ASN REPORT on the state of nuclear safety and radiation protection in France in 2022
The French Nuclear Safety Authority presents its report on the state of nuclear safety and radiation protection in France in 2022. 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.
2022 THE FRENCH NUCLEAR SAFETY AUTHORITY ROLES OPERATIONS KEY FIGURES ASN ORGANISATION CHART ASN was created by the 13 June 2006 Nuclear Security and Transparency Act. It is an independent administrative Authority responsible for regulating civil nuclear activities in France. On behalf of the State, ASN ensures the oversight of nuclear safety and radiation protection to protect people and the environment. It informs the public and contributes to enlightened societal choices. ASN decides and acts with rigour and discernment: its aim is to exercise oversight that is recognised by the citizens and regarded internationally as a benchmark for good practice. ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2022
REGULATING ASN contributes to drafting regulations, by submitting its opinion to the Government on draft decrees and Ministerial Orders, and by issuing technical regulations. It ensures that the regulations are clear, accessible and proportionate to the safety issues. AUTHORISING ASN examines all individual authorisation applications for nuclear facilities. It grants licenses and authorisations, with the exception of major authorisations for Basic Nuclear Installations (BNIs), such as creation and decommissioning. ASN also issues the licenses provided for in the Public Health Code concerning small-scale nuclear activities and issues licenses or approvals for radioactive substances transport operations. MONITORING ASN is responsible for ensuring compliance with the rules and requirements applicable to the facilities and activities within its field of competence. Since the Energy Transition for Green Growth Act of 17 August 2015, known as the “TECV Act”, ASN’s roles now include protecting ionising radioactive sources against malicious acts. Inspection is ASN’s primary monitoring activity. More than 1,900 inspections were thus performed in 2022 in the fields of nuclear safety and radiation protection. ASN has graded enforcement and penalty powers (formal notice, administrative fines, daily fines, ability to carry out seizure, take samples or require payment of a guarantee, etc.). The administrative fine is the competence of the ASN Administrative Enforcement Committee, which complies with the principle of the separation of the examination and sentencing functions. INFORMING ASN reports on its activities to Parliament. It informs the public and the stakeholders (environmental protection associations, Local Information Committees, media, etc.) about its activities and the state of nuclear safety and radiation protection in France. ASN enables all members of the public to take part in the drafting of its decisions with an impact on the environment. It supports the actions of the Local Information Committees of the nuclear facilities. The asn.fr website is ASN’s main information channel. IN EMERGENCY SITUATIONS ASN monitors the steps taken by the licensee to make the facility safe. It informs the public and its foreign counterparts of the situation. ASN assists the Government. More particularly, it sends the competent Authorities its recommendations regarding the civil security measures to be taken. REGULATION AND MONITORING OF DIVERSIFIED ACTIVITIES AND FACILITIES Nuclear power plants, radioactive waste management, fabrication and reprocessing of nuclear fuel, packages of radioactive substances, medical facilities, research laboratories, industrial activities, etc. ASN monitors and regulates an extremely varied range of activities and installations. This regulation covers: ∙ 56 nuclear reactors producing 70% of the electricity consumed in France, as well as the Flamanville EPR reactor under construction; ∙ about 80 other facilities participating in civil research activities, radioactive waste management activities or “fuel cycle” activities; ∙ 35 facilities which have been finally shut down or are being decommissioned; ∙ several thousand facilities or activities using sources of ionising radiation for medical, industrial or research purposes; ∙ several hundred thousand shipments of radioactive substances performed annually in France. EXPERT SUPPORT When drawing up its decisions, ASN calls on outside technical expertise, in particular that of the French Institute for Radiation Protection and Nuclear Safety (IRSN). The ASN Chairman is a member of the IRSN Board. ASN also calls on the opinions and recommendations of seven Advisory Committees of Experts (GPEs), from a variety of scientific and technical backgrounds. THE FRENCH NUCLEAR SAFETY AUTHORITY ROLES
THE COMMISSION The Commission defines ASN’s general policy regarding nuclear safety and radiation protection. It consists of five Commissioners, including the ASN Chairman, appointed for a term of 6 years(*). APPOINTED BY the President of the Republic APPOINTED BY the President of the Senate APPOINTED BY the President of the National Assembly * The Environment Code, modified by Act 2017-55 of 20 January 2017, introducing the general status of the independent administrative Authorities and the independent public Authorities, provides for the renewal of half of the ASN Commission, other than its Chairman, every three years. Decree 2019-190 of 14 March 2019 (codifying the provisions applicable to BNIs, the transport of radioactive substances and transparency in the nuclear field) sets out the relevant interim provisions and modifies the duration of the mandates of three Commissioners. ** By Decree of the President of the Republic dated 21 April 2021, Laure Tourjansky was appointed Commissioner for the remainder of the mandate of Lydie Évrard, called to other duties. *** Administrative region headed by a Prefect. IMPARTIALITY The Commissioners perform their duties in complete impartiality and receive no instructions from either the Government or any other person or institution. INDEPENDENCE The Commissioners perform their duties on a full‑time basis. Their mandate is for a six-year term. It is not renewable. The duties of a Commissioner can only be terminated in the case of impediment or resignation duly confirmed by a majority of the Commissioners. The President