Although the removal operations have progressed over the last few years, not all the ICSDs have been removed by the deadline set in the Order of 18 November 2011, that is to say 5 December 2021. It is estimated that nearly one million ICSDs are still installed. Faced with this situation, ASN has been discussing with the professionals on continuing regulating the possession of such detectors and their removal and dismantling operations, in order to complete the transition of all the fire detection devices to the optical technology, while at the same time allowing for safe disposal of the removed ICSDs and the radioactive sources they contain. ASN has also continued discussions with other actors concerned by the problem of removal of these ICSDs, notably the Ministry of Ecological Transition, in order to study the various possible regulatory options. This has not resulted in a new regulatory instrument, but this does not call into question the removal and dismantling operations governed by the notifications, registrations or licenses issued by ASN, which enables the drive to remove the ICSDs to continue. ASN maintains close relations with Qualdion, an association created in 2011 which labels the companies that comply with the regulations relative to radiation protection and fire safety. The list of Qualdion-labelled companies is available on the Internet. ASN participates with the association in communication campaigns targeting the holders of ionic detectors and the professionals (Expoprotection trade fair, Mayors’ trade fair, etc.). Surge suppressors Surge suppressors (sometimes called lightning arresters), not to be confused with lightning conductors, are small objects with a very low level of radioactivity used to protect telephone lines against voltage surges in the event of lightning strike. These are sealed devices, often made of glass or ceramic, enclosing a small volume of air containing radionuclides to pre-ionise the air and facilitate electrical sparkover. The use of surge suppressors has been gradually abandoned since the end of the 1970s, but the number remaining to be removed, collected and disposed of is still very high (several million units). When installed, these devices represent no risk of exposure for individuals. However, there can be a risk of exposure and/or contamination, albeit very low, if these objects are handled without precautions or if they are damaged. ASN issued a reminder to the company Orange (formerly France Télécom), which has begun an experimental process to identify, remove, sort and dispose of surge suppressors in the Auvergne region and has proposed a national removal and disposal plan. This plan was presented to ASN, and led in September 2015 to the issuing of a license governing the removal of all surge suppressors containing radionuclides present on the Orange network in France and their interim storage on identified sites. This license was renewed in 2021. The search for a disposal route is in progress in collaboration with the French National Agency for Radioactive Waste Management (Andra). The removal and disposal plan is being gradually implemented and should be completed in 2024. Lastly, Réseau de Transport d’Électricité (RTE), the French power transmission utility, filed an application for a license in late 2021 to remove the surge arresters installed on its network. Lightning conductors Radioactive lightning conductors were manufactured and installed in France between 1932 and 1986. The ban on the sale of radioactive lightning conductors was declared in 1987. This Order did not make the removal of installed radioactive lightning conductors compulsory. Consequently, there is no obligation at present to remove the radioactive lightning conductors installed in France, except in certain ICPEs (Order of 15 January 2008 which set the removal deadline at 1 January 2012) and in certain installations under Ministry of Defence responsibility (Order of 1 October 2007 which set a removal deadline at 1 January 2014). ASN nevertheless expects all existing radioactive lightning conductors to be removed and transferred to Andra, given the risks they can represent, depending in particular on their physical condition. For several years now ASN has been working to raise professional awareness of the radiation risks for workers and the public. ASN has stepped up its action in this respect by reminding the professionals of their obligations, particularly that of being licensed or registered by ASN for the removal and storing of lightning conductors pursuant to Articles L. 1333-1 and 2, L. 1333-8, and R. 1333-104 of the Public Health Code. ASN conducts field oversight operations targeting the companies involved in recovering these objects, combined with unannounced inspections on the removal sites. Andra estimates that some 40,000 radioactive lightning con– ductors were installed in France. Nearly 11,000 have already been removed and recovered by Andra. The current rate of removal is about 275 per year. 2.3 The regulatory changes 2.3.1 Tightening the regulation of electrical devices emitting ionising radiation ASN considers that the regulatory oversight of suppliers of electrical devices emitting ionising radiation is still insufficient, when the placing of devices on the market is so vitally important for the optimisation of the future radiation exposure of users. The work carried out by ASN in this area, which at present is directed towards the use of these devices, particularly in enclosures, has led to the publication of ASN resolution 2017-DC-0591 of 13 June 2017 setting the minimum technical design rules applicable to facilities that use X-rays. This resolution came into effect on 1 October 2017. It replaces ASN resolution 2013-DC-0349 of 4 June 2013 without creating additional requirements for already compliant facilities. It concerns facilities in the industrial and scientific (research) sectors, such as industrial X-ray radiography in bunkers and veterinary radiology. It takes account of experience feedback and sets the radiation protection goals by adopting a graded approach to the risks. ASN considers that these provisions, which are directed exclusively at the use these devices, must be supplemented by provisions concerning their actual design. This is because, for electrical devices used for non-medical purposes, there is no equivalent of the “CE” marking that is mandatory for medical devices, certifying conformity with several European standards that cover various aspects, including radiation protection. Furthermore, experience feedback shows that a large number of devices do not have a certificate of conformity to the standards applicable in France. These standards have been mandatory for many years now, but some of their requirements have become partly obsolete or inapplicable due to the lack of recent revisions. On the basis of the work done in collaboration with the Electrical Certification and Testing Entity (LCIE), the Alternative energies and Atomic Energy Commission (CEA) and IRSN, draft texts have been produced with the aim of defining minimum radiation protection requirements for the design of these devices; an informal technical consultation of the stakeholders (suppliers, French and foreign manufacturers and the principal users) was conducted in 2015. The various contributions are currently being analysed with the assistance of IRSN and the reference players (CEA and LCIE). The conclusions of this work will be taken into account to adapt the regulatory framework and subject the supply of electrical devices emitting ionising radiation to licensing, in the same way as for radioactive sources. In 2021, ASN Report on the state of nuclear safety and radiation protection in France in 2021 241 08 – SOURCES OF IONISING RADIATION AND THEIR INDUSTRIAL, VETERINARY AND RESEARCH APPLICATIONS 08 07 13 04 10 06 12 14 03 09 05 11 02 AP 01
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