Chapter 15 Safe Decommissioning Of

ACTIVITIES REGULATED BY ASN

SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

1 TECHNICAL AND LEGAL REQUIREMENTS APPLICABLE TO DECOMMISSIONING 421 1 I 1 Decommissioning strategies 1 I 2 Legal requirements 1 I 3 The financing of decommissioning and radioactive waste management 1 I 3 I 1 Reminder of regulatory provisions 1 I 3 I 2 Review of the reports forwarded by the licensees 1 I 4 Decommissioning risks 1 I 5 Complete clean-out

2 SITUATION OF NUCLEAR INSTALLATIONS UNDERGOING DECOMMISSIONING IN 2011 426 2 I 1 EDF nuclear power plants (NPPs) 2 I 1 I 1 The Brennilis NPP 2 I 1 I 2 Natural Uranium Graphite Gas Reactors (UNGG) 2 I 1 I 3 CHOOZ A reactor (Ardennes NPP) 2 I 1 I 4 SUPERPHÉNIX reactor 2 I 2 CEA installations 2 I 2 I 1 Fontenay-aux-Roses centre 2 I 2 I 2 The Grenoble centre 2 I 2 I 3 The Cadarache centre installations undergoing decommissioning 2 I 2 I 4 The Saclay centre installations undergoing decommissioning 2 I 3 AREVA installations 2 I 3 I 1 UP2 400 spent fuel reprocessing plant and associated facilities 2 I 3 I 2 SICN plant in Veurey-Voroize 2 I 4 Others installations 2 I 4 I 1 The Strasbourg University reactor 2 I 4 I 2 The Electromagnetic radiation laboratory

3 OUTLOOK 437

APPENDIX 1 LIST OF BASIC NUCLEAR INSTALLATIONS DELICENSED AS AT 31.12.2011 437

APPENDIX 2 LIST OF BASIC NUCLEAR INSTALLATIONS UNDERGOING DECOMMISSIONING AS AT 31.12.2011 439 CHAPTER 15

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l a e i n n n C d B i O 1 o t T i o ( – c A r d i T 1 1 T n – immediate decommissioning: decommissioning is started as regard to the possible recycling of the waste resulting from soon as the installation is shut down, without a waiting per - decommissioning, ASN is attentive to the application of iod, although the decommissioning operations can extend French waste doctrine, which states that material that has or over a long period of time. may have been contaminated in the nuclear sector may not be reused outside this sector. Waste from decommissioning may The decision to opt for one decommissioning strategy rather not therefore be used outside the nuclear sector. However, than another is influenced by many factors: national regula - ASN supports initiatives to recycle this waste in the nuclear tions, social and economic factors, financing of the operations, sector, and the National Radioactive Material and Waste availability of waste disposal routes, decommissioning tech - Management Plan (PNGMDR - see chapter 16) includes a niques and qualified personnel, exposure of the personnel and recommendation to this effect. the public to ionising radiation as a result of the decommissio - ning operations, etc. Consequently, practices and regulations differ from one country to another. 1 I 2 The legal framework of decommissioning In compliance with IAEA recommendations, French policy today aims to induce French BNI licensees to opt for immediate The technical provisions applicable to installations to be shut decommissioning strategies. down and decommissioned must comply with general safety and radiation protection rules, notably regarding worker exter - This strategy moreover avoids placing the technical and finan - nal and internal exposure to ionising radiation, the criticality cial burden of decommissioning on future generations. At pre - risk, the production of radioactive waste, the discharge of sent, the leading French licensees have all made a commitment effluents to the environment, and measures to reduce the risk of to immediate decommissioning of the installations currently accidents and mitigate their consequences. Issues relating to concerned by the decommissioning process. safety and the protection of persons and the environment can be significant during active clean-out or decommissioning opera - ASN also believes that management of the waste resulting from tions, and must never be neglected, including during passive decommissioning operations is a crucial point that determines surveillance phases. the correct running of the ongoing decommissioning pro - grammes (availability of disposal routes, management of waste Once the licensee has decided to proceed with final shutdown streams). In this respect, the waste management procedures are and decommissioning of its installation, it can no longer be systematically assessed as part of the review of the overall covered by the regulations set by the creation authorisation decommissioning strategies adopted by each licensee. decree nor the safety specifications associated with the operating phase. In accordance with the provisions of the TSN Act, final Decommissioning operations can therefore only begin if shutdown and decommissioning of a nuclear installation is appropriate disposal routes are available for all the waste authorised by a new decree, issued on the advice of ASN (see liable to be created. The example of the decommissioning of diagram 1). The final shutdown and decommissioning authori - EDF’s first generation reactors is a good illustration of this sation procedure for a nuclear installation is described in problem (see point 2 ⏐1⏐2). The French management policy chapter 3. for very low-activity waste is clear and protective: it does not provide release thresholds for this waste, but, on the contrary, In order to avoid fragmentation of the decommissioning pro - for it to follow a specific disposal route in order to confine it jects and improve their overall consistency, the file submitted to in a single place and ensure its traceability. This is why, with support the final shutdown and decommissioning application

Diagram 1 : phases in the life of BNI

Final shutdown Stopping point Stopping point Delicensing

Regulatory Creation authorisation decree Final shutdown / decommissioning decree phases

Major Major Technical operation 1 operation n phases Operation Decommissioning FinOpérationsal shutdow den préparationpreparation à la mise à l’arrêt opdéfinitiferation s

422 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs) must explicitly describe all the planned work, from final shutdown to attainment of the target final status and, for each 1 I 3 The financing of decommissioning and radioactive step, must explain the nature and scale of the risks presented by waste management the installation as well as the envisaged means of managing these risks. The decommissioning phase may be preceded by a final shutdown preparation stage, provided for in the initial 1 I 3 I 1 Reminder of regulatory provisions operating licence. This preparatory phase allows removal of all or part of the source term, as well as preparation for the decom - Article 20 of Programme Act 2006-739 of 28 June 2006 on the missioning operations (readying of premises, preparation of sustainable management of radioactive materials and waste worksites, training of staff, etc.). It is also during this prepara- (now codified in books I to V of the Environment Code) creates tory phase that installation characterisation operations can be a system for securing the nuclear costs involved in the decom - carried out: production of radiological maps, collection of perti - missioning of nuclear installations and management of radioac - nent data (operating history) with a view to decommissioning tive waste. This article is clarified by decree 2007-243 of and so forth. 23 February 2007 and the order of 21 March 2007 concerning the securing of financing of nuclear costs. The TSN Act requires that the safety of an installation in the decommissioning phase be periodically reviewed. The frequen - The legal system created by these texts aims to secure the finan - cy of these reviews is normally 10 years. ASN’s objective is to cing of nuclear costs, through implementation of the “polluter check through these periodic reviews that the level of safety of pays” principle. It is therefore up to the nuclear licensees to the installation remains acceptable until it is delicensed, with take charge of this financing, by setting up a dedicated portfolio the implementation of measures proportionate to the risks pre - of assets capable of meeting the expected costs. This is done sented by the installation during decommissioning. under the direct control of the State, which analyses the situa - tion of the licensees and can prescribe measures should it be Following decommissioning, a nuclear installation can be deli - seen to be insufficient or inadequate. Whatever the case, the censed. It is then deleted from the list of BNIs and is no longer nuclear licensees remain responsible for the satisfactory finan - attached to the BNI system. To support its delicensing applica - cing of their long-term expenses. tion, the licensee must provide a file demonstrating that the envisaged final status has indeed been reached and describing It stipulates that the licensees must make a conservative assess - the state of the site after decommissioning (analysis of the state ment of the cost of decommissioning their installations or, for of the soil and remaining buildings or equipment, etc.). radioactive waste disposal installations, their final closure, Institutional controls may be implemented, depending on the maintenance and surveillance costs. They must also evaluate final status reached. These may set a certain number of restric - the cost of managing their spent fuels and radioactive waste tions on the use of the site and buildings (use limited to indus - (I of article 20 of the act of 28 June 2006). They thus submit trial applications for example) or precautionary measures three-yearly reports and annual update memos. (radiological measurements to be taken in the event of excava - These costs are divided into five categories (defined in para - tion, etc.). ASN may make delicensing of a BNI dependent on graph I of article 2 of the decree of 23 February 2007): the implementation of such controls. – decommissioning costs, except for long-term management of An ASN guide created in 2003 specified the regulatory frame - radioactive waste packages; work for BNI decommissioning operations, following major – spent fuel management costs, except for long-term manage - work designed to clarify and simplify the administrative proce - ment of radioactive waste packages; dure while at the same time giving greater importance to safety – cost of legacy waste recovery and packaging (RCD), except for and radiation protection. A fully revised version of this guide, long-term management of radioactive waste packages; integrating the regulatory changes introduced by the TSN Act – cost of long-term management of radioactive waste packages; and decree 2007-1557 of 2 November 2007, and the work of – cost of surveillance following disposal facility closure. the association WENRA, was issued in June 2010 (ASN Guide These categories are detailed in the list contained in the order of No.6, available on the web site www.asn.fr ). 21 March 2007. This guide is intended for nuclear licensees and its main The costs involved must be assessed using a method based on objectives are: an analysis of the options that could be reasonably envisaged – to explain the regulatory procedure laid down by the decree for the operation, on a conservative choice of a reference implementing the TSN Act; strategy, on consideration of residual technical uncertainties and – to clarify what ASN expects with regard to the content of performance contingencies, and on consideration of operating certain items of the final shutdown and decommissioning experience feedback. These cost assessments, if necessary, com - authorisation application files, particularly the decommissio - prise a breakdown into variable and fixed costs and, if possible, ning plan; a method explaining the breakdown of the fixed costs over – to explain the technical and regulatory aspects of the various time. They also, insofar as is possible, comprise an annual sche - phases of decommissioning (preparation for final shutdown, dule of costs, a presentation and justification of the scenarios decommissioning, delicensing). adopted and methods used and, if necessary, an analysis of the operations carried out, the deviations from the forecasts and consideration of operating experience feedback. The licensees must also give a concise presentation of the assessment of these costs, the extent to which the work in progress is in line with

423 the forecast schedule, and the possible impact of work progress them of the regulatory requirements, particularly with on the costs. respect to article 2 of the decree. The licensees submitted their second three-yearly report in 2010. ASN gave its opinion to the On 3 January 2008, an agreement was signed by ASN and the DGEC (opinion 2011-AV-0107 of 3 February 2011, consultable General Directorate for Energy and Climate (DGEC) whereby on the web site), in which it recommends - as a general rule - ASN carries out surveillance of these long-term costs. This better substantiation of assessment robustness and clarification agreement defines: of the uncertainties in the decommissioning and waste manage - – on the one hand, the conditions in which ASN produces the ment operations that impact costs. Furthermore, as ASN had opinions it is required to issue pursuant to article 12, para - observed the need to check the tools used by the licensees to graph 4 of the above-mentioned decree of 23 February 2007, evaluate the decommissioning costs, it recommended on the consistency of the strategies for decommissioning and implementing audits, and assisted the DGEC in defining the management of spent fuels and radioactive waste; audit programme that should be conducted in the 2011-2013 – on the other, the conditions in which the DGEC can call on period. ASN expertise pursuant to article 15, paragraph 2 of the same decree. It in particular stipulates that, as necessary, and under ASN also informed the DGEC of its opinion on decree the same conditions as those governing analysis of the three- 2010-1673 of 29 December 2010 amending decree 2007-243 yearly reports, the DGEC may call on ASN after receiving the of 23 February 2007 relative to securing of the financial costs of annual update memos. decommissioning. ASN reiterated the importance of maintai - ning the robustness of the composition of the assets dedicated to covering the decommissioning costs and the asset liquidity 1 I 3 I 2 Review of the reports submitted by the licensees level in order to guarantee the effective availability of the funds. In 2007, all the nuclear installation licensees had submitted In 2011 ASN started drafting a guide for the licensees, to their first three-yearly reports pursuant to the provisions of specify what is required in application of the regulatory provi - article 20 of the Act of 28 June 2006. ASN had given the sions relating to cost assessments. Government its opinion on the first three-yearly reports (opinion 2007-AV-037 of 20 November 2007). 1 4 The implications of decommissioning In 2008 and 2009, ASN examined the new data forwarded by I the licensees in their annual update memos. In 2010, ASN and Diagram 2 presents the main risks associated with the decom - the DGEC verified the methods used by the licensees to prepare missioning of a nuclear installation and the periods during the three-yearly reports and the update memos, and reminded which these risks are highest.

Diagram 2: principal risks encountered during decommissioning

Final shutdown Delicensing

Operation Technical Decommissioning phases Final shutdown preparation operations

Risques liés à l’exploitationRisks linked normaleto normal operation

Risks linked to waste management

Risks linked to conventional safety, fire, explosion, etc.

Risks linked to ageing, obsolescence, memory lo ss

Risks linked to inadequate surveillance, long-term impact (polluted soils)

424 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

The risks involved in waste management and which concern safety or radiation protection (multiplication of the number of 1 I 5 Complete clean-out waste storage sites, storage of irradiating waste) are present Nuclear installation decommissioning operations lead to the throughout the phases in which large amounts of waste are pro - gradual delicensing of the “nuclear waste zones” to “conventio - duced and therefore in particular during the decommissioning nal waste zones”. When the licensee is able to prove that there phase. are no activation or contamination migration phenomena in all The risks presented by the nuclear installation when in opera - the structures making up a “nuclear waste zone”, this zone can tion change as decommissioning progresses. Even if certain be delicensed on completion of any necessary simple clean-out risks, such as criticality, quickly disappear, others, such as those operations (cleaning the walls of an area using appropriate pro - related to radiation protection or general working safety (nume - ducts for example). rous contractors working together, falling loads, work at height, However, if activation or contamination migration phenomena and so on) gradually become predominant. The same goes for occurred during the operating phase, complete clean-out – that the fire or explosion risks (technique of breaking down the is to say removal of the artificial radioactivity present in the structures by “hot points”, that is to say those generating heat, structures themselves – may require operations involving actual sparks or flames). physical removal of the parts of these structures considered Similarly, the risks associated with human and organisational to be nuclear waste (removing the skin of a concrete wall for factors (change in organisation with respect to the operating instance). phase, frequent use of outside contractors) must be taken into Operations such as these mean that within the structure concer - account. ned, a new limit has to be defined between nuclear waste and For complex nuclear installations such as NPP reactors, decom - conventional waste zones. To ensure consistency with the gene - missioning work often lasts for more than a decade. This fol - ral waste zoning doctrine, the definition of this new waste lows on from an operating period that often lasts several zoning limit is based on the implementation of independent, decades. Consequently, the risk of loss of the design and opera - successive lines of defence. The requirements of the ASN tech - tional memory of the nuclear installations must be taken into nical guide on complete clean-out operations, published in 2006 consideration. The sometimes rapid changes in the physical (guide SD3-DEM-02) have been implemented in a large number condition of the installation and the risks it presents raise the of installations of various types: research reactors, laboratories, question of ensuring that the means of surveillance used are fuel fabrication plants, etc. adequate and appropriate at all times. It is often necessary to At the end of 2008, ASN obtained national operating experience replace, either temporarily or lastingly, the centralised means of feedback on complete clean-out. The analysis has shown that, in operating surveillance by other more appropriate means of spite of certain technical difficulties, the complete clean-out surveillance. Following decommissioning, depending on the approach to civil engineering structures has proved its worth. end-status achieved and the specific characteristics of each ins - Having listened attentively to the arguments of the various tallation (operational history, incidents, etc.), there may be resi - stakeholders, in June 2010 ASN published a new version of the dual risks: soil pollution, areas for which clean-out is techni - 2006 guide (ASN guide no.14) which aims to specify the requi - cally impossible under acceptable technical and economic rements in terms of modelling, delicensing of very large struc - conditions, etc. In this case, prior to delicensing of the installa - tures, use of innovative decontamination techniques, adoption tion, the licensee must present and justify the envisaged means of a suitable approach to the management of deviations and the of ensuring the surveillance of the installation or site. In such approval of delicensing, while guaranteeing rigour in the chosen cases, institutional controls are imposed to restrict the use of strategy. the site.

425 2 SITUATION OF NUCLEAR INSTALLATIONS BEING DECOMMISSIONED IN 2011

decommissioning strategy for the PWR reactors in operation is 2 I 1 EDF NPPs presented. In 1996, EDF’s strategy was deferred decommissioning of its The conclusion after examining the file is that the principles of shutdown nuclear installations, namely the six gas-graphite the strategy are basically satisfactory, but some additions are reactors (Bugey 1, Saint Laurent A1 and A2, Chinon A1, A2 and required, particularly with regard to alternative solutions for the A3), the heavy water reactor at Brennilis, the PWR at Chooz A management of graphite waste. and the fast neutron reactor at Creys-Malville. In April 2001, at the instigation of ASN, EDF decided to change its strategy and Internal authorisations adopt a programme for the decommissioning of its first- In a letter dated 9 February 2004, ASN authorised EDF to set up g eneration plants, which is now scheduled for completion in 2036. an internal authorisation system for the installations concerned This new strategy was reviewed by the competent Advisory by the decommissioning programme. This approach addresses a Committee of Experts in March 2004. On the basis of this key requirement, namely to keep the safety specifications of an review, ASN concluded that the decommissioning strategy for installation permanently up to date. the first generation reactors adopted by EDF, as well as the pro - The system of internal authorisations is now governed by decree gramme and schedule, are acceptable in terms of safety and 2007-1557 of 2 November 2007 (see chapter 3) concerning BNIs radiation protection, provided that a certain number of requests and the regulation of the nuclear safety of the transport of radio - are taken into account and that there is compliance with the active substances. ASN decision 2008-DC-106 of 11 July 2008 undertakings made by EDF with regard to the issues of decom - specifies the ASN requirements for implementation of the provi - missioning feasibility, safety, radiation protection and waste and sions of the above decree relative to internal authorisations. effluent management. In July 2009, EDF forwarded a decom - Pursuant to article 3 of this decision, EDF submitted a file to ASN missioning strategy update file. In this file, EDF confirmed the presenting an update of its internal authorisation system, concer - position it had adopted in April 2001. The file includes a sum - ning the decommissioning operations, with a view to having it mary of the progress of the dismantling programme and identi - approved by the ASN Commission. This file is being examined fies the forthcoming major milestones. Current thinking on the by the ASN.

Installations shut down or undergoing decommissioning in 2011

COGEMA ORSAY Chooz Strasbourg reprocessing electromagnetic NPP University plants radiation laboratory reactor at La Hague

4 installations 1 installation 1 installation 1 installation

CEA's Bugey center in NPP Fontenay-aux-Roses

Site delicensing 1 installation

CEA Saclay Creys-Malville centre SUPERPHÉNIX reactor

2 installations 1 installation

Brennilis SICN plant NPP in Veurey-Voroize

1 installation 2 installations

Chinon Saint-Laurent- CEA's centre CEA's centre CEA's centre NPP des-Eaux in Marcoule in Cadarache in Grenoble NPP

3 installations 2 installations 1 installation 5 installations Site delicensing

426 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

Experience feedback from the Fukushima nuclear The partial decommissioning decree 2011-886 of 27 July 2011 accident was published in the Official Gazette of 28 July 2011. EDF engaged a new procedure for complete decommissioning by To take into account the experience feedback from the nuclear submitting an application file in December 2011. accident that occurred at the Fukushima Daiichi NPP in Japan, ASN took decision 2011-DC-0213 of 5 May 2011 instructing Pursuant to article 37 of the Euratom Treaty, the European Electricité de France (EDF) to carry out a complementary safety Commission was also consulted with respect to the filed autho - assessment of some of its BNIs in the light of the Fukushima risation application, and delivered a favourable opinion in Daiichi accident May 2010. This decision applies equally well to the EDF reactors in opera - Furthermore, through decisions 2011-DC-0239 and tion, the reactors undergoing decommissioning mentioned 2011-DC-0240 of 1 September 2011, and after receiving a below, and the fuel evacuation facility (APEC, situated on the favourable opinion from the CODERST (Departmental Council EDF Creys-Malville site in the Isère département ). ASN has for the Environment and for Health and Technological Risks), asked that the reports for the EDF reactors under decommissio - ASN has regulated the conditions and limits of water intakes ning and the APEC be submitted by 15 September 2012. and effluent discharges. The report presenting the methodology EDF will use for the reactor complementary safety assessments was examined by the 2 I 1 I 2 Natural Uranium Graphite Gas Reactors (UNGG) Advisory Committee of Experts on 6 July 2011. During the investigation of the file submitted by EDF in June 2009 concerning updating of the strategy for NPP decommissio - 2 I 1 I 1 The Brennilis NPP ning, ASN reaffirmed its strong support for an immediate decommissioning strategy. It nevertheless notes that where The Brennilis NPP is an industrial prototype of a heavy water- UNGGs are concerned, the question of the disposal route for moderated, carbon dioxide-cooled NPP, operated from 1966 to graphite waste complicates implementation of this strategy. 1985. Partial decommissioning operations were carried out from 1997 to mid-2007 (plugging of circuits, decommissioning ASN has confirmed that it is in favour of setting up a disposal of certain heavy water and carbon dioxides circuits and electro - centre for low-level long-lived waste, and graphite waste in par - mechanical components, demolition of non-nuclear buildings, ticular, as quickly as possible. It has set 2012 as a first interme - etc.). diate step to assess the situation regarding the creation of a gra - phite waste disposal centre, and will make a decision at that The decree 2006-147 of 9 February 2006 authorising EDF to time. The progress of this project will then determine ASN’s proceed with the complete decommissioning of the installation position - to be made known in 2014 at the latest - concerning was abrogated by the State Council on 6 June 2007 on the the need for EDF to build an storage site for graphite waste in grounds that the impact study, in application of directive order to continue the decommissioning of the UNGGs. 85/337/CEE of 27 June, amended, should have been made avai - lable to the public before the Government delivered the autho - Bugey 1 reactor risation. The operations that could be carried out, notably repackaging and removal of the legacy waste, were specified by The final shutdown and work continued until the end of 2008, ASN in decision 2007-DC-0067 of 2 October 2007 (amended), when the complete decommissioning decree for the installation pending the signing of a new decree authorising its complete was signed (decree 2008-1197 of 18 November 2008). At the decommissioning. end of 2009, EDF investigated the lower part of the Bugey 1 reactor compartment (taking radiological measurements, A new complete decommissioning authorisation application file photos, dimensions, samples, etc.) to optimally prepare for its was submitted by EDF on 25 July 2008. In March 2010, the future decommissioning. The compartment was found to be in investigation commission delivered an unfavourable opinion for good condition with relatively low dust loading. The file the project, on the grounds that no urgent need to decommis - sion the reactor block had been demonstrated and that decom - concerning the integrity of the reactor internal structures will missioning was premature as long as ICEDA – the activated be examined by ASN. waste packaging and interim storage installation – was not The decommissioning preparation work, excluding the reactor operational. It nevertheless considered that EDF should be vessel, started in November 2010 and continued in 2011. This authorised, as of now, to complete the inventory of the initial work consisted in freeing up the premises necessary for the radiological and chemical status of the site, to complete the installation of the reactor vessel decommissioning “support” effluent treatment station (STE) decommissioning operations, to functions. clean out and fill in the effluent discharge channel leading to the river Ellez, to clean out the diffuse pollution areas, and lastly, Chinon A1, A2 and A3 reactors start decommissioning of the heat exchangers following their radiological characterisation. After hearing EDF and the local The old Chinon A1, Chinon A2 and Chinon A3 reactors were information committee (CLI) of the Monts d’Arrée, the ASN partially decommissioned and transformed into storage facilities commission gave the Government a favourable opinion (opi - for their own equipment. These operations were authorised nion 2011-AV-0122 of 5 July 2011) to the draft partial decom - by the decrees of 11 October 1982, 7 February 1991 and missioning decree, authorising performance of the operations 27 August 19 96, respectively as amended on 25 November 2005, described above, in accordance with the commission’s opinion. respectively.

