- 174 - ASN considers it unsatisfactory that the technical instrumentation necessary for managing an accident situation, and particularly a severe accident situation, should be lost due to an external hazard. ASN will require EDF to include the technical instrumentation necessary for emergency management in the "hard core" provisions. This requirement will also extend to the environmental instrumentation necessary for emergency management, for which the external hazard resistance is not guaranteed either. Impact of other neighbouring facilities on the site: Among the industrial facilities situated near the NPP sites, EDF identifies in the CSA reports the Installations Classified on Environmental Protection grounds (ICPE) which can be subject to Authorisation (A) or subject to Authorisation with public protection restrictions (AS). For the ICPE A facilities, EDF concludes that they present no hazard risk for the NPP sites. For the ICPE AS facilities, EDF uses the perimeter of the Technological Risk Prevention Plan (PPRT) of the ICPE to evaluate its impact on the NPP site, and distinguishes two cases: the maximum distance between the site and the ICPE AS is greater than the PPRT perimeter: in this case EDF concludes that this ICPE does not present a hazard risk for the site; the maximum distance between the site and the ICPE AS is less than the PPRT perimeter: in this case EDF specifies that types of effect (thermal, toxic, overpressure) that could affect the site. EDF also mentions the existence of ICPEs subject to Declaration (D) in the environment of all the NPP sites and indicates that they present no known risk for the NPPs. With regard to the risks caused by the industrial facilities internal to the site, EDF identifies, depending on the site, the presence of monochloramine treatment plants, of hydrazine hydrate storage facilities and of plant unit diesel generators. EDF identifies the hazard potential and the nature of the hazardous phenomena associated with these facilities. It also indicates the measures that would be taken in the event of an accident. Regarding the identification of hazard sources relating to the on-site and off-site industrial environment, EDF does not always present the nature of the hazardous substances, the maximum quantities involved and the distances separating these hazard sources from the facility's safety targets in the CSA reports. For example, EDF concludes - without giving any justification - that the ICPE A and D facilities do not present a hazard risk for the sites. The CSA reports do not give an assessment of the consequences that the hazardous phenomena associated with these hazard sources - potentially aggravated in the event of an earthquake or flood - could have on the facilities which could have been made more vulnerable by the said earthquake or flood. EDF has undertaken to propose by mid-2012 a plan of action to study and deal with, in the event of extreme situations, the risks associated with the industrial environment on and off the site, and to verify the robustness of the complementary safety measures and emergency management means with respect to hazards associated with the industrial environment. In the particular case of the Tricastin site, EDF has undertaken to assess the impact of the AREVA facilities on the Tricastin NPP in the accident situations analysed in the CSAs. For the Gravelines NPP, EDF has undertaken to assess the impact of the oil pipeline that crosses the NPP intake channel and its bridge on the site. The hazardous phenomena associated with the hazard sources of the industrial facilities presented in the hazard studies have been taken into account in the design of the NPPs and are reassessed periodically, in accordance with the requirements of the order of 31 December 199949 and the recommendations of the RFS1.2.d50 defined by ASN. ASN nevertheless considers that EDF must examine these hazardous phenomena in the extreme situations analysed in the CSAs and draw its conclusions as to the complementary measures required. ASN also considers that EDF must assess the consequences of the induced hazardous phenomena (explosive, thermal, toxic, etc.) on its facilities, considering their condition after an 49 Order of 31 December 1999, amended, setting the general technical regulations intended to prevent and limit the harmful effects and risks resulting from the operation of basic nuclear installations 50 RFS 1.2.d of 7 May 1982 relative to consideration of the risks associated with the industrial environment and transport routes
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