of the Republic may terminate the duties of any member of the Commission in the event of a serious breach of his or her obligations. COMPETENCIES The Commission takes decisions and issues opinions, which are published in ASN’s Official Bulletin. The Commission defines ASN's oversight policy. The Chairman appoints the ASN inspectors. The Commission decides whether to open an inquiry following an incident or accident. Every year, it presents the ASN Report on the State of Nuclear Safety and Radiation Protection in France to Parliament. Its Chairman reports on ASN activities to the competent committees of the National Assembly and of the Senate and to the Parliamentary Office for the Evaluation of Scientific and Technological Choices. The Commission defines ASN's external relations policy at national and international level. THE DEPARTMENTS ASN comprises departments placed under the authority of its Chairman. The departments are headed by a Director General, appointed by the ASN Chairman. They carry out ASN’s day-to-day duties and prepare draft opinions and decisions for the ASN Commission. They comprise: ∙ head office departments organised according to topics, which oversee their field of activity at a national level, for both technical and transverse matters (international action, preparedness for emergency situations, information of the public, legal affairs, human resources and other support functions). They more specifically prepare draft doctrines and texts of a general scope, examine the more complex technical files and the “generic” files, in other words those which concern several similar facilities; ∙ 11 regional divisions, with competence for one or more administrative regions, so as to cover the entire country and the overseas territories. The regional divisions conduct most of the oversight in the field on the nuclear facilities, radioactive substances transport operations and small-scale nuclear activities. They represent ASN in the regions and contribute to public information within their geographical area. In emergency situations, the divisions assist the Prefect of the département(***) who is responsible for the protection of the population, and oversee the operations to safeguard the facility affected by the accident. Bernard DOROSZCZUK Chairman Sylvie CADET-MERCIER (*) Commissioner Géraldine PINA JOMIR Commissioner Laure TOURJANSKY (*)(**) Commissioner Jean-Luc LACHAUME (*) Commissioner from 13 november 2018 to 12 november 2024 from 21 december 2016 to 9 december 2023 from 15 december 2020 to 9 december 2026 from 21 april 2021 to 9 december 2023 from 21 december 2018 to 9 december 2026 THE FRENCH NUCLEAR SAFETY AUTHORITY OPERATIONS ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2022
€85.5 M 81 11 IRSN budget devoted to expert assessment work on behalf of ASN information notices press conferences budget for ASN (programme 181) €68.30 M THE FRENCH NUCLEAR SAFETY AUTHORITY 85% management 48% women PERSONNEL 516 staff members ASN ACTIONS INFORMATIONS BUDGET 2,161 individual licensing and registration resolutions issued 19 plenary sessions of the Advisory Committees of Experts 28,508 inspection follow-up letters available on asn.fr as at 31 December 2022 239 technical opinions sent to ASN by IRSN inspections of which 4% were carried out remotely 1,868 KEY FIGURES 2022 replies to queries from the public and the stakeholders 600 329 inspectors
111 THE FRENCH NUCLEAR SAFETY AUTHORITY NUMBER OF SIGNIFICANT EVENTS IN THE MEDICAL FIELD (*) NUMBER OF SIGNIFICANT EVENTS RATED ON THE INES SCALE (*) 1,082 events in the Basic Nuclear Installations 985 97 88 events in the transport of radioactive substances 76 12 202 events in small-scale nuclear activities (medical and industrial) 162 1 39 Level 0 Level 1 Level 2 619 significant events per area of exposure 117 significant events in external beam radiotherapy and brachytherapy according to the ASN-SFRO scale Brachytherapy External radiotherapy Nuclear medicine Computed tomography Conventional and dental radiology Fluoroscopy-guided interventional practices 67 219 191 6 25 * The INES scale (International Nuclear and Radiological Event Scale) was developed by IAEA to explain to the public the importance of an event in terms of safety or radiation protection. This scale applies to events occurring in BNIs and events with potential or actual consequences for the radiation protection of the public and workers. It does not apply to events with an impact on the radiation protection of patients, and the criteria normally used to rate events (notably the dose received) are not applicable in this case. As it was pertinent to be able to inform the public of radiotherapy events, ASN – in close collaboration with the French Society for Radiotherapy and Oncology – developed a scale specific to radiotherapy events (ASN-SFRO scale). These two scales cover a relatively wide range of radiation protection events, with the exception of imaging events. Out of scale Level 0 Level 1 Level 2 Level 3 4 KEY FIGURES 2022 73 24 16 ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2022
HEAD OF PRIVATE OFFICE Sylvie RODDE DEPUTY DIRECTORS GENERAL Pierre BOIS Julien COLLET Daniel DELALANDE CHIEF INSPECTOR Christophe QUINTIN DIRECTOR OF PRIVATE OFFICE Vincent CLOÎTRE DIRECTOR GENERAL Olivier GUPTA CHAIRMAN Bernard DOROSZCZUK ETHICS OFFICER Alain DORISON MANAGEMENT AND EXPERTISE OFFICE Adeline CLOS REGULATION AND OVERSIGHT SUPPORT MISSION Julien HUSSE NUCLEAR PRESSURE EQUIPMENT Corinne SILVESTRI WASTE, RESEARCH, FACILITIES AND FUEL CYCLE Cédric MESSIER NUCLEAR POWER PLANTS Rémy CATTEAU IONISING RADIATION AND HEALTH Carole ROUSSE ENVIRONMENT AND EMERGENCY SITUATIONS Olivier RIVIÈRE TRANSPORT AND SOURCES Fabien FÉRON INTERNATIONAL RELATIONS Luc CHANIAL LEGAL AFFAIRS Olivia LAHAYE INFORMATION, COMMUNICATION AND DIGITAL USAGES Clémence PICART COMMISSION DEPARTMENTS COMMISSIONERS Sylvie CADET-MERCIER Jean-Luc LACHAUME Géraldine PINA JOMIR Laure TOURJANSKY CHAIRMAN Maurice MÉDA ADMINISTRATIVE ENFORCEMENT COMMITTEE GENERAL DIRECTORATE GENERAL SECRETARIAT Jean-Patrick GOUDALLE THE FRENCH NUCLEAR SAFETY AUTHORITY ORGANISATION CHART(*)
