Table of Contents 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 354

Complementary-safety-assessments-french-nuclear-safety

COMPLEMENTARY SAFETY ASSESSMENTS OF THE FRENCH NUCLEAR INSTALLATIONS −−−−−−−−−− REPORT BY THE FRENCH NUCLEAR SAFETY AUTHORITY December 2011

SUMMARY GENERAL INTRODUCTION 3 CHAPTER 1 SUMMARY OF THE TARGETED INSPECTIONS CARRIED OUT IN 2011 ON TOPICS RELATED TO THE FUKUSHIMA ACCIDENT 15 CHAPTER 2 COMPLEMENTARY SAFETY ASSESSMENTS OF THE NUCLEAR POWER PLANTS AND EUROPEAN STRESS TESTS 75 CHAPTER 3 COMPLEMENTARY SAFETY ASSESSMENTS OF THE NUCLEAR FACILITIES OTHER THAN NUCLEAR POWER REACTORS 211 REFERENCES 347 GLOSSARY 349

- 3 - GENERAL INTRODUCTION 1. The organisation of nuclear safety and radiation protection regulation in France The regulation of nuclear safety and radiation protection in France is based on two main Acts:  Act 2006-686 of 13th June 2006 on transparency and security in the nuclear field (TSN Act);  Planning Act 2006-739 of 28th June 2006 concerning the sustainable management of radioactive materials and waste. ASN, which has been an independent administrative authority since the TSN Act of 2006, is tasked, on behalf of the State, with regulating nuclear safety and radiation protection in order to protect workers, patients, the public and the environment from the hazards involved in nuclear activities. It also contributes to informing the public in these fields. It assists the Government in the event of a radiological emergency. Since the TSN Act was passed, ASN has enjoyed greater powers enabling it to punish offenses and take all necessary measures in the event of an emergency. ASN is run by a commission of five commissioners who perform their duties in complete independence, on a full-time basis, and are appointed for a non-renewable mandate of 6 years. ASN relies especially on the expertise of the Institute for Radiation Protection and Nuclear Safety (IRSN) and on its advisory committees of experts. With regard to nuclear safety and radiation protection, after receiving the opinion of ASN, the Government issues the general regulatory texts concerning transparency, nuclear safety and radiation protection, as well as major political decisions regarding nuclear facilities (authorisation of a basic nuclear installation, final shutdown). Parliament has an oversight role, in particular of the policy undertaken by ASN. The French Parliament's office for the evaluation of scientific and technological options (OPECST) regularly produces reports on particular aspects of nuclear safety and radiation protection. Every year, ASN sends Parliament its report on the state of nuclear safety and radiation protection. The French High Committee for Transparency and Information on Nuclear Security (HCTISN), created by the TSN Act, is an information, consultation and debating body concerning the hazards linked to nuclear activities and their impact. It comprises elected officials, associations, trades union representatives, qualified personalities, licensees and representatives of the public authorities. 2. French nuclear safety regulations The French regulations applicable to civil basic nuclear installations are in conformity with various conventions, international standards and European legislation: IAEA "Basic safety standards"; Convention on Nuclear Safety for civil nuclear power generating reactors; Joint convention on the safety of spent fuel management and the safety of radioactive waste management; Euratom treaty; Euratom directive of 25th June 2009 establishing a community framework for the nuclear safety of nuclear installations.; Euratom directive of 19th July 2011 establishing a community framework for the responsible and safe management of spent fuel and radioactive waste (which will be transposed in 2013). French nuclear safety regulations include all the general legal texts setting down nuclear safety rules, whether binding (Act voted by Parliament, decrees and ministerial orders and ASN regulatory decisions) or non-binding (ASN basic safety rules and guides).

