International focus group on alternative technologies Radioactive sources present radiation exposure and safety risks for their users, the general public and the environment, which must be taken into consideration in the reflection phase preceding the deployment of a nuclear activity. Consequently, in France, when technologies presenting lower risks than a nuclear activity are available under technically and economically acceptable conditions, they must be implemented instead of the nuclear activity initially envisaged: this is the principle of justification. On this basis, as of 2014 and subsequently at the Nuclear Security Summit in Washington in April 2016, France was the initiator of an international initiative now supported by 31 countries and by Interpol. The aim is to support research into and the development of technologies that do not use high-activity sealed radioactive sources and to promote the use of these technologies. In this context, since April 2015, ASN and the National Nuclear Security Administration (NNSA) of the United States of America have created an informal focus group, comprising several countries, to explore the replacement of high-activity radioactive sources by alternative technologies. The aim of this group, which meets once a year, is to foster greater awareness of the benefits of such alternatives and to share experience feedback from each country in this respect. In December 2018, during the International Conference on Nuclear Security organised by the IAEA, the subject of alternative technologies was addressed by several presentations and two panel sessions, and the relevance of this focus group was underlined. The group’s meeting of 2024, like that of 2023, was a virtual on-line meeting held over three days and attended by 150 participants (experts representing governments, international organisations, private enterprises and research institutes). The discussions focused on innovative applications of alternative technologies other than in the medical sector, thereby breaking away from the themes of the previous years. The significant progress made in the development of compact e-beam techniques, which consist in exposing products to be sanitised to a beam of accelerated electrons which can destroy certain microorganisms, was noted in particular. This technology, which does not use radioactive sources, has numerous applications ranging, for example, from sterilisation to the depollution of water and effluents and the reduction of the microbial load in foodstuffs. These regular meetings provide the opportunity to highlight both successful initiatives in the implementation of alternative technologies and difficulties in the development or implementation of these technologies which must be the subject of complementary work. The forms used to apply for authorisation to exercise a nuclear activity have moreover been adapted, and two dedicated forms have been created for the category A, B or C sources or batches of sources. Lastly, to supplement the information for professionals, a brochure intended for RNAs who only possess category D sources (for which the number of regulatory obligations is limited) is also available on asn.fr. 2.4 Licensing, registration and notification of ionising radiation sources used for industrial, research or veterinary purposes 2.4.1 Integration of the principles of radiation protection in the regulation of non-medical activities With regard to radiation protection, ASN verifies application of the three major principles governing radiation protection which are written into the Public Health Code (Article L. 1333-2), namely: justification, optimisation of exposure and dose limitation. Assessment of the expected benefit of a nuclear activity and the corresponding health drawbacks may lead to prohibition of an activity for which the benefit does not seem to outweigh the risk. Either generic prohibition is declared, or the license required for radiation protection purposes is not issued or is not extended. For the existing activities, the elements supporting implementation of the justification principle are recorded in writing by the RNA, and are updated every five years and whenever there is a significant change in available knowledge or techniques. Optimisation is a notion that must be considered in the technical and economic context, and it requires a high level of involvement of the professionals. ASN considers in particular that the suppliers of devices are at the core of the optimisation approach (see point 4). They are effectively responsible for putting the devices on the market and must therefore design them such that the exposure of the future users is minimised. ASN also checks application of the principle of optimisation when examining the license applications, when conducting its inspections, and when analysing reported significant events. 2.4.2 The licensing, registration and notification systems Applications relating to the possession and utilisation of ionising radiation are examined by the ASN regional divisions, while those concerning the manufacture and supply of sources or devices containing sources are examined at the ASN head office by the Department of Transport and Sources (DTS). The entry into effect on 1 July 2018 of Decree 2018‑434 of 4 June 2018, introducing various provisions in the nuclear field, has introduced a third administrative system lying between the notification system and the licensing system: it is a simplified authorisation system called the “registration system”. ASN has prepared a classification system to allocate the various categories of nuclear activities to one of these three systems, whose implementation began on 1 January 2019 with the entry into effect of the ASN resolution extending the notification system to additional nuclear activities which until then were subject to licensing, and continued on 1 July 2021 with the entry into effect of the resolution concerning the registration system. The licensing system Small-scale nuclear activities in the industrial sector stand out by their considerable diversity and the large number of licensees involved. The licensing system is designed to regulate the nuclear activities involving the greatest radiation protection implications, for which ASN checks, when examining the license application, that the applicant has identified the risks and that the measures intended to limit their effects have been studied and planned for. To support this process, licensing application forms adapted to each activity are available on asn.fr. These forms are designed for the licensing applications to be formulated by the representative of a legal person, although it is possible for a physical person to apply for a license. These forms list the documents that must be enclosed with the application. All the documents listed in the appendix to ASN decision 2010-DC0192 of 22 July 2010 must be held by the applicant and kept at the disposal of the inspectors in the event of inspection. On completion of the examination, and provided that the measures described by the applicant are satisfactory, a limited-term (usually 5 years) license is issued for the exercise of the nuclear activity. ASN Report on the state of nuclear safety and radiation protection in France in 2024 259 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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