ASN REPORT on the state of nuclear safety and radiation protection in France in 2024 ABSTRACTS
The French Authority for Nuclear Safety and Radiation Protection presents the Report of the Nuclear Safety Authority on the state of nuclear safety and radiation protection in France in 2024. This Report is required by Article L. 592-31 of the Environment Code. It was submitted to the President of the Republic, the Prime Minister and the Presidents of the Senate and the National Assembly and transmitted to the Parliamentary Office for the Evaluation of Scientific and Technological Choices, pursuant to the above-mentioned Article.
p.2 Editorial by the Commission p.8 Editorial by the Director General p.12 Notable events 2024 p.22 ASN Assessments p.32 Regulatory News p.36 Regional overview of nuclear safety and radiation protection Find the full ASN Report on the state of nuclear safety and radiation protection in France in 2024 on asnr.fr Only regulatory news for the year 2024 is presented in this report. The regulations as a whole can be consulted on asnr.fr ADVICE TO THE READER Contents ASN Report on the state of nuclear safety and radiation protection in France in 2024 This report, which describes the state of nuclear safety and radiation protection in France in 2024, was drawn up by the French Authority for Nuclear Safety and Radiation Protection (ASNR). ASNR was itself created from the merging on 1 January 2025 of the Nuclear Safety Authority (ASN) and the Institute for Radiation Protection and Nuclear Safety (IRSN). The Commission and the departments speak on behalf of ASN concerning the year 2024, and on behalf of ASNR when it comes to more general considerations or projections. ABSTRACTS
Maintaining a high level of rigorous nuclear safety and radiation protection in an ambitious context From left to right Pierre‑Marie ABADIE, Chairman Stéphanie GUÉNOT BRESSON, Commissioner Olivier DUBOIS, Commissioner Géraldine PINA, Commissioner Jean‑Luc LACHAUME, Commissioner Montrouge, 1 March 2025 he safety level of the nuclear facilities was satisfactory in 2024, with considerable mobilisation around the performance of the fourth periodic safety reviews of the 900 Megawatts electric (MWe) reactors, stabilised production levels in the Melox plant and efforts by the industrial sector to improve manufacturing quality. In the medical field, the level of radiation protection is also considered to be satisfactory, despite some points warranting particular vigilance. At a time when nuclear energy is set to be a key component of the French energy system for the long-term, the French Authority for Nuclear Safety and Radiation Protection (ASNR) recalls that: • anticipation is required in order to take decisions informed by the best knowledge and underpinned by a questioning attitude that is attentive to weak signals; • the long-term future of the facilities must aim for the best safety standards, including by comparison with the projects for more modern facilities that will be replacing them; • physical and time margins must be maintained to be able to deal with contingencies without compromising safety. T 2 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024 EDITORIAL BY THE COMMISSION
The continued operation of the nuclear power plant fleet remains a major subject The provisions of Article L. 593-18 of the Environment Code stipulate that ASNR shall issue a position statement on the continued operation of the nuclear facilities every ten years, following their periodic safety review. The fourth periodic safety review of the 900 MWe reactors (RP4 900), is continuing reactor by reactor, in order to significantly improve the level of safety. In 2024, ASN issued a position statement on the guidelines to be followed for the fifth periodic safety review of these reactors, which will enable the conditions to be defined for their continued operation beyond 50 years, while maintaining the same safety objectives. EDF intends to focus the fifth periodic safety review on the one hand on verifying the conformity of the installations, maintaining equipment qualification and management of ageing. On the other hand, it will focus on reassessing the management of risks and detrimental effects, taking account of the effects of climate change. ASN considered that the general guidelines adopted by EDF are pertinent and consistent with the current level of knowledge. With regard to the fourth periodic safety review of the 1,300 MWe reactors (RP4 1,300), ASN’s examination of the main generic safety issues continued in 2024 with the support of IRSN. At the same time, in the opinion of the guarantors of the consultation appointed by the High Committee for Transparency and Information on Nuclear Safety (HCTISN), the public consultation on the conditions for improving the safety of the 1,300 MWe reactors as part of their fourth periodic safety review, conducted under the aegis of the HCTISN with the participation of EDF, IRSN, the National Association of Local Information Committees and Commissions (Anccli) and ASN, was able “to publicly and successfully tackle essential questions concerning society as a whole, over and above the ongoing regulatory authorisation procedure”. The examination was conducted efficiently thanks to the reutilisation of the governance processes put into place for examination of the fourth periodic safety review of the 900 MWe reactors with EDF and IRSN, while also making full use of Operating Experience Feedback (OEF). This result, along with the division of future modifications into batches, and the continuity of the objectives with the fourth periodic safety review of the 900 MWe reactors, aims to allow standardised deployment of the safety modifications on the 1,300 MWe reactors as of the first reactors concerned, while giving priority to the high-stakes modifications, starting in 2026. A strategy to examine the service life extension of the reactors is deployed on the occasion of the fourth and fifth periodic safety reviews and in anticipation of the possible continued operation beyond then. This strategy enabled these examinations to be industrialised. The launch of studies into the long-term future and upgrading of the fuel plants is a positive point with respect to the aim of balancing the “cycle”. With the