ASN Report 2018

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 by ASN with the aim of 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 to adapt the regulatory framework and subject the distribution of devices generating ionising radiation to licensing, in the same way as for radioactive sources. 2.3.2  –  Implementation of oversight of the protection of ionising radiation sources against malicious acts Although the safety and radiation protection measures provided for by the regulations guarantee a certain degree of protection of ionising radiation sources against the risk of malicious acts, they cannot be considered sufficient. Reinforcing of the oversight of protection against malicious acts targeting sealed radioactive sources has therefore been encouraged by the International Atomic Energy Agency (IAEA), which published a Code of conduct on the safety and security of radioactive sources, approved in 2003. As of the following year, France confirmed to the IAEA that it was working with a view to applying the guidelines set out in this code. • The organisation adopted for the oversight of protection against malicious acts The oversight of sources for radiation protection and safety purposes and oversight to combat malicious acts have many aspects in common. Generally speaking, ASN’s counterparts in other countries are responsible for oversight in these two areas. In France, the protection against malicious acts concerning nuclear materials used in certain points of vital importance is coordinated by the services of the HFDS (Defence and Security High Official) of the Ministry responsible for Energy (Ministry of Ecological and Solidarity-based Transition). The recent changes in regulations have led to an organisation for oversight of the protection of ionising radiation sources against malicious acts (hereinafter called “oversight of the security of sources”) which takes into account the existing oversight systems by entrusting: ∙ ∙ to the services of the HFDS of the Ministry responsible for Energy, oversight of the security of sources in installations whose security is already under their oversight; ∙ ∙ to the Ministry of Defence, oversight of the sources in the locations placed under its authority; ∙ ∙ to ASN oversight of the security of sources held by the other persons/entities responsible for nuclear activities. The process necessary to set up this oversight, initiated by the Government in 2008 with the assistance of ASN, resulted in Ordinance 2016‑128 of 10 February 2016 and then Decree 2018‑434 of 4 June 2018 introducing various provisions concerning nuclear activities. These texts divide up the oversight competences in the various installations, by including protection against malicious acts in the risks that must be taken into account by those responsible for nuclear activities and by the regulatory bodies when reviewing the licensing applications. • The sources and installations concerned Oversight of source security (combating malicious acts) concern all sources of ionising radiation. Additional regulatory requirements will nevertheless be issued to increase the security of the sources presenting the greatest security risks: this concerns sealed radioactive sources of categories A, B and C as defined in the Public Health Code, which stems directly from that of the IAEA. The protection requirements are proportionate to the intrinsic dangerousness of the sources. The graded approach therefore implies stricter obligations for the sources / batches of sources in category A than in category C. Sources that are not in category A, B or C are classified in category D. In the civil sector, there are about 4,918 sources presenting such risks held in some 250 installations in France. These sources are held essentially for the purpose of industrial irradiation, telegammatherapy, brachytherapy and industrial radiography. Due to their frequent use on worksites, industrial radiography sources present particular security risks during transport. As was said earlier, oversight of the security of these sources is ensured essentially by ASN. Because they are grouped together when in storage, sources of one category can find themselves alongside sources in a higher category and therefore be subject to stricter security measures. • Initial assessment regarding the security of high-activity sealed sources For five years, ASN has worked to gather baseline data on actual provisions implemented to ensure the security of high-activity sealed sources or presenting equivalent security risks. This work led to ASN making some 350 visits. Virtually all the licensees holding sealed sources in categories A, B and C, who are now under ASN oversight on account of the protection of sources against malicious acts, have therefore received such a visit. A synthesis of the information gathered during these visits was one of the inputs for the development of the future legally- binding requirements, coordinated by the HFDS of the Ministry responsible for Energy, and enabled the impact of these requirements to be assessed (see next paragraph). • Regulatory work The Decree modifying the regulatory part of the Public Health Code taken in application of Ordinance 2016‑128 of 10 February 2016 (Decree 2018‑434 introducing various provisions with regard to nuclear activities) was published on 4 June 2018. It contains several provisions concerning the protection of sources against malicious acts, and more specifically: ∙ ∙ the classification of ionising radiation sources and aggregation (batching) of radioactive sources into category A, B, C or D (R. 1333‑14); ∙ ∙ the prompt notification to various administrative authorities, and the regionally competent law enforcement agencies, of any actual or attempted malicious act or loss concerning a source of ionising radiation or a batch of radioactive sources of category A, B or C (R. 1333‑22); ∙ ∙ the sending of documents that could facilitate malicious acts by separate, specially identified mail (R. 1333‑130); ∙ ∙ the nominative and written authorisations to be delivered to the persons having access to ionising radiation sources or batches of radioactive sources in category A, B or C, transporting them, or having access to information concerning the protection of such sources or batches of sources against malicious acts (R. 1333‑148). ASN report on the state of nuclear safety and radiation protection in France in 2018  239 08 – SOURCES OF IONISING RADIATION AND THEIR INDUSTRIAL, VETERINARY AND RESEARCH APPLICATIONS 08