This resolution defines the rules specified in the Order of 24 October 2022, that the party in charge of a nuclear activity is required to have verified by an AORP. This resolution is based on rules defined in ASN resolution 2008-DC-0095 of 29 January 2008, specifying the technical rules to be met by the elimination of effluents and waste contaminated by radionuclides, or liable to be so contaminated as a result of a nuclear activity, as well as resolution 2014-DC-0463 of 23 October 2014 relative to the minimum technical rules for the design, operation and maintenance of in vivo nuclear medicine facilities. 1. The intervention is the unit representative of activity traditionally used by the labour inspectorate. Finally, ASN resolution 2010-DC-0191 of 22 July 2010 was replaced by resolution 2022-DC-0748 which entered into force on 5 February 2023. This resolution sets the conditions and procedures for approval of organisations responsible for the verifications mentioned in Article R. 1333-172 of the Public Health Code. 3 Performing efficient regulation and oversight 3.1 INSPECTION 3.1.1 Inspection objectives and principles The inspection carried out by ASN is based on the following principles: ∙ The inspection aims to verify compliance with the provisions that are mandatory under the regulations. It also aims to assess the situation with regard to the nuclear safety and radiation protection implications; it seeks to identify best practices, practices that could be improved and assess possible developments of the situation. ∙ The scope and depth of the inspection is adjusted to the risks inherent in the activity and the way they are effectively taken into account by those responsible for the activity. ∙ The inspection is neither systematic nor exhaustive; it is based on sampling and focuses on the subjects with the highest potential consequences. 3.1.2 Inspection resources implemented To ensure greater efficiency, ASN action is organised on the following basis: ∙ inspections, at a predetermined frequency, of the nuclear activities and topics of particular health and environmental significance; ∙ inspections of other nuclear activities decided on the basis of topical events (OEF, whistle-blower reports, context showing difficulties, etc.); ∙ inspections of approved organisations and laboratories. The inspections may be unannounced or notified to the licensee a few weeks beforehand. They take place mainly on the site or during the course of the activities (work, transport operation, etc.). They may also concern the head office departments or design and engineering departments at the major nuclear licensees, the workshops or engineering offices of the subcontractors, the construction sites, plants or workshops manufacturing the various safety-related components. ASN uses various types of inspections: ∙ routine inspections, usually two inspectors for one day; ∙ reinforced inspections, which consist in conducting an in-depth examination of a targeted topic by a larger team of inspectors than for a routine inspection; ∙ in-depth inspections which take several days and cover several topics, involving ten or so inspectors. Their purpose is to carry out detailed examinations and they are overseen by senior inspectors; ∙ inspections with sampling and measurements. With regard to both discharges and the environment of the facilities, these are designed to check samples that are independent of those taken by the licensee; ∙ event-based inspections carried out further to a particularly significant event; ∙ worksite inspections, ensuring a significant ASN presence on the sites on the occasion of reactor outages or particular work, especially in the construction or decommissioning phases; ∙ inspection campaigns, grouping inspections performed on a large number of similar installations, following a predetermined template. Labour inspectorate work in the NPPs entails various types of interventions(1), which more particularly involve: ∙ checking application of the Labour Code by EDF and outside contractors in the NPPs (verification operations that include inspections); ∙ participation in meetings of the Health, Safety and Working Conditions Commissions (CSSCT), of Social and Economics Committees and the inter-company committees on safety and working conditions (EPR construction site); ∙ conducting inquiries on request, following complaints or based on information, further to which the inspectors may take decisions as specified by the labour regulations, such as cessation of the works or the obligation to have the work equipment verified by an accredited organisation. Remote inspections can be performed by the inspectors, in conjunction with on-site inspections. This tool is suitable for certain inspection topics. On-site inspection however remains the preferred method of verification. Only a few percent of the inspections are performed remotely each year. The implementation of remote inspection measures in 2020 required that ASN modify the inspection indicators. For this type of inspection, the critical review of documents transmitted by a party RNA, during the on-site inspection preparation phases, becomes the primary method. It is then no longer possible to differentiate between preparation of the inspection, involving this documentary examination, and the inspection itself. The following paragraphs will therefore present the number of inspector.days corresponding to the on-site inspections and the number of remote inspections. The number of inspector.days in these paragraphs cannot therefore be directly compared with that of years before 2020, because it only reflects the time spent on the site and does not take account of the remote inspections. 150 ASN Report on the state of nuclear safety and radiation protection in France in 2023 • 03 • Regulation of nuclear activities and exposure to ionising radiation
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