Public consultation on safety enhancements to France's fleet of 900-MWe reactors on the occasion of their 4th periodic safety review

What is the scope of this consultation ?

The service life of France’s nuclear facilities is not limited by their operating licence. However, French legislation requires each facility to undergo a 10-yearly safety review. After reviewing the licensee’s report, France’s nuclear regulator (ASN), an administrative and independent authority that oversees France’s nuclear facilities, sends the Government its conclusions on the facilities’ safety status and on their fitness (or lack thereof) for continued operation.

The periodic safety review serves a dual purpose: 

  • Conducting an in-depth examination of the facility that takes account of ageing phenomena in order to verify its compliance with current safety standards;
  • Enhancing safety standards by capturing operating experience and implementing design upgrades that have been incorporated into the most recent reactors. 

EDF reactors:

The periodic safety-review process comprises a number of stages:

  • A generic phase during which the licensee prepares a "Fulfilment Report" that outlines the review scope for all reactors of a given reactor series. The regulator’s findings are informed by the content of this report.
  • · Implementation - reactor by reactor - of the enhancements determined upon completion of the initial phase, which finishes after the 10-yearly inspection with the licensee submitting a report setting out the review findings.

The regulator then reaches a conclusion as to the conditions under which the reactors may be allowed to continue operating.

As of the 4th safety review of nuclear power reactors:

Legislation on the energy transition for green growth, passed on 17 August 2015, demands the systematic conduct of a public enquiry into the arrangements put forward by the licensee for the life extension of its nuclear reactors after 35 years of operation.

In France, nuclear power reactors that were commissioned in the 1980s will shortly have to undergo their 4th periodic safety review. This review concerns the 900-MWe reactor fleet.

The first reactor to undergo this review is reactor no. 1 at Tricastin nuclear power plant. The report setting out the findings of this review will be submitted in 2020.

Prior to the public enquiries that will be conducted for each of the reactors in question, the High Committee for Transparency and Information on Nuclear Safety (HCTISN) has decided to hold a public consultation specifically for the generic phase, even though this is not explicitly required by legislation, thereby enabling the public to get involved in the decision-making process relating to the life extension of France’s 900-MWe reactors after 40 years of operation. 

The 40-year milestone is based on technical assumptions for the initial design basis of certain reactor components.

As part of this consultation, the public is invited to express its views on the arrangements put forward by EDF during the generic phase of the 4th periodic safety review of its 900-MWe reactors, set out in a “Fulfilment Report" with a view to extending the service life of France’s 900-MWe reactors after 40 years of operation.

Members of the public may provide feedback in response to the consultation up until the end of March 2019.

Once the generic phase of the 4th periodic safety review has been completed, the regulator will issue a set of findings, the draft of which will also undergo a public consultation. 


Focusing on the subject of plant safety, this consultation process will take place in parallel and in line with the revised Multi-year Energy Schedule (PPE) for the periods of 2019-2023 and 2024-2028. Directly resulting from a piece of legislation on the energy transition for green growth passed on 17 August 2015, this governance tool – developed for the oversight of France’s energy policy – sets out the public authorities’ priorities for the management of all energy Furthermore, the consultation is also being held concurrently with and independently of the public debate being led by the CNDP on the fifth version of France’s radioactive waste and materials management plan (PNGMDR). Stemming from a piece of framework legislation passed on 28 June 2006 and relating to the sustainable management of radioactive waste and materials, this plan seeks to review and improve existing arrangements for the management of radioactive waste and materials by setting new targets.


Who is organising the consultation ? 

Led by the HCTISN, the consultation is being organised by two specific bodies: one steering committee and one operational committee.

HCTISN

The High Committee for Transparency and Information on Nuclear Safety validates and assesses the process by ensuring that the consultation is conducted in keeping with the principles established to achieve a high level of public involvement.

Steering committee

Comprising 5 members selected by the HCTISN, the steering committee establishes the consultation process and provides direction for its implementation.

It regularly reports to the HCTISN on the consultation’s progress.

Operational committee 

Composed of representatives from EDF, from France’s nuclear regulatory authority (ASN), from the French Institute of Radiation Protection and Nuclear Safety (IRSN) and from the French Association of Local Community Liaison Councils, the Operational Committee runs the consultation with support from a company specialising in communication and consultation processes.

It will also provide proper coordination of the public’s involvement in the period between the end of the consultation on the generic phase and the initial public enquiries on each individual reactor.

What guiding principles will be applied to the consultation process?

The High Committee for Transparency and Information on Nuclear Safety (HCTISN) has determined 10 principles for the coordination of the public consultation on the occasion of the 4th periodic reactor safety review. These principles include the following:

  • All inputs, regardless of where they come from, will be considered. Only those falling within the scope of the consultation will be addressed in depth.
  • The ASN, EDF and other interested parties will inform the public of the means by which they respond to observations made during the consultation, as well as of its outcome.

