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andWorkingConditions (CIESCT), aswell as the regular
discussions with the social partners.
3.2.2 Inspection objectives and principles
The inspectioncarriedout byASNis basedon the following
principles:
•
The inspectionaims todetect anydeviations indicativeof a
possibledeterioration in facility safetyor theprotectionof
individuals or the environment and anynon-compliance
with the legislative and regulatory requirements the
licensee is required to apply.
•
The inspection is proportionate to the level of risk
presented by the facility or activity.
•
The inspection is neither systematic nor exhaustive,
is based on sampling and focuses on subjects with the
greatest potential consequences.
3.2.3 Inspection resources implemented
To ensure greater efficiency, ASN’s action is organised
on the following basis:
•
inspections, at a predetermined frequency, of the nuclear
activities and topics of particularhealthandenvironmental
significance;
•
inspections on a representative sample of other nuclear
activities;
•
systematictechnicalinspectionsofallfacilitiesbyapproved
organisations.
Activities of more limited significance or with particularly
high volume are inspected by the approved organisations,
but can also be the subject of targeted inspections by ASN.
The inspections may be unannounced or notified to the
licensee a few weeks before the visit. They take place
mainly on the site or during the course of the relevant
activities (work, transport operation). They may also
concern the head office departments or design and
engineering departments at the major licensees, the
workshops or engineering offices of the subcontractors,
the construction sites, plants or workshops manufacturing
the various safety-related components.
ASN uses various types of inspections:
•
standard inspections;
•
in-depth inspections, which take place over several days,
concern a number of topics and involve about ten or
so inspectors. Their purpose is to carry out detailed
examinations and they are overseenby senior inspectors;
•
inspections with sampling and measurements which
are designed to check discharges by means of samples
that are independent of those taken by the licensee;
•
event-basedinspectionscarriedoutfurthertoaparticularly
significant event;
•
worksite inspections, ensuring a significant ASNpresence
on the sites on the occasionof reactor outages or particular
work, especially in the constructionor decommissioning
phases;
•
inspection campaigns, grouping inspections performed
on a large numbers of similar installations, following a
predetermined template;
•
reinforced inspections, which consist in conducting an
in-depth examination of a targeted topic with a larger
team of inspectors than for a routine inspection.
Labour inspectorate duties lead to various types of
interventions
2
, focusing in particular on:
•
checking application of the Labour Code by EDF and
outside contractors in theNPPs (verification operations
that include inspections);
•
participation inmeetings of theCHSCT,CIESCTand inter-
firmHealth, Safety andWorkingConditionsCommittee
(CISSCT) (EPR construction site);
•
performance of inquiries further to requests, complaints
or information, after which the inspectors can issue
resolutions.
ASN sends the licensee an inspection follow-up letter
officially documenting:
•
deviations between the situation observed during the
inspection and the regulations or documents produced
by the licensee pursuant to the regulations.
•
anomalies or aspectswarranting additional justifications.
Some inspections are carried out with the support of
an IRSN representative specialised in the facility visited
or the topic of the inspection.
ASN inspectors
To meet its objectives, ASN has inspectors designated
and accredited by the ASN Chairman, in accordance
with the conditions defined by Decree 2007-831 of
11th May 2007, subject to them having acquired the
requisite legal and technical skills through professional
experience, mentoring or training courses.
The inspectors take an oath and are bound to professional
secrecy. They exercise their inspection activity under
the authority of the ASN Director-General and benefit
from regularly updated practical aids (inspection guides,
decision aids) to assist them in their inspections.
As part of its continuous improvement policy, ASN
encourages the exchange and integration of best practices
used by other inspection organisations:
•
by organising international exchanges of inspectors
between Safety Authorities, either for the duration of
one inspection or for longer periods that could extend
to a secondment of up to three years. Thus, after having
observed its advantages, ASNhas adopted the concept of
in-depth inspections described earlier. However, it did
not opt for the system involving a resident inspector on
a nuclear site, as ASNconsiders that its inspectorsmust
work within a structure large enough to allow sharing
2. The intervention is the representative unit of activity normally
used by the labour inspectorate.
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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