LES ACTIVITÉS NUCLÉAIRES : RAYONNEMENTS IONISANTS ET RISQUES POUR LA SANTÉ ET L’ENVIRONNEMENT These resolutions set the next steps required for the change of decommissioning strategy, notably the defining of a robust strategy for managing graphite waste that is independent of disposal outlet availability, the decommissioning operations to continue over the next few years and the information to be transmitted to ASNR to check effective implementation of the strategy. ASNR considers that it is appropriate for EDF to develop a graphite industrial demonstrator (commissioned in 2022 in Chinon) before decommissioning the reactor pressure vessels, but decommissioning of the various reactors must nevertheless begin within reasonable time frames in view of the obligation for dismantling to be carried out as rapidly as possible. In 2025, ASNR carried out an inspection to check the compatibility of the decommissioning strategy presented by EDF with this objective (see highlight No. 4). In 2026, the Advisory Committee of Experts for Decommissioning (GPDEM) will meet to give its opinion on the decommissioning files submitted in 2022 by the licensee, EDF. The Saint-Laurent-des-Eaux site also includes BNI 74 (the SaintLaurent silos). This facility is used for storage of graphite sleeves arising from the operation of Gas-Cooled Reactors (GCRs). Although EDF submitted a decommissioning file for the facility in 2022, the review of the file has now been suspended in view of the changes EDF wishes to make to it. ASNR closely monitoring the situation to ensure that the construction of the facilities for the retrieval and removal from storage of this graphite waste is not delayed. The other EDF facilities that have been shut down (notably Chooz A, the Irradiated Materials Plant (AMI) at Chinon, EL4-D and Superphénix) are currently being decommissioned. ASNR has noted increasing delays in the decommissioning of AMI Chinon and Chooz A, due to technical or organisational difficulties. ASNR will remain vigilant with regard to the implementation by the licensee of all the measures needed to ensure schedule compliance, under satisfactory conditions of safety and radiation protection. More generally, a large amount of decommissioning work will be carried out by EDF over the next few years. EDF has decided to adjust its industrial programme to be able to absorb this sharp increase in work and to incorporate experience feedback from the work carried out. This adjustment is reflected in the postponement of certain decommissioning operations. ASNR will take care to ensure that this smoothing of the industrial programme is justified and that regulatory deadlines are met. EDF has also made progress in defining the margins of the decommissioning schedules, which is satisfactory. 4.2 Assessment of Orano’s decommissioning strategy The decommissioning of old installations is a major challenge for Orano, which has to conduct several large-scale decommissioning projects over variable time scales (UP2-400 facility at La Hague, Eurodif Production plant, Comurhex plant, individual facilities of the DBNI at Pierrelatte, etc.). Implementation of decommissioning is closely linked to the legacy radioactive waste management strategy, given the quantity and the non-standard and hard to characterise nature of the waste produced during the prior operations phase and during the ongoing decommissioning operations. Furthermore, Orano must carry out special WRP operations in old waste storage facilities. The deadlines for completion have been stipulated by ASN, particularly for the La Hague site. Completion of these WRP operations determines the progress of decommissioning on the UP2-400 plant, as WRP is one of the first steps of its decommissioning. The WRP work is of particular importance given the large inventory of radioactive substances present and the age of the facilities in which they are stored, which do not generally meet current safety standards. In addition, WRP projects are considerably complex owing to the interactions with the plants in operation on the site. Further to the difficulties observed in the examination of files relating to the WRP and decommissioning operations on the Orano La Hague site and failure to perform the operations within the prescribed deadlines, ASN and Orano agreed to set up regular monitoring in order to anticipate and address any blocking situations and determine practical measures to be put into place to accomplish the WRP and decommissioning operations in the shortest time frame possible. In June 2016, at the request of ASN and the Defence Nuclear Safety Authority (ASND), Orano submitted its decommissioning and waste management strategy. The file also includes the application of this strategy to the La Hague and Tricastin sites. In its position statement letter of 14 February 2022, ASN underlined the progress made by the licensee in taking on-board the immediate dismantling objectives and running major WRP projects. ASNR considers that the methodology for calculating the margins of the decommissioning schedule put in place by Orano is likely to guarantee better control of the deadlines of the various decommissioning projects. However, after ten years of implementation of Orano’s decommissioning strategy, ASNR deplores the fact that the decommissioning completion dates for HIGHLIGHT No.4 Checking the compatibility of the GCR decommissioning strategy submitted by EDF with the requirement for immediate dismantling The principle of immediate dismantling has been enshrined in law since 2015 (see section 1.2.1). With decommissioning projects spanning several decades, given their complexity, the licensee’s organisation needs to be sufficiently robust and mature to ensure decommissioning “within the shortest time frame possible under economically acceptable conditions”. In 2025, ASNR carried out an inspection of EDF’s organisation for GCR decommissioning projects. The purpose of this inspection was to check that the licensee’s organisation is compatible with compliance with the principle of immediate dismantling. It also consolidated and supplemented the in-depth inspection of the industrial demonstrator and decommissioning projects for Chinon A2 carried out in 2020. The follow-up letter to the inspection is available on the ASNR website. During this inspection, the project management process developed within EDF appeared to be robust, with appropriate planning management. The inspectors also highlighted the clarity of EDF’s industrial policy and the efficiency of the organisation between EDF and its decommissioning subsidiaries. Some points requiring particular attention were noted. They are particularly critical in the context of decommissioning operations spanning several decades, where the conservation of memory is a major challenge. They concern the traceability of decisions taken on the project as well as the formalisation of learning from acquired knowledge. In addition, improvements are expected in the updating and monitoring of project-related risks, which are important to ensure the success of these decommissioning operations. This inspection enabled ASNR to adopt a position on the first milestones in the GCR decommissioning strategy, for which numerous technical elements and consolidated scenarios are still being developed and will be defined in the progress report due in 2028. Other inspections on this topic will be scheduled by ASNR in the coming years to check that the points requiring vigilance have been taken into account and that the licensee’s commitment continues. ASNR Report on the state of nuclear safety and radiation protection in France in 2025 351 11 13 12 A / Z 10 09 08 01 05 02 06 03 07 04
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