up-turn in the construction of new reactors and new fuel plants, highly active innovation in the medical sector, or Small Modular Reactors (SMRs), as well as new prospects for service life duration, the nuclear safety and radiation protection stakeholders must meet new challenges: acquisition of new knowledge, dissemination of the safety and radiation protection culture to all the stakeholders, including in the subcontracting chain, mobilisation of resources and skills on behalf of nuclear safety and radiation protection, at a time of extreme competition for resources. ASN, and now ASNR, are adapting to this new context. After the passage of Act 2024-450 of 21 May 2024 ratifying the merger of the Nuclear Safety Authority (ASN) with the Institute for Radiation Protection and Nuclear Safety (IRSN), the collective preparation work enabled ASNR to be immediately operational on 1 January 2025, with respect to all of its missions. ASNR covers research, expert assessment, examination and oversight, and comprises a full range of disciplines and skills ranging from the acquisition of knowledge, to decision-making and regulation/oversight. It is more independent, more robust and more visible, in France and internationally. The coming months will enable its organisation to be consolidated, enable ASNR to establish itself within its ecosystem, and gradually build an integrated strategy for research, expert assessment, oversight and transparency, and dialogue with society. Editorial by the Commission ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024 3
With regard to the possible operation of the current fleet of reactors beyond 60 years and on the basis of the work done by EDF, the year 2023 saw identification of the main technical subjects requiring specific analysis, or even research and development, ahead of the periodic safety reviews. The conclusions of EDF’s early analyses will be reviewed so that ASNR can issue a position statement in 2026. Finally, since they began operating, the operational baseline requirements of the reactors, in particular their General Operating Rules (RGEs), have become increasingly complex, notably to take account of OEF and reassessment of the threats from external hazards. This increased complexity may result in problems with applying the RGEs, or the operators may even lose sight of the purpose of their actions, which has consequences for risk management. EDF has started a short, medium and long-term simplification process, which has already led to exchanges with ASN and IRSN. At the same time, ASN called the profession together in 2024, for a round of discussions with the Steering Committee for Social, Human and Organisational Factors. A summary of this work will be published in 2025. Stress corrosion lessons to be consolidated The existence of the stress corrosion phenomenon affecting certain auxiliary piping was discovered at the end of 2021 and led to a strategy of systematic replacement of the lines considered to be susceptible in 2023, and increasingly wide-ranging inspections which will continue on the entire fleet up until 2025. On the occasion of the next periodic safety reviews, the lessons learned will need to be incorporated by EDF into its maintenance programmes. ASN in particular considers that the hypotheses concerning the lack of susceptibility to degradation mechanisms, adopted for certain zones which are not monitored by a preventive maintenance programme, must be backed up by a programme of additional investigations. Monitoring the commissioning of the Flamanville EPR and the EPR 2 programme Following the examination carried out by ASN with the support of IRSN, and after consulting the public about EDF’s dossier, the ASN decision of 7 May 2024 authorised commissioning of the Flamanville EPR reactor, thus allowing EDF to load nuclear fuel and carry out start-up tests. This authorisation comprised technical prescriptions concerning the performance of the tests, defining the deadline for replacement of certain components and stipulating provisions for the incorporation of OEF. Since this authorisation, ASN holds daily discussions with the site and, in 2024, carried out ten or so commissioning follow-up inspections, notably at the most important stages. The licensee encountered various equipment issues, which delayed the reactor’s power-up, but ASN has not at this stage identified any anomaly in the results of the start-up tests. About fifty significant safety events were however declared by the licensee between commissioning and the end of 2024, a rate that is significantly higher than expected, even for a new reactor. ASN was particularly vigilant on this subject, notably during inspections, and at this point considers the measures taken by the licensee to be pertinent. EDF has started a programme to build EPR 2 type reactors in France. The first reactor pairs will be built at Penly, Gravelines and Bugey. The creation authorisation application for a Basic Nuclear Installation (BNI) on the Penly site, submitted by EDF in 2023, is being examined and should reach a conclusion in 2027. Given the lessons learned from the Flamanville EPR project, ASN has initiated a process to monitor EDF’s project organisation and management, as well as management of the supply chain for safety-important equipment. Reception of the first examination files for small modular reactor projects confirms ASN’s prior positions regarding the need for a systemic approach In 2024, interest in SMRs, with more or less ambitious innovations, remained high, in the search for decarbonised energy production solutions. This context confirmed the pertinence of the organisation and the preparatory exchanges framework created by ASN in 2023 to support the new players, start-ups in particular, lead national and international discussions on the safety objectives to be applied to these objects and understand the diversity of designs and innovations. In 2024, the first creation authorisation application files or requests for opinions on the safety options were submitted for projects supported by the “France 2030” programme. In this context, a number of issues are crucial. First of all, most of these reactors should be located on the non-nuclear sites of their customers. This type of site can be in areas comprising major industrial or natural risks, or in immediate proximity to densely inhabited areas, which would make it complicated to implement population and environment protection measures in the Editorial by the Commission 4 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024
