ASN Report 2018

As part of its continuous improvement policy, ASN encourages the exchange and integration of best practices used by other inspection organisations: ∙ ∙ by organising international exchanges of inspectors between Safety Authorities, either for the duration of one inspection or for longer periods that could extend to a secondment of up to several years. Thus, after having observed its advantages, ASN has adopted the concept of in-depth inspections described earlier. However, it did not opt for the system involving a resident inspector on a nuclear site, as ASN considers that its inspectors must work within a structure large enough to allow experience to be shared and that they must take part in checks on different licensees and facilities in order to acquire a broader view of this field of activity. This choice also allows greater clarity in the exercise of the respective responsibilities of the licensee and the inspector; ∙ ∙ by taking on inspectors trained in other inspection practices. ASN encourages the integration into its departments of inspectors from other regulatory authorities, such as the Regional Directorate for the Environment, Planning and Housing (Dreal), ANSM, Regional Health Agencies (ARS), etc. It also proposes organising joint inspections with these authorities concerning the activities within their joint field of competence; ∙ ∙ by encouraging its staff to take part in inspections on subjects in different regions and domains, notably to ensure the uniformity of its practices. Table 3 presents the headcount of inspectors, which stood at 318 on 31 December 2018. Some inspectors operate in several inspection areas, and all the operational entity heads and their deputies fulfil both managerial and inspection functions. Most of the inspections are carried out by inspectors assigned to the regional divisions, who represent 54% of the ASN inspectors. The 147 inspectors assigned to the departments take part in ASN inspections within their field of competence; they represent 46% of the inspector headcount and carried out 17% of inspections in 2018, with most of their work being the examination of files. As previously mentioned, ASN continuously improves the efficiency of its oversight by targeting and adopting a graded approach to its inspections according to the scale of the implications for the protection of persons and the environment. The inspection work carried out by the ASN inspectors is not adequately reflected simply by the number of inspections performed, but more by the number of inspection days (a day spent on an inspection by one inspector represents 1 inspector.day). In 2018, the ASN inspectors carried out a total of 1,813 inspections, representing 4,178 inspection days in the field, broken down as shown in Table 4. • ASN inspections programme To guarantee a distribution of the inspection resources proportionate to the safety and radiation protection implications of the various facilities and activities, ASN drafts a forecast inspections schedule every year, taking account of the inspection implications (see point 3.1). This schedule is not communicated to the licensees or to those in charge of nuclear activities. ASN monitors the performance of the programme and the follow-up given to the inspections, through periodic reviews. This enables the inspected activities to be assessed and contributes to the continuous improvement of the inspection process. ASN definition of its inspection priorities In order to take account, on the one hand, of health and environmental issues, licensee safety and radiation protection performance and, on the other, of the large number of activities for which it has oversight, ASN regularly identifies and reassesses its inspection priorities. It conducts regular oversight of subjects entailing potential risks, which are systematically examined on a yearly basis, and also identifies topical subjects requiring more particular attention in any given year. For example, in 2018, the inspections focused on the following topics or activities: ཛྷ ཛྷ management of category 2 and 3 deviations in BNIs; ཛྷ ཛྷ management of subcontracted activities in the NPPs; ཛྷ ཛྷ cross-checking of waste studies updated in 2017 for the NPPs; ཛྷ ཛྷ the quality and inspection of retentions in the NPPs; ཛྷ ཛྷ shipments of radioactive substances by the radiopharmaceutical producers; ཛྷ ཛྷ transport operations performed by the nuclear medicine departments; ཛྷ ཛྷ fluoroscopy-guided interventional medical practices; ཛྷ ཛྷ the detection and prevention of radon risks; ཛྷ ཛྷ industrial radiography. The search for fraud is also among the priorities, mainly through the definition of inspection methods concerning this topic. To identify these activities and these topics, ASN relies on current scientific and technical know-how and considers the information collected by itself and by IRSN: inspection results, frequency and nature of incidents, major modifications to facilities, examination of dossiers, feedback of information concerning the dose received by the workers and information about checks by the approved organisations. It adapts its priorities to take account of significant events occurring in France or around the world. Breakdown of inspectors per inspection domain (as at 31 December 2018) INSPECTOR CATEGORIES DEPARTMENTS DIVISIONS TOTAL Nuclear safety inspector (BNI) 112 109 221 of which nuclear safety inspector (transport) 12 26 38 Radiation protection inspector 40 110 150 Labour inspector 2 12 14 Number of inspectors all domains 147 171 318 Table 3 ASN report on the state of nuclear safety and radiation protection in France in 2018  137 03 – REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION 03