ASN Report 2018

2.4.2  –  Applicable licensing and notification systems Applications relating to the possession and utilisation of ionising radiation are examined by the ASN regional divisions, while those concerning the manufacture and distribution of sources or devices containing sources are examined at the ASN head office by the Department of Transport and Sources (DTS). The entry into effect on 1 July 2018 of Decree 2018‑434 of 4 June 2018, introducing various provisions in the nuclear field, introduces a third administrative system lying between the notification system and the licensing system: this is a simplified authorisation system called the “Registration System”. ASN has prepared a nomenclature to allocate the various categories of nuclear activities to one of these three systems, whose implementation begins on 1 January 2019 with the entry into effect of the ASN resolution extending the notification system to new nuclear activities which until now were subject to licensing (see the “notification system” heading below). • The licensing system Small-scale nuclear activities stand out through their extreme heterogeneity and the very large number of licensees concerned. The licensing system is designed to regulate the nuclear activities involving the greatest radiation protection implications, for which ASN checks, when examining the application file, that the applicant has identified the risks and that the barriers intended to limit their effects have been studied and planned for. As part of this licensing simplification process, ASN has produced licensing application forms adapted to each activity which are available on asn.fr . These documents are designed for the licensing applications to be formulated by the representative of a legal person, although it is possible for a physical person to apply for a license. The forms list the documents that must be enclosed with the application. All the other documents listed in the appendix to ASN resolution 2010-DC-0192 of 22 July 2010 must be held by the applicant and kept at the disposal of the inspectors in the event of inspection. On completion of the examination, and provided that the measures described by the applicant are satisfactory, a limited-term (usually 5 years) license is issued for the exercise of the nuclear activity. • The notification system As part of the allocation of the nuclear activity classification into the three administrative systems introduced by the abovementioned Decree, ASN wanted to implement a more graded approach, more proportionate to the risks. Its initial work focused on the notification system. Notification is a simple procedure which does not require the transmission of any supporting documents. It is particularly suited to the nuclear activities that present the lowest risks for people and the environment. Since April 2018, those responsible for a nuclear activity in the industrial, research or veterinary sectors, that comes under the notification system, can carry out the notification procedure via the ASN “on-line services” portal. Through ASN resolution 2018-DC-0649 of 18 October 2018 approved on 21 November 2018 (see the “Regulatory news” sheet on p. 22), ASN has extended the list of activities subject to notification. The notification system extension should concern about 6,000 files which were previously subject to the licensing system. International think tank on alternative technologies Radioactive sources present safety and security risks for their users, the general public and the environment, which must be taken into consideration when considering the inititiation of a nuclear activity. Consequently, in France, when technologies presenting lower risks than a nuclear activity are available under technically and economically acceptable conditions, they must be implemented instead of the nuclear activity initially envisaged: this is the principle of justification. On this basis, as of 2014 and subsequently at the Washington Summit on nuclear security in April 2016, France was the initiator of an international initiative now supported by 31 States and by Interpol. The aim is to support research into and the development of technologies that do not use high-activity sealed radioactive sources and to promote their use. In this context, since April 2015 ASN has, along with the National Nuclear Security Administration (United States), initiated an informal think tank involving several States working on the subject of replacing high-activity radioactive sources by alternative technologies. The aim of this group, which meets once a year, is to foster greater awareness of the benefits of such alternatives and to share experience feedback from each country in this respect. ASN has contributed to these meetings by presenting the operations carried out by the French blood transfusion agency, in application of the principle of justification, to replace those of its irradiators that use radioactive sources by electrical irradiators that emit X-rays. ASN also invited the French Confederation for Non-Destructive Tests to present the progress of its work in replacing gamma radiography by other non-destructive testing technologies. The think tank continued its meetings in 2018. Other foreign licensees shared their experience, particularly in the use of electrical irradiators emitting X-rays for research activities. These meetings provide the opportunity to highlight both successful initiatives in the implementation of alternative technologies and difficulties in the development or implementation of these technologies which must be the subject of further consideration and complementary work. In December  2018, during the International Conference on Nuclear Security organised by the International Atomic Energy Agency (IAEA), the subject of alternative technologies was addressed by several presentations and two panel sessions, and the relevance of this think tank was underlined. ASN report on the state of nuclear safety and radiation protection in France in 2018  241 08 – SOURCES OF IONISING RADIATION AND THEIR INDUSTRIAL, VETERINARY AND RESEARCH APPLICATIONS 08