The Public Health Code requires that industrial activities which are likely to enhance natural ionising radiation must conduct "exposure supervision [of persons] and a dose estimation". The order of 25 May 2005, concerning professional activities using raw materials containing NORM and which are not used owing to their radioactive properties, lists the professional activities concerned by the provisions of this order and within the next 2 years will lead to a precise inventory of the industries concerned throughout France. However, it should take somewhat longer to complete the assessment required by the order of the doses received by workers exposed to this radiation, as well as the population.

These activities are likely to generate waste which has concentrated the natural radioactivity and may therefore trigger the radiation alarm at the entrance to technical landfills.

For some of these activities, and in particular those leading to mining treatment residues (mines operated for extraction of rare earths, phosphate ore treatment residues produced by the superphosphated fertiliser industry, etc), the same problem can occur as for uranium mine processing residues (see point 3.3.1) concerning the large quantities of waste produced, often managed on-site, and for which there is today no appropriate disposal channel.

Some of these installations are not currently active, however most of them are (or were) regulated by part 1 of book V of the Environment Code. The ASN is cooperating with the relevant classified installations inspection services and in particular is taking part in the working group dealing with the acceptability of enhanced natural radioactivity waste, for which the activity level and concentration could be neglected from the radiation protection standpoint in landfills. The ASN aims to ensure that this waste is sorted and packaged as far upstream as possible, so that it is always routed to the appropriate channel. It should be noted that given the absence of a long-lived low level waste repository, the only channel currently available for the most active waste is interim storage.

In 2004, the ASN asked the Robin des Bois association to conduct a study into the effects of natural occurring radioactivity enhanced by human activities, and the correspondingly polluted sites in France. From 2004 to about mid-2005, the Robin des Bois association therefore sent out about 2300 questionnaires (including reminder letters) to the companies or administrations concerned by TENORM (technologically enhanced naturally-occurring radioactive materials). Each activity sector concerned had a specific questionnaire. These areas involve phosphates, monazite, rare earths, ilmenite, zirconium (refractories, abrasives, sanding, ceramics, foundries), ferrous and non-ferrous metals, mineral and spring waters, drinking water, spas, wells, geothermal activities, oil and gas, coal (combustion ashes), wood (combustion ashes) and papermaking. Finally, a standard questionnaire was also sent out to companies managing class I and II landfills in order to define a typology of the events which triggered the access portal detectors in 2004. These questionnaires are part of the precautionary approach designed to identify the potential sources of exposure to ionising radiation of workers and the public and aimed at providing the public with better protection should they be exposed to significant radiation without being aware of it. The study report was submitted to the ASN at the end of August 2005. This extremely complete report is currently being analysed. It comprises a certain number of recommendations which could be incorporated into the PNGDR-MV.

The waste treatment stations on the CEA sites at Saclay (BNI 72), Fontenay (BNI 74) and Grenoble (BNI 79) (see chapters 13 and 15) also provide interim storage capacity for fuel elements or high level waste in pits and/or fuel blocks. The waste is packaged in containers and stored in radioactive decay pits. For BNIs 74 and 79, the CEA is involved in a programme to recover this waste as part of the process to denuclearise the Grenoble and Fontenay-aux-Roses sites.

In BNI 72, fuel is also stored in concrete blocks and is currently being recovered for reconditioning in the STAR facility at Cadarache prior to interim storage in the CASCAD facility in Cadarache.

The radioactive waste storage yard

The main role of the radioactive waste storage yard (BNI 56) in Cadarache is to provide interim storage of radioactive solid waste (IL-LL waste) from the operation or dismantling of CEA installations and which cannot be stored in the CSA.

The waste is stored there in pits, in warehouses and for the VLL waste, in a dedicated area. The start of operations at CEDRA makes it possible on the one hand to empty the recent pits in BNI 56 and the hangars, and on the other to recover waste stored in the old pits (Fosséa project). The ASN will be vigilant concerning implementation of these storage removal programmes.