ASN Report 2018

In 2018, ASN carried out three inspections on the conformity of maintenance operations. For example, on 6 June 2018, ASN examined the maintenance carried out on the R73 packagings intended for the transport of contaminated and activated waste. The ASN inspectors more particularly examined the organisation put into place by Robatel Industries to ensure the compliance of the maintenance and inspection operations with the requirements of the safety case. 4.2.3  –  Inspections of packages not requiring approval For the packages that do not require ASN approval, the consignor must, at the request of ASN, be able to provide the documents proving that the package model complies with the applicable regulations. More specifically, for each package, a file demonstrating that the model meets the regulation requirements and that it can in particular withstand the specified tests, along with a certificate delivered by the manufacturer attesting full compliance with the model specifications, must be held at the disposal of ASN. The various inspections carried out in recent years confirm the progress made concerning the documents presented to ASN and the implementation of the ASN recommendations detailed in its guide concerning packages which are not subject to approval (Guide No.7, volume 3). In 2016, ASN published the updated version of this guide. The guide proposes a structure and a minimum content for the safety cases demonstrating that packages which are not subject to approval do comply with all the applicable requirements, along with the minimum content of a declaration of conformity of a package design with the regulations. ASN thus noted improvements in the content of the certificate of conformity and the safety case drawn up by the relevant players, more specifically for the industrial package models. The representativeness of the tests performed and the associated safety case remain the focal points during the ASN inspections, in particular for type A packages. Furthermore, ASN still finds that some of the players (designers, manufacturers, distributors, owners, consignors, companies performing the regulatory drop tests, package maintenance, etc.) display shortcomings in the demonstration of package conformity with the regulations. The areas for improvement focus in particular on the following: ∙ ∙ the description of the authorised contents per type of package; ∙ ∙ the demonstration that there has been no loss or dispersion of the radioactive content under normal conditions of transport; ∙ ∙ compliance with the regulatory requirements regarding radiation protection, more specifically the demonstration as of the design stage that it would be impossible to exceed the dose limits with the maximum authorised content. In 2018, ASN carried out five inspections on the design, manufacture and maintenance of packages not requiring approval. It more specifically inspected the compliance of the packages marketed under the name of the ARPACK company with the regulations for the transport of radioactive substances. These packages are of the industrial type (IP) or type A, as defined by the regulations. They are used to transport, among others, contaminated items. During the inspection, the company marketing these packages was unable to present the safety cases corresponding to the package models currently used and was unable to justify that the safety case for the new ARPACK package model was able to fully demonstrate its safety. If the consignor is unable to prove the compliance of the packages used with the regulations, they are not authorised to transport radioactive substances. ASN therefore asked the company which leases and supplies packages of the ARPACK range to identify all the package models currently used and not covered by a conformity certificate or safety case compliant with ASN requirements and to implement an action plan, duly detailed and substantiated in the light of the corresponding safety issues, to remedy this situation. ASN also asked for details on the steps taken to inform the owners and users of the packages lacking a safety case demonstrating full compliance with the regulatory requirements. When taken individually, the packages not subject to approval represent little danger and accidents involving them have so far had limited radiological consequences. ASN must however remain vigilant given the very large number of these packages and the sometimes inadequate safety culture of those involved in their transport. The conformity with regulatory requirements of the packages not requiring approval has improved in recent years, although some deviations persist. In 2019, ASN will therefore continue its efforts regarding the monitoring of package models not requiring approval. 4.2.4  –  Monitoring the shipment and transportation of packages The scope of ASN inspections includes all regulatory requirements binding on each of the transport players, that is compliance with the requirements of the approval certificate or declaration of conformity, training of the personnel involved, implementation of a radiological protection programme, satisfactory stowage of packages, dose rate and contamination measurements, documentary conformity, implementation of a quality assurance programme, etc. More particularly with respect to small-scale nuclear activities, the ASN inspections confirm significant disparities from one transport operator to another. Among the observations or inspection findings, the most frequent discrepancies concern quality assurance, actual implementation of established procedures and worker radiation protection. Knowledge of the regulations applicable to the transport of radioactive substances seems to be sub-standard in the medical sector in particular, where the procedures adopted by some hospitals or nuclear medicine units for package shipment and reception need to be tightened. Their quality management system has not yet been formally set out and deployed, nor have the responsibilities of each member of staff involved in receiving and dispatching packages. Moreover, the radiological protection programmes and the safety protocols have not yet been systematically defined. ASN also found that checks on vehicles and packages prior to shipment could be improved. Finally, chocking and stowing defects are still found during gamma ray projector transport inspections. In the BNI sector, ASN considers that the consignors must improve how they demonstrate that the content actually loaded into the packaging complies with the specifications of the approval certificates and the corresponding safety cases. This demonstration is sometimes carried out by a third-party company. The consignor’s responsibilities require that, at the least, it verify that this demonstration exists and is sufficient, and that it monitor the third-party company in accordance with the usual methods of a quality assurance system. ASN has moreover observed that an increasing number of BNI licensees are using contractors to prepare and ship packages of radioactive substances. ASN is particularly attentive to ASN report on the state of nuclear safety and radiation protection in France in 2018  269 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES 09