ASN Report 2018

∙ ∙ 14 organisations tasked with the monitoring of worker internal dosimetry, 7 for external monitoring and 2 for monitoring exposure associated with natural radioactivity (one for internal exposure and one for external exposure). In 2018, ASN issued 6 new approvals or approval renewals; ∙ ∙ 5 organisations tasked with NPE inspections; ∙ ∙ 3 organisations qualified for Nuclear Pressure Equipment (NPE) and Simple Pressure Vessels (RPS) within the perimeter of BNIs (in-service monitoring); 1. The intervention is the unit representative of the activity traditionally used by the labour inspectorate. ∙ ∙ 19 inspection departments qualified for in-service monitoring of NPE and RPS within the perimeter of NPPs; ∙ ∙ 62 laboratories for environmental radioactivity measurements covering 880 approvals, of which 129 are approvals or approval renewals delivered during 2018. ASN gives the General Directorate for Health (DGS) an opinion on the approval of the laboratories analysing radioactivity in water intended for human consumption. 3 —  Efficient regulation and oversight 3.1  ̶  Inspection 3.1.1  –  Inspection objectives and principles The inspection carried out by ASN is based on the following principles: ∙ ∙ the inspection aims to verify compliance with the provisions that are mandatory under the regulations. It also aims to assess the situation with regard to the nuclear safety and radiation protection implications; it seeks to identify best practices, practices that could be improved and assess possible developments of the situation; ∙ ∙ the scope and depth of the inspection is adjusted to the risks inherent in the activity and the way they are effectively taken into account by those responsible for the activity; ∙ ∙ the inspection is neither systematic nor exhaustive; it is based on sampling and focuses on the subjects with the highest potential consequences. 3.1.2  –  Inspection resources implemented To ensure greater efficiency, ASN action is organised on the following basis: ∙ ∙ inspections, at a predetermined frequency, of the nuclear activities and topics of particular health and environmental significance; ∙ ∙ inspections on a representative sample of other nuclear activities; ∙ ∙ inspections of approved organisations. The inspections may be unannounced or notified to the licensee a few weeks before the visit. They take place mainly on the site or during the course of the relevant activities (work, transport operation). They may also concern the head office departments or design and engineering departments at the major licensees, the workshops or engineering offices of the subcontractors, the construction sites, plants or workshops manufacturing the various safety-related components. ASN uses various types of inspections: ∙ ∙ standard inspections; ∙ ∙ reinforced inspections, which consist in conducting an in-depth examination of a targeted topic by a larger team of inspectors than for a routine inspection; ∙ ∙ in-depth inspections, which take place over several days, concern a number of topics and involve about ten or so inspectors. Their purpose is to carry out detailed examinations and they are overseen by senior inspectors; ∙ ∙ inspections with sampling and measurements. With regard to both discharges and the environment of the facilities, these are designed to check samples that are independent of those taken by the licensee; ∙ ∙ event-based inspections carried out further to a particularly significant event; ∙ ∙ worksite inspections, ensuring a significant ASN presence on the sites on the occasion of reactor outages or particular work, especially in the construction or decommissioning phases; ∙ ∙ inspection campaigns, grouping inspections performed on a large numbers of similar installations, following a predetermined template. Labour inspectorate work in the NPPs entails various types of interventions (1) which more particularly involves: ∙ ∙ checking application of the Labour Code by EDF and outside contractors in the NPPs (verification operations that include inspections); ∙ ∙ participation in the meetings of the CHSCT, the Social and Economic Committee (CSE) and the Joint Contractors Committee on Safety and Working Conditions (CIESCT) (EPR worksite); ∙ ∙ conducting inquiries on request, following complaints or based on information, following which the inspectors may take decisions as specified by the labour regulations, such as cessation of the works or the obligation to have the work equipment verified by an approved organisation. ASN sends the licensee an inspection follow-up letter, published on , officially documenting: ∙ ∙ deviations between the situation observed during the inspection and the regulations or documents produced by the licensee pursuant to the regulations; ∙ ∙ anomalies or aspects warranting additional justifications; ∙ ∙ best practices or practices to which improvements could be made, even if not directly constituting requirements. Any non-compliance found during the inspection can lead to administrative or criminal penalties (see point 5.2). Some inspections are carried out with the support of an IRSN representative specialised in the facility checked or the topic of the inspection. • ASN inspectors ASN has inspectors designated and accredited by its Chairman, in accordance with the conditions defined by Decree 2007‑831 of 11 May 2007 setting the procedures for appointing and accrediting nuclear safety inspectors, subject to their having acquired the requisite legal and technical skills through professional experience, mentoring or training courses. The inspectors take an oath and are bound by professional secrecy. They exercise their inspection activity under the authority of the ASN Director-General and benefit from regularly updated practical aids (inspection guides, decision aids) to assist them in their inspections. 136  ASN report on the state of nuclear safety and radiation protection in France in 2018 03 – REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION