02 03 04 05 06 07 08 09 10 11 12 13 14 AP concerning the activity of the waste sent to the CSA, to improve its organisational arrangements to guarantee the allocation of sufficient resources to radioactive waste management, and to present the most appropriate process for the treatment of used steam generators. Finally, the spent control rod cluster guide tubes from the EDF fleet shall be disposed of directly in the CSA, following EDF’s decision to abandon the Cyclife France reprocessing project in the Centraco facility, in order to reduce the volume of waste. The issues and challenges The main issues relating to the EDF waste management strategy concern: ∙The management of legacy waste. This mainly concerns structural waste (graphite sleeves) from the GCR fuels. This waste could be disposed of in a repository for LLW-LL waste (see point 1.3.4). It is stored primarily in semi-buried silos at SaintLaurent-des-Eaux. Graphite waste is also present in the form of stacks in the GCRs currently being decommissioned. In the context of the PNGMDR 2016-2018, EDF conducted a study of the reliability of the activity predictions for this waste and submitted its conclusions in December 2019. Further to requests from ASN, further information was provided in 2023. This information is subject to review by ASN. ∙The changes linked to the “fuel cycle”. EDF’s fuel use policy (see chapter 10) has consequences for the “fuel cycle” installations (see chapter 12) and for the quantity and nature of the waste produced. ASN issued an opinion on the coherence of the “nuclear fuel cycle” in October 2018 (see chapter 12). 3 Management of mining residues and mining waste rock from former uranium mines Uranium mines were worked in France between 1948 and 2001, producing 76,000 tons of uranium. Some 250 sites in France were involved in exploration, extraction and processing activities. The sites were spread over 27 départements in the eight regions: Auvergne-Rhône-Alpes, Bourgogne-Franche-Comté, Bretagne, Grand Est, Nouvelle-Aquitaine, Occitanie, Pays de la Loire and Provence-Alpes-Côte d’Azur. Ore processing was carried out in eight plants. The former uranium mines are now almost all under the responsibility of Orano. The working of uranium mines produced two categories of products: ∙mining waste rock, that is to say the rocks excavated to gain access to the ore. The quantity of mining waste rock extracted is estimated at about 170 million tonnes; ∙static or dynamic processing tailings, which are the products remaining after extraction of the uranium from the ore. In France, these tailings represent 50 million tonnes spread over 17 disposal sites. These sites are ICPEs and their environmental impact is monitored. Redevelopment of the uranium processing tailings disposal sites consisted notably in placing a solid cover over the tailings to provide a geochemical and radiological protective barrier to limit the risks of intrusion, erosion, dispersion of the stored products and the risks of external and internal exposure of the neighbouring populations. The regulatory context The uranium mines, their annexes and their conditions of closure are covered by the Mining Code. The disposal facilities for radioactive mining tailings are governed by section 1735 of the ICPE classification system. The mines and the mine tailings disposal sites are not subject to ASN oversight. In the specific case of the former uranium mines, an action plan was defined by Circular 2009-132 of 22 July 2009 of the Minister responsible for the environment and the Chairman of ASN, along the following work lines: ∙monitor the former mining sites; ∙improve the understanding of the environmental and health impact of the former uranium mines and their monitoring; ∙manage the mining waste rock (better identify the uses and reduce impacts if necessary); ∙reinforce information and consultation. PNGMDR: The long-term behaviour of the sites The studies submitted for the PNGMDR since 2003 have enhanced knowledge of: ∙the dosimetric impact of the mine tailing disposal areas on man and the environment, in particular through the comparison of data obtained from monitoring and the results of modelling; ∙the evaluation of the long-term dosimetric impact of the waste rock stockpiles and waste rock in the public domain in relation to the results obtained in the context of the Circular of 22 July 2009; ∙the strategy chosen for the changes in the treatment of water collected from former mining sites; ∙the relation between the discharged flows and the accumulation of marked sediments in the rivers and lakes; ∙the methodology for assessing the long-term integrity of the embankments surrounding tailings disposal sites; ∙transport of uranium from the waste rock piles to the environment; ∙the mechanisms governing the mobility of uranium and radium within uranium-bearing mining tailings. Further to ASN opinion 2021-AV-0255 of 9 February 2016, and in the context of the PNGMDR 2016-2018, Orano submitted 11 studies between January 2017 and February 2020 to supplement the studies submitted prior to this. Based on this, ASN issued an opinion on 4 February 2021 to review the situation on these subjects. Consequently, ASN opinion 2021-AV-0255 of 9 February 2016 specifies the studies still to be carried out to meet the challenges associated with the former mining sites and reiterated above. These studies may lead to the performance of work such as removal of the mining tailings from public land, reinforcement of the structures encircling the disposal sites, and improving preservation of the memory. This opinion also recommends continuing the work of the two technical working groups concerning: ∙Maintaining the functions of the structures encircling the uranium ore treatment residue disposal areas. The final report on maintaining the functions of the structures encircling the uranium ore treatment residue disposal areas published on 30 January 2023, was updated on 12 November 2024. This update does not call into question the recommendations, methods and conclusions indicated in the final report published in 2023. From now on, this report shall be taken into consideration by Orano in order to update its assessments of the stability of its structures encircling the mining residue disposal sites. The study concerning the Bernardan site submitted in October 2023 is currently undergoing an expert assessment to verify Orano’s integration of the report’s methodologies and recommendations. With regard to the assessment of the Montmassacrot site, in November 2024 ASN asked Orano for additional information on the study submitted in October 2021 in order to demonstrate the short- and long-term stability of the structure. ∙Management of the water from the former uranium mining sites. With the aim of reducing the overall impact (radiological and chemical) of releases on people and ecosystems, the special technical working group finalised in June 2024 the drafting of the methodology guide for drafting the multi-stakeholder, multi-criterion analysis methodology. This is a decision-making aid guide regarding the questions of maintaining, shutting down or modifying ASN Report on the state of nuclear safety and radiation protection in France in 2024 389 01 Radioactive waste and contaminated sites and soils 15
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