427 Views of the Saint-Laurent-des-Eaux NPP before and after the works

The work to characterise the rubble in the underground premises with a view to using the pool for the decommissioning of the was completed in December 2010. The first observations showed reactor compartments. that the majority of the underground rooms are empty or partially backfilled. The first analysis results confirm the presence of conta - mination in certain rooms. 2 I 1 I 3 CHOOZ A reactor (Ardennes NPP) The additional sampling operations on the Chinon A2 reactor This reactor was the first PWR built in France. It operated from were completed in March 2011. 1967 to 1991. The studies prior to the work to decontaminate the ground For the partial decommissioning of the reactor, the decree of between the Chinon A2-A3 reactors are continuing. 19 March 1999 authorised the modification of the existing ins - tallation to convert it into a storage installation for its own The complete decommissioning of the Chinon A3 reactor vessel equipment left on site and thus create a new BNI called CNA-D. was authorised by decree 2010-511 of 18 May 2010. The main Its complete decommissioning was authorised by decree work carried out in 2011 was the preparation for decommissio - 2007-1395 published in the Official Gazette on 27 September ning of the heat exchangers (the first step in the decommissioning 2007. of the installation). By decision 2010-DC-0202 of 7 December 2010, ASN autho - Furthermore, in December 2010, under article 26 of decree rised the start of primary system decommissioning, apart from 2007-1557 of 2 November 2007, EDF lodged a file with ASN reactor vessel, subject to compliance with a number of technical applying for the modification of certain prescriptions of the minis - requirements, and thus lifted the stopping point mentioned in terial order of 20 May 2003, amended by the order of 17 August paragraph III of article 2 of the Chooz A decommissioning 2005, authorising EDF to continue the water intakes and liquid decree. and gaseous discharges for the operation of the Chinon site. This file aims at modifying the atmospheric discharge conditions to Two steam generators were dismantled in 2011. allow the decommissioning work on the Chinon A3 heat exchan - gers to be performed. This file, which is currently being exami - ned, was made available for public consultation in July 2011. Furthermore, pursuant to article 37 of the Euratom Treaty, on 20 December 2011 the European Commission gave a favourable opinion for the project to discharge radioactive effluents resulting from the first phase of decommissioning of the Chinon A3 reactor. Saint-Laurent-des-Eaux A1 and A2 reactors

Complete decommissioning of the installation, whose final shutdown was declared in April 1994, was authorised by decree 2010-511 of 18 May 2010. The work to renovate the instrumentation of the discharge stacks and reorganise the waste storage areas continued in 2011. For Saint-Laurent A1 reactor, the pre-clean-out work on the pool and its structural reconstitution were carried out in 2011 Removal of a steam generator at Chooz – October 2011

428 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

2 I 1 I 4 SUPERPHÉNIX reactor 2 I 2 I 1 Fontenay-aux-Roses centre The SUPERPHÉNIX fast neutron reactor, a sodium-cooled CEA’s first research centre, dating from 1946 and located in industrial prototype, is located at Creys-Malville. This installa - Fontenay-aux-Roses (Hauts-de-Seine département ) is continuing tion is associated with another BNI, the fuel evacuation facility to move away from nuclear activities to concentrate on research (APEC), consisting mainly of a storage pool for fuel removed into the life sciences. The decommissioning of the two installa - from the Superphénix reactor vessel. The final shutdown autho - tions present on the site, the Process installation (BNI 165) and risation for this reactor was given in decree 98-1305 of the Support installation (BNI 166), was authorised by decrees 30 December 1998. In early 2003, all the fuel assemblies were 2006-772 and 2006-771 of 30 June 2006 published in the removed from the reactor and stored in the APEC. The four Official Gazette of 2 July 2006. Since January 2008, the labora - reactor coolant pumps were decommissioned in 2010, while tory clean-out and installation decommissioning programme has the decommissioning of the intermediate heat exchangers, been built around a project called Aladin. This project uses the authorised by ASN on 3 August 2010, is in progress and should experience feedback from the Grenoble Passage project. These be completed in 2012. operations were initially planned to last about ten years, but the ASN has authorised EDF to put the sodium treatment facility CEA has already informed ASN that, due to the strong presump - (TNA) into service, and to store the blocks of soda concrete tions of radioactive contamination underneath building 18, the produced by TNA through decision 2010-DC-0187 of 6 July decommissioning operations will be extended until 2012 for 2010. The sodium treatment process is carried out by hydro - BNI 165, and 2025 for BNI 166. These dates are announced lysis and leads to the production of soda. This soda is then used without allowing for any major contingencies that could arise as the primary component of the concrete packages to be pro - during the works. duced in the cement encapsulation facility and stored for a Before the administrative delicensing of the BNIs of the centre, period on the site to allow decay prior to removal. ASN has asked the CEA to characterise the soils and propose a The treatment of sodium from the primary and secondary solution for their rehabilitation if necessary. The rehabilitation cooling systems in TNA is in progress and should end in 2016. work sites are continuing, and the results of the hydrogeological More than a quarter of the total sodium has been treated to study that started in 2009 should be submitted in 2013. date. The Process installation (BNI 165) Fuel evacuation facility (APEC) This BNI, which comprises two buildings (buildings 18 and This facility was commissioned on 25 July 2000 by the 52/2), accommodated nuclear fuel reprocessing research and Ministers for Industry and the Environment. The spent fuel development activities. These activities were stopped in 1985 for assemblies removed from the SUPERPHÉNIX reactor are treated building 52/2 and in 1995 for building 18. and placed in the APEC pool. The decommissioning file for the PETRUS unit, initially omitted The facility now includes within its bounds the storage area for in the safety analysis report, submitted in support of the the soda concrete packages produced by the sodium treatment application for decree 2006-772, was submitted by the licensee plant. in summer 2010 and was the subject in 2011 to decision EDF plans submitting the periodic safety review file at the end 2011-DC-0245 of 11 October 2001 subjecting these operations of 2012. to its authorisation, pursuant to article 4.2 of the abovemen - tioned decree. The decommissioning work for this unit, which contains one of the largest shielded lines of building 18, should 2 I 2 CEA installations start in 2012. In December 2006, the Advisory Committees of Experts for The SUPPORT installation (BNI 166) plants and for waste issued their opinions on the overall decommissioning strategy for CEA’s civil installations. This was The purpose of this installation is initially to support the decom - considered to be on the whole satisfactory from the safety missioning operations to decommission the Process installation standpoint. The decommissioning schedules for the installa - (BNI 165), before being decommissioned in turn. tions concerned are consistent with the strategy adopted. ASN considers that they should enable an acceptable level of safety This BNI is used for storage and removal of radioactive effluents to be maintained in these installations until they are delicensed. from the site as well as the treatment of solid waste, storage in a The documents outlining CEA’s decommissioning strategy will decay pit of irradiated drums pending removal and storage of be updated and reassessed every five years. Nevertheless, at the drums of low and very low level (VLL) waste pending shipment request of ASN, the CEA delivered an interim report on the to a repository. updating of its decommissioning strategy, justifying the cho - To improve the organisation of its activities and hence the safety sen deadlines and explaining the reasons, technical or other - of its installation, the CEA has installed a new waste drum cha - wise, for the many delays with respect to the schedule. In res - racterisation line called SANDRA B. It submitted an application ponse, ASN reiterated its position concerning the use of file in July 2010 and ASN authorised its entry into service in institutional controls, the priority given to immediate decom - March 2011. missioning, the clean-out levels to attain, and the schedule objectives for certain decommissioning operations.