event of an accident. When envisaging locating reactors on such sites, the safety objectives to be achieved must be adapted, consistently with the method used to take account of malicious attacks. ASN set up a pluralistic exchange framework involving the stakeholders, to inform its thinking and thus be able to define a position on the safety objectives of these reactors. The most innovative reactors also need specific fuel for which the industrial production and reprocessing chains do not yet exist and would require significant investment. ASN recalls the importance of developing a systemic approach incorporating the industrial chain, supply of nuclear fuel, management of spent fuels and other waste generated, as well as management of the risk of malicious acts and the proliferation of nuclear materials. Faced with quality and safety culture challenges along the subcontracting chain, the industry has launched numerous initiatives The revival of the nuclear industry represents a challenge for the sector, not only in terms of recruitment, but also with respect to growth not seen for several decades, as well as in terms of guaranteeing the required quality of all components involved in safety. Industrial rigour and the safety culture are essential and the sector, in particular within the French Nuclear Energy Industry Players Group (GIFEN), is fully aware of this. However, 2024 again saw significant deviations and even irregularities, which were dealt with by the licensees concerned and examined by ASN’s departments. Faced with these persistent deviations, the Commission held a hearing of the EDF Chief Executive Officer to ensure that there is a true collective mobilisation to avoid a recurrence of the manufacturing and construction defects that beset the construction of the Flamanville EPR, notably on the new nuclear construction sites. ASN considers that the plans proposed by EDF and the GIFEN are a step in the right direction, but finds that the mobilisation by the industrial players as a whole is insufficiently robust. In 2024, ASN produced a practical guide concerning the quality of equipment intended for nuclear facilities, which notably recalls the importance of accurately identifying the requirements and the need for appropriate and timely monitoring of the production chain. Considerations on the long-term development of the “fuel cycle” plants For several years now, ASN has been warning of the pressure on the “fuel cycle” in France. The “cycle” facilities are vulnerable and each unit is a unique link in the processing chain. Saturation of the spent fuel storage facilities at La Hague would also have consequences for the operation of the Nuclear Power Plants (NPPs). The significant drop in production by the Melox plant and the faster than anticipated corrosion of the evaporators at La Hague, used to concentrate the nitric acid solutions of fission and transuranic products, illustrated this vulnerability in recent years. This situation is however improving, with the gradual rise in Melox production over the past two years and replacement of the evaporators at La Hague which was completed this year. With regard to pressure on the “cycle”, the decision to continue to operate reactors consuming MOX fuel (those of 900 MWe), pushes back the prospect of saturation of spent fuel storage capacity. Following the Nuclear Policy Council meeting of February 2024, active consideration was given to the long-term future and upgrading of the “cycle” plants, with a view to continuation of the reprocessing policy up until the end of the century. In this context, EDF abandoned its centralised pool project in favour of a facility integrated into Orano’s industrial programme on the La Hague site. The new facilities will need to be designed taking account of the most recent safety standards, at least equivalent to those of EDF’s centralised pool project. While waiting for these future facilities and given the fact that they will not be able to take over instantaneously from the existing ones, it is essential to continue to implement countermeasures against the risk of saturation. Over and above simple announcements, it is essential that decisions be taken immediately so that the projects can move to the implementation phase and be completed as rapidly as possible, starting with commissioning of new pools in 2040. The major upcoming milestones are Orano’s submission of the Safety Options Dossiers (DOS) for the new facilities and then referral to the National Commission for Public Debate (CNDP) concerning a dossier presenting the projects for new spent fuel storage ponds. Following the current study phase, the Future Back-End project should ideally be the subject of debate and consultation. Editorial by the Commission ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024 5
Continued examination of the Cigéo dossier Following the January 2023 submission by the National Radioactive Waste Management Agency (Andra) of the creation authorisation application dossier for Cigéo, a geological disposal project for high- and intermediatelevel, long-lived waste (HLW and ILW-LL), ASN – with the support of IRSN – began a technical examination of the dossier, which will end with an ASNR opinion in 2025 and a public inquiry in 2026. This technical examination continued in 2024, notably with two meetings of the Advisory Committee of Experts for Waste dealing with the basic data and hypotheses used to establish the safety case, and then with safety during the operating phase. On these two thematic subjects, this work enabled an evaluation of the extent to which the dossier presented by Andra complied with the requirements for the possible issue of the authorisation decree, but also identification of the additional data that will have to be provided in order to successfully pass the future milestones in the life of the facility. Andra will thus have to provide additional data before the beginning of excavation work, currently scheduled for 2035, notably on the safety case for operation of bituminous waste disposal, closure of the ILW-LL vaults and operation of the high-level vaults. The long-term safety issues of the repository, following its closure, are studied in 2025 as part of the third and final phase of the technical examination of the dossier. At this stage, ASNR considers that there are no obstacles to the continuation of the examination procedure in accordance with the envisaged calendar, which schedules work for a period of five years. As described earlier, with a view to continued operation of the reactors for 50 to 60 years and the creation of six EPR 2 reactors, the adaptability of Cigéo was evaluated and nothing has as yet emerged to rule this out. However, the adaptation of the facility to changes such as the service life extension of the reactors beyond 60 years, the construction of eight additional EPR 2, or a fleet of SMRs and/or fast neutron reactors, would be evaluated after publication of the Creation Authorisation Decree on the basis of future adaptability studies, once the corresponding scenarios have been defined. A contrasting situation in the medical field In 2024, the level of radiation protection remained at a satisfactory level in the medical field, despite a contrasting situation and points warranting particular attention that have persisted for several years. The context remains marked by pressure, notably on human resources, and constantly rising activity levels. Working organisations are increasingly complex, with pooling of resources, multi-site working, increasingly frequent use of outside contractors and increasing outsourcing of radiation protection skills, including among the most advanced facilities. This situation is creating new technical, operational and organisational constraints. In this context, ASN alerts all the stakeholders to the risk of a lesser assimilation of the radiation protection issues and recalls the need to evaluate the radiation protection impact of any organisational change. Certain significant events and the findings made during inspections in 2024 confirm the weak signals indicative of a context that is prejudicial to radiation protection, as already mentioned in 2023. ASN recalls that the main guarantee of a high level of radiation protection lies in a robust radiation protection culture, promoted by trained professionals. This culture must be regularly maintained in order to adapt good practices to the new risks, maintain an efficient optimisation approach and prevent the repetition of previous incidents. ASN still observes an unsatisfactory situation regarding fluoroscopy guided interventional practices carried out in the operating theatre. In this field, where the indications and the number of patients concerned are increasing and diversifying, optimisation actions and the conformity of the facilities with the layout rules are essential to managing the radiation protection issues. Enforcement measures have been taken in the past two years owing to notable deficiencies in the registration of X-ray emitting equipment, as well as persistent deviations concerning the conformity of the premises and patients and personnel radiation protection training. In radiotherapy, target errors, notably wrong-side errors, were again observed in 2024. Nationwide operating experience feedback was collected, in collaboration with the professional organisations, and shared with the professionals, so that these admittedly rare errors are not repeated. In 2024, a radiotherapy accident with serious consequences affected a patient whose radiotherapy antecedents had not been taken into account. In the light of progress in the treatment of cancers, ASN draws the attention of the professionals to the increase in the cases of patients who could benefit from a second radiotherapy treatment and the over-exposure risks associated with these situations. In nuclear medicine, two particular situations can pose problems and are made more frequent by the development of Internal Targeted Radiotherapy (ITR). This involves on the one hand care of the patient in the event of extravasation during administration of the treatment; on the other, the waste management route when waste contaminated by radioactivity produced at the home of patients after out-patient treatment triggers the alarms on the detection portals at the entrance to the collection Editorial by the Commission 6 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024
centres. Owing to their radiological nature, these events mobilise considerable response resources and specific operational and support procedures, even if the health implications remain limited. Their increased frequency in 2024 is a subject of concern, given the expected rise in the number of patients eligible for these treatments. ASN calls on the professionals to be extremely attentive to preventing such situations. Anticipating and supporting innovation in the medical field The deployment of new techniques and practices in therapy is a source of hope for the patients, but a subject requiring vigilance in order to ensure that they are integrated into the health care system rapidly and safely. This entails being fully aware of the corresponding radiation protection issues, for the patient, their entourage, the workers and the environment, and identifying and then implementing the means needed to manage them. This vigilance is particularly important given the growth of ITR, the arrival of the ZAP-X® platform, or the development of flash radiotherapy, pulsed fields and adaptive radiotherapy. ASN recalls that the radiation protection issues are not limited to the performance of the procedure, but begin as of the design phase and, as applicable, continue up to management of waste and effluents. These radiation protection issues must be integral to the thinking at each step along the way. This means that data pertinent for radiation protection must be input and, as applicable, looked for or studied by the designers and developers. In 2025, ASNR will continue its research, expert assessment and regulation work, with the assistance of its Advisory Committees of Experts, such as the Committee for the analysis of new medical techniques and practices using ionising radiation, or the Advisory Committee of