ASN Report 2017

139 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 instance, the Agreement on the carriage of dangerous goods by road). The criteria for notifying the public authorities of events considered to be “significant” take account of the following: ཛྷ ཛྷ the actual or potential consequences for workers, the public, patients or the environment, of events that could occur and affect nuclear safety or radiation protection; ཛྷ ཛྷ the main technical, human or organisational causes that led to the occurrence of such an event. This notification process is part of the continuous safety improvement approach. It requires the active participation of all players (users of ionising radiation, carriers, etc.) in the detection and analysis of deviations. It enables the authorities: ཛྷ ཛྷ to ensure that the licensee has suitably analysed the event and taken appropriate measures to remedy the situation and prevent it from happening again; ཛྷ ཛྷ to analyse the event in the light of the experience available to other parties in charge of similar activities. The purpose of this system is not to identify or penalise any individual person or party. Moreover, the number and rating on the INES scale (International Nuclear and Radiological Event Scale) of the significant events which have occurred in a nuclear facility are not on their own indicators of the facility’s level of safety. On the one hand, a given rating level is an over-simplification and is unable to reflect the complexity of an event and, on the other, the number of events listed depends on the level of notification compliance. The trend in the number of events does not therefore reflect any real trend in the safety level of the facility concerned. ASN takes part in the INES consultative committee, a body comprising experts in the evaluation of the significance of radiation protection and nuclear safety events, tasked with advising the IAEA and the INES national representative of the member countries on the use of the INES scale and its updates. 3.3.2 Implementation of the approach Event notification The licensee of a BNI or the person responsible for the transport of radioactive substances is obliged to notify ASN and the administrative authority, without delay, of any accidents or incidents that occur on account of the operation of that installation or the transport activity and which could significantly prejudice the interests mentioned in Article L. 593-1 of the Environment Code. Similarly, the party responsible for a nuclear activity must notify any event which could lead to accidental or unintentional exposure of persons to ionising radiation and liable to significantly prejudice the protected interests. According to the provisions of the Labour Code, employers are obliged to declare significant events affecting their workers. When the head of a facility carrying out a nuclear activity calls in an external contractor or non-salaried worker, the significant events affecting salaried or non-salaried workers are notified in accordance with the prevention plans and the agreements concluded pursuant to Article R. 4451-8 of the Labour Code. The notifying party assesses the urgency of notification in the light of the confirmed or potential seriousness of the event and the speed of reaction necessary to avoid an aggravation of the situation or to mitigate the consequences of the event. The notification time of two working days, tolerated in the ASN notification guide, does not apply when the consequences of the event require intervention by the public authorities. ASN analysis of the notification ASN analyses the initial notification to check the implementation of immediate corrective measures, to decide whether to conduct an on-site inspection to analyse the event in depth, and to prepare for informing the public if necessary. Within two months of the notification, it is followed by a report indicating the conclusions the licensee has drawn from analysis of the events and the steps it intends to take to improve safety or radiation protection and prevent the event from happening again. This information is taken into account by ASN and its technical support organisation, IRSN, in the preparation of the inspection programme and when performing the BNI periodic safety reviews. ASN ensures that the licensee has analysed the event pertinently, has taken appropriate steps to remedy the situation and prevent it from recurring, and has circulated the operating experience feedback. The ASN review focuses on compliance with the applicable rules for detecting and notifying significant events, the immediate technical, organisational or human measures taken by the licensee to maintain or bring the installation into a safe condition, and the pertinence of the submitted analysis. ASN and IRSN also carry out a more wide-ranging examination of the operating feedback from the events. The significant event reports and the periodic reviews sent by the licensees, as well as the assessment by ASN and IRSN, constitute the basis of operating experience feedback. The examination of operating experience feedback may lead to ASN requests for improvements to the condition of the facilities and the organisation adopted by the licensee, but also to changes to the regulations. Operating experience feedback comprises the events which occur in France and abroad if it is pertinent to take them into account in order to reinforce safety or radiation protection. 3.3.3 Technical inquiries held in the event of an incident or accident concerning a nuclear activity ASN has the authority to carry out an immediate technical inquiry in the event of an incident or accident in a nuclear activity. This inquiry consists in collecting and analysing all useful information, without prejudice to any judicial inquiry, in order to determine the circumstances and the identified or possible causes of the event, and draw up the appropriate