4. ASN action in the transport of radioactive substances 4.1 Issuance of approval certificates and shipment approvals The type B and C packages, as well as the packages containing fissile materials and those containing more than 0.1 kilograms of UF6 must be covered by an ASN approval certificate in order to be transported. The designers of the package models who request approval from ASN must support their application with a safety case demonstrating the compliance of their package with all the regulatory requirements. Before deciding whether or not to issue an approval certificate, ASN reviews these safety cases, drawing on the expertise of IRSN, in order to ensure that the safety cases are pertinent and conclusive. If necessary, the approval certificate is issued with requests in order to improve the safety case. In some cases the IRSN expert assessment is supplemented by a meeting of the ASN GPT. The opinions of the Advisory Committees are always published on asn.fr. The approval certificate specifies the conditions for the manufacture, utilisation and maintenance of the transport package. It is issued for a package model, independently of the actual shipment itself, for which no prior ASN opinion is generally required. This shipment may however be subject to safety checks (physical protection of the materials against malicious acts under the supervision of the HFDS of the Ministry for the Environment). These approval certificates are usually issued for a period of five years. If a package is unable to meet all the regulatory requirements, the regulations nonetheless allow for its transport by means of a shipment under special arrangement. The consignor must then define compensatory measures to ensure a level of safety equivalent to that which would have been obtained had the regulatory requirements been met. For example, if it cannot be completely demonstrated that a package is able to withstand the 9m drop, a compensatory measure may be to reduce the speed of the vehicle, have it escorted and choose a route avoiding such a drop height. The probability of a serious accident, and thus of a violent shock on the package, is thus considerably reduced. A shipment under special arrangement is only possible with the approval of the competent authority, which then issues approval for shipment under special arrangement, stipulating the compensatory measures to be applied. In the case of certificates issued abroad, the international regulations provide for their recognition by ASN. In certain cases, this recognition is automatic and the foreign certificate is directly valid in France. In other cases, the foreign certificate is only valid if endorsed by ASN, which then issues a new certificate. In 2022, 30 approval applications were submitted to ASN by the designers or operators. ASN issued 37 approval or shipment authorisation certificates, for which the breakdown according to type is presented in Graph 2. The nature of the transports and packages concerned by these certificates is presented in Graph 3. 4.2 Monitoring all the stages in the life of a package ASN performs inspections at all the stages in the life of a package: from manufacture and maintenance of a packaging, to package preparation, shipment and reception. In 2022, ASN carried out 108 inspections in the field of radioactive substances transport (all sectors considered). The follow-up letters to these inspections are available on asn.fr. 4.2.1 Regulation of package manufacturing The manufacture of transport packaging is subject to the regulations applicable to the transport of radioactive substances. The manufacturer is responsible for producing packagings in accordance with the specifications of the safety case, demonstrating regulatory compliance of the corresponding package model. To do this, it must implement a quality management system covering all the operations from procurement of parts and raw materials up to final inspections. Furthermore, the manufacturer must be able to prove to ASN that it complies with the regulatory provisions and, in particular, that the as-built packagings are compliant with the specifications of the safety case. The inspections carried out by ASN in this field aim to ensure that the manufacturer satisfactorily fulfils its responsibilities. In 2022, ASN carried out four inspections on the manufacturing of various packagings for which ASN had issued an approval certificate, at various steps in the manufacturing process: welding, final assembly, manufacturing completion checks, assembly of internals (to immobilise the contents), etc. During these inspections, ASN reviews the quality management procedures implemented for the manufacture of a packaging on the basis of the design data and verifies their effective implementation. ASN ensures that the inspections performed and any manufacturing deviations are traceable. It also visits the manufacturing shops to check the package components storage conditions, the calibration of the inspection instruments and compliance with the technical procedures at the various manufacturing steps (welding, assembly, etc.). ASN checks the monitoring of package manufacturing by the lead contractor and may intervene directly on the sites of any subcontractors, who may sometimes be located abroad. EXTENSION OF THE MX6 PACKAGE APPROVAL TO TRANSPORT MOX As part of its multi-year energy programme, EDF intends to use “MOX” fuel for some of its 1,300 Megawatts electric (MWe) reactors. As the characteristics of the MOX assemblies intended for the 1,300 MWe reactors are different from those of the MOX assemblies currently in use in the 900 MWe reactors, their transportation is not covered by any approval currently in force in France. Orano NPS therefore submitted an application to ASN to extend the approval of the MX6 package model, so that these new MOX assemblies could be transported to the 1,300 MWe reactors. Following the review of the application, especially the review of the safety case for this package model with this new content, ASN issued the B(U) approval certificate for this MX6 package model on 23 September 2022. Issue of this approval however in no way prejudges the other authorisations needed to use MOX fuel in EDF’s 1,300 MWe reactors. 276 ASN Report on the state of nuclear safety and radiation protection in France in 2022 • 09 • Transport of radioactive substances 09
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