ASN may also inspect the manufacture of the specimens used for the drop tests and fire tests required by the regulations. The objectives are the same as for the series production model because the specimens must be representative and comply with the maximum requirements indicated in the mock-up manufacturing file, which will determine the minimum characteristics of the actual packaging to be manufactured. In 2023, ASN intends to continue spot-check inspections of transport packaging manufacturing. This is because the irregularities detected in 2016 at the Framatome Le Creusot plant, which notably affected certain transport packagings, as well as the discovery in 2022 of falsifications concerning conventional products at the manufacturer of steel castings and forgings, Japan Steel Works Ltd. (JSW) – which also produces parts for transport packagings – confirmed the importance of inspecting the packaging manufacturing and maintenance operations. 4.2.2 Packaging maintenance inspections The consignor or user of a packaging loaded with radioactive substances must be able to prove to ASN that this packaging is periodically inspected and, if necessary, repaired and maintained in good condition such that it continues to satisfy all the relevant requirements and specifications of its safety case and its approval certificate, even after repeated use. For approved packagings, the inspections carried out by ASN for example concern the following maintenance activities: ∙ the periodic inspections of the components of the containment system (screws, welds, seals, etc.); ∙ the periodic inspections of the securing and handling components; ∙ the definition of the frequency of replacement of the packaging components which must take account of any reduction in performance due to wear, corrosion, ageing, etc. 4.2.3 Inspections of packages not requiring approval For the packages that do not require ASN approval, the consignor must, at the request of ASN, be able to provide the documents proving that the package model complies with the applicable regulations. More specifically, for each package, a file demonstrating that the model meets the regulation requirements and that it can in particular withstand the specified tests, along with a certification delivered by the manufacturer attesting full compliance with the model specifications, must be kept at the disposal of ASN. The various inspections carried out in recent years confirm progress in compliance with this requirement and in implementation of the ASN recommendations detailed in its guide concerning packages which are not subject to approval (Guide No. 7, volume 3). This Guide proposes a structure and a minimum content for the safety cases demonstrating that packages which are not subject to approval do comply with all the applicable requirements, along with the minimum content of a declaration of conformity of a package design with the regulations. ASN thus noted improvements in the content of the certificate of conformity and the safety case drawn up by the relevant players, more specifically for the industrial package models. The representativeness of the tests performed and the associated safety case remain the focal points during the ASN inspections, in particular for type A packages. Furthermore, ASN still finds shortcomings in the demonstration by some of the players (designers, manufacturers, distributors, owners, consignors, companies performing the regulatory drop tests, package maintenance, etc.) of package conformity with the regulations. The areas for improvement concern the following points in particular: ∙ the description of the authorised contents per type of packaging; ∙ the demonstration that there is no loss or dispersion of the radioactive content under normal conditions of transport; ∙ compliance with the regulatory requirements regarding radiation protection, more specifically the demonstration, as of the design stage, that it would be impossible to exceed the dose rate limits with the maximum authorised content. 4.2.4 Monitoring the shipment and transportation of packages The scope of ASN inspections includes all regulatory requirements binding on each of the transport players, that is compliance with the requirements of the approval certificate or declaration of conformity, training of the personnel involved, implementation REFUSAL TO VALIDATE A GERMAN CERTIFICATE Pursuant to Article R. 595-1 of the Environment Code, Framatome Advanced Nuclear Fuels (ANF) GmbH submitted an application to ASN for French validation of approval D/430/IF-96 (revision 11) issued by the German competent authority for the ANF-10 package model loaded with fresh fuel assemblies, on the basis of a Safety Options Dossier. This validation request concerns two contents consisting of fresh fuel assemblies based on uranium oxide, intended for Boiling Water Reactors (BWRs), and one content consisting of two tubes transporting non-irradiated fuel rods in unspecified quantities, for BWRs or Pressurised Water Reactors (PWRs). The purpose of this application is to be able to resume transport operations by road, rail or sea on French territory with the ANF‑10 package, as an IP-2 type industrial package for fissile materials. This package is used more specifically for transport operations between the Framatome Lingen plant in Germany and the Cofrentes NPP in Spain. The transport of ANF-10 packages on French territory was authorised for the last time in France in 2005, under a special arrangement shipment approval, which expired on 31 July 2005. This authorisation had been delivered subject to the implementation of compensatory measures for the transport of the ANF-10 package. This special arrangement had been issued because, for ASN, this package model already at the time failed to meet all the requirements of the previous international transport regulations. In particular, the regulation package drop test had not been performed in the most penalising conditions; in addition the demonstrations that the package safety functions were guaranteed at -40°C and that safetycriticality was controlled were also insufficient under standardised transport accident conditions. The new review showed that the safety case for the package model was still not satisfactory with regard to maintaining sub-criticality. ASN therefore refused to validate the German certificate for the third consecutive time. 278 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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