In order to keep track of the pool of ICSD, the French Institute for Radiation Protection and Nuclear Safety (IRSN) set up in 2105, in collaboration with ASN, a computerised system enabling the professionals working in this sector (maintenance technicians, installers and removal companies) to file annual activity reports on line. The transmitted information is nevertheless not exhaustive enough to allow a conclusive assessment. Although the removal operations have progressed over the last few years, not all the ICSD 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 ICSD 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 ICSD and the radioactive sources they contain. ASN has also continued discussions with other actors concerned by the removal of these devices, notably the Ministry of Energy Transition (MTE), in order to study the various possible regulatory options. These reflections have not resulted in new regulatory provisions, 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 ionic detectors to continue, which remains the desired aim. 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-Rhône-Alpes 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, has also filed an application for a license in order to start a national plan for removal of the surge arresters installed on its network. A national licence regulating these surge arrester removal operations and their interim storage on specified sites was issued to RTE late 2022. As with Orange, RTE is working with Andra to find a disposal route. 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 considers it necessary for 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. The number of lightning conductors installed in France has been estimated at 40,000. Slightly more than 11,000 have already been removed and recovered by Andra. The current rate of removal is about 200 radioactive lightning conductors 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 ASN Report on the state of nuclear safety and radiation protection in France in 2022 245 08 • 08 • Sources of ionising radiation and their industrial, veterinary and research applications 01 07 13 AP 04 10 06 12 14 03 09 05 11 02
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