Experts for Radiation Protection, together with the various institutional stakeholders in the field of health and the professional organisations. It will capitalise on the lessons learned from European projects in order to mobilise all stakeholders and develop the regulation and oversight system, both nationally and at the European level, so that radiation protection issues remain at the heart of the decisionmaking process in an innovative and constantly evolving health system. Sustained international activity International activities continued apace. Numerous meetings with its counterparts enabled ASN to discuss its practices and share the challenges linked notably to the launch of new projects and the use of innovative technologies – such as Artificial Intelligence – in the nuclear sector. Work relative to the second thematic peer review (TPR ENSREG), chaired by an ASN representative, concerning protection of nuclear facilities against fire risks, has ended and will enable each country to draft its national action plan in 2025. Two seminars, held in Luxembourg, were a forum for discussions on best practices and identifying areas for improvement in each country. With regard to radiation protection, ASN – which is chairing the Heads of the European Radiological Protection Competent Authorities association (HERCA) – the aim of which is to promote a high level of radiation protection in Europe, was actively involved in encouraging sharing of experience between the European authorities regarding the practical implementation of international standards and contributing to balanced updating of them. Finally, the creation of ASNR will make it possible to reinforce France’s representation internationally on the subject of nuclear safety and radiation protection. With this in mind, the international teams at ASN and IRSN together laid the groundwork for the creation of a unified international department that is operational as of 1 January 2025. n Editorial by the Commission ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024 7
Unprecedented mobilisation in order to be ready by 1 January 2025 Olivier GUPTA Montrouge, 1 March 2025 he reform of the governance of nuclear safety and radiation protection oversight and regulation, as a result of the Act of 21 May 2024, represents a historic milestone with the creation of the Authority for Nuclear Safety and Radiation Protection (ASNR). It is independent of the licensees and the Government and not only has considerable oversight and regulatory powers but also significant expert assessment and research capabilities. Therefore, each decision that it takes, each check that it performs, each authorisation that it issues, will be based on state-of-the-art investigations and expert assessments, backed by the results of research. T EDITORIAL BY THE DIRECTOR GENERAL 8 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024
Unprecedented mobilisation of the departments so that ASNR can be operational as of 1 January 2025 Legislative and regulatory work It was essential for several Decrees needed for implementation of the 21 May 2024 Act to be published before 1 January. This is for example the case of the Decree transferring the goods, rights and obligations of the former IRSN to the Alternative Energies and Atomic Energy Commission (CEA), to the Ministry of the Armed Forces and to ASNR, or the Decree creating ASNR’s interim social bodies. A total of seven Decrees were published after the mandatory consultation of several bodies and review by the Conseil d’État (Council of State). This demanded extensive work by the partner administrations and the ASN and IRSN personnel, within a very short period of time, and I must thank them for their commitment and efforts. Work on operation and organisation While contributing to the preparatory work carried out by the Government on the specific Bill for this reform, the ASN and IRSN senior managements wished to see work started on defining the organisational and operating principles of the future entity by the autumn of 2023. Joint working groups were therefore set up, for individual fields of activity, with the aim of proposing broad outlines for the organisation and operation of the corresponding activity sector in the future ASNR. They mobilised the teams throughout the year 2024. A list of “essential” actions was drawn up to prepare for the creation of ASNR, mainly in the cross-cutting and support activities (human resources, budget and finance, IT, legal affairs, etc.). The work was extended to the Government departments whose support was needed, notably to determine the budgetary and financial architecture and set up a new budget programme dedicated to financing of the ASNR. The positioning of the personnel in the new structure had to be prepared. To do this, the ASN Commission, in its capacity as the future ASNR Commission, submitted a draft organisation of the departments for consultation by the ASN and IRSN social bodies in July 2024. An Executive Committee was created, then first Directors of the future ASNR entities were appointed in November 2024, and the personnel of the two entities were assigned to their posts during the course of December. The essential actions identified include ASNR’s ability to provide a unified response to its mission in the event of a nuclear accident, or more generally any radiological emergency situation. The joint work on this question ended in the summer of 2024 with the creation of a single Emergency Centre, staffed by personnel from the two entities, with integrated working arrangements. The organisation thus defined was tested by several exercises in the autumn of 2024, confirming its validity. Finally, as requested by Parliament, the ASNR internal rules of procedure, referred to by several Articles of the Act, notably to clarify the interface between “expert assessment” and “decision-making”, were submitted to the social bodies for consultation, then presented to the Parliamentary Office for the Evaluation of Scientific and Technological Choices (OPECST), before being adopted by the ASNR Commission in January 2025. This work as a whole guaranteed the continuity of the missions performed before and after 1 January 2025. Preparation for the creation of ASNR required unprecedented mobilisation of the personnel of the Nuclear Safety Authority (ASN) and the Institute for Radiation Protection and Nuclear Safety (IRSN) along with the partner administrations, in order to be ready by 1 January 2025. ASNR is now operational. The founding documents have been adopted, its governance structure is in place and the internal organisation has been set up. The emergency response organisation is functional with a single centre. Yet the ASNR creation work is far from over: even if the fundamentals are in place, many aspects still have to be dealt with day after day, in order to ensure harmonious routine operations. Thought must also continue to be given to a more complete organisation, making full use of synergies. This work has not however distracted the personnel from their primary role of protecting people and the environment. Editorial by the Director General ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024 9
