ASN Report 2018

∙ ∙ control of radiological zoning is progressing, although greater vigilance is required regarding the removal of signs by unauthorised staff. The prevalence of organisational shortcomings means that ASN is taking specific inspection measures to look at the links between the services competent in radiation protection and the other contributors to worker radiation protection, whether inside or outside EDF (see “Tightened inspections” box). In several NPPs, ASN observes the positive impact of allocating “zone managers” and the position of worker radiation protection supervisor during reactor outages. 2.8  ̶  Labour Law in the nuclear power plants 2.8.1  –  Monitoring Labour Law in the nuclear power plants ASN carries out labour inspectorate duties for the 58 reactors in operation (spread over the 19 NPPs), the eight reactors undergoing decommissioning and the EPR under construction at Flamanville. The number of people working in an NPP varies between 800 and 2,000 employees. The total number of staff assigned to all the nuclear sites is about 24,000 for the employees of EDF, and 23,000 for the employees of the subcontractors, which more specifically take part in maintenance during reactor outages. The role of the labour inspectorate is to ensure that the Labour Code as a whole is applied by the employers, whether EDF or its contractors. The labour inspectorate takes part in the integrated vision of regulation and oversight sought by ASN and it sees its monitoring work as being linked to other activities to monitor and oversee the safety of facilities and radiation protection. As at 31 December 2018, for its labour inspectorate duties, ASN’s staff was as follows: ∙ ∙ 16 labour inspectors, 4 of whom were undergoing training, assigned to its regional divisions; ∙ ∙ a labour director and deputy labour director in head office, responsible for running, coordinating and supporting the network of labour inspectors and providing the interface with the Ministry in charge of Labour. • Oversight of occupational health and safety With regard to occupational health and safety, the ASN labour inspections more specifically covered the following topics in 2018: ∙ ∙ The use of electrical installations. The inspections carried out on this topic on various sites led EDF to adopt an approach designed to restore compliance. ∙ ∙ The worksites with asbestos risks. The labour inspectors are particularly vigilant with regard to preventing the risk of inhalation of these fibres during their inspections and had to remind personnel of the regulations on several occasions. ∙ ∙ The conformity of working equipment and more specifically lifting gear. The collective measures taken in 2016 and 2017 led EDF to implement a compliance plan for this equipment. This plan is being closely monitored by the labour inspectors. ∙ ∙ The fire and explosion hazards, for which the ASN inspectors revealed non-conformities. ASN provides coordinated monitoring to take account of all aspects of these hazards, which are important both for worker safety and for nuclear safety (see point 2.4.6). Occupational accident inquiries are systematically held in the event of serious accidents or near-accidents. Three fatal accidents, caused by cardiac problems, unfortunately took place in 2018. • International subcontracting and provision of services Steps were taken in 2018 regarding the monitoring of notifications and the conditions for the secondment of staff from foreign companies, notably on the Flamanville EPR reactor construction site. In July 2018, ASN thus took part in action organised by the anti-fraud operational committee of the Manche département , coordinated by the Cherbourg District Court. • Criminal and administrative procedures in progress With regard to illegal work, ASN closely monitors the criminal proceedings instigated in previous years, more specifically through regular contacts with the Public Prosecutor’s offices. With regard to health and safety, the actions of the ASN labour inspectorate led in 2018 to the initiation of three criminal procedures against EDF or contractors concerning the electrical risk and the lack of suitable individual protection equipment for work in a confined space. A labour inspection concerned the incorporation of the EDF code of ethics into the in-house regulations of its NPPs. This inspection led to administrative decisions by the labour inspectorate requiring withdrawal from the internal regulations of the facilities concerned of the parts of the code of ethics which contradicted the provisions of the Labour Code. 2.8.2  –  Health and safety assessment, professional relations and quality of employment in the NPPs Certain occupational risk situations are still worrying and must be significantly improved: risks linked to work equipment and more particularly to lifting gear, the explosion risk and electrical risks. The labour inspectorate still observes situations in which the risk linked to the presence of asbestos is not systematically considered prior to the work, in order to avoid accidental exposure. Finally, progress is still required in the management of multiple contractors working simultaneously (quality of prevention plans in particular) and the use of subcontracting and the secondment of foreign employees. 2.9  ̶  Lessons learned from the accident in the Fukushima Daiichi NPP After the Fukushima Daiichi NPP accident, ASN issued a set of resolutions dated 5 May 2011 asking the licensees of major nuclear facilities to perform stress tests. ASN issued a position statement on the conclusions of these stress tests on 3 January 2012, which was itself subject to a European peer review, as part of the European stress tests, in April 2012. On the basis of the opinions of the Advisory Committee and the conclusions of the European stress tests, ASN issued a series of resolutions dated 26 June 2012 requiring that EDF implement: ∙ ∙ a “hardened safety core” of material and organisational measures which, in the event of an extreme external hazard, are designed to: ҃҃ prevent an accident with fuel melt, or limit its progression, ҃҃ limit large-scale radioactive releases, ҃҃ enable the licensee to carry out its emergency management duties; 304  ASN report on the state of nuclear safety and radiation protection in France in 2018 10 – EDF NUCLEAR POWER PLANTS