7th February 2012- INB-ORDER

Joëlle Elbez-Uzan
Head of Nuclear Safety Licencing and Environmental Protection
Lina Rodriguez-Rodrigo
Safety Control Section -SCS Leader
Safety Quality and Security Department

Presentation based on ASN presentation to the Nuclear Operators

Workshop on INB Order dated 7th February 2012 Page 1

Content

 1-Review of the legislative and regulatory framework applicable to

the nuclear facilities (INB)
 2-Order dated 7 February 2012 establishing the general rules for
the nuclear facilities (INB)
 3-Application of Order dated 7 February 2012 to ITER –INB

The document is available on IDM:

Order dated 7 February 2012 relating to the general technical regulations
applicable to INB - EN (7M2YKF v1.6)

For 1 & 2 :Presentation based on ASN presentation to the Nuclear Operators

For 3: Implementation of the INB-Order 7th February 2012 in ITER

Workshop on INB Order dated 7th February 2012 Page 2

1- Review of the legislative and regulatory framework
applicable to the nuclear facilities (INB)
Context and objectives

 The legal framework applicable to the nuclear facilities (INB) was

completely revised under the Act dated 13 June 2006.
 Previous framework dated back to the sixties (and 1995 for releases)
+ Supplemented by various orders (1984 Quality Order, General
Technical Regulatory orders in 1999 and 2006, as well as the
Environment Order in 1999)
which needed therefore be updated and adapted.

 Agreement with the European safety authorities (WENRA)*

to take into account joint “reference levels” in the national regulations.
 Promote experience feedback
 Develop a standardised approach.

 The ASN integrated regulatory review service of IAEA (IRRS)

underlined in 2006 the necessity to develop the general technical
regulations in France.
* Members: Belgium; Bulgaria; Czech Republic; Finland; France; Germany; Hungary; Italy; Lithuania; Romania; Slovak Republic; Slovenia; Spain;
Sweden; Switzerland; The Netherlands; United Kingdom;
Workshop on INB Order dated 7th February 2012 Page 3
Observers: Armenia; Austria; Denmark; Ireland; Luxemburg; Norway; Poland; Russian Federation; Ukraine
1-
Review of the legislative and
regulatory framework applicable to the
nuclear facilities (INB)

Workshop on INB Order dated 7th February 2012 Page 4

Regulatory framework - Pyramid

Nuclear Safety &

Parliament Transparency Act
Acts

Executive Decree No. 2007-1557 dated

Decrees power 02 November 2007 (INB procedures)
Mandatory
Orders
ASN
ASN INB Order
decisions

ASN regulatory decisions

Non-
Mandatory
Guidelines
ASN guidelines(and basic safety
rules)

Workshop on INB Order dated 7th February 2012 Page 5

 Structure of new technical regulations
(November 2012)
Nuclear Safety & Transparency Act and related implementation orders
INB Order
provisions and transitional
Scope, definitions, various

Controlling nuisances and

their impact on health &
responsibility (1) (2) (3)

Waste management (1)

the environment (1) (2)

emergency situations

Special provisions for

Pressure equipment
demonstration (1)
Organisation and

specific facilities
management of
Preparation &
Nuclear safety

Procedures
measures

Safety policy  Nuclear Waste  Emergency Reactor

Operation Protection shutdown Procedures Safety review
& safety pressure management situations 
of the (PWR )
management equipment methods
environment
(3)  Miscellaneous (1) Emergency Equipment
(1) (2)
risks (1) Spare guidelines PWR design changes 
On-call components Waste 
safety  Fire hazards conditioning Content of
guidelines Waste
(1)  Modifications final safety 
disposal INBs
Incident 12/12/05 Interim waste report
declaration “Flooding” and 10/11/99 storage
conditions Content of
guidelines guidelines PWR fuels
general 
operating rules
Guidelines
Annual In-house
report authorisations
Consultation Guidelines (1) Covering the scope of the Order dated 31/12/1999
“Informing Pending (2) Covering the scope of the Order dated 26/11/1999
completed
the public” (3) Covering the scope of the Order dated 10/08/1984
Decision
Published
Workshop on INB Order dated 7th February 2012
 Page 6
Principles and method for elaboration new
legislation followed by ASN
 Prescriptive and self consistent requirements
 Integrated safety approach

 Cover radiological and non-radiological risks

 Accident prevention and control
 Limit the inconveniences of facilities (impact & chronic
nuisances).

 Graduated approach
 Apply a principle of proportionality regarding the safety
challenges
 Provide room to manoeuvre when it comes to defining
specific requirements according to the context.

 Promote sentences in terms of objectives and not means.

Workshop on INB Order dated 7th February 2012 Page 7
Legislative part of the Environment Code
(e.g. Nuclear Safety & Transparency Act)
The Decree dated 2 November 2007 has been amended taking into account the
environmental code
http://www.legifrance.gouv.fr/affichTexte.do?cidTexte=LEGITEXT000006057182&dateTexte=20130926

Environmental Code Definitions

(Previous article I of TSN Law)
Nuclear safety
Article L591-1 of the Environment Code +
“Nuclear security includes nuclear safety, radiation Radiation protection
protection, prevention and fight against malevolent acts and +
civil security actions in the case of an accident. Prevention and fight
Nuclear safety involves all the technical and organisational against malevolent acts
measures relative to the design, construction, operation, +
shutdown and dismantling of licensed nuclear facilities, as Civil security actions in
well as the transport of radioactive material, which are all the case of an accident
taken to prevent or limit the effects of an accident.
Radiation protection concerns the protection against =
ionising radiation, i.e. all rules, procedures and means of
NUCLEAR SECURITY
prevention and monitoring designed to prevent or reduce
the harmful effects of ionising radiation for people either
directly or indirectly involved, including via any
environmental impacts.”

Workshop on INB Order dated 7th February 2012 Page 8

Legislative part of the Environment Code
Environmental Code Definitions
 What must be protected under the INB requirements
 Article L593-1 of the Environment Code PROTECTION
against
The INBs listed in Article L593-2 are governed by the legal
risks
framework defined by the provisions of this Chapter and of
and
Chapter VI in this Part owing to the risks and
inconveniences they can represent in terms of: inconveniences
IN
• Security Security
• Public health +
• Protection of nature and the environment.” Public Health
+
Protection of Nature
 To what are the INB requirements applicable and Environment
 Article L593-2 of the Environment Code
Previous article 28 of TSN Law
1° Nuclear reactors;
2° Installations meeting characteristics defined by a State
Council decree, for preparing, enriching,
producing, processing or storing nuclear fuels or treating,
storing or disposing of radioactive wastes;
3° Installations containing radioactive or fissile substances
and meeting characteristics defined by a State Council
decree;
4° Particle accelerators meeting characteristics defined by a
State Council decree.

Workshop on INB Order dated 7th February 2012 Page 9

 ‘Procedures’ Decree No. 2007-1557
Consequences related to Consequences related to
accident operation normal operation
Article L593-7
This authorisation of
creation can only be
RISKS issued when the operator
demonstrates that the INCONVENIENCES
technical and organisation
measures are capable of
preventing or sufficiently Impact
limiting the risks and
inconveniences Study
Preliminary
Safety Report
Content
Part 6
• Identity of the operator
• General data on the INB
• Maps and drawings
• Public easements
• Dismantling plan
• Conclusion of public debate
• Technical capabilities
Understandable • Financial means Understandable
version of RPrS • Data on the land owner version Impact study
• Health & safety notice
for the public (including radiation protection) for the public

+General monitoring & maintenance rules -RGSE

(when final shutdown/ dismantling)

The operator demonstrates ≠ the operator asserts

 The operator
Workshop on INB Order
demonstrates dated th Februaryprovides
the 7operator 2012 a demonstration
Page 10
 To prevent/limit risks/incoveniences, the operator defines technical and organisational measures
2- Main content of the
Order dated 7 February 2012
establishing the general rules for the
nuclear facilities (INB)

Workshop on INB Order dated 7th February 2012 Page 11

Order of 7th February 2012-The INB ORDER
This Order constitutes an update as regards the new legislative
framework established by Act No. 2006-686 of 13 June 2006 relating
to nuclear transparency and security now integrated in the
Environmental Code and Orders relating to basic nuclear
installations
• the Order of 10 August 1984 relating to the quality of the design,
the construction and the operation of basic nuclear installations,
• the Order of 26 November 1999 establishing the general technical
requirements relevant to the restrictions, and the terms and
conditions of intake and discharge subject to authorization, and
executed by the basic nuclear installations,
• the Order of 31 December 1999 establishing the general technical
regulations intended for preventing and limiting nuisances and
external risks arising from basic nuclear installation operations.

