Abstracts ASN Report 2019

ASN ASSESSMENTS PER LICENSEE AND BY AREA OF ACTIVITY In order to combat the risk of fraud, EDF has adapted its inspection practices, in particular by making greater use of unannounced or cross-inspections. ASN considers that EDF must nevertheless step up its actions in order to prevent abnormalities within its own organisations. Maintenance As a general rule, most of the NPPs are adequately organised to successfully carry out large-scale maintenance operations. In a context of a high maintenance workloads, due in particular to the continued operation of the reactors and the “ Grand Carénage ” major overhaul programme, ASN has in the past regularly drawn EDF’s attention to the persistence of an excessively large number of maintenance quality deficiencies. Over the last few years EDF has put in place action plans to reduce their occurrence. However, ASN finds that these have not been sufficiently effective. EDF must therefore learn from this and increase its professional rigour in maintenance operations. Several of these maintenance quality deficiencies result from operators losing sight of the fact that their actions contribute to safety, or from applying the maintenance procedures incorrectly or even applying inappropriate procedures. The operators still have to deal with constraints linked to work organisation, such as insufficient preparation for certain activities, unplanned scheduling changes and problems with worksite coordination. ASN in 2019 has again noted very high levels of fouling in certain internal structures of the Steam Generators (SG) of several reactors, which could impair their operating safety. These fouling levels are the result of maintenance that was insufficient to guarantee satisfactory cleanness. Further deterioration associated with the ageing of certain items of equipment, particularly SG internal structures, was also detected in 2019. ASN considers that EDF must therefore adapt the level of stringency of its in-service monitoring and look ahead to the development of repair processes. ASN regularly notes EDF’s difficulty in ensuring appropriate and proportional monitoring of subcontracted activities, whether the activities are performed on site or at the suppliers of goods and services. This being said, in 2019 ASN saw an improvement in the technical oversight of subcontracted operations and service provider monitoring, particularly through the use of computer aids recently deployed in the NPPs. Operation ASN observes organisational weaknesses on some sites and losses of know-how. These difficulties are increased on the sites which have had to carry out a ten-yearly outage due to the fact that these outages involve deploying substantial resources and lead to significant changes in the facilities and their baseline operating requirements. In 2019, the ASN inspections highlighted the need for closer monitoring of the activities of operational control operators. At several NPPS the average time taken to detect a breach of the operational management rules is too long. Despite this, the operators seem to know the reactor operational control rules, even though they have undergone relatively frequent changes over the last few years. ASN therefore considers that the analysis of these deviations must focus on their root causes and that EDF must be particularly attentive to the verification of the actions of the operational control teams. As in 2018, EDF encountered difficulties during the post- outage reactor restarts. Furthermore, the majority of the sites need to improve the scheduling and performance of the periodic tests and the analysis of their results. More particularly, ASN’s inspectors on several occasions found incorrect conclusions regarding equipment availability following periodic testing. EDF has initiated improvement measures, the effects of which are not yet measurable. The inspections ASN carried out in 2019 in the area of operational management in the event of an accident placed the operators in simulated accident situations. Although the operators showed that they knew the technical actions to carry out, ASN’s inspections revealed that in some cases these actions cannot be accomplished within the required times, or even cannot be carried out at all due to the configuration of the facilities. In other cases, the instructions did not take into account the actual status of the facility. EDF initiated an action plan in mid-2019, and its first effects can already be seen. In recent years, EDF has reinforced its organisation for controlling hazard-related risks, such as the organisation put into place to detect and eliminate the risk of objects falling in the event of an earthquake. However, ASN regularly observes that the steps taken by EDF to prevent hazards and mitigate their consequences need to be further improved. This is the case in particular with the provisions for explosion risks, for which some maintenance and inspection actions are not implemented satisfactorily. As in 2018, the ASN inspections focusing on the organisation and emergency resources confirmed that the organisation, preparedness and management principles for emergency situations covered by an on-site emergency plan have been correctly assimilated. The analyses conducted by the sites further to significant events are generally appropriate and the identification of organisational causes is getting better. However, these analyses often result only in corrective actions that are limited to one-off awareness-raising measures targeting the employees, services or companies identified as being the cause of the deviation. Protection of the environment EDF’s organisation for controlling the detrimental effects and impact of the NPPs on the environment needs to be improved on most sites. ASN considers that the licensee needs to raise its level of vigilance on these topics. EDF must more specifically improve the integration of the regulatory provisions relating to pollution prevention, particularly regarding the containment of hazardous liquid substances. Despite some occasional weaknesses, EDF has shown a good level of control over its process for managing effluent discharges. With regard to waste management, ASN observes the continuing improvements in EDF’s organisation, but remains vigilant regarding the various sites’ compliance with regulations. Worker radiation protection and occupational safety ASN notes an overall deterioration in the way radiation protection is taken into account in the NPPs. The significant events analyses often show in particular an inadequate perception of the radiological risks. ASN has nevertheless noted improvements in the implementation of means of cordoning off worksites. ASN Report on the state of nuclear safety and radiation protection in France in 2019 9