ASN Report 2017

138 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 04  - Regulation of nuclear activities and exposure to ionising radiation checks the packages intended for the transport of radioactive substances. Once the nuclear facility has been commissioned, following ASN authorisation, all changes to the facility or its operation made by the licensee that could affect security, public health and safety, or the protection of the environment, are notified to ASN or submitted to it for authorisation. Moreover, the licensee must perform periodic safety reviews to update the assessment of the facility, taking into account any changes in techniques and regulations, and experience feedback. The conclusions of these reviews are submitted by the licensee to ASN, which can issue new binding requirements for continued operation (see chapter 12 point 2.9.4). The other files submitted by BNI licensees There is a considerable volume of files on specific topics such as fire protection, PWR fuel management strategies, relations with contractors, and so on. The licensee also periodically submits activity reports and summary reports on water intake, liquid and gaseous discharges and the waste produced. 3.2.2 Review of the applications required by the Public Health Code ASN is responsible for reviewing applications to possess and use ionising radiation sources in the medical and industrial sectors. ASN also deals with the specified procedures for the acquisition, distribution, import, export, transfer, recovery and disposal of radioactive sources. It in particular relies on the inspection reports from the approved organisations and the reports on the steps taken to remedy nonconformities detected during these inspections. In addition to the internal inspections carried out under the responsibility of the facilities and the periodic checks required by the regulations, ASN carries out its own verifications. In this respect it directly carries out checks during the procedures for issue (pre-commissioning inspections) or renewal (periodic inspections) of the authorisations to possess and use radiation sources granted on the basis of Article R. 1333-23 of the Public Health Code. Authorisations and renewals can only be issued if the requests submitted by ASN following the checks have been taken into account. These checks are in particular designed to compare the data contained in the files with the actual physical reality (sources inventory, check on the conditions of production, distribution and utilisation of the sources and the devices containing them). They also enable ASN to ask the facilities to improve their in-house provisions for source management and radiation protection. 3.3 Lessons learned from significant events 3.3.1 Anomaly detection and analysis History The international Conventions ratified by France (Article 19vi of the Convention on Nuclear Safety of 20th September 1994; Article 9v of the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management of 5th September 1997) require that BNI licensees, on account of the defence in depth principle, implement a reliable system for early detection of any anomalies that may occur, such as equipment failures or errors in the application of operating rules. Ten years previously, the “Quality Order” of 10th August 1984 already required the adoption of this working method. Based on thirty years of experience, ASN felt that it would be useful to transpose this approach, which was initially limited to nuclear safety, to radiation protection and protection of the environment. ASN thus drafted three guides defining the principles and reiterating the obligations binding on the licensees with regard to notification of incidents and accidents: ཛྷ ཛྷ The Guide of 21st October 2005 contains the requirements applicable to BNI licensees and to on-site transport managers. It concerns significant events affecting the nuclear safety of BNIs, radioactive material transports taking place inside the perimeter of the BNI or an industrial site and without using the public highway, radiation protection and protection of the environment. ཛྷ ཛྷ Guide No. 11 of 7th October 2009, updated in July 2015, contains provisions applicable to those in charge of nuclear activities as defined in Article L. 1333-1 of the Public Health Code and to the heads of the facilities in which ionising radiation is used (medical, industrial and research activities using ionising radiation). ཛྷ ཛྷ Guide No. 31 which describes procedures for the notification of events relating to the transport of radioactive substances (see chapter 11). This guide has been applicable since 1st July 2017. These guides can be consulted on the ASN website, www.asn.fr . What is a significant event? Detection of events (deviations, anomalies, incidents, etc.) by those in charge of the activities using ionising radiation, and implementation of corrective measures decided after analysis, play a fundamental role in accident prevention. The nuclear licensees detect and analyse several hundred anomalies each year for each EDF reactor and about fifty per year for any given research facility. Prioritising the anomalies should enable the most important ones to be addressed first. The regulations have defined a category of anomalies called “significant events”. These events are sufficiently important in terms of safety or radiation protection to justify rapid notification of ASN, with a more complete analysis subsequently being sent to it. Significant events must be notified to it, as specified in the Order of 7th February 2012 (Article 2.6.4), the Public Health Code (Articles L. 1333-3 and R. 1333-109 to R. 1333-111), the Labour Code (Article R.4451-99) and the regulatory texts applicable to the transport of radioactive substances (for