ASN Report 2017

324 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 11  - Transport of radioactive substances Knowledge of the regulations applicable to the transport of radioactive substances seems to be substandard in the medical sector in particular, where the procedures adopted by some hospitals or nuclear medicine units for package shipment and reception need to be tightened. In the BNI sector, ASN considers that the consignors must improve how they demonstrate that the content actually loaded into the packaging complies with the specifications of the approval certificates and the corresponding safety analysis files. This demonstration is sometimes carried out by a third- party company. The consignor’s responsibilities require that at the least it verify that this demonstration exists and is sufficient and that it monitor the third-party company in accordance with the usual methods of a quality assurance system. ASN has moreover observed that an increasing number of BNI licensees are using outside contractors to prepare and ship packages of radioactive substances. ASN is particularly attentive to the organisation set up for the monitoring of these contractors. 4.2.5 Oversight of preparedness for emergency management In order to reinforce the preparedness of the transport operators (mainly consignors and carriers) for emergency management, ASN published Guide No. 17 in December 2014 on the content of accident and incident management plans concerning the transport of radioactive substances. This guide recommends the drafting of plans to prepare for emergency management and stipulates the minimum content of these plans. In order to check correct application of this guide, ASN carried out three inspections in 2017 on the topic of preparedness for emergency situations. The inspectors looked in particular at the organisation in place, the material and human resources available, personnel training and the emergency exercises held. 4.2.6 Analysis of transport events The safety of the transport of radioactive substances is based notably on the existence of a reliable system for detecting and processing anomalies, deviations or, more generally, any abnormal events that could occur. Therefore, once detected, these events must be analysed in order to: ཛྷ ཛྷ prevent identical or similar events from happening again by taking appropriate corrective and preventive measures; ཛྷ ཛྷ prevent a more serious situation from occurring by analysing the potential consequences of events which could be precursors of more serious events; ཛྷ ཛྷ identify the best practices to be promoted in order to improve transport safety. The regulations also require that ASN must be notified of the most important events so that it can ensure the correct working of the detection system, the analysis approach and the integration of operating experience feedback. This also provides ASN with an overview of events so that the sharing of operating experience feedback can be encouraged between the various stakeholders – including internationally – and so that ASN inspection of the transport of nuclear waste to Australia, port of Cherbourg, October 2015. FOCUS Inspection of a MOX fuel shipment to Japan In July  2017, two TN 12/2 packages loaded with new MOX fuel assemblies, were shipped to Japan from the La Hague site. The MOX fuel was produced by Areva’s Mélox plant and had previously been transported to La Hague, where the assemblies were loaded into the TN 12/2 packages. The ASN inspectors went to the La Hague plant a few days prior to departure and checked the documents confirming correct loading of the assemblies and closure of the packages. They ran spot checks to ensure compliance with the requirements of the package model safety analysis file. They examined the workshops in which the operations had been carried out, checked the tools used and examined the condition of the two packages on their storage site. The inspectors also had IRSN staff carry out dose equivalent rate and contamination measurements on the two TN 12/2 packages and on an irradiated fuel package which had arrived from the Paluel NPP. The results obtained showed that the three packages were in compliance with the applicable regulation limits. More particularly the maximum dose rate values measured in contact with the packages were 0.069 mSv/h for the packages loaded with MOX fuel and 0.610 mSv/h for the package loaded with irradiated fuel. The regulation limit is 2 mSv/h. In the light of this examination, the inspectors considered that Areva La Hague had satisfactorily met its regulation obligations as consignor of packages loaded with MOX Fuel.