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The Inspector General’s report

on Nuclear Safety andRadiation Protection

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FOREWORD THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

FOREWORD

This report is destined for the Chairman of EDF with the purpose of informing him of my judgement regarding nuclear safety and radiation protection within the EDF Group.This report is also intended for all those who, in any way, contribute to nuclear safety and radiation protection through their everyday acts and decisions. It will have achieved its goal if it provides food for thought about performance in these fields and how things can be improved.The General Inspectorate for Nuclear Safety and Radiation Protection (French acronym IGSNR) reports directly to the Chairman of EDF and was created in the aftermath of the Three Mile Island accident more than thirty years ago. In 2014, it was commended as a good practice by the IAEA1. The IAEA emphasised the independence of the IGSNR and its contribution to continuous improvement of nuclear safety within the EDF Group. This creditworthy assessment can be ascribed to the action of the successive EDF chairmen who were aware that there could be no proper nuclear safety without openness and independent oversight of operations. It also reflects the commitment of the Inspector Generals, notably my predecessor Jean Tandonnet, who was able to develop the methodology and credibility of this inspection capability.Progress in nuclear safety and radiation protection necessitates perseverance. This report is therefore similar to previous reports in both content and form. However, as a result of an agreement signed on 1 April 2014 between EDF and EXELON2, the latter now ensures the operational management of the five nuclear reactors operated in the US by CENG3. For this reason, these reactors are no longer discussed in this document.

1 International Atomic Energy Agency2 American power company3 Constellation Energy Nuclear Group

As in previous years, this report focuses on problems and weaknesses rather than on strengths and progress. This may seem unfair to those whose constant efforts ensure the safe everyday operation of the nuclear power generating facilities, a complex and demanding task.My assessment is based on the information gathered and the observations made during the year in France and the UK, from the workers in the field, during visits to the plants and encounters with the main stakeholders: managers, staff representatives and members of the medical professions, not to mention contractors. It also makes use of comparisons with numerous other international players on the nuclear scene and exchanges with WANO4.I would like to thank all those I met for their helpfulness and for the openness and fruitfulness of our exchanges. Their openness, vital to the relevance of this report, continues to reflect a spirit of nuclear safety culture.I would also like to thank my assistants, Jean-Paul Combémorel, Bernard Maillard, François Hedin and Mike Lavelle, who have been relentless in their efforts, particularly in drafting this report.Finally, although this document was not been written for the purpose of public relations, as in previous years, it is available to the general public on the EDF website in both French and English (www.edf.fr).

The Inspector General for Nuclear Safety and Radiation Protection of the EDF Group

François de Lastic

4 World Association of Nuclear Operators

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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SOMMAIRE THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

CONTENTS

1/ My view of 2014 5

2/ Contrasting trends in nuclear safety in different sets of plants 13

3 / Making safety culture central to management 19

4 / Towards an integrated approach to risk management 27

5 / Relying on professional unified operations 33

6 / The quest for robust maintenance 41

7 / Nuclear engineering: a major asset for the operator 51

8 / Nuclear managers - confidence builders 59

9 / on course for reactor operation beyond 40 years in France 63

10 / Service life challenges in the UK 73

11 / Preparing the future: from the EPR to other new models 79

12 / Noteworthy operational events 87

13/ Appendices 95

Result indicators for the nuclear power plants

13.1 EDF SA ��96

13.2 EDF Energy ��97

Maps of the nuclear power plants

13.3 EDF SA ��98


Technical key dates for the nuclear units

13.5 EDF SA ��100


13.7 - Table of abbreviations ��102

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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MY VIEW OF 2014 THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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1/ MY VIEW OF 2014

Gravelines Nuclear Power Plant

THE INTERNATIONAL SITUATION

The lessons of Fukushima

Throughout the world the nuclear power industry is continuing to make use of what has been learned from the Fukushima accident, which occurred in March 2011. Although work is continuing to clear and clean up the Fukushima Daiichi site, none of the nuclear power plants were back in service in Japan at the end of 2014.Many countries and nuclear operators consider that they have completed their checks and analysis and have defined the changes that need to be made in the plants in service, under construction or planned. However, I note considerable disparity in the extent of such improvements, which in some countries are considered to be complete while in others they are still in progress. WANO, which most of the nuclear operators in the world are members, is continuing to adapt its inspection methods to what has been learnt from the Fukushima accident, with the goal of continuing to improve nuclear safety levels. The corresponding changes in

the peer reviews will become effective in 2015, notably taking into account the operator’s control over facility design.I fully approve the goal announced by the EDF Group as early as 2012 that no severe accident should have consequences in terms of contamination of extensive areas of land in the long term. The scope and pace of the work on making the necessary modifications also raised considerable business-related difficulties. Being the foremost nuclear operator in the world with its 73 reactors in service, the EDF Group is closely scrutinised and needs to set an example. It may yet be able to derive further benefit from the best international practices, while in the meantime promoting its own experience as a nuclear operator and architect engineer. In 2014, apart from the regular WANO peer reviews of EDF’s nuclear plants, EDF SA5 benefited from an OSART6 inspection which highlighted the commitment of managers to nuclear safety, identified 16 good practices, issued 7 suggestions and made no recommendations.

5 Responsible for EDF activities in France6 Operational Safety Review Team (IAEA)

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION MY VIEW OF 2014

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Developments in the nuclear world

The trend towards plant life extension continues. At the end of 2014, 36 reactors in the US and 5 in Europe had been operating for more than 40 years. Furthermore, 74 of the 99 reactors in the US (of which two thirds are PWRs of similar design as those in France) were authorised by the nuclear safety authority called the NRC7 to operate for up to 60 years. The NRC processed 17 equivalent requests and examined, with the operators, the terms and conditions of extending the life of the reactors up to 80 years.The new build rate is higher than it has ever been in 25 years, with more than 70 nuclear reactors under construction, most of which are in Asia. It is to be noted that most of these reactors of the third generation, with higher nuclear safety standards, but I also observe the construction of many second-generation reactors. This disparity shows the need for more international-level work on harmonising nuclear safety requirements.In Europe, the UK is planning to modernise its set of nuclear plants, with progress being made with the EDF Energy project to build two EPRs at Hinkley Point.

