ASN Report 2022

During the pandemic, ASN implemented remote-inspection measures. This type of inspection has become one of the tools available to the inspectors and is suitable for certain inspection topics. On-site inspection however remains the preferred method. The implementation of remote inspection measures required ASN to modify the inspection indicators. For this type of inspection, the critical review of documents transmitted by a nuclear activity manager, during the on-site inspection preparation phases, becomes the primary method. It is then no longer possible to differentiate between preparation of the inspection, involving this documentary examination, and the inspection itself. The following paragraphs will therefore present the number of inspector.days corresponding to the on-site inspections and the number of remote inspections. The number of inspector.days in these paragraphs cannot therefore be directly compared with that of years before 2020, because it only reflects the time spent on the site and does not take account of the remote inspections. In addition, Table 5 presents the total number of inspector.days devoted to inspections, whether performed on-site, remotely, or using a combination of the two. ASN sends the licensee an inspection follow-up letter, published on, which officially documents: ∙ deviations between the situation observed during the inspection and the regulations or documents produced by the licensee pursuant to the regulations; ∙ anomalies or aspects warranting additional justifications; ∙ best practices or practices to which improvements could be made, even if not directly constituting requirements. The follow-up letter prioritises the actions requested by ASN, so that the licensees can also implement a graded approach to processing the deviations found and optimise management of the means at their disposal. In 2022, ASN finalised its work to update the text of its inspection follow-up letters. The main goal was to reinforce its graded approach and make it more legible. This work notably led to a new presentation of requests, findings and observations according to their potential consequences and to a reinforcement of the follow-up to the action taken further to the inspections for those subjects with the most serious implications. This revision was implemented as of mid-2022. The follow-up letters are now structured as follows: ∙ a summary of the inspection, which presents the subjects examined, the inspection process and the inspectors’ assessments. It can include the change observed with respect to a previous inspection; ∙ the inspection findings which, depending on their implications or their consequences, are either the subject of reasoned and prioritised requests, or are simply notified to the inspected entity without requiring any formal reply from it to ASN, in accordance with the following plan: I. the requests for priority actions, the implications of which warrant reactive processing and more in-depth follow-up; II. t he other requests: actions to be dealt with through an action plan with deadlines subject to ASN validation; III. findings and observations requiring no reply: findings of lesser importance made during the inspection, which require no formal reply from the inspected entity to ASN, but which it will nonetheless have to take into account, along with any observations the inspectors wish to make. In the event of a reoccurrence illustrating a systemic deficiency, these findings of lesser importance could be the subject of requests. The requests contained in the follow-up letters may concern requests for corrective actions or additional information, in the light of the deviations found during the inspections. The actual performance of the actions requested by ASN is followed up in a manner proportional to the issues at stake. Thus the priority action requests undergo exhaustive checks when their deadlines expire. The other requests are monitored by sampling, using appropriate methods (documentary check, follow-up inspection, etc.). Any non-compliance found during the inspection can lead to administrative or criminal penalties (see point 6). Some inspections are carried out with the support of one or more IRSN representatives specialised in the facility checked or the technical topic of the inspection. ASN inspectors ASN has inspectors designated and accredited by its Chairman, pursuant to Article L. 596-2 of the Environment Code for nuclear safety inspectors and Article L. 1333-29 of the Public Health Code for radiation protection inspectors, subject to their having acquired the requisite legal and technical skills through professional experience, mentoring or training courses. The inspectors take an oath and are bound by professional secrecy. They exercise their inspection activity under the authority of the ASN Director General and benefit from regularly updated practical tools (inspection guides, decision aids) to assist them in their inspections. As part of its continuous improvement policy, ASN encourages the exchange and integration of best practices used by other inspection organisations: ∙ by organising international exchanges of inspectors between Safety Authorities, either for the duration of one inspection or for longer periods that could extend to a secondment of up to several years. Thus, after having observed its advantages, ASN has adopted the concept of in-depth inspections described earlier. However, it did not opt for the system involving a resident inspector on a nuclear site, as ASN considers that its inspectors must work within a structure large enough to allow experience to be shared and that they must take part in inspections of different licensees and facilities in order to acquire a broader view of this field of activity. This choice also allows greater clarity in the exercise of the respective responsibilities of the licensee and the inspector; TABLE Breakdown of inspectors per inspection field as at 31 December 2022 INSPECTOR CATEGORIES DEPARTMENTS DIVISIONS TOTAL Nuclear Safety Inspectors 135 123 258 including nuclear safety inspectors for transport 13 47 60 Radiation protection inspectors 39 108 147 Labour inspectors 2 18 20 Inspectors for all fields 157 172 329 3 ASN Report on the state of nuclear safety and radiation protection in France in 2022 151 • 03 • Regulation of nuclear activities and exposure to ionising radiation 01 03 07 08 13 AP 04 10 06 12 14 09 05 11 02