“The French government has announced plans to transfer the competences of the Institute for Radiation Protection & Nuclear Safety (IRSN – Institut de Radioprotection et de Sûreté Nucléaire) to other institutions. The aim is to strengthen synergies at a time when France is seeking to expand its nuclear programme.”[1]
In fact, the government is officially willing to strengthen the independence of nuclear safety control within a single, independent center, increasing synergies in nuclear research and development, and guarantying the excellence of the teams. The guidelines to be implemented aim to preserve the working conditions and remuneration of IRSN staff while maintaining the resources needed to carry out its missions.
The 3rd of February 2023, the French Nuclear Policy Council reviewed the challenges towards civil and military nuclear and five days later the Ministry of the Energy Transition announced this very significant reform for the organization of the nuclear safety which could be presented to the national assembly very soon in the frame of the acceleration of the nuclear program (starting early March).
This is why the Parliamentary Office for Science and Technology Assessment (OPECST) held an audition Thursday 16th February 2023 to hear the stakeholders impacted by this project of reform.
During this audition the President of IRSN underlined three aspects he considered crucial:
1 – Separation between expertise and decision-making.
2 – Combination between expertise and research.
3 – Challenges of maintaining skills to meet the industrial challenges ahead.
While organizations such as the CEA (Commission for Atomic Energy), EDF or ORANO expressed their good will to serve this reform at their best, other participants have also expressed their views.
For instance, the historian and searcher in the nuclear field, Michaël Mangeon considered “this reform as a major rupture.” He also gave a bit of background reporting that “the wish to have a group working on safety in France is going back to the 70’s with the IPSN group belonging to the CEA (Commission for Atomic Energy) because the American control was considered too strict and less flexible while France was focusing more on the technical dialogue between experts, authorities and operators. This group has then operated away from the large public. The Three Miles Island accident proved wrong the American system of safety while on the other hand it is the Chernobyl catastrophe which impacted negatively the French system associated to the nuclear lobby and has eventually led to the creation of the IRSN for the expertise and the ASN for the safety authority. This model has now become a standard for a good risk management governance and the expression of a long effort to restore trust among the public. This system is of course not perfect, ten years ago the government tried to bypass the authority of safety using IRSN’s expertise for industrial and commercial purposes.
The Fukushima accident ended the willingness to change the safety system which is presented throughout the world as a model of independence between auditors and audited. In conclusion, he underlined the fact the system of safety is highly correlated to the risk and to potential accidents has Three Miles Island, Chernobyl and Fukushima showed. Here are risks he observes:
1°) Starting a nuclear program with a safety system in mutation.
2°) Separating the expertise and the research.
3°) Separating expertise and decision.
4°) Reputation and trust loss if a problem occurs.
5°) Relation with the Civil Society.
The ex-French deputy Claude Birraux involved in the safety debate during at the national assembly during the last decades also expressed his opinion saddened to see the syndical organizations of nuclear workers missing to the audition and worried about the risk to see the research move to the CEA (Commission for Atomic Energy) because of the risks of confusion. He therefore considers that this reform holds the threat of a potential step back of 40 years in the evolution of the safety system which is directly threatening safety itself and trust coming from the Civil Society.
The Nuclear Regulatory Commission, presented as an alternative model, is according to him still very rigid and bureaucratic while the French system has proven its efficiency and should therefore probably be preserved.
Finally, Jean-Claude Delalonde President of ANCCLI, member organisation of NTW, federation of the 35 local commissions of information operating for decades and established in their role by the law along the years, presented 3 documents to support his views:
1°) a document from the 15th of April 2014 co-signed by the ASN and the IRSN expressing how the efficiency of the dual system of separation between expertise and authority is proven.
2°) a document from the 2nd of June 2016 also co-signed by the ASN and the IRSN again pledging for the dual safety-system insisting on the negative outcomes of a potential competition between the evaluation of the nuclear risks if the IRSN and ASN were merged.
3°) a document from the 11th May 2015 from ANCCLI recalling its attachment to the access to independent expertise for the public and its concerns regarding precipitated procedure.[2]
Together with Jean-Claude Delalonde and ANCCLI, Nuclear Transparency Watch is wondering:
- Has the unanimously approved dual safety-system of governance prove to be inefficient?
- Is there an impact study supporting this decision?
- Isn’t threatening the openness to the Civil Society to envision a transfer of the research at the CEA (Commission for Atomic Energy)?
- Finally, is this reform not threatening the Citizen expertise developed by the CLIS together with the IRSN and ASN along the years?
A first strike from IRSN workers representatives took place on Monday 21st February 2023 and another strike was (almost) unanimously voted for the 28th February 2023. If you wish to support them you can sign this petition: https://www.change.org/p/disparition-de-l-irsn
Among the french Civil Society voices quickly expressed their fears:
👉 ACRO, member organisation of NTW, quickly reacted with the following statement:
“The government’s decision is not based on any audit or study that would support this major change in the governance of the most nuclearised country in the world. Sacrificing safety to gain a few months on the construction of future EPRs makes no sense when the current delays are technical and not procedural. The government communiqué contains neither the word “consultation” nor the word “transparency”. Unimportant concepts, no doubt…
The IRSN’s operation must be reformed by opening it up more to the academic world and to stakeholders by accepting a greater plurality of approaches. There is also the need to guarantee academic freedom to its researchers who are not free to publish or speak to the media. We do not forget the dismissal of a researcher from this institute in 2020, because her research results did not please her hierarchy. In reaction, ACRO resigned from the IRSN’s Research Steering Committee, where it had been sitting for about ten years. Finally, in certain areas not subject to secrecy, there is a need for other players to emerge, both in research and in expertise.
The fate that the government is promising IRSN will worsen the situation. ACRO, as an independent and civic-minded organisation working towards greater transparency, can only deplore this government policy, both in terms of its content and its form.”
👉 Cédric Villani, a mathematician, who has worked with all the civil nuclear authorities made a paper where he considers that dismantling the Nuclear Safety Institute is a big mistake.
Nuclear Transparency Watch will organize an informative webinar the 13 March 2023 at lunch time to inform about the impacts of this potential reform on other European countries and to exchange on the possible outcomes of such a change.
[1] https://www.neimagazine.com/news/newsfrench-safety-institute-to-be-merged-with-regulator-and-cea-10593184
[2] https://videos.assemblee-nationale.fr/video.12939494_63edf73d2d6e9.opecst–pierre-henriet-depute-et-gerard-longuet-senateur-rapporteurs-sur-la-reforme-du-systeme-d-16-fevrier-2023
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