THE SITUATION IN FRANCE

A recently voted bill on green energy is due to come into force early in 2015, which will entail a series of complex and delicate choices. This new act will set a ceiling for installed nuclear power at its current level (63 GWe) and will limit the share of nuclear power in total power generating to 50% in 2025. The EDF Group will naturally be affected by this change in energy policy under the new law. I note the resulting disquiet amongst the EDF SAstaff about the uncertainties of applying this act, which is made worse by the fact that the nuclear industry’s regulatory framework is insufficiently stable. In this context, I call for increased everyday vigilance of nuclear safety.Investment in staff turnover and work to extend plant life has made good progress. Provided efforts are maintained, this should guarantee the company’s results in nuclear safety and generating performance.At the end of 2014, the schedule for defining and implementing post-Fukushima measures was met. In addition, the extensive and complex file (60,000 pages) that makes up the application for licensing Flamanville 3 start-up was compiled and submitted to the safety authority in due time. I am very glad to see that this very important stage of the project has been reached. The EDF Group is also working on the construction of the Taishan 1 and 2 EPRs in China.7 Nuclear Regulatory Commission

DIFFERENT NUCLEAR SAFETY TRENDS FOR DIFFERENT SETS OF PLANTS

I note in 2014 that not a single major nuclear safety or radiation protection event occurred in France or the UK. For the second year running, no nuclear events occurred in the EDF Group ranked level 2 or greater on INES8. Nevertheless, a fault detected in an AGR9 with considerable implications for nuclear safety required EDF Energy to inform the British authorities of a nuclear reportable event, corresponding to the highest declaration level in the UK. I note EDF Energy’s decision to shut down, the three other AGRs liable to be affected by this type of fault in August 2014 as a precautionary measure. The way in which this event was handled highlighted the operator’s sense of responsibility and the desire for openness.In France, I note with satisfaction that nuclear safety results of the 19 sites are improving. I see this as a result of new operating methods that are more standardised and reflect good practices. The indicators shows stability or improvement: the number of scrams per reactor has diminished while the number of significant nuclear safety events is basically unchanged. However, the number of sub-standard maintenance and operation cases remains high, and the number of events due to failure to comply with technical specifications for operation has increased. The efforts to achieve the desired levels of results need to be intensified. Nevertheless, I consider them to be encouraging overall, as they have been obtained in the context of a heavy business workload and massive staff refreshment.My predecessor warned about the negative effects of excessive unit outage extensions. I note with satisfaction the way that the Nuclear Generation Division (DPN10) reacted and was able to rectify the situation with the support of the Nuclear Engineering Division (DIN11), thus obtaining tangible results. The volume of maintenance work carried out during such outages has been reassessed so as to give nuclear safety its due place. I have noticed the beneficial effect of better scheduling, and how it fosters serenity and hence nuclear safety. These efforts need to be maintained. In the UK, the nuclear safety results have somewhat deteriorated. In particular, I note the perceptible increase in the number of automatic and manual scrams I also note considerable disparity, with three plants out of eight being where most of the events significant for nuclear safety have occurred.

8 International Nuclear Event Scale9 Advanced Gas Reactor10 French abbreviation for Division Production Nucléaire11 French abbreviation for Division Ingénierie Nucléaire


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As regards fire prevention and fire-fighting, the results in France have generally always been good and they further even improved in 2014, whereas progress in the British plants requires further attention.As regards radiation protection, the results for the British plants remain excellent while those for the French plants are improving, particularly as a result of tighter control of the unit outages.I am glad to be able to report that no fatal accidents occurred in the nuclear plants in 2014. Nevertheless, the pace of improvement in industrial safety has been too slow in France, with results that failed to match those of the best nuclear operators worldwide, of which EDF Energy is one. I note that, given their respective strengths and weaknesses, the French and British plants have much to gain by exchanging experience feedback and good practices. I note the development of such essential benchmarking, reflecting the will of senior management of the two sets of plants. I encourage the nuclear plant directors to take initiatives at their own level.

INDEPENDENT INTERNAL NUCLEAR SAFETY OVERSIGHT TAKES ROOT

In France, the principles of the Independent Internal Nuclear Safety Oversight networks appear to be reliable and well-conceived. Its staff is of high quality, well-trained and fully aware of the importance of their job.The fact that many safety engineers in the nuclear plants are relatively young needs to be taken into consideration: they need old hands alongside them. Furthermore, as the skills needed are scarce, the Independent Internal Nuclear Safety Oversight networks are concentrating on operating activities and are failing to challenge the maintenance professions as often as they might. As the new arrivals build up their skills, the Independent Internal Nuclear Safety Oversight networks will need to integrate individuals with the necessary know-how to further increase their credibility and broaden the scope of their oversight to their full extent, which includes maintenance. I am glad to be able to report that a good practice was identified by the IAEA Operational Safety Analysis Review Team with regard to the Nuclear Inspectorate of the Nuclear Generation Division and the Assessment and Support Unit of the Nuclear Engineering Division, which are components of the Independent Internal Nuclear Safety Oversight networks in their respective divisions.In the UK, as my predecessor noted, attention was needed regarding the poor resources available for independent nuclear safety oversight in the plants. I commend the efforts of EDF Energy in 2014. Renamed the Independent Nuclear Assurance (INA), the internal nuclear safety

oversight body is now benefiting from the resources and skills needed, and its effectiveness should be accordingly increased. I would like to emphasise the importance of the Technical and Safety Managers who, alongside the plant directors, play a major role in assessing nuclear safety. I note that the first Nuclear Safety Review Boards (NSRB) have been set up in the plants and the functioning of the Nuclear Safety Committees (NSC), which benefit from skills and oversight external to EDF Energy.

