of a radiological protection programme, satisfactory stowage of packages, dose rate and contamination measurements, documentary conformity, implementation of a quality assurance programme, etc. More particularly with respect to transports concerning smallscale nuclear activities, the ASN inspections confirm significant disparities from one carrier to another. The differences most frequently identified concern the quality assurance programme, actual compliance with the procedures put into place and radiation protection of the workers. Knowledge of the regulations applicable to the transport of radioactive substances seems to be sub-standard in the medical sector in particular, where the procedures adopted by some hospitals or nuclear medicine units for package shipment and reception need to be tightened. Their quality management system has not yet been formally set out and deployed, more specifically with regard to the responsibilities of each member of staff involved in receiving and dispatching packages. More generally, in transport operations for small-scale nuclear activities, the radiological protection programmes and the safety protocols have not yet been systematically defined. ASN also found that checks on vehicles and packages prior to shipment need to be improved. The inspections concerning the transport of gamma ray projectors regularly reveal inappropriate stowage or tie-down. In the BNI sector, ASN considers that the consignors must improve how they demonstrate that the content actually loaded into the packaging complies with the specifications of the approval certificates and the corresponding safety cases, including if this demonstration is provided by a third-party. In this latter case, the consignor’s responsibilities then require that it verify that this demonstration is appropriate, and that it monitor the third-party company in accordance with the usual methods of a quality assurance system. As BNI licensees are increasingly using contractors to prepare and ship packages of radioactive substances, ASN is paying particularly close attention to the organisation put into place to monitor these contractors. Finally, with regard to on-site transports within NPPs, ASN considers that the licensees must remain vigilant to the application of package stowage rules. 4.2.5 Analysis of transport events The safety of the transport of radioactive substances relies in particular on the existence of a reliable system for detecting and processing anomalies, deviations or, more generally, any abnormal events that could occur. Therefore, once detected, these events must be analysed in order to: ∙ prevent identical or similar events from happening again, by taking appropriate corrective and preventive measures; ∙ prevent a more serious situation from developing by analysing the potential consequences of events which could be precursors of more serious events; ∙ identify the best practices to be promoted in order to improve transport safety. The regulations also requires on-line notification to ASN of the most significant events so that they can ensure that the detection system, the analysis approach and the integration of Operating Experience Feedback (OEF) are effective. This also provides ASN with an overview of events so that the sharing of OEF can be encouraged between the various stakeholders – including internationally – and so that ASN can consider potential changes to the provisions governing the transport of radioactive substances. As requested in Article 7 of the Order of 29 May 2009, amended, concerning the transport of dangerous goods by land, any significant event concerning the transport of radioactive substances, whether the consequences are actual or potential, must be notified to ASN within four working days, as stipulated in its Guide No. 31 on the notification of events. This Guide can be consulted on asn.fr. After notification, a detailed report of the event must be sent to ASN within two months. Events notified in 2022 In 2022, in the field of radioactive substances transport, ASN was notified of 76 events rated level 0 on the International Nuclear and Radiological Event Scale (INES) and 12 events rated level 1. A slight drop in the number of level 0 events is observed by comparison with 2021, whereas the number of level 1 events tripled. Graph 4 shows the variations in the number of significant events notified since 2005. ASN was also notified of 52 Events of Interest for the safety of Transports (EIT), a figure which is identical to 2021. Because they have no actual or potential consequences, these events are not rated on the INES scale. There is thus no obligation to notify ASN, but the latter does encourage periodic information so that it has an overview of the EIT and can detect any recurrence or trends which could be indicative of a problem. Finally, five transport events, occurring within nuclear installations, rated level 0 on the INES scale were notified in 2022. This figure, which has almost doubled in one year, indicates an improvement in the safety culture and the notification of transport events to ASN. Sectors concerned by these events As was the case last year, most of the significant events notified concern the nuclear industry. Only 15% relate to transports for the non-nuclear industry. However, by comparison with 2021, the number of transport events involving pharmaceutical products increased quite significantly: they account for 38% of significant events (as opposed to 11% in 2021). As for the events rated level 1 on the INES scale: ∙ five of them concern regulatory nonconformities observed during road and air transport of industrial gamma ray projectors (transport of a gamma ray projector from Chad without its transport case and without the appropriate regulation labelling/ marking, transport of a gamma ray projector from Tunisia without its appropriate transport case and stowing, rupture of a plug detected during a transport operation in France, absence of labelling and maintenance carried out more than one year previously, problem with closure of a package from Algeria and absence of seal). The foreign competent authorities concerned INSPECTIONS OF ON-SITE TRANSPORTS AT EDF NUCLEAR POWER PLANTS The last 2022 inspections on on-site transports in the Saint-Laurent-des-Eaux and Flamanville NPPs show that EDF needs to update the list of authorised packages and the corresponding safety requirements. These inspections also revealed insufficient compliance with the EDF internal requirements for on-site transports. Finally, the lack of any designated staff for the safety of on-site transports for periods of several months was observed. In 2023, ASN will continue its inspections of EDF’s on-site transports. ASN Report on the state of nuclear safety and radiation protection in France in 2022 279 • 09 • Transport of radioactive substances 09 01 07 08 13 AP 04 10 06 12 14 03 05 11 02
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