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 for example concern 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 demonstrating that the model meets the regulation requirements and that it can in particular withstand the specified tests, along with a certification 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 progress 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 demonstration 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 concern the following points in particular: ∙ 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 smallscale nuclear activities, the ASN inspections confirm significant disparities from one carrier to another. The differences most frequently identified concern the quality assurance programme, actual compliance with the procedures put into place and radiation protection of the workers. 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 need to 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 application of package stowage rules. 4.2.5 Oversight of preparedness for emergency situations management In order to reinforce 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. 272 ASN Report on the state of nuclear safety and radiation protection in France in 2021 09 – TRANSPORT OF RADIOACTIVE SUBSTANCES
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