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2.2.1 Operations subject to a licensee internal
authorisation procedure
ASNconsiders that the operations taking place in the BNIs
with the highest nuclear safety and radiation protection
implicationsmust require its prior authorisation.However,
it considers that operations for which the nuclear safety
and radiation protection implications are limited must
remain the responsibility of the licensee. For intermediate
operations presenting potential consequences in terms of
safety and radiationprotection that are significant but donot
compromise the safety scenarios used inBNI operation or
decommissioning, ASNallows the licensee to assumedirect
responsibility for them, provided that it sets up a systemof
enhanced, systematic internal checks, offering sufficient
guarantees of quality, independence and transparency. The
decision on whether or not to carry out the operations
must be the subject of a formal authorisation issuedby the
licensee’s duly qualified staff. This organisation is called
the “internal authorisations system”. It is presented to the
Local InformationCommittee (CLI). The systemof internal
authorisations is governedby theDecree of 2nd November
2007 and the resolution of 11th July 2008.
An internal authorisations systemmust thus be approved
beforehand by an ASN resolution defining:
•
the nature of the operations which can be covered by
an internal authorisation;
•
the process used to approve the operations, more
specificallywith anopinion issuedprior to any operation
by a bodywithin the company that is independent from
the people directly in charge of operation;
•
identificationof thepersons qualified to issue the internal
authorisations;
•
the procedures for periodically informing ASN of the
operations planned or completed.
ASN checks the proper application of the internal
authorisationssystemsbymeansofinspections,examination
of the periodic reports transmitted by the licensees and
counter-analysisofthefiles.Itmaytemporarilyordefinitively
suspend an internal authorisations systemat anymoment
if it considers that implementation is not satisfactory.
2.2.2 Internal monitoring of radiation protection
by the users of ionising radiation sources
The aim of internal monitoring of radiation protection
is to ensure regular assessment of the radiological safety
of the activities using sources of ionising radiation.
This monitoring is performed under the responsibility
of the licensees. It may be carried out by the Person
Competent in Radiation protection (PCR), appointed
andmandated by the employer, or be entrusted to IRSN
or to organisations approved by ASN. It does not replace
either the periodic checks required by the regulations,
or the inspections conducted by ASN. It for example
concerns the performance of the protection systems,
monitoring of the ambient atmosphere in regulated areas,
or checks onmedical appliances before they enter service
or after modification.
2.2.3 Inspection of radioactive substances transport
For the transport of radioactive substances, the consignor
is responsible for demonstrating that the packagemodel
used ensures compliance with the safety requirements
set by the regulations, as well as being suitable for the
contents to be transported. The following are subject to
ASN approval: packagemodels with the highest potential
safety implications, in particular those intended for the
transport of very high-level radioactive substances or those
for which the content is liable to create a criticality risk
(see chapter 11). These packages, and those which are
not subject to approval, are regularly inspected by ASN in
order to verify the measures adopted by the consignors.
2.3 ASN approval of organisations
and laboratories
Article L. 592-21 of the Environment Code states that ASN
must issue the necessary approvals to the organisations
taking part in the inspections and in ensuring the nuclear
safety and radiation protection watch. Depending on
the health or safety implications of a nuclear activity
or a facility category, ASN may rely on the results of
checks carried out by independent organisations and
laboratories it has approved and which it monitors via
second level checks.
ASN thus approves organisations so that they canperform
the technical inspections required by the regulations in
the fields within its scope of competence:
•
radiation protection checks;
•
measurement of radon activity concentration inpremises
open to the public;
•
assessment of nuclear pressure equipment conformity
and inspection of equipment in service.
The checks carried out by these organisations contribute
to ASN’s overview of all nuclear activities.
In order to approve the applicant organisations, ASN
ensures that they perform the inspections in accordance
with their technical, organisational and ethical obligations
and in compliance with the rules of professional good
practice. Compliancewith these provisions should enable
the required level of quality tobe obtained andmaintained.
ASN ensures that benefit is gained from the approval, in
particular through regular exchangeswith the organisations
it has approvedand themandatory submissionof anannual
report, in order to:
•
turn operating experience feedback to good account;
•
improve the approval process;
•
improvetheconditionsofinterventionbytheorganisations.
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CHAPTER 04:
REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION
ASN report on the state of nuclear safety and radiation protection in France in 2015