ASN Report 2020

products, three of which were notified as being level 1 on the INES scale. These consisted in workers exceeding the applicable regulatory occupational exposure limit. The fourth event rated ‘level 1’ on the INES scale was an excepted package, carrying contaminated equipment and tools, with a contact dose rate exceeding the applicable regulatory limit. Graph 5 shows the breakdown of significant events notified per notification criterion and Graph 6 presents the breakdown according to content and mode of transport. ASN observes that most EITs are notified by nuclear industry players, with few notifications from players in the medical and non-nuclear industry sectors despite the transport traffic concerned. ASN does however point out that notification of EITs is not a regulatory obligation. Causes of events The recurring causes of the Significant Events (EST) notified in 2020 include the following: ∙ non-conformities affecting a package: these mainly concern errors in calculation of the transport index leading to incorrect labelling and non-compliance with certain provisions indicated in the safety case or the user’s instructions. These events had no actual consequences for safety or radiation protection. However, in certain conditions, in the event of an accident, the strength of the package could be reduced; ∙ conveyance placarding faults or deficiencies in the transport documents; ∙ the presence of contamination spots exceeding the regulatory limits, mainly detected on conveyances which have been used to transport spent fuel packages. With regard to radiation protection, the impact of these events is low because the contamination spots detected were inaccessible; ∙ stowage errors concerning contaminated equipment and tools transported in containers; ∙ delivery errors or temporarily mislaid packages. The EIT of which ASN was notified are primarily deviations relating to incorrect labelling of packages, the absence of transport documents, as well as minor traffic accidents which did not compromise the safety of the package being transported. 4.3  Participation in drawing up the regulations applicable to the transport of radioactive substances 4.3.1 Participation in the work of the International Atomic Energy Agency ASN represents France on the IAEA Transport Safety Standards Committee (TRANSSC) which brings together experts from all countries in order to review the IAEA Safety Standards constituting the basis of regulations concerning the transport of radioactive substances. With a view to constant improvement of the safety level, ASN played, for example, an active part in drafting the 2018 edition of this document, SSR-6, a French translation of which has been available since mid-2019. The publication of the IAEA guide for application of the radioactive materials transport regulation (SSG-26) is expected in 2021. 4.3.2 Participation in drafting of national regulations ASN takes part in the drafting of French regulations relative to the transport of radioactive substances. These regulations mainly consist of the Order of 29 May 2009 and the Orders of 23 November 1987 concerning the safety of ships and of 18 July 2000 concerning the transport and handling of dangerous materials in sea ports. ASN therefore sits on the High Council for the Prevention of Technological Risks, which is required to issue an opinion on any draft regulation for the transport of dangerous good by rail, road and inland waterway. ASN is also consulted by the Ministry responsible for transport when a modification of the three Orders mentioned above can have an impact on the transport of radioactive substances. In 2020, ASN thus issued an opinion on a draft Order modifying the Orders of 23 November 1987 and 29 May 2009. Finally, the regulatory framework for the protection of radioactive substances against malicious acts, excluding nuclear materials already covered by a specific regulation, was reinforced in 2019: ASN more specifically ensured that transport operations, during which the substances are particularly vulnerable, were suitably incorporated into the Order of 29 November 2019 concerning the protection of ionising radiation sources and batches of category A, B, C and D radioactive sources against malicious acts. 4.4  Contributing to public information Ordinance 2012-6 of 5 January 2012, modifying Books I and V of the Environment Code, extends the obligations for public information to the persons responsible for nuclear activities. Article L. 125-10 of the Environment Code sets the thresholds beyond which the person responsible for transport must communicate the information requested by a citizen. The thresholds are defined as being those “ above which, in application of the international conventions and regulations governing the transport of dangerous goods, of the Code of Transport and of their implementing texts, the transport of radioactive substances is subject to the issuance – by ASN or by a foreign Authority competent in the field of radioactive substance transport – of an approval of the transport package design or a shipment approval, including under special arrangement ”. Any citizen may therefore ask the persons in charge of transport Inspection of Isovital activities concerning the transport of radiopharmaceuticals On 19 October 2020, ASN carried out an inspection of the activities of Isovital, focusing on the radiation protection of workers and the environment, the services of radiation protection advisor and transport safety advisor. This inspection showed that radiation protection issues are not satisfactorily addressed by the company. The radiation protection organisation put into place by the company needs to be clarified both internally and for its radiation protection advisor services. In addition, the individual evaluations of exposure to ionising radiation and the risk assessments are not detailed enough to be able to justify the dose constraints defined and the classification of workers. Finally, several major shortcomings with respect to transport regulations were also found, notably a faulty quality management system, leading to certain documents being unavailable for inspection, no processing of deviations detected by ASN during the inspections, or the use of carriers not declared with ASN for subcontracted transport of radioactive substances. ASN will make sure that these shortcomings are corrected. 280 ASN Report on the state of nuclear safety and radiation protection in France in 2020 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES