ASN Report 2018

In 2019, ASN will continue its oversight of the prevention of pollution and detrimental effects, the control of environmental discharges and waste management. 2.6  ̶  Prevention and control of organisational risks The contribution of people and organisations to the safety of NPPs is a decisive factor in all steps of the lifecycle of the facilities (design, construction, commissioning, operation, decommissioning). ASN therefore focuses on the conditions which are favourable or prejudicial to a positive contribution to NPP safety by the operators and worker groups. It defines Social, Organisational and Human Factors (SOHF) as being all the aspects of working situations and of the organisation that will have an influence on the work done by the operators. 2.6.1  –  Monitoring how organisations works • The Integrated Management System The Order of 7 February 2012 stipulates that the licensee must in particular have the technical skills needed to manage the activities. Of these, the processing of significant events requires an in-depth analysis of the organisational and human causes in addition to the technical causes. Furthermore, the above-mentioned Order requires the licensee to define and implement an Integrated Management System (IMS) to ensure that the requirements concerning the protection of interests are systematically considered in any decision concerning the facility. This IMS must specify the steps taken with regard to organisation and to resources of all types, in particular those adopted to manage the activities important for the protection of persons and the environment. ASN monitoring of the working of EDF’s organisations put into place by EDF focuses on how the IMS is implemented. ASN more particularly ensures that the design or modification approach adopted by the engineering centres when a new facility is designed or an existing facility is modified takes account of the users’ needs and does not compromise compliance with the defined requirements. More broadly, ASN checks the organisation put into place by EDF to manage the resources needed to perform these activities. • Control of subcontracted activities Maintenance and modification activities on French reactors are to a large extent subcontracted by EDF to outside contractors. EDF justifies the use of subcontracting by the need to call on specific or rare expertise, the highly seasonal nature of reactor outages and thus the need to absorb workload peaks. EDF’s decision to resort to subcontracting must not compromise the technical skills it needs to retain in-house in order to carry out its licensee’s responsibility for the protection of interests and be able to effectively monitor the quality of the work performed by the subcontractors. Poorly managed subcontracting is liable to lead to poor quality of work and have a negative impact on the safety of the facility and the radiation protection of the workers involved. EDF takes the necessary steps to control the risks associated with the subcontracted activities and regularly updates them. EDF has thus reinforced the preparation of outages, more particularly to guarantee the availability of human and material resources. ASN checks the conditions surrounding the preparation for (schedule, required human resources, etc.) and performance of the subcontracted activities (relations with the licensee, monitoring by the licensee, etc.). It also checks that the workers involved have the means necessary (tools, documentation, etc.) for the performance of the tasks, in particular when these means are made available by EDF. Tightened environmental inspections The “tightened” inspection campaigns carried out by ASN are a particular inspection format with a broader scope of inspection. They allow an overall assessment on a given topic for an entire site and a geographical area. Since 2015, ASN has carried out this type of inspection once per year on the topic of environmental protection. After the sites on the Loire Valley, those of the Rhone Valley and the Chooz and Cattenom NPPs, the NPPs of Le Blayais, Golfech and Civaux underwent tightened inspections in March and April 2018. Using a similar inspection programme of a day and a half, a team of ASN inspectors, accompanied by IRSN experts, examined the environmental protection organisation of each of these NPPs in turn. The large size of the team (up to sixteen ASN inspectors and three IRSN experts per site) enabled the control of discharges, waste management and pollution prevention measures to be inspected. On each of the sites, the duration of the inspection made it easier to hold large-scale exercises and simulations. Thus, at the request of ASN, each site tested its pollution prevention organisation by means of an exercise simulating a spillage of dangerous substances reaching the rainwater collection network. Although the inspectors found that the EDF teams had taken account of certain points raised by ASN in previous years, these inspections nonetheless showed that a general improvement is needed in the way the environmental protection issue is dealt with. In addition, the ineffectiveness of the pollution confinement strategy on the Civaux NPP, observed during the spillage exercise, led ASN to instruct EDF to reinforce its pollution confinement management resources. After the inspection campaign, the licensee therefore drew up an action plan for which ASN will continue to monitor the implementation. 300  ASN report on the state of nuclear safety and radiation protection in France in 2018 10 – EDF NUCLEAR POWER PLANTS