ASN Report 2017

323 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 11  - Transport of radioactive substances cylinder of enriched UF 6 ) or GMA 2500 (gamma ray projector model requiring transport approval because it is shipped once loaded with its radioactive source). 4.2.3 Inspections of packages not requiring approval For the packages that do not require ASN approval, the consignor must, at the request of ASN, be able to provide the documents proving that the package model complies with the applicable regulations. More specifically, for each package, a file demonstrating that the model meets the regulation requirements and that it can in particular withstand the specified tests, along with a certificate delivered by the manufacturer attesting full compliance with the model specifications, must be held at the disposal of ASN. The various inspections carried out in recent years confirm the progress made concerning the documents presented to ASN and the integration of the ASN recommendations made in its guide concerning packages which are not subject to approval (Guide No.7, volume 3). In 2016, ASN published the updated version of this guide. The guide proposes a structure and a minimum content for the safety files demonstrating that packages which are not subject to approval do comply with all the applicable requirements, along with the minimum content of a declaration of conformity of a package design with the regulations. ASN thus noted improvements in the content of the certificate of conformity and the safety file drawn up by the participants concerned, more specifically for the industrial package models. The representativeness of the tests performed and the associated safety case remain the focal points during the ASN inspections, in particular for type A packages. Furthermore, ASN still finds that some of the entities (designers, manufacturers, distributors, owners, consignors, companies performing the regulatory drop tests, package maintenance, etc.) display shortcomings in the demonstration of package conformity with the regulations. The areas for improvement focus in particular on the following: ཛྷ ཛྷ the description of the authorised contents per type of package; ཛྷ ཛྷ the demonstration that there has been no loss or dispersion of the radioactive content under normal transport conditions; ཛྷ ཛྷ compliance with the regulatory requirements regarding radiation protection, more specifically the demonstration as of the design stage that it would be impossible to exceed the dose limits with the maximum authorised content. In 2017, ASN carried out seven inspections on the design, manufacture andmaintenance of packages not requiring approval. It more particularly carried out a joint inspection with the Belgian Authority at a Belgian designer of a package model used to transport fluorine-18 (used in the medical field) in France. This inspection was conducted as a result of several events involving these packages. It showed that the quality management system set up by the package manufacturer needed to be improved. The safety analysis files and compliance certificates issued by the manufacturer were incomplete. Subcontractor monitoring also needed to be reinforced. 4.2.4 Monitoring the shipment and transportation of packages ASN devotes more than half of its transport inspections to checking consignors and carriers. During these inspections, the checks concern all regulatory requirements binding on each of the transport stakeholders, that is compliance with the requirements of the approval certificate or declaration of conformity, training of the personnel involved, implementation of a radiological protection programme, satisfactory stowage of packages, dose rate and contamination measurements, documentary conformity, implementation of a quality insurance programme, etc. Among the observations or findings formulated further to the inspections, the most frequent discrepancies concern quality assurance, compliance with implemented procedures andworker radiation protection. ASN inspection of a package shipment, November 2017.