TRANSPORT OF RADIOACTIVE MATERIALS

Transport safety management within the AREVA group Experience feedback from certain inspections, and the analysis of significant events occurring in the AREVA group, has evidenced deficiencies in the overall system of transport safety management within the group (see box in paragraph 4|2|2). It has been observed more specifically that the regulatory responsibilities (shipment, transport, etc.), the mutual obligations in the case of internal contracting, especially with regard to packaging maintenance and the tracking of packaging design modifications, are poorly defined in the group's procedures. This situation often leads to a dilution of responsibilities (role of the designer, manufacturer, consignor, maintenance organisation). In this respect, ASN considers that the AREVA group entities must take corrective action and ensure better mutual coordination in applying a quality assurance system to transport operations as required by the regulations.

The AREVA group undertook to implement corrective actions during 2011 in response to these various ASN findings.

The AREVA group will be subject to inspections in the area of transport organisation in 2012, and subcontracted activities in particular.

The increase in safety requirements relating to on-site transport operations performed within the bounds of the BNIs

As part of the revision of the technical regulations for BNIs, ASN has planned to tighten the regulatory framework and the requirements concerning on-site transport operations performed within the bounds of the BNIs. The nuclear sites concerned must take prompt action to plan the necessary forthcoming modifications to the existing baseline safety standards. The requirements will be specified in regulatory decisions in 2012, and an ASN guide should help clarify the regulatory requirements.

Monitoring the projects to develop European regulations concerning radioactive material carriers

With regard to regulatory matters, 2011 saw the European Commission adopt a draft regulation aiming at instituting a system for registering radioactive material carriers. This unique registration system, if ratified, will replace the national notification and licensing procedures stemming from application of the Euratom 96/29 directive and transcribed in France by Article R.1333-44 of the public health code. The Council of European Ministers has not yet given its decision on this regulation. In 2012, ASN will contribute to the European discussions in this area and the development of a French stance on the draft regulation.

Continuation of inspections of packages that are not subject to ASN approval

Compliance with regulatory requirements with regard to the transport of packages that are not subject to approval (see point 3) is still insufficient in ASN's opinion. Back in 2007 ASN asked for them to be brought into compliance with the regulations before the end of 2010. ASN's inspections reveal shortcomings in the content of the package design conformity justification file, and sometimes its complete absence. These inspections must still be continued, and in 2012 ASN will focus on an additional inspection of the organisations that assist the packaging suppliers in preparing the package conformity files and the certificates.

Continuation of inspections in the manufacture and maintenance of transport packages subject to ASN approval

The design of transport packages requiring ASN approval is inspected in depth during the examination of the approval request. Once ascertained that the package design complies with the regulatory requirements, its manufacture and subsequent routine maintenance in accordance with the requirements of its safety file must be verified. ASN has planned to maintain a large number if inspections in this area in 2012, particularly with regard to the maintenance of the oldest packagings.

Improvement in emergency situation preparedness and experience feedback from the Fukushima accident in the field of transport

ASN has led an initiative to draw up a guide to the drafting of emergency plans intended for the entities responsible for transport. The aim of this guide, which could be published in 2012, is to harmonise and improve the practices of those responsible for transport in this area.

The Ministry of the Interior and the major stakeholders of the French nuclear industry are moreover looking into the management of emergency situations resulting from a transport accident to improve the national response should such an event arise.

ASN also wishes to draw all the possible lessons that the Fukushima accident can bring in the field of transport. The question of how to better evaluate the margins existing in the design of transport packagings will be addressed in 2012, with a view to preventing the consequences of any type of event, even highly improbable, that could affect them, whether on the public highway or within the BNIs.

Transparency in the area of transport

Growing public and media interest in the transport of radioactive materials was observed for several international shipments organised in 2011. Consequently, ASN has made it a priority to develop the information made available to the public concerning the regulating of the safety of transport of radioactive materials. An educational file was posted on ASN's web site www.asn.fr at the end of 2011. At the end of the first quarter of 2012, ASN will also be publishing a new issue of its review Contrôle, addressing the subject of transport safety.

ASN will ensure that article L.125-10 of the Order 2012-6 of 5 January 2012, which codifies Act 2006-686 of 13 June 2006 relative to security and transparency in the nuclear field, which reclassifies the provisions of Decree 2011-1844 of 9 December 2011, is applied.