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3. REGULATING THE NUCLEAR FUEL
CYCLE FACILITIES
ASN regulates the fuel cycle facilities at different levels:
•
the safety cases produced by the licensee during the
various steps in the operation of the nuclear facilities;
•
the organisation of the licensees through inspections
conducted in the field;
•
fuel cycle consistency;
•
operating experience feedback within the fuel cycle
BNIs.
This part specifies how the steps taken by ASN apply
to the fuel cycle facilities.
3.1 The main steps in the life
of nuclear facilities
When the facilities undergo a significant modification or
make the transition todecommissioning, ASNis responsible
for reviewing thesemodifications andproposes the relevant
decrees for these changes to the Government. ASN thus
establishes prescriptions for thesemain steps. Finally, ASN
also reviews the safety files specific to each BNI, paying
attention to their integration into the broader framework
of laboratory and plant safety.
The Areva group has not yet carried out the first periodic
safety reviews on all its facilities. The series of initial
periodic safety reviews to be completed before the end
of 2017 is a major challenge for the Areva facilities.
The review of the methodology and the conclusions
of the review of the UP3-A facility on the La Hague site
presented by the licensee should be an opportunity for
Areva to improve its process for the future periodic
safety reviews. When examining each new file, ASN
will be attentive to ensuring that experience feedback
from the previous reviews has been correctly taken into
account. ASN will in particular ensure that lessons are
learned from the UP3-A safety review with regard to
identifying Elements Important for Protection (EIP)
and the associated defined requirements, in compliance
with the “BNI” Order.
3.2 Particular regulatory actions
conducted in consultation with the
Defence Nuclear Safety Authority
Given the probable declassification of the Tricastin secret
BNI (SBNI) andASN’s takeover of responsibility for oversight
of these facilities, ASN and the Defence Nuclear Safety
Authority (ASND) are attempting tomaintain a degree of
consistency in the application of the safety and radiation
protection requirements for the facilities under their
respective responsibility on the Tricastin site.
Most of the facilities regulated by the ASND have in fact
been shut down or are being decommissioned and no
longer play a role in national defence. In this respect,
they no longer need to be subject to secrecymeasures and
will thus be gradually “declassified” in the coming years.
The facilities which are currently reprocessing the
effluents and wastes from the entire site are scheduled
for decommissioning and their activities will be taken over
by the Trident unit in the Socatri facility (see chapter 14).
Some of the uranium storage facilities will be dismantled
and the others will be incorporated into the project to
group the storage areas on the Tricastin site within the
same BNI (see point 1.1.1).
ASN and ASND have set up a working group to clarify
the steps involved in ASN’s takeover of the regulation
of the safety of activities on this site. The decision was
made that this take-over would be gradual, comprise as
few steps as possible and be an opportunity to reorganise
the oversight of the Tricastin site, so that no zones
are outside the control of a safety regulator. Jointly
with the ASND and the Ministry for the Environment,
Energy and the Sea (MMEM), ASNwill define the final
breakdown into BNIs resulting from the ongoing process
to declassify the INBS on the site. The BNI and INBS
systems are in fact different and even if an INBS can
house several nuclear facilities with different purposes
and safety issues, the same does not apply to a BNI. The
Tricastin INBS, which houses a wide variety of facilities,
will thus need to be broken down into coherent BNIs as
part of the declassification process. Their safety baseline
requirements will then need to be brought into line
with the BNI system.
The first step of the declassification process has been
initiated, which should lead to ASN registering a first
BNI radioactive materials storage area as a BNI in 2016.
This process should end by the year 2018.
3.3 The licensee’s organization and
management structure for fuel cycle
nuclear installations
For each facility, ASN regulates the organisation and
means chosen by the licensee to enable it to assume
its responsibilities in terms of nuclear safety, radiation
protection, emergency management in the event of an
accident and protection of nature, the environment
and public health and safety. ASN issues an opinion or
recommendations regarding the chosen organisations and
may issue prescriptions on specific identified points if it
considers that these organisations present shortcomings
in terms of internal oversight of safety and radiation
protection, or that they are inappropriate.
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CHAPTER 13:
NUCLEAR FUEL CYCLE INSTALLATIONS
ASN report on the state of nuclear safety and radiation protection in France in 2015