IRRS follow-up mission to France - October 2017

40 Suggestion17: In the French regulatory approach, the safetyobjectives for incidents and accidents are set based on intervention levels (e.g., levels initiating evacuation, sheltering and restrictions to food consumption). BNI ministerial order (7 February 2012) also requires the licensees to ensure that the radiological consequences are as low as reasonably achievable (ALARA) in the case of incidents and accidents (not only for normal operation). In November 2015, ASN published a resolution concerning the BNI safety analysis report (SAR), which requires that the SAR defines the criteria for addressing the consequences of incidents and accidents in the light of regulatory requirements. In practice, this means that the licensee is performing the radiological consequence analysis and confirming that the results are well below the intervention levels. The IRRS review team concluded that the actions taken by ASN are sufficient to ensure the fulfilment of the general safety goal in the GSR Part 1 Section 4.62. Recommendation 11: ASN published an external guide “Preparation of ASN statutory resolutions and ASN guides” in October 2016. The guide provides the framework and the process whereby the licensees, manufacturers and other stakeholders are invited to take part in the preparations of the ASN draft resolutions and guides relating to BNIs. The guide also describes how feedback from the stakeholders can be sent to ASN after the resolutions and guides have been in use for a few years. Regulatory experience feedback is collected through formalised evaluation processes and there is also a formalised procedure to seek guidance from the legal office. The legal office also gives feedback to the drafting team when updating resolutions and guides. The update of ASN’s internal procedure, Note ASN/REG/01, describing the process for developing and updating regulations and guides has been started but it needs to be finalised. ASN’s note ASN/REG/01 states the IAEA Safety Standards that are to be used when developing national resolutions and guides. However, the process to keep national resolutions and guides consistent with the IAEA safety standards as they evolve is not yet formalised. In 2016, ASN developed an informal table covering IAEA safety requirements level documents and the sections responsible to ensure their implementation. Status of the finding in the initial mission Recommendation 10 (R10) is closed on the basis of progress made and confidence in the effective completion. ASN has made significant progress since the initial mission by publishing new decisions and guides and have clear plans to finalise the project. Suggestion 16 (S16) is closed as ASN has published a new resolution establishing a classification of BNIs into three categories. ASN is also finalising a new regulatory guide on management of BNI modifications and the regulations for small-scale nuclear activities clarifying the graded approach by the end of 2017. Suggestion 17 (S17) is closed as ASN has published a new resolution concerning the BNI safety analysis report. The utilization of the ALARA principle and the requirement for licensees to analyse the radiological consequences and compare them to the intervention levels is sufficient to ensure the fulfilment of the general safety goal in the GSR Part 1. Recommendation 11 (R11) remains open as an internal procedure describing the process for developing and updating regulations and guides has not been updated since the initial IRRS mission. Although a new external guide was published concerning the participation of the stakeholders in the updating of resolutions and guides, there is no procedure for regular assessment of the need to update the resolutions or guides. In addition, the process to keep national regulations consistent with the IAEA safety standards as they evolve is not yet formalised.