IRRS follow-up mission to France - October 2017

21 3. RESPONSIBILITIES AND FUNCTIONS OF THE REGULATORY BODY 3.1. ORGANIZATIONAL STRUCTURE OF THE REGULATORY BODY AND ALLOCATION OF RESOURCES 2014 MISSION RECOMMENDATIONS, SUGGESTIONS R4 Recommendation: The Government and ASN should explore new ways to ensure that the human and financial resources needed for effective regulation of nuclear and radiation safety are sustained into the future as ASN's workload increases. S3 Suggestion: ASN should consider reviewing its system for delegating regulatory powers to ensure (1) that the system contains sufficient measures to provide assurance that these powers are being exercised in accordance with Commission expectations and (2) that the balance between the decision-making responsibilit ies of the HQ and regions is optimal. Changes since the initial IRRS mission Recommendation 4: The financial and human resources of ASN and IRSN are established by the State budget. For the 2015-2017 Budget Bill, ASN considered that 125 positions would need to be created by end of 2017. At the end of 2014, 30 additional positions (10 per year) were granted which only partly reflects the anticipated increase in workload. The initial IRRS mission 2014 noted that, if not carefully managed, the shortfall in resources could have a negative impact on the effectiveness of ASN’s future regulation. In 2015, ASN, at the request of the government, performed a more detailed analysis of the resource needs for 2015-2020 that was reflected in the Budget Bill for the 2017. Based on this analysis, the Government granted ASN and IRSN additional resources for 2017 (20 positions at the ASN). However, this still did not fully meet the request. Therefore, ASN and IRSN are continuing the budget discussions with the government for 2018. For the next budget cycle, ASN issued a new opinion concerning the budget for the regulation of nuclear safety and radiation protection in France. In this opinion, ASN requests the recruitment of an additional 15 FTE for 2018-2020 (5 per year). At the same time, ASN reiterated its request for reform of the financing of its budget to be based partly on the state budget and partly on an annual fee from the licensees. In addition, ASN has continued to improve its organization to be more efficient by making use of a more graded approach. For example, to better utilize its resources, ASN has categorised nuclear installations into three safety categories based on several criteria (thermal power, activity…) and is finalising regulatory resolutions specifying the scope of declaration, registration and authorisation regimes in the area of use of radiation sources (see also R7), but also another resolution to clarify the approval system of BNI modifications. Suggestion 3: ASN has revised its system for delegating regulatory signing authority. In 2016- 2017 they updated the roles and responsibilities of each hierarchical level and the delegation of signing authority was adjusted, in particular according to the categorisation of BNIs. In the revision of the system for BNI modifications, the regional division heads were delegated the signature authority for resolutions concerning authorisation of temporary measures during plant modifications if they do not include any additional requirements. Delegation of signing authority