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international protocol for the detection of radioactivity
in goods at borders.
At present the only information at the disposal of France
is that received from its neighbouring countries. Belgium
thus informs ASN whenever its portals are triggered by
shipments coming from or intended for France. In such
cases, additional investigations are carried out to identify
the companies concerned (traders, manufacturers and
importers) and/or the exporting country, and todetermine
the fate of the goods.
In some cases it is necessary to sort thepackage(s) to identify
and segregate the incriminated products and have them
disposed of in authorised facilities. If they are returned
to the consignor, the transport of the goods must comply
with the regulations applicable to the carriage of dangerous
goods. These operations (transport, sorting, packaging,
disposal, etc.) involve significant cost which is generally
borne by the French manufacturer.
ASN considers that Francemust rapidly adopt a national
strategy for radioactivitydetectionon its territory, andmake
the corresponding investments in equipment and training.
Given the possible economic side-effects of these incidents,
ASN recommends that all firms involved in commercial
trading of metal-based products with countries outside
the EuropeanUnion, conduct checks on the radioactivity
level of the imported products.
4.6 Implementation of monitoring
of radioactive source protection
against malicious acts
Evenifthesafetyandradiationprotectionmeasuresasaresult
of the regulations do guarantee a certain level of protection
against the riskofmalicious acts, they cannot be considered
sufficient for all radioactive sources. Reinforced oversight
of protection against malicious acts using hazardous
sealed radioactive sources was thus strongly encouraged
by International Atomic Energy Agency (IAEA) which
published a code of conduct for the safety and security of
radioactive sources (approved by the Board of Governors
on8thSeptember 2003) and guidelines for the import and
export of radioactive sources (published in2005). TheG8
supported this approach, notably at the Evian summit in
June 2003, andFrance sent IAEA confirmation that it was
working towards application of the guidelines laid out in
the code of conduct (undertakings by the Governor for
France of 7th January 2004 and 19th December 2012).
The general aim of the Code is to obtain a high level of
safety and security for those radioactive sources which
can constitute a significant risk for individuals, society
and the environment.
Monitoring sources for radiation protection and safety
purposes andmonitoring them to combat malicious acts
have many aspects in common andmutually consistent
objectives. This is why ASN’s counterparts abroad are
usually responsible for monitoring both domains. ASN
has the necessary hands-on knowledge of the sources
concerned and of the entities responsible for nuclear
activities, which are regularly inspected by its regional
divisions.
The Government has decided to entrust ASN with the
monitoring of the measures – incumbent on the entities
responsible for nuclear activities – to track and protect
sources against malicious acts. It could in particular
consist of limiting source access to duly authorised
persons only, of placing one or more physical protective
barriers between the source and unauthorised persons,
of making intruder detection systems mandatory, or of
ensuring source tracking. The legislative process started in
2008 by the Government with the assistance of ASNwas
integrated into Act No. 2015-992 of 17th August 2015
(Energy Transition for Green Growth Act – TECV) and
the Ordinance of 10th February 2016 which divides
up the competences for oversight in the various
facilities by including protection against malicious
acts among the concerns that the services examining
licence applications must take into account. Without
waiting for these provisions to come into effect, ASN has
instructed all holders of high-activity sealed sources to
exercise great vigilance with regard to the conditions of
storage, transport and utilisation of these sources, and
the restriction of access to the associated information.
ASN also reminded them of the obligations that are
already applicable.
As it had announced, ASN continued its work to prepare
the implementing texts necessary for actual deployment
of the controls and reinforced its measures to inventory
the existing facilities. This identification process, which
focused on establishments holding high-activity sealed
sources, led ASN to carry out a total of 220 visits. At
present, virtually all the licensees holding high-activity
sealed sources who will be inspected by ASN for the
protection of sources against malicious acts have received
such a visit.
Furthermore, in order to obtain a harmonised view
of the country as a whole, to reinforce the training
of ASN’s radiation protection inspectors in this new
area of competence and prepare for rapid and effective
deployment of this new mission, the ASN inspectors
conducted these visits using tools produced by ASN
especially for this purpose. Additional training modules
will be developed as the work progresses and will be
incorporated into the inspectors’ initial training.
These check-out visits will more specifically make it
possible to assess the impact of the technical prescriptions
envisaged and currently being defined by a working
group coordinated by the Defence and Security High
Official at the Ministry for the Environment, in which
ASNplays an active role, more specifically by contributing
its knowledge of the facilities.
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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