Furthermore, ASN is still finding shortcomings in the demonstration by some of the players (designers, manufacturers, distributors, owners, consignors, companies performing the regulatory drop tests, package maintenance, etc.) of package conformity with the regulations. The areas for improvement concern the following points in particular: ∙ the description of the authorised contents per type of packaging; ∙ the demonstration that there is no loss or dispersion of the radioactive content under normal conditions of transport; ∙ compliance with the regulatory requirements regarding radiation protection, more specifically the demonstration, as of the design stage, that it would be impossible to exceed the dose rate limits with the maximum authorised content. 4.2.4 Monitoring the shipment and transportation of packages The scope of ASN inspections includes all regulatory requirements binding on each of the transport players, that is compliance with the requirements of the approval certificate or declaration of conformity, training of the personnel involved, implementation of a radiological protection programme, satisfactory stowage of packages, dose rate and contamination measurements, documentary conformity, implementation of a quality assurance programme, etc. More particularly with respect to transports concerning smallscale nuclear activities, the ASN inspections confirm significant disparities from one carrier to another. The differences most frequently identified concern the quality assurance programme, actual compliance with the procedures put into place and radiation protection of the workers. Knowledge of the regulations applicable to the transport of radioactive substances seems to be sub-standard in the medical sector in particular, where the procedures adopted by some hospitals or nuclear medicine units for package shipment and reception need to be tightened. Their quality management system has not yet been formally set out and deployed, more specifically with regard to the responsibilities of each member of staff involved in receiving and dispatching packages. More generally, in transport operations for small-scale nuclear activities, the radiological protection programmes and the safety protocols have not yet been systematically defined. ASN also found that checks on vehicles and packages prior to shipment need to be improved. The inspections concerning the transport of gamma ray projectors regularly reveal inappropriate stowage or tie-down. In the BNI sector, ASN considers that the consignors must improve how they demonstrate that the content actually loaded into the packaging complies with the specifications of the approval certificates and the corresponding safety cases, including if this demonstration is provided by a third-party. In this latter case, the consignor’s responsibilities then require that it verify that this demonstration is appropriate, and that it monitor the third-party company in accordance with the usual methods of a quality assurance system. As BNI licensees are increasingly using contractors to prepare and ship packages of radioactive substances, ASN is paying particularly close attention to the organisation put into place to monitor these contractors. Finally, with regard to on-site transports within NPPs, ASN considers that the licensees must remain vigilant to the application of package stowage rules. 4.2.5 Analysis of transport events The safety of the transport of radioactive substances relies in particular on the existence of a reliable system for detecting and processing anomalies, deviations or, more generally, any abnormal events that could occur. Therefore, once detected, these events must be analysed in order to: ∙ prevent identical or similar events from happening again, by taking appropriate corrective and preventive measures; ∙ prevent a more serious situation from developing by analysing the potential consequences of events which could be precursors of more serious events; ∙ identify the best practices to be promoted in order to improve transport safety. The regulations also require on-line notification to ASN of the most significant events so that they can ensure that the detection system, the analysis approach and the integration of Operating Experience Feedback (OEF) are effective. This also provides ASN with an overview of events so that the sharing of OEF can be encouraged between the various stakeholders – including internationally – and so that ASN can consider potential changes to the provisions governing the transport of radioactive substances. As requested in Article 7 of the Order of 29 May 2009, amended, concerning the transport of dangerous goods by land, any significant event concerning the transport of radioactive substances, whether the consequences are actual or potential, must be notified to ASN within four working days, as stipulated in its Guide No. 31 on the notification of events. This Guide can be consulted on asn.fr. After notification, a detailed report of the event must be sent to ASN within two months. On 7 September 2023, ASN inspectors went to a worksite where a non-destructive testing company was to check the weld on a district heating network pipeline using gamma radiography, in the 14th arrondissement of Paris. They observed the arrival of the vehicle containing the gamma ray projector. They noted the absence of external signage and placarding on the vehicle and, after the van was opened, the lack of correct stowage of the gamma ray projector. The orange plates and the regulation “7D” label-holders, along with the chains and padlocks intended for package stowage were however on-board the vehicle. As these numerous breaches constituted a class 5 violation, the gamma radiography company was cited in a report which was sent to the Public Prosecutor’s Office. UNSCHEDULED EVENING INSPECTION OF A GAMMA INDUSTRIAL RADIOGRAPHY WORKSITE 282 ASN Report on the state of nuclear safety and radiation protection in France in 2023 • 09 • Transport of radioactive substances
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