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ASN nevertheless considered that some of the technical

and economic hypotheses adopted by Andra were

too optimistic and consequently did not satisfy the

requirement for caution imposed by such an evaluation.

Moreover, at this stage of project development,

uncertainties are inevitable. ASN therefore considered

that it was essential to provide a mechanism for regularly

updating the reference cost, particularly during key

stages of project development.

ASN pointed out that this evaluation is one of the bases

for calculating the funds required by the licensees to

cover the expenses associated withmanagement of their

radioactive waste. The purpose of these funds is to ensure

that these costs will not be borne by future generations.

In accordance with the procedure stipulated in

Article L. 542-12 of the Environment Code, after

consideration of ASN’s opinion and the comments of

the radioactive waste producers, the Minister responsible

for Energy issued an Order on the reference cost of the

Cigéo disposal project on 15th January 2016: a

“cost is

set at €25 Bn under the economic conditions prevailing on

31st December 2011, the year in which the cost evaluation

work began”.

This Order also specifies that the cost must

be updated regularly and

“at least at the key stages of

project development (creation authorisation, commissioning,

end of the “industrial pilot phase”, periodic safety reviews),

in accordance with the opinion of ASN.”

ASN’s position on reversibility

The reversibility of deep geological disposal is a requirement

contained in the Environment Code. This requirement is to

be detailed in a future Act. In 2016, Andra will submit a file

to ASN presenting the main technical options to ensure the

retrievability of the emplaced waste packages. ASN informed

Andra of its expectations on this subject.

ASN considers that the notion of reversibility must not only

guarantee retrievability, in other words the possibility of

retrieving the waste packages already emplaced for a given

period of time, but also that the facility is adaptable in order

to guarantee the possibility of modifying the previously

adopted provisions during construction and operation of the

disposal facility. As such, ASN considers that Andra must

demonstrate that a change in the waste inventory intended

for deep geological disposal further to – for example – a

political decision in terms of energy policy leading to the

direct disposal of spent fuel, does not call into question the

safety of disposal.

To ensure that these safety issues are integrated as of the

design phase, ASN considers it essential that the technical

requirements associated with reversibility be defined by

Parliament prior to submission of the creation authorisation

application for such a disposal facility. ASN will publish its

position on reversibility in 2016.

TO BE NOTED

ASN visit to the Bure underground laboratory, July 2015.

492

CHAPTER 16:

RADIOACTIVE WASTE AND CONTAMINATED SITES AND SOILS

ASN report on the state of nuclear safety and radiation protection in France in 2015