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




