ASN Report 2020

Prevention of the health impacts caused by the growth of legionella and amoeba in certain cooling systems of the Nuclear Power Plant secondary systems Certain NPP cooling systems constitute environments favourable to the development of legionella and amoeba (see point 1.4). ASN resolution 2016-DC-0578 of 6 December 2016 on the prevention of risks resulting from the dispersal of pathogenic micro-organisms (legionella and amoeba) by PWR secondary system cooling installations sets requirements concerning: ∙ the design, upkeep and monitoring of the facility; ∙ the maximum legionella concentrations in the water in the facility and downstream of it with regard to amoeba; ∙ the steps to be taken in the event of proliferation of micro­ organisms in the systems, or infection, identified in proximity to the facility; ∙ information of the public and the administrations in the event of proliferation of micro-organisms. Through file reviews and its field checks, ASN closely monitors the preventive or remedial measures taken by EDF to reduce the risk of the proliferation of these micro-organisms and the results of these actions, including the chemical discharges resulting from biocidal treatment. 2.5.3 Assessment of control of detrimental effects and impact on the environment Assessment of prevention of detrimental effects, control of environmental discharges and waste management In 2020, ASN carried out inspections on the control of detrimental effects and the environmental impact of NPPs, mainly concerning the prevention of pollution and detrimental effects, control of environmental discharges and waste management. EDF’s organisation for controlling the detrimental effects and impact of NPPs on the environment needs to be improved on most sites and ASN considers that the licensee needs to raise its level of vigilance on this topic. Although ASN observes improved assimilation by the sites of the methodical analyses of the microbiological risks and efforts to improve the containment of dangerous liquid substances on certain sites, it nonetheless considers that corrective measures are still needed with respect to pollution prevention and waste management. EDF has defined a national action plan on this latter subject. Inadequacies in the containment of dangerous liquid substances, observed during inspections in 2018 and 2019, led ASN to ask EDF for a review of all the NPPs. The information communicated offers a satisfactory level of detail on the current situation of the sites. ASN asked EDF to inform it of the steps it intends to take to improve the situation on each of the sites. In 2020, as in previous years, ASN observed that discharges are well managed on most of the sites. However, certain events indicate occasional weaknesses In January 2020, ASN served EDF with formal notice to transmit certain data required by its resolution 2013-DC-0360 concerning the Blayais, Bugey, Chinon, Chooz, Cruas-Meysse, Gravelines and Saint-Laurent-des-Eaux sites. EDF had not enclosed the following with the concluding report for the periodic safety review of certain installations: ∙ an analysis of the performance and the means for preventing and mitigating impacts and detrimental effects of the installation in the light of the effectiveness of the best available techniques; ∙ an analysis of the chemical and radiological status of the environment of the installation and its immediate vicinity. EDF met the 2020 deadlines stipulated in this formal notice. 2.6  The contribution of man and organisations to safety The contribution of people and organisations to the safety of NPPs is a decisive factor in all steps of the plant lifecycle (design, construction, commissioning, operation, decommissioning). ASN therefore focuses on the conditions which are favourable or prejudicial to the contribution to NPP safety by the operators and worker groups. It defines the Organisational and Human Factors (OHF) as being all the aspects of working situations and the organisation which will have an influence on the work done by the operators. 2.6.1 Monitoring how organisations work The Integrated Management System The Order of 7 February 2012 stipulates that the licensee must in particular have the technical skills needed to manage the activities involved in operation. Of these, the processing of significant events requires an in-depth analysis of the organisational and human causes in addition to the technical causes. Furthermore, the above-mentioned order requires that the licensee define and implement an Integrated Management System (IMS) to ensure that the requirements concerning the protection of interests are systematically considered in any decision concerning the facility. This IMS must specify the steps taken with regard to organisation and to resources of all kinds, in particular those adopted to control the activities important for the protection of persons and the environment. ASN oversight of the working of the organisations set up by EDF aims to check the IMS implementation procedures. ASN more particularly ensures that the design or modification approach adopted by the engineering centres at the moment of the design of a new facility or a modification to an existing facility takes account of the users’ needs and does not compromise compliance with the defined requirements. More broadly, ASN monitors the organisation put into place by EDF to manage the resources needed to perform these activities. Management of subcontracted activities Maintenance and modification activities on French reactors are to a large extent subcontracted by EDF to outside contractors. EDF justifies the use of subcontracting by the need to call on specific or rare expertise, as well as the highly seasonal nature of reactor outages and thus the need to absorb workload peaks. EDF’s decision to resort to subcontracting must not compromise the technical skills it must retain in-house in order to carry out its responsibility as licensee with regard to the protection of persons and the environment and to be able to effectively monitor the quality of the work performed by the subcontractors. Poorly managed subcontracting is liable to lead to poor quality work and have a negative impact on the safety of the facility and the radiation protection of the workers involved. EDF takes the necessary steps to control the risks associated with the subcontracted activities and regularly updates them. EDF has thus reinforced the preparation of outages, more particularly to guarantee the availability of human and material resources. ASN checks the conditions surrounding the preparation for (schedule, required human resources, etc.) and performance of the subcontracted activities (relations with the licensee, monitoring by the licensee, etc.). It also checks that the workers involved have the means needed (tools, operating documentation, etc.) to perform their tasks, in particular when these means are made available by EDF. 306 ASN Report on the state of nuclear safety and radiation protection in France in 2020 10 – THE EDF NUCLEAR POWER PLANTS