FIVE POINTS NEEDING ATTENTION

In the interests of nuclear safety, simplification is needed, particularly in France

As regards operations, I would like to draw parallels between the 2014 nuclear safety results and the observed weaknesses in certain fundamental professions, in operations and maintenance, in France and the UK:• control of physical phenomena in the control room,• planning of activities and risk analysis before field work,• technical checking,• pre-qualification of equipment after field work,• human error reduction practices in France, which are

one of the strengths of the British teams.In the UK and irrespective of the considerable differences between the plants, I have noticed there is a significant backlog of faulty equipment waiting to be repaired.Much is expected of rigour and quality, in addition to providing other avenues of progress. In France, as concerns engineering, I have observed that some installation modification files are not yet up to standard. However, I note that, for the first time, the Nuclear Engineering Division managed to submit all the necessary job files four months before the Paluel 2 unit outage, the first of the third 10-yearly inspections in the 1300 MWe plants. In operations in France, I also note that there is an increasing number of local projects relating to the quality of maintenance and operation, and initiatives to make them link-up with other actions (relating to experience feedback12, skills, practices to ensure reliability etc.). Within the EDF Group, I have met managers who speak of their difficulty in being central to their teams and getting them to understand what quality demands, particularly as concerns the “rigorous and prudent” approach outlined in INSAG 413. They are indeed faced

12 Known as REX in France (Retour d’EXpérience)13 Recommendations issued by the International Nuclear Safety

Advisory Group of the IAEA detailing the concept of nuclear safety culture organisations and individuals in activities relating to nuclear energy


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with increasing internal demands and demands due to an increasingly complex regulatory environment. Given the situation, they are unable to sufficiently focus on the conditions under which they exercise their activity to properly understand problems, identify root causes and implement the correct solutions. I am calling on the senior management to better protect these managers from any requests that keep them away from their staff Furthermore, I have noticed in France that both EDF SAand contractor staff are not always placed in situations where they can get things right the first time: they are particularly burdened by the volume of the job documentation and all is entails. The work begun by the Nuclear Generation Division is therefore particularly pertinent. I am aware how difficult this work is, yet I still consider it vital for nuclear safety. This requires commensurate leadership and lasting support, initially focused on the field workers.I would also like to encourage the certification and rationalisation work begun by the Nuclear Generation Division to clarify and facilitate appropriation of the rule sets and their application.Consequently, I call on the managers, at all levels, to take initiatives to simplify and prioritise processes and procedures.

Simplifying and stabilising the French regulatory framework: vital for nuclear safety

Like my predecessors, I consider the oversight of nuclear energy generation and the industry by a strong nuclear safety authority to be indispensable. Acceptance by the general public depends on this fundamental concept. Throughout the world, nuclear operators benefit from the challenges thrown at them by the “nuclear police”, preventing slackness and tending to raise levels of nuclear safety.In France and the UK, the existence of a strong nuclear safety authority is a sine qua non condition for the continued existence of the nuclear power industry.French law14 states that the nuclear operator is responsible for the nuclear safety of its facilities. One of the provisions of this Act is that the French nuclear safety authority (ASN) may accordingly lay down legal provisions and check compliance with the general rules and the specific requirements. The Act accordingly provides for the division of roles: the ASN expresses the general rules in terms of nuclear safety goals and checks that they are achieved, while the operator is responsible for providing the resources necessary to satisfy the objectives set by the ASN. In

14 Act No. 2006-686 of 13 June 2006 on nuclear safety and transparency, called the TSN Act

essence, relations between operators and the nuclear safety authority reflect their different viewpoints, while their shared concern for nuclear safety enables them to find common ground.I am glad to see that the relations between the regional ASN officers and the nuclear plants are mainly balanced and constructive, intense on a technical level, uncompromising and beneficial to nuclear safety. On the other hand, I note that, despite my predecessors’ warnings, relations are becoming increasingly tense on a central level: were the situation to continue, it would be of a nature to compromise nuclear safety.It is true that the context complicates relations between EDF SAand the ASN. First of all, there are number of difficult issues to be resolved, including:• post-Fukushima modifications which require further

discussion and action,• plant life extension,• preparation for the start-up of the EPR plant at

Flamanville.These three issues with tight time-constraints are generating tension between EDF SAand the main suppliers, including AREVA, as well as with staff from the ASN and its technical adviser called the Institute for Nuclear Safely and Radiation Protection (IRSN). These issues are raised and dealt with within the regulatory framework that is increasingly demanding, but above all even more complex and unstable. This regulatory rule set, which is progressively coming into force, is designed to accurately specify — sometimes going as far as to state the means to be used — the provisions for design, construction and operation, having been built up over decades and which new requirements are being added. This situation is generating regulatory change which can be problematic.There are those among the operator and supplier staff who find this rule set questionable, and even incomprehensible, failing to see what benefits it may bring in terms of nuclear safety. They consider at least part of it hard to reconcile with industrial reality.Furthermore, the requirements continue to accumulate, and the operators and suppliers need to comply with hundreds of acts, decrees and orders, without counting the requirements and guidelines at a lower level. Compliance with all this requires considerable manpower, resulting, for instance, in nearly doubling the time taken between the order and delivery of a steam generator. More seriously, however, the number of rules to follow detracts from the importance of each, which is extremely prejudicial to nuclear safety.This being the case, I call for urgent step change in regulatory simplification, to the great benefit of nuclear safety.


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The nuclear pressure equipment order of 12 December 2005

Ministerial Order No. 99-1046 of 13 December 1999 covers the design, manufacture, market implementation, compliance assessment, essential industrial safety requirements, in-service testing operations including regular requalification, and the minimum criteria for accreditation of independent organisations and user inspection bodies for pressure equipment. This ministerial order is the transposition of Pressure Equipment Directive (PED) 97/23/EC published by the European Commission. The in-service monitoring of pressure equipment is governed by the ministerial order of 15 March 2000 amended.In France, an additional regulatory provision has been issued: the nuclear pressure equipment order (known as the ESPN Order) of 12 December 2005, which came into force under the ministerial decree of 13 December 1999. This covers pressure equipment specifically designed for nuclear applications whose failure may result in the release of radioactive material.Nuclear pressure equipment is classified as follows:

• Three levels, from N1 to N3, depending on the amount of nuclear material liable to be released should they fail:

N1: pressure equipment such as part of the reactor coolant system and the main secondary-side systemsN2: pressure equipment that is not classified N1 whose failure may result in the release of more than 370 giga-becquerel of radioactivity.N3: any other pressure equipment not classified N1 or N2.

• Five categories, from 0 to IV, depending on the risks associated with the temperature and the pressure of the fluids they contain.

The nuclear pressure equipment order covers the manufacture, conformity assessment, essential industrial safety requirements, installation, commissioning, surveillance, maintenance, utilisation and in-service checking. It came into effect for equipment in service (Part III of the ministerial order) on 21 January 2011. This ministerial order notably introduces changes in the manner of substantiating and monitoring the design, manufacture and assembly of nuclear pressure equipment.Implementation guidelines have been published by the ASN (Guide 8 of September 2012 on conformity assessment, Guide 19 of February 2013 on implementing the ministerial order).

The nuclear pressure equipment order: finding a solution to what has become an inextricable problem

Applying the nuclear pressure equipment order is currently a source of tension.In 2013, my predecessor highlighted the difficulty of applying this ministerial order. He stressed its impact on the generating facilities on the one hand, and on the availability of spare parts and new equipment on the other. He also pointed out that the situation was demoralising many in the industry. He said the application of this order had to be stabilised by focusing on reasonable provisions and by restoring a climate of confidence between the different stakeholders with due respect to the roles of each.I echo his warning that this situation is still at a standstill which is prejudicial to nuclear safety as it is delaying the replacement of old equipment. I would particularly like to draw attention to the probable deferment of several steam generator replacements scheduled for reasons of nuclear safety. This deferment results from the fact that the replacement equipment, although designed and fabricated in the same way with

a level of technical stringency at least as great as for the equipment in place, does not formally comply with the new regulations. I also note that there is difficulty in ensuring conformity of the Flamanville 3 EPR nuclear pressure equipment, as well as in ensuring the erection of the main large components and the auxiliary systems.

Transporting a new steam generator at Cruas Nuclear Power Plant

This situation is disorganising the maintenance operations in the nuclear plants, while affecting the workload, the serenity and the morale of the staff, and hence nuclear safety. It is greatly complicating the work of French and non-French players in the industry as the unstable requirements of the nuclear pressure equipment order


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make it hard to organise their work, and some are even contemplating leaving the industry.I note that the experience feedback from steam generator replacement in France shows proper mastery of design and fabrication, acquired in partnerships between EDF and the vendors. I also observe that no significant problems have been encountered with the replacement steam generators. Given the circumstances, priority needs to be given to replacing original steam generators with new steam generators, without seeking too many complications. This is in concordance with the ASN position that old equipment should be replaced when beneficial to nuclear safety.I believe it a good idea to dissociate the equipment considered acceptable under the previous requirements from the current discussions between the ASN, the manufacturers and EDF SAon the practical terms and conditions of applying this ministerial order as regards, for instance, risk analysis. In these discussions, I recommend that a pragmatic approach be adopted to obtain nuclear pressure equipment that is designed, manufactured and operated with due regard to the nuclear safety requirements.Here, I consider it essential to maintain exchanges and technical dialogue and to prioritise what is important to find common ground and overcome these sticking points, possibly by high-level intervention.

Skills: keep up the pressure as we are half way there

Nuclear safety is as much a human matter as a technical and organisational one. It greatly depends on the staff, their skills, their experience and their individual and collective behaviour.In France, EDF SAis under growing a very substantial staff turnover affecting all the professions in the nuclear industry: 40% of the staff at the Nuclear Engineering Division and the Nuclear Generation Division have less than five years’ experience. The greater part of the generation that built and commissioned the nuclear power plants has left EDF SA. During my visits, I assessed the effectiveness of the recruitment and training arrangements to ensure staff replacement. In view of the shape of the age pyramid, the departure rate will not be slowing and I consider it essential to keep up the recruitment, training and integration efforts. The situation in the UK is totally different, as the incoming and outgoing flows are relatively stable. The EDF Group is attractive and has little difficulty in recruiting staff in adequate numbers and of adequate

quality, particularly as regards recently-qualified engineers. Incomers are generally satisfied with the training they receive on arrival and the manner in which they are received in the departments and plants. The presence of young new arrivals that are duly qualified and with open minds represents an opportunity to more broadly disseminate nuclear safety practices and culture.In every team, it is important to mix the generations so that they can benefit from each other: the young have questioning attitudes and are willing to innovate, while the senior staff have experience, knowledge and know-how. In France, the transmission of knowledge is all too often difficult and patchy: too many new arrivals compared with the number of experienced staff still present, and the knowledgeable staff being monopolised by increasingly heavy workloads. The relatively large number of new arrivals in the teams necessitates particular vigilance in view of the potential impact on nuclear safety and the quality of work.During my visits, I was struck by number of young people in positions of responsibility. They are quickly placed in professional working situations, which is excellent for their integration, their motivation and development of their skills. I feel greatly encouraged by the fact that the good results achieved in 2014 were obtained with staff of which approximately half had less than five years of experience.

Mentoring and training

Although integration of new recruits generally takes place without difficulty, their skills develop progressively and the acquisition of experience with difficult tasks requires practice, and hence time. Accordingly, in many domains (operation and automation in the Nuclear Generation Division, design in the Nuclear Engineering Division etc.), incomers can only be fully operational after three to five years, if not longer. Moreover, it takes considerable time for them to progress through the company, particularly to become managers and experts. The lack of sufficiently skilled staff, who are in short supply in certain areas (operation planners, safety engineers, design engineers


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etc.), will continue for several years, which is liable to result in weaknesses, particularly the field of nuclear safety.I ask that managers pay attention to these weaknesses and be more present in the field, as well as being more active in the monitoring their staff training. Within the Nuclear Generation Division, there is a skills programme that fulfils this last need. The situation is similar in most EDF SAcontractor companies for whom nuclear safety and work quality are vital too.To maintain the effectiveness and the motivation of these new arrivals, the professional career trajectories need to be made more attractive, particularly by crossovers between professions, between engineering and operations and between EDF SAand EDF Energy. Provided the efforts are maintained, the EDF Group will, in a few years, greatly benefit from the abundance, the quality, the nuclear safety culture and the proper integration of this well-trained and dynamic upcoming generation.

In the AGRs: special vigilance needs to be paid to plant life duration

As the sole survivors of what was once a unique family, the 14 AGRs belonging to EDF Energy in the UK are encountering problems that are specific to their type for which no international experience feedback is available to assist them as is the case for PWRs.In 2014, a crack was discovered in one of the steam generators of a reactor at the Heysham 1 Nuclear Power Plant. The metallurgy of the components of these steam generators is complex and can be a source of weakness. Furthermore, as AGRs operate at high temperatures of around 600°C within the steam generators, the structures are vulnerable to creep fatigue.Without misjudging the difficulties arising from the design of these steam generators, I recommend reinforcing their in-service monitoring by using predictive means to anticipate any deterioration and to ensure that the nuclear safety margins are preserved.The condition of the graphite, used as the moderator in AGRs, also determines their service lives. Under the effect of neutron bombardment and oxidation, this non-replaceable graphite loses weight and starts to crack. In the event of a major earthquake, such phenomena could prevent the control rods from dropping to automatically shut down the reactor and could impede the circulation of the gas that cools the reactor core. I would like to emphasise the considerable efforts that EDF Energy has taken to control graphite ageing and to assess and regain the margins, notably by setting in place

additional means of protection. Here again, assessment of the margins need to be substantiated by a more ambitious in-service monitoring plan.Long-term operation of these reactors requires special vigilance and more careful forward planning by the entire EDF Group, making use of its high-level engineering skills, particularly those in the Nuclear Engineering Division of EDF SAand in the Research and Development Division of EDF.

Qualification testing methods on a mock-up of a central

boiler spine of the Heysham 1 reactor

The double objective of the General Refurbishment in France: maintaining nuclear safety during maintenance and improving it in the long term

EDF SAhas begun a programme of a scale unparalleled since the construction of its nuclear power plants. This programme will last about 10 years and will prepare for reactor operation beyond 40 years while, at the same time, integrating the second and third phase of post-Fukushima modifications. This work will include nuclear safety improvements associated with the 10-yearly inspections and all the routine maintenance operations.I have seen how the scale of the changes is perceived by the personnel. Although I have heard worries being voiced here and there, most of those I met were confident and encouraged by the way in which an industrial programme of this scale can bring people together.Nuclear safety is fundamental to these operations, most of which are intended to strengthen it, as expected by the ASN which calls for improvements in the reactors in service with regard to the nuclear safety goals applicable to new reactors. In bringing things up to standard, especially when carrying out activities that are onerous and often complex, the nuclear safety of the plants in service must be guaranteed at all times. The process must therefore be one of improvement in a reasonable


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timeframe with regard to the industrial realities and the everyday requirements of nuclear safety. I consider that the priorities need to be determined, as there is a risk of losing overall control in trying to do everything all at once. The pace and the scale of the work depend on the capacity of the nuclear generating sites to function in total safety. I am pleased to see that the plant directors have prime responsibility for assessing this capacity. They also have much else to manage, notably establishing a strong multi-year programme.Success with the General Refurbishment will necessitate the general mobilisation of the company, predictably the teams at the Nuclear Engineering Division who are extremely busy with concurrent major projects (Flamanville 3, Hinkley Point C, etc.). I have seen the Nuclear Engineering Division engineering centres’ efforts to adapt and innovate when organising these major projects. This general mobilisation will need to extend to the contractors who are still waiting to find out how the programme will be scheduled. The manner in which

the General Refurbishment is to be organised has been described to me. The Nuclear Generation Division will be in charge of the organisation, which seems appropriate, and its effectiveness will depend on decisive action by the different stakeholders. I note that the build-up will be progressive and that the operations will be carried out at a realistic pace, which will be favourable to nuclear safety.I consider that there is sufficient visibility ahead for the next three years and that the choices already made have made it possible to plan things properly. But around 2019-2020, at the start of the fourth 10-yearly inspections for the 900 MWe reactors and the end of the second phase of the post-Fukushima modifications, there remains considerable uncertainty outside the control of EDF SA.In view of the need to plan ahead properly for such an extensive programme, I recommend maintaining the schedule for determining the nuclear safety options linked to these fourth 10-yearly inspections.

cOnTRASTIng TREnDS In nUcLEAR SAFETY In DIFFEREnT SETS OF PLAnTS THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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2/ CONTRASTING TRENDS IN NUCLEAR SAFETY IN DIFFERENT SETS OF PLANTS

Operator in the control room at Saint-Laurent Nuclear Power Plant

The 2014 results for the French nuclear power plants were satisfactory, with less disparity between the plants, confirming the improvement observed in 2013.

The results for the EDF Energy plants have deteriorated due to considerable disparity between the plants which calls for renewed vigilance.