- 4 - 2.1 Acts The TSN Act of 13th June 2006 on transparency and security in the nuclear field extensively overhauled the legal regime applicable to basic nuclear installations. It in particular made this regime "integrated" with the aim of preventing the hazards and detrimental effects of all types that nuclear facilities are liable to create: nuclear or non-nuclear accidents, radioactive or other pollution, radioactive pollutions and others, production of radioactive wastes or others, noise, and so on. Act 2006-739 of 28th June 2006 on the sustainable management of radioactive materials and waste, known as the "Waste" Act, creates a coherent, exhaustive legislative framework for the management of all radioactive waste. 2.2 Main decrees and ministerial or inter-ministerial orders in force Decree 2007-1557 of 2nd November 2007 on basic nuclear installations and the control, from a nuclear safety point of view, of the transport of radioactive materials, known as the "procedures" decree, implements article 36 of the TSN Act. It defines the framework for carrying out procedures in nuclear facilities and deals with the entire lifecycle of a nuclear facility, from its authorisation decree and commissioning up to final shutdown and decommissioning. Finally, it makes clear the relations between the Ministers responsible for nuclear safety and ASN, in the field of basic nuclear installation safety. The order of 10th August 1984 on the quality of the design, construction and operation of basic nuclear installations, known as the "quality" order, specifies the steps that the licensee of a nuclear facility must take to define, obtain and maintain the quality of its facility and the conditions necessary for ensuring its safe operation. The order of 31st December 1999 amended by the order of 31st January 2006 stipulates the general technical regulations, except for water intakes and effluent discharges, designed to prevent and mitigate off-site detrimental effects and hazards resulting from the operation of nuclear facilities. The order of 26th November 1999 sets the general technical requirements concerning the limits and procedures for water intakes and effluent discharges subject to authorisation in nuclear facilities. Pressure vessels specifically designed for nuclear facilities are subject to particular requirements that are regulated and monitored by ASN. They are defined in the decree of 13th December 1999 and in specific orders. ASN has undertaken to incorporate most of these texts into a single order setting out the essential requirements applicable to all basic nuclear installations (BNI) for the protection of humans and the environment from the risks of accident, chronic pollution or other detrimental effects. This order, known as the "BNI regime order", underwent a number of consultation processes, including two public consultations. It will be submitted to the Ministers responsible for nuclear safety in early 2012, for their signature. 2.3 ASN decisions Pursuant to article 4 of the TSN Act, ASN can take regulatory decisions to point out decrees and orders issued concerning nuclear safety or radiation protection, which are submitted to the Government for approval. ASN also issues individual decisions concerning nuclear activities (for example, commissioning authorisation for a basic nuclear installation, authorisation to use radioactive material transport packaging, authorisation to use radioactive sources, definition of requirements concerning the design, construction, operation or decommissioning of a facility, etc.). Since its creation in 2006, ASN has issued about 90 binding decisions, half of which concern water intakes and environmental discharges.

- 5 - 2.4 ASN basic safety rules and guides On a variety of technical subjects concerning nuclear facilities, ASN has in the past drawn up basic safety rules (RFS). These are recommendations which clarify the safety objectives and describe practices that ASN considers to be satisfactory. As part of the current overhaul of the general technical regulations, the RFS are being gradually replaced by "ASN guides". There are at present about forty RFS and other technical rules from ASN, which can be consulted on its website. 3. The nuclear safety approach in France The nuclear safety approach in France is based on:  the prime responsibility of the licensee for the safety of its facilities, under the oversight of ASN ;  continuous improvement of nuclear safety and radiation protection. The safety principles and approaches presented below were implemented gradually. They included experience feedback from accidents. Safety can never be totally obtained and, despite the precautions taken in the design, construction and operation of nuclear facilities, an accident always remains possible. There must thus be a constant desire to move forwards and to implement a continuous improvement approach in order to reduce the risks. To ensure the safety of nuclear facilities, the French regulations require that they be designed, built and operated to deal with a certain level of risk. These risks in particular comprise natural hazards, such as earthquake and flooding. The regulations also require the implementation of a "defence in depth" arrangement, which consists of a set of redundant, diversified measures (automation, systems or procedures) able to prevent accidents, manage them if they are not preventable or, failing which, mitigate the consequences. These arrangements are regularly checks and systematically reviewed on the occasion of the ten-yearly periodic safety reviews created by article 29 of the Act of 13th June 2006. 3.1 The "defence in depth" concept The main means of preventing and mitigating the consequences of accidents is "defence in depth". This involves a series of consecutive, independent levels of protection. If one level of protection, or barrier, were to fail, the next level would take over. An important aspect in the independence of the levels of defence is the use of technologies of different natures ("diversified" systems). The design of a nuclear facility is based on a defence in depth approach. For example, for nuclear reactors, there are the following five levels: First level: prevention of abnormal operation and system failures This entails choosing a robust and prudent design for the facility, incorporating safety margins, able to withstand its own failures or off-site hazards. This implies conducting a study of the normal operating conditions that is as complete as possible, to determine the most severe constraints to which the systems will be subjected. An initial design of the facility incorporating safety margins can then be established. Second level: Control of abnormal operation and detection of failures This entails designing control and limitation systems which maintain the facility well within its safety limits. For example, if the temperature of a system rises, a cooling system is activated before the temperature exceeds the authorised limit. Monitoring the good condition of the equipment and the correct operation of the systems is part of this level of defence.

