IRRS follow-up mission to France - October 2017

56 Decree that includes regulatory security provisions and a draft ministerial Order with detailed provisions for the security of radioactive sources. These are expected to be published in 2018 and be enforced in 2019 (with transitional arrangements). Therefore, in addition to contributing to the drafting of the regulations and performing visits at sites to exchange information with operators, ASN has initiated preparation for this new responsibility by creating a new security unit with three engineers within the transport and source department, initiating internal training on security and developing internal guidance for the assessment of future applications and future inspection of facilities. The IRRS team supported the approach that ASN has initiated. The team noted that they faced a similar situation after the events of 9/11. After those events the security of sealed sources became a more significant issue for many governments. One team member noted that their agency addressed this situation in a phased approach and established a grace period before taking any enforcement actions. This provided licensees an opportunity to better meet the new requirements and for the regulator to ensure that these requirements are appropriate. The IRRS team recommended applying a graded approach, which is consistent with ASN’s priority to focus on the security of high activity sealed sources. The team also noted that ASN should pay attention to those disused sources. The team recommended ASN to continue benchmarking with other countries that have already have established and implemented requirements and processes for authorizing and inspecting the security of radioactive sources. In addition, France should focus on the transitional arrangements related to the new security regulations to enable source users to plan, finance and implement the new security measures. The team recommended that ASN develop a single organizational culture that embeds both security and safety. The team noted that experience had shown that maintaining separate security and safety cultures creates confusion for licensee and regulatory bodies. The team also suggested that, based on their experience, ASN should combine the authorization and inspection process for safety and security, after providing the inspectors with appropriate training and guidance. Several IRRS team members noted that doing so has been successful in their countries. ASN noted a concern with the possible lack of transparency of not disclosing the results of security inspections to the public. In that regard, the IRRS team members discussed their experiences in sharing some general information about security but keeping the more detailed or confidential information which could compromise the security of a facility out of the public domain. Finally, the IRRS team recommended that ASN coordinate early with the all involved interested parties when implementing any new requirements for the security of radioactive sources.