OPERATIONAL RESULTS

In the French plants

I would first like to point out that not a single Level-2 nuclear safety significant event on the International Nuclear Event Scale occurred for the second year running.I note a further drop (-4%) in the number of events graded Level 1 on the International Nuclear Event Scale (1.14 per reactor) compared with 2013. The total number of nuclear safety significant events of Level 0 and 1 dropped slightly (10.8 per reactor), reflecting the high levels of openness practised by these nuclear power plants.I am pleased to see improving and more consistent nuclear safety results in the 19 plants, as well as improvements in other fields (unit outage duration

control, generating etc.). In the plants, I have observed the increasing standardisation of job management methods, focusing on operational performance. I note with satisfaction the accurate monitoring of the nuclear plants now taking place at corporate level, making it possible to provide appropriate support when needed.In 2013, my predecessor warned about the negative effect of excessive unit outage extensions (26 days per outage) on nuclear safety. I note that, this year, the significant progress in this field has been very beneficial to nuclear safety. With extensions being reduced to an average of 9 days, with more realistic scheduling targets being adopted (+5 days on average), the situation is far more favourable to staff serenity and the quality of operations. I expect this positive trend to continue.In 2014, I also observed the high level of integration of the recommendations issued in the Overall Assessments

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION cOnTRASTIng TREnDS In nUcLEAR SAFETY In DIFFEREnT SETS OF PLAnTS

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of Excellence by the EDF Nuclear Inspectorate and the WANO Peer Reviews, the respective factors being 76% and 79%, signifying significant progress. Follow-up of the SOERs15 also improved, the factor being 68%. This spectacular progress, the fruit of strong management leadership, needs to continue.

Progress in key areas

The number of automatic reactor trips reached a figure of 0.53 per reactor, corresponding to its best level between 2011 and 2012. This is a satisfactory result, even in terms of the best international figures (0.60 automatic and manual reactor trips16 for 69 PWRs17 in the US). In 2014, there were no automatic trips in 34 of the 58 reactors. I would like to draw attention to the impact of the human factor (55%), which merits examination.

0,69

0,60

0,2

0,4

0,6

0,8

1,0

1,2

1,4

Mean number of automatic trips + manual reactor trips per year and per unit

Automatic trip + Manual trip/ year/ unitUS PWRs (65 reactors)

Automatic trip + Manual trip/ year/ unitFrench PWRs (58 reactors)

Comparison of the number of automatic and manual reactor

trips in PWRs in France and the US

I also note the progress made, once again this year, concerning fire, a major potential hazard. I note the small number of outbreaks of fire and positive trends in the fields of prevention, organisation and fire-fighting in all the plants. Also, the onsite emergency response plan was not activated in 2014 for fire, nor were there any significant fire-related events (2 in 2013).I would like to emphasise the vigilance of those involved and the excellent organisation that confirmed proper control in the field of administrative lockouts, which are operations that have major nuclear safety implications. In 2014, there were no violations of administrative lockouts in 50 reactors. The organisation of surveillance tests, which establish the availability of equipment and systems important to nuclear safety, remains satisfactory.

15 Significant Operating Experience Report16 Known as AMR in France (Arrêt Manuel Réacteur)17 Pressurised Water Reactor

I am pleased to see that for the last 3 years, the forced loss rate (FLR) for the reactors (2.4%) has been maintained at a good level. This is the result of vigorous action by all the professions, led by dynamic and well-organised “units in service”18 teams. This also reflects the growing influence of AP91319 which ensures that progress will continue well into the future. At the end of 2014, the forced outage factor did not exceed 1% in 22 nuclear units. There was also a drop in the number of work requests, which fell to a level rarely reached in the past (reduced by half in 5 years), showing a growing ability to properly control the means of production on a daily basis. I would like to encourage this trend, with care being taken to properly prioritise the work requests liable to affect nuclear safety in the context of properly managing the amount of maintenance work.

0

1

2

3

4

5

6

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

French EDF fleet

Average Forced Loss Rate factor (FLR)

US PWR fleet

FLR

(%)

Comparing the average forced loss rate of PWRs in France

and the US

I would like to emphasise the excellent availability factors of the engineered safety features, i.e. those of the safety injection system20, the auxiliary feedwater system21 and the standby diesel generators, which sit at 0.02%, 0.0% and 0.03% respectively.

Issues of concern

I would like to draw attention to the number of nuclear safety significant events corresponding to violations of the technical specifications for operation, which can be likened to a kind of highway code for nuclear operators (1.55 per reactor). After improving in 2013, the deterioration (+15%) mainly results from the substantial increase, over the last 3 years, in the number of excursions outside the authorised operating envelope, associated with control problems and equipment faults. Problems relating to skills are apparent (knowledge, know-how, awareness of physical phenomena

18 Known as TEM in France (tranche en marche)19 INPO Advanced Process 913 which lays down standards and

processes for continuously improving equipment and systems20 Known as RIS in France (Injection d’eau de secours)21 Known as ASG in France (Alimentation de secours des

générateurs de vapeur)


15

and equipment behaviour) in 70% of all control-related nuclear safety significant events. I consider that mastery of the nuclear safety rule set needs to be the nuclear operator’s top priority and I call for vigorous action to improve the situation in the nuclear power plants. I will make a point of checking this in 2015.Like my predecessor, I am focusing on difficulties in having complete control over activities: planning, risk analysis, technical checking, practices relating to reliability and requalification. This type of situation always leads to high numbers of nuclear safety significant events associated with substandard quality (more than two thirds of all such events), during unit outages and when in service, whether during activities relating to operations (control in 90% of the cases) and maintenance. For instance, the amount of alignment errors increased (by 25%) after perceptible progress in 2013. These events in 2014 have had less impact on nuclear safety and generating outages, but I consider the persistence of such a high number calls for decisive action.In 2013, the Nuclear Generation Division set in place the MQME22 project, intended to address these issues. During my visits to the plant, I saw the difficulties faced in making progress. I note extreme differences between plants. It is up to the plant managements to focus on this if significant change is to be achieved in the short term.Finally, I would like to draw attention to the persistent number of significant events relating to core reactivity control in service. I wish to highlight the importance of ensuring proper control over physics-related phenomena, particularly by the control room operators. My predecessor was pleased to report in 2013 that the Nuclear Generation Division had made its requirements more stringent. I have seen how motivated the people and professionals are, notably on the basis of the reviews of responsiveness first carried out at corporate level in the spring of 2014 and then in all the plants.I would also like to emphasise that events associated with fuel handling are continuing to occur, revealing shortcomings in the maintenance of fixed and mobile equipment, and in the training of machine operators, even though this may have been upgraded in recent years. This activity needs to be recognised as being important, to avoid any risk of it being considered a routine matter.

