ASN Report 2017

302 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 10  - Sources of ionising radiation and their industrial, veterinary and research applications ASN nevertheless expects all existing radioactive lightning conductors to be removed and placed in the care of Andra, given the risks they can represent, depending in particular on their physical condition. For several years ASN has been informing professionals to ensure that these objects are removed in compliance with radiation protection requirements for workers and the public. ASN has stepped up its action in this respect by reminding the professionals of their obligations, particularly that of having an ASN license for the activity of removing and storing the lightning conductors pursuant to Articles L. 1333-1, L. 1333-4, and R. 1333-17 of the Public Health Code. ASN conducts field oversight operations targeting the companies involved in recovering these objects, combined with unannounced inspections on the removal sites. Andra estimates that some 40,000 radioactive lightning conductors were installed in France. Nearly 10,000 have already been removed and transfered to Andra. The current rate of removal is about 450 per year. Additional information on radioactive lightning conductors is available on www.andra.fr and the website of the association Inaparad www.paratonnerres-radioactifs.com . 4.4 Reinforcement of the regulation of electrical devices generating ionising radiation ASN resolution 2017-DC-0591 of 13th June 2017 setting the minimum technical design rules which facilities using X-rays must comply with came into effect on 1st October 2017 (see chapter 3). This resolution replaces ASN resolution 2013-DC-0349 of 4th June 2013 without creating additional requirements for already compliant facilities. It concerns facilities in the industrial and scientific (research) sectors, such as industrial X-ray radiography in bunkers and veterinary radiology. It takes account of experience feedback and sets the radiation protection goals by adopting a graded approach to the risks. With regard to the design of devices, ASN intends to supplement the provisions introduced into the Public Health Code in 2007, and thus complete the development of the regulatory framework allowing the distribution of electrical devices for generating ionising radiation to be subject to licensing in the same way as the suppliers of radioactive sources. Experience shows that in this respect the joint technical examination of files by ASN and the device suppliers/manufacturers brings substantial gains in radiation protection optimisation (see points 3 and 4.2.1). For electrical devices used for non-medical purposes, there is no equivalent of the mandatory CE marking for medical devices, such as to confirm conformity with several European standards covering various fields, including radiation protection. Furthermore, experience feedback shows that a large number of devices do not have a certificate of conformity to the standards applicable in France. These standards have been mandatory for many years now, but some of their requirements have become partly obsolete or inapplicable due to the lack of recent revisions. On the basis of the work done by the LCIE (Electrical Certification and Testing Entity for Bureau Véritas), CEA and IRSN, draft texts have been produced with the aimof defining minimum radiation protection requirements for the design of X-ray generators, and an informal technical consultation of the stakeholders (suppliers, French and foreign manufacturers and the principal users) was conducted in 2015. The various contributions are currently being analysed with the assistance of IRSN and the reference players (CEA and LCIE). The conclusions of this work will be taken into account when defining the new systems mentioned in paragraph 4.2.2 in order to create a new regulatory framework for the distribution of electrical devices generating ionising radiation. 4.5 Implementation of oversight of radioactive source protection against malicious acts Even if the safety and radiation protectionmeasures as a result of the regulations do guarantee a certain level of protection against the risk of malicious acts, they cannot be considered sufficient for all radioactive sources. Reinforced oversight of protection against malicious acts using hazardous sealed radioactive sources was thus strongly encouraged by the IAEA which published a Code of Conduct for the Safety and Security of Radioactive Sources (approved by the IAEA Board of Governors on 8th September 2003) and Guidelines for the Import and Export of Radioactive Sources (published in 2005). The G8 supported this approach, notably at the Evian Summit in June 2003, and France sent the IAEA confirmation that it was working towards application of the guidelines laid out in the Code of Conduct (undertakings by the Governor for France of 7th January 2004 and 19th December 2012). The general aim of the Code of Conduct is to obtain a high level of safety and security for those radioactive sources which can constitute a significant risk for individuals, society and the environment. 4.5.1 The organisation adopted for overseeing the security of sources Regulatory oversight of sources for radiation protection and safety purposes and oversight to combat malicious acts have many aspects in common and mutually consistent objectives. This is why ASN’s counterparts abroad are usually responsible for oversight in both domains. ASN has the necessary hands-on knowledge of the sources concerned and of the entities responsible A lightning conductor.