ASN Report 2020

4. ASN action in the transport of radioactive substances 4.1  Issuance of approval certificates and shipment approvals The type B and C packages, as well as the packages containing fissile materials and those containing more than 0.1 kilogramme of UF 6 require an ASN approval certificate in order to be transported. The designers of the package models who request approval from ASN must support their application with a safety case demonstrating the compliance of their package with all the regulatory requirements. Before deciding whether or not to issue an approval certificate, ASN reviews these safety cases, drawing on the expertise of IRSN, in order to ensure that the safety cases are pertinent and conclusive. If necessary, the approval certificate is issued with requests in order to further improve the safety cases. In some cases the IRSN appraisal is supplemented by a meeting of the ASN Advisory Committee for Transports (GPT). The opinions of the Advisory Committees are always published on asn.fr . The approval certificate specifies the conditions for the manufacture, utilisation and maintenance of the transport package. It is issued for a package model, independently of the actual shipment itself, for which no prior ASN opinion is generally required. This shipment may however be subject to security checks (physical protection of the materials against malicious acts under the supervision of the HFDS of the Ministry for the Environment). These approval certificates are usually issued for a period of five years. If a package is unable to meet all the regulatory requirements, the regulations nonetheless allow for its transport by means of a shipment under special arrangement. The consignor must then define compensatory measures to ensure a level of safety equivalent to that which would have been obtained had the regulatory requirements been met. For example, if it cannot be completely demonstrated that a package is able to withstand the 9 m drop, a compensatory measure may be to reduce the speed of the vehicle, have it escorted and choose a route avoiding such a drop height. The probability of a serious accident, and thus of a violent shock on the package, is thus considerably reduced. A shipment under special arrangement is only possible with the approval of the competent authority, which then issues approval for shipment under special arrangement, stipulating the compensatory measures to be applied. In the case of certificates issued abroad, the international regulations provide for their recognition by ASN. In certain cases, this recognition is automatic and the foreign certificate is directly valid in France. In other cases, the foreign certificate is only valid if endorsed by ASN, which then issues a new certificate. In 2020, 39 approval applications were submitted to ASN by the manufacturers. ASN issued 32 approval or shipment authorisation certificates, for which the breakdown according to type is presented in Graph 2. The nature of the transports and packages concerned by these certificates is presented in Graph 3. In 2019, Robatel initiated the development of a new packaging, called R85, designed for the road or rail transport of irradiated and contaminated control rod cluster guide tubes from French NPPs. Before shipment, the package may be stored for several years. In mid-2020, ASN issued a favourable opinion on the safety options for this new package model, after considering the new provisions of the 2018 edition of IAEA’s SSR-6 regulations. In 2021, it will examine the approval certificate application received at the end of 2020. 4.2  Monitoring all the stages in the life of a package ASN performs inspections at all the stages in the life of a package: from manufacture and maintenance of a packaging, to package preparation, shipment and reception. In 2020, ASN carried out 62 inspections in the field of radioactive substances transport (all sectors considered). The follow-up letters to these inspections are available on asn.fr . 4.2.1 Regulation of package manufacturing The manufacture of transport packaging is subject to the regulations applicable to the transport of radioactive substances. The manufacturer is responsible for producing packagings in accordance with the specifications of the safety case, demonstrating regulatory compliance of the corresponding package model. To do this, it implements a quality management system covering all the operations from procurement of parts and raw materials up to final inspections. Furthermore, the manufacturer must be able to prove to ASN that it complies with the regulatory provisions and, in particular, that the as-built packagings are compliant with the specifications of the safety case. The inspections carried out by ASN in this field aim to ensure that the manufacturer satisfactorily fulfils its responsibilities. In 2020, ASN carried out four inspections on the manufacturing of various packagings for which ASN had issued an approval certificate, at various steps in the manufacturing process: welding, final assembly, manufacturing completion checks, assembly of internals (to immobilise the contents), etc. During these inspections, ASN reviews the quality management procedures implemented for the manufacture of a packaging on the basis of the design data and verifies their effective implementation. ASN ensures that the inspections performed by or on behalf of the manufacturer and any manufacturing deviations are traceable. It also visits the manufacturing shops to check the package components storage conditions, the calibration of the inspection instruments and compliance with the technical procedures at the various manufacturing steps (welding, assembly, etc.). ASN checks the monitoring of package manufacturing by the lead contractor and may intervene directly on the sites of any subcontractors, who may sometimes be located abroad. For example, on 10 and 11 December 2019, in a plant in Germany, ASN and the German competent authority for transport ( Bundesanstalt für Materialforschung und Prüfung – BAM), jointly inspected the manufacture of new DN 30 overpacks used to transport UF 6 in 30 B cylinders. One point investigated by the inspectors was how Daher, the ordering customer, monitored its subcontractor. ASN may also inspect the manufacture of the specimens used for the drop tests and fire tests required by the regulations. The objectives are the same as for the series production model because the specimens must be representative and comply with the maximum requirements indicated in the mock-up manufacturing file, which will determine the minimum characteristics of the actual packaging to be manufactured. In 2021, ASN intends to continue spot-check inspections of transport packaging manufacturing. This is because the irregularities detected at the Creusot Forge plant, some of which affected certain transport packagings, confirmed the importance of inspecting the packaging manufacturing and maintenance operations. 276 ASN Report on the state of nuclear safety and radiation protection in France in 2020 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES