ASN Report 2018

2.6  ̶  Regulations governing the transport operations within the perimeter of nuclear facilities Dangerous goods transport operations can take place on the private roads of nuclear sites, in what are referred to as “on-site transport operations”. Such operations are not subject to the regulations governing the transport of dangerous goods, which only apply on public highways. Since 1 July 2013, these transport operations have been subject to the requirements of the Order of 7 February 2012 setting out the general rules applicable to BNIs. This Order requires that on-site transport operations be incorporated into the safety baseline requirements for BNIs. The on-site transport of dangerous goods presents the same risks and inconveniences as the transport of dangerous goods on the public highway. Their safety must be overseen with the same rigour as for any other risk or inconvenience present within the perimeter of the BNI. In 2017, ASN published Guide No. 34 providing the licensees with recommendations for implementing the regulatory requirements concerning on-site transport operations. In 2018, ASN also authorised the new general rules for the on-site transport of dangerous goods within the installations of the French Alternative Energies and Atomic Energy Commission (CEA). Given that certain BNI licensees have not yet incorporated on-site transport operations into their general operating rules, ASN will continue its actions with regard to these licensees in 2019. 3 —  Roles and responsibilities in regulating the transport of radioactive substances 3.1  ̶  Regulation of nuclear safety and radiation protection In France, ASN has been responsible for regulating the safety and the radiation protection of transports of radioactive substance for civil uses since 1997, while ASND (the Defence Nuclear Safety Authority) fulfils this role for transports relating to national defence. Within its field of competence, ASN is responsible, in terms of safety and radiation protection, for the regulation and oversight of all steps in the life of a package: design, manufacture, maintenance, shipment, actual carriage, receipt and so on. 3.2  ̶  Protection against malicious acts The prevention of malicious acts consists in preventing sabotage, losses, disappearance, theft and misappropriation of nuclear materials (as defined in Article R*. 1411-11-19 of the Defence Code) that could be used to manufacture weapons. The Defence and Security High Official (HFDS), under the Minister responsible for Energy, is the Regulatory Authority responsible for preventing malicious acts targeting nuclear materials. In the field of transport security, the IRSN Transport Operations Section (EOT) is responsible for managing and processing applications for approval of nuclear material shipments, for supervising these transports and for notifying the authorities of any alerts concerning them. This security duty is defined by the Order of 18 August 2010 relative to the protection and regulation of nuclear materials during transport. Thus, prior to any transport operation, the Defence Code obliges the carriers to obtain a transport authorisation. The EOT reviews the corresponding application files. This review consists in checking the conformity of the intended provisions with the requirements defined by the Defence Code and the above-mentioned Order of 18 August 2010. In 2019, ASN intends to update its resolution 2015-DC-0503 of 12 March 2015 relative to the notification system for companies transporting radioactive substances on French territory. This update aims to introduce an authorisation system for the transport of the highest activity sealed sources, in the light of their safety and security implications. ASN will ensure satisfactory interfacing with the provisions established in the future regulations on the protection of ionising radiation sources and batches of category A, B, C and D radioactive sources against malicious acts and the transport regulations. 3.3  ̶  Regulation of the transport of dangerous goods Regulation of the transport of dangerous goods is the responsibility of the dangerous materials transport Commission of the Ministry responsible for the Environment. This entity is tasked with ensuring the measures relative to the safe transport of dangerous goods other than class 7 (radioactive) by road, rail and inland waterways. It has a consultative body (CITMD – Interministerial Hazardous Materials Transport Committee) that is consulted for its opinion on any draft regulations relative to the transport of dangerous goods by rail, road or inland waterway. Inspections in the field are carried out by land transport inspectors attached to the Dreals (Regional Directorates for the Environment, Planning and housing). For the regulation of dangerous goods to be as consistent as possible overall, ASN collaborates regularly with the authorities concerned. In 2019, ASN will take part in the training of DGAC (General Directorate for Civil Aviation) staff responsible for inspecting the air transport of hazardous goods in order to present the specificities of class 7 and to share experience feedback from ASN’s inspections on these subjects. The breakdown of the various regulatory missions is summarised in Table 3. ASN report on the state of nuclear safety and radiation protection in France in 2018  265 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES 09