- 6 - Third level: managing accidents without core melt This entails the assumption that certain accidents, which are the most penalising and encompass all the accidents of a given family, can occur, and to design some safeguard systems to deal with them. These accidents are generally based on conservative hypotheses, in other words it is assumed that the various parameters determining this accident are the most unfavourable possible. Furthermore, the single failure criterion is applied, in other words, in the accident situation, the failure of a component is also postulated. This means that the systems responding in the event of an accident (emergency shutdown, safety injection, etc.) must comprise at least two redundant channels. Fourth level: managing accidents with core melt These accidents were examined following that which occurred at Three Mile Island (1979) and are now incorporated into the design of new reactors such as the EPR. The aim is either to rule out these accidents, or to design systems able to deal with them. The study of these accidents will be reassessed in the light of the experience feedback from the Fukushima accident. Fifth level: mitigation of the radiological consequences of significant releases This involves implementing emergency plan provisions, including population protection measures: sheltering, administration of stable iodine tablets to saturate the thyroid and prevent it from absorbing the radioactive iodine carried by the radioactive plume, evacuation, restrictions on the consumption of water or foodstuffs, etc. 3.2 Safety management Safety management consists in creating a safety culture within the risk management organisations. The safety culture is defined by INSAG1, an international consultative group for nuclear safety reporting to the Director General of the IAEA2, as being a range of characteristics and attitudes which, for both organisations and individuals, ensure that matters relating to the safety of nuclear facilities are given the priority attention warranted by their importance. The safety culture thus reflects how the organisation and the individuals perform their roles and assume their responsibilities with regard to safety. It is one of the key factors in maintaining and improving safety. It requires that each organisation and each individual pay particular and appropriate attention to safety. It must be expressed at an individual level by a rigorous and prudent approach and a questioning attitude which ensure compliance with rules while leaving room for initiative. It is applied operationally in the decisions and actions relating to the various activities. 3.3 Operating experience feedback Operating experience feedback contributes to defence in depth. It consists in implementing a reliable system for detecting any anomalies that may arise, such as equipment failures or errors in the application of a procedure. This system should be able to ensure early detection of any abnormal operation and draw the conclusions (particularly in organisational terms) such as to prevent these anomalies from happening again. Operating experience feedback includes events taking place in France and abroad with pertinence for improved nuclear safety or radiation protection. 4. ASN regulation of civil nuclear facilities The French civil nuclear fleet is the world's second largest. It comprises a total of 150 nuclear facilities: 58 pressurised water reactors producing most of the electricity consumed in France, one EPR type reactor under construction, the various fuel cycle facilities, research facilities and facilities currently undergoing decommissioning. 1 INSAG: International Nuclear Safety Group 2 IAEA: International Atomic Energy Agency

- 7 - ASN, with the technical support of IRSN and its advisory committees, devotes particular attention to rigorous regulation of safety. In accordance with the law, it ensures continuous improvement of safety in French civil nuclear facilities, through the process of periodic safety reviews and the incorporation of operating experience feedback. Every year, ASN performs more than 700 inspections in the French civil nuclear facilities. These inspections are by means of spot-checks and by analysis of the proof of regulatory compliance provided by the licensee. In addition to this continuous monitoring, the licensees are required – under ASN oversight – to periodically review (generally every ten years) the safety of their facilities, in accordance with part III of article 29 of the TSN Act. The ten-yearly periodic safety review is an opportunity for a detailed inspection of the conformity of the facility with its own nuclear safety requirements. Its aim is also to make changes to the facility in order to improve its level of safety and as far as possible comply with the requirements applicable to the most recent facilities. The safety review enables ASN to assess the possibility of continuing with operation of the facility up until the next ten-yearly periodic safety review. ASN also examines anomalies occurring in the nuclear facilities. It ensures that the licensee has made a pertinent analysis of the event, has taken appropriate steps to correct the situation and prevent a reoccurrence, and has sent out operating experience feedback. ASN and IRSN also conduct an overall examination of experience feedback about events. This feedback can result in requests to improve the condition of the facilities and the organisation adopted by the licensee, but also in changes to the technical regulations. Operating experience feedback includes those events occurring in France and abroad with pertinence for enhancing nuclear safety or radiation protection. Finally, ASN is heavily committed to relations with its foreign counterparts, whether bilateral, European union or international level. ASN is developing active bilateral cooperation (more than 20 cooperation agreements with its counterparts); it is a member of several nuclear safety and radiation protection Regulatory Bodies. In compliance with the provisions of the TSN Act and at the request of the Government, ASN also takes part in the French representation to the international and European organisations in charge of nuclear safety and radiation protection. 5. ASN's sanctions powers In certain situations where the licensee's actions are not in conformity with the regulations or the legislation, or when it is important for it to take appropriate action to deal immediately with the most important risks, ASN has a number of means of action at its disposal. In the event of failure to comply with the regulations, its available tools are primarily:  ASN official request to the licensee through an inspection follow-up letter;  ASN formal notice to the licensee to regularise its administrative situation within a specified time, or meet certain stipulated conditions;  administrative sanctions, pronounced after formal notice, which can go as far as temporary suspension of operation of the nuclear facility. The administrative sanctions are defined in articles 41 to 44 of the TSN Act:  placing in the hands of a public accountant of a sum corresponding to the amount of the work to be performed;  performance of the work by another party at the expense of the licensee (any sums previously placed with the public accountant can then be used to pay for this work);  suspension of working of the facility or of a particular operation, until the licensee restores conformity.

- 8 - The law also makes provision for interim measures taken to safeguard public security, safety and health or to protect the environment. ASN may therefore:  temporarily suspend the operation of a BNI, immediately informing the Ministries responsible for nuclear safety, in case of any serious and imminent risk;  at any time, stipulate the evaluation and the implementation of the measures necessary in the event of a threat to the above-mentioned interests. In parallel with ASN's administrative actions, reports can be drawn up by the ASN inspectors and forwarded to the public prosecutor's office. 6. The French approach to the complementary safety assessments (CSAs) As with the Three Mile Island and Chernobyl accidents, detailed analysis of the experience feedback from the Fukushima accident could take about ten years3. The Fukushima accident, triggered by an earthquake and a tsunami on an exceptional scale, confirmed that despite the precautions taken in the design, construction and operation of the nuclear facilities, an accident is always possible. In this context, and given its knowledge of the 150 French nuclear facilities, through its regulation and oversight, ASN considered in the days following the accident that a complementary assessment of the safety of the facilities, with regard to the type of events leading to the Fukushima disaster, should be initiated without delay, even if no immediate emergency measures were necessary. These assessments were carried out in addition to the safety approach performed permanently and described previously. These complementary safety assessments are part of a two-fold approach: on the one hand, performance of a nuclear safety audit on the French civil nuclear facilities in the light of the Fukushima event, which was requested from ASN on 23rd March 2011 by the Prime Minister, pursuant to article 8 of the TSN Act and, on the other, the organisation of "stress tests" requested by the European Council at its meeting of 24th and 25th March 2011. 6.1 Specifications consistent with the European specifications In order to manage the complementary safety assessments, ASN issued twelve decisions on 5th May requiring the various licensees of the nuclear facilities to perform these complementary safety assessments in accordance with precise specifications. The complementary safety assessments concern the robustness of the facilities to extreme situations such as those which led to the Fukushima accident. They complement the permanent safety approach followed. To ensure consistency between the European and French approaches, the French specifications for the complementary safety assessments were drafted on the basis of the European specifications produced by WENRA4 and approved by ENSREG5 on 25th May 2011. The provisions of the French specifications are consistent with those of the European specifications. The complementary safety assessment thus consists of a targeted reassessment of the safety margins of the nuclear facilities in the light of the events which took place in Fukushima, that is extreme natural phenomena (earthquake, flooding and a combination of the two) placing considerable strain on the safety functions of the facilities and leading to a severe accident. The assessment first of all concerns the effects of these natural phenomena; it then looks at the loss of one or more systems important for safety involved in Fukushima (electrical power supplies and cooling systems), regardless of the probability or cause of the loss of these functions; finally, it deals with the organisation and the management of the severe accidents that could result from these events. 3 It should be remembered that after the Three Mile Island accident, it took six years to evaluate the proportion of the reactor core which had melted. 4 WENRA: Western European Nuclear Regulators’ Association 5 ENSREG: European Nuclear Safety REgulators Group

- 9 - Three main aspects are included in this assessment:  The steps taken in the design of the facility and its conformity with the design requirements applicable to it;  The robustness of the facility beyond the level for which it was designed; the licensee in particular identifies the situations leading to a sudden deterioration of the accident sequences ("cliff-edge effects"6) and presents the measures taken to avoid them;  All possible modifications liable to improve the facility's level of safety. 6.2 Specifications broader than the European specifications ASN decided to apply the complementary safety assessments to all French nuclear facilities and not simply to the power reactors. Thus, virtually all of the 150 French nuclear facilities will undergo a complementary safety assessment, including for example the EPR reactor currently under construction, or the spent fuel reprocessing plant at La Hague7. In this respect, the French specifications have been extended compared to those adopted at the European level by ENSREG. As of the beginning of the process, the association of stakeholders, particularly HCTISN, asked ASN to place particular emphasis on social, organisational and human factors, especially subcontracting. The Fukushima accident showed that the ability of the licensee and, as necessary, its subcontractors to organise and work together in the event of a severe accident is a key factor in the management of such a situation. This ability to organise is also a key aspect of accident prevention, facilities maintenance and the quality of their operation. The conditions for the use of subcontracting are also tackled in the French complementary safety assessments. On 3rd May 2011, the HCTISN issued a favourable opinion of the specifications for the complementary safety assessments. 6.3 Specifications which can also take account of some of the situations resulting from a malevolent act Even if the Fukushima accident involves no malevolent acts and even if such acts are not considered in the European Council conclusions of March 2011, the complementary safety assessments approach can cover some of the situations arising from such an act. Malevolent acts are in fact one of the possible causes (equipment failure, natural hazard, human activities) of a loss of electrical power or cooling which could lead to a nuclear accident. The loss of electrical power and cooling, regardless of the cause, are specifically covered by the complementary safety assessments and appear in this report. Specifically combating malevolent acts is being examined by the European Member States in a group devoted to this subject. The close link between these subjects (malevolent acts, safety) means that in most of the relevant countries (United States, Canada, Japan, Russia, Finland, Spain, Sweden, Switzerland, Ukraine, etc.) they are dealt with by the nuclear Regulatory Body. In this respect, France is an exception. 6.4 Categorization of the facilities concerned The complementary safety assessments concern virtually all the 150 basic nuclear installations in France (58 nuclear power generating reactors, EPR reactor under construction, research facilities, fuel cycle plants). 6 For example, in the case of flooding, the water level would gradually rise and a cliff-edge effect would be reached when the water level reaches the top of the embankment and floods the entire site. 7 Fewer than about ten facilities are excluded, as their decommissioning is nearing completion.

- 10 - These facilities have been divided into three categories, depending on their vulnerability to the phenomena which caused the Fukushima accident and on the importance and scale of the consequences of any accident affecting them. For the 79 facilities felt to be a priority, including the 59 power reactors in operation or under construction, the licensees (AREVA, CEA, EDF, Laue-Langevin Institute) submitted their reports to ASN on 15th September 2011. Given the time available, ASN asked the licensees of the priority nuclear facilities to present their conclusions according to the data at their disposal and based on existing safety studies and the expert opinions of the engineers. The licensees were also to propose complementary studies, to be carried out in particular on the weak points and the "cliff-edge" effects identified, as well as an appropriate calendar for these studies. For the facilities of lower priority, the licensees are required to submit their reports before 15th September 2012. Finally, the other facilities will be dealt with through appropriate ASN requests, in particular on the occasion of their next ten-yearly periodic safety review, except for about ten facilities for which decommissioning is nearing completion. 6.5 Assistance of a diversified technical expertise In accordance with the principle of the licensee's prime responsibility, which is the keystone of nuclear safety and a principle that is recognised in international legal texts, the complementary safety assessments led first of all, and for each facility concerned, to the production by the licensee of a report in response to the specifications defined by ASN. In order to analyse the reports submitted by the licensees on 15th September 2011, ASN called on the expertise of its technical support organisation, IRSN, which forwarded its report in early November. On 8th, 9th and 10th November 2011, ASN also convened two of the seven advisory committees it consults on the most important subjects: the advisory committee for reactors and the advisory committee for laboratories and plants. These advisory committees, consisting of French and foreign experts, submitted their opinion to ASN on 10th November 2011. At the same time the ANCCLI, the national association of CLIs (local information committees) mandated a number of experts to examine the reports submitted to ASN by the licensees. Several CLIs also initiated analyses: the Fessenheim CLIS sent ASN a study on the risk of flooding for the Fessenheim NPP; the CLIs at Civaux, Dampierre, Golfech, Gravelines, Saint-Laurent and the three CLIs of the Cotentin peninsula forwarded their opinions on the reports from the licensees. Finally, the experts mandated by the Grand Duchy of Luxembourg and the German States of Saarland and Rhineland-Palatinate, as well as the CGT trade union national mines-energy federation, sent ASN analyses of these reports. The complementary safety assessments thus led to considerable mobilisation on the part of the licensees, experts, stakeholders and ASN. ASN's initial conclusions on the complementary safety assessments of the priority nuclear facilities are based on a review of all this work and the results of its regulation and monitoring actions. They are the subject of this report. 6.6 An open and transparent approach ASN attached the greatest importance to this approach being both open and transparent: the French High Committee for Transparency and Information on Nuclear Security (HCTISN), the local information committees (CLI) and several foreign Regulatory Bodies were invited to take part as observers in the targeted inspections carried out by ASN and to attend meetings of the advisory committees. These various stakeholders also received copies of the reports sent in by the licensees. On its website (www.asn.fr) ASN also made available on-line the reports from the licensees, the IRSN report, the opinions of the advisory committees and the follow-up letters to its inspections.

- 11 - Finally, ASN published several information notes and held three press conferences on 9th May, 14th September and 17th November 2011. This ASN report will also be made public and presented to the press. On 8th December 2011, the HCTISN issued an opinion on the complementary safety assessment process. This opinion underlines the fact that the information concerning the Fukushima accident was made known to the public in a satisfactory manner. 7. The targeted inspections ASN initiated a campaign of targeted inspections on topics related to the Fukushima accident. The purpose of these inspections was to run field checks on the conformity of the licensee's equipment and organisation with the existing baseline safety requirements. The topics dealt with during these inspections were as follows:  protection against off-site hazards, in particular the ability to withstand earthquakes and protection against flooding;  the loss of electrical power;  the loss of heat sinks;  operational management of radiological emergencies. 7.1 Organisation of the targeted inspections Thirty-eight inspections were scheduled and performed by teams comprising several ASN inspectors accompanied by IRSN representatives. This campaign of inspections involved 110 days of inspection in the field. These targeted inspections were scheduled between June and October 2011. For any given site, they took the form of in-depth inspections lasting several days, involving spot-checks on all the topics mentioned above. They were based on baseline requirements common to the NPPs on the one hand and to civil nuclear facilities on the other. They placed emphasis on field visits rather than documentary checks. A summary of the targeted inspections is presented in chapter 1 of the report. This summary, based on the inspection follow-up letters, contains the most representative observations for each category of facilities. It is not therefore exhaustive and does not represent ASN's judgement of the safety of these nuclear facilities. All the requests made by the ASN inspectors are available in the follow-up letters sent out to the licensees, posted on the ASN’s website (www.asn.fr). 7.2 Transparency and public information In the same way as all the other ASN inspection follow-up letters, those concerning the post-Fukushima targeted inspections were posted on the ASN website (www.asn.fr). ASN also wished to involve the representatives of civil society in its inspections. ASN thus proposed that the local information committees (CLIs) of the nuclear facilities and the French High Committee for Transparency and Information on Nuclear Security (HCTISN) could take part in the targeted inspections as observers, subject to the approval of the licensee. ASN also invited the inspectors of the German, Swiss, Belgian and Luxembourg Regulatory Bodies to attend a few targeted inspections in France. More than 100 outside observers thus took part in the targeted inspections carried out by ASN, primarily in the NPPs. 8. A long-term approach

- 12 - The experience feedback from the Fukushima accident could take about ten years. As a first step it was felt that an immediate evaluation of the robustness of the facilities to extreme situations should be carried out. This is the goal of the complementary safety assessments, which led to an exceptional mobilisation of the licensees, experts, stakeholders and ASN. After the complementary safety assessments on the priority nuclear facilities, ASN considers that the facilities examined offer a sufficient level of safety requiring no immediate shutdown of facilities. At the same time, ASN considers that the continued operation of the facilities demands that their robustness to extreme situations be improved as rapidly as possible. Therefore in the first quarter of 2012, ASN will be imposing a range of requirements on the licensees and will tighten up the safety requirements concerning the prevention of natural hazards (earthquake and flooding), the prevention of risks linked to other industrial activities, subcontractor monitoring and how nonconformities are dealt with. The corresponding ASN decisions will be posted on the www.asn.fr website. ASN will subsequently ensure that the licensees comply with the hundred or so requirements it will have issued and take account of the new safety requirements it will have approved. ASN will also take into consideration the conclusions of the peer reviews conducted at the European level. ASN also considers that additional studies will need to be undertaken to complete certain aspects, in particular the initial analyses carried out by the licensees. It will send the licensees the corresponding requests in letters which will also be posted on its website. In the summer of 2012, ASN will present the progress of all of these measures. ASN will also continue the process of complementary safety assessments of nuclear facilities with lower priority, for which the reports have to be submitted by the licensees before 15th September 2012. ASN considers that these initial complementary safety assessments confirmed the benefits of such an innovative approach, complementing the existing safety approach. It envisages continuing this process of complementary assessment of safety margins by making it a mandatory component of the ten-yearly periodic safety reviews. Finally, ASN will continue to participate actively in all the analyses to be conducted worldwide, in order to gain a clearer understanding of the Fukushima accident.

- 13 - CHAPTER 1 SUMMARY OF THE TARGETED INSPECTIONS CARRIED OUT IN 2011 ON TOPICS RELATED TO THE FUKUSHIMA ACCIDENT···········································15 1.. INTRODUCTION..................................................................................................................................... 15 1.1 Organisation of the targeted inspections 15 1.2 Transparency and public information 15 2.. SUMMARY OF THE PRESSURISED WATER REACTOR (PWR) TARGETED INSPECTIONS CARRIED OUT IN 2011 ON TOPICS RELATED TO THE FUKUSHIMA ACCIDENT...................................16  Summary of the inspections........................................................................................................16 2.1 Protection of facilities against off-site flooding 18 2.1.1 Introduction..........................................................................................................................................18 2.1.2 Organisation.........................................................................................................................................18 2.1.3 Special operating rule in the event of flooding....................................................................................19 2.1.4 Monitoring of forecast criteria (meteorological, flood and tidal)........................................................19 2.1.5 Decision-making in an alert situation..................................................................................................20 2.1.6 Implementation of procedures.............................................................................................................20 2.1.7 Actions and modifications performed following the event at Le Blayais............................................20 2.1.8 Monitoring of volumetric protection (PV)...........................................................................................21 2.1.9 Maintenance of flood protection features............................................................................................21 2.1.10 Mobile pumping resources (MMP)....................................................................................................22 2.1.11 Powering the pumps after loss of off-site power supplies .................................................................22 2.1.12 Site isolation in the event of flooding................................................................................................23 2.1.13 Flooding of galleries between units and management.......................................................................23 2.1.14 Diversity of telecommunication resources.........................................................................................23 2.1.15 Optimisation of discharges at the prediction of a flooding risk.........................................................23 2.1.16 Exercises: deployment of flood protection and prevention equipment (cofferdams, sandbags, mobile pumping resources)................................................................................................................23 2.1.17 Overall evaluation of the "protection of facilities in an off-site flooding situation"..........................24 2.2 Earthquake protection of the facilities 24 2.2.1 Introduction..........................................................................................................................................24 2.2.2 Organisation.........................................................................................................................................25 2.2.3 Instrumentation....................................................................................................................................28 2.2.4 Event earthquake approach..................................................................................................................30 2.2.5 General evaluation on the topic "Protection of facilities in an earthquake situation"..........................31 2.3 Loss of heat sink 32 2.3.1 Introduction 32 2.3.2 Organisation / human factors 32 2.3.3 Conformity of pumping station systems with the EDF national frame of reference (deployment of particular directive DP 143) 33 2.3.4 Integration of experience feedback (REX) particularly interim requirement 303 concerning how to deal with clogging of the heat sink 33 2.3.5 Anticipation: monitoring, prevention and detection resources 34 2.3.6 Management of cooling in a degraded situation 34 2.3.7 Maintenance, servicing and availability of equipment, upkeep of premises 35 2.3.8 General evaluation of the "loss of heat sink" topic 36 2.4 Loss of electrical power supplies 36 2.4.1 Introduction 36 2.4.2 Organisation and operation 36 2.4.3 Backup electricity generating sets 37 2.4.4 Combustion turbines (TAC) 38 2.4.5 Backup turbine generator (LLS) 38 2.4.6 Electrical transformers 39 2.4.7 Fuel oil storage 39 2.4.8 Storage of oil and coolant fluid 39 2.4.9 Management of the loss of electrical power supplies 39 2.4.10 General evaluation of the "loss of electrical power supplies" topic 40

- 14 - 2.5 Operational management of accident situations 40 2.5.1 Introduction 40 2.5.2 Incident or accident operating rules 40 2.5.3 Organisation put into place for the on-site emergency plan (PUI) 41 2.5.4 General evaluation on the topic "management of accident situations" 46 3.. SUMMARY OF TARGETED INSPECTIONS CONDUCTED IN 2011 CONCERNING TOPICS RELATED TO THE FUKUSHIMA ACCIDENT ON LABORATORY, PLANT, WASTE AND DECOMMISSIONING FACILITIES (LUDD) ....................................................................................47  Summary of inspections..............................................................................................................47 3.1 General presentation of the sites and facilities 48 3.1.1 Experimental reactors 48 3.1.2 Nuclear fuel cycle facilities 48 3.1.3 Other facilities (ATPu, Masurca) 50 3.2 Protection of the facilities against off-site flooding 50 3.2.1 Experimental reactors 50 3.2.2 Nuclear fuel cycle facilities 51 3.2.3 Other facilities 53 3.3 Protection of facilities against earthquakes 54 3.3.1 Experimental reactors 54 3.3.2 Nuclear fuel cycle facilities 55 3.3.3 Other facilities 58 3.4 Loss of heat sink 59 3.4.1 Experimental reactors 59 3.4.2 Nuclear fuel cycle facilities 59 3.4.3 Other facilities 60 3.5 Loss of electrical power supplies 61 3.5.1 Experimental reactors 61 3.5.2 Nuclear fuel cycle facilities 61 3.5.3 Other facility 64 3.6 Operational management of accident situations and crisis management 64 3.6.1 Introduction and frame of reference considered 64 3.6.2 Organisation put into place for management of incident/accident situations 65 3.6.3 Coordination with external players 67 3.6.4 Exercises and integration of experience feedback 67 3.6.5 Crisis management resources 67 3.6.6 Crisis premises and assembly points 68 3.6.7 Conclusion 69

- 15 - SUMMARY OF THE TARGETED INSPECTIONS CARRIED OUT IN 2011 ON TOPICS RELATED TO THE FUKUSHIMA ACCIDENT 1. Introduction In addition to the complementary safety assessments, ASN conducted a campaign of targeted inspections on topics related to the Fukushima accident. These inspections, carried out on all the nuclear facilities considered to be high-priority, were designed to check the actual conformity of the licensee's equipment and organisation in the field with the existing safety frame of reference. The following topics were covered by these inspections:  protection against external hazards, in particular against earthquakes and flooding,  the loss of electrical power supplies,  the loss of heat sinks,  operational management of radiological emergency situations. 1.1 Organisation of the targeted inspections 38 inspections were scheduled and carried out by teams comprising several ASN inspectors accompanied by representatives from the IRSN. This campaign of inspections represented 100 days of inspection in the field. These inspections, referred to as "targeted" inspections were scheduled between June and October 2011. For each of the given sites, the inspections lasted several days (not necessarily continuous) and involved spot-checks on all the topics mentioned above. The inspections were based on a frame of reference common to the nuclear power plants (NPP) on the one hand, as well as the other civil nuclear facilities on the other, with preference being given to field visits over documentary checks. This summary contains the observations most representative of each facility category and is not therefore exhaustive. All the requests submitted by the ASN inspectors are nonetheless available in the follow-up letters sent out to the licensees. The references of these follow-up letters are provided in the appendix. The conclusions of the targeted inspections enabled ASN to complete its analysis of the complementary safety assessment reports, so that it could issue additional requirements aimed at strengthening the nuclear safety of the facilities. 1.2 Transparency and public information In the same way as all the other ASN inspection follow-up letters, those concerning the post-Fukushima targeted inspections were published on the ASN's website (www.asn.fr). In addition, ASN wanted to involve the representatives of civil society in its inspections. ASN thus proposed that the local information committees (CLI) of the nuclear facilities and the French High Committee for Transparency and Information on Nuclear Security (HCTISN) participate in a number of the targeted inspections as observers, subject to the approval of the licensee. ASN also invited inspectors from the German, Swiss, Belgian and Luxembourg nuclear safety regulators to attend a number of targeted inspections in France. 51 outside observers thus took part in the targeted inspections performed by ASN, primarily on the nuclear power plants.

- 16 - 2. Summary of the pressurised water reactor (PWR) targeted inspections carried out in 2011 on topics related to the Fukushima accident  Summary of the inspections The inspections showed that the five subjects targeted by the programme were not always correctly integrated into the current frame of reference. The main steps to be taken by EDF are summarised below. 1. With regard to the topic of flooding, the conclusions of the inspections are diverse and vary according to the sites. ASN considers that the organisation put into place to manage the flooding risk complies satisfactorily with the expectations. However, ASN does consider that the management of volumetric protection1 needs to be improved on some of the sites inspected. EDF will therefore focus its efforts in particular on the monitoring and maintenance of volumetric protection. ASN also considers that EDF needs to define and implement exercises for testing the ability of the equipment and crews to deal with this type of situation and to incorporate experience feedback from these exercises. Finally, ASN considers that improvement is required on the following topics:  the strict application on the sites of special operating rules in the event of flooding;  monitoring of meteorological, flood and tide parameters;  the schedule for the performance of actions decided on in the light of the experience feedback from the partial flooding of the Le Blayais site in 1999;  management of mobile pumping resources. 2. With regard to the topic of earthquakes, ASN finds that the inspections revealed shortcomings on several sites and that progress is required on all the sites as a whole. It is important to conduct exercises simulating an earthquake leading to the implementation of planned procedures and to prepare the personnel for this type of situation. ASN moreover considers that greater consideration must be given to the event-earthquake problem in the procedures and day-to-day operations of the units. Finally, EDF must ensure compliance with RFS I.3.b2 concerning seismic instrumentation, in particular with regard to operator familiarity with the equipment, its upkeep and its calibration. On the whole, ASN considers that this subject requires permanent vigilance on the part of EDF, so that the potential implications of a hazard of this nature during the day-to-day operation of the reactors are not lost. EDF informed ASN that it has already taken steps in response to ASN's findings (seismic risk awareness campaigns launched on all the sites, appointment of a local seismic coordinator, currently ongoing checks of the positioning of the seismic measurement sensors, and updating of procedures). ASN considers that this subject should be the focus of priority action in 2012. 3. ASN finds that the heat sink, which plays a fundamental safety role, requires particular vigilance. Recent heat sink clogging or partial loss of heat sink events, at Cruas and Fessenheim in December 2009 in particular, revealed its vulnerability and led EDF to initiate a plan of action to enhance the robustness of all the heat sinks. ASN asked EDF to conduct a design review of all heat sinks. ASN will be asking EDF for the detailed conclusions of this design review, site by site, along with the associated plan of action with its milestones and deadlines. The inspections carried out by ASN in 2011 showed that the general condition of the facilities was correct but that a certain number of problems still persisted on certain sites. Rigorous operation and maintenance, monitoring of the condition of the equipment and structures, and exhaustive application of the national directives are as a general rule areas of improvement for many sites. At numerous sites, maintenance of the SEC (Essential Service Water) system needs to be improved. 1In a flooding situation, the equipment designed to ensure reactor safety must remain operational. Therefore, when necessary, systems are thus put into place to protect against the various hazards that could lead to flooding. This protection is based on several lines of defence (embankments, walls, water drainage networks, etc.), including volumetric protection. The perimeter of volumetric protection, which encompasses buildings containing equipment designed to guarantee reactor safety, was defined by EDF to guarantee that the arrival of water outside this perimeter does not lead to flooding of the premises situated inside the perimeter. In concrete terms, the volumetric protection consists of walls, ceilings and floors. Protection of existing openings in these walls (doors, other openings, etc.) can constitute potential points of water ingress in the event of flooding. 2 RFS I.3.b of 8th June 1984 concerning seismic instrumentation.

- 17 - EDF plans to reinforce the heat sink safety frame of reference by early 2013. 4. With regard to electrical power supplies, the ASN inspectors judged the EDF sites to be on the whole satisfactory but nonetheless there was room for improvement on the following points:  rigour in utilisation of the operating and maintenance documents (filling out of operational documents, updating of maintenance programmes);  physical condition of certain fuel storage equipment (piping corrosion, water infiltration);  management of fluids needed by the electricity generating sets (periodic analyses);  periodic inspections associated with the TAC (combustion turbine) on certain sites. 5. Operations in an accident situation could be improved. The PUI (on-site emergency plan) arrangements implemented by the sites are satisfactory. ASN finds that EDF needs to improve management of the fallback stations and certain agreements with outside organisations.

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