ASN Report 2017

300 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 10  - Sources of ionising radiation and their industrial, veterinary and research applications Users Case of radioactive sources In 2017, ASN reviewed and notified 280 new licenses, 942 license renewals or updates and 235 license cancellations. Graph 5 presents the licenses issued or cancelled in 2017 and trends in this area for the last five years. Once the license is obtained, the licensee can procure radioactive sources. To do this, it collects supply request forms from IRSN, enabling the institute to verify – as part of its duty to keep the inventory of ionising radiation sources up to date – that the orders are in conformity with the licenses of both the user and the supplier. If the order is correct, the transfer is then recorded by IRSN, which notifies the interested parties that delivery can take place. If there is any difficulty, the transfer is not validated and IRSN refers the case to ASN (see box). Case of electrical generators of ionising radiation ASN has been responsible for regulating these devices since 2002, and is gradually building up its capacity in this area where numerous administrative situations need to be brought into compliance. In 2017, it granted 146 licenses and 319 license renewals for the use of X-ray generators. ASN also issued 346 notification acknowledgements for electrical devices emitting ionising radiation in 2017. A total of 2,199 licenses and4,570notification acknowledgements have been delivered for electrical devices emitting ionising radiation since Decree 2002-460 was issued. Graph 6 illustrates this trend over the past five years. 0 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 Notifications Authorisations GRAPH 6: Total number of “user” license and notifications for devices generating ionising radiation Number of facilities 2016 2017 2015 2014 2013 4.3 Unjustified or prohibited activities
 4.3.1 Application of the ban on the intentional addition of radionuclides in consumer goods and construction products The Public Health Code indicates “that any addition of radionuclides […] to consumer goods and construction products is prohibited” (Articles R. 1333-2 and 3). Article R. 1333-4 of this same Code states that waivers to these prohibitions can, if justified by the advantages they bring, be granted by order of the Minister responsible for Health and, depending on the case, by theMinister responsible for Consumption or the Minister responsible for Construction, after consulting ASN and HCSP (French High Public Health Council) (see chapter 3). Thus, the trading of accessories containing sources of tritium such as watches, key-rings, hunting equipment (sighting devices), navigation equipment (bearing compasses) or river fishing equipment (strike detectors) is specifically prohibited. ASN considers that this mechanism of granting waivers to the regulations must remain the exception. It was implemented for the first time in 2011 for a waiver request concerning the use of a neutron analysis device in several cement works (Order of 18th November 2011 from the Ministers responsible for Health and Construction, ASN opinion 2011-AV-0105 of 11th January 2011 and ASN opinion 2011-AV-0124 of 7th July 2011). It was then used in 2014 for light bulbs containing very small quantities of radioactive substances (krypton-85, thorium-232 or tritium), serving mainly for applications requiring very high intensity lighting such as public places, professional environments, or for certain vehicles (Order of 12th December 2014 of the Ministers responsible for Health and Construction, ASN opinion 2014-AV-0211 of 18th September 2014). A waiver request to allow the addition of radionuclides (tritium) in certain watches was also denied (Order of 12th December 2014, ASN opinion 2014-AV-0210 of 18th September 2014). The list of consumer goods and construction products concerned by an ongoing waiver request or for which a waiver has been granted is published on the website of the French High Committee for Transparency and Information on Nuclear Security (HCTISN). In 2017, the waiver for the use of a neutron analysis device was renewed for ten years for three cement works, the fourth cement work mentioned in the initial Order of 2011 having closed (Order of 19April 2017 of the Ministers responsible for Health and Construction, ASN opinion 2017-AV-0292 of 7th March 2017). 4.3.2 Application of the justification principle for existing activities The justification of existing activities must be re-assessed periodically in the light of current knowledge and technological changes in accordance with the principle described in point 4.2.1. If the activities are no longer justified by the benefits they bring, or with respect to other non-ionising technologies that bring comparable benefits, they must be withdrawn from the market. A transitional period for definitive withdrawal from the market may be necessary, depending on the technical and economic context, particularly when a technological substitution is necessary.