The changes in regulations adopted since early 2016 have led to an organisation for oversight of the protection of ionising radiation sources against malicious acts which takes into account the existing organisation by entrusting this oversight: ∙ to the service of the HFDS of the Ministry responsible for energy in facilities whose security is already under its control; ∙ to the Ministry of the Armed Forces in the locations placed under its authority; ∙ to ASN for the other facilities where nuclear activities take place. The process necessary to set up this oversight, initiated by the Government in 2008 with the assistance of ASN, resulted in Ordinance 2016‑128 of 10 February 2016 and then Decree 2018‑434 of 4 June 2018 introducing various provisions concerning nuclear activities. These texts, which amend the Public Health Code, divide up the oversight duties in the various installations as indicated above, by including protection against malicious acts in the risks that must be taken into account by the persons/ entities Responsible for Nuclear Activities (RNAs) and by the regulatory bodies when reviewing the licensing applications. The sources and installations concerned Oversight of source protection against malicious acts concerns all sources of ionising radiation, that is to say all the devices that could cause exposure to radiation. The majority of the regulatory measures are however taken to increase the security of the sources presenting the greatest radiological risks: this concerns radioactive sources of categories A, B and C as defined in the Public Health Code, which stems directly from that of the IAEA. The protection requirements are proportionate to the intrinsic dangerousness of the sources. The graded approach therefore implies stricter obligations for the sources (or batches of sources) in category A than those in category C. Sealed sources that are not in categories A, B or C and whose activity exceeds the exemption threshold, and the other ionising radiation sources such as X‑ray generators, are classified in category D. Some 240 facilities in the civil sector in France hold slightly less than 6,000 radioactive sources presenting such security risks. These sources are used essentially for industrial purposes (irradiation, radiography, measurements, etc.) or medical purposes (such as telegammatherapy and brachytherapy. Due to their frequent movements when on worksites, industrial radiography sources present particular security risks. If sources of different categories are stored together, the lower category sources may be subject to the stricter security measures applicable to the higher category sources. Regulations The Decree modifying the regulatory part of the Public Health Code taken in application of Ordinance 2016‑128 of 10 February 2016 (Decree 2018‑434 introducing various provisions with regard to nuclear activities) was published on 4 June 2018. It contains several provisions concerning the protection of sources against malicious acts, and more specifically: ∙ the classification of ionising radiation sources and aggregation (batching) of radioactive sources into category A, B, C or D according to the intrinsic level of risks presented by these sources or batches of sources. The category A sources are the most dangerous and the category D sources the least dangerous (Article R. 1333‑14 of the Public Health Code); ∙ the obligation to promptly notify the various administrative authorities, particularly the regionally competent law enforcement agencies, of any actual or attempted malicious act or loss concerning a source of ionising radiation or a batch of radioactive sources of category A, B or C (R. 1333‑22); ∙ the sending of sensitive information, that is to say elements that could facilitate malicious acts by separate, specially identified mail (R. 1333‑130); ∙ the issuing of a nominative and written authorisation to the persons having access to ionising radiation sources or batches of radioactive sources in category A, B or C, transporting them, or having access to information concerning their protection against malicious acts (R. 1333‑148). Radioactive sources present radiation exposure and safety risks for their users, the general public and the environment, which must be taken into consideration in the reflection phase preceding the deployment of a nuclear activity. Consequently, in France, when technologies presenting lower risks than a nuclear activity are available under technically and economically acceptable conditions, they must be implemented instead of the nuclear activity initially envisaged: this is the principle of justification. On this basis, as of 2014 and subsequently at the Nuclear Security Summit in Washington in April 2016, France was the initiator of an international initiative now supported by 31 countries and by Interpol. The aim is to support research into and the development of technologies that do not use high‑activity sealed radioactive sources and to promote the use of these technologies. In this context, in April 2015, ASN and the National Nuclear Security Administration (NNSA) of the United States of America jointly created an informal focus group, comprising several countries, to explore the replacement of high‑activity radioactive sources by alternative technologies. The aim of this group, which meets once a year, is to foster greater awareness of the benefits of such alternatives and to share experience feedback from each country in this respect. In December 2018, during the International Conference on Nuclear Security organised by the IAEA, the subject of alternative technologies was addressed by several presentations and two panel sessions, and the relevance of this think tank was underlined. The group’s meeting of 2023, like that of 2022, was an virtual on‑line meeting attended by 200 participants. It provided the opportunity to carry out a first assessment of the experience acquired by several facilities after using X‑ray irradiators or accelerators instead of radioactive source irradiators for a few years. Several contributors underlined the need to plan ahead with regard to device maintenance. More generally, access to the theoretical and practical training courses, for both the device operators and support teams, such as maintenance, is still problematic in certain countries. Lastly, the NNSA underlined the publication in spring 2023 by the US Government of the National Security Memorandum 19 which includes guidelines on the transition towards these alternative technologies. These regular meetings provide the opportunity to highlight both successful initiatives in the implementation of alternative technologies and difficulties in the development or implementation of these technologies which must be the subject of complementary work. INTERNATIONAL FOCUS GROUP ON ALTERNATIVE TECHNOLOGIES ASN Report on the state of nuclear safety and radiation protection in France in 2023 251 • 08 • Sources of ionising radiation and their industrial, veterinary and research applications 08 05 15 11 04 14 06 07 13 AP 03 10 02 09 12 01
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