Dampierre Nuclear Power Plant

22 Project to improve the quality of maintenance and operations

In the plants in the UK

Although I note that, as in France, no Level-2 nuclear safety significant event occurred regarding the International Nuclear Event Scale, I would like to highlight an event affecting Reactor 1 of Heysham Nuclear Power Plant. I appreciate the decision-making process that was rigorous and conservative in terms of nuclear safety, which led EDF Energy to immediately shut down the three other reactors of the same type (Heysham 1 and the two Hartlepool reactors). This event was graded Level 1 on INES and was the only Nuclear Reportable Event23 that occurred in 2014. It is covered in detail in Chapter 10.I observe that the number of nuclear safety significant events graded INES Level 0 and Level 1 has been relatively stable in recent years (4.5 per reactor), with different declaration procedures in the UK and France reflecting the requirements of their respective nuclear safety authorities.I would also like to draw attention to the widening gaps in results between the eight plants operated by EDF Energy. This considerable disparity in performance, primarily in nuclear safety, calls for action at plant and corporate levels. The plants that have been lagging behind for too long need to be provided with the necessary support to achieve the levels of performance expected of them. I am pleased to see the initial action taken by EDF Energy and will make a point of the results being shown to me in 2015.

grounds for satisfaction

I noted the good availability figures for the AGRs, the engineered safety features, the safety injection system (0.23%), the auxiliary feedwater system (0.06%) and the standby diesel generators (0.30%) as well as the exceptional figures for the Sizewell B PWR, with 100% availability for a number of years, largely due to its robust design with four nuclear safety trains.Sustained progress has been made with operating the AGR fuel handling machines, which are important in terms of nuclear safety. The improved results are partly thanks to the great efforts made to render this equipment more reliable. I note that the fault affecting a fuel assembly in Reactor 4 of Hunterston B has been corrected.I am pleased to see how many of the recommendations from the WANO peer reviews have been taken into account, corresponding to more than 90%, putting EDF Energy at the top of the class. The way in which the Significant Operating Experience Reports have been

23 The highest level of event declaration for the UK regulator


16

taken into account is also remarkable, with an improved factor of 90%.

Issues of concern

What the British plants have in common with the French is the repeated violation of the technical specifications for operation (1.53 per reactor), giving rise to numerous nuclear safety significant events24. The level reached this year calls for prompt corrective action in the worse-ranked British plants.Once again, this year, I would like to draw attention to the insufficient level of fire prevention measures. No significant outbreaks of fire or actual fires were reported in 2014, and the number of minor outbreaks of fire slightly diminished. However, this is an area where vigorous corrective action is required. In particular, there was a series of outbreaks of fire in a particular plant which resulted in an automatic reactor trip and the unavailability of equipment important for nuclear safety (gas turbines).My findings during my visits confirm the observations repeatedly made during the WANO peer reviews. I note corporate-level coordination by the manager in charge of fire protection and the initial positive results to reduce oil leaks in certain plants, but the situation remains inconsistent. I encourage further assessment with the assistance of experts from the French plants and involvement from the Independent Nuclear Assurance25. I ask the plant managers to return to these assessments to ensure significant improvement in this field which is vital for nuclear safety.At EDF Energy, automatic scrams need to be considered together with manual reactor trips as the British procedures more frequently require the operators to manually trip the reactor before the automatic functions operate. After 2 years of stability at a level already too high, there was a significant increase in the number of trips (1.79) in 2014, far higher than the best international rates and those of EDF SA. There is considerable disparity between the plants (between 0 and 14 trips per plant) and very high numbers of trips due to equipment faults.I also note deterioration in the forced loss rate for the reactors (units in service) which reached 10.7%, deviating further from international standards (less than 2%). This result reflects the shutdown of four reactors at Heysham 1 and Hartlepool, due to steam generator issues (see Chapter 10). I note that there is still considerable disparity in performance, with three plants accounting

24 These have been defined in the same way by EDF SA and EDF Energy since 2012 (known as ESS in France)

25 Independent safety body at EDF Energy (formerly the Safety and Regulation Department)

for more than 20% of the outage and four plants less than 4%. Nevertheless, some of the oldest AGR plants regained their excellent rates of the past, comparable to those of PWR plants, despite being considered harder to operate. At the plants, I was able to see positive impact of management that focuses on operations on a long-term basis.

Sizewell B Nuclear Power Plant

ANALYSIS OF PRECURSOR EVENTS

Information on precursor events26 is gathered from international experience feedback. They are also the subject of the EDF SAprecursor event programme organised by UNIE27, the quality which I would like to hail. I note that the trend is positive since 2000 with, no significant precursor event since 2007 and no important precursor event since 2011. In 2013, 16 precursors events were identified out of almost 700 nuclear safety significant events, all graded below the important precursor event level.These studies and the international feedback indicate that electrical power loss incidents are the cause of 50% of the core meltdown risk. Careful attention needs to be paid to the systems required to control such incidents: transformers, standby generating sets and standby turbine-driven generators.

