ASN Report 2020

ASN inspectors ASN has inspectors designated and accredited by its Chairman, pursuant to Decree 2007-831 of 11 May 2007 setting the procedures for appointing and accrediting nuclear safety inspectors, subject to their having acquired the requisite legal expertise and technical skills through professional experience, mentoring or training courses. The inspectors take an oath and are bound by professional secrecy. They exercise their inspection activity under the authority of the ASN Director General and benefit from regularly updated practical tools (inspection guides, decision aids) to assist them in their inspections. As part of its continuous improvement policy, ASN encourages the exchange and integration of best practices used by other inspection organisations: ∙ by organising international exchanges of inspectors between Safety Authorities, either for the duration of one inspection or for longer periods that could extend to a secondment of up to several years. Thus, after having observed its advantages, ASN adopted the concept of in-depth inspections described earlier. However, ASN did not opt for the system involving a resident inspector on a nuclear site, as ASN considers that its inspectors must work within a structure large enough to allow experience to be shared and that they must take part in inspections on different licensees and facilities in order to acquire a broader view of this field of activity. This choice also allows greater transparency in the exercise of the respective responsibilities of the licensee and the inspector; ∙ by welcoming inspectors trained in other inspection practices. ASN encourages the integration into its departments of inspectors from other regulatory authorities, such as the Regional Directorate for the Environment, Planning and Housing (Dreal), French National Agency for Drug and Health Product Safety (ANSM), Regional Health Agencies (ARS), etc. ASN also proposes organising joint inspections with these authorities on activities falling within their common areas of competence; ADAPTATION OF INSPECTION DURING THE HEALTH CRISIS ASN carried out the scheduled inspections in its 2020 programme up until the first lockdown on 16 March 2020. On that date, the inspectors, as well as the licensees and nuclear activity managers, were subject to working restrictions, designed to halt the spread of Covid-19. Unless absolutely necessary, for example if a significant event occurred, the on-site inspections were suspended. ASN immediately began to look at ways of continuing with its inspections. ASN rapidly defined methods for remote-inspection by the inspectors. These notably involved examining documents relating to routine operations (periodic test records, operating documents, etc.) along with audio and video conferences with the activity manager. ASN used digital tools, hitherto little employed, such as real-time and off-line remote-examination of the physical operating parameters of the reactors. In order to take account of the significant reduction in maintenance work on the facilities, this type of inspection first of all targeted operational activities (operation of reactors, periodic tests, etc.). The follow-up letters for the inspections performed remotely are placed online on the asn.fr website, in the same way as the on-site inspections. In the medical facilities, and as detailed in chapter 7, ASN first of all suspended its inspections during the first lockdown, to avoid creating an additional workload on hospital structures already under considerable pressure. The inspections were subsequently carried out after first of all checking that the facilities were in a position to make their teams available to answer the inspectors’ questions. At the beginning of April, ASN reassessed the inspections that it was essential to perform on-site, targeting field observations that could not be carried out remotely, as well as topics of particular importance during the crisis, such as waste management, or the organisation of the teams in a pandemic context. The on-site inspections thus resumed in early May, with strict rules in place to ensure the safety of the inspectors and those with whom they were in contact. Therefore, between 15 March and 15 May 2020, 18 on-site inspections were carried out: 12 on safety and the possible consequences of the epidemic on the working of the facilities and 6 on labour inspectorate subjects. 26 inspections were conducted remotely during this period. At the beginning of June, ASN decided to plan ahead, given the uncertainties surrounding the health situation and set priorities for its entire inspection programme for 2020, defining: ཛྷ those inspections to be performed in 2020; ཛྷ those which may be cancelled or postponed to 2021. The objectives of the initial inspection programme were also revised: the prioritisation made it possible to estimate the volume of inspections that might not be maintained owing to lockdown, targeting those with lesser safety implications. Following this step, ASN planned to perform about 1,500 inspections in 2020. The pace of inspections, both on-site and remotely, returned to normal as of mid-June, reaching the same level as in previous years up until the end of the year, despite the changing health situation. More particularly, during the second lockdown, on-site inspections were considered to be activities for which home-working was not applicable and the rate of inspection remained at a satisfactory level. For 2020, a total of 1,573 inspections was carried out. Fewer than 400 inspections were cancelled for various reasons, as a result of prioritisation and constraints external to ASN, for example the workload on hospitals treating Covid-19 patients, or the postponement of reactor outages. The true benefit of remote-inspections for suitable topics, combining them with a field part (“mixed” inspections) if necessary, and categorisation of the inspections according to the priorities established, giving greater flexibility to the inspection programme in the case of particular events, are the two main lessons learned and will be continue to be used by ASN. THE IMPACT OF COVID-19 ASN Report on the state of nuclear safety and radiation protection in France in 2020 153 03 – REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION 03