ASN identifies several areas for progress concerning the level of safety for the transport of radioactive material in France and draws up an action plan

Since 1997, ASN has been responsible for regulating the safety of the transport of radioactive and fissile materials used for civil purposes. ASN's actions in this field comprise:

• from the safety viewpoint, regulating all the stages in the life of a package, from design and manufacture through to maintenance;
• monitoring compliance with the safety regulations during the shipment and transportation of the packages.

Packages of radioactive material transported in France

About 900,000 packages of radioactive material are transported each year in France, which represents about 6% of the total number of dangerous goods packages transported.

To ensure the safety of the transport operations, the level of the requirements applicable to the radioactive substance packages is adapted to the potential danger of the material transported. There are five main package types: excepted packages, industrial packages, type A packages, type B packages and type C packages. These package types are determined according to the characteristics of the transported material, such as the total radiological activity, or the specific activity, corresponding to the concentration of the material, its physical-chemical form, or the possible presence of fissile radioactive material, which could be the origin of a nuclear chain reaction.

Thus, for each package type, the regulations define safety requirements including tests to assess their robustness. The higher the potential risks, the harsher these tests. For example, the type B packages used to transport large quantities of the most radioactive material, such as spent fuel or vitrified high level, long-lived nuclear waste, must be designed such that safety is guaranteed, including in the event of transport accident which is represented by a 9m drop onto an unyielding surface, A 1m drop onto a spike, a fully engulfing fire of at least 800°C for 30 minutes and immersion in water .

Given the level of risk associated with these packages, they are subject to an approval delivered by a competent authority (ASN in France). The approval confirms that the package design complies with the requirements of the applicable international regulations . To get this approval, the designer of any new transport package design must demonstrate the package’s conformity with the regulations in a “safety analysis report” transmitted to ASN along with the approval application. ASN then calls on the IRSN to assess this “safety analysis report”. ASN takes the decision to deliver an approval certificate on the basis of this technical examination, possibly combined with requests for further information to be added to the safety analysis report before the next approval renewal deadline.

For lower-risk packages, referred to as “packages not subject to ASN approval” (excepted packages, non-fissile industrial and type A packages), the regulations do not require ASN approval. The design and performance of the tests are the responsibility of the packaging manufacturer or owner. At the request of ASN, they must be able to demonstrate that the package type complies with the applicable requirements. A certificate from the packaging manufacturer or owner attesting full compliance with the model specifications for each package must be held at the disposal of ASN. These packages and their safety case files are regularly checked by the ASN inspectors.
 

ASN produces a report on the state of the safety of the transport of radioactive material

In 2012, ASN produced a report on the state of the safety of the transport of radioactive material used for civil purposes in France, drawing on the ASN inspection reports and on the events notified by the consignors and shippers between 2007 and 2011. Based on these data, areas for improvement were identified for the various stages in the transport of radioactive material.
Given the large number of packages transported, ASN considers that the level of safety of the transport of radioactive material in France is relatively satisfactory. It has however identified certain areas for progress concerning three fields: BNIs, small-scale nuclear facilities and transport companies.

On leaving the BNI, package conformity must be checked more thoroughly

Improvements could be made to improve the verification of package conformity with the requirements of the regulations and the provisions of the package model safety analysis report . More specifically, stricter guarantees of the conformity of the procedures with these requirements must be provided, at all stages in the life of the package, from design and preparation up to reception. The organisational, human and material resources necessary for implementation of these requirements must be adequate.
The use of appropriate procedures and tools, such as to minimise the risk of human error, and the utilisation of more ergonomic documentation (transport document, approval certificate, procedures, etc.) are all practices that need to be developed.
The monitoring of transport subcontractors needs to be tightened up, so that the licensee can ensure that the operations they perform, or the goods or services they provide (packaging for example), strictly comply with the defined requirements.
The various inspections at the manufacturers, owners and consignors of "packages not subject to ASN approval" show that the demonstration of package conformity with the regulations is often unavailable or incomplete. Proof of the conformity of these packages with the regulations therefore needs to be improved.

In the field of small-scale nuclear activities, ASN identifies a lack of familiarity with the regulations applicable to transport operations

During their inspections, the inspectors observed that many consignors were unable to provide them with proof of the regulatory conformity of the shipments, in particular in the medical field and the production of low level radioactive waste (research laboratory effluents, certain waste produced by industries using radioactive markers, etc.).

 Carrier radiation protection needs to be improved

There is insufficient “radiation protection culture” among the transporters, more specifically the transporters of medical packages and certain air and sea carriers, who are little used to handling packages containing radioactive material. The rarity of vehicle contamination checks, the inadequacy (or indeed total absence) of “radiological protection programmes” (documents required by the regulations which stipulate provisions to reduce human exposure), the failure to wear dosimeters in airports, and insufficient tie-down of packages are deviations frequently observed by the inspectors during their controls.

Generally speaking, ASN observes that in all fields, and although it is improving, the sharing of information and experience feedback between all transport players is still insufficient and requires renewed efforts. This must not simply be limited to significant events of which ASN is notified, but must also take account of the “early warning signs” .

Finally, preparedness for emergency situations, by means of “local” exercises, is a practice that should be encouraged, given the difficulties involved in organising national level emergency exercises.

This experience feedback was analysed by ASN and its report is available for consultation by the public on asn.fr. This report lists areas for improvement designed to tighten up safety and radiation protection in the transport of radioactive material, on the basis of which ASN drew up an action plan, which will be developed during the course of 2013 and 2014.
Given the international nature of transport operations, the areas for improvement identified, as well as the action plan implemented by ASN, will be published and shared internationally with foreign licensees and regulators. This work will notably be presented in August 2013 at an international symposium on the transport of radioactive material (PATRAM) to be held in the United States.

[1] This includes preparation of the packages, verification of the packaging (including manufacture and maintenance), the performance ot tightness tests, the drafting of the transport documents, the shipping of the packages, examination of the approval applications, or preparedness for emergency stuations specific to the transport of radioactive substances.

[2] In particularfor the type B4 packages, packages containing fissile materials, or those containing UF6.

[3] An early warning sign is an anomaly or series of anomalies, of the same type and/or recurring, which are in themselves relatively minor but which, if analysed early enough, can teach certain lessons and identify actions liable to prevent events with more severe consequences.