On the 1st July 2013, these 3 orders have been superseded by

the INB-ORDER 7th February 2012
Workshop on INB Order dated 7th February 2012 Page 12
 Order 10th August 1984 and INB-ORDER
• Order 10th August 1984 applies to Safety Important Class Structures Systems
and Components (SIC)
• The INB-Order applies to Protection Important Components
• INB-Order- title II and definitions of title I replace the Order 10th August 1984.
• The INB-Order gives more details and requires (in parenthesis related article of AQ84)

I. Technical capacities (art.7)

II. Surveillance of external contractors (art. 4, 8, 9)
III. A policy on nuclear safety and environment
IV. An Integrated management system
V. The identification of the Protection Important Components-PIC and
Protection Important Activities-PIA (art. 1, 2, 6)
actual ITER approach to SIC kept as a sub-ensemble of PIC.
any Activities which may influence the performance (safety characteristic)
of a PIC must be called Protection Important Activity (PIA).
VI. Management of discrepancies NCR’s (art. 12)
VII. Continuous improvement (includes corrective actions and lessons learned) (art. 13)
VIII. Public information procedures
Workshop on INB Order dated 7th February 2012 Page 13
Title I: GENERAL PROVISIONS
 Purpose of the order  Definitions
 Nuclear safety
 Applies throughout the entire
lifecycle of the INB  Protection-important activities
 Approach proportional to the  Protection-important
level of risks or inconveniences components
 Technical aspects and  Defined requirements
organisational & human factors  External contractors
(definition included in the order).  On-site transport operations
 General Principles  Area where nuclear waste
 Protection of the interests in production is possible
Article L593-1 of the Environment  Operating conditions of an
Code INB (normal, degraded,
 Compliance with L1333-1 of the incident and accident)
Public Health Code  Failures in normal operation
 Use of the best available (internal failure, internal and
techniques external events, initiating events)
Workshop on INB Order dated 7th February 2012 Page 14
Order of 07/02/2012 – Title II
 To be responsible for the safety of its facility, the operator must in
practice:
 Clearly show the priority it gives to the prevention/ mitigation of
risks/inconveniences and implement the necessary measures to do so
Art 2.3.1 to 2.3.3
 Possess the necessary skills and resources
Art 2.1.1, 2.1.2, 2.4.2
 Manage the different requirements, including the prevention/mitigation of
risks/inconveniences, which are compulsory or self-imposed
Art 2.4.1, 2.4.2
 Identify the equipment and activities contributing to the prevention/mitigation of
risks/inconveniences and make sure they have the required characteristics
Art 2.5.1 to 2.5.7
 Monitor all sub-contracted activities
Art 2.2.1 to 2.2.4
 Safety must neither decline nor stagnate. The operator must:
Ensure compliance by managing discrepancies
 Art 2.6.1 to 2.6.5
Improve safety, particularly by integrating feedback
 Art 2.7.1 to 2.7.3
 The operator must make sure the public is satisfied in terms of the
transparency of information.
 Art 2.8.1 and 2.8.2
Workshop on INB Order dated 7th February 2012 Page 15
Title II - Organisation & responsibility
 Technical capabilities
 Specify how the technical  Integrated management system
capabilities have been organised
 Protection-important components
 Make sure all technical capabilities
and activities
deemed fundamental are available
in-house or offered by a subsidiary  Obligations of the Quality Order
remain applicable - supplemented
 Monitoring external contractors or clarified - and now also cover
 External contractors must be integrated safety
monitored
 Managing deviations and non-
 This monitoring must be ensured by conformities improving safety
the operator
 The processing of deviations has
 It is possible to get support to ensure been consolidated
monitoring
 Obligation to take into account
 Policy relative to the protection of local and international feedback
interests
 This involves protecting all interests
covered by law (integrated safety
Workshop on INB Order dated 7 th February 2012
concept) Page 16
Technical capabilities of the operator
 Foundation of activities
 Long-term aspect (perennity)
 Control of the activities (performance of the activities)

Allows the operator to understand and assimilate the foundations of the activities in a
durable manner (design, construction, operation, etc.)

