During ASN’s examination of the organisation of the expertise centres set up by EDF, specific inspections were performed on all the NPPs during the course of 2022. Following these inspections and based on the OEF from the operation of the provisional centres, ASN considered that the radiation protection organisation put into place is able to meet the regulatory requirements of the Order of 28 June 2021, which led to the approval of the expertise centres for all the NPPs. 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. 800 to 1,400 EDF employees work in each NPP consisting of two to four reactors, and nearly 2,000 EDF employees in the Gravelines NPP, which has six reactors. About 23,000 EDF employees and 10,000 employees from permanent outside contractors are thus assigned to these nuclear sites. 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, which takes part in the integrated vision of oversight sought by ASN, carries out its monitoring work in conjunction with the other activities to monitor and oversee the safety of facilities and radiation protection. Oversight of occupational health and safety regulations Following on from the action taken in 2021, the labour inspectors carried out checks in all the NPPs on the exhaustiveness of the verifications of the electrical installations EDF is required to perform in accordance with the Labour Code. In addition, in 2022 ASN extended its checks to the field of electrical lock-outs prior to maintenance work on equipment, as well as to the regulations applicable to measures to prevent asbestos-related risks during work on the installations. In 2022, the labour inspectors therefore monitored and checked the worksites being carried out in the NPPs, notably during reactor outages and the removal and reinstallation of sections of auxiliary piping affected by stress corrosion, in particular as relating to the waivers requested by the employers with regard to the maximum working times and the safety of workers during maintenance operations. At the same time, monitoring continued on worksites with risks relating to the non-conformity of the work equipment and more specially of lifting gear. Finally, the labour inspectors followed up events relating to occupational safety which occurred on the sites, systematically opening inquiries in the event of serious accidents or “near accidents”. They were also called on to deal with subjects relating to psychosocial and working hours risks. CAMPAIGN OF INSPECTIONS ON THE SKILLS AND TRAINING OF THE TEAMS IN CHARGE OF REACTOR OPERATION Following a number of significant events directly implicating the competence of the teams in charge of reactor operations, ASN conducted inspections in 2021 on the EDF head office departments, to check how the national training programme for these teams is drawn up. Following these inspections, ASN decided to conduct an inspection campaign in 2022 in all the NPPs, with the aim of checking the local adoption of the national skills management process, along with concrete implementation in the field. The inspectors carried out situational exercises, on a control simulator, and at the same time held a series of explanatory interviews with the control staff and skills management players. During the situational exercises on the simulator, the control teams were faced with scenarios built around recent unforeseen technical events which occurred in the EDF NPPs. The inspectors verified the ability of the teams to run the installation in compliance with the baseline safety requirements. Following this campaign of inspections, ASN considers that the skills management process for the control staff is well applied in most of the NPPs. However, its correct implementation depends directly on the organisation adopted by each NPP and the human and material resources devoted to it. The inspectors were in particular able to see too few training personnel in certain NPP, vacant training correspondent positions or insufficient equipment in the training spaces. In addition, identification of the training needs could be improved in certain NPPs and the effectiveness of the training is on the whole insufficiently measured. Moreover, during the situational exercises on the simulator, ASN sometimes observed a lack of communication within the control teams, insufficient implementation of certain practices to reduce errors and problems with the distribution of roles within the teams. After each of these inspections ASN sent improvement requests to EDF. ASN Report on the state of nuclear safety and radiation protection in France in 2022 307 • 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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