In 2006, ASN 217 inspectors conducted 740 inspections of BNIs and radioactive material transports (non-BNIs) and 568 radiation protection inspections. An assessment of the level of safety resulting from ASN regulation is presented in the chapters devoted to the various nuclear stakeholders. Quite apart from its assessment of each type of licensee, ASN considers that the inspection itself contributes to advancing nuclear safety and radiation protection. In 2007, ASN intends to take legislative measures providing it with the powers to designate its inspectors and put the finishing touches to the discussions conducted with the Directorate General for Labour (DGT) for implementing the process of exchanges with the Labour Inspectorate.

Surveillance of BNI discharges

To ensure that the licensees fully assume their responsibility to monitor their discharges, ASN carries out unannounced inspections with sampling and sends the samples representative of the effluent discharged for analysis by an organisation it has designated. In 2006, ASN had IRSN carry out 17 sampling inspections. These inspections identified deviations or drift for which ASN demanded explanations from the licensees. ASN considers that this type of check helps instil confidence in the results of the regulation effluent measurements taken by the licensees. Under application of the polluter-pays principle, ASN aims in 2007 to have the financial burden borne by the licensees.

Regulation of approved organisations

ASN supervises the organisations it approves for nuclear pressure vessels, measurement of environmental and drinking water radioactivity, regulation of exposure to radon in premises open to the public and technical radiation protection checks.

ASN now has sole responsibility for approval and in 2007 aims to harmonise its review and inspection practices, in particular by basing its reference system on standards and making widespread use of the practice of audits and spot-checks.

Penalties

ASN inspections and checks are all official and all lead to a formal outcome issued by it. Depending on the gravity of the nonconformity, this outcome may be either a verbal observation on the part of the inspector, a letter which may include requests, a decision for partial or total revocation of a license, or an administrative or penal sanction defined by the nuclear transparency and safety law. In this way the ASN is following the recommendations of the IRRS mission report and in 2007 aims to formalise the procedure for scaled application of these penalties.

ASN regulation of nuclear activities is designed to check that all users of ionising radiation fully assume their responsibilities. ASN ensures that its actions are guided by the notion of proportionality, so that its level of inspection is commensurate with the health and environmental protection issues. Regulation involves review and investigation of the files and data supplied by the licensee to justify its actions, along with surveillance of installations, activities and the environment, follow-up of incidents (significant events) and inspections. As and when necessary, infringements can be penalised. In the case of an activity involving too many parties for direct regulation by ASN, this can be carried out via approved organisations and may be accompanied by an awareness-raising programme including work to promote the production of guides.

Awareness-raising

ASN vision of a world protected against risks for which the citizens as a whole take collective responsibility, implies the involvement of each and every one. ASN aims to ensure the spread of the radiation protection and safety culture so that everyone becomes a participant in his or her own supervision. There are two key steps in this goal, education in the safety culture and implementation of tools enabling each individual or organisation to identify their own faults and more generally assess the progress made in achieving the safety culture.

ASN will continue to encourage the production of national or international guides by professionals to promote conformity with regulatory requirements. Aware as it now is of the importance of human factors in the origin of the incidents that have occurred in France, ASN considers that thought needs to be given to the place devoted to safety culture in the training given to students as part of the nuclear safety curriculum and in medical and industrial activities using ionising radiation. It will initiate discussions with the main stakeholders in the sector in 2007.

Analysis of significant events

The detection and analysis of anomalies by the licensees is a fundamental tool contributing to the safety of nuclear installations. It is also a way of assessing the progress of the safety culture, as it expresses the ability of individuals and organisations to point out their own failings. ASN is satisfied with how the nuclear licensees have adopted this principle. It has reservations however concerning the nuclear licensees' subcontractors, where the penalty culture frequently takes precedence over the safety culture. Based on the experience acquired in the field of BNIs and radioactive material transports with regard to declaration of significant events, ASN will on 1 March 2007 be implementing an experimental system of significant event declarations for small-scale nuclear activities. At the end of the year it will analyse the results and draw conclusions before adapting this system and putting it into general use. The system is designed to protect workers, patients and the public by learning the lessons from past technical and organisational malfunctions.

Inspection

To ensure that the licensee abides by the requirements binding upon it, ASN carries out on-site inspections and, if necessary, conducts visits during the license review process. Every year, ASN draws up a schedule of inspections, the purpose of which is to detect any isolated deviations or anomalies and to ensure that the licensee or the user of ionising radiation meets its responsibilities. The inspections are carried out by specifically designated ASN staff.