IRRS follow-up mission to France - October 2017

29 The ASN resolution 2015-DC-0521 demonstrates the graded approach where the requirements for registering high activity sources are increased, and exempt sources do not require registration. Although the national sealed source register contains details of all sealed sources, it only contains limited information on radiation generators. However, there is a requirement in the Labour Code (R.4451-38) for ASN licence holders to submit an annual inventory of all their sources, including radiation generators, to IRSN which is also available to ASN. Status of the finding in the initial mission Recommendation 7 (R7) is closed on the basis of progress made and confidence in the effective completion as the Government will issue an updated PHC in early 2018. The PHC will introduce an additional category of authorization known as “Registration” allowing a more graded approach to authorization of radiation sources and facilities. The draft decree has been approved in principle by Government, but still requires the ongoing review by the Council of State to be completed before it can be issued. Suggestion 7 (S7) is closed on the basis of progress made and confidence in the effective completion. When the updated PHC is issued in early 2018 with the additional category of authorization, ASN will progressively reissue authorizations to legal entities rather than physica l persons which is expected to be completed in a time period of 3-5 years, covering approximately 10 000 authorizations. Recommendation 8 (R8) is closed as ASN issued a new resolution 2015-DC-0521 in January 2016 which details the processes which need to be undertaken to register a sealed source in the national register. The updated PHC which will be issued in early 2018 references this ASN resolution and clearly defines the framework for registering and tracking radioactive sources, including the responsibilities of both ASN and IRSN. 5.7. AUTHORIZATION OF DECOMMISSIONING ACTIVITIES There were no findings in this area in the initial IRRS mission. 5.8. AUTHORIZATION OF TRANSPORT ACTIVITIES There were no findings in this area in the initial IRRS mission.