The set of principles established by the HCTISN are aligned with the general framework of public information and consultation as defined by article L. 120-1 of the environment code. A detailed description of these principles is provided on the HCTISN website.

What role do the guardians play in the consultation process ?

The consultation is being overseen by two guardians (Marianne Azario and Isabelle Barthe) who have been freely selected by the HCTISN from a national list of guardians drawn up by the national public debate commission (CNDP).

They are involved in the entire process. They ensure that the consultation is efficiently run by seeing that the public is provided with relevant information and that it is actively involved in the consultation by issuing observations and suggestions. They will also produce a consultation report, which will be posted on the HCTISN website.

Statements from the guardians:

"The consultation is an essential step in the decision-making process: it provides a forum for dialogue and for highlighting issues pertaining to the life-extension plan, topics of agreement/disagreement and crucial subjects, all the more importantly in consideration of the highly technical context coupled with societal challenges.

The arguments being discussed during the consultation should throw some light on subsequent public decisions.

We are hopeful that the process being led by the High Committee will encourage the public to seek information, challenge, hold discussions and put forward suggestions, either nationally via the "ad hoc" digital platform or locally within the affected regions.

In keeping with our role as independent guardians of the consultation process and of the principles that are inherent to environmental dialogue, we will be paying particular attention to the following aspects:

  • Quality and transparency of information
  • Adequacy of answers provided to questions asked
  • Freedom of expression
  • The rationale behind inputs 

The public can contact us at [email protected]ûreténucléaire.fr for any questions relating to the consultation process. We are not controlled by the HCTISN (organiser of the consultation), nor by the operator (EDF) or any other stakeholders.

We are not required to give an opinion on the content of the life-extension plan.

However, once the consultation is over, we will be required to write a report and issue a succinct summary of all inputs. This report will be made public and where appropriate, it will be used during subsequent phases of the public consultation such as the public enquiries conducted for each reactor in question."

Marianne Azario and Isabelle Barthe

How to take part, seek information or submit an opinion

Each citizen is invited to take part in this public consultation by seeking information, asking questions, submitting their opinions and viewpoints and by responding to discussions:

High Committee for Transparency and Information on Nuclear Safety (HCTISN)

The High Committee for Transparency and Information on Nuclear Safety (HCTISN) has decided to hold a public consultation on the occasion of the 4th periodic safety review of France’s 900-MWe nuclear power reactors, with a view to involving the general public in decisions regarding the life extension of these reactors after 40 years of operation.

The remit of the High Committee for Transparency and Information on Nuclear Safety is to inform the public, hold consultations and organise discussions on the risks associated with the activities of the nuclear industry and their impact on public health, environmental safety and nuclear safety.

Established in 2008, the founding of this committee marked a major milestone in the implementation of a piece of legislation pertaining to transparency and nuclear safety, passed on 13 June 2006. This committee plays an instrumental role in maintaining transparency and upholding the right to information on nuclear issues as required by the aforementioned legislation.

It is worth highlighting the multiplicity of representatives making up this independent committee. The High Committee comprises representatives of all stakeholders affected by issues relating to transparency and public information on nuclear matters:

  • Members of parliament (MPs appointed by the National Assembly and senators appointed by the Senate);
  • Representatives from local community liaison councils who work hand in hand with members of the public living close to nuclear facilities;
  • Representatives from environmental safety NGOs and from NGOs upholding the interests of health system users;
  • Representatives of persons in charge of nuclear activities;
  • Representatives from trade union organisations;
  • Personalities chosen for their scientific, technical, economic and/or social expertise, or for their expertise in information and communication, of which three have been selected by the Parliamentary Office of Science and Technology (OPECST), one by the Academy of Science and one by the Academy of Moral and Political Sciences;
  • Representatives from France’s nuclear regulatory authority (ASN), from specific State services, and from the French Institute of Radiation Protection and Nuclear Safety (IRSN).

Among its incumbent members who are appointed for a period of six years, four are MPs whilst six come from each of the remaining categories (not counting the “selected personalities”, a deputy is also appointed).

The High Committee may also issue a view on any matters pertaining to risks associated with nuclear activities and their impact on public health, environmental safety and nuclear safety. It may also address any issues pertaining to the accessibility of nuclear-safety-related information and recommend measures to maintain or improve transparency in this regard.

In recent years, it has been involved in a number of topical issues which have given rise to debate, such as those pertaining to abnormalities found on the Flamanville EPR reactor vessel or the management of very-low-level radioactive waste, with a view to ascertaining the comprehensive nature of the information provided to the public and the transparency exhibited with regard to these issues, as well as to involving the public in the attendant discussions. On its own initiative, the High Committee has been involved in discussions pertaining to conditions for the life extension of nuclear power plants after 40 years of operation by deciding to organise a public consultation in order to take account of the public’s opinions and queries relating to this issue.

The HCTISN considers that the consultation will be a resounding success if:

  1. The information provided to the public is both educational and appropriate;
  2. The public is actively involved and that adequate information and answers are provided in response to the public’s queries;
  3. The purpose of this consultation is to involve the public in discussions on the challenges and goals associated with the life extension of nuclear power plants after 40 years of operation and to throw light on subsequent decisions;
  4. The way in which inputs are addressed is transparently described, including how they inform decisions taken by the nuclear regulatory authority;
  5. Residents living close to nuclear power plants and the French public are better informed on the general subject of nuclear safety, as well as on arrangements for the potential life extension of the 900-MWe reactor fleet after 40 years of operation.

For more information: The High Committee's views and publications are posted on its website at www.hctisn.fr.

EDF's expectations with regard to the public consultation on the 4th period safety review

EDF, a responsible operator, is an instrumental player when it comes to promoting transparency and dialogue on the operation and nuclear safety of nuclear power plants.
Ever since local community liaison councils (CLI in French) were founded, EDF has been an active contributor to the councils representing the communities living near each of its nuclear sites. Its facilities open their doors to the public by receiving more than 100 000 visitors every year.

A 4th periodic safety review must be held in order to examine conditions for the life extension of the 900-MWe reactor fleet after 40 years of operation. Prior to the conduct of public enquiries required by legislation pertaining to the energy transition for green growth, EDF and France’s other nuclear-safety stakeholders have proactively undertaken to hold a consultation in which the public is invited to take part. For EDF, this unprecedented and novel initiative is an opportunity to boost the country’s trust by holding discussions on the subject of nuclear safety. As EDF stated on the occasion of the public debate on the Multi-year Energy Schedule (PPE), we are fully confident in our ability to safely extend the service life of our reactors after 40 years of operation. Whilst the life extension of nuclear power plants lies within the scope of France’s energy policy, the 4th set of periodic plant safety reviews will ensure that these facilities continue to be operated safely. During the consultation period, EDF will describe the safety enhancements it will be implementing on the occasion of the 4th periodic safety review. It will provide documents and educational material in order to share its knowledge of nuclear safety issues and enhancements with a broad spectrum of the general public. During this consultation period, EDF will highlight issues and proposals that will inform the 4th period safety review in order to achieve the intended objective: alignment with the nuclear-safety standards of the most advanced reactors.

ASN - The regulator's expectations

Founded by a piece of legislation passed on 13 June 2006 pertaining to nuclear safety and transparency, France’s nuclear regulatory authority is mandated by the state to oversee nuclear safety and radiation protection with a view to protecting the public and the environment. Another of its crucial roles is to keep the public abreast of these issues, including during emergency conditions, thereby helping the State to make informed societal choices.

An independent authority, the ASN has been mandated by the State to oversee nuclear safety and radiation protection with a view to protecting the public and the environment. Another of its roles is to keep the public abreast of these issues, including during emergency conditions, thereby helping the State to make informed societal choices. More specifically, the 11 regional regulatory divisions work closely together with the local community liaison councils, who interface with the country’s local populations.

The ASN allows all citizens to be involved in a fair number of its decisions affecting the environment (as required by article 7 of the environmental policy statement) or in those requiring its input. In 2017 for example, a public consultation was held for more than 80 draft decisions at www.asn.fr.

The ASN allows all citizens to be involved in a fair number of its decisions affecting the environment (as required by article 7 of the environmental policy statement) or in those requiring its input. In 2017 for example, a public consultation was held for more than 80 draft decisions at www.asn.fr.

Information on Nuclear Safety (HCTISN) set up a working group to examine viable public consultation arrangements. This working group recommended the conduct of a public consultation on the fulfilment report issued by EDF in preparation for the generic phase of the 4th periodic safety review of its 900-MWe reactors.

This consultation will provide an opportunity for sharing information with a broad spectrum of the public (local residents, knowledgeable members of the public, people with no nuclear knowledge), whilst at the same time identifying the public’s expectations with regard to nuclear safety and information, prior to the periodic safety review of each reactor. By providing input and feedback on EDF’s fulfilment report, the general public is invited to describe their perception of the risks and disadvantages that these nuclear reactors may pose for the public and the environment, of their acceptability and of the expected safety criteria for their continued operation.

During the consultation, the ASN will be helping the public to understand the related issues and highlight its expectations of the licensee. Based on the expectations expressed by the public, these different inputs will inform the regulator’s review and its decisions by taking account of the public’s nuclear-safety concerns.

This public consultation is the first in a series of exchanges with the public over the next ten years. In 2020, the regulator will issue its draft findings on EDF’s fulfilment report after consulting with the IRSN (its technical support branch) and with other expert groups. The arrangements established by EDF for the 4th periodic safety review of each 900-MWe reactor will also give rise to a public enquiry, the first of which will concern the findings relating to reactor no. 1 at Tricastin nuclear power plant. Last but not least, the ASN will hold a public consultation on the draft requirements it deems necessary for the continued operation of each reactor.

Expectations of the French Institute of Radiation Protection and Nuclear Safety

Through its involvement in the consultation being held for the 4th periodic safety review of France’s 900-MWe nuclear reactors, the IRSN intends to provide every member of the public with clear and objective insights resulting from its investigations, whilst also informing its own decisions by taking account of issues raised by stakeholders and the general public.

The IRSN offers a public service prior to the taking of public decisions: it assesses nuclear and radiological risks, as well as the means of mitigating these risks. In order to conduct its scientific and technical investigations, it carries out lengthy surveys and research work. The high standards of work produced by the IRSN are particularly due to its scientific and technical expertise, as well as its ability to independently conduct research and issue findings whilst avoiding conflicts of interest.

The transparency of its research work and public information are also an essential part of its contribution to risk control.

Public transparency is therefore one of the three key strategic principles enshrined in the Performance Agreement signed with the State.

The research and investigation work conducted by the IRSN is therefore shown to all stakeholders at both a local and national level. From the very outset of its investigation work pertaining to the 4th safety review of the 900-MWe reactor fleet, the IRSN resolved to exchange information with the general public. In 2017 and 2018, these exchanges took the form of technical meetings with the public, jointly organised with ANCCLI and the ASN, focusing on three key topics: ageing and compliance, internal and external hazards, severe accidents.

More specifically, these meetings enabled the IRSN to take account of the queries raised by participants. These queries will be addressed through findings that the Institute will submit with regard to the 4th periodic safety review.

All these findings will be made public. The public consultation will provide the IRSN with an opportunity to prolong the period of discussion by extending its scope to include all topics covered by the review and by opening these discussions up to a wider audience.

As far as the IRSN is concerned, only an integrated approach to risks and their interactions will be effective in achieving safety improvements.

This integrated approach will rely on real openness and active transparency in support of a risk-aware society.

Involvement of the French Association of Local Community Liaison Councils in the consultation process being held for the 4th safety review of 900-MWe reactors.

Through the proactive launch in 2017 of a public consultation on the generic phase of the 4th periodic safety review concerning the 900-MWe reactor series, the High Committee for Transparency and Information on Nuclear Safety (HCTISN) has taken a novel initiative and has taken a further step towards greater transparency with the intention of informing and listening to the general public by means of constructive dialogue, in order to capture the public’s opinions and queries on issues to be considered when deciding on the life extension of these reactors after 40 years of operation.

This consultation is novel and unprecedented for multiple reasons. Firstly, because it goes further than what is demanded by legislation and secondly owing to its proactiveness, its governance, its scope, its scale (nation-wide and on the 8 sites in question). And last but not least, because it is being overseen by 2 guardians from the National Public Debate Commission (CNDP).

It is for all these reasons that ANCCLI, upon the HCTISN’s request, immediately started taking part in discussions on the subject in order to put forward organisational recommendations on the public consultation for the 4th periodic safety review.

It intends to ensure that the 8 local community liaison councils involved in this process (Tricastin, Gravelines, Dampierre-en-Burly, Bugey, Blayais, Saint-Laurent-des-Eaux, Chinon, Cruas-Meysse) are heard and supported in their initiatives to locally inform and educate the public in support of greater citizen and regional stakeholder involvement.

ANCCLI is pleased with this development which includes a proper public consultation phase in the procedure, whilst at the same time pointing out that it has always believed that nation-wide public debate is essential during the generic phase of life-extension discussions after 40 years of nuclear power-plant operation.

ANCCLI, the ASN and the IRSN have started holding technical discussions with the general public on the subject of periodic safety reviews. From 2017 to 2018, 3 meetings were held on the key topics being covered by the technical reviews (ageing, compliance, internal and external hazards, severe accidents, etc.), which will be addressed during the HCTISN-led consultation.

Issues identified during these discussions will prompt citizens to raise other questions and to respond on the digital platform that will be set up for the consultation process.

Last but not least, ANCCLI considers that where nuclear matters are concerned and more specifically, that of nuclear safety, interactions between multiple stakeholders with diverse interests will either be cohesive or conflictual. The consultation does not seek to reach a consensus but rather to set up a clear, authentic and accessible system which enables everyone to feel that they are involved in an integrated approach with numerous local interactions.

For more information:
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