- 116 - Given the lack of vulnerability of some sites, EDF concluded that it was not necessary to install an alert system on them. For those sites concerned by flood RPCs, ASN checked their implementation during targeted inspections between June and October 2011 (see chapter 1); on this occasion, ASN observed that the flood RPCs had not been applied on certain sites (Chooz, Cruas, Nogent, Tricastin, Dampierre, Gravelines)22, even though they radically alter the flooding hypotheses (for example, in Tricastin, the site is now considered potentially subject to isolation and exposed to a LOOP), which is not the case in the current procedures. ASN will require that EDF adapt the organisation on the Cruas and Tricastin sites to deal with isolation in the event of flooding. Finally, in its specifications, ASN asked EDF to clarify whether other effects, either linked to the flood itself or to the phenomena which triggered the flood (such as very poor meteorological conditions) were considered, in particular the loss of off-site electrical power, the loss of the water intake (effect of debris, of hydrocarbon slicks, etc.) and the situation outside the facility, including complete blockage or delay in access to the site by personnel and equipment. In the CSA reports, EDF states that loss of off-site electrical power (in particular as a result of a storm) and of the water intake (which could result from the massive arrival of clogging material or hydrocarbon slicks) were taken into account. The analysis led EDF to propose additional studies and material and operating measures for certain sites (for example: raising the level of the interconnection center on certain sites). 3.1.3 Conformity of facilities with the current baseline safety requirements In its specifications, ASN asked EDF to describe the general organisation set up to guarantee conformity (periodic maintenance, inspections, tests, etc.); ASN in particular asked EDF to describe the organisation enabling EDF to ensure that the mobile equipment outside the site, provided for in the emergency procedures, is available and remains in good working conditions. Any anomalies observed, and the consequences of these anomalies in terms of safety, as well as the programming of remedial work or compensatory measures, were to be specified. Finally, ASN asked EDF to submit the conclusions of the specific conformity examinations initiated following the accident in the Fukushima nuclear power plant. In its CSA reports, EDF states that the flood protection conformity of its facilities is based on: periodic surveillance through periodic tests or inspections as part of the preventive maintenance programmes on equipment contributing to protection, identified in the design studies; monitoring and management of the VP . With regard to the periodic inspections carried out on the equipment contributing to flood risk protection, EDF has stated that the monitoring or maintenance programme for certain equipment items was in the process of being deployed on certain sites. The equipment concerned constitutes the lines of defence against off-site flooding. ASN thus considers that these monitoring and maintenance programmes must be implemented as early as possible, in order to guarantee the availability, integrity and correct operation of the measures adopted in case of flood. EDF states that the monitoring and protection of the VP, designed to provide a long-term guarantee of its watertightness at all times, is based on the following two checks: verification that there is no deterioration of the watertightness of the VP over time: the various components of the VP are subjected to maintenance, as identified in the basic preventive maintenance programmes (PBMP). 22 For Chooz, the notification of modification pursuant to article 26 of decree 2007-1557 of 02/11/2007 was filed by EDF and is currently being examined by ASN. For Nogent and Tricastin, the process is ongoing.
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