ASN Report 2015

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The notification system
To achieve a balance in the sectors of activity subject
to notification or licensing, and therefore better adapt
the regulatory requirements to the radiation protection
implications, ASN introduced a notification system
for the industrial, research and veterinary sectors in
2009. This led to the publication of several approved
resolutions (see chapter 3) defining on the one hand
the scope of application of this system and on the other,
its implementation procedures.
The following are concerned:
• veterinary diagnostic radiology devices (fixed only)
meeting one of the following conditions:
-- the emission beam is directional and vertical, except
for all tomography devices;
-- the device is used for intra-oral radiography (ASN
resolution2009-DC-0146of 16th July2009, amended
by resolution 2009-DC-0162 of 20thOctober 2009,
Official Journal of 26th February 2010).
• electrical devices emitting ionising radiation, for which
the equivalent dose rate 10 cm from all accessible
surfaces in normal conditions of use and as a result
of their design, is less than 10 microsieverts per hour
(µSv/h).
Through ASN resolution 2015-DC-0531 of
10thNovember 2015, ASNwidened the scope of activities
subject to notification to all users and holders of these
devices in order to integrate unambiguously into the
notification system all the activities using devices in
these categories, that is to say putting into service,
inspection, maintenance, training, etc., insofar as these
uses do not lead to modifications in safety systems or
radiological protection shielding.
The notification form drawn up by ASN to facilitate
application of amended resolution 2009-DC-0148 of
16th July 2009 defining the detailed content of the
information to be appended to the notifications has been
designed so as to simplify its utilisation and processing.
No document has to be added to the notification form if
the devices declared meet the requirements specified in
ASN’s resolutions and are eligible for this system. ASN
reviewed this form in 2015 to incorporate the latest
regulatory changes and is continuing an ongoing on-line
notification project to further simplify the procedures.
In a completely different field, the notification system
was extended in 2012 to include companies installing,
maintaining or removing Ionisation Chamber Smoke
Detectors (ICSD) (see point 4.3). Following the
publication on 15th March 2012 of ASN resolution
2011-DC-0252 of 21st December 2011, a notification
form was produced and placed on-line on .
4.2.3 Statistics for 2015
Suppliers
In the light of the fundamental role played in the radiation
protection of future users by the suppliers of sources or
devices containing them (see points 3 and 4.2.1), ASN
exercises particularly strict control in this field. During the
course of 2015, 94 license or license renewal applications
were examinedbyASN, and53 inspectionswere carriedout.
Users
Case of radioactive sources
In 2015, ASN reviewed and notified 218 new licenses,
1,017 license renewals or updates and 396 license
cancellations. Graph 5 presents the licenses issued or
cancelled in2015and trends in this area for the last fiveyears.
Once the license is obtained, the licensee can procure
sources. To do this, it collects supply request forms from
IRSN, enabling the institute to verify – as part of its duty
to keep the inventory of ionising radiation sources up to
date – that the orders are in conformity with the licenses
of both the user and the supplier. If the order is correct,
the movement is then recorded by IRSN, which notifies
the interested parties that delivery can take place. If there
is any difficulty, themovement is not validated and IRSN
refers the case to ASN (see box below).
Procedures for recording and tracking
radioactive sources
Articles R. 1333-47 to 49 of the Public Health Code provide
for prior recording by IRSN (French Institute of Radiation
Protection and Nuclear Safety) of movements of radioactive
sources and Article R. 1333-50 for tracking these sources.
ASN resolution 2015-DC-0521 of 8th September 2015
relative to the tracking and methods of recording radioactive
sources and products or devices containing them has defined
a clear regulatory framework governing the methods of
recording and the rules for tracking movements of radioactive
sources.
This resolution, applicable as of 1st January 2016, takes into
account the existing mode of functioning and supplements it
as follows by:
• graded source inspections according to how dangerous
the sources are;
• confirming the absence of recording for sources whose
activity is below the exemption thresholds;
• imposing deadlines between the recording of source
movements and the actual movement;
• making it an obligation for each source to be accompanied
by a “source certificate” indicating all its characteristics and
which must be transmitted to IRSN within two months after
receiving the source.
TO BE NOTED
334 CHAPTER 10: INDUSTRIAL, RESEARCH AND VETERINARY USES AND SOURCE SECURITY
ASN report on the state of nuclear safety and radiation protection in France in 2015