In addition, Table 5 (see next page) presents the total number of inspector.days devoted to inspections, whether performed on-site, remotely, or using a combination of the two. ASN sends the licensee an inspection follow-up letter, published on asn.fr, which officially documents: ∙ deviations between the situation observed during the inspection and the regulations or documents produced by the licensee pursuant to the regulations; ∙ anomalies or aspects warranting additional justifications; ∙ best practices or practices to which improvements could be made, even if not directly constituting requirements. The requests contained in the follow-up letters may concern requests for corrective actions or additional information, in the light of the deviations found during the inspections. The follow-up letter prioritises the actions requested by ASN, so that the licensees can also implement a graded approach to processing the deviations found and optimise coordination of the means at their disposal. The actual performance of the actions requested by ASN is followed up in a manner proportional to the issues at stake. Thus the priority action requests undergo exhaustive checks when their deadlines expire. The other requests are monitored by sampling, using appropriate methods (documentary check, follow-up inspection, etc.). Any non-compliance found during the inspection can lead to administrative or criminal penalties (see point 6). Some inspections are carried out with the support of one or more IRSN representatives specialised in the facility checked or the technical topic of the inspection. ASN inspectors ASN has inspectors designated and accredited by its Chairman, pursuant to Article L. 596-2 of the Environment Code for nuclear safety inspectors and Article L. 1333-29 of the Public Health Code for radiation protection inspectors, subject to their having acquired the requisite legal and technical skills through professional experience, mentoring or training courses. The inspectors take an oath and are bound by professional secrecy. They exercise their inspection activity under the authority of the ASN Director General and benefit from regularly updated practical tools (inspection guides, decision aids) to assist them in their inspections. As part of its continuous improvement policy, ASN encourages the exchange and integration of best practices used by other inspection organisations: ∙ by organising international exchanges of inspectors between Safety Authorities, either for the duration of one inspection or for longer periods that could extend to a secondment of up to several years. Thus, after having observed its advantages, ASN has adopted the concept of in-depth inspections described earlier. However, it did not opt for the system involving a resident inspector on a nuclear site, as ASN considers that its inspectors must work within a structure large enough to allow experience to be shared and that they must take part in inspections of different licensees and facilities in order to acquire a broader view of this field of activity. This choice also allows greater clarity in the exercise of the respective responsibilities of the licensee and the inspector; ∙ by welcoming inspectors trained in other inspection practices. ASN encourages the integration into its departments of inspectors from other regulatory authorities, such as the Regional Directorate for the Environment, Planning and Housing (Dreal), ANSM, Regional Health Agencies (ARS), etc. It also proposes organising joint inspections with these authorities on activities falling within their common areas of competence; ∙ by organising the participation of its staff in inspections on subjects in different regions and fields, notably to promote the uniformity of its practices. Each ASN inspector in a particular region takes part every year in at least one inspection performed in a different region. Table 3 presents the headcount of inspectors, which stood at 307 on 31 December 2023. Some inspectors operate in several inspection fields, and all the operational entity heads and their deputies fulfil both managerial and inspection functions. Most of the inspections are carried out by inspectors assigned to the regional divisions, who represent 51% of the ASN inspectors. The 150 inspectors assigned to the departments take part in ASN inspections within their field of competence; they represent 49% of the inspector headcount and carried out 20% of inspections in 2023, with most of their work being the examination of files. As previously mentioned, ASN continuously improves the efficiency of its oversight by targeting and modulating its inspections according to the scale of the implications for the protection of persons and the environment. TABLE Breakdown of inspectors per inspection field as at 31 December 2023 INSPECTOR CATEGORIES DEPARTMENTS DIVISIONS TOTAL Nuclear safety inspectors 130 111 241 including nuclear safety inspectors for transport 17 39 56 Radiation protection inspectors 37 98 135 Labour inspectors 3 19 22 Inspectors for all fields 150 157 307 3 TABLE Number of inspections per field in 2023 BASIC NUCLEAR INSTALLATION (EXCEPT PRESSURE EQUIPMENT) PRESSURE EQUIPMENT TRANSPORT OF RADIOACTIVE SUBSTANCES SMALL-SCALE NUCLEAR ACTIVITIES APPROVED ORGANISATIONS AND LABORATORIES TOTAL 718 147 88 771 66 1,790 4 ASN Report on the state of nuclear safety and radiation protection in France in 2023 151 • 03 • Regulation of nuclear activities and exposure to ionising radiation 03 05 15 08 11 04 14 06 07 13 AP 10 02 09 12 01
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