ASN checks that the periodic tests of safety-important equipment items do effectively check their operation and level of performance. It carries out this verification during the review of RGE modification authorisation applications. During inspections, it also verifies that these periodic tests are carried out in accordance with the test programmes stipulated in the RGEs. As in previous years, the periodic tests were the origin of several ESS. The main causes of these significant events are incorrect specification of the test rules in the operating documents, errors in application of the test procedure when performing tests, inconsistencies between documents, or periodic test programming errors. Further to OEF from these events, EDF is adapting its organisations to ensure better sharing of information between the various actors responsible for defining, programming and carrying out tests. Skills management In 2022, ASN ran an inspection campaign on the skills management of the teams in charge of operating the installations. In 2023, it again carried out inspections on the sites it considered to be in the greatest difficulty and saw improvements in the working of the training departments (team reinforcements, revitalization of training and skills committees, clarity and relevance of processes, increase in training equipment). Persistent weaknesses in the skills acquisition process for operating personnel were however still observed during the inspections or during analysis of significant events, which raises questions regarding the effectiveness and scope of the training. ASN observed frequent use of self-training through on-line e-learning, or by means of a questionnaire for refresher courses. Practical work in the field is limited or completely absent with this type of arrangement. Shortcomings in mentoring of newcomers is also observed. In 2023, ASN also observes a continued lack of mentoring and training 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 operational documentation In 2023, as in previous years, the significant event reports regularly spotlight insufficient documentation quality. This has been an underlying problem for a number of years. The difficulties identified are of various types (documentation not concise enough, not explicit, incomplete, or even non-existent). This situation has consequences for a wide range of activities, including control activities (periodic tests, lock-outs and administrative closures, line connections) and maintenance work (technical inspections, maintenance work on equipment, requalifications, local control actions). Operational documentation faults impair the effectiveness of the documentation as a line of defence. These recurring anomalies in the operational documentation remain to a large extent linked to organisational problems. Failures in oversight of the documentary management process are present at all steps in the lifecycle of the documents, from identification of requirement up to document archival. The Independent Safety Organisation During its inspections, ASN examines the actions of the Independent Safety Organisation (FIS – see box below) and checks that its opinions are correctly taken into account by the operational departments. The inspectors found that the FIS on the various sites inspected in 2023 were competent, functional and independent. Some sites are still experiencing resourcing problems, as the number of safety engineers is sometimes lower than the number required for lengthy periods. EDF took steps to ensure that there would be sufficient numbers of safety engineers in the future, so that they can calmly perform their independent verification of reactor safety. Operation in an incident, accident, or severe accident situation ASN checks the processes to draft and validate the incident or accident operating rules, their pertinence and how they are implemented. ASN thus carried out several inspections in 2023 on the organisational and technical arrangements made by EDF to deal with an incident and accident situation. These inspections almost always include a situational exercise for the facility’s control teams in the room or on a simulator, to check the application of instructions and intervention and communication practices within these teams. In 2023, ASN thus carried out reactive inspections on the sites where the control of the installations had been disrupted by operating contingencies; these inspections aimed to verify compliance with the applicable procedures in the management of these contingencies. Following these inspections, ASN considered the implementation of the incident or accident operating provisions to be satisfactory. During the situational exercises, ASN nonetheless found that the operating documents still contained errors and inaccuracies, even though regular checks are normally scheduled to prevent these anomalies. ASN therefore remains attentive to ensuring correct implementation of the processes to verify the operating documents and process the anomalies detected. ASN also found errors in application of the procedures during certain transient incidents. EDF must analyse the origin of these application errors and, if necessary, modify the documentation, the organisation or the training of the parties involved, so that they do not happen again. Emergency organisation When the situation in the installation deteriorates or additional means are needed to manage the situation, the incident or accident operating procedures provide for activation of the PUI, which leads to deployment of an emergency organisation. At EDF, the Independent Safety Organisation (FIS) verifies the actions and decisions taken by the departments in charge of operating the installations, from the viewpoint of safety. On each NPP, the FIS comprises safety engineers and auditors, who notably conduct a daily check on the safety of the reactors. The working of each FIS is checked and evaluated at a national level by the FIS of EDF’s Nuclear Production Division. Finally, the EDF internal inspectorate, in particular the general inspector reporting to the Chairman of the EDF group, assisted by a team of inspectors, represents the highest level of independent verification of nuclear safety within the EDF group. THE INDEPENDENT SAFETY ORGANISATION 300 ASN Report on the state of nuclear safety and radiation protection in France in 2023 • 10 • The EDF Nuclear Power Plants
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