ASN Report 2018

Graph 5 shows the breakdown of significant events reported according to notification criterion and Graph 6 presents the breakdown according to content and mode of transport. ASN observes that about 80% of EIT are reported by nuclear industry players, with few reports from players in the medical and non-nuclear industry sectors by comparison with the transport traffic concerned. ASN does however point out that notification of EITs is not a regulatory obligation. • Causes of events The causes of the significant events notified and requiring particular vigilance on the part of ASN include the following: ∙ ∙ material non-conformities affecting a package: use of inappropriate containment seals, loosening of screws during transport, periodic maintenance date exceeded, non- performance of a pre-departure tightness test, etc. These events had no actual consequences for safety or radiation protection. However, in the event of an accident, a non- conformity can impair the robustness of the package; ∙ ∙ the shipment of packages containing radioactive substances, without notification, as well as delivery errors or packages being temporarily mislaid; ∙ ∙ the packaging of radiopharmaceutical products and medical sources in inappropriate packagings; ∙ ∙ non-compliance with internal procedures, leading to the shipment of non-conforming packages (for example, container door not properly locked) or with inappropriate labelling; ∙ ∙ the presence of contamination spots exceeding the regulation limits. The impact of these events on radiation protection is low, because the contamination spots were present on the drums containing the ore, which are themselves carried inside closed metal containers. By comparison with 2017, the situation improved for packages of uranium ore from the mines, as the shipment procedures had themselves been improved. The EIT reported to ASN are primarily deviations relating to incorrect labelling of packages, the absence of transport documents, delivery errors and the discovery of foreign objects in empty packagings used to transport spent fuel. These foreign objects are discovered during packaging maintenance operations. The analysis of these events shows that the presence of foreign bodies that are larger or of a different nature could lead to radiolysis or criticality phenomena in certain conditions. ASN therefore requested that the licensees exercise particular vigilance regarding the procedures for loading of fuel in the packagings. 4.3  ̶  Participation in drawing up the regulations applicable to the transport of radioactive substances 4.3.1  –  Participation in the work of the IAEA ASN represents France on the Transport Safety Standards Committee (TRANSSC) which, under the auspices of the International Atomic Energy Agency (IAEA), brings together experts from all the countries in order to draw up the founding document for regulations concerning the transport of radioactive substances. With the aim of ensuring continuous improvement in the level of safety, ASN more particularly played an active part in drafting the new 2018 edition of this document, entitled “ Specific Safety Requirements – 6 ” (SSR-6). 4.3.2  –  Participation in drafting of national regulations ASN takes part in the drafting of French regulations relative to the transport of radioactive substances. These regulations mainly consist of the Order of 29 May 2009 and the Orders of 23 November 1987 concerning the safety of ships and of 18 July 2000 concerning the transport and handling of dangerous materials in sea ports. In this respect, ASN sits on the CITMD (Interministerial Hazardous Materials Transport Committee) that is consulted for its opinion on any draft regulations concerning the transport of dangerous goods by rail, road or inland waterway. ASN is also consulted by the Ministry responsible for Transport when a modification of the three Orders mentioned above can have an impact on the transport of radioactive substances. In 2018, ASN thus issued two opinions on draft orders modifying the Orders of 23 November 1987 and 29 May 2009. The regulatory framework for the protection of radioactive substances against malicious acts, excluding nuclear materials which are dealt with separately, will be developed in 2019. ASN will ensure that appropriate attention is given to their transport, during which the substances are particularly vulnerable. 4.4  ̶  Contributing to public information Ordinance 2012-6 of 5 January 2012, modifying Books I and V of the Environment Code, extends the public information obligations to the persons responsible for nuclear activities. It is Article L. 125-10 of the Environment Code that sets the threshold beyond which the person responsible for transport must communicate the information requested by a citizen. The thresholds are defined as being those “ above which, in application of the international conventions and regulations governing the transport of dangerous goods, of the Code of Transport and of their implementing texts, the transport of radioactive substances is subject to the issuance – by ASN or by a foreign Authority competent in the field of radioactive substance transport - of an approval of the transport package design or a shipment approval, including under special arrangement ”. Any citizen can therefore now ask Modification of the TMD Order: remote-notification of events The publication of the Order of 11 December 2018 modifying the Order of 29 May 2009 concerning the transport of dangerous goods by road, makes the use of ASN’s on-line services portal mandatory from 1 January 2019, for the notification of significant events concerning the transport of radioactive substances on the public domain. With a view to harmonisation, the on-line services portal will also be extended during the course of 2019 to the notification of on-site transport events of dangerous goods within Basic Nuclear Installations (BNI). Notification of an event as stipulated in the guide does not take the place of the obligation of immediately alerting ASN to any emergency situation. 272  ASN report on the state of nuclear safety and radiation protection in France in 2018 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES