safety review, except for about ten facilities for which decommissioning is nearing completion. 6.5 Assistance of a diversified technical expertise In accordance with the principle of the licensee's prime responsibility, which is the keystone of nuclear safety and a principle that is recognised in international legal texts, the complementary safety assessments led first of all, and for each facility concerned, to the production by the licensee of a report in response to the specifications defined by ASN. In order to analyse the reports submitted by the licensees on 15th September 2011, ASN called on the expertise of its technical support organisation, IRSN, which forwarded its report in early November. On 8th, 9th and 10th November 2011, ASN also convened two of the seven advisory committees it consults on the most important subjects: the advisory committee for reactors and the advisory committee for laboratories and plants. These advisory committees, consisting of French and foreign experts, submitted their opinion to ASN on 10th November 2011. At the same time the ANCCLI, the national association of CLIs (local information committees) mandated a number of experts to examine the reports submitted to ASN by the licensees. Several CLIs also initiated analyses: the Fessenheim CLIS sent ASN a study on the risk of flooding for the Fessenheim NPP; the CLIs at Civaux, Dampierre, Golfech, Gravelines, Saint-Laurent and the three CLIs of the Cotentin peninsula forwarded their opinions on the reports from the licensees. Finally, the experts mandated by the Grand Duchy of Luxembourg and the German States of Saarland and Rhineland-Palatinate, as well as the CGT trade union national mines-energy federation, sent ASN analyses of these reports. The complementary safety assessments thus led to considerable mobilisation on the part of the licensees, experts, stakeholders and ASN. ASN's initial conclusions on the complementary safety assessments of the priority nuclear facilities are based on a review of all this work and the results of its regulation and monitoring actions. They are the subject of this report. 6.6 An open and transparent approach ASN attached the greatest importance to this approach being both open and transparent: the French High Committee for Transparency and Information on Nuclear Security (HCTISN), the local information committees (CLI) and several foreign Regulatory Bodies were invited to take part as observers in the targeted inspections carried out by ASN and to attend meetings of the advisory committees. These various stakeholders also received copies of the reports sent in by the licensees. On its website (www.asn.fr) ASN also made available on-line the reports from the licensees, the IRSN report, the opinions of the advisory committees and the follow-up letters to its inspections.
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