429 inspection carried out at the end of summer 2011 validated the 2 I 2 I 2 The Grenoble centre internal authorisation system in order proceed with delicensing The CEA Grenoble centre was inaugurated in January 1959 and of the waste zoning. the site’s nuclear activities grew in line with the development of The CEA is continuing the clean-out of the very high level reactor technologies. (VHL) cells and could use this procedure for the delicensing of As from the 1980’s, the nuclear activities were gradually trans - the VHL cells by 2013. ferred to other centres. Now the Grenoble centre conducts its research and development in the fields of renewable energies, MÉLUSINE reactor (BNI 19) health and microtechnology. MÉLUSINE is an old pool reactor intended for fundamental In 2002 the CEA centre in Grenoble launched a site delicensing research into structures and the production of radionuclides. process. This project, called “Passage”, aims for nuclear activi - Final shutdown was declared in 1994. The decree ties to be completely over by 2012. 2004-26 authorising CEA to modify the Mélusine reactor prior to its decommissioning and delicensing was published in the The site housed six nuclear installations which have been gra - Official Gazette on 9 January 2004. The clean-out work has dually phasing out their activities and moving to the decommis - been completed and in mid-2009, CEA submitted a file sioning phase with the ultimate aim of delicensing. Delicensing applying for BNI delicensing. ASN consulted the Prefect of the of the SILOETTE reactor (BNI 21) was declared in 2007. Isère département , the parishes concerned and the local infor - The CEA Grenoble centre has organised a large-scale event to mation committee (CLI), which gave a favourable opinion in highlight the progress of the “Passage” project, uniting all the summer 2010. Nevertheless, owing to the residual presence of contributing stakeholders. It was held on 1 July 2011 in the three zones that did not comply with the chosen clean-out cri - presence of the chairman of ASN, who underlined the quality of teria, ASN asked the CEA to continue its cleaning out in order the work carried out and urged the CEA to continue its efforts to achieve complete clean-out or to introduce institutional in compliance with the regulations. controls over the areas in question. The departure of part of the CEA teams from the "Passage" pro - The CEA then proceeded with the clean-out of the three parti - ject must not negatively impact the running of the operations. cular points in the first half of 2011. Thus, the ministerial order ASN thus asked the CEA Grenoble to remain vigilant and main - of 15 December 2011 approving ASN decision 2011-DC-250 tain the means enabling it to ensure maximum control over the for the delicensing of BNI 19 was published in the Official safety of its facilities, in spite of the gradual reduction of the Gazette of 22 December 2011. Consequently, this installation is risks in terms of worker safety and radiation protection. no longer subject to the BNI legal system. Radioactive effluent and solid waste treatment station SILOÉ reactor (BNI 20) and decay storage (STED) (BNIs 36 and 79) This former research reactor, currently undergoing decommis - The STED decommissioning operations were authorised for a sioning and clean-out, was primarily used for technological period of eight years by decree 2008-980 of 18 September 2008, irradiation of structural materials and nuclear fuels. Since the published in the Official Gazette o n 21 September 2008. decree of 26 January 2005, authorising final shutdown and decommissioning of the installations, operations have been The BNI 79 (STED) included in the bounds of BNI 36 is a continuing. All the internal structures have been dismantled, decay storage facility for high-activity (HA) waste, which was but the activity level of the pool block turned out to be higher comple tely emptied in 2010. There is currently no HA waste on than predicted in the initially envisaged decommissioning sce - the site. nario. Despite a one year extension to the operations time ini - The buildings have either already been destroyed or are tially prescribed in decree 2010-111 of 1 February 2010, the undergoing dismantling in accordance with the abovementioned CEA reported further difficulties in treating the basemat (migra - decree. The work to rehabilitate the ground is continuing, tion of low level contamination within the basemat). ASN has and part of the radiologically contaminated soils has been asked the CEA to present its strategy for completing the excavated. basemat clean-out work. Active material analysis laboratory (LAMA - BNI 61) 2 I 2 I 3 The Cadarache centre installations undergoing The active material analysis laboratory (LAMA) entered service decommissioning in 1961. This laboratory conducted post-irradiation studies of uranium and plutonium based nuclear fuels, and structural ASN considers that decommissioning of the Cadarache centre materials from nuclear reactors. The scientific research activi - installations is proceeding satisfactorily on the whole. The ties ended in 2002. example of the decommissioning of the HARMONIE reactor, delicensed on 10 June 2009, illustrates the feasibility of com - Decommissioning of the LAMA was authorised by decree plete decommissioning. 2008-981 of 18 September 2008 and published in the Official Gazette of 21 September 2008. The year 2011 was marked by Nevertheless, all the lessons must be drawn from the malfunc - the delicensing of a portion of the premises of the installation tions associated with the ATPu incident (discovery of an unde - by internal authorisation, with the approval of ASN. An restimation of the quantity of fissile materials retained in the

430 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

ASN inspection of the delicensing of the SILOE reactor basemat – December 2011 View of the RAPSODIE reactor

glove-boxes) and declared by the CEA on 6 October 2009. The Enriched uranium processing facilities (ATUEs) CEA thus indicated that ways of improving the quality of the information feedback chain had been identified. It pointed out The ATUEs converted the uranium hexafluoride (UF 6) from the that further to this incident, it has established a new procedure isotopic enrichment plants into sinterable oxide. They were also for immediate information feedback, up to CEA General used for the chemical reprocessing of fuel element fabrication Administrator level if justified by the nature of the incident. scraps to recover the enriched uranium they contain. The facility was also equipped with a low level organic liquid incinerator. RAPSODIE reactor and fuel assembly shearing Production in the facilities ended in July 1995 and the incine - laboratory (LDAC) rator was shut down at the end of 1997.

Final shutdown of RAPSODIE, an experimental fast neutron The final shutdown and decommissioning decree for the facility reactor which ceased operations in 1983, was declared in 1985. was issued in February 2006, and prescribed work completion The work designed to partially decommission the reactor, within 5 years. The year 2006 saw completion of the decom - which began in 1987, was interrupted in 1994 following a fatal missioning phase for the process equipment. accident during washing of a sodium tank. This accident, The phases of structural dismantling and complete clean-out of which emphasizes the risks involved in decommissioning ope - the civil engineering continued from that time, but with several rations, necessitated rehabilitation and partial clean-out work, interruptions due to technical and economic difficulties. Owing which was completed at the end of 1997. Since then, clean-out to these difficulties, the licensee submitted a decree modifica - and decommissioning work limited to certain equipment items tion application file in June 2010 requesting a five-year exten - has been resumed, along with waste removal. Renovation sion of the time scale to complete these works. operations have also been carried out. Because of the significant extension in the duration of the plan - The LDAC, located within the same BNI as the RAPSODIE reac - ned decommissioning operations (10 years instead of the tor, was designed for inspection and examination of spent fuel 5 years initially planned) and the increase in the quantity of from the RAPSODIE reactor or other fast neutron reactors. This very low level (VLL) waste to be produced, the modifications laboratory has been shut down since 1997. It has been cleaned- envisaged by the licensee were considered to be significant and out, is under surveillance and awaiting decommissioning. therefore require a new authorisation. In 2007, ASN approved a revised version of the safety require - The licensee was thus asked to submit a complete authorisation ments for the operations involved in preparing final shutdown, modification application file as rapidly as possible, so that it can enabling the licensee to carry out a number of reactor auxiliary be subject to the public consultations provided for in applica - equipment clean-out and dismantling operations. In 2008, CEA tion of the “TSN” Act. submitted a file applying for final shutdown and complete decommissioning. ASN informed CEA that its file was incom - Pending transmission of this file and its examination prior to plete. The decommissioning strategy is currently being revised. the modification of the final shutdown and decommissioning A new file will be submitted on completion of this process. ASN decree for the facility, the provisions of the initial decree of reminded the CEA in 2011 that it wanted the decommissioning 2006 remain applicable and the clean-out and decommissio - authorisation application file to be submitted without delay. ning operations continue in this framework

431 to decommissioning of the installations, ended in the first half of 2008. The nuclear materials removed in this phase were repackaged and removed from the facilities, essentially being transferred to the AREVA NC La Hague site. On 6 October 2009, CEA Cadarache informed ASN that the amounts of plutonium in the installation’s glove boxes had been underestimated at about 8 kg during the installation operating period, whereas the quantities recovered to date stood at about 22kg and CEA estimated that the total quantity could even reach 39kg at the end of decommissioning. This significant incident, evidencing deficiencies in the procedures for fissile material accounting and tracking, was rated level 2 on the INES scale by ASN. Further to this incident, two ASN decisions taken in October 2009 suspended the ongoing decommissioning operations in the facility and defined the conditions for work resumption. During the years 2010 and 2011, ASN gradually authorised the CEA to resume the decommissioning activities on the basis of specific safety analysis files. Two ASN decisions taken in October 2010 define the technical requirements governing the decommissioning operations. ASN is very attentive to the integration of experience feedback from the incident of 2009, particularly in the aspects relating to the estimation of fissile material quantities and The enriched uranium processing facilities (ATUEs) criticality safety. The association Les Amis de la Terre, the Collectif Antinucléaire 13, and some private individuals, appealed to the Conseil d’État Plutonium technology facility (ATPu) (Council of State) in February 2011 to suspend the ATPu decommissioning activities. The ATPu produced plutonium-based fuel elements, initially intended for fast neutron or experimental reactors and then, as With regard to the summary proceedings aiming at the imme - of the 1990s, for PWRs using MOX fuel. The activities of the diate suspension of the activities, ASN was called upon to draw LPC were associated with those of the ATPu: physical and che - up the statement of case in defence of the State. mical checks and metallurgical examination of plutonium-based By order of 18 March 2011, the interim relief judge rejected the products, processing of effluents and waste contaminated with suspension request, having considered it unfounded. alpha emitters. AREVA NC has been the industrial operator since 1994, initially in charge of operation and currently in As for the decree cancellation petition, it will undergo a second charge of decommissioning. From a regulatory standpoint, CEA examination by the Council of State in the coming months. nonetheless remains the nuclear licensee for these installations. Chemical purification laboratory (LPC) Because it was impossible to demonstrate the seismic resistance 1 of these facilities in accordance with the standards in effect , Operation of the LPC, which primarily served for the treat - AREVA NC ended the commercial activities of the ATPu in ment of effluents and the analysis of the ATPu production, August 2003. Since then, CEA has been involved in a final was stopped in 2003. The operations for final cessation of shutdown and decommissioning process for the two installa - operations carried out as from 2003 consisted notably in tions. The corresponding application files, sent to ASN in 2006, removing the radioactive material present in the facilities by were the subject of a public inquiry at the beginning of the emptying and rinsing the effluent tanks and treatment equip - summer of 2008 and resulted in the Official Gazette publishing ment. final shutdown and decommissioning decrees 2009-262 and 2009-263 on 6 March 2009. The final shutdown and decommissioning decree for the LPC, dated 6 March 2009, provides for six steps: The first step, of A first phase consisted in recovering and packaging the manu - an estimated duration of seven years, is currently under way. facturing discards and the materials contained in the ATPu and the Chemical Purification Laboratory (LPC.) This phase, which It consists in removing the first containment barrier within is necessary to reduce the risks inherent in these materials prior which the nuclear material was prepared.

1. The unsatisfactory resistance of the ATPu to the reference earthquake was confirmed by the complementary safety assessment (CSA) requested by ASN further to the Fukushima accident in March 2011 and submitted by the CEA in September 2011. This CSA confirmed the need to decommission and clean-out this facility as early as possible and plans for additional emergency management measures.

432 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

Schematic diagram of the LPC cryogenic processing unit

The decree of 6 March 2009 included two stopping points for final shutdown are currently being carried out (BNI 35, this step, subject to the prior agreement of ASN, relative firstly BNI 72 and BNI 50). to the decommissioning of the cryogenic processing unit, and secondly to the active tanks and associated equipment. High activity laboratory (LHA) (BNI 49) On 20 October 2011 ASN took two decisions, firstly to par - The high level activity laboratory (LHA) comprises several tially lift the stopping point concerning decommissioning of laboratories intended for research into or production of various the active tanks, and secondly to totally lift the stopping point radionuclides. On completion of the decommissioning for decommissioning of the cryogenic processing unit. These and clean-out work authorised by decree 2008-979 of decisions also include additional requirements, relating in 18 September 2008, published in the Official Gazette on particular to safety and the prevention of criticality risks in 21 September 2008, only two laboratories should remain under the tank decommissioning operations . the ICPE system by 2018. Dismantling work on the active effluent inter-cell tanks is continuing. 2 I 2 I 4 The Saclay centre installations undergoing ASN has asked the licensee to improve monitoring of the decommissioning outside contractors who are carrying out all the decommis - sioning work . The site decommissioning plan includes two BNIs that are definitively shut down, two ICPEs (Installations Classified on ULYSSE reactor (BNI 18) Environmental Protection Grounds), namely EL2 and et EL3, which were previously BNIs but which have not been comple - Built in 1961 in the CEA Saclay centre, this reactor was used for tely dismantled due to the absence of a disposal route for teaching and experimental purposes. Operating authorisation HLW-LL waste, and three BNIs in operation but with sections was granted on 16 June 1967. The total energy delivered in having ceased their activity in which operations to prepare for operation is around 115 MWh, which is low. The end of reactor

433 operation was declared on 9 February 2007, and the final shut - BNI 33, 38 and ELAN IIB (BNI 47) : down and decommissioning application was filed with the – AT1 pilot reprocessing plant MSNR (Nuclear Safety and Radiation Protection Mission) in June The AT1 pilot plant reprocessed fuel from the RAPSODIE and 2009. ASN gave its opinion in 2010, considering that the file PHÉNIX fast breeder reactors from 1969 to 1979. It is part of was admissible, but asked that some additional information be BNI 38 (STE2). integrated before the public inquiry. The file is currently being Clean-out of this installation began in 1982 and ended in reviewed. 2001, at which time ASN formally acknowledged completion of clean-out, civil engineering structures excluded, and entry CELIMENE cell (BNI 50) into surveillance status. This installation is not however deli - censed as its complete decommissioning will be part of the The CELIMENE cell, adjoining the EL3 reactor, was commis - decommissioning application for the UP2 400 plant as a sioned in 1965 for review of the fuels from this reactor. This whole. cell is now attached to the spent fuel testing laboratory – Caesium-137 and strontium-90 source fabrication installation (LECI). The last fuel rods were removed in 1995 and a num - (ÉLAN IIB). ber of partial clean-out operations conducted until 1998. The ÉLAN IIB (BNI 47) installation manufactured caesium-137 Experimental clean-out methods using the ASPILASER tech - and strontium-90 sources until 1973. The initial decommis - nique were tested in this cell in 2009. sioning operations undertaken by the Technicatome firm ended in November 1991. A large number of renovation and maintenance operations took place during 2002 and 2003 2 I 3 AREVA installations (upgrading of the ventilation system, radiological mapping, etc.) with a view to resuming decommissioning operations. All the installation upgrade work and the work preparatory to 2 I 3 I 1 The spent fuel reprocessing plant UP2 400 and the decommissioning of the installation was carried out during associated facilities 2004 and 2005. In October 2008, AREVA NC submitted three final shutdown UP2 400 spent fuel reprocessing plant and associated and decommissioning authorisation applications for BNIs 33 facilities (UP2 400), 38 (STE2 and AT1 facility) and 47 (ELAN IIB). Further to the examination conducted by ASN, these files were HAO / Sud (High Activity Oxide / South) (BNI 80): judged inadmissible by the ministers in charge of nuclear safety 2. AREVA thus made a number of additions to its files in The situation of UP2 400 is described in chapter 13. The November and December 2009. former UP2 400 reprocessing plant and the associated facilities (BNI 33, 38, 47 and 80), which have been shut down since In a letter dated 13 January 2010, the ministers in charge of 2004, are scheduled for decommissioning. nuclear safety, on the basis of ASN’s proposal, judged these files admissible. The public inquiry was held from 27 September to The final shutdown and decommissioning application file for 27 October 2010, and concluded with a favourable opinion BNI 80 (HAO) was submitted at the beginning of 2008. The from the inquiry commissioners. final shutdown and decommissioning decree for this faci lity, dated 31 July 2009, was published in the Official Gazette on On completion of the technical examination of the files submit - 4 August 2009. This decree provides for three steps. The first ted by the licensee, the Advisory Committee of Experts for step, planned to continue until the end of 2015, is in progress. plants (GPU) examined the possible conditions for authorising It aims at carrying out the majority of the decommissioning decommissioning of these facilities, at its meeting of 23 March operations of the HAO / South facility, while the HAO / North 2011. The GPU indicates in its opinion sent on 20 April 2011 facility, still in operation, is to be decommissioned in a second phase. that the decommissioning measures defined by AREVA NC dis - play nothing unacceptable from the point of view of safety, The abovementioned final shutdown and decommissioning radiation protection or the management of waste and effluents. decree of 31 July 2009 provides for four stopping points that The opinion of the GPU nevertheless reveals the need for the are subject to prior ASN agreement. operator to provide a large number of complementary studies, particularly with respect to the risks associated with earth - The first of these stopping points concerns the recovery and quakes and the feasibility and safety of certain legacy waste packaging operations for the waste contained in the HAO silo recovery and packaging operations. and in the organised disposal of hulls (SOC). Between July and December 2010, the licensee sent ASN a set of files relative to These decommissioning files are currently being examined. the safety of these operations, which are subject to a technical examination. COMURHEX plant of Pierrelatte (BNI 105) A first draft decision on the partial lifting of this stopping point Since 1961, the activity of the COMURHEX Pierrelatte plant on is currently being prepared. the Tricastin nuclear platform has been the chemical conversion

2. It is the MSNR (Nuclear Safety and Radiation Protection Mission) within the Ministry of Ecology, Sustainable Development, Transport and Housing, that delivers the decisions, based on the ASN proposal.

434 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

The HAO facility (AREVA)

of uranium (fluorination of uranium tetrafluoride, UF 4, into administrative tracking and regulation of the facilities, currently uranium hexafluoride, UF 6). This step precedes the enrichment ensured by the DREAL (Regional Directorate for the of UF 6 carried out by EURODIF. Environment, Planning and Housing) for the ICPEs, and ASN for the BNI. In addition, this situation is not in conformity with The COMURHEX Pierrelatte plant comprises several facilities the provisions of the TSN act, which in such cases provides for with different administrative statuses: there are ICPEs ensuring all the facilities to be included within the perimeter of the BNI, the fluorination of natural uranium, and BNI 105 which fluori - and for ASN to regulate all the facilities, including the ICPEs. nates reprocessed uranium. This BNI definitively stopped operation at the end of 2008. Consequently, to bring the administrative situation of BNI 105 into conformity with the applicable requirements, ASN deci - A project for the creation of a new BNI to take over from BNI ded in October 2011 to propose a draft decree to the ministers 105 is being studied. responsible for nuclear safety, modifying the perimeter of BNI In May 2011, at the request of ASN, the BNI 105 licensee sub - 105 in order to include all the site’s facilities in it. mitted a final shutdown and decommissioning application file. ASN judged this file inadmissible, mainly due to the inade - quacy of the impact study. 2 I 3 I 2 SICN plant in Veurey-Voroize Moreover, the coexistence on the same site of a BNI and various Two nuclear installations, BNIs 65 and 90, located on the site of ICPEs displaying associated risks and possessing a number of the SICN company (AREVA group) in Veurey-Voroize, constitute common equipment items, considerably complicates this former nuclear fuel fabrication plant. Fuel fabrication ceased

435 definitively at the beginning of the years 2000. Final shutdown (RUS - BNI 44) at Louis Pasteur University was mainly used operations took place between 2000 and the end of 2005. The for experimental irradiations and the production of short- decrees authorising the decommissioning operations were lived radioisotopes. signed on 15 February 2006 and published in the Official The decree authorising Louis Pasteur University in Strasbourg Gazette on 22 February 2006, thereby allow the operations to to proceed with final shutdown and decommissioning was start. published in the Official Gazette of 22 February 2006. The civil engineering structural clean-out operations continued Decommissioning work began in the second half of 2006 and in 2010. On completion of these operations it was possible to ended in mid-2009. In 2010, ASN continued its review of the delicense a large number of areas from the waste zoning view - file for the installation to be removed from the list of BNIs. point. Nonetheless, the licensee had to deal with a number of Pursuant to the TSN Act, ASN consulted the Government ser - problems with implementing its complete clean-out methodo - vices, the 21 municipalities situated within less than five logy, because some of the older design buildings were incompa - kilometres of the installation, and the CLI which was institu - tible with easy and optimum use of this methodology. The stra - ted in July 2010 by the Conseil Général of the Bas-Rhin dépar - tegy has therefore changed and entails the dismantling of tement . An institutional control to maintain a record that a certain buildings on the site, contrary to what had been initially BNI was operated on the land, should be signed before deli - planned in the project. censing of the facility is declared. The review of the file describing the management strategy for the site floors and soils, polluted by the former activities, has 2 4 2 The Electromagnetic radiation laboratory resulted in steps being taken to determine the nature of the ins - I I titutional controls that will be put in place during adminis - The electromagnetic radiation laboratory (LURE), located at the trative delicensing of the BNIs. heart of the Orsay campus (Essonne département ), is an installa - tion producing synchroton radiation (high-power X-rays) for a The inspections carried out by the ASN in 2010 revealed a lack wide variety of research applications. It comprises six particle of rigour in the monitoring of the decommissioning worksites. accelerators. During the inspections carried out in 2011, ASN had samples In January 2007, following a final shutdown preparation phase taken from the soils and ground water in order to assess the that lasted from 2004 to 2008, the LURE licensee, the CNRS level of radiological and chemical contamination of the areas (French National Centre for Scientific Research) submitted an outside the site. These analyses are in progress. application for authorisation to decommission its installation, During one of these inspections, pipes that still contained with the exception of the CLIO and PHIL accelerators, which contaminated effluents were discovered, necessitating additio - are to be kept in operation. Review of this application resulted nal work to eliminate these structures. At the request of ASN, in MAD-DEM (final shutdown and decommissioning) decree the licensee notified a significant event further to this discovery. 2009-405 dated 14 April 2009. As the decommissioning work has not been completed, ASN The decommissioning operations were completed in 2010, considers that delicensing of the facilities cannot be envisaged though two particular areas present residual activity linked to in their present state. Delicensing could be envisaged in 2012 the presence of the electron converters and have not been com - after completing the works, subject to confirmation by appro - pletely cleaned out, to maintain the stability of the building. priate radiological measurements that the clean-out objectives The licensee submitted its decommissioning file in spring 2011. have been achieved. ASN performed a delicensing inspection of the waste zoning which revealed the presence of radiological activity in a pipe. ASN asked the licensee to completely remove this piping. The 2 I 4 Others installations work was carried out during the 4th quarter of 2011. At the same time, institutional controls to restrict access to 2 4 1 The Strasbourg University reactor specific areas have been engaged with the Essonne département I I prefecture. Very similar in design and characteristics to the CEA ULYSSE reactor at Saclay, the Strasbourg University reactor

436 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

3 OUTLOOK The main actions ASN will carry out in 2012 will be firstly – continue examining the decommissioning applications and the continuing development of the regulatory framework for finalise its opinion concerning the draft final shutdown and decommissioning, and secondly closer monitoring of certain decommissioning (MAD DEM) decrees for the nuclear faci - installations. ASN will thus endeavour to finalise the guide to lities of the UP2 400 plant at La Hague; the clean-out of polluted soils on sites undergoing decommis - – reviewing the preparatory operations for final shutdown of sioning, and, after publication of the BNI order, to finalise the the installations that will soon be shut down and decom - revision of the guide relating to complete clean-out methodo - missioned (PHÉNIX, COMURHEX, EURODIF). logies. The announcement of the pushing back of several decommis - In 2012, ASN will continue its inspections of installations sioning deadlines has led ASN to ask the CEA for an interim undergoing decommissioning. It will focus in particular on: report on the updating of its decommissioning strategy (see – examining the complete decommissioning authorisation point 2 ⏐2). ASN will endeavour to examine the information application for the Brennilis NPP; communicated by the CEA as part of this update.

APPENDIX 1: LIST OF BASIC NUCLEAR INSTALLATIONS DELICENSED AS AT 31.12.2011

Installation Type of Commis- Final Last BNI Current status Location installation sio ned shutdown regulatory acts

NEREIDE (former BNI 10) Reactor 1960 1981 1987: Removed from BNI list Decommissioned FAR* CENTRE (500 kWth)

TRITON (former BNI 10) Reactor 1959 1982 1987: Removed from BNI list and classified Decommissioned FAR* CENTRE (6.5 MWth) as ICPE

ZOÉ (former BNI 11) Reactor 1948 1975 1978: Removed from BNI list and classified Confined (museum) FAR* CENTRE (250 kWth) as ICPE

MINERVE (former BNI 12) Reactor 1959 1976 1977: Removed from BNI list Dismantled at FAR* and re- FAR* CENTRE (0.1 kWth) assembled at Cadarache centre

EL 2 (former BNI 13) Reactor 1952 1965 Removed from BNI list Partielly decommissioned, SACLAY CENTRE (2.8 MWth) remaining parts confined

EL 3 (former BNI 14) Reactor 1957 1979 1988: Removed from BNI list and classified Partielly decommissioned, SACLAY CENTRE (18 MWth) as ICPE remaining parts confined

PEGGY (former BNI 23) Reactor 1961 1975 1976: Removed from BNI list Decommissioned CADARACHE CENTRE (1 kWth)

CÉSAR (former BNI 26) Reactor 1964 1974 1978: Removed from BNI list Decommissioned CADARACHE CENTRE (10 kWth)

MARIUS (former BNI 27) Reactor 1960 IN 1983 1987: Removed from BNI list Decommissioned CADARACHE CENTRE (0.4 kWth) MARCOULE , 1964 IN CADARACHE

LE BOUCHET (former BNI 30) Ore 1953 1970 Removed from BNI list Decommissioned processing

GUEUGNON (former BNI 31) Ore 1965 1980 Removed from BNI list Decommissioned processing

STED BNI 34 Processing of BEFORE 1964 2006 2006: Removed from BNI list Integrated into BNI 166 FAR* CENTRE liquids and solid waste

437 APPENDIX 1: LIST OF BASIC NUCLEAR INSTALLATIONS DELICENSED AS AT 31.12.2011 Installation Type of Commis- Final Last BNI Current status Location installation sio ned shutdown regulatory acts

HARMONIE (former BNI 41) Reactor 1965 1996 2009: Removed from BNI list Destruction of ancillaries CADARACHE (1 kWth) building

