Radioactive waste and polluted sites

The management of radioactive waste is governed by the 28 June 2006 Act on the sustainable management of radioactive materials and waste. This Act defines a roadmap for management of all radioactive waste, in particular by requiring the updating every 3 years of a French National Radioactive Material and Waste Management Plan (PNGMDR). The first edition of the PNGMDR, produced by a pluralistic working group co-chaired by ASN, was issued at the end of 2006. A new edition of the PNGMDR for the period 2010-2012 was finalised at the end of 2009. This new edition identifies new possibilities for continuing to improve the management of radioactive waste, in particular with regard to the former radioactive waste storage sites, the fate of the waste stored by AREVA on its Malvési site, packaging of waste, particularly that containing organic substances, the management of mining waste rock liable to have a radiological impact, reuse in the nuclear sector of waste resulting from decommissioning, and optimisation of the waste management solutions.

ASN considers that the 28 June 2006 Act and the PNGMDR provide a clear, coherent and complete framework for the management of radioactive waste in France. It also considers that the discussion and debating arrangements put into place to deal with the subject of radioactive waste, particularly within the framework of the PNGMDR, are satisfactory. ASN attaches importance to informing its foreign counterparts of the framework created for radioactive waste management in France. This was in particular the case with the 2009 presentation of the French report, pursuant to the Joint Convention on the safety of spent fuel management and on the safety of radioactive waste management (www.asn.fr). This Convention requires that each Contracting Party present a report every three years, describing how it implements the obligations of the Convention. For France, drafting of this report was coordinated by ASN, with contributions from other nuclear regulators and nuclear licensees. This report was presented in Vienna in May 2009.

In 2009, ASN continued with its actions aimed at ensuring that radioactive waste is managed safely, right from the moment it is first produced. ASN thus regulates its management within the nuclear installations and periodically assesses the management strategies put in place by the licensees. Therefore in 2006, ASN took a stance on the possibility of recovering legacy waste in the AREVA NC plant at La Hague. It would appear that although AREVA NC has adequate resources for implementing its recovery strategy, the safety of some of the storage facilities, such as the HAO silos, is unsatisfactory. ASN will remain vigilant in ensuring that the strategy changes announced by the licensee in 2009 do not compromise the announced time-frame for removal from storage.

The safety of the CEA waste and spent fuel treatment and interim storage installations was assessed at the end of the 1990s, following which CEA envisaged creating new installations and renovating certain others. ASN observes that, on the whole, CEA is experiencing difficulty in meeting its commitments, particularly the time aspect, and it has to periodically review its strategy and regularly postpone deadlines for removal of legacy waste from storage. A new summary file concerning the CEA waste strategy will be transmitted in mid-2010 so that ASN can adopt a stance following a joint review by the Advisory Committee for waste and the waste management safety committee for defence installations. ASN will pay close attention to ensuring that CEA presents a coherent and well-structured strategy for management of all the existing and future waste, identifying the needs with respect to treatment and packaging facilities, transport and storage of the waste, along with the anticipated resources (both human and material) required. It will also ensure that the storage removal schedules comply with the CEA commitments and the schedules defined during its discussions with ASN. ASN will also closely monitor the storage removal operations for waste with the highest safety stakes.

With regard to EDF, ASN will in 2010 be reviewing the document transmitted by EDF at the end of 2008 concerning the consistency of the nuclear fuel cycle.
With regard to the long-term management of radioactive waste, ASN is encouraged by the way ANDRA operates its waste centres currently in service.

In January 2009, ASN submitted its opinion to the Minister for Ecology concerning the search for a site started by ANDRA in June 2008 for the LL-LL waste repository project, pursuant to the 28 June 2006 Programme Act and the decree of 16 April 2008. The repository is designed to take graphite and radium-containing waste and could also accept other low level long-lived waste. ASN believes that it is essential for France to have a repository of this type. ASN will therefore continue to closely monitor the selected sites investigation process and, together with ANDRA, will prepare the forthcoming review milestones with a view to obtaining the authorisation decree for the future repository.

After it adopts a stance on the choice of a reversible repository in deep geological formations in January 2010, ASN will in 2010 review the dossiers submitted at the end of 2009 by ANDRA. These dossiers concern a small area of interest suitable for siting of a repository, a presentation of the design options, the operational and long-term safety and reversibility options, a presentation of the waste inventory model to be used and a definition of the storage options that will be needed in addition to the repository. ASN will also be referring to the Advisory Committee for waste with regard to the application for renewal of the license to operate the Bure laboratory after 2011, to be presented by ANDRA in early 2010.

Since 2002, ASN has been involved in regulating management of sites polluted by radioactive materials. The circular that was published in 2008, specifying the roles and responsibilities of the various stakeholders with regard to handling of polluted sites and soils, consolidates ASN's role of providing support for the préfets. ASN also takes part in the National Funding Commission for Radioactive Matters set up within ANDRA as part of its public service role, the aim of which is to review rehabilitation projects for contaminated sites for which the party responsible has defaulted. This renovated regulatory framework gave ASN greater powers to act on polluted sites in 2009 and this will continue in 2010, in collaboration with the administrations concerned and the other stakeholders (ANDRA, IRSN, local authorities, associations, etc.). ASN restates its position that the solution involving maintaining the contamination in-situ must not be the reference solution for management of sites polluted by radioactive materials and that this option can only be an interim solution or reserved for situations in which the complete clean-out option cannot be contemplated owing to the volume of waste to be excavated.
In 2010, ASN will also continue to work on revising the regulations, following the publication of the TSN Act, in particular by issuing decisions to clarify the measures applicable to BNIs concerning the production of nuclear waste, the storage of this waste, its packaging and its disposal in the appropriate installations.

Finally, ASN will remain closely involved in international work, by maintaining its active participation in the working groups of WENRA and NEA and by completing the work it revived in 2009 within the European Pilot Group (comprising a number of European regulatory authorities and international bodies) on what is required in the safety case for a deep geological repository and the acceptance criteria for radioactive waste. ASN will also make an active contribution to the work done within the European Nuclear Safety Regulators Group (ENSREG) in order to ensure that a European directive on radioactive waste and spent fuel is adopted.