ASN Report 2018

for these checks take account of the recommendations issued by ASN and are taken up in the DGS Circular of 13 June 2007. The results of the checks are jointly analysed and utilised by ASN and the services of the Ministry of Health. 3.2  ̶  Assessment of the demonstrations provided by the licensee The purpose of the files supplied by the licensee is to demonstrate compliance with the objectives set by the general technical regulations, as well as those that it has set for itself. ASN is required to check the completeness of the data and the quality of the demonstration. The review of these files may lead ASN to accept or to reject the licensee’s proposals, to ask for additional information or studies or to ask for work to be done to bring the relevant items into conformity. 3.2.1  –  Analysing the files transmitted by (BNI) licensees Reviewing the supporting documents produced by the licensees and the technical meetings organised with them are one of the forms of control carried out by ASN. Whenever it deems necessary, ASN seeks the advice of technical support organisations, primarily IRSN. The safety review implies cooperation by numerous specialists, as well as efficient coordination, in order to identify the essential points relating to safety and radiation protection. IRSN assessment relies on research and development programmes and studies focused on risk prevention and on improving our knowledge of accidents. It is also based on in-depth technical discussions with the licensee teams responsible for designing and operating the plants. For certain dossiers, ASN asks the competent Advisory Committee of Experts (GPE) for its opinion. For other matters, IRSN examines the safety analyses and gives its opinion directly to ASN. ASN procedures for requesting the opinion of a technical support organisation and, where required, of an Advisory Committee, are described in chapter 2. At the design and construction stage, ASN – aided by its technical support organisation – assesses the safety analysis reports describing and justifying the design principles, equipment and system design calculations, utilisation rules and test procedures, and quality organisation provisions implemented by the prime contractor and its suppliers. It also analyses the facility’s environmental impact assessment. ASN regulates and oversees the construction and manufacture of structures and equipment, in particular that of the main primary system and the main secondary systems of pressurised water reactors. In accordance with the same principles, it 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. • 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 verifications carried out under the responsibility of the facilities and the periodic checks required by the regulations, ASN carries out its own controls when examining the applications. 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 20 September 1994; Article 9v of the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management of 5 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 10 August 1984 already required the adoption of such as system. 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: ∙ ∙ Guide of 21 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. ∙ ∙ Guide No. 11 of 7 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). ∙ ∙ Guide No. 31 describes procedures for the notification of events relating to the transport of radioactive substances (see chapter 9). This guide has been applicable since 1 July 2017. These guides can be consulted on the ASN website, asn.fr . 140  ASN report on the state of nuclear safety and radiation protection in France in 2018 03 – REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION