Orano - Annual Activity Report 2024 90 3 RISKS, CONTROL AND DUTY OF VIGILANCE PLAN Duty of vigilance plan ● at the design stage, packages are subjected to a series of regulatory tests designed to demonstrate their resistance and the maintenance of containment and radiological protection in the event of an impact, accident, fire or immersion; and ● the technologies and manufacturing processes used, as well as the maintenance carried out in accordance with national and international regulations, to guarantee the performance of the packages. The transport of radioactive materials is subject to planned or unannounced inspections and checks by the competent authorities as well as the Orano Transport Supervision Department. Orano organizes around 200 inspections per year around the world to ensure compliance with applicable regulations. Orano’s staff or its subcontractors involved in the handling and transport of radioactive materials also receive appropriate training in radiation protection and are subject to dosimetric monitoring. At international sites located in areas potentially exposed to intrusion attempts, the group ensures optimal physical protection, in close coordination with the relevant states and their respective armed forces. Prevention of the risk of accidental chemical or radiological spills An accidental spill of hazardous or radioactive substances (such as environmental incident or dike breaches) can have an impact on the environment. As part of the group’s internal requirements, discharges and accidental spills into the environment of radioactive or hazardous substances must be considered throughout all phases the facility’s lifecycle (design, construction, operation, shutdown and dismantling). In accordance with the ALARA principle (As Low As Reasonably Achievable), a risk reduction approach at source is implemented (limiting the hazardous nature of the substances used, limiting the quantities stored, etc.) whenever possible. Active measures to mitigate the consequences must also be implemented and integrated into incident management systems. At Orano Mining, the prevention of the risk of accidental spills has been a key focus for several years, with dedicated team efforts. To prevent accidental spills, the operational teams (Operations and Environment) are encouraged to: ● Adopt a proactive approach (from the design and construction phases through to the monitoring and operation of the facilities); ● Analyze and share lessons learned from potentially significant accidents to ensure that they do not occur again; and ● Conduct rigorous monitoring of facilities. Environmental events are fed back at Group level via a dedicated internal digital platform named AHEAD. The Orano group has also developed a severity classification scale for environmental near-misses and events, ASSESS, in order to promote operating experience feedback and sharing within the group. Each site has an internal procedure governing actions to be taken immediately and in the short term in the event of leak detection (cleaning up the area, checking for contamination and analyzing the causes of the leak). Thanks to these efforts and the sharing of experience, such spills are limited and handled very swiftly. Prevention and control of pollution risks The group’s past activities, carried out in accordance with the environmental standards of their time, or incidents that have occurred, may have left historical environmental legacies that need to be managed as part of liability control. To address this, Orano maintains constant monitors of its environmental performance and strives to reduce the environmental impact of its activities, for each of its operations and throughout their entire lifecycle. Environmental monitoring Orano conducts more than 100,000 measurements and analyses annually from approximately 1,000 sampling points to monitor the environment around its sites and mitigate the risk of harm to nature and neighboring populations. The results of these analyses provide in-depth environmental assessments of emissions’ impacts on air, water, and waste. They can be consulted on Orano’s website as part of the annual information report for each site, published under Article L.125-15 of the Environmental Code. Since February 2010, the public can consult the website managed by the IRSN (www.mesure-radioactivite.fr) to access all radioactivity levels in the environment and environmental monitoring reports conducted as part of regulatory surveillance around French sites. Each site is given the necessary tools to manage and submit the data. The group’s laboratories have obtained the required approvals from the ASN for conducting their analyses. These approvals are renewed periodically following inter-comparison tests organised by the French Institute for Radiation Protection and Nuclear Safety (Institut de radioprotection et de sûreté nucléaire, IRSN), based on an analysis framework defined by the French National Environmental Radioactivity Measurement Network (Réseau national de mesure de la radioactivité de l’environnement, RNM). In late 2021, the Malvési site was inspected by the European Commission under Article 35 of the Euratom Treaty, focusing on the monitoring of radioactive discharges. The report is available on the “Verifications of radiation monitoring in EU countries” website (europa.eu). Environmental monitoring of mining activities and end-of-life remediation Orano Mining conducts environmental studies throughout the lifecycle of mining and industrial projects. Environmental impact studies (EIS) are carried out for each new mining project or whenever a major modification to industrial facilities is expected. These studies comply with current regulatory requirements and are subject to public consultation for approval by local authorities. The process of conducting and reviewing an impact study is relatively similar across the various regulations in force in the countries where Orano Mining operates.
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