LES ACTIVITÉS NUCLÉAIRES : RAYONNEMENTS IONISANTS ET RISQUES POUR LA SANTÉ ET L’ENVIRONNEMENT operation of successive sections of a disposal facility, or to reassess previous choices and change the management solutions. Reversibility is materialised by the progressive nature of the construction, the adaptability of the design and the operational flexibility of placing radioactive waste in a deep geological repository which can integrate technological progress and adapt to possible changes in waste inventory following a change in energy policy. It includes the possibility of retrieving waste packages from the repository under conditions and over a time frame that are consistent with the strategy for operation and closure of the repository”. In its opinion 2016-AV-0267 of 31 May 2016 relative to the reversibility of the deep geological disposal of radioactive waste, ASN had considered that the principle of reversibility implied a requirement for adaptability of the facility and retrievability of the packages during a period governed by law. The Decree of 9 December 2022 relative to the provisions of the PNGMDR 2022-2026 details certain principles applicable to Cigéo, and more particularly those set out in Articles D. 542-91 and D. 54292 of the Environment Code. These specify that the inventory to be adopted by Andra for the studies and research conducted for the design of the Cigéo disposal facility shall include a reference inventory and a reserve inventory. The reference inventory takes account of all HLW and ILW-LL waste already produced and to be produced by the existing nuclear facilities (nuclear power plants, research centres, etc.), as well as that to be produced by the authorised nuclear facilities (Flamanville EPR, ITER, Jules Horowitz experimental reactor), assuming an average reactor operating life of 50 years. The reserve inventory takes into account some uncertainties, particularly those associated with energy policy changes, and gives rise to adaptability studies aimed at assessing the extent to which the facility’s design margins would make it possible to accommodate these uncertainties without calling into question the fundamental hypotheses of the project as set out in the Creation Authorisation Decree (DAC) application (see Highlight No. 2). These studies have been extended to include waste from future reactors planned for construction in France (in particular the first six EPR 2 reactors). This waste would be liable to be included in the reserve inventory. Underground laboratory of Meuse/Haute-Marne Studies on deep geological disposal necessitate research and experiments in an underground laboratory. Andra has been operating such an underground laboratory within the Bure municipality since 1999. 7. Article R. 593-14 of the Environment Code stipulates that “any person planning to operate a BNI can, before initiating the creation authorisation procedure, ask ASN for an opinion on all or part of the options it has retained to ensure protection of the interests mentioned in Article L. 593‑1. ASN, in an opinion issued and published in the conditions and forms determined by itself, specifies to what extent the safety options presented by the applicant are such as to prevent or limit the risks for the interests mentioned in Article L. 593.1, in view of the technical and economic conditions prevailing at the time. ASN may define the additional studies and justifications that will be required for a prospective creation authorisation application. It can set a validity period for its opinion. This opinion is communicated to the applicant and to the Minister responsible for nuclear safety.” 8. The follow-up letters are available on the reglementation-controle.asnr.fr under the headings “ASN informs”, “Educational files”, “Management of radioactive waste”, “French National Radioactive Material and Waste Management Plan”, “PNGMDR 2016-2018”. In the context of the studies on the deep geological disposal, ASNR issues recommendations concerning the research and experiments conducted in the laboratory, and by random sampling during follow-up inspections ascertains that they are carried out using processes that guarantee the quality of the results. Technical reviews Pursuant to the Act of 30 December 1991, and then pursuant to the Act of 28 June 2006 and the PNGMDR, Andra has carried out studies and submitted reports on deep geological disposal. These reports have been examined by ASN – referring in particular to the Safety Guide of 2008 – and it has issued an opinion on them. ASN has thus more specifically examined the reports submitted by Andra in 2005 and 2009. It issued opinions on these reports on 1 February 2006 and 26 July 2011. Andra subsequently submitted various files to ASN presenting the progress of the studies and work carried out. ASN thus issued a position statement: ∙in 2013, on the documents produced between 2009 and 2013 – the year of the public debate, and on the intermediate design milestone at the outline stage presented by Andra in 2012; ∙in 2014, on the safety components of the closure structures and the expected content of the DOS for the facility; ∙in 2015, on the control of operating risks and the cost of the project; ∙in 2016, on the components development plan; ∙in 2018, on the Cigéo DOS; ∙in 2022, on the seismic hazard to be considered in the design of the facility. The Cigéo Safety Options Dossier The filing of a DOS marks the start of a regulatory process(7). ASN received the DOS for Cigéo in April 2016. At the end of the technical review phase, the ASN draft opinion underwent public consultation and ASN issued its opinion on 11 January 2018. ASN also sent a follow-up letter giving recommendations on the safety options to prevent or limit the risks and asked Andra for additional studies and justifications (corrosion phenomena, low-pH concretes, representativeness of the hydrogeological model, surveillance strategy, etc.). The demands made in this letter took account of the suggestions and comments received through the public consultation. The examination of the Cigéo DOS highlighted several issues relating to specific aspects (architecture, definition of hazards, post-accident management, etc.). Among these issues, ASN pointed out that the management of bituminised waste required special attention. Particular case of bituminised waste The management of bituminised waste is also monitored under the PNGMDR, 2016-2018, which requested several studies relative to the characterisation of these waste packages, their transport conditions and treatment possibilities. In 2019, ASN made additional information requests(8) to the waste producers and to Andra further to the examination of the study submitted under Article 46 of the Order of 23 February 2017. The requests focus more specifically on the effect of self-irradiation on the thermal behaviour of the bituminised waste packages, on the thermal reactivity of the bituminised coatings, on the long-term swelling considering the long-term behaviour of the Cigéo repository and on the design changes to control the risks associated with the disposal of packages of bituminised waste. The Minister responsible for energy and ASN moreover wanted an independent multidisciplinary assessment drawing on international Experiments in the Meuse/Haute-Marne underground laboratory drifts. 366 ASNR Report on the state of nuclear safety and radiation protection in France in 2025
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