ASN Report 2020

2.6.2 Assessment of the working of the organisations and control of activities The overall organisation ASN considers that EDF correctly managed the changes to its organisations made necessary by the health measures linked to the Covid‑19 pandemic. Some of these changes were even beneficial to safety. This is the case with the steps taken to limit contacts with the control operators, which created a calmer atmosphere in the control rooms, and to extend the scheduled reactor outage durations, the effect of which was to reduce activity scheduling problems on certain sites. Over and above the particular problem of the health crisis, ASN carried out a campaign of “explanatory” interviews in 2020, during which the inspectors urged the site personnel to discuss their experience and their day-to-day working conditions. During the course of these discussions, ASN found that the personnel were on the whole satisfied with their working conditions, but it did identify recurrent failings liable to degrade the quality of the work done (schedule changes increasing the time pressure or waiting times, logistics problems, problems with the provision of tools and spares, inappropriate operational documentation, rooms and equipment to which access was sometimes difficult, etc.). In some cases, ASN observed working groups that were in difficulty, notably with regard to maintaining a balance between workload and resources, as well as the management of interfaces with the other disciplines (operating and maintenance disciplines, for example). In 2021, ASN will remain vigilant with regard to these points. It will ensure that these difficulties experienced on a day to day basis by certain personnel do not cause them to lose sight of the meaning of their activity and the contribution of their actions to safety, notably through a process whereby certain deviations gradually become the norm. Management of skills, training and qualifications The organisation put into place on the sites to manage skills, qualifications and training remained on the whole satisfactory in 2020, despite the difficulties linked to the Covid‑19 pandemic. ASN observed robust implementation and assimilation of the discipline baseline requirements on the sites (baseline requirements identifying the duties of each discipline and the corresponding training path) and relatively good working by the specific training programming and follow-up entities (common training service, training committees at several levels of the organisation). Integration into the site departments of various profiles dedicated to skills management (“training support”, “discipline coordinators”, etc.) is an efficient system for supporting and advising the managers. However, in 2020, ASN regularly found failings in the field of skills, notably with regard to assimilation of operational processes and documents, and the technical skills of certain personnel and monitoring supervisors (lack of technical familiarity with the equipment on which the contractors work). These shortcomings are particularly noticeable on the sites where there is significant workforce turnover. The scheduled ASN inspections in 2021 on the subject of skills will focus on these failings. Monitoring of subcontracted activities ASN considers that the quality of monitoring of subcontracted activities remained on the whole stable in 2020 for all the sites, by comparison with 2019. The progress observed on certain sites in terms of preparation for and application of the monitoring programmes is partly due to the correct assimilation of the new tool helping with the definition of monitoring programmes and performance of the monitoring actions. However, the monitoring procedures still reveal difficulties on certain sites (shortcomings in the monitoring of technical operations, difficulties with the transmission of defined requirements to certain contractors or, more generally, with making them aware of the issues linked to the sensitive activities). These difficulties imply that monitoring is not always an effective line of defence against potential failures by the contractors. They will remain a point of particular attention for ASN in 2021. Management of operational documentation ASN considers that the operational documentation could still be extensively improved in 2020. This is a recurring fundamental problem. Numerous analyses of significant events reported in 2020 still show problems relating to the operational documentation, regardless of the discipline concerned. The sites are still experiencing difficulties with providing the high- quality documents needed for satisfactory performance of the activities (inappropriate ergonomics, operating documents that are incomplete, overly generic or not up-to-date, operating procedures which do not take account of reactor states or site specificities, etc.). These weaknesses can be found in various operating domains, notably incident or accident operations, with regard to which significant improvements must be made to the documentation. On numerous sites, ASN also observes failings in the utilisation of the operational documentation (insufficient assimilation of the files, incomplete work follow-up files, incomplete lock-out conditions, risk assessments not covering the risks specific to the activity, etc.). These failings are to a large extent related to organisational malfunctions in the documentation creation and update process and they potentially compromise the documentary support line of defence. In 2021, ASN will remain vigilant with regard to these problems. The operating experience feedback process In recent years, all the NPPs have implemented a formal organisation and dedicated tools to oversee and coordinate internal and external operating experience feedback. By comparison with 2019, ASN observes some progress, but considers that this organisation must be further improved on the majority of sites. Failing persist in terms of detecting, reporting and processing difficulties encountered in the field, notably with respect to early warning signs. As in 2019, the encouragement given to the contractors to report positive or negative findings via the debriefings and dedicated tools remains insufficient and needs to be reinforced on a majority of sites. The analyses conducted by the sites further to significant events are generally relevant and the identification of organisational causes is progressing. However, as in 2019, the analysis of the root causes still all too often leads to relatively unambitious corrective measures, with no actual changes to the organisations. Finally, too many sites are still particularly limited when it comes to assessing the effectiveness of the corrective measures. In 2021, ASN will be particularly attentive to the operating experience feedback approach to be implemented by the licensee concerning its health crisis management and the conclusions that will be drawn with regard to the long-term adoption of certain new practices. The organisation of numerous disciplines, including operations, was indeed modified, entailing significant adaptations in the day-to-day activities and operations. 2.7  Personnel radiation protection 2.7.1 Monitoring of personnel radiation protection Exposure to ionising radiation in a nuclear power reactor comes primarily from the activation of corrosion products in the primary system and fission products in the fuel. All types of radiation are present (neutrons, α , β and γ ), with a risk of internal and external ASN Report on the state of nuclear safety and radiation protection in France in 2020 307 10 – THE EDF NUCLEAR POWER PLANTS 10