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even after repeated use. For approved packagings, the
ASN inspections concern the following maintenance
activities, for example:
•
the periodic inspections of the components of the
containment system (screws, bolts, welds, seals, etc.);
•
the periodic inspections of the securing and handling
components;
•
the frequency of replacement of the package components
whichmust take account of any reduction inperformance
due to wear, corrosion, aging, etc.
In 2015, ASN carried out several inspections on the
conformity of maintenance operations, in particular on
the FS 47 packagings (package model approved for the
transport of plutonium powder), TN MTR (package
model approved for the transport of research fuel) and
GMA 2500 (industrial radiography device, approved as
a package transporting a source).
4.2.3 Inspections of packages not requiring
approval
For the packages that do not require ASN approval (see
table 3), the consignor must, at the request of ASN, be
able to provide the documents proving that the package
design complies with the applicable prescriptions. More
specifically, for each package, a certificate delivered by the
manufacturer attesting full compliance with the design
specifications must be held at the disposal of ASN.
The various inspections carried out in recent years confirm
the improvements to the documents presented to ASN
and the integration of the recommendations in ASN
Guide No.7, volume 3, concerning packages which are
not subject to approval.
In 2015, ASNcompleted its updating of this guide, which
was published on 16th November. The manufacturers
were asked to submit their comments concerning this
update, whichwas opened for public consultation on the
ASNwebsite, from1st to 30th June. The guide proposes
a structure and a minimum content for the safety files
demonstrating that packages which are not subject to
approval do complywith all the applicable prescriptions,
along with the minimum content of a declaration or a
certificate of conformity of a package design with the
regulations.
ASN thus noted improvements in the content of the
certificate of conformity and the safety file drawn up
by the participants concerned, more specifically for the
industrial package models. However, the designers of
type A package models must continue to make efforts,
notably on the representative nature of the tests performed
and the associated safety case.
Furthermore, ASN still finds that some of the entities
concerned (designers,manufacturers, distributors, owners,
consignors, companies performing the regulatory drop
tests, package maintenance, etc.) display shortcomings
in the demonstration of package conformity with the
regulations. The areas for improvement remain inparticular
the following:
•
the description of the authorised contents per type
of package;
•
demonstration that there has been no loss or dispersion
of the radioactive content under normal transport
conditions;
•
compliance with the regulatory radiation protection
requirements;
•
the representativeness of the tests performed.
4.2.4 Inspections of the shipment of packages
of radioactive substances
ASN devotes more than half of its transport inspections
to checking shipments and carriers, at both regional
and national levels.
During these inspections, the checks concern all
regulatory requirements binding on each of the transport
stakeholders, that is compliance with the requirements
of the approval certificate or declaration of conformity,
training of the personnel involved, implementation of
a quality assurance programme, satisfactory stowage of
packages, dose rate and contamination measurements,
documentary conformity, etc.
Among the observations or findings formulated further to
the inspections, themost frequent discrepancies concern
quality assurance and documentation, or compliance
with procedures as indicated in the approval certificates,
safety files, or the regulatory texts in general.
ASN’s inspections reveal deficiencies in the knowledge
of the regulations and responsibilities on the part of the
transport stakeholders in small-scale nuclear activities.
Knowledge of the regulations applicable to the transport
of radioactive substances seems to be substandard in the
medical sector in particular, where themeasures taken by
some hospitals or nuclear medicine units when returning
radionuclide packages after use and shipping sources for
maintenance need to be tightened.
ASN has moreover observed that an increasing number
of BNIs are using outside contractors to prepare and ship
packages of radioactive substances. ASN is particularly
attentive to the monitoring of these contractors.
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CHAPTER 11:
TRANSPORT OF RADIOACTIVE SUBSTANCES
ASN report on the state of nuclear safety and radiation protection in France in 2015