ASN Report on the state of nuclear safety and radiation protection in France in 2019

The Nuclear Safety Authority presents its report on the state of nuclear safety and radiation protection in France in 2019.

This report is required by Article L. 592-31 of the Environment Code.

It was submitted to the President of the Republic,  the Prime Minister and the Presidents of the Senate and the National Assembly and  transmitted to the Parliamentary Office for the  Evaluation of Scientific and Technological Choices, pursuant to the above-mentioned Article.

A commitment to quality and rigour is demanded from everyone

In a context where the level of safety in nuclear facilities has remained on the whole satisfactory, 2019 was marked by increased awareness on the part of the nuclear licensees of the challenges that face them as a group. The need to reinforce the quality of the work done and professional rigorousness in terms of safety has been broadly taken on board, which is essential if progress is to be made. The increase in inspections cannot be considered an appropriate response. As those with prime responsibility for safety, it is therefore up to the licensees to address these challenges.

In the medical field, the radiation protection of patients undergoing diagnostic or therapeutic procedures involving ionising radiation has been maintained at a high level.

The number of significant radiation protection events reported by the health professionals remained very low in 2019 when compared with the number of procedures carried out on the patients every year and the complexity of some of these procedures. However, particular attention must be maintained, owing to the extremely sophisticated technical nature of some medical procedures and the chain of professionals involved.

Professional competence and rigour at the heart of the nuclear industry’s recovery

At the end of 2018 , ASN underlined the need for re-engagement by the nuclear industry in order to maintain the key industrial skills vital to the quality of the work done and the safety of the facilities.

In 2019, in response to a request from the Government and further to the conclusions of the Building the Flamanville EPR report by Jean-Martin Folz, EDF presented an action plan “to restore the level of quality, rigour and excellence which underpinned the construction of the French NPP fleet”.

ASN considers that the orientations of the plan are a step in the right direction. Quality and professional rigour are key aspects in ensuring the safety of the facilities. They must be applied both in the performance of the activities and in their oversight by the licensees, who hold prime responsibility for safety.

ASN considers that the commitment to quality and rigour in running projects must be restated, not only for new constructions, but also for legacy waste recovery and packaging projects, decommissioning, or major maintenance works. The nuclear industry must more precisely define the conditions for implementation of this action plan, notably in terms of reinforcing the safety culture and a rigorous professional attitude.

Continued operation of the 900 MWe reactors: an EDF goal still to be achieved

With the support of the IRSN, ASN continued to examine the fourth periodic safety review of the 900 MWe reactors, in order to define the generic conditions for their continued operation, in other words those that are applicable to all these reactors. The main goals of this review concern the management of installation conformity, more particularly ageing management, as well as the facility’s greater robustness to natural hazards and the mitigation of the radiological consequences in the event of an accident, notably with core melt. These goals were defined in the light of the safety objectives set for the third generation reactors, in particular the EPR.

For the fourth periodic safety review, EDF proposed installation modifications in order to achieve these goals, for example to improve the safety of the spent fuel pool, or to reduce the risk of containment basemat melt-through with the resulting contamination of the soil and groundwater in the event of an accident with core melt. ASN will issue a resolution on the generic part of the periodic safety review of these reactors at the end of 2020, to regulate their continued operation.

ASN considers that implementation of the modifications proposed by EDF leads to significant safety improvements for the facilities and contributes to achieving the goals of the periodic safety review. However, at this stage of the examination, ASN considers that these modifications alone are unable to meet all the targets set. In the absence of any additional proposals from the licensee during the course of 2020, ASN will prescribe additional modifications.

In 2019, Tricastin reactor 1 was the first to carry out its fourth ten-yearly outage. EDF set up a specific organisation and extensively mobilised its national engineering division to provide the site with support, before and during the outage, so that the modifications to be deployed could be fully assimilated. This organisation enabled the work to be carried out satisfactorily. ASN underlines the fact that over the next few years several reactor ten-yearly outages will be performed at the same time and queries EDF’s ability to implement such an organisation simultaneously on the sites concerned.

Questions about the operational intervention conditions

During its inspections, ASN placed greater emphasis on controlling the implementation of the operational measures planned by the licensees to deal with undesirable events in a nuclear facility. In this respect, ASN conducted exercises simulating an outbreak of f ire, internal flooding, loss of containment of hazardous products, or an accident situation. For certain exercises, ASN observed that the actions required in these situations were not feasible or that the intervention times were longer than those planned by the licensee.

These findings mean that the licensee must ensure that the actions required by the operating documents are actually operationally feasible and take corrective measures where applicable.

More generally, the growing complexity of the rules to be followed and of the operational measures to be taken, demands extra vigilance on the part of all the players.

The eight EPR containment penetration welds to be repaired

The Flamanville EPR reactor is a pressurised water reactor, providing a significantly higher level of safety than the reactors currently in operation. The EPR in particular offers greater protection against external hazards and more effective means of mitigating the consequences of accidents with core melt.

Numerous deviations from the expected quality were found in the construction and manufacture of the EPR equipment, primarily due to a loss of experience and a lack of professional rigour, notably in the use of special processes (welding, forging, heat treatment, non-destructive testing, etc.). These problems also revealed shortcomings in the oversight exercised by the licensee.

With regard to the deviations in the design and production of welds on the main steam letdown lines, ASN stated as early as 2018 that preference should be given to repairing all the welds. At the end of 2018, EDF however proposed an approach to justify maintaining certain welds as they were (the eight containment penetration welds). Given the nature and the particular high number of deviations which occurred in the design and production of these welds, and given that their repair is technically feasible, ASN informed EDF in June 2019 that their repair prior to commissioning of the reactor was the baseline solution.

Irregularities which should cause everyone to re-examine their activities

ASN has established an action plan to deal with the risk of fraud. The first conclusions have been reached after a campaign of fraud-targeted inspections and the analysis of fraud reports sent by whistle blowers.

The risk of fraud exists, but the number of confirmed cases at this stage is very low when compared with the volume of activities. The first findings mainly concern irregularities in the implementation of special processes (identity fraud among welders or inspectors), in internal controls at the suppliers (falsification of test results) or in the monitoring of activities (declaration of monitoring work not actually performed). Not all of these irregularities were detected by the licensee’s monitoring activities.

In most cases, the analyses by the licensees and the investigations carried out by ASN further to these findings, revealed no safety risks. The manufacturers and licensees must remain vigilant, including with regard to their own personnel, and question the underlying root causes of this type of behaviour.

A new step in the consultation process for the management of radioactive materials and waste

As co-sponsor, alongside the Ministry for Energy, ASN was heavily involved in the public debate held in 2019 to prepare the next version of the French National Radioactive Material and Waste Management Plan. The conclusions of the public debate underlined the major importance of the management of high and intermediate level, long-lived waste, the need to take greater account of certain aspects (transport, environmental assessment, decommissioning issues and interaction with energy policy) as well as the central nature of the governance of the national radioactive materials and waste management system. The joint decision by the Ministry for Ecological and Inclusive Transition and the ASN Chairman, specifying how the lessons learned from the public debate are to be addressed, was published in February 2020. ASN will continue its involvement to ensure safe management of the waste and materials and will work to make an effective contribution to high-quality consultation with the stakeholders.

The permanent need to anticipate the nuclear safety and radiation protection challenges of new projects

ASN seeks to anticipate the safety challenges associated with the facilities it regulates, in particular on the basis of forward-looking analysis carried out within the framework of the National Radioactive Materials and Waste Management Plan and the guidelines of the multi-year energy programme.

In this context, ASN issued its opinion on the safety options dossier of the EDF project for a centralised storage pool, sufficiently early on so its safety requirements could be integrated into the project.

Faced with the prospect of final shutdown of the two reactors of the Fessenheim NPP, and then of several other reactors, planned under the multi-year energy programme, ASN will be attentive to ensuring that the steps taken by the licensee enable decommissioning to be carried out as rapidly as possible. ASN will aim to optimise its examination processes and learn all relevant lessons from the decommissioning of the Fessenheim NPP, for the benefit of subsequent decommissioning work.

Finally, with regard to the potential construction of new reactors, ASN issued its opinion on the safety options of the “EPR New Model” reactor project and its “EPR 2” evolution, taking account of the lessons learned from the Flamanville EPR and the reactors in operation. This opinion identifies the subjects which would need to be examined in greater depth, or the choices that would have to be justified for a possible reactor creation authorisation application, for example, the adoption of a break preclusion approach.

Vigilance to be maintained owing to the complexity of some medical procedures and the chain of professionals involved

In 2019, the number of significant radiation protection events reported to ASN in the medical field did not change significantly and remains low when compared with the number of procedures performed and the complexity of some of them. The most important challenges from the radiation protection viewpoint concern:

• for workers: fluoroscopy-guided interventional practices and nuclear medicine, where the dose limits are excee- ded, notably for the hands and eyes;
• for patients: fluoroscopy-guided interventional practices, owing to the duration of certain procedures, external beam radiotherapy, notably owing to wrong-side errors and, finally, nuclear medicine, with radiopharmaceutical administration errors;
• for the public and the environment: nuclear medicine, with radioactive source losses, leaks from pipes and radioactive effluent containment systems.

Concerning external beam radiotherapy, the number of significant radiation protection events reports stabilised in 2019. Three events were rated at level 2 on the ASN-SFRO scale (5 in 2018). The security of access to high-level sealed sources needs to be improved in brachytherapy units and will remain a priority inspection topic. The occurrence of two events in which the source remained blocked in a projector recalls the importance of staff training in the emergency measures to be taken in such a situation.

The deployment of new therapies in nuclear medicine, with high activity levels being administered to the patients, requires particular attention with regard to radioactive effluent management. In addition, personnel training efforts must be maintained and the coordination of preventive measures during work by outside contractors must be improved.

With regard to fluoroscopy-guided interventional practices, too few of the premises where they are carried out actually fully meet the regulatory requirements, although the situation is however better in the interventional radiology units. Insufficient training of the professionals in patient radiation protection and a shortfall in application of the principle of optimisation of procedures are recurring findings during the inspections. There is insufficient exploitation of the collection of the doses received by the patients during procedures in order to optimise practices. Patient follow-up –as defined by the French National Authority for Health– if the skin exposure limit is exceeded, is not very satisfactory, particularly in the operating theatres.

Similarly, in the field of external beam radiotherapy, this monitoring is also considered to be insufficient. It led ASN to request that a follow-up study be conducted by professionals on patients affected by a level 2 significant radiation protection event.

Proposals to reinforce the management of a nuclear post-accident situation

On the basis of the lessons learned from the Fukushima NPP accident and the emergency exercises, the Steering Committee for the management of the post-accident phase of a nuclear accident (Codirpa) headed by ASN, proposed a number of changes to post-accident doctrine to the Prime Minister. They primarily aim to simplify the post-accident zoning used as the basis for the population protection measures. More specifically, new criteria were proposed to define the population evacuation perimeter.

The Codirpa also drew up a  public guide and created  a joint Anccli/ASN/IRSN website to raise awareness of post-accident situations. This site enables elected officials, health professionals, associations, education personnel and economic players to access documents and information for preparing or managing life in a region contaminated by a nuclear accident.

New exchange framework to reinforce cross-border cooperation

ASN took the initiative of setting up a new framework of exchanges to reinforce the sharing of experience on specific subjects with its counterparts in neighbouring countries: Germany, Belgium, Luxembourg and Switzerland. In November 2019, it therefore organised the first inter-regional seminar devoted to cross-inspections, consultation with the stakeholders, emergency preparedness and response and maintaining the skill levels of the nuclear safety regulators. This format for sharing, which is broader than a bilateral meeting and more focused than a multilateral framework, showed the added value to be gained from examining these subjects in greater depth and formulating common proposals to reinforce international cooperation.