2.6 Regulations governing the transport operations within the perimeter of nuclear facilities Dangerous goods transport operations can take place on the private roads of nuclear sites, in what are referred to as “on-site transport operations”. Such operations are not subject to the regulations governing the transport of dangerous goods, which only apply on public roads. However, these operations present the same risks and detrimental effects as dangerous goods transports on the public highway. The safety of these operations must thus be overseen with the same rigour as for any other risk or detrimental effect present with the perimeter of BNIs. This is why the on-site transport of dangerous goods is subject to the requirements of the Order of 7 February 2012 setting out the general rules applicable to BNIs. This Order requires that on-site transport operations be incorporated into the baseline safety requirements for BNIs. The Environment Code, supplemented by ASN resolution 2017‑DC-0616 of 30 November 2017, defines the on-site transport operations for which authorisation must be requested from ASN. In addition, in 2017, ASN published Guide No. 34 providing the licensees with recommendations for implementing the regulatory requirements concerning on-site transport operations. Finally, in 2020, ASN extended the on-line notification and on-line transmission functions to deal with requests for noteworthy changes to on-site transports as set out in Articles R. 593‑59 and R. 593‑56 of the Environment Code. 3 // Roles and responsibilities in regulating the transport of radioactive substances 3.1 Regulation of nuclear safety and radiation protection In France, ASN has been responsible for regulating the safety and the radiation protection of transports of radioactive substance for civil uses since 1997, while the Defence Nuclear Safety Authority (ASND) fulfils this role for transports relating to national defence. Within its field of competence, ASN is responsible, in terms of safety and radiation protection, for the regulation and oversight of all steps in the life of a package: design, manufacture, maintenance, shipment, actual carriage, receipt and so on. 3.2 Protection against malicious acts The prevention of malicious acts consists in preventing sabotage, losses, disappearance, theft and misappropriation of nuclear materials (as defined in Article R*.1411-11-19 of the Defence Code) that could be used to manufacture weapons. The Defence and Security High Official (HFDS), under the Minister responsible for energy, is the Regulatory Authority responsible for preventing malicious acts targeting nuclear materials. In the field of transport security, the IRSN Transport Operations Section (EOT) is responsible for managing and processing applications for approval of nuclear material shipments, for supervising these shipments and for notifying the authorities of any alerts concerning them. This security duty is defined by the Order of 18 August 2010 relative to the protection and regulation of nuclear materials during transport. Thus, prior to any transport operation, the Defence Code obliges the carriers to obtain a transport authorisation. The EOT reviews the corresponding application files. This review consists in checking the conformity of the intended provisions with the requirements defined by the Defence Code and the abovementioned Order of 18 August 2010. ASN has initiated the process to update its resolution 2015-DC0503 of 12 March 2015 relative to the notification system for companies transporting radioactive substances on French soil. This update aims to introduce an authorisation system for the transport of the most radioactive sources, in the light of their security implications. In 2019, ASN held a public consultation on the orientations it was planning to adopt for this update. ASN will complete this update, primarily focusing on the interface between the provisions taken from the new regulations on the protection of ionising radiation sources and batches of category A, B, C and D radioactive sources against malicious acts (Order of 29 November 2019, amended) and the transport regulations. 3.3 Regulation of the transport of dangerous goods Regulation of the transport of dangerous goods is the responsibility of the Dangerous Materials Transport Commission (MTMD) of the Ministry responsible for the environment. This entity is tasked with measures relative to the safe transport of dangerous goods other than class 7 (radioactive) by road, rail and inland waterways. It has a consultative body (standing sub-committee in charge of dangerous goods transport, within the High Council for the Prevention of Technological Risks), that is consulted for its opinion on any draft regulations relative to the transport of dangerous goods by rail, road or inland waterway. Inspections are carried out by land transport inspectors attached to the Regional Directorates for the Environment, Planning and Housing (Dreals). For the regulation of dangerous goods to be as consistent as possible, ASN collaborates regularly with the administrations concerned. ASN regularly takes part in the training of the General Directorate for Civil Aviation (DGAC) inspectors responsible for the inspection of air transport of dangerous goods in order to present them with the specificities of class 7 and to share experience feedback from ASN’s inspections on these subjects. The breakdown of the various inspection duties is summarized in Table 3. ASN Report on the state of nuclear safety and radiation protection in France in 2021 269 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES 08 07 13 04 10 06 12 14 03 09 05 11 02 AP 01
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