In-house capabilities of Capabilities over which the Capabilities which the

the operator (III of 2.1.1) operator has authority (II of 2.1.1) operator has available if
needed (I of 2.1.1)
Allows the External contractors Allows the
operator to make Domestic Agencies operator to ensure
any decision or Direct contractors control over
implement any Experts under contracts activities (design,
conservative Staff from labs, universities, construction,
measures etc under MOU operation,
permitted under Any contractors providing dismantling, etc.)
its responsibility PIC or PIA
as INB operator
Informing the public
Updated under
authorities of its DAC files
Workshop on INB Order dated 7th February 2012
articles 26, 27 or
Page 1731
technical capacities
 Monitoring external contractors
 The operator is responsible for the
safety of the INB
 The operator can decide to not do To be able to meet its responsibilities
everything itself and call upon as nuclear operator, the operator
contractors (and their sub- cannot lose interest in the activities of
these experimenters/users, nor can it
contractors)
lose interest in what its sub-
 Studies contractors/ service providers are
 Manufacture or supply of equipment performing, preparing or providing
 Construction of structures and
1/ The operator must make them
installation of equipment
aware of the constraints related to
 Appraisals and inspections activities in an INB
 Dismantling and clean-up
 The operator can provide
2/ The operator must
experimenters or users with all or part
of its INB so they can perform their ensure the monitoring
activities
 R&D work Exception: Notified bodies
 Sample irradiationWorkshop on INB Order dated 7 February 2012acting on behalf of the ASN Page 18
th
Monitoring external contractors

 The operator “performs the monitoring”. However, the operator can be

assisted so the monitoring is more relevant/ efficient, but without this
leading to the delegation of monitoring.
 Article 2.2.3. "I.―Any protection-important activities performed by an external
contractor must be monitored by the operator who cannot subcontract the
task.
 However, the operator can obtain assistance with this monitoring in
specific cases, as long as he retains the skills necessary to control this
monitoring.”
 “II. ― When requested, the operator shall send the ASN a list of the
situations during which it has used assistance, indicating the reasons and
the way in which it implements the obligations defined in I."

Workshop on INB Order dated 7th February 2012 Page 19

 Continuous improvement

Article 2.7.1: "In addition to dealing with each deviation, discrepancy and Non-
Conformities individually, the operator shall periodically review the NCR’s to
assess the cumulative effect of as-yet uncorrected defaults on the facility, and to
identify and analyse trends in the recurrence of similar discrepancies." »

1 Close- 3
Minor Processing 1 Significant Processing 1 OPEN
out
NCR NCR

2 Close- 5 OPEN
Significant Processing 1 out Major Processing 1
NCR
NCR

6
Close- OPEN
5
Deviation
Processing 1 out Minor Processing 1
NCR

Periodic identification and

analysis of trends in the Periodic analysis of
repetition of similar accumulated impact
discrepancies
Workshop on INB Order dated 7th February 2012 Page 20
Title III-Demonstration of Nuclear Safety

 Accident risk control  Consolidating design

requirements
 Radiological or non-radiological
 Integrating conditions with the
 Using existing, renowned
accumulation of events
standards
 Accidents with fast kinetics
 Defence in depth
resulting in significant releases
 IAEA standards
 Making them physically
 EPR technical directives impossible
 Widespread application of  Failing this, making them
principles currently used today highly improbable with a high
degree of confidence.
 Probabilistic analyses
Not applicable to ITER tokamak

Workshop on INB Order dated 7th February 2012 Page 21

Title III-Accidents that must be practically impossible

Preliminary
Nuclear Safety
Safety demonstration
Report
RISKS
 Identification
of relevant accidents
 Description &
substantiation of Accident that must be
measures applied to
make such accidents
practically impossible
practically impossible

Accident made Accident made highly improbable with a

physically impossible high degree of confidence

Very low probability of occurrence (initiating events, etc.)

High level of confidence:
 Defence in depth (prevention, mitigation)
 Robustness of the demonstration (margins, conservative codes, etc.)
 Probabilistic analyses (uncertainties, sensitivity)

Workshop on INB Order dated 7th February 2012 Page 22

Title III-Demonstration of Nuclear Safety

Plausible Postulated single

accumulation of initiating events
initiating events
Nuclear Safety
demonstration
RISKS

Thorough
Probabilistic Deterministic
analysis approach

Non applicable for ITER

For PWRs level 1&2
probabilistic safety
analyses
Art. 8.1.2

Technical aspects Organizational aspects Human aspects

Workshop on INB Order dated 7th February 2012 Page 23

Title IV-Control of nuisances and the impact on
health and the environment
Best available techniques (according to the Measurement means
Order of 26 April 2011)
Efficient
Supervision of releases and water intake
Available
based on regulations for environmentally-
regulated facilities (ICPE) in general cases Annual inter-comparison of
measurements
Application of ICPE technical regulations
to ‘required equipment’ in general cases Annual estimate of water intake and
releases
 Limitation of certain substance
discharges and releases in the soil and Annual dose estimate due to the INB
sub-soil and an environmental impact report
Monitoring Informing the relevant authority
 Of water intake and effluent releases Application of requirements from
European directives
 Of the environment around the INB
Declarations of releases and of the
possession of any dangerous
substances
Workshop on INB Order dated 7th February 2012 Page 24
Title IV-Objectives of revising the regulations
 Revising the regulations on the basis of established law: using existing general
regulations and making them binding to operators
 Applying the requirements of the orders dated 26/11/1999 and 31/12/1999
 Simplifying and reducing the number of individual requirements (procedural
deadlines shortened)
 Integrating requirements from European directives which are applicable to INBs
 Defining principles/rules applicable to INBs (e.g. accountancy rules) and making
them binding
 Ensuring the INB requirements are at least equivalent to those applied to
environmentally regulated facilities and installations, structures, works & activities
 Confirming the integrated approach
 Improving the quality of the measurements conducted (effluents and
environmental monitoring)
 Consolidating the operator’s responsibility (release estimates, elimination of prior
authorisations)
 Ensuring transparency and informing the public.
Workshop on INB Order dated 7th February 2012 Page 25
Title IV-General principals
 Avoiding, reducing and compensating
Art. 4.1 - I –
III. – Whenever possible, the operator shall take the necessary
measures to compensate for any inconveniences if it was not possible
to sufficiently reduce them.
Art. 4.1.1. – I – The operator shall take all the measures – as early as
design – to limit effluent releases from the facility.

Using the best available techniques

► Definition: refers to the definition in the ministerial order dated 26 April 2011
(Article 4.1)
► Establishment of emission limits (Article 4.1.2)
 Ecological continuity
Art. 4.1.3 – I – The water intake and discharge structures and facilities in
waterways must not prevent the ecological continuity as specified in
point 7 of Article L211-1 of the Environment Code. In waterways or parts
of waterways and canals for which the list is established in application of
Article L 432-6 of the Environment Code, these structures must include
set-ups that ensure the circulation of migratory fish.
Workshop on INB Order dated 7th February 2012 Page 26
Title IV-General principals
 Requirements at least equivalent to environmentally regulated facilities
(ICPE) and installations, structures, works & activities (IOTA)

 Independence of ICPE and INB regulations

Orders applicable from the date of publication

of the Order of 7 February 2012

Workshop on INB Order dated 7th February 2012 Page 27

Title IV-Definitions

Workshop on INB Order dated 7th February 2012 Page 28

Title IV-Emission Limits
 Several principles can govern how limit values are established
Dose constraints Choices must be substantiated in the
impact assessment
Best available techniques

Art. 4.1.2 – I – The limits on emissions, water withdrawal and effluent discharges for the facility are
established on the basis of the best available techniques under technically and economically acceptable
conditions, taking into account the characteristics of the facilities, its geographic location and the local
environmental conditions.

 Emissions cannot exceed the limit values (II of Article 4.1.2)

 Established in Articles 27, 31, 32, 34 and 14° of Article 33 in the
Ministerial Order dated 2 February 1998 (applicable as of 1 July 2013)
 For certain categories of facilities, the limits are established in
documents mentioned in Appendix II (deferred application)
 Possibility of obtaining an exemption by means of individual requirements
 Some substances described in Article R 211-11-1 of the Environment Code
can only be released if individual requirements establish their emission
limits (Article 4.1.11)
Workshop on INB Order dated 7th February 2012 Page 29
Title IV-Emission Limits - release estimates
Estimates must be sent to the ASN before
31 January of each year

First time in 2014

Art. 4.1.3 – I – Based on the programme of activities or operations likely to result in effluent releases, the
operator must define a yearly estimate of its water withdrawal and consumption, as well as its effluent
releases. This estimate must be sent to the ASN and the local information commission by 31 January of the
each year at the latest.

Results before 30 June of the following year

 A summary of the register mentioned in I of Article 4.4.2 in which there is 1) a list of the analyses and
measurements for the registers, 2) the operator's analysis of any anomalies or exceeded limits observed
and 3) the operator’s assessment of how the operations were managed
 Information making it possible to assess the consistency of releases with the estimate stated in I of
Article 4.4.3.

Results sent to the Local Information Commission

The report must be sent by 30 June of the following year to the ASN, to the regional department for the
environment, land planning and housing, to the regional health agency, to the water police authority, and to
the local information commission. It can be incorporated into the report stipulated in Article L 125-15 of the
Environment Code.
Workshop on INB Order dated 7th February 2012 Page 30
Title IV-Quality of measurements
 Measurements must include an assessment of uncertainties
 INTER-comparison of measurements (chemical & radiological)

IV. – At least once a year, the operator must ensure the inter-comparison of measurements with a third-
party organisation as stated in Article 9.2 for all or part of the measurements and analyses required to
check radioactive effluent releases.

The operator must have a third-party organisation – as stated in Article 9.2 - check the measurements
and analyses which are required for non-radioactive effluent releases.

 Incorporation of Public Health Code measures into the INB regulations in

terms of the RNM (French national network responsible for measuring
environmental radioactivity)
 Obligation to have notified laboratories ensure the environmental monitoring
and have the results sent to the RNM

Workshop on INB Order dated 7th February 2012 Page 31

Title IV- Equipment required for operation

 Application of ministerial orders such as the ICPE Order mentioned in

Appendix II (Article 4.3.1):

Art. 4.3.1. – The documents mentioned in Appendix II apply to the equipment and facilities mentioned in
the first paragraph of Article 593-3 of the Environment Code. Nonetheless, the operator can implement
different measures – specified in the documents compiling the files mentioned in Articles 8, 20, 37 and 43
of the above-mentioned Decree dated 2 November 2007 – when it has been demonstrated that they
ensure a level of protection for the interests cited in Article L 593-1 of the Environment Code that are at
least equivalent.

 Different measures are possible with an equivalent level of protection

 Applies to versions in force on 8 February 2012 (independence of two
types of regulations)
 □Article 4.3.1 applies from the date of the first safety review after 1 July
2015
 □ All water cooling towers: exemptions maintained for the large towers
of nuclear power plants

Workshop on INB Order dated 7th February 2012 Page 32

Title IV-Prevention of nuisances

 Extension of requirements to cover sound levels

 Containers must be leaktight!

Art. 4.3.3. – I – The disposal, interim storage and handling of radioactive or hazardous
substances is forbidden outside the areas foreseen and developed for this reason so as
to prevent any dispersal.

The disposal or storage areas for containers, as well as loading and unloading areas for
tanker-trucks and vehicles carrying mobile tanks which are likely to contain radioactive
or hazardous substances in significant quantities, must be equipped with retention
tanks.

 It is forbidden to burn outside in the open air

Art. 4.3.4. – It is forbidden to burn anything outside.

Workshop on INB Order dated 7th February 2012 Page 33

Title IV-Informing the ASN and the public

Informing the ASN without delay

 In the case of an abnormally high level of
radioactivity in the environment (Article 4.2.4)
 In the case of accidental pollution, all useful
information making it possible to determine the
measures designed to protect the interests (Art.
4.4.1)
Providing information regularly
 Electronic registers (Article 4.4.2)
 Monthly summaries (Article 4.4.2)
 Annual report before 30 December (Article
4.2.4)
Calculation of doses
Workshop on INB Order dated 7th February 2012 Page 34
Title V-Pressure equipment specially designed for INBs

An article is still pending

The intention to implement an integrated

approach that includes the risks represented
by nuclear pressure equipment

Workshop on INB Order dated 7th February 2012 Page 35

Title VI-Waste management
 Responsibility of the operator-
producer of waste  Interim storage must be
 Principles reversible, controlled and limited
in time
 Separation at source or as close
as possible to production  Accountancy and annual results
 Characterisation, packaging and  Application of specifications from
conditioning waste disposal outlets
 Meeting waste management  For outlets under investigation
objectives and plans as  conditioning subject to ASN
stipulated in the Environment approval
Code  Old waste
 Traceability  Reconditioning as quickly as
 Definition of a waste zoning plan possible
and characterisation of storage
areas
Workshop on INB Order dated 7th February 2012 Page 36
Title VII-Onsite emergency plan (Art 7.4)
Definition study for the onsite emergency plan
(scenarios)
DAC AND SAFETY In the safety report
REVIEWS

Presentation of representative scenarios

COMMISSIONING &
MODIFICATIONS
In the onsite emergency plan
art. 26  Criteria for trigger the plan + action sheets
 Material and organisational measures
 Coordination with external services and
organisations

Technical bases for the specific emergency plan

(hazardous th
areas)
Workshop on INB Order dated 7 February 2012 Page 37
 Title VII-Agreements and drills (Art. 7.5 & 7.6)

 Agreements
 Making external means available
 Alerting in the case of an external hazard
 Nearby neighbours (Tricastin, Marcoule, Saclay, ILL)
 External services and organisations (fire & rescue)
 Drills
 Proportional number (at least 1 per year)
 Annual testing of agreements
 Feedback
 Updating the onsite emergency plan
 Checking its relevance every 3 years or more if
necessary
 SEVESO directive (Art. 11.4)

Workshop on INB Order dated 7th February 2012 Page 38

3-Application of
Order dated 7 February 2012 to ITER –
INB

Workshop on INB Order dated 7th February 2012 Page 39

 PRELIMINARY WORK
• A Working Group within SQS since June 2012 to consider the application of
this new order
• A Working Group was set up also with the other nuclear operators (club
des exploitants) to define a common position for the application of this
order
– some discussions are still on-going between this group and the
regulator on the definition of “Protection Important Components”
(PIC)
– ITER guide for application of the INB Order was issued in March 2013
and sent to all IO and the DA’s
ITER_D_AW6JSB - Preliminary analysis of the impact of the INB order 7th
February 2012
– The list of documents to apply is available
– all the documents required to satisfy the Order are ready
• The actual ITER approach to Safety Important Class Structures Systems
and Components (SIC) will be kept as a sub-ensemble of PIC.
SPECIFIC INSTRUCTIONS ON THE APPLICABLE TEXTS WILL BE PROVIDED IN IO
Workshop on INB Order dated 7th February 2012 Page 40
The main tool for propagation of the safety
requirements:

“Order 10th AUGUST 1984”

…till 1st of July 2013

NOW:

“Order 7th February 2012”

Arrêté du 7 février 2012 fixant les règles générales relatives aux installations nucléaires de base

=
Order of the 7th February 2012 fixing the rules related to the nuclear facilities (INB)

Workshop on INB Order dated 7th February 2012 Page 41

 What are the implications of the INB Order on ITER project ?
o Management principles developed in the INB order

Integrated approach (compilation of the previous orders: QO 84,

31/12/99, 26/11/99)

Radiological and non radiological hazards with the same management

(already integrated in IO since 2009, for instance for Beryllium)

Graduated approach regarding the impacts to nuclear safety,

environment, public

Non-prescriptive regulation, it defines objectives. The means to satisfy

these objectives must be proposed by the nuclear operator to ASN

The supervision of the supplier chain must be endorsed by the nuclear

operator and cannot be subcontracted

Workshop on INB Order dated 7th February 2012 Page 42

Main wording changes
1- PROTECTION IMPORTANT COMPONENTS = PIC
 ALL THE PREVIOUS SAFETY IMPORTANT CLASS COMPONENTS are PIC
 PIC will have safety class SIC-1 OR SIC-2
 NON-PIC are previous NON-SIC among them we keep SR: Safety
Relevant components
2- PROTECTION IMPORTANT ACTIVITY = PIA
 ALL THE PREVIOUS QUALITY RELATED ACTIVITIES (QRA)

3-In the scope of the

• Procurement Arrangements,
• Task Agreements
• direct contracts
• Agreement with an university
• Expert contract
• Memorandum of understanding
• …
ITER ORGANIZATION = the NUCLEAR OPERATOR
The second party having signed the contract = the EXTERNAL CONTRACTOR

4-DEFINED REQUIREMENTS (Dreq) = SAFETY REQUIREMENTS (called Quality Définie in

the past)
4-DETAILED DEFINED REQUIREMENTS (DDR) = Expected characteristics (called Defined
requirements in the past)

Workshop on INB Order dated 7th February 2012 Page 43

 1st July
2013

Order 10th
INB-Order
August 1984
PIC, PIA
SIC, QRA

-in the new texts

-replace progressively in the

old ones when issuing new
versions

Workshop on INB Order dated 7th February 2012 Page 44

 LIST OF APPLICABLE DOCUMENTS
• Conformity with Order 7th February 2012
Most of the documents available in French  For ASN
in English For ITER

Workshop on INB Order dated 7th February 2012 Page 45