Abstracts ASN Report 2019

ג ِ א ِ ב XȇɀȵƺƬɎǣȒȇɀ Ȓǔ ȵƏƬǸƏǕƺɀ ȇȒɎ ȸƺȷɖǣȸǣȇǕ ƏȵȵȸȒɮƏǼ łŅ ŇĻĸ ŃĴĶľĴĺĸņ ŇĻĴŇ ķł ŁłŇ ŅĸńňļŅĸ ĴŃŃŅłʼnĴĿё ŇĻĸ 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 declaration of conformity delivered by the manufacturer attesting full compliance with the model specifications, must be available for ASN review, if needed. The inspections carried out in recent years confirm progress in compliance with this requirement and in implementation of the ASN recommendations detailed in its guide concerning packages ŊĻļĶĻ ĴŅĸ ŁłŇ ņňĵĽĸĶŇ Ňł ĴŃŃŅłʼnĴĿ Ҏ ňļķĸ łєׇӊё ʼnłĿňŀĸ ӆҏє This guide, updated in 2016, 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 declaration 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. ňŅŇĻĸŅŀłŅĸё ņŇļĿĿ ĹļŁķņ ņĻłŅŇĶłŀļŁĺņ ļŁ ŇĻĸ ķĸŀłŁņŇŅĴŇļłŁ by some of the players (designers, manufacturers, distributors, owners, consignors, companies performing the regulatory drop tests, package maintenance, etc.) of package conformity with the regulations. The areas for improvement focus in particular on the following: Ҋ the description of the authorised contents per type of package; Ҋ the demonstration that there is no loss or dispersion of the radioactive content under normal conditions of transport; Ҋ 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 rate limits with the maximum authorised content. ג ِ א ِ ג xȒȇǣɎȒȸǣȇǕ Ɏǝƺ ɀǝǣȵȅƺȇɎ ƏȇƳ ɎȸƏȇɀȵȒȸɎƏɎǣȒȇ Ȓǔ ȵƏƬǸƏǕƺɀ 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 transports concerning small- scale nuclear activities, the ASN inspections confirm significant disparities from one carrier to another. The differences most frequently identified concern quality management, actual compliance with the procedures put into place and radiation protection of the workers. ³z ǣȇɀȵƺƬɎǣȒȇ Ȓǔ ȅƏȇɖǔƏƬɎɖȸƺ Ȓǔ Ə Áz J ژב ȵƏƬǸƏǕƺ ٫ zȒɮƺȅƫƺȸ אژ ׎׏ ח ³z ǣȇɀȵƺƬɎǣȒȇ ǣȇ א ׎׏ ژח Ȓǔ ȵƏƬǸƏǕƺɀ ȇȒɎ ȸƺȷɖǣȸǣȇǕ ƏȵȵȸȒɮƏǼ In 2019, 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 designed, manufactured, marketed and maintained by the CNMO company with the regulations for the transport of radioactive substances. These packages, referred to as type A under the regulations, are more specifically used to transport contaminated equipment, radioactive waste and other radioactive substances. CNMO was unable to demonstrate that it had set up an appropriate management system to control and monitor its design, manufacturing and maintenance activities regarding packagings for the transport of radioactive substances, as required by the applicable regulations. On this subject, no improvement with ȸƺɀȵƺƬɎ ɎȒ Ɏǝƺ ȵȸƺɮǣȒɖɀ ǣȇɀȵƺƬɎǣȒȇ ǣȇ א ׎׏ ژב ɯƏɀ ȒƫɀƺȸɮƺƳِ If the consignor is unable to prove the compliance of the packages used with the regulations, the shipment cannot take place. ASN therefore required that CNMO inform its customers accordingly. 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 2020, ASN will therefore continue its efforts regarding the monitoring of package models not requiring approval. ASN Report on the state of nuclear safety and radiation protection in France in 2019 269 ׎ ٲ ח TRANSPORT OF RADIOACTIVE SUBSTANCES 09