2.3.2 The protection of ionising radiation sources against malicious acts Although the safety and radiation protection measures provided for by the regulations guarantee a certain degree of protection of ionising radiation sources against the risk of malicious acts, they cannot be considered sufficient. Reinforcing the oversight of protection against malicious acts targeting sealed radioactive sources has therefore been encouraged by the International Atomic Energy Agency (IAEA), which published a Code of Conduct on the Safety and Security of Radioactive Sources, approved in 2003, supplemented in 2012 by two implementation guides relative to the security of radioactive sources and the security of radioactive material transport. As of 2004, France confirmed to the IAEA that it was working on applying the guidelines set out in this Code. The organisation adopted for the oversight of protection against malicious acts Measures implemented to ensure radiation protection, safety, and protection against malicious acts have many interfaces. Generally speaking, ASN’s counterparts in other countries are responsible for oversight in these three areas (see Table 2 in chapter 2). In France, the protection against malicious acts concerning nuclear materials, particularly those used in certain facilities termed “of vital importance” because they contribute to productions or services that are essential for the functioning of the country, is coordinated by a service under the authority of the Defence and Security High Official (HFDS) of the Ministry responsible for energy. The changes in regulations adopted since early 2016 have led to an organisation for oversight of the protection of ionising radiation sources against malicious acts which takes into account the existing organisation by entrusting this oversight: ∙to the service of the HFDS of the Ministry responsible for energy in facilities whose security is already under its control; ∙to the Ministry of the Armed Forces in the locations placed under its authority; ∙to ASN for the other nuclear activities. The process necessary to set up this oversight, initiated by the Government in 2008 with the assistance of ASN, resulted in Ordinance 2016‑128 of 10 February 2016 and then Decree 2018‑434 of 4 June 2018 introducing various provisions concerning nuclear activities. These texts, which amend the Public Health Code, divide up the oversight duties in the various installations as indicated above, by including protection against malicious acts in the risks that must be taken into account by the persons/entities Responsible for Nuclear Activities (RNAs) and by the regulatory bodies when reviewing the licensing applications. The sources and installations concerned Oversight of source protection against malicious acts concerns all sources of ionising radiation, that is to say all the devices that could cause exposure to radiation. The majority of the regulatory measures are however taken to increase the security of the sources presenting the greatest radiological risks: this concerns radioactive sources of categories A, B and C as defined in the Public Health Code, which stems directly from that of the IAEA. The protection requirements are proportionate to the intrinsic dangerousness of the sources. The graded approach therefore implies stricter obligations for the sources (or batches of sources) in category A than in category C. Sealed sources that are not in categories A, B or C and whose activity exceeds the exemption threshold, and the other ionising radiation sources such as X-ray generators, are classified in category D. In France, 270 facilities in the civil sector hold just under 6,200 radioactive sources of category A, B or C presenting real security risks. These sources are used essentially for industrial purposes (irradiation, radiography, measurements, etc.) or medical purposes (such as telegammatherapy and brachytherapy). Due to their frequent movements when on worksites, industrial radiography sources present particular security risks. If sources of different categories are stored together, the lower category sources may be subject to the stricter security measures applicable to the higher category sources. Regulations The Decree modifying the regulatory part of the Public Health Code taken in application of Ordinance 2016‑128 of 10 February 2016 (Decree 2018‑434 introducing various provisions with regard to nuclear activities) was published on 4 June 2018. It contains several provisions concerning the protection of sources against malicious acts, and more specifically: ∙the classification of ionising radiation sources and aggregation (batching) of radioactive sources into category A, B, C or D according to the intrinsic level of risks presented by these sources or batches of sources. The category A sources are the most dangerous and the category D sources the least dangerous (Article R. 1333‑14 of the Public Health Code); GRAPH 5 Breakdown of high-activity sealed sources according to their category and their oversight authority for protection against malicious acts Ministry of Defence Defence and Security High Official (HFDS) ASN The sources in category A of the Public Health Code correspond to the IAEA category 1 sources. The Public Health Code category B sources correspond to: – the IAEA category 2 sources, – the IAEA category 3 sources contained in a mobile or portable device. The Public Health Code category C sources correspond to the IAEA category 3 sources not contained in a mobile or portable device. 0 10 % 20 % 30 % 40 % 50 % 60 % 70 % Category A Category C Category B 63.6% 30.3% 2.8% Categorisation of radioactive sources Radioactive sources have been classified by the IAEA since 2011 on the basis of predetermined exposure scenarios, in five categories from 1 to 5, according to their ability to create early harmful effects on human health if they are not managed safely and securely. Category-1 sources are considered extremely dangerous while those in category 5 are considered very unlikely to be dangerous. Sources in categories 1 to 3 are considered dangerous for humans to varying degrees. This categorisation is based solely on the capacity of the sources to produce deterministic effects in certain exposure scenarios and must not under any circumstances be considered as proof that there is no danger in exposure to a category 4 or 5 source, as such exposure could cause stochastic effects in the longer term. The principles of justification and optimisation (see point 2.4.1) must therefore be respected in all cases. This IAEA work has been taken up in an Appendix to the Public Health Code amended by Decree 2018‑434 establishing various provisions in the nuclear field. Nevertheless, the IAEA categories 4 and 5 have been grouped together in category D of this Code. ASN Report on the state of nuclear safety and radiation protection in France in 2024 257 11 12 13 14 15 AP 10 09 Sources of ionising radiation and their industrial, veterinary and research applications 08 01 02 03 04 05 06 07
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