(1) For BNI oversight only, the Caen and Orléans divisions hold responsibility for the Bretagne and Île-de-France regions respectively. (2) The Paris division is responsible for Martinique, Guadeloupe, Guyane, Mayotte, La Réunion, Saint-Pierre-et-Miquelon. (3) The Bordeaux and Marseille divisions jointly regulate nuclear safety, radiation protection and the transport of radioactive substances in the Occitanie region. (4) The Châlons-en-Champagne and Strasbourg divisions jointly regulate nuclear safety, radiation protection and the transport of radioactive substances in the Grand Est region. * As at 1 March 2023. 1 BORDEAUX REGIONAL REPRESENTATIVE Alice-Anne MÉDARD REGIONAL HEAD Simon GARNIER 2 CAEN REGIONAL REPRESENTATIVE Olivier MORZELLE REGIONAL HEAD Gaëtan LAFFORGUE REGIONAL DIVISIONS 4 DIJON REGIONAL REPRESENTATIVE Jean-Pierre LESTOILLE REGIONAL HEAD Marc CHAMPION 7 MARSEILLE REGIONAL REPRESENTATIVE Sébastien FOREST REGIONAL HEAD Bastien LAURAS 5 LILLE REGIONAL REPRESENTATIVE Julien LABIT REGIONAL HEAD Rémy ZMYSLONY 8 NANTES REGIONAL REPRESENTATIVE Anne BEAUVAL REGIONAL HEAD Émilie JAMBU 10 PARIS REGIONAL REPRESENTATIVE Emmanuelle GAY REGIONAL HEAD Agathe BALTZER 6 LYON REGIONAL REPRESENTATIVE Jean-Philippe DENEUVY REGIONAL HEAD Nour KHATER 9 ORLÉANS REGIONAL REPRESENTATIVE Hervé BRÛLÉ REGIONAL HEAD Arthur NEVEU 11 STRASBOURG REGIONAL REPRESENTATIVE Hervé VANLAER REGIONAL HEAD Camille PERIER 3 CHÂLONS-EN-CHAMPAGNE REGIONAL REPRESENTATIVE Hervé VANLAER REGIONAL HEAD Mathieu RIQUART THE FRENCH NUCLEAR SAFETY AUTHORITY 10 9 8 7 5 4 3 2 1 DROM-COM (overseas France) Lille Division Hauts-de-France Châlons-en-Champagne Division (4) Grand Est Strasbourg Division (4) Grand Est Lyon Division Auvergne-Rhône-Alpes Marseille Division (3) Corse, Occitanie, Provence-AlpesCôte d'Azur Bordeaux Division (3) Nouvelle-Aquitaine, Occitanie Nantes Division Bretagne, Pays de la Loire Caen Division (1) Normandie Paris Division (2) Île-de-France, DROM-COM Orléans Division (1) Centre-Val de Loire 11 6 Dijon Division Bourgogne-Franche-Comté 10 ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2022
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EDITORIAL BY THE COMMISSION p. 2 • EDITORIAL BY THE DIRECTOR GENERAL p. 8 NOTABLE EVENTS 2022 p. 11 • ASN ASSESSMENTS p. 18 • REGULATORY NEWS p. 30 REGIONAL OVERVIEW OF NUCLEAR SAFETY AND RADIATION PROTECTION p. 36 SUMMARY Medical uses of ionising radiation 07 p. 206 Radioactive waste and contaminated sites and soils 14p. 356 International relations 06p. 192 Decommissioning of Basic Nuclear Installations 13 p. 334 Informing the public 05 p. 180 Nuclear research and miscellaneous industrial facilities 12 p. 328 Radiological emergency and post-accident situations 04p. 168 “Nuclear fuel cycle” facilities 11 p. 318 Regulation of nuclear activities and exposure to ionising radiation 03 p. 144 The EDF Nuclear Power Plants 10 p. 284 The principles of nuclear safety and radiation protection and the regulation and oversight stakeholders 02p. 118 Transport of radioactive substances 09 p. 266 Nuclear activities: ionising radiation and health and environmental risks 01p. 98 Sources of ionising radiation and their industrial, veterinary and research applications 08p. 236 Overview of the Basic Nuclear Installations as at 31 December 2022 APPENDIX p. 376 ADVICE TO THE READER i The control of small-scale nuclear facilities (medical, research and industry, transport) is presented in chapters 7, 8, 9. Only regulatory news for the year 2021 is present in this report. All the regulations can be consulted on asn.fr, under the heading “L’ASN réglemente”. ASN REPORT ON THE STATE OF NUCLEAR SAFETY AND RADIATION PROTECTION IN FRANCE IN 2022
EDITORIAL BY THE COMMISSION 2022, AN EXCEPTIONAL YEAR AND CONTEXT Montrouge, 7 March 2023 In 2022, the level of safety in the nuclear installations remained at a satisfactory level, as did radiation protection in the industrial, medical and radioactive substances transport sectors. However, the year 2022 was marked by issues in the nuclear installations hitherto never encountered, as well as by a period of intense heatwave. These events once again highlighted the need to maintain safety margins and to anticipate the challenges ahead, including dealing with exceptional situations linked to climate change. The year 2022 was also the year of debate on the French energy mix and the new prospects for nuclear energy, whether the continued operation of the existing installations or the construction of new ones. These come against the backdrop of the war in Ukraine and international tensions, which accentuate the issues of energy sovereignty and re-industrialisation. Given this context, the French Nuclear Safety Authority (ASN) considers that the discussions being held in preparation for the next Multi-year Energy Programme (MEP) should tackle the nuclear sector as a system (nuclear power generation, operation and future of the “fuel cycle”, management of the associated wastes). This nuclear system has to be taken in an holistic way, in order to be able to anticipate the safety, radiation protection and environmental protection issues as a whole, including those linked to climate change, with a medium and long term vision, thereby ensuring that these issues are at the heart of public decisions-making process. 2 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022
An unexpected stress corrosion phenomenon on the nuclear fleet which recalls the need for safety margins In 2022, the number and duration of reactor outages were unprecedented. This situation was partly foreseeable given the operations involved in the “major overhaul” of the nuclear fleet decided on by EDF and the consequences of the postponement of certain maintenance operations as a result of the health crisis. It was made worse by the detection, during periodic inspections, of a phenomenon of stress corrosion on the welds of the safety injection system, something never before encountered on the international Pressurised Water Reactors fleet. Faced with this unexpected phenomenon EDF, which has prime responsibility for safety, decided to shut down, or extend the outage of about fifteen reactors from all plant series, in order to perform additional inspections and initiate a major investigation plan. This identified the main factors in the onset of stress corrosion and determined which reactors were most sensitive to this phenomenon, that is the four N4 type reactors and the twelve P’4 type reactors. On this basis, EDF proposed a prioritised inspection strategy to be gradually deployed on all operating reactors in the fleet. ASN considered this strategy to be appropriate and underlined that it could be revised in the light of any new knowledge. EDF decided to opt for the systematic replacement of the lines considered to be more sensitive to the phenomenon on the sixteen reactors likely to be the most severely affected, by the end of 2023. This choice is positive with regard to safety, but it does however come at a time of workload pressure in the industrial segments concerned. From left to right: Géraldine PINA JOMIR, Commissioner Jean‑Luc LACHAUME, Commissioner Sylvie CADET‑MERCIER, Commissioner Bernard DOROSZCZUK, Chairman Laure TOURJANSKY, Commissioner ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 3 Editorial by the Commission
