2.4 Licensing, registration and notification of ionising radiation sources used for industrial, research or veterinary purposes 2.4.1 Integration of the principles of radiation protection in the regulation of non-medical activities With regard to radiation protection, ASN verifies application of the three major principles governing radiation protection which are written into the Public Health Code (Article L. 1333‑2), namely: justification, optimisation of exposure and dose limitation. Assessment of the expected benefit of a nuclear activity and the corresponding health drawbacks may lead to prohibition of an activity for which the benefit does not seem to outweigh the risk. Either generic prohibition is declared, or the license required for radiation protection purposes is not issued or is not extended. For the existing activities, the elements supporting implementation of the justification principle are recorded in writing by the person responsible for the nuclear activity, and are updated every five years and whenever there is a significant change in available knowledge or techniques. Optimisation is a notion that must be considered in the technical and economic context, and it requires a high level of involvement of the professionals. ASN considers in particular that the suppliers of devices are at the core of the optimisation approach (see point 4). They are effectively responsible for putting the devices on the market and must therefore design them such that the exposure of the future users is minimised. ASN also checks application of the principle of optimisation when examining the license applications, when conducting its inspections, and when analysing reported significant events. 2.4.2 The licensing and notification systems Applications relating to the possession and utilisation of ionising radiation are examined by the ASN regional divisions, while those concerning the manufacture and supply of sources or devices containing sources are examined at the ASN head office by the Department of Transport and Sources (DTS). The entry into effect on 1 July 2018 of Decree 2018-434 of 4 June 2018, introducing various provisions in the nuclear field, has introduced a third administrative system lying between the notification system and the licensing system: this is a simplified authorisation system called the “registration system”. ASN has prepared a classification system to allocate the various categories of nuclear activities to one of these three systems, whose implementation began on 1 January 2019 with the entry into effect of the ASN resolution extending the notification system to additional nuclear activities which until then were subject to licensing, and continued on 1 July 2021 with the entry into effect of the resolution concerning the registration system. The licensing system Small-scale nuclear activities stand out by their considerable diversity and the large number of licensees involved. The licensing system is designed to regulate the nuclear activities involving the greatest radiation protection implications, for which ASN checks, when examining the license application, that the applicant has identified the risks and that the measures intended to limit their effects have been studied and planned for. To support this process, licensing application forms adapted to each activity are available on asn.fr. These forms are designed for the licensing applications to be formulated by the representative of a legal person, although it is possible for a physical person to apply for a license. These forms INTERNATIONAL WORKING GROUP ON ALTERNATIVE TECHNOLOGIES Radioactive sources present radiation exposure and safety risks for their users, the general public and the environment, which must be taken into consideration in the reflection phase preceding the deployment of a nuclear activity. Consequently, in France, when technologies presenting lower risks than a nuclear activity are available under technically and economically acceptable conditions, they must be implemented instead of the nuclear activity initially envisaged: this is the principle of justification. On this basis, as of 2014 and subsequently at the Nuclear Security Summit in Washington in April 2016, France was the initiator of an international initiative now supported by 31 countries and by Interpol. The aim is to support research into and the development of technologies that do not use high-activity sealed radioactive sources and to promote the use of these technologies. In this context, since April 2015 ASN has, along with the National Nuclear Security Administration (United States), initiated an informal think tank involving several countries working on the subject of replacing high-activity radioactive sources by alternative technologies. The aim of this group, which meets once a year, is to foster greater awareness of the benefits of such alternatives and to share experience feedback from each country in this respect. At the group meetings ASN has presented, for example, the operations conducted by the French blood transfusion agency to replace – in application of the principle of justification – its irradiators that use radioactive sources by electric irradiators emitting X-rays. ASN has also enabled the French Confederation for Non-Destructive Testing to present the progress of its work to replace gamma radiography by other non-destructive testing technologies. In December 2018, during the International Conference on Nuclear Security organised by the IAEA, the subject of alternative technologies was addressed by several presentations and two panel sessions, and the relevance of this think tank was underlined. After a break in 2020 due to the Covid-19 pandemic, the annual meetings of the working group resumed in 2012 and 2022. The 2022 meeting organised as an on-line event brought together more than 200 participants. This meeting provided the opportunity to review the prospects of bypassing the use of radioactive sources in diagraphy (well logging) and to discuss applications (medical, industrial and research alike) for which the particle accelerators can be used effectively. These regular meetings provide the opportunity to highlight both successful initiatives in the implementation of alternative technologies and difficulties in the development or implementation of these technologies which must be the subject of complementary work. 248 ASN Report on the state of nuclear safety and radiation protection in France in 2022 • 08 • Sources of ionising radiation and their industrial, veterinary and research applications 08
RkJQdWJsaXNoZXIy NjQ0NzU=