In 2022, as in previous years, ASN observed that discharges are well managed on most of the sites. However, certain events are indicative of isolated weaknesses reflecting operating defects in certain equipment such as the oil removers. Finally, the exceptional heatwave episodes in the summer of 2022 led to the warming of some of the watercourses used to cool the NPPs. To guarantee the security of the electricity grid and save the natural gas reserves and the water in the hydroelectric dams, ASN temporarily modified its prescriptions relating to thermal discharges from the Blayais, Bugey, Golfech, Saint-Alban and Tricastin NPPs (see “Notable events” in the introduction to this report). 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). 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. 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 the 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. 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 Human and Organisational Factors (HOF) 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 are the subject of requests for improvement actions. The overall organisation The organisation set up by EDF to control risks is on the whole satisfactory but could still be improved in a few NPPs. Maintenance and operational non-quality remained at a high level, despite a larger number of reactor outages in 2022, and some of them were the cause of significant events. The inspections and event analyses carried out by ASN notably reveal a significant uptick in deviations during lock-out and line connection activities. Certain weak points in the organisational provisions, notably inadequately managed scheduling, do not enable absolute priority to be given to the activity preparation phases, which leads to programming errors, failures in the risk assessments performed upstream or insufficient assimilation of OEF. The ASN inspections highlight improvements in the performance of the pre-job briefings, by comparison with 2021. The involvement of the first-line managers on this subject would appear to be producing tangible results. During its inspection campaign (see box page 307), ASN encountered difficulties with the distribution of roles and with communications within the control teams. ASN also notes that there are still coordination problems with the other disciplines and project teams. With regard to maintenance activities, problems of coordination between the various departments were found on a number of sites, with under-performing organisations for the management of several activities at the same time. The NPPs were able implement an efficient organisation for forward planning of the deployment of the modifications associated with the fourth periodic safety review of the 900 MWe reactors, with the adoption of extensive supporting information work and an oversight body for integration of the modifications. Finally, in 2022, the organisational and professional practices changes that EDF had adopted during the acute phases of the Covid-19 pandemic were terminated. However, OEF from implementation of these changes was initiated by EDF and will continue in 2023. Skills management Skills management among the control teams was the subject of an inspection campaign in 2022 (see box page 307). With regard to the maintenance activities, ASN is continuing to find that the explicit underlying cause is errors in tutoring and training and therefore ultimately insufficient skills, which notably manifests itself in an inadequate perception of the safety issues by the parties involved. Finally, ASN also observes a persistent lack of tutoring and training in 2022, with regard to material modifications to the installations. These shortcomings can be attributed to various organisational failures (lack of resources, insufficient forward planning for training, lack of coordination between the disciplines during the final phase of deployment of a modification, etc.). Management 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. ASN Report on the state of nuclear safety and radiation protection in France in 2022 305 • 10 • The EDF Nuclear Power Plants 10 01 07 08 13 AP 04 06 12 14 03 09 05 11 02
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