Dialogue with and support for the personnel At the end of 2023, the ASN and IRSN senior managements, the IRSN personnel representative trades union organisations and the ASN personnel representative trades union organisations reached a consultation agreement regarding implementation of the reform project. This agreement made provision for the creation of a consultation commission for the merger project, in addition to the personnel representative bodies for each entity, so that joint discussions could be held up to the end of 2024 between the two senior managements and the personnel representatives of the two organisations. The personnel representatives took part in the working groups set up to prepare for the creation of ASNR. Finally, given the scope of the reform, the psychosocial risks prevention and treatment system was reinforced, both at IRSN and at ASN. The personnel were questioned and their responses were input into a “barometer” which, despite concerns surrounding the reform, revealed no particular negative aspects. A support unit staffed by occupational psychologists was also set up. Continuing to deploy ASNR in the future, adapting it to the new context, while performing its missions in full Despite the scale and scope of the preparatory work, much remains to be done. Future work will focus on two key areas. Continuing with setting up ASNR Setting up ASNR first of all entails implementing day-to-day operations. The beginning of the year 2025 is essentially devoted to smoothing out the differences in the operating and management methods between the two merged entities. As with any merger, good day-to-day working involves the creation of a unified information system and identical digital tools for all the personnel: this is a colossal and costly endeavour in the short term, even if it will eventually lead to savings. The overhaul of the management system (mapping of processes, management meetings cycles, internal oversight, etc.) has started, but is far from over. The Scientific Council and the Code of Conduct and Professional Ethics Committee, both required by law, should be set up in the first months of 2025. With respect to budget and finance matters, the creation of the new budgeting and purchasing processes is underway: these processes were not the same at ASN, an independent administrative Authority, and at IRSN, an industrial and commercial public establishment. The construction of a medium-term budget plan is in progress, even if the “voted services” period represented an additional constraint on the start of the works. In mid-2025, ASNR will present Parliament with its evaluation of the anticipated human, technical and financial resources it will need for the coming five years in order to carry out its duties in the new nuclear context, along with the essential steps to ensure the attractiveness of the working conditions of its personnel on the labour market in the nuclear field. With regard to human resources, a project is needed to harmonise employment conditions, which nonetheless respects the public or private status of the personnel. The long-term success of ASNR entails constructing an attractive framework for employment and skills. This involves setting up a legible hiring process, developing an “employer brand” which helps create an “ASNR” identify and stimulation of recruitment through an ambitious policy to take on young people in internships and apprenticeships. Building on IRSN’s experience, ASNR will be able to rely on an in-house tool, with the “Nuclear Safety and Radiation Protection University”, tasked not only with developing and transmitting in-house knowledge and skills to ASNR, but also making it available to all nuclear safety and radiation protection stakeholders in France and abroad. Setting up ASNR, also means building a collective mind-set. The general management decided to create joint integration days for the new arrivals at ASNR. Participative work was initiated around ASNR’s values: it will have to be taken further and expanded to involve more personnel. The managers involved in the construction of this collective mind-set will make a decisive contribution. The collective mind-set also involves high-quality social dialogue, bringing together the representatives of the personnel, regardless of their status. Finally, ASNR will have to be consolidated in its ecosystem in France and internationally, by reaffirming its legitimacy as the successor to ASN and IRSN, in the bodies where these two organisations were present. This also entails defining an ASNR integrated roadmap, in terms of dialogue with the stakeholders, notably with the support of the High Committee for Transparency and Information on Nuclear Safety (HCTISN). Editorial by the Director General 10 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024
