320 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 11 - Transport of radioactive substances 3. Roles and responsibilities in regulating the transport of radioactive substances 3.1 Regulation of nuclear safety and radiation protection In France, ASN has been responsible for regulating the safety and the radiation protection of transports of radioactive substance for civil uses since 1997, while ASND (the Defence Nuclear Safety Authority) fulfils this role for transports relating to national defence. Within its field of competence, ASN is responsible, in terms of safety and radiation protection, for the regulation and oversight of all steps in the life of a package: design, manufacture, maintenance, shipment, actual carriage, receipt, etc. 3.2 Protection against malicious acts The prevention of malicious acts consists in preventing sabotage, losses, disappearance, theft and misappropriation of nuclear materials that could be used to manufacture weapons. The Defence and Security High Official (HFDS), under the Minister responsible for Energy, is the Regulatory Authority responsible for preventing malicious acts targeting nuclear materials. 3.3 Regulation of the transport of dangerous goods Regulation of the transport of dangerous goods is the responsibility of the dangerous materials transport commission of the Ministry for Ecological and Solidarity-based Transition. This entity is tasked with ensuring the measures relative to the safe transport of dangerous goods other than class 7 (radioactive) by road, rail and inland waterways. It has a consultative body (CITMD – Interministerial Hazardous Materials Transport Committee) that is consulted for its opinion on any draft regulations relative to the transport of dangerous goods by rail, road or inland waterway. Inspections in the field are carried out by land transport inspectors attached to the Dreals (Regional Directorates for the Environnment, Planning and housing). For the regulation of dangerous goods to be as consistent as possible, ASN collaborates regularly with the administrations concerned. For example, in 2017 ASN took part in the training of DGAC (General Directorate for Civil Aviation) inspectors responsible for monitoring the air transport of hazardous goods in order to teach them about the specific aspects of class 7 and present experience feedback from ASN’s inspections on these subjects. The breakdown of the various regulatorymissions is summarised in Table 3. 4. ASN action in the transport of radioactive substances 4.1 Delivery of approval certificates and shipment approvals The type B and C packages, as well as the packages containing fissile materials and those containing more than 0.1 kg of UF 6 must be covered by an ASN transport approval. The designers of the package models who request approval from ASN must support their application with a safety file demonstrating the compliance of their package with all the regulatory requirements. Before deciding whether or not to issue approval, ASN examines this file, drawing on the expertise of IRSN, in order to ensure that the safety cases are pertinent and conclusive. If necessary, the approval is issued with requests in order to improve the safety cases. In some cases, IRSN’s appraisal is supplemented by a meeting of the Advisory Committee for Transport (GPT). The opinions of the Advisory Committees are always published on www.asn.fr. The GPT for example met in 2017 to examine the TN G3 package model developed by the Areva TN company to transport spent fuel from the EDF NPPs. The approval certificate specifies the conditions for the manufacture, utilisation and maintenance of the transport package. It is issued for a package model independently of the TABLE 3: Administrations responsible for regulating the mode of transport and the package MODE OF TRANSPORT REGULATION OF MODE OF TRANSPORT PACKAGE REGULATION Sea General Directorate for Infrastructures, Transports and the Sea (DGITM) at the Ministry for Ecological and Solidarity-based Transition. In particular, the DGITM is responsible for regulating compliance with the prescriptions applicable to ships and contained in the International Code for the Safe Carriage of irradiated nuclear fuel, plutonium and high-level radioactive wastes on board ships ( “Irradiated Nuclear Fuel” Code). The DGITM has competence for regulation of dangerous goods packages in general and is in close collaboration with ASN for radioactive substances packages. Road, rail, inland waterways General Directorate for Energy and Climate (DGEC) of the Ministry for Ecological and Solidarity-based Transition (MTES). The General Directorate for the Prevention of Risks (DGPR) is responsible for regulation of packages of dangerous goods in general and, in close collaboration with ASN, of packages of radioactive substances. Air General Directorate of Civil Aviation (DGAC) of the MTES. The DGAC has competence for regulation of dangerous goods packages in general and, in close collaboration with ASN, of radioactive substances packages.