In the field of transport security, the IRSN Transport Operations Section (EOT) is responsible for managing and processing applications for approval of nuclear material shipments, for supervising these shipments and for notifying the authorities of any alerts concerning them. This security mission is defined by the Order of 28 February 2023 relative to the security of transport of nuclear materials, implementing Articles R. 1333-4 and R. 1333-17 to R. 1333-19 of the Defence Code. Thus, prior to any transport operation, the Defence Code obliges the carriers to obtain a transport authorisation. The EOT reviews the corresponding application. This review consists in checking the conformity of the intended provisions with the requirements defined by the Defence Code and the above-mentioned Order of 28 August 2023. ASN has initiated the process to update its resolution 2015‑DC‑0503 of 12 March 2015 relative to the notification system for companies transporting radioactive substances on French soil. This update aims to introduce an authorisation system for the transport of the most radioactive sources, in the light of their security implications. The interface between the provisions taken from the new regulations on the protection of ionising radiation sources and batches of category A, B, C and D radioactive sources against malicious acts (Order of 29 November 2019, amended) and the transport regulations will be dealt with. 3.3 REGULATION OF THE TRANSPORT OF DANGEROUS GOODS Regulation of the transport of dangerous goods is the responsibility of the Dangerous Materials Transport Commission (MTMD) of the Ministry responsible for the Environment. This structure is tasked with measures relative to the safe transport of dangerous goods other than class 7 (radioactive) by road, rail and inland waterways. It has a consultative body (standing sub-committee in charge of dangerous goods transport, within the High Council for the Prevention of Technological Risks – CSPRT), that is consulted for its opinion on any draft regulations relative to the transport of dangerous goods by rail, road or inland waterway. Inspections are carried out by land transport inspectors attached to the Regional Directorates for the Environment, Planning and Housing. For the regulation of dangerous goods to be as consistent as possible, ASN collaborates regularly with the administrations concerned. The breakdown of the various inspection duties is summarized in Table 3. 4 ASN action in the transport of radioactive substances 4.1 ISSUANCE OF APPROVAL CERTIFICATES AND SHIPMENT APPROVALS The type B and C packages, as well as the packages containing fissile materials and those containing more than 0.1 kilogram of UF6 must be have an ASN approval certificate in order to be used for transportation. The designers of the package models who request approval from ASN must support their application with a safety case demonstrating the compliance of their package with all the regulatory requirements. Before deciding whether or not to issue an approval certificate, ASN reviews this safety case, drawing when necessary on the expertise of IRSN, in order to ensure that the safety cases are pertinent and conclusive. If necessary, the approval certificate is issued with requests in order to improve the safety case. In some cases the IRSN appraisal is supplemented by a meeting of the Advisory Committee of Experts for the Transport of radioactive substances (GPT). The opinions of the Advisory Committees are always published on asn.fr. The approval certificate specifies the conditions for the manufacture, utilisation and maintenance of the transport package. It is issued for a package model, independently of the actual shipment itself, for which no prior ASN opinion is generally required. This shipment may however be subject to safety checks (physical protection of the materials against malicious acts under the supervision of the HFDS of the Ministry for the Environment). TABLE Administrations responsible for regulating the mode of transport and the packages MODE OF TRANSPORT REGULATION OF MODE OF TRANSPORT PACKAGE REGULATION By sea General Directorate for Infrastructures, Transports and the Sea (DGITM) at the Ministry for the Environment. In particular, the DGITM is responsible for regulating compliance with the prescriptions applicable to ships and contained in the International Code for the Safe Carriage of irradiated nuclear fuel, plutonium and high-level radioactive wastes on board ships (“Irradiated Nuclear Fuel” Code). The DGITM has competence for regulation of dangerous goods packages in general and is in close collaboration with ASN for radioactive substances packages. By road, rail and inland waterways General Directorate for Energy and Climate (DGEC) of the Ministry for the Environment. The General Directorate for the Prevention of Risks (DGPR) is responsible for regulation of packages of dangerous goods in general and, in close collaboration with ASN, of packages of radioactive substances. By air General Directorate for Civil Aviation (DGAC) at the Ministry for the Environment The DGAC has competence for regulation of dangerous goods packages in general and is in close collaboration with ASN for radioactive substances packages. 3 ASN Report on the state of nuclear safety and radiation protection in France in 2023 279 09 • 09 • Transport of radioactive substances 05 15 08 11 04 14 06 07 13 AP 03 10 02 12 01
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