ASN Report 2017

417 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 15  - Decommissioning of Basic Nuclear Installations ASN shall be attentive to ensuring that the licensee remains compliant with its operating baseline requirements until the decree authorising it to perform the major decommissioning operations is issued. ASN recommends that the licensee inform the Local Information Committee (CLI) of the planned work in the decommissioning preparation phase, regularly inform the CLI of the progress of operations and present the results once they are completed. As part of its oversight duties, ASN monitors the implementation of the decommissioning operations as directed by the decommissioning decree. The Environment Code provides that – as is the case for all other basic nuclear installations – the safety of a facility undergoing decommissioning be reviewed periodically, and at least every 10 years. ASN’s objective with these safety reviews is to ascertain that the installation complies with the provisions of its decommissioning decree and the associated safety and radiation protection requirements through to its delicensing by applying the principles of defence in depth specific to nuclear safety. On completion of decommissioning, a nuclear facility can be delicensed by an ASN resolution approved by the Minister responsible for Nuclear Safety. It is then removed from the list of BNIs and is no longer subject to the BNI System. To support its delicencing application, the licensee must, among other things, provide a file containing a description of the state of the site after decommissioning (analysis of the state of the soils, remaining buildings or facilities, etc.) and demonstrating that the planned final state has been reached. Depending on the final state reached, ASN may make delicensing of a BNI subject to the putting in place of active institutional controls. These may set a certain number of restrictions on the use of the site and buildings (use limited to industrial applications for example) or precautionary measures (radiological measurements to be taken in the event of excavation, etc.). 1.4 The financing of decommissioning and radioactive waste management 1.4.1 The legislative and regulatory provisions Articles L. 594-1 to L. 594-14 of the Environment Code define the system for ring-fencing funds to meet the costs of decommissioning nuclear facilities and managing the spent fuel and the radioactive waste. This system is clarified by Decree 2007-243 of 23rd February 2007 amended relative to securing the funding of the nuclear costs and by the Order of 21st March 2007 relative to securing the funding of nuclear costs. It aims to secure the funding for nuclear costs in compliance with the “polluter-pays” principle. It is therefore up to the nuclear licensees to take charge of this financing by setting up a dedicated portfolio of assets capable of meeting the expected costs. They are obliged to submit three-yearly reports on these costs and annual update notices to the Government. Provisioning is ensured under direct control of the State, which analyses the situation of the licensees and can prescribe the necessary measures should it be found to be insufficient or inappropriate. Whatever the case may be, the nuclear licensees remain responsible for the satisfactory financing of their long-term costs. These costs are divided into five categories: ཛྷ ཛྷ decommissioning costs, except for long-term management of radioactive waste packages; ཛྷ ཛྷ spent fuel management costs, except for long-term management of radioactive waste packages; ཛྷ ཛྷ cost of Retrieving and Packaging legacy Waste (RCD), except for long-term management of radioactive waste packages; ཛྷ ཛྷ costs of long-term management of radioactive waste packages; ཛྷ ཛྷ cost of surveillance following disposal facility closure. The costs involved must be assessed using a method based on 1) an analysis of the options that could be reasonably envisaged for the operation, 2) a conservative choice of a reference strategy, 3) consideration of residual technical uncertainties and performance contingencies, and 4) consideration of operating experience feedback. An agreement signed between ASN and the General Directorate for Energy and Climate (DGEC) whereby ASN ensures the surveillance of these long-term costs, defines: ཛྷ ཛྷ the conditions in which ASN produces the opinions it is required to issue pursuant to Article 12 of the above- mentioned Decree of 23rd February 2007, on the consistency of the strategies for decommissioning and management of spent fuels and radioactive waste; ཛྷ ཛྷ the conditions in which the DGEC can call on ASN expertise pursuant to Article 15 of the same Decree. 1.4.2 Review of the reports submitted by the licensees On 8th June 2017, ASN gave the DGEC its opinion on the three-yearly reports concerning the securing of provisions to cover the long-term financial costs. As in the previous years, ASN underlines the lack of details in the EDF report, making it impossible for ASN to adopt a position on the completeness of the financial costs evaluation. ASN recommends that the licensees evaluate the cost of cleaning out the civil engineering structures and the soils, as few licensees take them into account in their cost evaluation. ASN also recommends that third-party audits be carried out on the sums provisioned for the management of spent fuel from the EDF facilities and management of the repackaging of legacy waste from the Areva plant in La Hague and for its decommissioning. Lastly, the BNI licensees duly transmitted the three-yearly report update notices during 2017. These notices are currently being examined. 1.5 Lessons learned from the Fukushima Daiichi accident To take into account the lessons learned from the nuclear accident that occurred at the Fukushima Daiichi nuclear power plant in Japan, ASN asked the BNI licensees to carry out stress tests on their installations, including those undergoing decommissioning.

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