were informed by ASN of the breaches of the regulations, and corrective measures were taken by the consignors to prevent such events from happening again; ∙ four other events concerned the same carrier which, over the space of four months, delivered radiopharmaceutical packages to the wrong hospitals. An ASN inspection recorded shortcomings in the company’s organisation, with possible human factors underlying the repeated delivery errors. ASN expects effective corrective measures to be taken and their actual implementation will be verified during an upcoming inspection; ∙ the discovery, by a service company, of an empty package in the basement of a building was rated level 1 on the INES scale, owing to a lack of radiation protection culture; ∙ the penultimate event rated level 1 concerns non-compliance with a criticality control rule in a rail shipment; ∙ and finally, the last event rated level 1 on the INES scale concerns incorrect tightening of one or two screws participating in the closure system for FCC transport packages loaded with fresh fuel, detected at reception in the NPPs. None of these 12 level 1 events on the INES scale had any consequences for the workers, population, or environment. Graph 5 shows the breakdown of significant events reported per notification criterion and Graph 6 presents their breakdown according to content and mode of transport. Causes of events The recurring causes of the significant events notified in 2022 include the following: ∙ non-conformities affecting a package: they mainly concern dose rate measurement errors, leading to under-evaluation of the package category, or labelling faults (error or omission). These events had no actual consequences for safety or radiation protection; ∙ surface contamination spots exceeding the regulation limits, detected mainly on conveyances which have been used to transport spent fuel packages, or inside containers or packagings. These events had very little impact on radiation protection of the public, who cannot have access to the contaminated areas; ∙ radiopharmaceutical products delivery errors, with no real consequences, as the drugs delivered are appreciably the same. Most of them could therefore be used with no impact on patient treatment or on the environment. The EIT reported to ASN are primarily deviations relating to incorrect labelling (loss or error) of packages and stowage faults. With regard to significant events occurring during transport within nuclear installations, these concern the transport of a drum containing a sample of radioactive materials, even though it was supposed to be empty, the failure to perform a ten-yearly inspection of a cylinder participating in a truck fire-fighting system, a transport documents error and the use of screws specific to another packaging configuration. The significant on-site transport events concern non-compliance with a package transport authorisation and the detection of contamination on the transport system carrier vehicle. 4.3 Participation in drawing up the regulations applicable to the transport of radioactive substances 4.3.1 Participation in the work of the International Atomic Energy Agency ASN represents France on the IAEA’s Transport Safety Standards Committee (TRANSSC), which brings together experts from all countries and reviews the IAEA Safety Standards constituting the basis of regulations concerning the transport of radioactive substances. With a view to constant improvement of safety levels, ASN notably played an active part in drafting the 2018 edition of this document, SSR-6. The IAEA Guide for application of the regulation of radioactive materials transport (SSG-26) was published in 2022. In 2022, ASN also supported the launch of a new revision cycle for SSR-6, submitting about sixty modification proposals to the IAEA in 2023. 4.3.2 Participation in drafting of national regulations ASN takes part in the drafting of French regulations relative to the transport of radioactive substances. These regulations mainly consist of the Order of 29 May 2009 and the Orders of 23 November 1987 concerning the safety of ships and of 18 July 2000 concerning the transport and handling of dangerous materials in sea ports. ASN therefore sits on the High Council for the Prevention of Technological Risks, which is called on to issue an opinion on any draft regulation for the transport of dangerous goods by rail, road and inland waterway. ASN is also consulted by the Ministry responsible for transport when a modification of the three Orders mentioned above can have an impact on the transport of radioactive substances. 4.4 Contributing to public information Ordinance 2012-6 of 5 January 2012, modifying Books I and V of the Environment Code, extends the obligations for public information to the persons responsible for nuclear activities. Article L. 125-10 of the Environment Code sets the thresholds beyond which the person responsible for transport must communicate the information requested by a citizen. The thresholds are defined as being those “above which, in application of the international conventions and regulations governing the transport of dangerous goods, of the Code of Transport and of their implementing texts, the transport of radioactive substances is subject to the issuance – by ASN or by a foreign Authority competent in the field of radioactive substance transport – of an approval of the transport package design or a shipment approval, including under special arrangement”. Any citizen may therefore ask the persons in charge of transport for Participants in the IAEA TRANSSC Committee No. 45 – 2 December 2022 280 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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