ASN Report 2020

of the principle of optimisation when examining the license applications, when conducting its inspections, and when analysing reported significant events. 2.4.2 Applicable licensing and notification systems Applications relating to the possession and utilisation of ionising radiation are examined by the ASN regional divisions, while those concerning the manufacture and supply of sources or devices containing sources are examined at the ASN head office by the Department of Transport and Sources (DTS). The entry into effect on 1 July 2018 of Decree 2018-434 of 4 June 2018, introducing various provisions in the nuclear field, has introduced a third administrative system lying between the notification system and the licensing system: this is a simplified authorisation system called the “registration system”. ASN has prepared a nomenclature to allocate the various categories of nuclear activities to one of these three systems, whose implementation begins on 1 January 2019 with the entry into effect of the ASN resolution extending the notification system to new nuclear activities which until now were subject to licensing (see the “notification system” heading below). The licensing system Small-scale nuclear activities stand out by their considerable diversity and the large number of licensees involved. The licensing system is designed to regulate the nuclear activities involving the greatest radiation protection implications, for which ASN checks, when examining the license application, that the applicant has identified the risks and that the measures intended to limit their effects have been studied and planned for. To support this licensing process, ASN has produced licensing application forms adapted to each activity and which are available on asn.fr . These forms are designed for the licensing applications to be formulated by the representative of a legal person, although it is possible for a physical person to apply for a license. These forms list the documents that must be enclosed with the application. All the other documents listed in the appendix to ASN resolution 2010-DC-0192 of 22 July 2010 must be held by the applicant and kept at the disposal of the inspectors in the event of inspection. On completion of the examination, and provided that the measures described by the applicant are satisfactory, a limited- term (usually 5 years) license is issued for the exercise of the nuclear activity. The notification system As part of the allocation of the nuclear activity classification into the three administrative systems introduced by the above­ mentioned Decree, ASN wanted to implement a more graded approach, proportionate to the risks. Its initial work focused on the notification system. Notification is a simple procedure which does not require the submission of any supporting documents. It is particularly suited to the nuclear activities that present the lowest risks for people and the environment. Since April 2018, those responsible for a nuclear activity in the industrial, research or veterinary sectors that comes under the notification system, can carry out the notification procedure via the ASN “online services” portal. Through ASN resolution 2018-DC-0649 of 18 October 2018 approved on 21 November 2018, ASN has extended the list of activities subject to notification. The notification system extension should concern about 6,000 companies or individuals which were previously subject to the licensing system. However, it will not be possible to accurately quantify the number of companies or individuals concerned until a five-year term is reached (31 December 2023). This is because, in accordance with the principle of grandfathering, the licenses issued before 1 January 2019 act as notification acknowledgements until the license reaches term, on condition that in the interim there is no change in the nuclear activity. This means that a number of nuclear activities, though now subject to notification, are still regulated by a license. International think tank on alternative technologies Radioactive sources present radiation exposure and safety risks for their users, the general public and the environment, which must be taken into consideration in the reflection phase preceding the deployment of a nuclear activity. Consequently, in France, when technologies presenting lower risks than a nuclear activity are available under technically and economically acceptable conditions, they must be implemented instead of the nuclear activity initially envisaged: this is the principle of justification. On this basis, as of 2014 and subsequently at the Nuclear Security Summit in Washington in April 2016, France was the initiator of an international initiative now supported by 31 countries and by Interpol. The aim is to support research into and the development of technologies that do not use high-activity sealed radioactive sources and to promote the use of these technologies. In this context, since April 2015 ASN has, along with the National Nuclear Security Administration (United States), initiated an informal think tank involving several countries working on the subject of replacing high-activity radioactive sources by alternative technologies. The aim of this group, which meets once a year, is to foster greater awareness of the benefits of such alternatives and to share experience feedback from each country in this respect. ASN has contributed to these meetings by presenting the operations carried out by the French blood transfusion agency, in application of the principle of justification, to replace those of its irradiators that use radioactive sources by electrical irradiators that emit X‑rays. ASN also invited the French Confederation for Non-Destructive Tests to present the progress of its work in replacing gamma radiography by other non-destructive testing technologies. In December 2018, during the International Conference on Nuclear Security organised by the International Atomic Energy Agency (IAEA), the subject of alternative technologies was addressed by several presentations and two panel sessions, and the relevance of this think tank was underlined. The meetings of the think tank continued in 2019. Other foreign licensees shared their experience, particularly in the use of electrical irradiators emitting X‑rays for research activities. These regular meetings provide the opportunity to highlight both successful initiatives in the implementation of alternative technologies and difficulties in the development or implementation of these technologies which must be the subject of further consideration and complementary work. The interchanges had to be interrupted in 2020 due to the Covid-19 pandemic, and should be resumed in 2021. 250 ASN Report on the state of nuclear safety and radiation protection in France in 2020 08 – SOURCES OF IONISING RADIATION AND THEIR INDUSTRIAL, VETERINARY AND RESEARCH APPLICATIONS