ASN Report 2018

2.6.2  –  Evaluation of the working of the organisations and control of activities In 2018, ASN in certain cases observed inappropriate working environments. In terms of organisation, this sometimes takes the form of a disparity between the workload and the available workforce, excessive time pressure or joint-contractor work in conditions that are not always satisfactory. In ergonomic terms, ASN regularly observes cramped premises, poor ventilation, degraded lighting, non-conforming scaffolding, or barely legible equipment identification. In equipment terms, this means missing or inappropriate operating documents, tools or spare parts. These recurring problems can be partly ascribed to more deep-rooted organisational causes, for example degraded relations between the site and the contractor responsible for logistics, delays in the preparation of the work, difficulties in obtaining working conditions or inefficient coordination between trades. In 2018, ASN observes that the vast majority of the NPPs are making real efforts to reinforce the application of error- reduction practices by all those involved (pre-job briefing, stop and think phase, self-checks, cross-checks, secure communication, debriefing), but that the results differ considerably from one site to another. The “immediate” debriefing which takes place immediately after the end of the work, remains the weak point on most sites and is prejudicial to the creation of operating experience feedback which could be beneficial for future activities. ASN also considers that in a certain number of significant event reports, the inadequacies observed in the application of these practices are over-estimated by the analysts, which runs the risk of creating a blinkered view of the situation, simply pinpointing the responsibility of the persons involved and hiding the deeper human or organisational causes (time pressure, inappropriate working environment, etc.). For all the NPPs, EDF must improve its control of the operational documentation. The cause of many significant events reported in 2018 is operational documentation that is hard to use (poor legibility, lack of consistency between the various documents, lack of diagrams or photos, etc.), or inappropriate (incomplete or obsolete documentation, procedures which do not take account of the reactor states, etc.). In the face of these findings, ASN decided to reinforce its monitoring of EDF’s organisations and defined documentation management as one if its inspection priority topics for 2019. • Skills, training and qualifications management The organisation in place on the sites for managing skills, qualifications and training remains on the whole satisfactory. On most of the sites, the steps taken to manage skills are satisfactory in that employment and skills are managed with four to five years of visibility and arrivals in and departures from the various departments are planned in advance. Skills are acquired and maintained by means of training (training worksites, training and refresher courses, tutoring and mentoring with simulation work) that is appropriate and well followed. In 2018, on a few sites, ASN nonetheless observed the difficulties experienced by certain departments with formally identifying rare and sensitive skills and with maintaining adequate means and human resources for the work to be performed over the course of the year. Moreover, the ASN inspectors sometimes found the technical skills of certain staff members to be insufficient (lack of knowledge of equipment leading to equipment unavailability, out of date knowledge of equipment which has been modified, monitoring supervisors with insufficient technical expertise of the subjects being monitored, and so on). ASN finds that the weak points identified on these sites, some of which contributed to significant events, can be explained by sometimes inadequate training or mentoring (notably new hardware and software installed and changes to the regulations) or insufficiently rigorous monitoring of the clearances and qualifications required for the contractors. • Monitoring of subcontracted activities In 2018, ASN observes that the monitoring processes for subcontracted activities still indicate difficulties on a certain number of sites. These difficulties are persisting despite a clearly stated commitment on the part of the site managements (awareness-raising, seminars, management presence in the field, deployment of a new tool to facilitate the preparation of monitoring programmes, etc.). The origins of these shortcomings can be ascribed to difficulties in guaranteeing the long-term availability of the resources assigned to contractor monitoring and to monitoring supervisors who do not always have the necessary technical skills for the subject being monitored. ASN is encouraging EDF to continue with its actions to promote the presence of staff in the field and develop their ability to detect anomalies. ASN nonetheless finds that progress was observed in 2018 in terms of preparation of the monitoring programmes. The monitoring supervisors highlight the contribution of the new tool currently being deployed in all the plants and which enables them to save time and be more efficient. Tightened radiation protection inspections Since 2011, ASN has carried out tightened inspections on the subject of protection of workers against ionising radiation. The Bugey, Cruas-Meysse, Saint-Alban/Saint-Maurice and Tricastin NPPs, located in the Rhone Valley, were the subject of a tightened inspection campaign in September and October 2018. Simulations were used to check the organisation for dealing with contaminated workers and processing atmospheric contamination detection alarms inside the reactor building. An unannounced night-time inspection of the steps taken to ensure the radiation protection of workers during a reactor outage was also carried out. The inspectors observed that the teams on the sites had taken account of certain points raised by ASN in previous years and that good practices were implemented. However, they did note that in certain NPPs, the synergy between the department in charge of the prevention of radiological risks and the operational departments needs to be strengthened so that the radiation protection advisor can carry out the tasks entrusted to them by the Labour Code. This point will be given particular attention by ASN during the forthcoming examination of the applications for approval of the radiation protection centres of expertise required by Article R. 4451-125 of the Labour Code. ASN report on the state of nuclear safety and radiation protection in France in 2018  301 10 – EDF NUCLEAR POWER PLANTS 10