ASN Report 2021

set by the framework directive on water and contributes to those of the strategy framework directive for the marine environment, by limiting the input of pollutants into the marine environment from water courses. For the NPPs, the campaigns to search for hazardous substances in water concluded that close monitoring of copper and zinc discharges was required. Under the Micro-pollutants Plan, the ASN action initiated in 2017 comprises three parts: ∙ monitor the effective implementation of the action plan proposed by EDF to reduce discharges of copper and zinc (gradual replacement of the brass condenser tubes with stainless steel or titanium tubes); ∙ monitor the discharge trends for these substances; ∙ if necessary revise the individual requirements applicable to NPPs, setting emission limits for these substances. To allow a revision of the emission limits for copper and zinc, among other things, ASN is examining EDF’s requests for modification of the requirements concerning water discharge and intake for the NPPs of Dampierre-en-Burly and Bellevillesur-Loire. Within this context, the Environmental Authority issued an opinion on the modification authorisation application file, submitted by the licensee of the Belleville-sur-Loire NPP, on 23 June 2021 and a public inquiry was held on it from 13 December 2021 to 28 January 2022. The modification authorisation application file submitted by the licensee of the Dampierre-en-Burly NPP was the subject of numerous discussions between the licensee and ASN in 2021, in order to reach draft resolutions which will be submitted for public consultation during the course of 2022. Accounting of BNI discharges The rules for accounting of discharges, both radioactive and chemical, are set in the general regulations by amended ASN resolution 2013-DC-0360 of 16 July 2013 relative to control of the detrimental effects and the impact of BNIs on health and the environment. These rules were set so as to guarantee that the discharge values accounted by the licensees, notably those considered in the impact calculations, will in no case be under-estimated. For discharges of radioactive substances, accounting is not based on overall measurements, but on an analysis per radionuclide, introducing the notion of a “reference spectrum”, listing the radionuclides specific to the type of discharge in question. The principles underlying the accounting rules are as follows: ∙ radionuclides for which the measured activity exceeds the decision threshold for the measurement technique are all counted; ∙ the radionuclides of the “reference spectrum” for which the measured activity is below the decision threshold (see box page 159) are counted at the decision threshold level. For discharges of chemical substances with an emission limit value set by an ASN binding requirement, when the concentration values measured are below the quantification limit, the licensee is required by convention to declare a value equal to half the quantification limit concerned. Monitoring discharges in the medical sector Pursuant to ASN resolution 2008-DC-0095 of 29 January 2008, radioactivity measurements are taken on the effluents coming from the places that produce them. In hospitals that have a nuclear medicine department, these measurements chiefly concern iodine-131 and technetium-99m. In view of the difficulties encountered in putting in place the permits to discharge radionuclides into the public sewage networks, as provided for by the Public Health Code, ASN has created a working group involving administrations, “producers” (nuclear physicians, researchers) and sanitation professionals. The report from this working group formulating recommendations to improve the efficiency of the regulations was presented in October 2016 to the Advisory Committee for Radiation Protection (GPRADE), for industrial and research applications of ionising radiation and the environment. ASN consulted the stakeholders in 2017 on this subject. The report from the working group and a circular letter intended for the professionals concerned and constituting the applicable doctrine on the subject were published on the ASN website on 14 June 2019. Since 2019, the CIDRRE tool (Calculation of the impact of radioactive discharges into the sewage networks) developed by IRSN, enables the licensees to evaluate the impact of their discharges. It is on-line on the Internet. Moreover, additional work has been started concerning the use of new radiopharmaceutical drugs and their environmental impact, as well as the definition of guideline levels enabling the sewage network managers to regulate the effluent discharges into the sewage networks. In the small-scale industrial nuclear sector, few plants discharge effluents apart from cyclotrons (see chapter 8). The discharge permits stipulate requirements for the discharges and their monitoring, which are subject to particular scrutiny during inspections. 4.1.2 Evaluating the radiological impact of nuclear activities The radiological impact of effluents produced by medical activities The radiological impact of the effluents or waste produced by the nuclear medicine departments underwent recent assessments, which concluded that these discharges represent a low dose impact for persons outside the health facility. The radiological impact of BNIs In accordance with the optimisation principle, the licensee must reduce the radiological impact of its facility to values that are as low as possible under economically acceptable conditions. The licensee is required to assess the dosimetric impact of its activity. As applicable, this obligation is the result of Article L. 1333-8 of the Public Health Code, or the regulations concerning BNI discharges (Article 5.3.2 of ASN resolution 2013-DC-0360 of 16 July 2013, amended, concerning control of detrimental effects and the impact of BNIs on health and the environment). The result is to be assessed considering the allowable annual dose limit for the public (1 millisievert per year –mSv/year) defined in Article R.1333-11 of the Public Health Code, which corresponds to the sum of effective doses received by the public as a result of nuclear activities. In practice, only traces of artificial radioactivity are detectable in the vicinity of the nuclear facilities; most measurements taken during routine surveillance are below the decision threshold or reflect the natural radioactivity. As these measurements cannot be used for dose estimations, models for the transfer of radioactivity to humans must be used, on the basis of measurements of discharges from the installation. These models are specific to each licensee and are detailed in the facility’s impact assessment. During its assessment, ASN devotes efforts to verifying that these models are conservative, in order to ensure that the impact assessments are not underestimated. In addition to the impact assessments produced on the basis of discharges from the facilities, the licensees are required to carry out environmental radioactivity monitoring programmes (aquatic environments, air, earth, milk, grass, agricultural produce, etc.), ASN Report on the state of nuclear safety and radiation protection in France in 2021 157 03 – REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION 08 07 13 04 10 06 12 14 03 09 05 11 02 01 AP

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