3.1.7 Checks on exposure to Radon and Naturally Occurring Radioactive Materials ASN also checks radiation protection in premises where the exposure of persons to naturally occurring radiation may be reinforced owing to the underlying geological context (radon in PABs and in the workplace). Monitoring exposure to radon Article R. 1333-33 of the Public Health Code states that the activity concentration of radon in PABs is measured either by IRSN, or by organisations approved by ASN. These measurements are to be taken between 15 September of a given year and 30 April of the following year. Article R. 4451-44 of the Labour Code stipulates that, whenever required, the initial checks on the radon activity concentration in areas identified owing to the radon risk must be carried out by accredited organisations. Monitoring natural radioactivity in water intended for human consumption Monitoring the natural radioactivity in water intended for human consumption is the role of the ARS. The methods used for these checks take account of the recommendations issued by ASN and included in the circular from the General Directorate for Health of 13 June 2007. The results of the checks are jointly analysed and utilised by ASN and the services of the Ministry of Health. 3.2 ANALYSIS OF THE DEMONSTRATIONS PROVIDED BY THE LICENSEE The purpose of the files supplied by the licensee is to demonstrate compliance with the objectives set by the general technical regulations, as well as those that it has set for itself. ASN is required to check the completeness of the data and the quality of the demonstration. The review of these files may lead ASN to accept or to reject the licensee’s proposals, to ask for additional information or studies or to ask for work to be done to bring the relevant items into conformity. 3.2.1 Analysing the files transmitted by BNI licensees Reviewing the supporting documents produced by the licensees and the technical meetings organised with them are one of the forms of control carried out by ASN. Whenever it considers it necessary, ASN requests an opinion from its technical support organisations, the most important of which is IRSN. The safety review implies cooperation by numerous specialists, as well as efficient coordination, in order to identify the essential points relating to safety and radiation protection. The IRSN assessment is based on in-depth technical discussions with the licensee teams responsible for designing and operating the installations. It is also based on studies and research and development programmes focused on risk prevention and on improving our knowledge of accidents. For certain dossiers, ASN asks the competent Advisory Committee of Experts (GPE) for its opinion. For other matters, IRSN examines the safety analyses and gives its opinion directly to ASN. ASN procedures for requesting the opinion of a technical support organisation and, where required, of a GPE, are described in chapter 2. At the design and construction stage, ASN – aided by its technical support organisation – assesses the safety analysis reports describing and justifying the design principles, equipment and system design calculations, utilisation rules and test procedures, and quality organisation provisions implemented by the prime contractor and its suppliers. It also analyses the facility’s environmental impact assessment. ASN regulates and oversees the construction and manufacture of structures and equipment, in particular those of the main primary system and the main secondary systems of Pressurised Water Reactors (PWRs). In accordance with the same principles, it checks the packages intended for the TSR. Once the nuclear facility has been commissioned, following ASN authorisation, all changes to the facility or its operation made by the licensee that could affect security, public health and safety, or the protection of the environment, are reported to ASN or submitted to it for authorisation. Moreover, the licensee must perform periodic safety reviews to update the assessment of the facility, taking into account any changes in techniques and regulations, as well as OEF. The conclusions of these reviews are submitted by the licensee to ASN, which can issue new binding requirements for continued operation. The other files submitted by BNI licensees A large number of files concern specific topics such as fire protection, fuel management in PWRs, relations with the outside contractors, etc. The licensee therefore also periodically provides activity reports as well as summaries of water intake, liquid and gaseous discharges and waste produced. 3.2.2 Review of the applications required by the Public Health Code ASN is responsible for reviewing applications to possess and use ionising radiation sources in the medical and industrial sectors. ASN also deals with the specified procedures for the acquisition, distribution, import, export, transfer, recovery and disposal of radioactive sources. It in particular relies on the inspection reports from the approved organisations and the reports on the steps taken to remedy nonconformities detected during these inspections. In addition to the verifications carried out under the responsibility of the facilities and the periodic checks required by the regulations, ASN carries out its own checks when examining the applications. 3.3 LESSONS LEARNED FROM SIGNIFICANT EVENTS 3.3.1 Anomaly detection and analysis Background The international Conventions ratified by France (section VI of Article 19 of the Convention on Nuclear Safety of 20 September 1994; section V of Article 9 of the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management of 5 September 1997) require that BNI licensees implement a reliable system for early detection and notification of any anomalies that may occur, such as equipment failures or errors in the application of operating rules. Ten years previously, the “Quality Order” of 10 August 1984 already required such a system in France. ASN Report on the state of nuclear safety and radiation protection in France in 2023 153 • 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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