An initial inspection campaign on non-approved packages was carried out in 2005 and mainly concerned type IP-2 packages and type A packages. This inspection showed that the conformity of non-approved packages is generally poor. The inspectors in particular identified the following deviations:
- regulation references are often incomplete or obsolete;
- the allowable contents of the packagings are generally not specified;
- the definition of the packagings (materials, weight, dimension, drawings) is not stringent enough;
- the ability to withstand the routine transport conditions is not proven;
- the penalising nature of the drop tests included in the tests is not proven;
- the radiological protection and containment integrity demonstration is incomplete;
- correct performance of the package between -40°C and +70°C is not proven;
- the ability of the containment envelope to retain the radioactive contents in the event of an ambient pressure drop to 60 kPa is not proven.

Among the observations or findings formulated further to the inspections, the most frequent concern quality assurance, documentation, the responsibilities of the various parties involved, or compliance with procedures and established practice as indicated in the approval certificates, safety files or, more generally, regulatory texts.

As regards quality assurance, the observations most frequently encountered concern the following:
- organization;
- quality plan, procedures, established practice;
- traceability of checking operations;
- handling of deviations;
- supplier audits.

In order to reinforce the effectiveness of its actions in this field, the ASN sent the licensees a radioactive materials transport quality assurance guide.

With regard to the other fields, the observations mainly concern:
- the training programme for all those involved in transport operations;
- the duties of the security adviser;
- the annual report from the security adviser;
- lack of inspection;
- procedures for declaring events and incidents.

The observations made during the inspections are the subject of follow-up letters published on the www.asn.gouv.fr website. The ASN asks the licensees to forward the information specified in these follow-up letters, generally within two months. Progress has been observed in the companies already inspected, although certain licensees do need to improve further.

Within the framework of its special assignment, the 5th sub-directorate of the DGSNR carried out a visit to suppliers chosen by the Framatome company to manufacture the FCC containers designed to transport new fuel for power reactors. The purpose of this visit was to review the extent to which the requests and observations made during the previous inspection in 2003 had been taken into account on the manufacturing stations (straightening and resin pouring), and to check the conformity of the packages manufactured in 2005 with the manufacturing reference framework.


5 INCIDENTS AND ACCIDENTS

The guide associated with the letter of 24 October 2005, sent out by the ASN to all consignors and transporters, redefines the incident and accident declaration criteria initially sent out in the circular of 7 May 1999 (see chapter 4, point 1.2.2). It also reuses the incident report model proposed in the ADR and RID orders.

All transport deviations are thus to be declared to the ASN. Apart from this declaration, a detailed incident report must be sent to the ASN within two months. Events concerning regulatory nonconformities but which do not impair the safety function are not concerned by this report. In the case of contamination, an analysis report is to be sent to the ASN within two months.

The main events that occurred this year are detailed below according to category. These events may be of several types:
- nonconformity with the requirements of the orders specific to each mode and of the package model approval certificates;
- package handling event;
- incident or accident during actual transport, particularly a stowage fault.

The trend in the number of incidents/accidents reported during the last nine years is illustrated below: