list the documents that must be enclosed with the application. All the other documents listed in the appendix to ASN resolution 2010-DC-0192 of 22 July 2010 must be held by the applicant and kept at the disposal of the inspectors in the event of inspection. On completion of the examination, and provided that the measures described by the applicant are satisfactory, a limitedterm (usually 5 years) license is issued for the exercise of the nuclear activity. To further the implementation of a graded approach in the oversight of the nuclear activities coming under the Public Health Code, ASN started revising the above-mentioned resolution in 2022 in order to adapt and simplify the content of applications. This will complete the work started in 2018 which has already led to revising of the notification system and creation of the registration system (see below). The notification system As part of the overhaul of the classification of nuclear activities into the three administrative systems introduced by the above-mentioned Decree of 4 June 2018, ASN decided to implement a more graded approach, proportionate to the risks. Its initial work focused on the notification system. Notification is a simple procedure which does not require the submission of any supporting documents. It is particularly suited to the nuclear activities that present the lowest risks for people and the environment. Since April 2018, those responsible for a nuclear activity in the industrial, research or veterinary sectors, that comes under the notification system, can carry out the notification procedure via the ASN “on-line services” portal. Through ASN resolution 2018-DC-0649 of 18 October 2018 approved on 21 November 2018, ASN has extended the list of activities subject to notification. The notification system extension should concern about 6,000 companies or individuals which were previously subject to the licensing system. However, the exact number of cases will not be quantifiable until after five years (31 December 2023). This is because, in accordance with the principle of grandfathering, the licenses issued before 1 January 2019 act as notification acknowledgements until the license reaches term, on condition that in the interim there is no change in the nuclear activity. This means that a number of nuclear activities, though now subject to notification, are still regulated by a license. 2.4.3 The new registration system (simplified authorisation) The new registration system came into effect on 1 July 2021, after approval on 4 March 2021 of ASN resolution 2021-DC-0703 of 4 February 2021. This resolution governs nuclear activities in industry, research and veterinary applications, as nuclear activities for medical purposes that come under this system are governed by another resolution (see chapter 7). This system applies to certain sources of ionising radiation, whether in the form of sealed or unsealed radioactive sources, and X‑ray generators, where the risks and drawbacks of possessing or using them can be prevented by complying with the specific general requirements set by the resolution. The resolution therefore defines, apart from the nuclear activities concerned, the content of the simplified authorisation application and the conditions for exercising (specific general requirements) the nuclear activity with which the licensees must comply. Its entry into effect marks the second stage – following that of extension of the notification system – of effective implementation of the reform of small-scale nuclear activity regulation, aiming to better materialise a graded approach to the risks. The resolution effectively implies significant alleviations in the administrative procedures compared with those for nuclear activities subject to licensing, such as: a simplified application (both in the information and the substantiation documents to provide), PRACTICAL ILLUSTRATION OF THE ENTRY INTO EFFECT OF PROVISIONS CONCERNING THE PHYSICAL PROTECTION OF RADIOACTIVE SOURCES: “OPENABLE ELEMENTS” GUIDE With the entry into effect, on 1 July 2022, of the appendices of the Order of 29 November 2019 amended, in addition to the implementation of a few organisational measures complementary to those already in effect, the installation of physical systems contributing to protection of the site is required: ■ the resistance of walls and openable elements (door or window leaves, locks, hinges); ■ access control (identification and authentication) by badge with or without contact or by biometric recognition; ■ detection (peripheral and perimetric) which can use various technologies (opening detectors, impact or seismic detectors, movement detectors using infrared, microwave or ultrasound waves); ■ surveillance by fixed or mobile cameras; ■ alarms (luminous and audio); ■ transmission and processing of information to lift any uncertainty. As far as the resistance of wall and openable elements is concerned, the Order appendices could not stipulate extremely precise requirements as the facilities were built at a time when the protection of sources against malicious acts was not a major concern. Furthermore, the Order sets objectives rather than imposing means. The practical application of the requirements by persons/entities responsible for nuclear activities should therefore be acceptable to the inspector (ASN or MTE‑SHFDS). Moreover, the chosen criteria had to have the same level of stringency in all the facilities. IRSN, which has an office specialised in physical protection, was mandated by ASN in late 2021 and early 2022 to visit some facilities and establish a field report on the provisions already in place and what could be required, in practical terms for the openable elements (essentially doors and windows). This procedure was undertaken before the Order appendices came into effect. Interviews with professionals, law enforcement authorities and the National Centre for Prevention and Protection (CNPP) allowed a better assessment of the minimum level of requirements that could be adopted. Following this field report a guide was drafted. It attributes points according to the various elements characterising the openable element (leaf, hinge, lock), enabling the element to be assigned a score. This score determines whether the openable element can be deemed to meet the essential requirements of the appendices or not. A draft was tested during ASN inspections in spring before its final validation, jointly with the MTE‑SHFDS and IRSN. ASN has issued this guide to persons/entities responsible for nuclear activities in a controlled manner as it contains sensitive information, asking them to undertake a self-assessment which can be subsequently examined during an inspection. ASN Report on the state of nuclear safety and radiation protection in France in 2022 249 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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