ASN Report 2022

THE INDUSTRIAL, VETERINARY AND RESEARCH SECTOR The licensees of the industrial, veterinary and research sector are characterised by their diversity: they are numerous and carry out their activities in structures of widely varying size and status; they also use ionising radiation sources for a wide variety of applications. With regard to radiation protection, ASN’s assessment of these licensees is to a large extent comparable to that of previous years. Among the nuclear activities in the industrial sector, industrial radiography and more particularly gamma radiography are priority sectors for ASN oversight owing to their radiation protection implications. ASN observes that the vast majority of companies maintained the necessary degree of rigorousness to meet the regulatory obligations concerning the organisation of radiation protection, training and dosimetric monitoring of the workers, the use of operators holding the required Certificate of proficiency in handling industrial radiology devices (CAMARI) and maintaining gamma radiography devices. Although the risk of incidents and the doses received by the workers are on the whole well managed by the licensees when this activity is performed in a bunker in accordance with the applicable regulations, ASN is still concerned by the observed shortcomings in terms of the signalling of the operations area during site work. More generally, ASN considers that the ordering parties should give priority to industrial radiography services in bunkers and not on the worksite. Furthermore, unlike in recent years, in the few situations in which the radioactive source could not be returned to the safe position in the gamma ray projector, inappropriate actions and handling were undertaken by the operators in the majority of cases, although without generating exposure of the operators or their hands beyond the regulation limits. ASN considers that the reoccurrence of such cases, albeit few in number, is a subject requiring particular attention because inappropriate actions can lead to significant over-exposure, as is shown by international operating experience feedback every year. In the other priority sectors for ASN oversight in the industrial sector (industrial irradiators, particle accelerators including cyclotrons, suppliers of radioactive sources and devices containing them) the state of radiation protection is considered to be on the whole satisfactory. With regard to suppliers, ASN considers that the areas in which practices still need to be improved are advance preparations for the expiry of the sources administrative recovery period (which by default is 10 years), information for the purchasers regarding future source recovery procedures, and the checks prior to delivery of a source to a customer. The actions carried out by the licensees in recent years are continuing to improve radiation protection within the research laboratories. The conditions for the storage and elimination of waste and effluent remain the primary difficulties encountered by the research units or universities, including with regard to the performance and traceability of checks prior to elimination, the recovery of “legacy” unused sealed radioactive sources or the regular elimination of stored radioactive waste. It would appear to be necessary for the licensees to reinforce the organisational provisions designed to ensure compliance with the prescriptions of their licenses, notably that regarding the maximum activity they possess, or to perform all the technical checks required by the regulations, and that they anticipate the costs related to the handling of “legacy” sources or waste. With regard to the veterinary uses of ionising radiation, ASN can see the result of the efforts made by veterinary bodies over the past few years to comply with the regulations, notably in conventional radiology activities on pets. For practices concerning large animals such as horses, or performed outside veterinary facilities, ASN considers that the implementation of radiological zoning and the radiation protection of persons from outside the veterinary facility who take part in the radiographic procedure, are points requiring particular attention. With regard to the protection of sources of radiation against malicious acts, more particularly when high-level radioactive sources or batches of equivalent sources are used, the inspections conducted by ASN show that the licensees are gradually implementing the measures needed to comply with the requirements set out in the Order of 29 November 2019. Thus, the categorisation of sources, an essential step in identifying the applicable requirements and in implementing an approach proportionate to the risks, has been done by the vast majority of the facilities concerned. Similarly, the issue of nominative permits for access to sources is progressing, even if it still needs to be implemented in nearly half the facilities. ASN therefore considers that significant progress is still needed, in particular because, since mid-2022, the requirements regarding the presence of physical systems to prevent unauthorised access to sources have become applicable, offering intrusion resistance compliant with that stipulated by the Order. In 2023, ASN will continue its actions to raise licensee awareness on these subjects. 28 ABSTRACTS – ASN Report on the state of nuclear safety and radiation protection in France in 2022 ASN Assessments