RETROSPECTIVE ON THE INSPECTIONS RELATING TO THE PROTECTION OF IONISING RADIATION SOURCES AGAINST MALICIOUS ACTS Since 2019, when ASN inspects facilities where sealed radioactive sources of category A, B or C are present, whether individually or in batches, it checks compliance with the regulations relative to the protection of sources against malicious acts and the implementation of national monitoring indicators. With gradual entry into effect of the requirements of the Order of 29 November 2019 amended, the monitoring was adjusted accordingly on 1 January 2021 (organisational provisions) and 1 January 2022 (technical systems). The number of inspection items that are verified systematically and consistently during the inspections as a whole therefore gradually increased from 4 to 6, then to above 10 on 1 January 2022 (the technical systems are more numerous for the sources or batches in category A or B than in category C; moreover, certain inspection items address transport vehicles which the majority of persons/entities responsible for nuclear activities do not possess, as they prefer to subcontract transport operations). Notes: 1° Out of all the inspection points, four concern questionnaires stemming from obligations figuring in the non-published appendices of the Order of 29 November 2019 amended. Consequently, they cannot be addressed in a publication. 2° The changes indicated in the medical sector must be taken with caution as the number of inspections dedicated to malicious acts is relatively small. 3° The aggregate of the responses since 2019 gives some hindsight, but this only concerns the first two indicators as the others were put in place later. Classification of radioactive sources or batches of sources This criterion and the one following it have been monitored since 2019. The findings of 2022 can therefore be compared with the aggregated result for the years 2019‑2021. In 2022, 80% of the inspections performed in industrial facilities raised no comment on this point. This good result for 2022 is an improvement of about 30% on the findings made over the 2019‑2021 period. Out of the remaining facilities, about 10% have taken no action. Likewise, 90% of the medical centres inspected have classified their sources. The increase in compliant situations in 2022 compared with the previous three years is more than 30%. The situation of the sites which have not yet carried out this classification obligatorily leads to nonconformities, since this evaluation is the basis for determining the technical provisions of the protection plan against malicious acts which is applicable since 1 July 2022. Nominative authorisations These are delivered by the nuclear activity licensee to allow access to the sources, their carriage, or access to the information relating to the means or measures that protect them. In the industrial facilities inspected in 2022, more than 60% duly issued the necessary authorisations. This represents an increase of 60% on the findings for 2019-2021. The percentage of situations without any authorisation is now marginal (less than 5%). The situation can nevertheless be further improved in nearly 25% of the cases for 2022. The situation in the medical sector is similar (even if the indicator is less representative given that fewer inspections are carried out here than in the industrial sector) with 50% of findings compliant. This nevertheless represents just under a two-fold increase in compliant situations compared with the aggregate for 2019‑2021. Policy of protection against malicious acts This indicator (and the following one) was not put in place until 2021 since a general statement of management’s commitment regarding protection against malicious acts and its distribution was not required by the regulations until 1 January 2021. This provision contributes to establishing a corporate security culture, including in terms of cyber security, which is a long process by nature. It is not sufficient, but is should provide some impetus for the organisation to address the question of malicious acts. In the industrial sector, although such a policy exists in 70% of the licensees inspected in 2022, 15% need more appropriate dissemination. The number of cases that raised no comments during inspection has increased by 30% compared with last year. In the medical sector, the proportion of inspected facilities that have a management commitment statement has increased with respect to last years. However, the proportion of situations where the inspection found communication to be inadequate increased to 50% in 2022, a significant increase on the previous year. Identification and control of sensitive information In 2022, nearly 60% of the industrial facilities inspected had a duly applied procedure on this matter, which is an improvement on last year. In slightly less than 20% of the situations, there was no document. In the medical sector, 50% of the facilities had no document addressing this question, the same figure as in 2021. Principle of barriers This inspection item concerns the basic provisions with regard to resistance to forced entry, based on criteria which are now more precise and therefore more stringent than before. This indicator, and the subsequent ones, were put in place to track the requirements that came into effect in 2022, therefore they cannot be compared with the previous years. Slightly less than 40% of the industrial sites inspected are considered to have “barriers” that are clearly identified and suitably resistant. In the medical sector, this figure increases to above 50%, but one centre has still not taken this aspect of the order into consideration. There is therefore still room for improvement. Maintenance of technical protection systems The systems adopted to protect against malicious acts necessitate the installation of detectors forming part of a chain of components allowing surveillance of the site. This equipment requires maintenance to prevent failures. It is therefore vital to have a verifications programme. Such a programme exists in the industrial sector but is only implemented by 30% of the companies inspected in 2022. In the same percentage of situations the subject is not addressed at all. The remaining cases correspond to situations where a programme exists but is poorly applied or is inappropriate. In the medical sector the number of inspected sites with a maintenance plan is slightly lower, standing at 25%, but in nearly 60% of the cases the issue has not been addressed. The remaining 15% of inspected facilities have a plan that is inappropriate or poorly applied. 256 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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