A French national network to guarentee transparency and nuclear safety
Around the table, we often have operators, regulators and technical support organisations. But we are often missing a fourth pillar: the civil society. How is civil society organized? What is the influence civil society?
In the context of the governance of nuclear activities, particularly in the field of nuclear safety and nuclear waste management, the vigilance of civil society is necessary. The experience of the French “Local Information Commissions” (CLI) and their national federation, ANCCLI, is an interesting example in Europe of the involvement of civil society on nuclear issues.
A system of involvement of civil society
In France, each basic nuclear installation and assimilated structure benefits from a CLI (Local Information Commission). A CLI has a dual mission of providing information to the public and permanent monitoring of the impact of nuclear installations on the environment. The national federation of CLIs, ANCCLI, was created in 2000. ANCCLI has been formed by the CLIs and is composed (excluding its permanent staff) by representatives of the CLIs from each installation who are representatives of the civil society. ANCCLI promotes the sharing of experiences and brings the voice of the CLIs to the national and international levels. It forges close partnerships with ASN (Nuclear Safety Authority), IRSN (Institute for Radiation Protection and Nuclear Safety) and HCTISN (High Committee for Transparency and Information on Nuclear Safety). Today, there are 35 CLIs from all over the French territory, they are composed of four panels: local elected people, representatives of environmental protection associations, representatives from nuclear industry trade unions, and qualified persons and representatives of the economic world. CLIs question plant operators, the ASN (Nuclear Safety Authority) or the IRSN (Institute for Radioprotection and Nuclear Safety), organize public discussions, take part in inspections, mandate experts on specific points and organize the radiation monitoring of the environment around the plant. CLIs listen to the requests of the citizens.
History of ANCCLI and the CLIs
The experience of CLIs and ANCCLI also shows that the structure of civil society on nuclear issues is progressive and that a lingering path remains to be travelled. The first Local Information Commission was created in 1977 around Fessenheim NPP.In 1981, as a result of a circular from the Prime Minister, CLIs were created for all NPPs & some other installations.CLIs were officially recognized in 2006 by the Transparency and Nuclear Safety (TSN) Act that provided a legal basis. This basis is confirmed by the new law on energy (TECV). CLIs are under the supervision of the Departemental Council that does not intervene in nuclear safety control (This is a ASN prerogative).
In 2000, ANCCLI was founded as the national representation of CLIs. Article 22 of TSN act says: “(…) a local information committee is (…) tasked with a general follow-up, information and consultation mission in the field of nuclear safety, radioprotection and the impact of nuclear activities on persons and the environment as far as the site installations are concerned.”
The Energy Transition Act from 2015 adds new missions for CLIs (public meetings, consultation on emergency plan updates, etc.).
Influence on nuclear accident preparedness
Several examples show thatANCCLI can change the game in French nuclear accident preparedness.
CLI Gravelines CLI – 2005 – Implementation of a floating boom in the fore-port.
The water used to cool the Gravelines NPP is taken in through a fore-port where there are many ships circulating and where oil tankers are parked at platforms. The CLI of Gravelines raised the problem of risks of marine oil pollution in the fore-port and the risks for the water intake of the nuclear plant.
Following the remarks of the CLI, the French Nuclear Safety Authority (ASN) requested that the operator produce a study of the problem. This study confirmed the risks posed by the CLI and the ASN imposed on the operator to build a floating boom in the fore-port.
CLI Fessenheim – 2014 – Taking into account the remarks of the Fessenheim-CLI in the update of the regulations on the releases of effluents from the Fessenheim nuclear power plant.
As part of the updating of the regulations on the releases of the Fessenheim nuclear power plant, the CLI-Fessenheim appealed to the Scientific Committee (SC) of ANCCLI to analyse the dossier submitted by the operator. The analysis of the SC allowed the CLIs to propose additions to the regulations planned to be set by the French Safety Authority (ASN): additional measures, monitoring on emerging pollutants, reduction of the limit of other pollutants releases. Some of these CLI s’proposals were taken into account by the ASN.
ANCCLI – 2015 – Extension of special intervention plans.
In a press release dated November 7, 2014, ANCCLI required a thorough review of the perimeters of “special intervention plans“ (“plans particuliers d’intervention” – PPI) of basic nuclear installation and even suggested an extension of the emergency plans to a radius of 80 km. In the report released in April 2015 by ANCCLI on emergency plans strengths and weaknesses, ANCCLI emphasized that, in the light of the Fukushima disaster, the current emergency plans, with a radius of 10 km, were inadequate.
On April 26 2016, the anniversary of the Chernobyl disaster, the Environment Minister Ségolène Royal announced the extension from 10 to 20 km from the scope of the special intervention plans (PPI). This will multiply considerably the populations involved.
Although there is still a lack of action on the part of administrative decision-makers, we can observe a measureable change in the political decision-makers’ view on planning of nuclear safety in France.
An interesting example for Europe
Today, we can observe that ANCCLI is developing its own expertise to play an influential role and to be involved in decision processes. The ANCCLI model of action can be studied and adopted by civil society in other contexts, which would add value to nuclear safety in Europe as a whole. The ANCCLI model is indeed known. For example, in a report by the Belgium High Health Council a transparent and structured communication process is advocated, such as that of the French CLIs, on nuclear safety issues and on emergency planning. It recognises that “this participatory approach improves the quality of vulnerability analyzes, highlights concerns of citizens and allows people to react in case of accident”.
There is a need of civil society involvement at the European level, as stressed by the European Union Council. Conclusions of the Council of the European Union on off-site nuclear Emergency Preparedness and Response (EP&R) stresses “the benefits of involving civil society in preparedness activities, in particular during nuclear emergency exercises, to increase transparency and public participation, and to improve public confidence in the arrangements”.