ASN Report 2017

131 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 04  - Regulation of nuclear activities and exposure to ionising radiation The ASN labour inspectors have the same powers and the same prerogatives as common law labour inspectors. They belong to the labour inspectorate system for which the central authority is the General Directorate for Labour. The duties of the labour inspectors are based on international standards (International Labour Organisation Convention No. 81) and national regulations. ASN carries them out in liaison with the other Government departments concerned, mainly the departments of the Ministry responsible for Labour. ASN has set up an organisation enabling it to deal with these issues. The action of the ASN labour inspectors (6.7 Full- Time Equivalent - FTE) in the field has increased since 2009, particularly during reactor outages, with inspection visits, advisory roles at the meetings of the Committee for Health, Safety and Working Conditions (CHSCT) and the Inter- company Committee on Safety and Working Conditions (CIESCT), as well as the regular discussions with the social partners. 2.3 Main checks performed by the licensees The operations that take place in the BNIs and which have the highest potential safety and radiation protection implications require prior authorisation by ASN (see chapter 3). 2.3.1 BNI licensee internal oversight In 2017, ASN adopted a resolution concerning operations taking place within the BNIs. This resolution identifies the administrative procedures to be implemented in the event of changes to a BNI, its authorised operating procedures, aspects which led to its authorisation or its commissioning authorisation, or its decommissioning conditions. This resolution more particularly identifies the organisational measures regarding internal oversight to be implemented by the licensee to guarantee management of the design and performance of the modifications eligible for the administrative system of notification. ASN checks correct application of the provisions stipulated by the above-mentioned resolution. The above-mentioned resolution replaces the internal authorisations system, which was regulated by Decree 2007-1557 of 2nd November 2007 and ASN resolution 2008-DC-0106 of 11th July 2008 concerning the procedures for implementation of internal authorisation systems within BNIs. This system was the subject of prior approval by an ASN resolution which defines: ཛྷ ཛྷ the nature of the operations which can be covered by an internal authorisation; ཛྷ ཛྷ the process used to approve the operations, more specifically with an opinion issued prior to any operation by a body within the company that is independent from the people directly in charge of operation; ཛྷ ཛྷ identification of the persons qualified to issue the internal authorisations; ཛྷ ཛྷ the procedures for periodically informing ASNof the operations planned or completed. This systemmay last until 1st January 2019 for those facilities benefiting from such a resolution, the provisions of which are checked by ASN during inspections. 2.3.2 Internal monitoring of radiation protection by the users of ionising radiation sources The current aim of internal monitoring of radiation protection is to ensure regular assessment of the radiological safety of the activities using sources of ionising radiation. This monitoring is performed under the responsibility of the licensees. It may be carried out by the Radiation Protection Expert-Officer (RPE-O), appointed and mandated by the employer, or be entrusted to IRSN or to organisations approved by ASN. It does not replace either the periodic checks required by the regulations, or the inspections conducted by ASN. It for example concerns the performance of the protection systems, monitoring of the ambient atmosphere in regulated areas, or checks on medical appliances before they enter service or after modification. As a result of the transposition of Directive 2013/59/Euratom of 5th December 2013, this system will inevitably change. TABLE 1: Methods of ASN regulation of the various radiation protection players INSTRUCTION/AUTHORISATION INSPECTION OPENNESS AND COOPERATION Users of ionising radiation sources • Review of the dossiers required by the Public Health Code (Articles R. 1333-1 to R. 1333-54) • Pre-commissioning inspection • Registration of notification or delivery of the authorisation • Radiation protection inspection (Article L. 1333-17 of the Public Health Code) • Jointly with the professional organisations, drafting of guides of good practices for users of ionising radiation Bodies approved for radiation protection inspections • Review of application files for approval to perform the inspections specified in Article R. 1333- 95 of the Public Health Code and Articles R. 4451-29 to R. 4452-34 of the Labour Code • Organisation audit • Delivery of approval • Second level inspection: -- in-depth inspections at head office and in the branches of the organisations -- unannounced field inspections • Jointly with the professional organisations, drafting of rules of good practices for performance of radiation protection inspections