REGULATORY CHALLENGES IN RELATION TO URANIUM LEGACY IN FRANCE

Transcription

1 REGULATORY CHALLENGES IN RELATION TO URANIUM LEGACY IN FRANCE AIEA RLS Workshop Grand Junction (Colorado, US) August 21-24, 2012 Presented by Marie-Odile GALLERAND & Jérôme GUILLEVIC Système de management de la qualité IRSN certifié

2 Content Short presentation of IRSN The French situation regarding nuclear activities / focus on uranium mining The French regulation Technical issues relative to uranium post-mining activities

3 Short presentation of IRSN Role Public expert body in charge of the scientific and technical assessment related to nuclear and radiological risks Expertise is based on research Key features Public body reporting to 5 ministers: Environment, Industry, Health, Defence, Research Research, expertise and public service mission 1,675 specialists: researcher, doctors, post-doctoral students A budget of 290 M, financed up to 82% by public funding 11 locations in France, including 3 major sites: Clamart/Fontenay-aux-Roses, Cadarache, Le Vésinet

4 The French situation regarding nuclear activities The French situation regarding nuclear activities with a focus on uranium mining

5 The French situation regarding nuclear activities The French nuclear background An historic and political Choice after the 2 nd world war A strategic choice for energy independence and for military reasons The complete fuel cycle Nuclear question is a very sensitive issue Problem of transparency and Public information (Tchernobyl syndrom) Perception of danger Democratic choice of Energy COMURHEX Concentré d oxyde d uranium EURODIF Autunite Centrale nucléaire EDF Site minier

6 The French situation as regards nuclear activities GRAVELINES BASIC NUCLEAR INSTALLATIONS PENLY MAUBEUGE Basic Nuclear Installation LA HAGUE BRENNILIS (Monts d Arrée) MANCHE FLAMANVILLE PALUEL SACLAY CHOOZ FONTENAY-AUX-ROSES NOGENT 300 MW AUBE CATTENOM STRASBOURG Pressurized water reactors Fuel cycle facilities Other reactors Effluent and waste treatment plants Laboratories, maintenance facilities Accelerators, irradiators Declassified units Fast neutron reactors Waste repositories St- LAURENT CHINON CIVAUX LE BLAYAIS GOLFECH DAMPIERRRE FESSENHEIM BELLEVILLE BUGEY CREIS-MALVILLE St- ALBAN VEUREY GRENOBLE ROMANS CRUAS TRICASTIN MARCOULE CADARACHE REACTORS IN SERVICE REP 900 Mwe 1300 Mwe 1400 Mwe GAZ COOLED REACTOR HEAVY WATER FAST NEUTRONS FUEL CYCLE FACILITIES WASTE REPOSITORIES DECOMMISSIONED UNIT LABORATORIES REACTORS

7 The French situation as regards nuclear activities ORGANISATIONS PLAYING AN ACTIVE PART IN NUCLEAR ACTIVITIES Operators (EDF, CEA, AREVA...) Processing contractors (SOCODEI, AREVA...) Interim storage or disposal centre operators (CEA, EDF, ANDRA...) Organisations responsible for research and development (CEA, ANDRA...) Each entity is responsible for the safety of its own activities

8 The French situation regarding nuclear activities A focus on uranium mining in France Current situation 230 mine sites A M C N E H Working period : LIGNOL PARIS STRASBOURG TEUFELSLOCH ET SCHAENTZEL tons of U 17 tailings disposals Tailings :~ tons O C PEN AR RAN E A N A T L A N T I C U E NANTES L'ECARPIERE LA COMMANDERIE LE BERNARDAN RIBIERE BESSINES BELLEZANE MONTMASSACROT LE FRAISSE MARGNAC FANAY ROPHIN BORDEAUX St PIERRE du CANTAL LA BESSE LE CELLIER BERTHOLENE BAUZOT GUEUGNON BOIS NOIRS LIMOUZAT LYON LES PIERRES PLANTEES LES BONDONS Rehabilitation work period : LODEVE MARSEILLE BASTIA Km M E R M E D I T E R R A N E E AREVA/NC August 2012 AIEA RLS Workshop Grand Junction (Colorado, US) August Grand 21-24, Junction 2012 Workshop 8 - REGULATORY CHALLENGES

9 The French regulation Overview of the French regulatory framework and organisation Regulation in effect concerning uranium mining and post-mining activities The recent circular dated July 2009 requiring the continuation of the management of the former uranium mine sites

10 Overview of the French regulatory framework and organisation Regulatory framework Codes Legislative domain Laws THE REGULATORY PYRAMID Parliament The Mining code The Environmental code The Public Health code. Regulatory domain Decrees Ministerial orders Circulars Executive authorities Standards system Option letters Basic safety rules (RFS) Industry Design and construction rules Codes and standards

11 Overview of the French regulatory framework and organisation Regulatory framework GOVERNMENTAL AUTHORITIES ASN/DSNR, ministry of environment Authorizations Checks Reports OPERATOR DESIGNERS BUILDERS RESEARCH ASSESSMENT EVALUATION IRSN

12 ICPE regulation Framework : Repositories Mining code regulation Framework : Mines The French regulation Overview of the French regulatory framework and organisation Regulatory framework AUTHORITIES : Ministry of environment and ASN BNI regulation Framework : All the installations of the fuel cycle AUTHORITIES : Nuclear safety Authority (ASN) Autunite Mining site

13 The French regulation Overview of the French regulatory framework and organisation Regulation in effect concerning uranium mining and post-mining activities The recent circular dated July 2009 requiring the continuation of the management of the former uranium mine sites

14 Regulation in effect concerning uranium mining and post-mining activities Uranium mining and milling regulatory framework National level Mining code Public Health code Environment code Laws and decrees Authorities : Ministry of Environment and Nuclear Safety Authority Local level Licence and site-specific regulatory requirements Authorities : Prefect of region, local technical support organisation (DRIRE/DREAL)

15 Regulation in effect concerning uranium mining and post-mining activities Uranium mining and milling regulatory framework Mining code Environment code Exploration Exploitation site ORES Treatment ICPE Yellow cake Public Health code Rehabilitation Mill taillings ICPE

16 Regulation in effect concerning uranium mining and post-mining activities Uranium mining and milling regulatory framework At national level The mining code Set the rules for Uranium ore mining works and facilities Is complemented by two decrees 1980 General Rules applicable to mining and quarrying industries (RGIE) 1990 Specifies technical rules relative to environmental protection : management of radioactive materials ; discharge authorisation ; environment monitoring and control completed by additional requirements : the Environment Code (for ICPE) the Public Health Code (protection of the population) based on EURATOM directive and include the (ICRP) principles At local level National regulations give rise to compliant local regulations taken by the local authorities (Prefect)

17 Regulation in effect concerning uranium mining and post-mining activities Uranium mining and milling regulatory framework M I N I N G C O D E Mining sites Start : Mining license (for research, exploration and mining), Decree (ministry) Suspension of mining operations (application file submitted by the operator) site E N V N T C O D E : I C P E Tailings disposals Start : Authorisation :impact studies, administrative instructions Local Authority order Renouncement to the concession by the operator End of the mining claim Rehabilitation and survey

18 Regulation in effect concerning uranium mining and post-mining activities Uranium mining and milling regulatory framework Document required for any modification of on site industrial activities study analysing the impact of the project on the environment. the initial state of the site and of the environment the direct/indirect, temporary /permanent effects of the facility on the environment the reasons for which, the project was selected among possible solutions the planned measures to reduce or compensate any inconvenience induced by the facility a risk analysis, (description of likely accidents due to potential external causes) ; a management plan to limit the radiological impact on the environment ; a monitoring plan.

19 Regulation in effect concerning uranium mining and post-mining activities Uranium mining and milling regulatory framework Evolution of the regulation In 1980 and 1993, and 1999 ministry of environment issued several documents to define fundamental concepts applicable to the final closure of mill tailings disposals and give the objectives and technical requirements for long term in 2001, in support of the recommandations of the ministry methodological documents have been prepared by institutional technical supports (IRSN and BRGM) Méthodologie d évaluation de la stabilité des digues à stériles uranifères - Application à deux sites pilotes 2001 Expertise de la méthode COGEMA d identification et de caractérisation des groupes de référence associés aux anciens sites miniers 2001

20 Regulation in effect concerning uranium mining and post-mining activities Uranium mining and milling regulatory framework Evolution of the regulation A new circular dated July, 2009, signed jointly by ASN (the Safety Authority) and the Ministry of the Environment, relative to the management of the former uranium mines in France Define a plan of actions to pursue the management of the former uranium mines Address to the local authorities (DRIRE) Involve many actors (operator, IRSN ) 1. Control the former sites 2. Improve the knowledge of the environmental and health impact and improve monitoring programs 3. Manage the waste rock transferred to the public domain : purpose and impact assessment if necessary 4. Strengthen information and dialogue

21 Regulation in effect concerning uranium mining and post-mining activities Uranium mining and milling regulatory framework Evolution of the regulation The TSN Act (Nuclear Transparency and Security act.) In 2006, the French government decided to reinforce the regulation regarding transparency and public information through the TSN Act Aim : overhauls in depth the legal framework applicable to nuclear activities and their control, by creating ASN as an independent administrative authority and including several improvements regarding transparency Content and basic principles : Prevention, precaution, public participation and the polluter-pays Consolidation of the major radiation-protection principles: justification, optimisation and limitation Statement concerning the fundamental principle involving the primary responsibility of operators with regard to the daily safety of their facilities (a clarification of operators and the regulatory authority of their respective responsibilities).

22 : Key points There is still an owner (and responsible) for most of the sites : easier for management of those sites and memory A structured (but complex) regulation (national and local) adapted to the situation and operational staff (visit and inspections) Necessary evolution of the regulation in relation to the activities and the issues (mining or rehabilitation works, increase of the knowledge, and social demand) Feedback experience, technical analysis Is it enough? Sure No : a lot to learn and do! (Long term issues, public information.)