A summer marked by an exceptional heatwave and drought which had no impact on nuclear safety The summer of 2022 was marked by an exceptional heatwave and drought which, for the first time since 2003, obliged ASN to issue resolutions waiving thermal discharge requirements and keeping five reactors in operation. This situation had no consequences for nuclear safety. Environmental monitoring was specifically strengthened so that any deterioration of the environment could be rapidly detected. The initial results of this monitoring, produced at the end of 2022, revealed no impact on the environment downstream of the facilities. According to the Intergovernmental Panel on Climate Change (IPCC), the frequency of this summer’s extreme episodes could double or even triple by the year 2050. The management of their consequences will require consolidation of scientific knowledge on the environmental consequences of water intake and discharge, along with forward planning concerning the long-term global issues. A backdrop of war in Ukraine that is undermining safety responsibilities With regard to the situation of the nuclear facilities in Ukraine, ASN together with its European counterparts conducted a joint assessment of the radiological consequences of a possible accident scenario. The work to reinforce nuclear facilities in the wake of the accident on the Fukushima Daiichi Nuclear Power Plant – NPP (Japan) led to an increase in the robustness of the Zaporizhzhia NPP (Ukraine), notably regarding the loss of off-site power risk. However, nuclear facilities are not designed to withstand acts of war. ASN considers that it is fundamental that the licensee of a facility can in all circumstances exercise its prime responsibility for safety, notably by maintaining control of the decision-making chain, and that the operators can act without being subjected to physical and psychological pressure, whether for day-to-day management of safety or in the event of a possible accident situation. ASN also recalls that Ukraine’s State Nuclear Regulatory Inspectorate of Ukraine (SNRIU), which is legally responsible for the oversight of nuclear safety, should be able to carry out its duties without hindrance. EPR commissioning which remains conditional on the final milestones to be reached In 2022, EDF devoted major efforts on the Flamanville site to carry out the final activities required prior to commissioning, to requalify the facility following the modifications and repairs made. ASN however underlines that significant work is still to be done ahead of commissioning, to carry out the final hot testing campaign on the site and also to complete the conformity justifications of the nuclear pressure equipment. At the request of ASN, EDF conducted in-depth analyses to identify the causes of the anomalies affecting the fuel and the core, which had been observed in the first EPR reactors abroad, along with their consequences for safety. EDF in particular learned the lessons regarding the design of the fuel assemblies which will be incorporated as from the first loading into the reactor, to prevent the risk of loss of fuel integrity. EDF is also examining the design of a system to prevent the hydraulic phenomena observed in the first reactors. ASN recalls that analyses are still needed to substantiate the design of certain safety-related equipment, notably the reliability of the pressuriser valves and the performance of the filters for the water reinjected from the bottom of the reactor building in an accident situation. Innovative small reactor projects which raise unprecedented safety issues In a context where the aim is decarbonised energy production, there is considerable interest worldwide in Small Modular Reactors (SMR), more particularly in those countries with no NPPs. This interest should not however overshadow the nuclear safety and security issues raised by these reactors. They should be accorded just as much importance as the decarbonised electricity generation concerns. The deployment of these small reactors for various uses could in particular lead to them being sited in industrial or built-up areas, raising specific questions such as the licensee’s capacity to control the risk of malicious acts or the proliferation of nuclear materials. Moreover, the deployment of these small reactors will not only require an industrial chain for their construction, but also the development and implementation of specific management for spent fuel and waste which do not yet exist. … 4 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 Editorial by the Commission
Finally, the level of safety to be set in the context of the strong call for international harmonisation is a subject of debate. For ASN, the level to be adopted should not simply aim to equal that of the existing generation 3 reactors (Evolutionary Power Reactors – EPR – in France) but should exploit the potential for improvement offered by this type of reactor. In 2022, ASN continued its discussions with several French companies developing SMR projects involving different technologies. At the initiative of ASN, the French, Finnish and Czech regulators and their respective technical support organisations, initiated a preliminary examination of the main safety options of the Nuward project sponsored by EDF. The conclusions of their joint evaluation will be shared with the European safety authorities under the Community SMR development initiative launched by the European Union in 2021. For ASN, this type of concrete initiative on sufficiently mature reactor designs constitutes a crucial step towards greater convergence of safety requirements for SMR. Vulnerabilities in the “fuel cycle” facilities which remain a concern for ASN The vulnerabilities found in 2021 in the “fuel cycle” facilities remain a concern for ASN despite the progress observed. The operators must continue their actions to enhance the operational robustness of their units, each being often unique in the “fuel cycle” process. In the light of this situation, ASN recalls the importance of rapidly obtaining new spent fuel storage capacity meeting the most recent safety standards, in order to address the problem of saturation of the existing capacities. Over the long term, the densification of the existing pools could not be considered an alternative to the centralised storage pool project presented by EDF. Generally speaking, spent fuel management raises questions of short-, medium- and long-term forward planning, each of which has major safety implications. ASN reaffirms that, in the short term, the question of whether or not to continue with the existing reprocessing strategy must be settled so that there are sufficient margins for safety with respect to the choice to be made. Whatever the decision taken, the consequences will have to be anticipated at least a decade in advance. This decision should be preceded by a strategic review on the future of the “fuel cycle” as a whole. In this respect, ASN suggests that a pluralistic review be undertaken of the possible futures of the “fuel cycle” and the corresponding waste, similar to that performed by the Réseau de transport d’électricité (RTE) grid utility on future energy scenarios in their “Energy Pathways 2050 study”. Decommissioning and waste retrieval and conditioning operations which must be more transparent Decommissioning is a complex operation which generally takes several decades. ASN remains vigilant with regard to the progress made for the successive milestones to be reached in the coming years and aims to enhance the visibility of these milestones. As part of its oversight of complex projects, it has set up an “observatory of waste retrieval and conditioning (RCD) and decommissioning” which it now includes in this report. This observatory presents the priority projects: for RCD, these are operations concerning waste with the highest source term or with specific safety implications; for decommissioning, this concerns the facilities for which important milestones are to be reached in the coming five to ten years. These priority projects will now be subject to a monitoring approach by project phase or milestone. An important step in the Cigéo project which opens up a period of examination during which the consultative process must continue The Cigéo project for the geological disposal of high and intermediate level long-lived waste has reached an important milestone with the submission of the creation authorisation application for the facility by the French National Radioactive Waste Management Agency (Andra), in January 2023. In 2022, ASN continued the detailed technical work prior to the submission of this file which is of considerable scope. It also played an active role in the work done under the aegis of the High Committee for Transparency and Information on Nuclear Safety (HCTISN) to define the arrangements for continued consultation on the project over the coming years: it will include workshops with the stakeholders most concerned by the project, in order to guarantee that all technical issues that raise concerns are taken into account. ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 5 Editorial by the Commission
A medical and industrial radiation protection culture that must be nurtured In 2022, the level of radiation protection remained at a satisfactory level in the medical field. This field, in which the radiation protection issues are particularly high, is under significant pressure, in particular with regard to human resources, a problem that has been exacerbated over the past two years. This has led to the implementation of new work organisations, notably multi-site or calling on outside contractors. ASN remains particularly vigilant in ensuring that these new organisations do not lead to any impairment of worker radiation protection. These unprecedented situations, such as a complete change in the medical team, must be anticipated, notably regarding change management and professional qualification procedures. Knowledge of and commitment to radiation protection requirements are well established in teams specialising in techniques using ionising radiation. However, the observations made over the past four years show that this radiation protection culture could still be improved in the field of fluoroscopy-guided interventional practices, for which staff training in patient and worker radiation protection is struggling to progress. In addition, the lessons learned from previous events are sometimes forgotten. External radiotherapy calibration errors were once again observed in 2022, despite the fact that similar events had been the subject of ASN Feedback sheets shared within the profession. The same observation can be made in other fields, such as industrial gamma radiography, where there have been further cases of poor practices in the management of source blockages. These events remind us that the radiation protection culture can never be taken for granted, but must be maintained in order to avoid the loss of the competence and experience needed to deal with unexpected or undesirable events. As part of the 2018-2022 action plan for control of the doses delivered to patients, ASN is promoting all measures liable to contribute to the implementation of the justification and optimisation principles, both for routine activities and for the introduction of technological innovations or new practices. In accordance with these principles, ASN stresses the importance and added value of external clinical peer audits, in particular in areas where the risks are high. Similarly, given the significant percentage of radiotherapy treatments in oncology and the improved survival rates, ASN recalls the need to set up follow-up registers for patients who received radiotherapy treatment, to allow improved assessment of the long-term radiation induced effects, in particular for the new practices (hypofractionation, flash-radiotherapy). Codirpa’s innovative and partnership-based approaches which are continuing The Steering Committee for the Management of the Post-Accident Phase (Codirpa) published its report to the Prime Minister containing recommendations on foodstuffs in an area contaminated by a nuclear accident around an NPP, recommendations which are backed up by field work carried out with a panel of local residents. It also continued its work on the management of post-accident situations around facilities other than NPPs, as well as its work on waste management. As part of the work done under the mandate given to Codirpa by the Prime Minister regarding the safety and radiation protection culture among the population, its members were involved on 13 October 2022 in the United Nations International Day for Disaster Risk Reduction. The aim of this was to prepare the populations for the appropriate reflexes to deal with in the event of nuclear emergency. ASN, together with the National Association of Local Committees and Commissions (Anccli) and the Institute for Radiation Protection and Nuclear Safety (IRSN), coordinated the actions of the various stakeholders within Codirpa. … 6 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 Editorial by the Commission
A new Strategic Plan(1) for ASN which takes account of a changing context The year 2022 was marked by ASN’s adoption of a new five-year Strategic Plan. After a decade that could be characterised as “post-Fukushima”, new long-term prospects are emerging for the nuclear sector. They are primarily driven by the need to accelerate the decarbonisation of the economy and by sovereignty issues. This new context is accompanied by innovations and initiatives to develop new types of reactors, which are forcing the regulators to take a fresh look at how they work together. Safety questions will lie at the heart of the debate and will need ASN to be able to explain matters and ensure that the safety and radiation protection issues are anticipated by all stakeholders, both for new constructions and for the continued operation of the reactors, management of the “fuel cycle”, or waste management, in the nuclear system taken as a whole. The new prospects will make it even more necessary for ASN to cultivate consultation and pluralism and, in addition to its oversight and regulation duties, to contribute to the development of a safety and radiation protection culture within the population. In the coming period, ASN will have to work on an unprecedented number of new facility applications in recent years, while remaining mobilised on the facilities in operation or being decommissioned, as well as on medical, industrial and transport of radioactive substances activities. 1. The 2023-2027 multi-year strategic plan is available on french-nuclear-safety.fr. In this general context, ASN has defined four points that will underpin its strategy for the next five years: 1/ state and share its short-, medium- and long-term vision of the challenges relating to nuclear safety, radiation protection and environmental protection, for the nuclear system as a whole; 2/ enhance knowledge of the risks and, together with the other stakeholders concerned, promote a safety and radiation protection culture to meet the expectations and demands of society; 3/ adapt our regulation and oversight to a new context, reaffirming our refocusing on high-stakes activities and installations and reinforcing our project management actions; 4/ and finally, make a success of the internal transformations in order to be more attractive and efficient. Faced with these challenges, ASN will need additional and appropriate resources, along with a greater capability for independent management of these resources, in a manner comparable to its counterparts abroad. n ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 7 Editorial by the Commission
REGULATION AND OVERSIGHT EQUAL TO THE CHALLENGES AHEAD Montrouge, 7 March 2023 2022 was a pivotal year for the nuclear sector in France, with the President of the Republic’s announcement of a programme to build new reactors and the desire to see the existing Nuclear Power Plants (NPPs) to continue to operate. It was more generally a pivotal year on an European scale, with an unprecedented energy crisis which completed the process of ushering in a new era for the nuclear industry. In a joint declaration, the heads of Europe’s nuclear safety regulators recalled the importance of nuclear safety in this new context. They urge all the stakeholders to fully exercise their responsibilities in this field, whether Governments, industrial firms or the regulatory authorities themselves. It is up to these latter to take balanced decisions. To this end, the in-depth technical dialogue between the French Nuclear Safety Authority (ASN), with the support of the Institute for Radiation Protection and Nuclear Safety (IRSN) when necessary, and industry, is the best guarantee for obtaining a high level of safety while taking account of industrial realities. In the current period, more than ever, it is essential for the regulation and oversight of nuclear safety and radiation protection to be independent and equal to the challenges. 8 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 EDITORIAL BY THE DIRECTOR GENERAL
The importance of nuclear safety in the current energy crisis context: a call for collective vigilance The energy crisis that we are currently experiencing in France, along with many other countries, notably in Europe, merits particular attention from the nuclear safety viewpoint. This question was discussed within the WENRA association, which brings together the heads of Europe’s nuclear safety regulators. With the growing concerns regarding the balance between electricity supply and demand, and the need to combat climate change, many countries are once again turning to nuclear energy, whether by extending the service life of existing NPPs or by building new reactors. Given the urgent need for electricity production capacity, this situation could place pressure on a number of stakeholders, in particular industry or the nuclear safety regulators, to the detriment of project quality. In a joint declaration, these regulators, including ASN, issued a number of recommendations aimed at mitigating this risk: • first of all, energy policy decisions must be taken sufficiently well in advance, taking