ASN Report 2023

these deviations. Thus, more than 40% of the inspections found deviations concerning the prevention plan (for example: no plan, operators unaware of the plan, plan not available on the worksite, or shortcomings in the content). ASN points out that the work area must be cordoned off before the work begins and, in all events, before the radiography equipment is installed, that the cordoning off must be continuous and that it is essential to have warning lights in sufficient quantity. To ascertain that cordoning off ensures compliance with the effective dose integrated over one hour set by the regulations, it is vital to take one or more measurements and to record the results. Cordoning off the work zone effectively constitutes the main safety barrier in worksite conditions, particularly to prevent unintended exposures. Consequently, ASN remains extremely vigilant regarding this point, which is systematically checked during worksite inspections. Moreover, penal enforcement actions have already been proposed for serious breaches. The recurrence of the deviations observed in the last few years in cordoning off the work zone induced ASN to address a circular letter to the profession as a whole in 2021, asking for tightened vigilance in this respect. ASN also points out that in the case of gamma radiography, it is vital to approach a measuring device to the projector in order to check that the radioactive source is effectively in the safe position. It is still found too frequently that this check is either not carried out or does not go right up to the tip of the projector (where the guide tube is connected to the projector), which could lead to significant exposures of the operators in the event of an equipment failure. ASN also notes disparities in the quality of the technical files it has to examine for inspection preparation or follow‑up, and those received for license applications. The companies must in particular be more attentive to the reports establishing the conformity of their facilities with the appropriate technical baseline requirements. ASN still detects errors too frequently, particularly when production of these reports has been subcontracted, and these errors sometimes lead to nonconformities. ASN considers that the risks of incidents and the workers’ occupational exposure are generally well controlled by the companies when radiography is performed in a bunker complying with the applicable regulations. France has a good network of permanent industrial radiography facilities. The figures in 2023 stand at: ∙ 95 licensed gamma radiography facilities (35 gamma radiography facilities and 60 combined facilities, that is to say which can accommodate either gamma ray projectors or electrical devices emitting X‑rays); ∙ 465 licensed X‑ray radiography facilities (398 facilities using electrical devices, 60 combined facilities and 7 facilities using accelerators). This network thus enables 82% of the professionals to propose industrial radiography services within facilities (55% for gamma radiography). Despite the availability of such facilities, ASN still observes too often that parts that undergo radiography on worksites could have been easily moved to a facility. Apart from optimising doses for the workers, it would also eliminate the risk of having to temporarily shut down the worksite (which could last several days) due to the setting up of an exclusion area, in the event of an incident preventing the radioactive source of a gamma ray projector from returning to the safe position. ASN considers that the ordering customers have a key role to play to improve radiation protection in industrial radiography, by favouring industrial radiography services in a facility, or even turning to alternative technologies. Indeed, with regard to application of the principles of justification and optimisation, the long‑term reflections undertaken by the non‑destructive testing professionals have resulted in guidelines which aim to promote the use of alternative methods to industrial radiography. The work is continuing within the professional bodies, in particular with the updating of the construction and maintenance codes for industrial equipment, in order to promote the use of non‑ionising inspection methods. Enhancing the awareness of all the players is therefore a priority. The regional initiatives to establish charters of good practices in industrial radiography implemented for several years now at the instigation of ASN and the labour inspectorate, particularly in areas corresponding to the (former) regions of Provence‑Alpes‑Côte d’Azur, Normandie, Auvergne‑Rhône‑Alpes, Nord‑Pas‑de‑Calais, Bretagne and Pays de la Loire, allow regular exchanges between the various stakeholders. The ASN regional divisions and other regional administrations concerned also regularly organise regional awareness‑raising and discussion symposia for which the actors of this professional branch show a real interest. Lastly, in 2023 as in the last few years, no cases of overexposure of industrial radiography operators were reported to ASN, even if several significant events linked to loss of source control (source “jamming”) did occur during the use of gamma ray projectors. Unlike the last three years, the operators have undertaken no inappropriate or prohibited actions or manipulations, thereby avoiding causing unnecessary exposure or complicating the subsequent work that would be necessary to restore a normal situation. ASN points out the obligation for all gamma ray projector users to obey the instructions applicable in the event of a situation of “source jamming” outside the projector, which consists during the emergency phase in immediately stopping any handling of the projector or its accessories, rapidly cordoning off the area to avoid any further exposure to ionising radiation and contacting the device supplier for assistance. ASN remains particularly attentive to the management of these events. The need to plan for an emergency organisation for managing such events was moreover recalled in the circular letter that ASN sent to the radiography professionals in 2021. Penal enforcement actions have already been proposed for serious breaches, and will continue to be so. 3.2 INDUSTRIAL IRRADIATORS 3.2.1 The devices used Industrial irradiation is used for sterilising medical equipment, pharmaceutical or cosmetic products and for the conservation of foodstuffs. It is also used to voluntarily modify the properties of materials, such as for the hardening of polymers. These consumer product irradiation techniques can be authorised because, after being treated, these products display no residual artificial radioactivity (the products are sterilised by passing through radiation without themselves being “activated” by the treatment). Industrial irradiators often use cobalt‑60 sources, whose activity can be very high and exceed 250,000 terabecquerels (TBq). Some of these facilities are classified as BNIs (see chapter 13). In many sectors, X‑ray generators are gradually replacing high‑activity sealed sources for the irradiation of products (see point 1.3.1). 260 ASN Report on the state of nuclear safety and radiation protection in France in 2023 • 08 • Sources of ionising radiation and their industrial, veterinary and research applications

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