In addition, every year, each site sends ASN a summary report on its production of waste and the corresponding disposal routes, a comparison with the results of previous years, a summary of the site organisation and the differences observed with respect to the management procedures specified in the waste management study, the list of significant events which have occurred and the outlook for the future. 2.5.2 Prevention of soil pollution and health impacts Prevention of pollution resulting from accidental spillage of dangerous substances As with numerous industrial activities, the operation of an NPP involves the handling and storage of dangerous chemical substances. The management of these substances and the prevention of pollution, which are the responsibility of the licensee, are regulated by the Order of 7 February 2012 and ASN resolution 2013-DC-0360 of 16 July 2013 and must also comply with the requirements of the European texts. The licensee has obligations regarding the operational management of these substances and the identification of the corresponding potential hazards. It must also be able to take the necessary steps in the event of any incident or accident situations which would lead to pollution. The licensee must thus for instance precisely identify the location of each dangerous substance on its site, along with the corresponding quantities. Drums and tanks must be labelled in compliance with the European “Classification, Labelling, Packaging” (CLP) regulation and there must be retention areas designed to collect any spills. The NPPs must also adopt an organisation and resources to prevent pollution of the natural environment (groundwater, river, soil). For several years and at the request of ASN, EDF has been carrying out steps to improve its management of the pollution risk by working to improve the confinement of dangerous liquid substances on its sites. Prevention of the health impacts caused by the growth of legionella and amoeba in certain cooling systems of the NPP secondary systems The cooling systems of nuclear reactors equipped with a cooling tower are environments favourable to the development of legionella and other amoeba (see point 1.4). EDF monitors the legionella and amoeba concentrations and takes preventive measures and, if necessary, remedial measures in accordance with the provisions of ASN resolution 2016-DC-0578 of 6 December 2016 on the prevention of risks resulting from the dispersion of pathogenic micro-organisms (legionella and amoeba) by the cooling installations of the system. For most of these reactors, preventive and remedial measures to limit the development of legionella and amoeba are based on the injection of a biocidal product (monochloramine) into the cooling system. 2.5.3 Assessment of control of detrimental effects and impact on the environment ASN monitors the organisational and material provisions adopted by EDF to manage the dangerous substances present in its facilities and to deal with any pollution. In 2021, ASN carried out a campaign of inspections on the organisation of 11 NPPs and their ability to confine dangerous substances in an accidental spillage scenario. These inspections, which were primarily based on field checks, consisted of an unannounced situational exercise that was identical for all the NPPs. Most of the NPPs inspected have an organisation and means enabling them to confine a large volume of pollution. These inspections were also able to identify the corrective measures to be implemented rapidly in each facility. EDF must also continue with the extensive work it has undertaken to reinforce the confinement capacity on certain sites. ASN also ran a campaign of inspections on the NPPs emitting the most sulphur hexafluoride (SF6), a gas with a significant greenhouse effect. This gas is used in the NPPs as an electrical insulator in electricity distribution equipment. During this in– spection campaign, ASN verified that EDF had implemented an action plan to deal with sources of leaks. The organisation and the correction plan put in place by the NPPs, based on prevention, detection and reactive repair resources, are satisfactory. ASN considers that EDF must remain fully mobilised to implement this action plan. In 2021, as in previous years, ASN observed that discharges are well managed on most of the sites. However, certain events indicate occasional weaknesses. Finally, with regard to waste management, the inspections carried out by ASN reveal that operational management of waste needs to be further improved. During its inspections, ASN also found missing signage, non-compliance with operating baseline requirements, notably on the outside areas, and waste storage in unauthorised zones. 2.6 The contribution of man and the safety organisations 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). 2.6.1 The operation of organisations The Integrated Management System The Order of 7 February 2012 stipulates that the licensee must 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, this 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. 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 reactor outages, more particularly to guarantee the availability of human and material resources. 298 ASN Report on the state of nuclear safety and radiation protection in France in 2021 10 – THE EDF NUCLEAR POWER PLANTS
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