ADMINISTRATIVE TRACKING OF RADIOACTIVE SOURCES Articles R. 1333‑154, 156 and 157 of the Public Health Code provide for the prior registration by IRSN of transfers of radioactive sources and Article R. 1333‑158 for administrative tracking of these sources. ASN resolution 2015-DC-0521 of 8 September 2015 relative to the tracking and methods of registering radionuclides in the form of radioactive sources and products or devices containing them details the methods of registering transfers and the rules for tracking radionuclides in the form of radioactive sources. This resolution, applicable as of 1 January 2016, takes into account the existing mode of functioning and supplements it as follows by: ■ grading source administrative tracking according to how dangerous the sources are; ■ confirming the non-registration of sources whose activity is below the exemption thresholds; ■ imposing deadlines between the registering of source transfer and the actual transfer; ■ making it an obligation for each source to be accompanied by a “source certificate” indicating all its characteristics and which must be transmitted to IRSN within two months after receiving the source. ten year registration validity by default (and even unlimited validity by default for certain nuclear activities), the possibility of applying for registration via the on-line registration service which is available on asn.fr, review and assessment by ASN within six months, with silence after six months being considered as acceptance of registration of the applicant nuclear activity. Entry into effect of the registration system should ultimately concern between 1,200 and 2,000 licensees in industry, research and veterinary applications, hitherto subject to the licensing system. However, as is the case with the notification system, the number will not be able to be accurately quantified until a 5-year period has expired (1 July 2026). This is because, in accordance with the principle of grandfathering, the licenses issued before 1 January 2021 will act as registration until the license reaches term, on condition that in the interim there is no change in the nuclear activity. 2.4.4 Statistics for the year 2022 Suppliers In view of the fundamental role played by the suppliers of radioactive sources or devices containing them in the radiation protection of future users (see point 2.4.1), ASN exercises tightened oversight in this field. During 2022, 98 radioactive source supply license applications or license renewal applications were reviewed by ASN, and 37 inspections were carried out (all ionising radiation sources combined). Users The case of radioactive sources In 2022, ASN examined and issued 9 new licences, 206 license renewals or updates, 60 license cancellations, and 133 registration decisions. ASN also issued 661 notification acknowledgements for sealed radioactive sources in 2022. Graph 6 shows the regulatory acts issued by ASN for radioactive sources in 2022 and, where applicable, their development over the last five years. The entry into effect of ASN resolution 2018-DC-0649 of 18 October 2018 (see point 2.4.2) is the main reason for the very large drop in the number of licenses issued in favour of the issuance of notification acknowledgements, and illustrates the concrete application of the graded approach to risk control. This drop will become greater in the coming years as the new registration system (see point 2.4.3) applicable since 1 July 2021 gradually increases in scale. Once the license, registration or notification acknowledgement is obtained, the holder can procure sources. To do this, it receives supply request forms from IRSN, enabling IRSN to verify – as part of its duty to keep the national inventory of ionising radiation sources up to date – that the orders are in conformity with the license, registration or notification acknowledgement issued to the user and the license of its supplier. If the order is correct, the transfer is then recorded by IRSN, which notifies the interested parties that delivery can take place. In the event of difficulty, the transfer is not validated and IRSN refers the case to ASN (see box above). The case of electrical generators of ionising radiation ASN has been responsible for the oversight of these devices since 2002, devices for which numerous administrative compliance actions are still required. In 2022 it granted 22 new licenses, 130 license renewals or updates and issued 141 registration decisions for the use of electrical devices emitting X-rays. ASN also delivered 722 notification acknowledgements for electrical generators of ionising radiation. As with radioactive sources, the large reduction in the number of licenses issued and, conversely, the significant increase in notification acknowledgements and issuing of the first registration decisions, are the direct consequence of the entry into effect of the above-mentioned ASN resolutions 2018-DC-0649 of 18 October 2018 and 2021DC-0703 of 4 February 2021. Altogether, 1,673 licences, 178 registrations and 8,420 notification acknowledgements have been issued for electrical devices emitting ionising radiation since 2002. Graph 7 illustrates the development over the last few years. 250 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
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