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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 delicensing application,
the licensee must provide a dossier demonstrating that
the envisaged final state has indeed been reached and
describing the state of the site after decommissioning
(analysis of the state of the soil and remaining buildings
or equipment, etc.). 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 tomeet the costs
of decommissioning nuclear facilities and managing the
spent fuel and the radioactivewaste. This systemis clarified
byDecree 2007-243of 23rd February 2007 amended and
theOrder of 21stMarch 2007 concerning the securing of
financing 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 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 measures should it be found to be
insufficient or inappropriate. In any case, the nuclear
licensees remain responsible for the satisfactory financing
of their long-term costs.
These costs are divided into five categories:
•
decommissioning costs, except for long-term
management of radioactive waste packages;
•
spent fuel management costs, except for long-term
management of radioactive waste packages;
•
cost of Recovering and Packaging legacyWaste (RCD),
except for long-termmanagement of radioactive waste
packages;
•
costs of long-term management of radioactive waste
packages;
•
cost of surveillance following disposal facility closure.
The costs involvedmust be assessedusing amethodbased
on an analysis of the options that could be reasonably
envisaged for the operation, on a conservative choice of
a reference strategy, on consideration of residual technical
uncertainties and performance contingencies, and on
consideration of operating experience feedback.
An agreement signed between ASN and the General
Directorate for Energy andClimate (DGEC)wherebyASN
ensures the surveillance of these long-termcosts, defines:
•
the conditions in which ASN produces the opinions it
is required to issue pursuant to Article 12, paragraph 4
of the above-mentionedDecree of 23rdFebruary 2007,
on the consistency of the strategies for decommissioning
and management of spent fuels and radioactive waste;
•
the conditions in which the DGEC can call on ASN
expertise pursuant to Article 15, paragraph 2 of the
same Decree.
1.4.2 Review of the reports submitted
by the licensees
The third three-yearly reports were submitted in 2013
and formed the subject of ASN opinion 2013-AV-0198
of 9th January 2014. In this opinion, ASN recommends
as a general rule that the licensees:
•
implement harmonised approaches for the declaration
of decommissioning costs;
•
take into account the costs of remediation of
contaminated soil, favouring the complete clean-
out of sites;
•
assess the impact on the unavailability of waste
treatment, packaging and storage facilities on the
evaluation of the costs;
•
assess the impact of the modifications of their
installations induced by the conclusions of the
stress tests and the periodic safety reviews on the
decommissioning strategy, and hence on the evaluation
of the costs;
•
re-evaluate the costs of implementing long-term
management solutions for high-level waste and
intermediate-level, long-lived waste, on the basis of
the latest technical design options of the deep geological
disposal (see chapter 16).
The opinion also contains specific recommendations
concerning each licensee.
In 2014, the licensees transmitted the first discounting
notes for the third three-yearly reports on which ASN
gave an opinion to the DGEC on 18th December 2014.
In addition to the points put forward in its opinion of
9th January 2014, ASN urges the licensees to include
the final shutdown preparation operations in their
decommissioning costs, as these are an integral part
of the decommissioning operations of an installation.
ASN has also drawn the attention of the DGEC to the
hypothesis considered by CIS bio international of a start
of decommissioning in 2078, which is not credible in
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CHAPTER 15:
SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS
ASN report on the state of nuclear safety and radiation protection in France in 2015