ASN Report 2015

mark and label the packages. It must also provide the

carrierwith all the requireddocuments and information.

•

The actual transport is organised by the carriage

commission agent. The carriage commission agent is

responsible for obtaining all the necessary authorisations

on behalf of the consignor, and for sending the various

notices. He also selects themeans of transport, the carrier

and the itinerary, in compliance with the regulatory

requirements.

•

The carrier, usually a specialised company with the

necessary authorisations, appropriate vehicles and

duly trained drivers, must verify the completeness and

availability of the informationprovided by the consignor,

and the good overall condition and correct labelling of

the vehicles and packages. It must also verify that the

materials to be transported are authorised for transport.

•

The consignee is under the obligation not to postpone

acceptance of the goods, without vital reason and,

after unloading, to verify that the requirements of the

corresponding ADR

have been satisfied.

•

Finally, the container owner must set up amaintenance

system in conformity with that described in the safety

documents and the authorisation certificate.

The transport of some radioactive substances (including

packages containing fissile material) is subject to prior

notification to ASN and theMinistry of the Interior by the

consignor. This notification stipulates thematerials carried,

the packagings used, the transport conditions and the

details of the persons involved. In2015, 1,343notifications

were sent to ASN.

3.4 The regulation of radiation

protection for transports

of radioactive substances

The radiation protection of workers and the public around

shipments of radioactive substances must be a constant

concern.

The regulations applicable to the transport of radioactive

substancesmake provision for the radiation protection of

the public and workers: the public and non-specialised

workers must not be exposed to a dose exceeding

1 millisievert (mSv) per year. However, this limit is not

intended to be an authorisation to expose the public to

up to 1mSv. Moreover, the justification and optimisation

principles applicable to all nuclear activities also apply to

the transport of radioactive substances (see chapter 2).

Radiation protection is the subject of specific requirements

in the regulations applicable to the transport of radioactive

substances. Thus, for transport by road, the regulations

stipulate that the radiation at the surface of the package

2. European agreement on the international carriage

of dangerous goods by road.

must not exceed 2 mSv/h (this limit can be increased

to 10 mSv/h in the case of exclusive use, where actions

near the package are limited). The radiation should

not exceed 2 mSv/h in contact with the vehicle and

should be less than 0.1 mSv/h at a distance of 2 m

from the vehicle.

Assuming that a transport vehicle reaches the limit of

0.1 mSv/h at 2 metres, a person would have to spend

10 hours without interruption at a distance of 2 metres

from the vehicle for the dose received to reach the annual

public exposure limit.

These limits are supplemented by requirements relative to

the organisation of radiation protectionwithin companies.

The transport stakeholders must establish a radiological

protection programme that integrates themeasures taken

to optimise human exposure. It may be necessary to

implement dose monitoring of the exposed person

according to the foreseeable dose evaluation for certain

operations (loading, stowing, unloading, etc.). Training

is also one of the pillars of the radiological protection

programmes. This training is also provided for in the

regulations. All the stakeholders in the transport chain

must thus be trained andmade aware of the nature of the

risks associated with radiation so that they can protect

themselves and others against these risks.

3.5 Regulation of the safety

of transport operations within

the perimeter of nuclear facilities

Dangerous goods transport operations can take place on

the private roads of nuclear sites, in what are referred to

as “on-site transport operations”. Such operations are

not subject to the regulations governing the transport of

dangerous goods, which only apply on public highways.

Since 1st July 2013, these transport operations have

been subject to the requirements of the “BNI Order”,

published on 7th February 2012 (see chapter 3). This

Order requires that on-site transport operations be

incorporated into the safety baseline requirements for

BNIs. The on-site transport of dangerous goods presents

the same risks and inconveniences as the transport of

dangerous goods on the public highway. The safety of

transport must be overseen with the same rigour as

for any other risk or inconvenience present within the

perimeter of the BNI.

In 2015, ASN continued to receive notification from

most BNIs that they were modifying their general

operating rules in order to incorporate on-site transport

operations into their baseline safety requirements. These

notifications were systematically examined by ASN.

However, ASN notes that not all the BNIs have as yet

incorporated on-site transport operations into their

general operating rules.

355

CHAPTER 11:

TRANSPORT OF RADIOACTIVE SUBSTANCES

ASN report on the state of nuclear safety and radiation protection in France in 2015