ASN Report 2017

325 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 11  - Transport of radioactive substances it can consider potential changes to the provisions governing the transport of radioactive substances. Any significant event concerning the transport of radioactive substances, whether the consequences are real or potential, must be the subject of ASN notification within four working days, as stipulated in its event notification guide and as required by Article 7 of the Order of 29th May 2009, amended, on the transport of dangerous goods by road, known as the “TMD Order”. The ASN guide was entirely revised in 2017 (see box) and is available for consultation on www.asn.fr . After notification, a detailed event report must be sent to ASN within two months. Events notified in 2017 In 2017, concerning the transport of radioactive substances, ASN was notified of 64 level 0 events and2 level 1 events. Graph4 shows the trend in the number of significant events notified since 2000. In addition, ASN was notified of 36 events of lesser importance (Events of Interest for the safety of Transport – EIT). Given that they have no actual or potential consequences, these events are not rated on the INES scale (International Nuclear and Radiological Event Scale). There is thus no obligation to notify ASN of them, although ASN nonetheless wishes to be kept periodically informed in order to have an overview of the various events of lesser importance and detect any accumulation or any trends which could be indicative of a problem. Areas of activity concerned by these events More than half of the significant events notified concern the nuclear industry. About one third concern radioactive pharmaceutical products. The other events concern transport related to non-nuclear industrial activities (gamma radiography for example). Very few transport-related events are linked to the non-nuclear industry sectors, when compared with the corresponding traffic levels. This small number of events is probably due to medical activity professionals failing to submit notifications, which can be explained by unfamiliarity with the events notification process and its purpose. ASN does however observe an improvement in the notification rate in the medical sector by comparison with previous years. The contents concerned by the event notifications are extremely varied: radionuclides for medical uses, contaminated material, fuel, empty packaging, etc. Graph 5 shows the breakdown of significant events notified according to content and mode of transport. ASN observes that about 80% of EIT are notified by nuclear industry stakeholders. This demonstrates an almost total absence of notification by stakeholders from the medical sector and from non-nuclear industry. ASN does however point out that notification of EITs is not a regulatory obligation. Causes of events The most frequent causes of the significant events notified include the following: ཛྷ ཛྷ material non-conformities affecting a package: use of inappropriate containment seals, loosening of screws during transport, periodic maintenance date exceeded, non- performance of a pre-departure tightness test, etc. These events had no actual consequences for safety or radiation protection. However, in the event of an accident, a non- conformity can impair the strength of the package; ཛྷ ཛྷ the shipment of packages containing radioactive substances, without this being notified, as well as delivery errors or packages being temporarily mislaid; ཛྷ ཛྷ non-compliance with internal procedures, leading to the shipment of non-conforming packages (for example, container door not properly locked) or with inappropriate labelling; ཛྷ ཛྷ the presence of contamination spots exceeding the regulation limits. In this respect, it should be noted that the situation has improved appreciably for packages approved by ASN, more particularly spent fuel packages. However, these situations persist with packages of uranium ore from the mines. The impact of these events on radiation protection is low, because the contamination spots are present on the drums containing the ore, which are themselves carried inside closed metal containers. FOCUS Revision of the ASN guide on the notification of transport-related events In 2005, ASN published a guide devoted to the notification of events occurring in BNIs and during transport operations. In 2017, ASN split this guide into two parts, one devoted to transports on the public highway and the other to BNIs. The regulatory bases for the notification of events in the two fields are different. As on-site transport is regulated by the same order as all the BNI operations, the corresponding events are subject to the part of the guide devoted to BNIs. For events related to BNIs, the 2005 guide continues to apply. In 2017, ASN published Guide N°31, which replaces the part of the 2005 guide applying to transports on the public highway, by air or by sea. This was an opportunity for a complete overhaul of the contents of the guide to take account of changes to regulations and the experience feedback from application of the previous guide. The revision more particularly aims to simplify and rationalise the criteria for the notification of events and clarify the responsibilities of the various transport stakeholders with regard to notification and the drafting of the report. The new guide also specifies the regulatory requirements applicable, notably the obligation of notifying significant events within four working days and of sending ASN a detailed event report two months after notification. Notification of an event as stipulated in the guide does not take the place of the obligation of immediately alerting ASN to any emergency situation.