account of the time needed to carry out industrial projects, and must be stable over time. These two aspects are important, because a lack of visibility and stability is prejudicial to safety; • then, the Governments and all the stakeholders must recognise that the licensees have prime responsibility for nuclear safety: they must not be stripped of this responsibility. It is therefore up to them to construct safety cases for the operation of their facilities or their new projects and to do so within the time allowing examination by the safety regulators in good conditions; • finally, the independence of the safety regulators is essential in this current period. They must work efficiently and issue their resolutions within an appropriate time. As we can see, each of these stakeholders has a role to play in obtaining the high level of safety that the citizens are entitled to expect as a new nuclear programme dawns. Striking the right balance in the resolution through in-depth technical dialogue As is often the case in a context of nuclear development – this was already the case at the end of the 1970s when the existing reactors were being built – questions were heard in 2022 regarding the potentially excessive level of stringency shown by the safety authorities in general, and ASN in particular. At the same time, some expressed the fear that ASN was “under pressure”. In this context, it is important to recall how ASN issues its resolutions: this is done by a Commission – in other words not by a single person – and following Olivier Gupta Editorial by the Director General ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 9
an examination process which allows broad scope for technical dialogue with industry and the nuclear activity licensees. During this technical dialogue, the possibilities for improving safety are explored in the light of what is reasonably achievable. The state of the art regarding the subject in question, including international experience feedback, is examined. Dialogue covers not only questions of nuclear safety, radiation protection and environmental protection, but also technical and industrial feasibility and the implementation lead-times. Over and above dialogue with industry, the licensees or the nuclear activity managers, the ASN resolutions process includes wide-ranging consultations. On the more important subjects, ASN may call on the opinion of its Advisory Committees of Experts (GPEs). They comprise experienced experts from French and foreign safety organisations, but also from industry, universities, as well as non-institutional experts, and allow a rich debate offering a degree of perspective with respect to the conclusions of the expert assessments – whether from ASN or the IRSN – and the arguments put forward by industry. Barring a few rare exceptions, the opinions issued by the GPEs are the result of a consensus by all members. The use of this in-depth technical dialogue is of benefit both for safety and for the development of innovative technologies, such as the Small Modular Reactors (SMR) or Advanced Modular Reactors (AMR). As this dialogue takes place well upstream of the regulatory procedures, it enables ASN to inform the project sponsor of the choices made in terms of safety, as of the first discussions concerning a new installation project. Dialogue is iterative, in other words, the industrial firm presents initial options at the preliminary design studies stage. Very early upstream in the process, it is possible to state whether such or such an option envisaged is likely to lead to a deadend, thus helping the industrial concern to avoid wasting time. This dialogue also helps the industrial firms by giving them visibility regarding the applicable baseline safety requirements. Above all, it helps ensure that safety issues are correctly taken into account at each step in the projects. A nuclear safety and radiation protection regulation and oversight organisation equal to the challenges In the current context, independent regulation and oversight based on technical dialogue is of particular importance. ASN already has a solid in-house skills base enabling it to carry out this technical dialogue. Competence – one of ASN’s four values – is acquired through high-level recruitment, a systematic initial training programme such as very few institutions possess, and career paths enabling the personnel to commit to the longhaul and develop their experience of regulation and oversight. These skills, some of which are expert assessment skills, enable ASN to issue a significant percentage of its resolutions without having recourse to its external support organisations. It is important to preserve and even reinforce this capacity because the very credibility of ASN’s resolutions is based on science and technology: the existence of a continuum between expert assessment and resolution is therefore already in reality an essential component of the existing regulation and oversight system. At the beginning of February 2023, the Government announced its intention to change the regulation organisation to reinforce its independence and the competence of ASN. At the time I am writing these lines, this proposal is still being debated by Parliament. Whatever the regulatory organisation finally chosen, the personnel at ASN and the personnel at IRSN will continue to work together, in pursuit of the same goal of protecting people and the environment. I know that I will be able to count on their commitment to continuing the mission our fellow citizens expect of them. n 10 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 Editorial by the Director General
Stress corrosion phenomenon affecting the French nuclear power reactors Impact of the summer of 2022 heatwave and drought on the nuclear power plants ASN mobilises against the backdrop of the war in Ukraine NOTABLE EVENTS 2022 PAGE 12 PAGE 14 PAGE 16 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 11