ALS (former BNI 43) Accelerator 1958 1996 2006: Removed from BNI list Cleaned-out – institutional controls***

SATURNE (former BNI 48) Accelerator 1966 1997 2005: Removed from BNI list Cleaned-out – institutional controls***

ATTILA** (former BNI 57) Reprocessing 1968 1975 2006: Removed from BNI list Integrated into BNIs 165 FAR* pilot and 166

LCP u (former BNI 57) Plutonium 1966 1995 2006: Removed from BNI list Integrated into BNIs 165 FAR* CENTRE chemistry laboratory and 166

BAT 19 (former BNI 58) Plutonium 1968 1984 1984: Removed from BNI list Decommissioned FAR* CENTRE metallurgy

RM2 (former BNI 59) Radio-metallurgy 1968 1982 2006: Removed from BNI list Integrated into BNIs 165 FAR* CENTRE and 166

LCAC (former BNI 60) Fuels 1975 1984 1997: Removed from BNI list Decommissioned GRENOBLE CENTRE analysis

STED s (former BNI 73) Radioactive waste 1989 2006: Removed from BNI list Integrated into BNI 166 FAR* CENTRE decay storage

ARAC SACLAY (former BNI 81) Fabrication of fuel 1981 1995 1999: Removed from BNI list Cleaned-out CENTRE assemblies

IRCA (former BNI 121) Irradiator 1983 1996 2006: Removed from BNI list Cleaned-out, institutional controls***

FBFC PIERRELATTE (former BNI 131) Fuel fabrication 1990 1998 2003: Removed from BNI list Cleaned-out, institutional controls***

SNCS OSMANVILLE (former BNI 152) Ioniser 1983 1995 2002: Removed from BNI list Cleaned-out, institutional controls***

MAGASIN (former BNI 134) Uranium bearing 1964 2004 2007: Removed from BNI list Cleaned-out, institutional D’URANIUM materials controls*** MIRAMAS warehouse

SILOETTE GRENOBLE (former BNI 21) Reactor 1964 2002 2007: Removed from BNI list Cleaned-out, institutional CENTRE (100 kWth) controls***

MÉLUSINE (former BNI 19) Reactor (8 MWth) 1958 1988 2011: Removed from BNI list Cleaned-out GRENOBLE CENTRE

(*) FAR: Fontenay-aux-Roses – (**) Attila: reprocessing pilot located in a unit of BNI 57 – (***) Private law documents have been signed by the State and the licensee for the cleaned out parcels, to conserve a record of the former nuclear activity.

438 CHAPTER 15 SAFE DECOMMISSIONING OF BASIC NUCLEAR INSTALLATIONS (BNIs)

APPENDIX 2: LIST OF BASIC NUCLEAR INSTALLATIONS UNDERGOING DECOMMISSIONING AS AT 31.12.2011

Installation Type of Commis- Final Last BNI Current status Location installation sio ned shutdown regulatory acts

CHOOZ AD 163 Reactor 1967 1991 2007 : Final shutdown Decommissioning in progress (FORMERLY-CHOOZ A) (former BNI 1, 2, 3) (1,040 MWth) and decommis sioning decree

CHINON A1D 133 (former BNI 5) Reactor 1963 1973 1982: Chinon A1 confinement decree and Partially decommissioned, (FORMERLY- (300 MWth) creation of the Chinon A1D storage BNI changed into a BNI for storing CHINON A1) waste left in place (museum)

CHINON A2D 153 (former BNI 6) Reactor 1965 1985 1991: Partial decommissioning decree for Partially decommissioned, (FORMERLY- (865 MWth) Chinon A2 and creation of the Chinon A2D changed into a BNI for storing CHINON A2) storage BNI waste left in place

CHINON A3D (FOR - 161 (former BNI 7) Reactor 1966 1990 2010 : Decommissioning decree Decommissioning in progress MERLY-CHINON A3) (1,360 MWth)

SILOÉ GRENOBLE 20 Reactor (35 MWth) 1963 1997 2010: Modification of final shutdown and Decommissioning in progress decommissioning decree

RAPSODIE 25 Reactor (40 MWth) 1967 1983 Preparation for final shutdown CADARACHE

EL 4D (FORMERLY- 162 Reactor 1966 1985 1996: Decree for decommissioning and Partially decommissioned, EL4 BRENNILIS) (former BNI 28) (250 MWth) creation of the EL 4D storage BNI 2006: changed into a BNI for storing final shutdown and decommissioning waste left in place. decree 2007: decision of the Conseil d’État / Decommissioning in progress State Council cancelling the decree again. of 2006 2011: Partial decommissioning decree

SPENT FUEL 33 Transformation 1964 2004 2003: Boundary change Preparation for final shutdown REPROCESSING of radioactive PLANT (UP2) materials (LA HAGUE)

STED AND HIGH 36 and 79 Waste treatment 1964/1972 2008 2008 : Final shutdown Decommissioning in progress LEVEL WASTE and storage facility and decommis sioning decree STORAGE UNIT (GRENOBLE)

EFFLUENT AND 38 Effluent and waste 1969 1979 Preparation for final shutdown SOLID WASTE treatment facility TREATMENT STATION (STE2) AND FORMER PILOT REPROCESSING PLANT FOR SPENT FUEL FROM FAST NEUTRON REACTORS (AT1) (LA HAGUE)

439 APPENDIX 2: LIST OF BASIC NUCLEAR INSTALLATIONS UNDERGOING DECOMMISSIONING AS AT 31.12.2011

Installation Type of Commis- Final Last BNI Current status Location installation sio ned shutdown regulatory acts

STRASBOURG 44 Reactor 1967 1997 2006 : Final shutdown and Decommissioning in progress UNIVERSITY (100 kWth) decommissioning decree REACTOR

BUGEY 1 45 Reactor 1972 1994 2008 : Final shutdown and Decommissioning in progress (1,920 MWth) decommissioning decree

ST-LAURENT A1 46 Reactor 1969 1990 2010 : Decommissioning decree Decommissioning in progress (1,662 MWth)

ST-LAURENT A2 46 Reactor 1971 1992 2010 : Decommissioning decree Decommissioning in progres (1,801 MWth)

ÉLAN II B LA HAGUE 47 Fabrication of 1970 1973 Preparation for final shutdown Cs 137 sources

HIGH ACTIVITY 49 Laboratory 1960 1996 2008 : Final shutdown and Decommissioning in progress LABORATORY (LHA) decommissioning decree SACLAY

ATUE CADARACHE 52 Uranium Processing 1963 1997 2006 : Final shutdown and Decommissioning in progress decommissioning decree

LAMA GRENOBLE 61 Laboratory 1968 2002 2008 : Final shutdown and Decommissioning in progress decommissioning decree

SICN VEUREY- 65 and 90 Fuel fabrication 1963 2000 2006 : Final shutdown and Decommissioning in progress VOROIZE plant decommissioning decree

HAO (HIGH LEVEL 80 Transformation 1974 2004 OXIDE) FACILITY of radioactive Decommissioning in progress (LA HAGUE) materials

ATP u CADARACHE 32 Fuel fabrication 1962 2003 2009 : Final shutdown and Decommissioning in progress plant decommissioning decree

LPC CADARACHE 54 Laboratory 1966 2003 2009 : Final shutdown and Decommissioning in progress decommissioning decree

SUPERPHÉNIX 91 Reactor 1985 1997 2009 : Final shutdown and Decommissioning in progress CREYS-MALVILLE (3,000 MWth) decommissioning decree

COMURHEX 105 Uranium chemical 1979 2009 Preparation for final shutdown PIERRELATTE Transformation plant

LURE 106 Particle accelerators FROM 1956 2009 : Final shutdown and Decommissioning in progress TO 1987 2008 decommissioning decree

FAR* CENTRE 165 Grouping of former 2006 2006 : Final shutdown and Decommissioning in progress PROCESS process installations decommissioning decree

FAR* CENTRE 166 Waste packaging 2006 2006 : Final shutdown and Decommissioning in progress SUPPORT and processing decommissioning decree

(*) Fontenay-aux-Roses : création des INB 165 et 166, en substitution aux INB 34,57,59 et 73 et mise en œuvre des opérations de mise à l’arrêt et de démantèlement des INB 165 et 166 suite au regroupement de bâtiments dans le cadre du projet de dénucléarisation du site de Fontenay aux Roses. 440