The deadline of 5 December 2021 indicated in the abovementioned Order led to an increase in removal operations at the end of 2021. Since then, the removal operations are continuing and the number of ICSDs remaining is gradually decreasing. ASN continues to maintain close relations with Qualdion, an association created in 2011 which labels the companies that comply with the regulations relative to radiation protection and fire safety. The list of Qualdion-labelled companies is available on the Internet. ASN participates with the association in communication campaigns targeting the holders of ionic detectors and the professionals (Expoprotection trade fair, Mayors’ trade fair, etc.). Surge suppressors Surge suppressors (sometimes called lightning arresters), not to be confused with lightning conductors, are small objects with a very low level of radioactivity used to protect telephone lines against voltage surges in the event of lightning strike. These are sealed devices, often made of glass or ceramic, enclosing a small volume of air containing radionuclides to pre- ionise the air and facilitate electrical sparkover. The use of surge suppressors has been gradually abandoned since the end of the 1970s, but the number remaining to be removed, collected and disposed of is still very high (several million units). When installed, these devices represent no risk of exposure for individuals. However, there can be a risk of exposure and/or contamination, albeit very low, if these objects are handled without precautions or if they are damaged. ASN issued a reminder to the company Orange (formerly France Télécom), which has begun an experimental process to identify, remove, sort and dispose of surge suppressors in the Auvergne-Rhône-Alpes region and has proposed a national removal and disposal plan. This plan was presented to ASN, and led in September 2015 to the issuing of a license governing the removal of all surge suppressors containing radionuclides present on the Orange network in France and their interim storage on identified sites. This license was renewed in 2021. The search for a disposal route is in progress in collaboration with Andra, the French National Agency for Radioactive Waste Management. This progressively implemented removal and disposal plan was completed in 2024. Lastly, Réseau de Transport d’Électricité (RTE), the French power transmission utility, has also filed an application for a license in order to start a national plan for removal of the surge arresters installed on its network. A national licence regulating these surge arrester removal operations and their interim storage on specified sites was issued to RTE late 2022. As with Orange, RTE is working with Andra to find a disposal route. Additional characterisations are going to begin, with the aim more specifically of determining whether or not occluded gases are present in the surge arresters (gases which could be present from the manufacturing stage in certain models) in order to subsequently determine the appropriate methods of dealing with these devices. Lightning conductors Radioactive lightning conductors were manufactured and installed in France between 1932 and 1986. The ban on the sale of radioactive lightning conductors was declared in 1987. This Order did not make the removal of installed radio- active lightning conductors compulsory. Consequently, there is no obligation at present to remove the radioactive lightning conductors installed in France, except in certain ICPEs (Order of 15 January 2008 which set the removal deadline at 1 January 2012) and in certain installations under Ministry of Defence responsibility (Order of 1 October 2007 which set a removal deadline at 1 January 2014). ASN nevertheless considers it necessary for all existing radioactive lightning conductors to be removed and transferred to Andra, given the risks they can represent, depending in particular on their physical condition. For several years now ASN has been working to raise professional awareness of the radiation risks for workers and the public. ASN has stepped up its action in this respect by reminding the professionals of their obligations, particularly that of being licensed or registered by ASN for the removal and storing of lightning conductors pursuant to Articles L. 1333-1 and 2, L. 1333-8, and R. 1333-104 of the Public Health Code ASN conducts field oversight operations targeting the companies involved in recovering these objects, combined with unannounced inspections on the removal sites. The number of lightning conductors installed in France was estimated at about 40,000 in the 1990’s. Slightly more than 12,000 have already been removed and recovered by Andra. The current rate of removal is about 200 radioactive lightning conductors per year. 2.3 The regulatory changes 2.3.1 Tightening the regulation of electrical devices emitting ionising radiation ASN considers that the regulatory oversight of suppliers of electrical devices emitting ionising radiation is still insufficient, when the placing of devices on the market is so vitally important for the optimisation of the future radiation exposure of users. The work carried out by ASN in this area, which at present is directed towards the use of these generators, particularly in enclosures, has led to the publication of ASN resolution 2017-DC-0591 of 13 June 2017 setting the minimum technical design rules applicable to facilities that use X-rays. This resolution came into effect on 1 October 2017. It replaced ASN resolution 2013-DC-0349 of 4 June 2013 without creating additional requirements for already compliant facilities. It concerns facilities in the industrial and scientific (research) sectors, such as industrial X-ray radiography in bunkers and veterinary radiology. It takes account of experience feedback and sets the radiation protection goals by adopting a graded approach to the risks. ASN considers that these provisions, which are directed exclusively at the use these devices, must be supplemented by provisions concerning their actual design. This is because, for electrical devices used for non-medical purposes, there is no equivalent of the “CE” marking that is mandatory for medical devices, certifying conformity with several European standards that cover various aspects, including radiation protection. Furthermore, experience feedback shows that a large number of devices do not have a certificate of conformity to the standards applicable in France. These standards have been mandatory for many years now, but some of their requirements have become partly obsolete or inapplicable due to the lack of recent revisions. On the basis of the work done in collaboration with the Electrical Certification and Testing Entity (LCIE), the Alternative Energies and Atomic Energy Commission (CEA) and IRSN, draft texts have been produced with the aim of defining minimum radiation protection requirements for the design of these devices and an informal technical consultation of the stakeholders (suppliers, French and foreign manufacturers and the principal users) was conducted in 2015. The various contributions are currently being analysed with the assistance of IRSN and the reference players (CEA and LCIE). The conclusions of this work will be taken into account to adapt the regulatory framework and subject the supply of electrical devices emitting ionising radiation to licensing, in the same way as for radioactive sources. Since 2021, ASN has thus been conducting work to characterise the advantages, drawbacks and the feasibility of various regulatory provisions for regulating, on the basis of appropriate technical baselines (work conducted with IRSN in particular), the design of industrial radiography devices. The discussions with the General Directorate for Labour (DGT) on the various options are continuing and highlight the need to strengthen their link with the existing European framework. 256 ASN Report on the state of nuclear safety and radiation protection in France in 2024 Sources of ionising radiation and their industrial, veterinary and research applications
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