ASN considers that the performance of the Orano Recyclage La Hague site in 2023 is satisfactory in the areas of nuclear safety, radiation protection and environmental protection. With regard to nuclear safety, ASN found the proficiency of operational management to be satisfactory. ASN thus notes positively the tracking of the skills and staffing levels of the operational management teams in the context of the organisational changes linked to the “Convergence” project. It also noted that the teams were closely associated with the resulting changes and that the management of staff numbers was well anticipated. With regard to operational management of incidents and accidents, ASN considers that the teams concerned have a sound knowledge of the baseline requirements. Particular attention must nevertheless be paid to the training of the teams in the management of rarely encountered facility situations or configurations, which caused several significant events in 2023. Greater rigour is also expected in the tracking of periodic inspections. The aspects relating to the control of chain nuclear reactions have been examined for several of the site’s facilities, and here again ASN considers the organisational set-up to be satisfactory, even if particular attention must be paid to the filling out of the periodic inspection and test documents and compliance with the frequencies. ASN underlines the generally good organisation of outside contractor monitoring. ASN nevertheless considers that Orano must adapt its functioning to be capable of maintaining an adequate level of monitoring during outages, when the number of work interventions is higher. Orano must also ensure that its 1st-tier contractors monitor its 2nd-tier contractors sufficiently closely. Lastly, the rigour with which the monitoring reports are filled out must be improved in some cases (reference of the monitoring actions, consistency between what is expected and the final results, etc.). With regard to management of the fire risk, ASN considers that the work programmes to reinforce fire detection and protection are proceeding at a satisfactory pace. ASN also notes positively the responsiveness of the personnel of the facilities when unannounced exercises are initiated, and the way in which the operational management teams and local response groups duly accomplish the majority of the tasks incumbent upon them. With regard to the actions to be taken by the “material safety protection” service, ASN regrets that it was not possible to test them in 2023, as the teams withdrew from the exercise due to the concomitant operational activity. Lastly improvements are necessary in the safety analysis associated with the sectorisation losses, in the management of disabling of the fire detection system, and in the integration of new equipment deployed in the fire risk control management project. With regard to emergency management, ASN carried out an unannounced exercise involving the activation of an on-site emergency plan and notes with approval the site’s ability to deploy its emergency organisation and to feed back the facility’s technical data to the ASN’s Emergency Centre. In the area of radiation protection, ASN considers the results from the setting up of radiation protection competence centres to be broadly positive, even if some documentary and operational adjustments are still to be finalised. ASN notes with approval the material and awareness-raising measures taken to reduce cases of personnel entering controlled areas without activating their active dosimeter. These measures must nevertheless be maintained and consolidated. With regard to environmental protection in 2023, ASN notes that the organisation defined and implemented to apply the updated requirements regulating the site’s discharges is satisfactory. This notably results in the operational integration of the new discharge limits which places an operational constraint on effluent management. It will however be necessary to consolidate the submitted regulatory registers and notifications, taking care in particular to ensure their consistency and exhaustiveness. Alongside this, the ongoing momentum must be maintained and materialised in anticipation of the forthcoming submittal of studies to ASN (technical-economic studies aiming to assess the possibilities of reducing discharges, study relating to the conformity of the outfalls and the conditions of dispersion of discharges in the atmosphere). ASN also considers that as soon as possible Orano must carry out the studies and compliance work on the hydraulic structure of the Moulinets dam, with a view to restoring nominal operation of the facilities, including with respect to the routing of raw water to the site. With regard to the storage of plutonium-bearing materials, Orano commissioned a second storage area extension within a room of the R4 facility in August 2023. Like the first storage area extension, this project was also examined and implemented in a very short time frame. An application for a third extension was filed in September 2023. Alongside this, ASN considers that the projects relating to the installation of the new evaporators of the NCPF project ran satisfactorily, which enabled the NCPF project for the T2 facility to enter service in April 2023. More broadly, ASN examined the organisation defined and implemented for operational application of the safety requirements relating to facility modifications. The operational implementation fits into a structured organisation that is adapted to the scale of the projects. However, this must not lead to shortcomings in the robustness of the verifications or≈in the traceability for demonstrating compliance with the specified requirements, particularly with projects involving more limited risks. This must lead, from time to time, to the reviewing of the organization and level of resources assigned to the monitoring of this type of project. Lastly, ASN observes that the organisation for the off-site and on-site transport of radioactive substances and for the maintenance of the packagings used on the La Hague site remains satisfactory. ASN does however note an increase in significant events in off-site transport operations, and the occurrence of events on the on-site transport operations linked to deviations from the baseline requirements. Furthermore, in the context of the on-site transport system improvements, ASN – through its resolution of 6 July 2023 – has authorised a further postponement of the deadline for the improvements to the Mobile Material Evacuation Enclosure (EMEM) transport system. The project monitoring inspections carried out at Orano and the supplier of this transport package confirmed the difficulties encountered; consequently, ASN considers that the licensee has to make a strong commitment with more robust ASSESSMENT OF THE ORANO SITE 78 ASN Report on the state of nuclear safety and radiation protection in France in 2023 Regional overview of nuclear safety and radiation protection • NORMANDIE •
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