ASN Report 2020

4.2.2 Packaging maintenance inspections The consignor or user of a packaging loaded with radioactive substances must be able to prove to ASN that this packaging is periodically inspected and, if necessary, repaired and maintained in good condition such that it continues to satisfy all the relevant requirements and specifications of its safety case and its approval certificate, even after repeated use. For approved packagings, the inspections carried out by ASN focus on, for example, the following maintenance activities: ∙ the periodic inspections of the components of the containment system (screws, welds, seals, etc.); ∙ the periodic inspections of the securing and handling components; ∙ the definition of the frequency of replacement of the packaging components which must take account of any reduction in performance due to wear, corrosion, ageing, etc. 4.2.3 Inspections of packages not requiring approval For the packages that do not require ASN approval, the 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 (safety case) demonstrating that the model meets the regulatory requirements, including that the model withstands the specified tests, along with a declaration of conformity delivered by the manufacturer attesting full compliance with the model specifications, must be kept at the disposal of ASN. The various inspections carried out in recent years confirm pro­ gress in compliance with this requirement and in implementation of the ASN recommendations detailed in its guide concerning packages which are not subject to approval (Guide No.7, volume 3). 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 certificate 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. Furthermore, ASN still finds shortcomings in the demonstra­ tion 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 include the following points: ∙ the description of the authorised contents per type of packaging; ∙ the demonstration that there is no loss or dispersion of the radioactive content under normal conditions of transport; ∙ 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. 4.2.4 Monitoring the shipment and transportation of packages 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. Approval certificate for the TN Eagle package On 21 December 2020, ASN issued a type B(U) fissile materials approval certificate for a new package model developed by Orano NPS (formerly TN International). This new package model, called TN Eagle, is designed for exclusive-use land and sea transport of spent fuel assemblies, as well as for their interim storage. The issue of this approval is aimed at transport operations and in no away anticipates the subsequent outcome of a request for dry storage of spent fuels in such packages, in France. Inspection of package shipment to the Taishan NPP On 29 September 2020, the ASN inspectors went to the port of Sète (Hérault département ) to control the shipment of FCC4 packages loaded with uranium oxide fresh fuel assemblies to the Taishan NPP in China. They observed the arrival of the road convoys and the loading of the maritime flats containing the packages onto a ship. They examined the handling means used and checked the compliance of the vehicles, the placarding and the labelling, as well as the qualification of the drivers. They also checked that the packages were in good condition and observed the package handling operations from the road vehicles into the ship’s hold. The inspectors also reviewed the transport documents to verify the traceability of package conformity as of departure, as well as the emergency protocol and the function sheets of those involved in the transport operations. One of the inspectors inspected the ship’s hold to check stowage of the packages and reviewed the loading plan and the handling resources available on the ship. The inspectors were accompanied by the French Institute for Radiation Protection and Nuclear Safety (IRSN) experts, who took radiological measurements, both on the packages and on the road vehicle, in order to check compliance with the regulation limits. No non-compliance was found as a result of these measurements. The inspectors found no noteworthy deviation as a result of their checks. They inspectors consider that the safety of the transport operations and its organisation were satisfactory. 278 ASN Report on the state of nuclear safety and radiation protection in France in 2020 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES