ASN and ASND consider that CEA’s facility decommissioning strategy and its updating of the waste and material management strategy are the result of an in-depth review and analysis. CEA’s decommissioning and materials and waste management strategies present considerable uncertainties, particularly concerning the availability of support facilities. These strategies rely on the sharing of resources between its research centres and are based on the use of facilities of which some are at the project stage while others are undergoing commissioning, being refurbished, waiting for a periodic safety review or are authorised to continue operation for a limited period of time. Most of them are unique, with no obvious operational alternative in the event of failure. All these factors constitute vulnerabilities in CEA’s strategy, particularly the support facilities and means necessary for the post-operational clean-out & decommissioning and WRP projects, for which the availability requirement appears to be particularly critical given that they fulfil functions that no other CEA facility is able to perform. ASN and ASND have therefore addressed several demands to the CEA with the aim of limiting these vulnerabilities, consolidating its strategy and detailing the operations schedule. They demanded that CEA make regular progress reports on the decommissioning and waste management projects, and ensure regular communication with the public, applying procedures appropriate to the nature of the facilities, civil or defence. ASN, ASND and CEA have agreed to set up regular monitoring of these operations, through progress indicators in particular and the periodic updating of CEA’s major safety commitments. Monitoring implementation of CEA’s waste management strategy ASN has observed the difficulty CEA has in fully controlling the challenges associated with these projects, which must be carried out simultaneously and concern as much the management of the decommissioning operations as the operation of the waste management support facilities. It will continue to be particularly attentive to the management and monitoring of these projects. ASN nevertheless underlines the good forward-planning of the work necessary to avoid saturating some of the waste storage capacities, such as phase 3 of the Cedra facility, and the goodness of fit of the blueprint for transport operations with CEA’s storage capacities. 2.4 Orano’s waste management strategy and its assessment by ASN The spent fuel reprocessing and recycling plant at the La Hague site presents major radioactive waste management issues. The waste on the La Hague site comprises on the one hand waste resulting from reprocessing of the spent fuel, which generally comes from nuclear power plants but also from research reactors, and on the other, waste resulting from operation of the various facilities on the site. Most of this waste remains the property of the licensees - whether French or foreign - who have their spent fuel reprocessed. French waste is directed to the management routes described earlier, whereas foreign waste is sent back to its country of origin. On the Tricastin site, Orano also produces waste associated with the front-end activities of the “cycle” (production of nuclear fuel), essentially contaminated by alpha emitters. In 2016, Orano submitted a file to ASN and ASND, which was supplemented in 2017, presenting its decommissioning and waste management strategy for the group’s French facilities, and its practical implementation on the La Hague and Tricastin sites. Moreover, Orano submitted general and particular commitments for the La Hague and Tricastin sites in 2018. ASN issued a position statement on the strategy on 14 February 2022. Orano has sent information to ASN since 2022 in response to ASN’s various requests in its letter of 14 February 2022. These elements are currently being reviewed by ASNR. The issues and challenges The main issues relating to the management of waste from the licensee Orano are: ∙The safety of the legacy waste storage facilities. On the La Hague site, the facilities dedicated to legacy waste retrieval, packaging and storage have to be designed, built and then commissioned. These projects meet with technical difficulties which can make it necessary to adjust deadlines set by ASN (see chapter 14). In addition, the on-site radioactive waste storage capacities must be planned for with conservative margins in order to prevent them reaching saturation. The legacy waste stored on the Tricastin site necessitates a large amount of work to characterise it and find management solutions. The storage conditions in some of the Tricastin site facilities do not meet current safety requirements and must be improved. ∙The definition of solutions for waste packaging, in particular the legacy waste. The methods of packaging radioactive waste intended for a projected disposal BNI must receive the prior approval of ASN pursuant to Article 6.7 of the Order of 7 February 2012 (see point 2.2.2). Keeping control of the packaging deadlines is a particularly important aspect, which requires the development of characterisation and R&D programmes to demonstrate the feasibility and compatibility of the chosen packaging processes with the subsequent management steps and to identify sufficiently early the risks that could significantly affect the associated project. If necessary, when the feasibility of the defined packaging cannot be determined within times compatible with the prescribed deadlines, the licensee must plan for an alternative solution, including in particular interim storage areas allowing the retrieval and characterisation of the legacy waste as rapidly as possible, while guaranteeing the absence of any counter- action that could jeopardise the safety of their storage, the final packaging and the subsequent management phases of the resulting packages. Within the framework of the WRP operations, Orano is examining packaging solutions that necessitate the development of new processes, particularly for the following ILW-LL waste: ∙the radioactive sludge from the La Hague STE2 facility; ∙ the alpha-emitting technological waste which comes primarily from the La Hague and Melox (Gard département) plants and is not suitable for above-ground disposal. For other types of ILW-LL waste resulting from the WRP operations, Orano is examining the possibility of adapting existing processes (compaction, cementation, vitrification). Some of the associated packaging baseline requirements are currently being examined by ASN. 2.5 EDF’s waste management strategy and its assessment by ASN The radioactive waste produced by EDF comes from several distinct activities. It mainly comprises waste from the operation of the NPPs, which consists of activated waste from the reactor cores, and waste from their operation and maintenance. Some legacy waste and waste resulting from ongoing decommissioning operations can be added to this. EDF is also the owner, for the share attributed to it, of HLW and ILW-LL waste resulting from spent fuel reprocessing in the Orano La Hague plant. Activated waste This waste notably comprises control rod assemblies and poison rod assemblies used for reactor operation. This is ILW-LL waste that is produced in small quantities. At present this waste is stored in the NPP fuel storage pools pending transfer to the Iceda facility. Operational and maintenance waste Some of the waste is processed by melting or incineration in the Centraco facility, in order to reduce the volume of ultimate waste. The other types of operational and maintenance waste are packaged on the production site then shipped to the CSA or Cires repositories for disposal (see points 1.3.1 and 1.3.2). This waste contains beta and gamma emitters, and few or no alpha emitters. At the end of 2013, EDF submitted a file presenting its waste management strategy. After examining this file, ASN in 2017 asked EDF to continue its measures to reduce the uncertainties 388 ASN Report on the state of nuclear safety and radiation protection in France in 2024 Radioactive waste and contaminated sites and soils
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