Adapting working methods and organisations to the new context It is clear that today’s French and global nuclear context is no longer that which existed in the aftermath of the accident at the Fukushima Daiichi Nuclear Power Plant (Japan). From the technical viewpoint, there are many challenges: the prospect of nuclear reactors operating up to 60 years and beyond represents technical challenges requiring the acquisition of new knowledge able to deal with these remote time-frames. The construction of several EPR 2 and the refurbishment of the “fuel cycle” plants requires the construction of an oversight strategy for this large number of worksites. The development of innovation and the integration of new technologies, whether they concern small modular reactor or nuclear medicine projects, mean that ASNR must take a fresh look at how it dialogues with the stakeholders it regulates and oversees, so that it can anticipate future issues. The development of artificial intelligence will also modify interactions between ASNR and those responsible for nuclear activities, but will also offer new prospects for researchers, experts and inspectors. War at the gates of Europe raises the question of monitoring nuclear installations in areas of armed conflict. More broadly, over and above the nuclear field, the organisations in charge of regulation or oversight are facing queries about their role and how they carry out their missions. Finally, the increasingly tight budget situation for public organisations is to be taken into account. This changing context in which ASNR is carrying out its missions and today’s nuclear safety and radiation projection challenges will have to be taken into account in future changes to ASNR. The aim here is not simply change for change’s sake, but to take account of the fact that the current working methods and organisations, to a large extent inherited from the existing situation, were designed to allow the coexistence of two separate organisations, whereas the corresponding missions are now carried out by just one. As has just been done with management of emergency situations, a review will be needed of the extent to which these missions can be carried out differently, giving new meaning to the work of the personnel – taking account of their integration into ASNR – to benefit the protection of people and the environment, while ensuring that the processes are robust, notably in expert assessment and decision-making. The personnel concerned will be involved in these reviews. Giving absolute priority to our primary mission of protecting people and the environment Despite the scale of this work, which is to a large extent based on support or cross-cutting functions, the ASNR technical teams will remain fully committed to performing their mission to protect people and the environment. *** 2025 will be a decisive year for ASNR, which will have to continue with its transformation and conduct its essential missions to protect people and the environment. I know that to achieve this, I can count on the commitment of all the personnel, driven by a single goal: the public interest. n Editorial by the Director General ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024 11
Notable events 2024
01 I Flamanville EPR reactor The first months of reactor operation p. 14 02 I The challenges involved in preparing for the upcoming examination of numerous small modular reactor projects p. 16 03 I Radiation protection faced with the challenges of innovative medical techniques p. 18 04 I The guidelines of the fifth periodic safety review of the 900 MWe reactors p. 20 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024 13
On 7 May 2024, ASN authorised commissioning of the Flamanville EPR reactor. This was the first commissioning of a nuclear power reactor in France since that of Civaux Nuclear Power Plant (NPP) reactor 2 in 1999. The EPR is the first third-generation reactor in France. Its design allows a significant reduction in the probability of core melt and radioactive releases in the event of an accident by comparison with the previous generation of reactors. Despite the considerable difficulties encountered during construction, the reactor was commissioned in good conditions of safety. However, the first months of operation showed that EDF needs to reinforce its oversight and control of operational activities. Completion of the start-up tests In the commissioning authorisation, ASN regulated the various phases of the reactor’s power increase, so that – throughout the process – the start-up tests were performed correctly until nominal power was reached. Once the commissioning authorisation was given, EDF initiated fuel loading into the reactor vessel. First criticality, that is the beginning of the nuclear chain reaction in the reactor, took place on 3 September 2024. Flamanville EPR reactor The first months of reactor operation 01 I 02 I 03 I 04 NOTABLE EVENTS 2024 14 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024
EDF then carried out gradual power increases. The reactor was coupled to the electricity grid for the first time on 21 December 2024. When the reactor is started for the first time, EDF has to perform a large number of specific tests to check the correct operation of the systems which could not be tested before fuel was loaded. The purpose of these tests is to check that: • The core, its instrumentation and its protection systems behave as expected at the various power levels. • The nuclear steam supply system and turbine controls are correctly adjusted. • The secondary system, the turbine and the generator work correctly. These tests can only be carried out once enough steam is being produced. • Certain situations, such as reactor trip or turbine shutdown for example, are correctly managed. These tests are particularly closely monitored by ASN, which is kept informed in detail about their performance, the results and any incidents encountered. It also carries out inspections, most of which are unannounced. At the end of 2024, the tests already performed on the reactor’s safety-important systems had taken place satisfactorily. The various events which occurred since reactor commissioning Since the reactor was commissioned, EDF has notified a number of significant safety events that was higher than expected, even for the start-up of a new reactor. These events are primarily related to the learning curve followed by the teams when carrying out initial operation of the reactor and the transition between management of a construction site and actual operation of an installation. The causes of the vast majority of the events are organisational and human, with few being linked to equipment failures. Most of the human errors are rapidly detected and lead to the installation being restored to conformity almost