- 65 - Therefore, the requests made following the targeted inspections are more observations of problems with the implementation of the PUI than conformity deviations. 3.6.2 Organisation put into place for management of incident/accident situations General organisation The documents requested were always presented to the inspectors, whether organisation memos, PUI supervisor assignment letters, or reflex response sheets. The La Hague site in particular demonstrated a good level of general organisation. The organisation and the procedures for taking account of experience feedback from exercises and from actual events that have occurred could on the whole be improved, especially with regard to operational communication during management of the crisis. The facilities on the Tricastin site (Socatri, GBII, Eurodif, Comurhex and AREVA NC) presented reflex response sheets that were unknown to ASN, even though these documents are an integral part of the PUI, itself subject to ASN approval in the event of modification. The reflex response sheets are updated outside the scope of the PUI, which constitutes a deviation from the PUI guideline plan. The inspections concerning CEA Saclay and CEA Cadarache reveal insufficient coordination of the crisis organisation between the site PC and the local PCs, in particular: the composition of the local PCs in terms of PUI functions; personnel training in these functions (use of reflex response sheets and standard messages, directories, means of communication, etc.); procedures for alerting the centre's management (reaching trigger criteria). The inspectors organised emergency exercises during the inspections. The support services such as the FLS (Local Safety Organisation) and the SPR (Radiological Protection Service) demonstrated their full effectiveness during these exercises. However, the reconnaissance by the local initial response teams (ELPI) on the site of the accident and communication with the FLS were deficient during the course of exercises on the Tricastin site, in particular concerning AREVA NC and Eurodif. This coordination could be improved through a precise definition of the role of the ELPI and by holding exercises with effective deployment of the mitigation resources and coordination between ELPI and FLS. Long-term crisis management Most of the sites have no procedures for long-term crisis management. Full-scale deployment of the emergency teams, as is for example the case on the RHF, means that all the personnel of the reactor division are called onto the site, even though their presence is not necessarily required as of the beginning of the crisis. However, the AREVA site at La Hague and CEA Saclay reinforced their long-term organisation following the snow episodes of 2009-2010 and as part of the preparations for a flu pandemic (H1N1 swine flu). National alert ASN's national alert procedure was tested satisfactorily. However, in the event of an earthquake or flood type severe accident, which would lead to the loss of all means of external communication, the sites would be unable to trigger the alert with the means currently at their disposal. The need for the sites to acquire additional telecommunication resources, such as satellite phones, was pointed out (see crisis management resources). Procedures, instructions, reflex response sheets The licensees' staff are on the whole well familiar with intervention procedures and instructions in the event of a crisis situation. Nonetheless, effective implementation of these procedures and instructions was not systematic during the exercises held. Only the Mélox inspection highlighted the need to improve the content of the FLS intervention plans.
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