In 2023, 20 approval applications were submitted to ASN. ASN issued 28 approval or shipment authorisation certificates, for which the breakdown according to type is presented in Graph 2. The nature of the transports and packages concerned by these certificates is presented in Graph 3. 4.2 MONITORING ALL THE STAGES IN THE LIFE OF A PACKAGE ASN performs inspections at all the stages in the life of a package: from manufacture and maintenance of a packaging, to package preparation, shipment and reception. In 2023, ASN carried out 100 inspections in the field of radioactive substances transport (all sectors considered). The follow-up letters to these inspections are available on asn.fr. Since 2023 and twice a year, ASN publishes the applicable list of package model approval certificates that it has issued, on its website. 4.2.1 Regulation of package manufacturing The manufacture of transport packaging is subject to the regulations applicable to the transport of radioactive substances. The manufacturer is responsible for producing packagings in accordance with the specifications of the safety case, demonstrating regulatory compliance of the corresponding package model. To do this, it must implement a quality management system covering all the operations from procurement of parts and raw materials up to final inspections. Furthermore, the manufacturer must be able to prove to ASN that it complies with the regulatory provisions and, in particular, that the as-built packagings are compliant with the specifications of the safety case. The inspections carried out by ASN in this field aim to ensure that the manufacturer satisfactorily fulfils its responsibilities. In 2023, ASN carried out ten inspections on the manufacturing of various packagings for which ASN had issued an approval certificate, at various steps in the manufacturing process: welding, final assembly, manufacturing completion checks, assembly of internals (to immobilise the contents), etc. During these inspections, ASN reviews the quality management procedures implemented for the manufacture of a packaging on the basis of the design data and verifies their effective implementation. ASN ensures that the inspections performed and any manufacturing deviations are traceable. It also visits the manufacturing shops to check the package components storage conditions, the calibration of the inspection instruments and compliance with the technical procedures at the various manufacturing steps (welding, assembly, etc.). ASN checks the monitoring of package manufacturing by the lead contractor and may intervene directly on the sites of any subcontractors, who may sometimes be located abroad. ASN may also inspect the manufacture of the specimens used for the drop tests and fire tests required by the regulations. The objectives are the same as for the series production model because the specimens must be representative and comply with the maximum requirements indicated in the mock-up manufacturing file, which will determine the minimum characteristics of the actual packaging to be manufactured. In 2024, ASN intends to continue inspections of transport packaging manufacturing. This is because the irregularities detected in 2016 at the Framatome Le Creusot plant, which notably affected certain transport packagings, as well as the discovery in 2022 of falsifications concerning conventional products at the manufacturer of steel castings and forgings, Japan Steel Works Ltd. (JSW) – which also produces parts for transport packagings – confirmed the importance of inspecting the packaging manufacturing and maintenance operations. 4.2.2 Packaging maintenance inspections The consignor or user of a packaging loaded with radioactive substances must be able to prove to ASN that this packaging is periodically inspected and, if necessary, repaired and maintained in good condition such that it continues to satisfy all the relevant requirements and specifications of its safety case and its approval certificate, even after repeated use. For approved packagings, the inspections carried out by ASN for example concern the following maintenance activities: ∙ the periodic inspections of the components of the containment system (screws, welds, seals, etc.); ∙ the periodic inspections of the securing and handling components; ∙ the definition of the frequency of replacement of the packaging components which must take account of any reduction in performance due to wear, corrosion, ageing, etc. 4.2.3 Inspections of packages not requiring approval For the packages that do not require ASN approval, the consignor must, at the request of ASN, be able to provide the documents proving that the package model complies with the applicable regulations. More specifically, for each package, a file demonstrating that the model meets the regulation requirements and that it can in particular withstand the specified tests, along with a certification delivered by the manufacturer attesting full compliance with the model specifications, must be kept at the disposal of ASN. The various inspections carried out in recent years confirm progress in compliance with this requirement and in implementation of the ASN recommendations detailed in its guide concerning packages which are not subject to approval (Guide No. 7, volume 3). This Guide proposes a structure and a minimum content for the safety cases demonstrating that packages which are not subject to approval do comply with all the applicable requirements, along with the minimum content of a declaration of conformity of a package design with the regulations. ASN thus noted improvements in the content of the certificate of conformity and the safety case drawn up by the relevant players, more specifically for the industrial package models. The representativeness of the tests performed and the associated safety case remain the focal points during the ASN inspections, in particular for type A packages. In January 2023, ASN renewed the approvals for the organisations responsible for checking conformity, issuing approvals for tanks designed to transport radioactive substances, and checking the conformity of packagings containing UF6. These approvals were issued further to a favourable opinion from the CSPRT. Only Bureau Veritas Exploitation and Apave Exploitation France hold five-year approval to carry out these operations. INSPECTION ORGANISATIONS FOR TANKS AND UF6 PACKAGINGS ASN Report on the state of nuclear safety and radiation protection in France in 2023 281 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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