The other files submitted by BNI licensees A large number of files concerns specific topics such as fire protection, fuel management in PWRs, relations with the outside contractors, etc. The licensee therefore also periodically provides activity reports as well as summaries of water intake, liquid and gaseous discharges and waste produced. 3.2.2 Review of the applications required by the Public Health Code ASN is responsible for reviewing applications to possess and use ionising radiation sources in the medical and industrial sectors. ASN also deals with the specified procedures for the acquisition, distribution, import, export, transfer, recovery and disposal of radioactive sources. It in particular relies on the inspection reports from the approved organisations and the reports on the steps taken to remedy nonconformities detected during these inspections. In addition to the verifications carried out under the responsibility of the facilities and the periodic checks required by the regulations, ASN carries out its own checks when examining the applications. 3.3 Lessons learned from significant events 3.3.1 Anomaly detection and analysis approach Background The international Conventions ratified by France (section VI of Article 19 of the Convention on Nuclear Safety of 20 September 1994; section V of Article 9 of the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management of 5 September 1997) require that BNI licensees implement a reliable system for early detection and notification of any anomalies that may occur, such as equipment failures or errors in the application of operating rules. Ten years previously, the “Quality Order” of 10 August 1984 already required such a system in France. ASN thus drafted three guides defining the principles and reiterating the obligations binding on the licensees with regard to notification of incidents and accidents: ∙ The Guide of 21 October 2005 contains the provisions applicable to BNI licensees. It concerns significant events relating to nuclear safety, radiation protection and environmental protection, applicable to BNIs. ∙ Guide No. 11 of 7 October 2009, updated in July 2015, contains provisions applicable to those in charge of nuclear activities as defined in Article L. 1333-1 of the Public Health Code and to the heads of the facilities in which ionising radiation is used (medical, industrial and research activities using ionising radiation). ∙ Guide No. 31 describes the procedures for notification of TSR events (see chapter 9). This Guide has been applicable since 1 July 2017. These Guides can be consulted on asn.fr. What is a significant event? Detection of events (deviations, anomalies, incidents, etc.) by those in charge of the activities using ionising radiation, and implementation of corrective measures decided on after analysis, play a fundamental role in accident prevention. For example, the nuclear licensees detect and analyse several hundred anomalies every year, for each EDF reactor. Prioritising the anomalies should enable the most important ones to be addressed first. The regulations have defined a category of anomalies called “significant events”. These are events which are sufficiently important in terms of safety, the environment or radiation protection to justify that ASN be rapidly informed of their occurrence and subsequently receive a fuller analysis. Significant events must be reported to it, as specified in the Order of 7 February 2012 (Article 2.6.4), the Public Health Code (Articles L. 1333-13, R. 1333-21 and R. 1333-22), the Labour Code (Article R. 4451-74) and the regulatory texts applicable to the TSR (for instance, the European Agreement on the Carriage of Dangerous goods by Road). The criteria for notifying the public authorities of events considered to be “significant” take account of the following: ∙ the actual or potential consequences for the workers, the general public, patients or the environment, of events which could involve safety or radiation protection; ∙ the main technical, human or organisational causes that led to the occurrence of such an event. This notification process is part of an approach to continuously improve safety and radiation protection. It requires the active participation of all players (users of ionising radiation, carriers, etc.) in the detection and analysis of deviations. It enables the authorities: ∙ to ensure that the licensee has suitably analysed the event and taken appropriate measures to remedy the situation and prevent it from happening again; ∙ to ensure that other parties responsible for similar activities benefit from experience feedback about the event. The purpose of this system is not to identify or penalise any individual person or party. Moreover, the number and rating on the International Nuclear and Radiological Event scale (INES) of the significant events which have occurred in a nuclear facility are not on their own indicators of the facility’s level of safety. On the one hand, a given rating level is an over-simplification and is unable to reflect the complexity of an event and, on the other, the number of events listed depends on the level of notification compliance. The trend in the number of events does not therefore reflect any real trend in safety levels. 3.3.2 Implementation of the approach Event notification The licensee of a BNI or the person responsible for the TSR is obliged to notify ASN and, as applicable, the administrative authority, without delay, of any accidents or incidents that occur on account of the operation of that installation or the transport activity and which could significantly prejudice the interests mentioned in Article L. 593-1 of the Environment Code. Similarly, the party responsible for a nuclear activity must report any event which could lead to accidental or unintentional exposure of persons to ionising radiation and liable to significantly prejudice the protected interests. According to the provisions of the Labour Code, employers are obliged to report significant events affecting their workers. When the head of a company carrying out a nuclear activity calls in an external contractor or non-salaried worker, the significant events concerning the workers are reported in accordance with the prevention plans and the agreements concluded pursuant to the provisions of Article R. 4451-35 of the Labour Code. The reporting party assesses the urgency of notification in the light of the confirmed or potential seriousness of the event and the speed of reaction needed to avoid an aggravation of the situation or to mitigate the consequences of the event. The notification time of two working days (four days for significant TSR events), mentioned in the ASN notification guides, does not 154 ASN Report on the state of nuclear safety and radiation protection in France in 2022 • 03 • Regulation of nuclear activities and exposure to ionising radiation 03
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