2.6.2 Assessment of the operation of the organisations and control of activities ASN 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. ASN oversight of the working of the organisations set up by EDF aims to check the IMS implementation procedures. More specifically, ASN ensures that the design or modification approaches implemented by the engineering centres at the moment of the design of a new facility or modification of an existing one take account of the needs of the users and organisations that will be operating it. More broadly, ASN monitors the organisation put into place by EDF to manage the resources needed to perform these activities. The comments expressed during the inspections observed are the subject of requests for corrective action. The overall organisation EDF is able to satisfactorily adapt its organisations along with certain professional practices in order to deal with the consequences of the Covid-19 pandemic. The main difficulties identified concerned postponed training programmes. In 2021, ASN continued its campaign of “explanatory” interviews, which it had started in 2020, so that its personnel could talk about their experiences and their day-to-day working conditions. Through these discussions, ASN noted that the personnel were on the whole satisfied with their working conditions, but –in particular for the operation and maintenance professions– it noted recurring operational difficulties, more especially the activities preparation phases (modification of schedules exacerbating the time pressure, problems with logistics and availability of tools and spare parts, inappropriate or overly voluminous operational documentation). The result of these difficulties was the deterioration in the preparation of activities (insufficient quality in the risk assessments and integration of OEF, lack of familiarisation with the documentation) with a direct impact on the quality of the activities in the control room or in the field. Skills management Despite the difficulties related to the Covid-19 pandemic and with making up the delays in certain training programmes (control operators, safety engineers), the organisation implemented by the sites to manage skills, qualifications and training remained on the whole satisfactory. The 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) was confirmed in 2021, as was the good working by the specific training programming and follow-up entities (common training service, training committees at several levels of the organisation). Even if the overall results with regard to skills are on the whole positive, ASN regularly found weaknesses in 2021 in the field of skills, notably with regard to the operation of the facilities. Certain shortcomings have been persistent for several years (process control, familiarity with equipment and hardware modifications) on a vast majority of the sites. Weak points, notably related to alignment and lock-out activities, are even tending to get worse. Monitoring of subcontracted activities 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. Monitoring of subcontracted activities was on the whole satisfactory in 2021, notably thanks to the correct deployment of the tool designed to help with production of monitoring programmes and performance of monitoring actions. However, the inspections are still showing weaknesses on certain sites (monitoring overly focused on quality assurance and safety rules and not enough on technical proficiency and the specific nature of the activities, inappropriate or only partially implemented monitoring plans). These difficulties mean that monitoring is not always an effective line of defence against potential failures by the contractors. GRAPH Mean collective dose per reactor (Man.Sv/reactor) 5 Source: EDF. This Graph includes data from the Fessenheim NPP until 2020. 0.00 0.25 0.50 0.75 1.00 2021 2020 2019 2018 2017 2016 2015 2014 2013 2012 2011 0.71 0.67 0.79 0.72 0.71 0.76 0.74 0.61 0.67 0.61 0.73 ASN Report on the state of nuclear safety and radiation protection in France in 2021 299 10 – THE EDF NUCLEAR POWER PLANTS 08 07 13 04 10 06 12 14 03 09 05 11 02 AP 01
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