ASN Report 2020

to the appointing of a Radiation Protection Advisor (RPA – no noncompliance observed) and worker dose monitoring (less than 10% noncompliance observed). The inspectors have also noted that the frequency of gamma radiography device maintenance complies with the regulations. Likewise, all the operators inspected by ASN were, when necessary, in possession of the certificate of aptitude to operate industrial radiology devices (Camari) required by Article R. 4451-61 of the Labour Code. The inspectors also noted that the efforts made by the companies to train newly-arrived classified workers had been maintained. Thus, in 2020 this information was duly dispensed to the new arrivals in more than 85% of the inspected facilities concerned. However, the periodic refreshing of this training and its content require further improvements. Conversely, ASN is still concerned by the deviations seen in cordoning off the work zones on temporary worksites. Even if the deviations observed in 2020 are proportionally fewer in number than in 2019, they are still too frequent (one inspection out of four). ASN underlines that the lack of preparation and cooperation between the ordering customers and the radiography contractors before starting temporary worksites (particularly the failure to draw up a precise prevention plan) is one of the causes of these deviations. ASN points out that the work area must be cordoned off before the work begins and, in all events, before the radiography equipment is installed, that the cordoning off must be continuous and that it is essential to have warning lights in sufficient quantity. To ascer- tain that cordoning off ensures compliance with the regulatory dose rate values, it is vital to take at least one measurement and to record the result(s). Zoning and cordoning off effectively constitute the main safety barrier in worksite configurations, particularly to prevent unintended exposures. Consequently, ASN remains extremely vigilant regarding this point, which is systematically checked during worksite inspections; moreover, penal enforcement actions have already been proposed for serious breaches. ASN also notes disparities in the quality of the technical files it has to examine for inspection preparation or follow-up, and those received for license applications. The contractors must in particular be more attentive to the reports establishing the con­ formity of their facilities with the appropriate technical baseline requirements. ASN still detects errors too frequently, particularly when production of these reports has been subcontracted, and these errors sometimes lead to nonconformities. Furthermore, the inspections carried out in 2020 show that in a quarter of the cases the gamma radiography facility safety devices were not properly installed or verified. Lastly, the protection of ionising radiation sources against malicious acts (see box on next page) must be further improved. For example, the individual authorisations for access to radio­ active sources were correctly drawn up in less than half the inspected sites. With regard to application of the principles of justification and optimisation, the long-term reflections undertaken by the non- destructive testing professionals have resulted in guidelines which aim to promote the use of alternative methods to industrial radiography. The work is continuing within the professional bodies, in particular with the updating of the construction and maintenance codes for industrial equipment, in order to promote the use of non-ionising inspection methods. Furthermore, France has a large network of fixed industrial radiography facilities (99 gamma radiography facilities are licensed in France in 2020), enabling 70% of the professionals to propose industrial radiography services in bunkers. ASN considers that the risks of incidents and the workers’ occupational exposure are generally well controlled by the licensees when radiography is performed in a bunker complying with the applicable regulations. Despite the availability of such facilities, ASN still observes too often that parts that undergo radiography on worksites, particularly those scheduled at night in workshops, could have been easily moved to a bunker. Apart from optimising doses for the workers, it would also eliminate the risk of having to temporarily shut down the workshop in the event of an incident preventing the radioactive source of the gamma ray projector from returning to the safe position. ASN considers that the ordering customers have a key role to play to improve radiation protection in industrial radiography, by favouring industrial radiography services in facilities that have a bunker. Enhancing the awareness of all the players is therefore a priority. The regional initiatives to establish charters of good practices in industrial radiography implemented for several years now at the instigation of ASN and the labour inspectorate, particularly in areas corresponding to the former regions of Provence-Alpes- Côte d’Azur, Haute-Normandie, Rhône-Alpes, Nord-Pas-de- Calais, Bretagne and Pays de la Loire, allow regular exchanges between the various stakeholders. The ASN regional divisions and other regional administrations concerned also regularly organise regional awareness-raising and discussion symposia for which the actors of this professional branch show a real interest. Spotlight on regulatory annual maintenance operations on gamma radiography devices At the end of 2020, ASN conducted an inspection focusing on the annual maintenance of gamma radiography devices (projectors and accessories) required by the regulations, on the premises of the main supplier of these devices, who is also responsible for these maintenance operations. The purpose of this inspection was to check the management and traceability of the maintenance operations (including the sealed radioactive source loading/unloading operations) performed by the supplier and comparing the information at its disposal with that obtained (mainly maintenance reports) throughout 2020 during the ASN inspections on non-destructive testing sites. On the basis of a sampling inspection of half of the 160 or so maintenance reports collected, the inspectors checked that the information presented by the gamma radiography device users was consistent with the information established by the supplier. The inspectors concluded that the supplier’s administrative tracking of all the operations conducted on the gamma ray projectors and their accessories was functional and generally satisfactory. This inspection formed part of the anti-fraud actions implemented by ASN for several years now to check the veracity of the documents presented by the licensees. No attempt to falsify documents by either the supplier or the users of gamma radiography device supplier was detected. 256 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