LES ACTIVITÉS NUCLÉAIRES : RAYONNEMENTS IONISANTS ET RISQUES POUR LA SANTÉ ET L’ENVIRONNEMENT In view of the conclusions of the public debate of 2019, ASN and the DGEC have decided to change the governance of the PNGMDR. The 5th edition was drawn up by the Ministry of Energy Transition, based in particular on the work of a “Guidelines Commission”. Introduced by the resolution of 21 February 2020, this Commission is chaired by an independent qualified personality and brings together, in addition to the legacy members of the pluralistic working group mentioned in chapter 2, elected officials and representatives of the regional authorities. This Commission gave opinions on various major subjects relating to the management of radioactive waste (management of VLL/LLW-LL waste, management of radioactive materials, etc.). ASNR participates actively in the Guidelines Commission – albeit without voting rights – to provide its guidance on the safety and radiation protection issues. Implementation of the plan is followed up at periodic meetings of the PNGMDR working group jointly chaired by ASNR and the DGEC. Three meetings of the PNGMDR working group, also known as the “Technical Commission”, were held in 2025. In 2020 and 2021, ASN moreover assessed the studies submitted within the framework of the PNGMDR 2016-2018. For the preparation of the 5th PNGMDR, ASN has thus issued seven opinions on the radioactive material and waste management routes in which it sets out a number of recommendations. In addition, on 9 November 2021, ASN issued a favourable opinion for the 5th PNGMDR, on condition that it is supplemented with a study of worst-case operating scenarios for the “fuel cycle”, an assessment of the impact on the nuclear facilities of continuing the reprocessing of spent fuel beyond 2040 or not, the inclusion of measures relative to the safety of HL/ILW-LL waste management and the management of waste necessitating specific work, such as tritiated waste, and better assessing the recyclability of certain radioactive materials. Lastly, on 23 June 2022 ASN issued a favourable opinion on the draft Decree and Order establishing the requirements of the 5th PNGMDR, subject to the integration of the modifications proposed in this opinion. These texts and the 5th PNGMDR covering the 2022‑2026 period were published on 9 December 2022. Prior to the preparation of the 6th National Radioactive Material and Waste Management Plan (PNGMDR), ASNR, in its opinion 2025AV-003 of 4 March 2025, set out its position on the major issues that must structure the actions of the plan, in particular concerning the management of VLL and LLW-LL waste, spent fuel and waste that will be produced by future reactors. It also considers that particular attention should be paid to the management of medical waste, which presents new challenges, and waste that is currently without a disposal route, such as certain used radioactive sources. From 10 October 2025 to 10 February 2026, the National Commission for Public Debate (CNDP) organised a public debate to draw up the 6th edition of the plan. This debate, in which ASNR took part, aimed to inform future decisions by taking account of public opinion. At the end of the debate, the plan’s project owner will make a commitment on the contributions to be retained for the further development of the 6th PNGMDR. 1.3 Long-term management of waste – existing or projected disposal facilities 1.3.1 – Very low-level waste Very low-level waste (VLLW) comes essentially from the operation, maintenance and decommissioning of nuclear facilities. It consists mainly of inert waste (rubble, earth, sand) and metal waste. Its specific activity is generally less than 100 Bq/g. The Cires includes a VLL waste disposal facility. This facility, which has ICPE status, has been operational since August 2003. At the end of 2024, Cires held about 486,000 m3 of VLL waste, which represents 51% of its authorised regulatory capacity. According to the national inventory produced by Andra, the quantity of VLL waste resulting from decommissioning of the existing nuclear facilities will be about 2,200,000 m3. According to current forecasts, the centre could be filled to maximum capacity by 2045. In April 2023, Andra submitted a request to increase the authorised capacity of this disposal facility to 950,000 m3 (Acaci project), on the same surface area (as opposed to the 650,000 m3 authorised at present). Andra obtained the Prefectural Order necessary for deployment of this project in July 2024. In its opinion 2020-AV-0356 of 30 June 2020 on the management of VLL waste, ASN calls for the continuation and extension of the work undertaken in the 2016-2018 edition of the PNGMDR with the aim of improving current management methods and developing complementary management solutions which remain to be devised and implemented. ASNR reaffirms that, as a general rule, VLL waste management must continue to be based on the place of origin of the waste and guarantee its traceability, thanks to specific routes, from production through to disposal, with the exception of metallic VLL waste that is to be recycled, as stated in the resolution of 21 February 2020. The reuse of certain types of waste, the volumes of which will be significant, is encouraged, consistently with the waste management hierarchy defined in the Environment Code; ASNR is particularly in favour of the development of a facility for processing recyclable metal materials, subject to the implementation of a specific monitoring framework for this activity. In 2021, the Government worked on setting up this regulatory framework. In its opinion 2021-AV-0380 of 11 May 2021, ASN expressed its views on the draft regulations. In February 2022, the Government published the regulatory framework for issuing waivers to authorise the recycling of weakly radioactive metal substances after melting and decontamination. Such a waiver will be granted by ministerial order after consulting the public and obtaining ASNR’s opinion. In this context, EDF plans building and operating a facility for recycling VLL metals baptised “Technocentre” on the site of the Fessenheim NPP currently being decommissioned. This facility will have ICPE status. A public debate on this EDF project was held between October 2024 and February 2025, with submission of the construction application planned in 2026. ASNR considers it necessary for all the stakeholders, particularly the representatives of the regions concerned or likely to be concerned, to be more closely involved in the defining of the VLL waste management solutions. It recommends that the studies for putting in place additional disposal facilities, whether centralised or decentralised, be continued and that the government should clarify Andra’s responsibility in this respect. Consistently with the abovementioned ASN opinion, the 5th PNGMDR contains the following objectives concerning the management of VLL waste: ∙continue the studies aiming to deploy new centralised and decentralised storage capacities for VLL waste; ∙continue looking into the recycling of VLL waste, particularly defining the conditions of implementation of metallic waste recycling; ∙define VLL waste management scenarios, cast light upon their environmental, regional, health and safety issues, and use this to establish an overall management strategy; ∙refine the perspectives for the production of VLL waste from the decommissioning of the nuclear installations, by explicitly identifying the waste associated with the clean-out of structures and contaminated soils. 362 ASNR Report on the state of nuclear safety and radiation protection in France in 2025
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