ASN Report 2020

exposure. In practice, more than 90% of the doses received come from external exposure to ß and γ radiation. Exposure is primarily linked to maintenance operations during reactor outages. ASN monitors compliance with the regulations relative to the protection of workers liable to be exposed to ionising radiation in NPPs. In this respect, ASN is attentive to all the workers on the sites, both EDF personnel and those of contractors. This oversight is carried out during inspections (specifically on the topic of radiation protection, one to two times per year and per site, during reactor outages, following incidents, or more occasionally in the EDF head office departments and engineering centres), and on the occasion of the review of files concerning occupational radiation protection (significant events, design, maintenance or modification files, EDF documents implementing the regulations, etc.) with the support of the IRSN as applicable. Periodic meetings are held with EDF as part of the technical dialogue with the licensee. They enable ASN to check the progress of technical or organisational projects being run to improve radiation protection. Significant contamination events The number of significant contamination events concerning workers in the NPPs operated by EDF remained at a high level in 2020: eight events (including one concerning the Fessenheim NPP) were reported in 2020, as compared with seven events in 2019 and two in 2018. These events, which led to exposure greater than one quarter the annual regulation limit per square centimetre of skin, were rated level 1 on the INES scale. The procedure adopted by EDF, which consists in removing the contaminating particles with a wipe as soon as they are detected was implemented in most of these cases and helped reduce the time the workers were exposed. ASN also observes that the wearing of surgical masks, made mandatory owing to the health situation, is liable to increase the number of reflex hand movements towards the face and thus the risk of transferring a radioactive particle to the face or neck of the workers. ASN will continue its inspections on this topic in 2021, more particularly with regard to the procedures for providing care for those contaminated and preventing the dissemination of radioactive contamination. 2.7.2 Assessment of personnel radiation protection The collective dose on all the reactors fell in 2020 by comparison with 2019 (Graph 5), as did the average dose received by the workers for one hour of work in the controlled area (Graph 7). The doses received by the workers are broken down as illustrated below in Graphs 3 and 4. Graph 6 shows the breakdown of the workers according to whole body external dosimetry. It can be seen that the dosimetry for 75% of the exposed workers is less than 1 mSv (millisievert) for the year 2020, which corresponds to the annual regulation limit for the public. The annual regulation limit for whole body external dosimetry (20 mSv) was exceeded on no occasion in 2020. Graph 7 shows the trend in whole body average individual dosimetry according to the categories of workers in the NPPs. The most exposed worker categories in 2020 are personnel in charge of heat insulation, welding, monitoring, mechanical work and ancillary systems. The doses recorded by the most exposed workers are down on 2019. Despite these results, ASN found that the regression in worker radiation protection already observed in 2019, worsened in 2020. This notably concerns the application of radiation protection rules and the consideration of worker protection when planning the activities. Shortcomings are in particular observed in the implementation of processes for access to and demarcation of operation areas and prohibited areas, in which the dose equivalent rate is liable to be higher than 100 millisieverts per hour (mSv/h). They reflect an inadequate perception of the radiological risks and an inappropriate radiation protection culture. During the inspections carried out during reactor outages, the ASN inspectors repeatedly submit requests regarding the availability of radiation protection equipment, and regarding risk and dose optimisation assessments. They nonetheless underline the fact that steps have been taken to remedy the deviations observed, notably with regard to dose optimisation. The drop in the standard of radiation protection is particularly flagrant in certain NPPs. For these NPPs, ASN has reinforced its monitoring. It observes that the steps taken by EDF are not fully bearing fruit, notably with regard to the correction of organisational deviations. ASN will be remaining vigilant on these issues during the course of 2021. 2.8  Labour Law in the Nuclear Power Plants 2.8.1 Oversight of Labour Law in the Nuclear Power Plants ASN is responsible for labour inspectorate duties in the 18 NPPs, the EPR reactor under construction at Flamanville and 11 other installations, most of which are reactors undergoing decommissioning. The workforce in an NPP varies between 800 and 2,000 people. The total number of staff assigned to all the nuclear sites is about 24,000 for the employees of EDF, and 23,000 for the employees of the subcontractors, who more specifically take part in maintenance during reactor outages. The role of the labour inspectorate is to ensure that the Labour Code as a whole is applied by the employers, whether EDF or its contractors. The labour inspectorate takes part in the integrated vision of oversight sought by ASN and carries out its monitoring work in conjunction with the other activities to monitor and oversee the safety of facilities and radiation protection. In 2020, the ASN resources for its labour inspectorate duties were: ∙ 15 labour inspectors, 4 of whom were undergoing training, assigned to its regional divisions; ∙ a labour director and deputy labour director in head office, responsible for running, coordinating and supporting the network of labour inspectors and providing the interface with the Ministry in charge of labour. Oversight of occupational health and safety regulations Throughout the year 2020, and more particularly during the lockdown periods, the ASN labour inspectors were in great demand from the employers, the staff, the EDF or contractor personnel representatives, regarding the protection measures to be implemented on the workplace to deal with the health crisis, and the conditions for the continuity of their activities on the sites. The labour inspectorate provided considerable support by supplying information and explanations regarding the Government measures to the employers and the health, safety and working conditions commissions of the social and economic committees. Specific actions were taken on the sites and notably concerned: ∙ monitoring of the updating of the activity continuity plans and the consolidated occupational risk assessment documents; ∙ monitoring of the quality of the protection masks and personal protection equipment made available to the staff; 308 ASN Report on the state of nuclear safety and radiation protection in France in 2020 10 – THE EDF NUCLEAR POWER PLANTS