For ASN, 2011 is the fiftieth anniversary of the creation of
the basic nuclear installations regime, the fifth anniversary
of the creation of ASN and, finally, the year of the
Fukushima disaster.
50th birthday
of the basic nuclear installation.
Jean-Christophe NIEL, ASN Director-General
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In the 1950s, the Minister of Health tasked the central service
for the protection against ionising radiation (SCPRI)
with handling radiation protection issues; the French atomic
energy commission (CEA) for its part dealt with regulating
the safety of its own facilities. The Government felt
no need to establish a regulatory system that involved
them directly. The very notion of nuclear facilities - later
to be known as "basic nuclear installations (BNI)" - that
represented a particular risk requiring monitoring and
regulation, did not even exist.
This notion came about in France almost unintentionally,
as a result of international constraints. The Euratom
Treaty, signed in 1957, stipulated that nuclear facilities
should be subject to a regime of authorisation, or at the
very least notification; moreover, the Paris Convention on
Nuclear Third Party Liability, signed in 1960, required
identification of the facilities which could be the source of
any damage.
To establish the basic nuclear installations administrative
regime, the Government then chose a relatively unusual
legislative vehicle; a bill concerning mitigation of atmospheric
pollution, which became the atmospheric pollution
and odours Act. This bill, submitted by the Government in
1960, did not primarily target industrial facilities, which
had been regulated for a long time by a law dating back to
1917. It was therefore aimed mainly at other sources of
potential atmospheric pollution: vehicles, non-industrial
facilities such as domestic hearths and diffuse sources.
However, the text of the Government's draft contained the
word radioactive: radioactivity was just beginning to be
recognised as a component of ambient atmospheric pollution,
mainly as a result of the atmospheric atomic tests
being carried out by the major powers.
It was thus designated as the appropriate medium for
introducing an administrative regime for basic nuclear installations,
in order to meet France's international obligations.
One could be forgiven for thinking that it would have been
simpler to change the nomenclature of installations covered
by the 1917 Act on classified installations and simply
add nuclear facilities.
There would appear to be two reasons for not having done
so:
- the scope of the 1917 Act was then limited to industrial
and commercial establishments; however CEA's sites,
which housed a large number of the nuclear facilities,
did not fall into this category;
- the other reason was the extremely specific technical
nature of these facilities, which justified centralised
monitoring and regulation, by specialised individuals,
whereas the principle of the classified facilities was that
the inspectors of these facilities be appointed in each
département1 by the préfet2, and be able to cover all facility
categories.
The first provisions concerning nuclear facilities were therefore
incorporated into an Act dealing with mitigation of
atmospheric pollution and odours. According to the
minutes of the debates in the National Assembly and the
Senate, the members of parliament showed that even at
that time, they were aware of the problems of radioactivity:
the problem of ambient radioactivity as a result of atomic
testing was highlighted by a number of speakers. Fewer
speakers however mentioned nuclear facilities, although
one member of parliament did express concern about
sites too close to Paris.
This is how the BNI came about, almost as an afterthought.
ASN is 5 years old.
In November 2006, the ASN Chairman, André-Claude Lacoste,
stated that the creation of ASN would lead initially to little
change but that after five years, we would be able to see how far
we had come. I believe that the best way to talk about these five
years is to present the significant milestones reached during the
period, although this choice has to be somewhat arbitrary given
the wealth of potential topics:
The lessons learned from the Épinal and Toulouse accidents
Following these accidents, ASN took steps to promote the safety
of radiotherapy treatment.
For example:
- jointly with the French Society for Radiation Oncology
(SFRO), by creating the scale for rating radiation protection
events affecting patients receiving radiotherapy treatment;
- by recommending an increase in the number of radiological
physicists;
- by suspending the operations of several radiotherapy centres
as a result of major anomalies;
- by organising an international conference in Versailles, in
2007, entitled "Advances and challenges in radiation protection
of patients";
- by adopting a decision concerning radiotherapy quality
management in 2008.
BNI regulatory provisions
The regulations applicable to BNIs were already well under way
with the "BNI procedures" decree of 2007. The BNI order was
published on 7th February 2012 and a dozen regulatory decisions
are already well advanced: this work was extensively discussed
with the various stakeholders. ASN will be implementing
a complete and rigorous working and intervention framework
that is consistent with that of its European colleagues, as
it is using the "reference levels" of WENRA, the Western
European Nuclear Regulators' Association.
Source security
Source security is a new role, taken on by ASN in 2008. ASN is
making active preparations for effective performance of this
role, which requires legislation: the Government has decided to
include it in the draft bill ratifying the ordinance codifying the
TSN Act and to table it before the Senate. It could thus be passed
by the next Parliament.
Transparency on environmental matters
Jointly with the Institute for Radiation Protection and Nuclear
Safety (IRSN) and the stakeholders, ASN has developed the
www.mesure-radioactivite.fr website which collates all environmental
radioactivity measurements made by the licensees, institutions
and approved associations. The events of Socatri,
Fukushima and Centraco have shown that the public is increasingly
interested in these questions.
Continued operation of the 900 MWe reactors
ASN has issued an initial generic opinion on the continued operation
of the 900 MWe reactors beyond thirty years. This assessment
will need to be supplemented by a position statement
reactor by reactor. This has already been done for Tricastin 1
and Fessenheim 1.