immediately. Faced with this finding, and even if these events had no consequences for the installations, people and the environment, EDF implemented a number of measures to reinforce the oversight and control of its activities. These measures notably consist in stabilising the activity schedules and more clearly identifying and managing the risks before starting an operation. EDF also reinforced the support provided by its national teams. ASN considers that these measures are pertinent and appropriate for the difficulties encountered during this particular phase in the life of the installation. The next steps ASN authorisation was required for the first reactor increase to a power of more than 25% its nominal power. Beyond this power level, the systems required for core protection are different and the Authority for Nuclear Safety and Radiation Protection (ASNR) will in particular check that they are able to perform their function. ASNR approval will again be required before the first increase to a power higher than 80% nominal power. Most of the start-up tests will then have been carried out. After the start-up testing phase, EDF will continue with reactor operation up until the first refuelling outage. During this outage, EDF will conduct specific checks, notably a complete requalification of the main primary system. The licensee will also have to incorporate modifications to the installation and in particular replace the reactor vessel closure head. ASNR will examine these modifications and will check the operations carried out during this outage, as it does for any nuclear reactor. It will pay particular attention to capitalising on the Operating Experience Feedback (OEF) acquired during this phase. Finally, six months after the end of this outage, EDF shall send ASNR an end of start-up file presenting the results of other start-up tests, the OEF from the first operating cycle and shall update the reactor’s safety analysis report and general operating rules. ♦ NOTABLE EVENTS 2024 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024 15
In 2024, ASN was faced with a significant acceleration in contacts from Small Modular Reactor(1) (SMR) project developers. The steps taken as of 2023 to set up new frameworks for technical exchanges meant that it was possible to deal with this unprecedented situation and prepare for effective examination of the first dossiers. On of ASN’s main findings following these exchanges concerns the frequently unrealistic nature of the deployment schedules announced by many of the project developer. Acceleration in technical exchanges in 2024 with companies developing small modular reactor projects 1. Several SMR projects are currently being developed around the world. These are reactors with a power of less than 300 Megawatts electric (MWe), built mainly in a factory. They use a variety of technologies: that of the pressurised water reactors or advanced technologies (high-temperature, molten salt, fast neutron, etc. reactors). 2. asn.fr/reglementation/bulletin-officiel-de-l-asnr/fonctionnement-de-l-asnr/decisions-nominatives/decision-n-codep-mea-2024019956-du-directeur-general-de-l-asn In 2024, ASN and the Institute for Radiation Protection and Nuclear Safety (IRSN) had to deal with a very large number of contacts from all the companies developing SMR projects and who wished to initiate technical exchanges as rapidly as possible, while others wished to continue those already started in 2023. The fact of having to deal with about ten SMR projects, all promoted by as many different project developers, is an unprecedented situation in the French context and represents a very real challenge to the examination capacity of both ASN and IRSN. Given this challenge, ASN considered that it was essential to be able to initiate technical exchanges with the project developers rapidly, ahead of submission of the forthcoming applications required by the applicable regulatory procedures. Advance exchanges such as these have the advantage of making it possible to understand the innovations and new safety issues of these projects early on, and thus be as well prepared as possible to effectively examine the future dossiers to be submitted. In 2023, ASN had thus carried out a reorganisation of its departments, by creating a new entity specifically for these innovative reactor projects, and had also adapted its methods for technical exchanges with the project sponsors (see details in chapter 11 of the full ASN Report) so that the commitment of its resources and those of IRSN was proportionate to the development level of these various projects. These new technical exchange frameworks, gradually put into place in 2023 with the first France 2030 “Innovative reactors” award winners, were thus able to deal with a first significant increase in contacts from project developers in 2024. As shown in the diagram opposite, although these contacts in 2024 primarily concern preparatory technical exchanges (follow-up on screening phase and preparatory reviews), it should be noted that the developers of two projects this year decided to actually submit an examination request within a regulatory framework: • on 3 May 2024, a creation authorisation application was submitted by the Jimmy Energy company to the Minister responsible for nuclear safety for its SMR project designed to provide high-temperature heat for an industrial site; • on 31 October 2024, a request for an opinion on the main safety options of its SMR project designed to provide steam to an urban district heating network was submitted to ASN by the Calogena company. Creation of a specific Advisory Committee of Experts for innovative SMRs ASN can consult Advisory Committees of Experts (GPEs) for opinions and recommendations when preparing its most important resolutions relative to nuclear safety or radiation protection issues. As part of its preparation for the forthcoming examinations of innovative SMR projects, ASN set up a Crosscutting Advisory Committee of Experts in 2024(2) from The challenges involved in preparing for the upcoming examination of numerous small modular reactor projects 01 I 02 I 03 I 04 NOTABLE EVENTS 2024 16 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2024
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