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Page Background

In 2015, ASN more particularly began the review of

the notification of modification of the baseline safety

requirements applicable to all the EDF nuclear power

plants, with a view to incorporating on-site transport

operations. ASN also began its examination of the

notification submitted by Areva La Hague for the

creation of a chapter in the general operating rules

describing on-site transport operations. During this

examination, ASNwill take account of the conclusions

of the 14th January 2015 joint review by the Advisory

Committees for “Transport” (GPT) and “Plants” (GPU)

of the safety of certain on-site transport operations.

3.6 Public information in the field

of transport

Order 2012-6 of 5th January 2012 extends the public

information obligations to persons responsible for nuclear

activities. It is Article L. 125-10 of the Environment

Code that sets the threshold beyond which the person

responsible for transport must communicate the

information requested by a citizen, by reclassification

of the provisions of Decree 2011-1844 of 9th December

2011. The thresholds are defined as being those

“above

which, in application of the international conventions and

regulations governing the transport of dangerous goods, of the

Code of Transport and of the texts taken for their application,

the transport of radioactive substances is subject to the

delivery – by ASN or by a foreign Authority competent in

the field of radioactive substance transport - of an approval

of the transport package design or a shipment approval,

including under special arrangement”.

Any citizen can

therefore now ask the persons in charge of transport

for information on the risks presented by the transport

operations referred to in the Decree.

A person to whom a nuclear licensee or transport

supervisor has refused to communicate information, can

refer the matter to the CADA (Administrative Documents

Access Commission), for its opinion. The matter must be

referred to the CADA prior to any legal action. Disputes

relative to communication refusals can then be brought

before the administrative jurisdictions, even if they are

between two private individuals.

In 2014, ASN also drew up an information sheet on the

transport of radioactive substances, intended for the

general public and available on

www.asn.fr

(information

sheet No. 8). This sheet answers questions frequently

asked by the public, notably concerning the risks inherent

in these transport operations, the organisation of the

response by the public authorities to an emergency

or the routes followed for these transport operations.

4. ASN ACTION IN THE

TRANSPORT OF RADIOACTIVE

SUBSTANCES

4.1 Delivery of approval certificates

and shipment approvals

The type B and C packages, as well as the packages

containing fissile materials and those containing more

than 0.1 kg of uranium hexafluoride (UF

6

) must be

covered by an ASN transport approval. The designers of

the packagemodels who request approval fromASNmust

support their application with a safety file demonstrating

the compliance of their package model with all the

regulatory prescriptions. Before deciding whether or

not to issue approval, ASN examines this file, drawing

on the expertise of the Institute for Radiation Protection

and Nuclear Safety (IRSN), in order to ensure that the

safety cases are pertinent and sufficient. If necessary, the

approval is issuedwith requests for additional information

in order to improve the safety cases.

In some cases, IRSN’s appraisal is supplemented by

a meeting of the Advisory Committee for Transport

(GPT). The opinions of the Advisory Committees are

always published on

www.asn.fr

.

The GPT, for example,

met twice in 2011 to examine a new package concept,

DE 25, developed by CEA for the transport of waste.

Update of volume 1 of ASN Guide No. 7,

known as the

“Applicant’s guide”

In May 2009, ASN published an applicant’s guide for requests

for approval of shipments of package models or radioactive

substances for civil purposes transported on the public

highway. This guide contains recommendations concerning

the content and format of the application files, to make them

easier to examine. It in particular presents the structure of

the safety file to be submitted by the applicant in support of

its request, the provisions in the event of a modification to an

existing package model, the ASN’s positions regarding the

safety cases, experience feedback from previous technical

examinations as well as points concerning the right of access

to information and concerning penalties This guide was

translated into English in 2010 for distribution to some of the

European Union authorities with competence for transport

issues. In order to take account of the latest changes to the

regulations and lessons learned, ASN initiated an update of

this guide. The project was opened to public consultation from

13th October to 13th November 2015 on the ASN website.

The comments received are currently being analysed and will

be taken into consideration in updating the guide.

The updated guide will be published in 2016.

TO BE NOTED

356

CHAPTER 11:

TRANSPORT OF RADIOACTIVE SUBSTANCES

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