IRRS follow-up mission to France - October 2017

53 activities. In addition, there has been substantial training of many of the involved staff to assure they are well versed in source security techniques and are prepared for implementing the requirements that will be contained in the decree. Notwithstanding these notable efforts, much work remains to establish a viable regulatory and inspection program in this area of new responsibility. Status of the finding in the initial mission Recommendation 16 (R16) is closed on the basis of progress made and confidence in the effective completion. The first part of the recommendation is essentially not applicable due to the government’s decision to not allocate security responsibility for BNIs and ICPEs to ASN. With respect to the second part of the recommendation, the progress made to date, in addition to the decree that is soon to be finalized, provide adequate confidence that ASN’s role in security of radioactive sources, mainly in the industrial, research and medical fields, will be appropriately implemented. 12.2. REGULATORY OVERSIGHT ACTIVITY 2014 MISSION RECOMMENDATIONS, SUGGESTIONS S27 Suggestion: The Regulatory Body should consider including, in its inspection and assessment programme for BNI and ICPE facilities, activities to verify that security measures in place do not impair safety, especially in case of an accident. S28 Suggestion: The Regulatory Body should consider incorporating to its training program topics related to safety/security interface of facilities and activities. Changes since the initial IRRS mission Suggestion 27: Control of security measures in BNIs is the responsibility of the Department for Nuclear Security (DSN) within the Ministry of Ecological and Solidary Transition. Regarding review and assessment activities, the DSN communicates to ASN information about safety impacts that may result from malicious acts, including accident situations, and the study of their consequences. This information is to be documented in a separate part of the safety report, as required by an ASN resolution of 12 November 2015 (article 2.4). Regarding inspections, in May 2016 and February 2017, a team of ASN inspectors (including an inspector specialised in radioactive substance transportation issues) conducted inspections at the headquarters of carriers of radioactive substances and nuclear materials to evaluate their emergency preparedness and response organizations. These inspections were carried out concomitantly with inspections of the Department for Nuclear Security. Both authorities agreed to participate in one common inspection per year, beginning with the field of radioactive substance transportation. However, conducting such inspections at BNIs and ICPEs is yet to take place, though such an approach is being discussed. Article 6 of a draft convention to be co-signed by HFDS and ASN (as discussed in Suggestion 30) discusses the agreement to conduct one concomitant inspection on an annual basis. Additionally, Article 7 of the same draft document discusses expectations that ASN and HFDS participate in exercises organized by the other authority, including national security protection and evaluation exercises (EPEES). DSN representatives indicated that there is a high reliance placed on operators to identify safety/security interface issues. Notwithstanding, the cooperation between ASN and DSN requires