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3. REINFORCING THE EFFICIENCY
OF ASN’S MEANS OF REGULATION
The licensee is required to provide ASN with the
information it needs tomeet its regulatory responsibilities.
The volume and quality of this information should
enable ASN to analyse the technical demonstrations
presented by the licensee and target the inspections.
It should also allow identification and monitoring of
the milestones in the operation of a nuclear activity.
ASN’s regulatory action takes the form of reviews of files,
pre-commissioning visits, inspections, and consultation
withprofessional organisations (trade unions, professional
orders, learned societies, etc.).
3.1 Assessment of the files
submitted by the licensee
The purpose of the files supplied by the licensee is to
demonstrate compliance with the objectives set by the
general technical regulations, as well as those that it has
set for itself. ASN is required to check the completeness
of the data and the quality of the demonstration.
The reviewof these filesmay leadASNto accept or to reject
the licensee’s proposals, to ask for additional informationor
studies or to ask for work to be done to bring the relevant
items into conformity.
3.1.1 Analysing the information supplied
by Basic Nuclear Installation (BNI) licensees
Reviewing the supporting documents produced by the
licensees and the technical meetings organisedwith them
are one of the forms of control carried out by ASN.
Whenever it deems necessary, ASN seeks the advice of
technical support organisations, primarily IRSN. The safety
reviewimplies cooperationbynumerous specialists, aswell
as efficient coordination, in order to identify the essential
points relating to safety and radiation protection.
IRSN assessment relies on research and development
programmes and studies focused on risk prevention and
on improving our knowledge of accidents. It is also based
on in-depth technical discussionswith the licensee teams
responsible for designing and operating the plants. For
the more important issues, ASN requests the opinion of
the competent AdvisoryCommittee of Experts (GPE). For
othermatters, IRSNexamines the safety analyses and gives
its opiniondirectly toASN. ASNprocedures for requesting
the opinionof a technical support organisation and, where
required, of an Advisory Committee, are described in
point 2.5.2 of chapter 2.
At the design and construction stage, ASN – aided by
its technical support organisation – examines the safety
analysis reports describing and justifying basic design
data, equipment design calculations, utilisation rules
and test procedures, and quality organisation provisions
made by the prime contractor and its suppliers. ASN also
checks the construction and manufacture of structures
and equipment, in particular PWRMain Primary Systems
(MPS) andMain Secondary Systems (MSS). In accordance
with the same principles, it checks the packages intended
for the transport of radioactive substances.
Once the nuclear facility has been commissioned,
following ASN authorisation, all changes to the facility
or its operation made by the licensee that could affect
security, public health and safety, or the protection
of nature and the environment, are notified to ASN.
Moreover, the licensee must perform periodic safety
reviews to update the assessment of the facility, taking into
account any changes in techniques and regulations, and
experience feedback. The conclusions of these reviews are
submitted by the licensee to ASN, which can issue new
prescriptions in order to tighten the safety requirements
(see chapter 12 point 2.9.4).
Other data submitted by BNI licensees
The licensee submits routine activity reports and summary
reports on water intake, liquid and gaseous discharges
and the waste produced.
Similarly, there is a considerable volume of informationon
specific topics suchas fireprotection, PWR fuelmanagement
strategies, relations with contractors, and so on.
ASN reinforces the graduated approach
for regulation of industrial small-scale
nuclear activities
In 2015, ASN re-assessed its inspection priorities for industrial
small-scale nuclear activities, following a detailed analysis of
the characteristics of these activities. ASN thus modified the
list of activities with potentially high risks, for example adding
veterinary activities other than conventional radiology or the use
of electrical generators of neutrons. It also identified activities
for which inspections are not necessary if there is nothing to
suggest deterioration of radiation protection in a given facility.
ASN also experimented oversight methods in addition to
inspection, among veterinarians in certain
départements
. This
for example consisted in analysing documents (answers to the
auto-evaluation questionnaire or substantiating documentation)
sent by the veterinarians when requested by ASN.
TO BE NOTED
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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