ASN Report 2020

Knowledge of the regulations applicable to the transport of radioactive substances seems to be sub-standard in the medical sector in particular, where the procedures adopted by some hospitals or nuclear medicine units for package shipment and reception need to be tightened. Their quality management system has not yet been formally set out and deployed, more specifically with regard to the responsibilities of each member of staff involved in receiving and dispatching packages. More generally, in transport operations for small-scale nuclear activities, the radiological protection programmes and the safety protocols have not yet been systematically defined. ASN also found that checks on vehicles and packages prior to shipment could be improved. The inspections concerning the transport of gamma ray projectors regularly reveal inappropriate stowage or tie-down. In the BNI sector, ASN considers that the consignors must improve how they demonstrate that the content actually loaded into the packaging complies with the specifications of the approval certificates and the corresponding safety cases, including if this demonstration is provided by a third-party. In this latter case, the consignor’s responsibilities then require that it verify that this demonstration is appropriate, and that it monitor the third-party company in accordance with the usual methods of a quality assurance system. As BNI licensees are increasingly using contractors to prepare and ship packages of radioactive substances, ASN is paying particularly close attention to the organisation put into place to monitor these contractors. Finally, with regard to on-site transports within NPPs, ASN considers that the licensees must remain vigilant to the applic­ ation of package stowage rules. 4.2.5 Oversight of preparedness for emergency situations management In order to enhance the preparedness of the transport operators (mainly consignors and carriers) for emergency situations management, ASN published Guide No. 17 in December 2014 on the content of accident and incident management plans concerning the transport of radioactive substances. This Guide recommends the production of plans to prepare for emergency situations management and stipulates their minimum contents. 4.2.6 Analysis of transport events The safety of the transport of radioactive substances relies in particular on the existence of a reliable system for detecting and processing anomalies, deviations or, more generally, any abnormal events that could occur. Therefore, once detected, these events must be analysed in order to: ∙ prevent identical or similar events from happening again, by taking appropriate corrective and preventive measures; ∙ prevent a more serious situation from developing by analysing the potential consequences of events which could be precursors of more serious events; ∙ identify the best practices to be promoted in order to improve transport safety. The regulations also requires online notification to ASN of the most significant events so that it can ensure that the detection system, the analysis approach and the integration of operating experience feedback are effective. This also provides ASN with an overview of events so that the sharing of operating experience feedback can be encouraged between the various stakeholders – including internationally – and so that ASN can consider potential changes to the provisions governing the transport of radioactive substances (see box page 282). As required by Article 7 of the Order of 29 May 2009, amended, concerning the transport of dangerous goods by land, any significant event concerning the transport of radioactive substances, whether the consequences are actual or potential, must be notified to ASN within four working days, as stipulated in its Guide No.31 on the notification of events. This Guide, which was entirely revised in 2017, is available on asn.fr . After notification, a detailed report of the event must be sent to ASN within two months. Events notified in 2020 In 2020, in the field of the transport of radioactive substances, ASN was notified of 71 events rated ‘level 0’ on the International Nuclear and Radiological Event Scale (INES scale) and 4 events rated ‘level 1’. A slight drop in the number of ‘level 0’ events is observed by comparison with 2019, whereas the number of ‘level 1’ events remains stable. Graph 4 shows the variations in the number of significant events notified since 2003. ASN was also notified of 33 Events of Interest for the Safety of Transports (EIT), a figure which is stable by comparison with 2019. Because they have no actual or potential consequences, these events are not rated on the INES scale. There is thus no obligation to notify ASN, but the latter does encourage periodic information so that it has an overview of the EITs and can detect any recurrence or trends which could be indicative of an issue. Sectors concerned by these events Most of the significant events notified concern the nuclear industry. Only just over 10% concern transports related to the non- nuclear industry (primarily the transport of gamma ray projectors). Nearly one quarter concern the transport of pharmaceutical Inspection of a fresh fuel shipment en route for the Flamanville EPR reactor In preparation for the future commissioning of the new EPR reactor at Flamanville, EDF has started to receive the first fresh fuel assemblies in the installation (fuel building pool). At the end of 2020, this involved a number of road shipments from the Framatome plant at Romans-sur-Isère. The inspections concerning this type of transport operation are generally carried out on departure from the plant or at arrival in the Nuclear Power Plant (NPP); they can however be performed at another point along the route. A team of ASN inspectors thus performed an unannounced evening inspection when the convoy stopped for the night along the route. This was an opportunity to inspect the compliance of the transport operations, of the vehicles and of the qualification of the drivers. ASN also checked correct implementation of the regulation regarding radiological zoning that is applicable during this type of prolonged stay. This inspection revealed no significant deviations from the regulations in force. The operator of the stopover site was also notified of a few points meriting minor improvement. ASN Report on the state of nuclear safety and radiation protection in France in 2020 279 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES 09