Monitoring the EPR construction site
ASN is heavily involved on a day to day basis in monitoring of
the Flamanville 3 construction site. This is an activity that had
to be re-learned after more than ten years with no construction
work on such a scale. This monitoring is leading to a number
of important decisions, such as the decree creating this facility,
suspension of the site, in particular the concrete pouring activities,
or the joint position statement by the British, Finnish and
French regulatory authorities concerning the architecture of the
EPR reactor's instrumentation and control system.
Production of the PNGMDR
This is a requirement of "the other 2006 Act", that concerning
radioactive waste. ASN and the ministry responsible for ecology
have, since then, drafted two editions of the national radioactive
material and waste management plant.
Construction of the European nuclear safety
and radiation protection area
Over the past five years, nuclear safety and radiation protection
in Europe has been strengthened:
- WENRA finalised its "safety reference levels" for the European
power plants in service and each of its members has agreed to
incorporate them into its national regulations;
- WENRA drafted safety objectives for new reactors;
- HERCA, the association of Heads of European Radiological
Protection Competent Authorities, was created;
- the European Union issued two directives, one on nuclear
safety and one on the management of radioactive waste and
spent fuel;
- ENSREG, a grouping of all the European safety regulators and
the Commission, has been adopted as an advisory body for
the European institutions;
- the first European conference on nuclear safety was held in
Brussels in the post-Fukushima context.
Dose optimisation in medical imaging
Exposure linked to medical examinations has increased by
more than 70% in five years.
ASN organised a seminar on medical imaging in order to raise
the awareness of institutions, professionals and manufacturers
of the need formore rigorous application of the principles of
radiation protection (justification of procedures and dose optimisation)
and the development of alternative techniques, a
prime example of which is MRI.
Following on from this seminar, it issued several position statements
on this subject last July.
The post-accident approach
Post-accident doctrine is being clarified: it is presented in guidelines,
tested during exercises and should be integrated into
the off-site emergency plans (PPI).
The full value of an approach such as this became apparent at
the time of the Fukushima accident. It was presented to the
Codirpa international seminar on 5th and 6th May 2011.
And now to
2011.
What a contrast between the beginning of the year, when ASN
was criticised by some for over-playing the safety card and
issued warnings concerning the risk of creating a two-speed
nuclear world, and the end of 2011 in the wake of the
Fukushima accident! 2011 will remain synonymous with
Fukushima.
This accident is a major event and it will for ever mark the history
of nuclear power, as did Three Mile Island and Chernobyl:
there will be a before and after Fukushima.
As early as 11th March, ASN foresaw the potential scale of this
natural disaster, combined with a nuclear crisis. Its emergency
centre was activated on the afternoon of 11th March and remained
operational round the clock, 7 days a week, until 13th
April. Its activities were subsequently scaled back but it remained
operational for a considerable time.
Two hundred people, or nearly half the ASN workforce, in the
regions and the Paris area, were mobilised in the emergency
centre.
Daily audio-conferences were held with IRSN, the International
Atomic Energy Agency (IAEA), the foreign safety regulators and
the French Embassy in Japan.
During the course of this first month, the level of communication
was intense, with ASN holding seventeen press conferences
and publishing twenty-eight press releases. About fifteen
staff were mobilized to answer 1200 media queries. A special
website was created and received more than 700,000 hits. A
call centre was set up to answer the public's questions
At the same time, ASN initiated the complementary safety
assessments (CSA) process. In addition to these CSAs, ASN in
2011 organised a campaign of targeted inspections on topics
related to the Fukushima accident. Thirty-eight inspections
were thus carried out on all the nuclear facilities felt to be highpriority,
corresponding to a total of one hundred and ten days
of inspection.
ASN also wanted to ensure that this process was transparent
and to involve civil society. Therefore the members of the local
information committees (CLI) and foreign experts, representing
a total of fifty people, were able to take part in the inspections.
Foreign experts and members of the French High Committee
for Transparency and Information on Nuclear Security
(HCTISN) took part in the meetings of the Advisory
Committees of experts, which for three days in November
brought together more than two hundred people.
ASN received and took full account of numerous contributions
from the CLIs, the ANCCLI, foreign experts and trade union
organisations
Given the exceptional nature of this situation, ASN made
public in real-time the reports from its licensees, that from the
IRSN produced at its request and the opinions of the Advisory
Committees. ASN published its report and its opinion on 3rd
January 2012.
ASN worked with the HCTISN, which issued two opinions,
one on 3rd May concerning the specifications for the complementary
safety assessments, the other on 8th December concerning
the transparency of the process. The involvement of the
HCTISN and the CLIs represented a crucial contribution to the
necessary transparency and openness of this entire approach.
Considerable work was done in a very short time, commensurate
with the scale of the disaster.
This work needs to be continued nationally, at a European
level, and internationally. It must concern both the safety of the
facilities and the management of emergencies.
The commitment, professionalism and availability of the ASN
and IRSN staff, as well as the considerable work they have done
since 11th March 2011, has enabled ASN to learn the first lessons
from the Fukushima accident, for which complete experience
feedback analysis will take many years.
These three periods - 50 years, 5 years, last year - remind us
that the time-scale of change in nuclear safety, radiation protection
and their regulation, is a very long one. It is essential that
adaptation is always based on experience feedback and stringency
and vigilance must be the watchwords at all times.
1. In a département, representative of the State appointed by the President
2. Administrative region headed by a préfet
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