ASN Report 2018

∙ ∙ ensuring that the start-up tests programme is complete, that the tests are correctly performed and that the deviations brought to light are dealt with; ∙ ∙ ensuring that the licensee take the necessary steps so that the teams in charge of operating the installation after commissioning are well-prepared. To do this, ASN has set binding requirements regarding the design, construction and start-up tests for the Flamanville NPP EPR reactor and for operation of the two reactors 1 and 2 close to the construction site. As this is a nuclear power reactor, ASN is also responsible for labour inspectorate duties on the construction site. Finally, ASN oversees the manufacture of the NPE that will form part of the primary and secondary systems of the nuclear steam supply system. The main steps taken by ASN in 2018 are described below. • Oversight of the construction, assembly and test activities on the Flamanville EPR reactor site In 2018, ASN carried out twenty inspections on the Flamanville EPR reactor construction site to monitor construction, the performance of the start-up tests and the preparedness of the teams who will be in charge of operating the reactor. These in particular concerned the following technical topics: ∙ ∙ mechanical assembly activities, notably concerning the secondary systems of the NSSS, the main primary system protection valves, the nuclear auxiliary systems, the containment mechanical penetrations, the effluent treatment systems and the equipment necessary for operation of the backup electricity generating sets. In 2018, ASN notably checked the compliance of the main secondary systems (see introduction to this report), following EDF’s notification of two significant safety events; ∙ ∙ the electrical systems installation activities, including cable connections in the buildings; ∙ ∙ preservation of equipment and structures present on the construction site until commissioning of the reactor. Owing to the postponements announced by EDF, ASN ensures that EDF continues to pay particular attention to defining and complying with the requirements relating to the preservation of the equipment already installed and the structures already built, notably taking account of water filling of systems for the hydrotests and start-up tests; ∙ ∙ continuation of start-up tests, in particular during the first tests of the installation as a whole. ASN has tightened up its oversight of these tests, which must help demonstrate that the structures, systems and components of the reactor meet the requirements assigned to them. ASN pays particular attention to the organisation put into place to guarantee that the tests are representative and traceable; ∙ ∙ the environmental impact of the construction site, in particular the management of buried waste discovered on the site in 2017, preparation for operation, taking account of the management of conventional and nuclear waste, control of environmental risks and the consideration of the new binding requirements issued by ASN regarding water intake and discharges for the Flamanville reactors; ∙ ∙ the radiation protection of workers during radiographic inspection of welds; ∙ ∙ preparations for operation by the EDF entity that will be in charge of operating the Flamanville EPR after its start-up. This entity currently comprises more than 400 staff. With a view to reactor commissioning, EDF is continuing with a process of gradual transfer of responsibility for the operation of the structures, systems and components from the entity in charge of reactor construction and start-up operations to the entity in charge of its future operation. Through its oversight, ASN verifies that the future operating staff take advantage of operating experience and best practices employed in EDF’s NPPs and that they correctly assimilate the working of the equipment during reactor construction and systems start-up tests. ASN also ensures that these preparations for operation are completed before actual commissioning of the reactor. Furthermore, given the importance of the start-up tests in the facility’s safety case, ASN carried out a tightened inspection on this topic in October 2018. • Oversight of the Flamanville EPR engineering activities In 2018, ASN focused its inspections in the EDF engineering departments on the topics of managing the deviations encountered and advance preparation for the operations phase. In 2018, ASN therefore carried out inspections in the EDF engineering departments responsible for the detailed design studies of the Flamanville NPP EPR reactor, on the topic of equipment qualification, management of deviations and the modifications to be implemented after commissioning of the installation. • Labour inspectorate duties on the Flamanville EPR reactor construction site The actions carried out by the ASN labour inspectors in 2018 consisted in: ∙ ∙ performing checks on the contractors working on the site; ∙ ∙ answering direct queries from the employees; ∙ ∙ carrying out inquiries following occupational accidents; ∙ ∙ investigating or jointly investigating requests for exemptions to provisions under the labour regulations. Application of the safety rules was regularly checked. In 2018, the ASN labour inspectors also initiated and carried out a number of checks on the regulatory provisions governing transnational secondment of workers. • Oversight of NPE design for the Flamanville EPR reactor During the course of 2018, ASN continued to assess the conformity of manufacture of the NPE for the main primary and secondary systems. Having observed inadequate justification and incomplete design files for this equipment, more specifically with regard to the risk assessments, choice of materials and in-service inspectability of the equipment, ASN held numerous technical meetings with Framatome (formerly Areva NP) in 2013 and 2014 to define the additional data to be provided. Framatome began a revision of all technical design documentation for this equipment in 2015, completing it in 2018. “Air” testing of the fuel loading machine ASN report on the state of nuclear safety and radiation protection in France in 2018  311 10 – EDF NUCLEAR POWER PLANTS 10