At the end of 2021, EDF informed ASN that it had discovered cracks resulting from a stress corrosion phenomenon on the lines of the Safety Injection System (SIS) of the main primary system of Civaux NPP reactor 1 (N4 type reactor), and then on that of Penly reactor 1 (P’4 type reactor). Although stress corrosion is a known phenomenon and one that had already occurred on other components of the French NPP fleet, this type of crack had not been expected on these lines. This is because they are made of stainless steel, which is considered to be resistant to this type of damage. By leading to cracking of the material on the inner wall of the lines, this phenomenon weakens them mechanically. It is thus liable to lead to rupture of the SIS or Residual Heat Removal System (RHRS) in the event of major mechanical stresses. As a result of this situation, EDF shut down its four N4 type reactors, which were considered to be the most susceptible, and brought forward the outage of several reactors in order to carry out inspections. These cracks are particularly hard to detect. In 2022, EDF developed a new inspection process, notably using ultrasounds, capable of measuring the depth of the cracks. During the first half of 2022, EDF initiated an in-depth programme of inspections and expert assessments(1) on the various types of reactors(2). This programme enabled it to identify the geometry of the lines and the thermomechanical stresses to which they are subjected as being the main factors liable to influence the appearance of stress corrosion and thus identify the reactors most susceptible to the phenomenon. EDF defined an inspection strategy, which was validated by ASN on 26 July 2022. Stress corrosion phenomenon affecting the French nuclear power reactors Civaux Blayais Golfech Tricastin Cruas-Meysse Saint-Alban Bugey Nogent-sur-Seine Cattenom Chooz Gravelines Penly Dampierre-en-Burly Belleville-sur-Loire Flamanville Paluel Chinon Saint-Laurent-des-Eaux 2 2 4 2 4 2 1 6 4 2 4 2 4 2 2 900 MWe Reactor capacity Number of reactors per site 1,300 MWe 1,450 MWe 1,600 MWe P4 P4 P’4 CPY CPY P’4 P’4 P’4 P4 2 P’4 CP0 CPY CPY 4 CPY 4 CPY 4 CPY N4 N4 X LOCATIONS OF NPP REACTORS IN FRANCE IN 2023 Civaux Blayais Golfech Tricastin Cruas-Meysse Saint-Alban Bugey Nogent-sur-Seine Cattenom Chooz Gravelines Penly Dampierre-en-Burly Belleville-sur-Loire Flamanville Paluel Chinon Saint-Laurent-des-Eaux 2 2 4 2 4 2 1 6 4 2 4 2 4 2 2 900 MWe Reactor capacity Number of reactors per site 1,300 MWe 1,450 MWe 1,600 MWe P4 P4 P’4 CPY CPY P’4 P’4 P’4 P4 2 P’4 CP0 CPY CPY 4 CPY 4 CPY 4 CPY N4 N4 X he presence of stress corrosion cracking was the major event encountered by the French Nuclear Power Plant (NPP) fleet in 2022. This unexpected event led EDF to mobilise significant resources to identify the causes and carry out repairs. ASN considers that EDF was reactive and responsible in response to this event with significant safety implications and affecting a large percentage of its reactors. This situation illustrates the electricity supply problems that could arise in the event of a generic problem concerning several reactors on the same time. As early as 2013, ASN had underlined the need for sufficient margins in the electrical system in order to deal with an event of this type. T 12 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 Notable events 2022
For the latest information on the subject: asn.fr/l-asn-controle/corrosion-sous-contrainte The Flamanville EPR reactor is also undergoing analysis and checks with regard to this issue. With the technical support of the IRSN, ASN will remain focused on this dossier in 2023 and will closely monitor the results of the checks carried out by EDF. It will examine any EDF strategy changes that could result from this. 1. More than 110 metallurgical expert assessments have been performed in the laboratory, after cutting of the welds on several reactors. Further assessments are to be carried out in order to consolidate the data acquired. 2. The reactors are classified according to their model – or “plant series” – and according to the electrical power they deliver: 900 Megawatts electric (MWe), 1,300 MWe and 1,450 MWe. There are 32 reactors of the 900 MWe type: 4 reactors of the CP0 plant series (4 at Bugey) and 28 reactors of the CPY series (4 at Tricastin, 6 at Gravelines, 4 at Dampierre-en-Burly, 4 at Le Blayais, 4 at Chinon, 4 at Cruas-Meysse and 2 at Saint-Laurent-des-Eaux). The 20 reactors of 1,300 MWe can be subdivided into two plant series: the P4 series with 8 reactors (4 at Paluel, 2 at Saint-Alban and 2 at Flamanville) and the P’4 series with 12 reactors (2 at Belleville-sur-Loire, 4 at Cattenom, 2 at Golfech, 2 at Nogent-sur-Seine and 2 at Penly). There are 4 reactors of the 1,450 MWe type, in the N4 plant series (2 at Chooz and 2 at Civaux). 3. With the exception of those of Cattenom NPP reactor 4, on which the expert assessments carried out in 2022 revealed no stress corrosion cracks. EDF will define the strategy concerning this reactor following the inspections scheduled for 2023. The second half of 2022 was devoted to repairing several reactors and completing the investigations on those most susceptible. This problem justified close monitoring by ASN, in close collaboration with the Institute for Radiation Protection and Nuclear Safety (IRSN), which enabled rapid and informed decisions to be made. ASN considers that the choices made by the licensee are appropriate, whether regarding the reactor outages or the in-depth investigations. ASN considers that EDF acted as a responsible licensee given the safety issues related to the cracks revealed on equipment for which the integrity must be guaranteed. ASN carried out more than 40 dedicated inspections. These inspections notably took place as part of the lines verification or replacement operations in the EDF engineering departments, in the NPPs and at the subcontractors. The High Committee for Transparency and Information on Nuclear Safety (HCTISN), the Local Information Committees (CLIs) and, more broadly, the public – through information meetings and notices – were informed of the important stages of this dossier. ASN held regular discussions with its foreign counterparts, some of whom intend to request inspections on this same subject. The reactors of the French NPP fleet will be inspected using the new inspection system developed by EDF, by the end of 2025. In 2023, EDF will carry out preventive replacement of the areas of interest on the susceptible lines of the P’4(3) type reactors. ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 13 Notable events 2022 Preparation of the line before installation on the auxiliary system Welding training
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