ASN Report 2020

∙ 3 organisations qualified for NPE and Simple Pressure Vessels (RPS) within the perimeter of BNIs (in-service monitoring); ∙ 19 inspection departments qualified for in-service monitoring of NPE and RPS within the perimeter of NPPs; 1. The intervention is the unit representative of activity traditionally used by the labour inspectorate. ∙ 67 laboratories for environmental radioactivity measurements covering 906 approvals, of which 259 are approvals or approval renewals delivered during 2020. 3. Efficient regulation and oversight 3.1  Inspection 3.1.1 Inspection objectives and principles The inspection carried out by ASN is based on the following principles: ∙ The inspection aims to verify compliance with the provisions that are mandatory under the regulations. It also aims to assess the situation with regard to the nuclear safety and radiation protection implications; it seeks to identify best practices, practices that could be improved and assess possible developments of the situation. ∙ The scope and depth of the inspection is adjusted to the risks inherent in the activity and the way they are effectively taken into account by those responsible for the activity. ∙ The inspection is neither systematic nor exhaustive; it is based on sampling and focuses on the subjects with the highest potential consequences. 3.1.2 Inspection resources implemented To ensure greater efficiency, ASN action is organised on the following basis: ∙ inspections, at a predetermined frequency, of the nuclear activities and topics of particular health and environmental significance; ∙ inspections on a representative sample of other nuclear activities; ∙ inspections of approved organisations. The inspections may be unannounced or notified to the licensee a few weeks before the visit. They take place mainly on the site or during the course of the activities (work, transport operation, etc.). They may also concern the head office departments or design and engineering departments at the major nuclear licensees, the workshops or engineering offices of the subcontractors, the construction sites, plants or workshops manufacturing the various safety-related components. ASN uses various types of inspections: ∙ routine inspections; ∙ reinforced inspections, which consist in conducting an in-depth examination of a targeted topic by a larger team of inspectors than for a routine inspection; ∙ in-depth inspections, which take place over several days, concern a number of topics and involve about ten or so inspectors. Their purpose is to carry out detailed examinations and they are overseen by senior inspectors; ∙ inspections with sampling and measurements. With regard to both discharges and the environment of the facilities, these are designed to check samples that are independent of those taken by the licensee; ∙ event-based inspections carried out further to a particularly significant event; ∙ worksite inspections, ensuring a significant ASN presence on the sites on the occasion of reactor outages or particular work, especially in the construction or decommissioning phases; ∙ inspection campaigns, grouping inspections performed on a large number of similar installations, following a predetermined template. Labour inspectorate work in the NPPs entails various types of interventions (1) , which more particularly involve: ∙ checking application of the Labour Code by EDF and outside contractors in the NPPs (verification operations that include inspections); ∙ participation in meetings of the Health, Safety and Working Conditions Commissions, created as of 2020 for EDF, of Social and Economics Committees and the Inter-company Committees on safety and working conditions (EPR construction site); ∙ conducting inquiries on request, following complaints or based on information, following which the inspectors may take decisions as specified by the labour regulations, such as cessation of the works or the obligation to have the work equipment verified by an accredited organisation. The implementation of remote-inspection methods during the health crisis led ASN to modify the inspection indicators. For this type of inspection, the critical examination of documents transmitted by a nuclear activity manager, performed during the on-site inspection preparation phases, becomes the primary method. It is then no longer possible to differentiate between the preparation of the inspection, involving this documentary examination, and the inspection itself. The following paragraphs will therefore present the number of inspector-days corresponding to the on-site inspections and the number of remote inspections. The number of inspector-days in these paragraphs cannot therefore be directly compared with that of previous years, because it only reflects the time spent on the site and does not take account of the remote inspections. In addition, Table 6 presents the total number of inspector-days devoted to inspections, whether performed on-site, remotely, or using a combination of the two methods. ASN sends the licensee an inspection follow-up letter, published on asn.fr , which officially documents: ∙ deviations between the situation observed during the inspec­ tion and the regulations or documents produced by the licensee pursuant to the regulations; ∙ anomalies or aspects warranting additional justifications; ∙ best practices or practices to which improvements could be made, even if not directly constituting requirements. Any non-compliance found during an inspection can lead to administrative or criminal penalties (see point 6.2). Some inspections are carried out with the support of an IRSN representative specialised in the facility checked or the topic of the inspection. 152 ASN Report on the state of nuclear safety and radiation protection in France in 2020 03 – REGULATION OF NUCLEAR ACTIVITIES AND EXPOSURE TO IONISING RADIATION