FUEL PERFORMANCE

I would like to emphasise the importance of nuclear fuel reliability, as it is the fuel cladding that constitutes the first technical barrier of the defence in depth.In France, action has begun in the last few years ranging from the fuel assembly design to the FME28 campaign

26 Events for which the conditional probability of core meltdown is greater than 10-6 per reactor per year. Events of a conditional probability greater than 10-4 are termed important and those of a conditional probability greater than 10-3 are termed significant

27 Operations Engineering Unit28 Foreign Material Exclusion


17

intended to protect fuel cladding from mobile foreign objects during operations. After a good year in 2013, with a fuel assembly failure rate of 0.11%, I see that the results are not as good in 2014 (0.21%). A total of 17 fuel assemblies (out of the 8172 removed) from 9 different reactors were no longer leaktight. This result needs to be compared with that of the PWRs in the US, which are substantially better as a result of their “zero fault” policy.I would also like to stress the need to have full control over the fuel handling activities in view of the unexpected events in 2014 - some which were graded Level 1 on INES - having resulted in the stacking of fuel assemblies in two nuclear units for instance. Such events reveal lack of rigour but they have not had any actual consequences on safety. However, I can only encourage the plant managers to ensure the teams in charge of these sensitive operations are properly trained, particularly in reliability practices.In 2013, fuel assembly distortion liable to reduce the effectiveness of control rod dropping, which is essential for nuclear safety, was observed in certain 1300 MWe and N4 reactors. I was shown the progress of the studies and actions undertaken by EDF SAand AREVA, with particular regard to increasing the rigidity of the fuel assemblies. I note the decision in 2014 to abandon the GALICE29 mode, used only in the Nogent 2 reactor and resulting in greater deformation.I would also like to highlight the decision relating to fuel assemblies with Zircaloy 4 cladding. This cladding is less corrosion-resistant than cladding made of advanced alloys, such as AREVA’s M5 or Westinghouse’s ZIRLO. This is why no new Zircaloy 4 fuel assemblies will be loaded into the reactors from 2016. I would like to stress the importance of the policy of having a diversified portfolio of fuel suppliers, which the EDF Group has adopted. This could well be extended to the CP0 and N430 nuclear units, given that the availability of fuel assemblies compatible with accident-situation requirements and offering sufficient nuclear safety margins in the various core fuel configurations.In the UK, the failure rate for AGR fuel assemblies is satisfactory, with a maximum of 6 found not to be leaktight in the last 5 years. The introduction of a new type of fuel assembly, termed “robust fuel”, with a new grid technology will further increase reliability. It will be made universal in 2017. I was shown the action taken to counter the phenomenon of carbon deposition that

29 One of the fuel management modes of the 1300 MWe reactors intended to achieve high burn-ups

30 CP0: 900 MWe reactors at Fessenheim and Bugey Nuclear Power Plants. N4: 1450 MWe reactors at Chooz B and Civaux Nuclear Power Plants

has appeared in 6 reactors. I note the progressive loading of new “pre-oxidised” fuel assemblies that do not suffer from this type of the deposition, but would like to draw attention to the importance of continuing the studies to identify the cause of this phenomenon.

Fuel assembly handling

PERFORMANCE IN THE FIELD OF CHEMISTRY

My predecessor has been insisting since 2012 on the need for greater consideration of chemistry in operations in France. I met some of those involved. Immediate and short-term issues raised by the plant chemists are being properly taken into consideration by the unit outage teams, with greatly improved support from the operating teams. I also note the encouraging WANO assessment of the performance of the French nuclear units, which can be ascribed to greater operator focus on the chemistry specifications. However, I am not certain that the chemists are being properly heard yet in their call for compliance with certain operational requirements affecting nuclear safety in the long term (in particular as regards unit outages for drying and preserving the feedwater train) and guaranteeing the durability of steam generators.Although the situations still vary greatly in terms of skills, I am happy to see the corporate-level initiative taken to address these questions and the establishment of a framework of consistency for the chemistry professionals, equivalent to those drawn up for the other technical professions.I would like to draw attention to the state of the laboratories in the nuclear power plants; they are all too often ageing badly and poorly located. I encourage the senior management of the plants to address these issues to ensure that this profession vital to nuclear safety be duly recognised and re-invigorated.


18

TESTING THE POWER GRID CONNECTION

I would like to draw attention to the importance of testing the power grid connection for nuclear safety. Such tests have been carried out in France by plant staff and RTE31 staff to verify, in each nuclear power plant, the various possibilities for reconnecting to the external power supply (voltage return tests). This is done so as to be able to cope with major grid faults. In addition to the possibility of this supply by its own standby generators, each plant has three scenarios available for voltage resupply, many of which depend on the EDF SAhydropower capability. One scenario must be tested by each plant every year, frequently with complex testing configurations necessitating close cooperation between the plants, RTE, COPM32 and DTG33. Here again, I have remarked upon the considerable difficulties involved in conducting these tests, often due to the constraints evoked by the nuclear power plants (30 deferments and cancellations in 2013, 10 in 2014).I have seen that the nuclear safety implications are properly understood by the national grid staff in charge of the tests. I am pleased to see that proper technical discussions have been resumed and the technical terms and conditions of these tests were jointly updated in 2014. I ask the NPP managers to ensure that these actions are properly conducted.

31 French national grid company32 Power Sales Management Centre33 General Technical Division

MAKIng SAFETY cULTURE cEnTRAL TO MAnAgEMEnT THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

19

3 / MAKING SAFETY CULTURE CENTRAL TO MANAGEMENT

Fessenheim Nuclear Power Plant: briefing in the control room

The managers of the EDF Group would benefit greatly from developing nuclear safety culture to make further progress with due respect for rigour and quality.

Reinforcement of the internal nuclear safety oversight teams - independent of the operational departments - contributes to continuous improvement.

In France, composure and effectiveness could be fostered by better prioritising projects and assigning greater responsibility to the operational units.

DEVELOPING NUCLEAR SAFETY CULTURE AT ALL LEVELS

IAEA34 recommendations In 1991, the IAEA defined the notion of nuclear safety culture in INSAG 4 in the wake of the Chernobyl accident on 26 April 1986.

Inspiration needs to be taken from the principles of action expressed in this seminal document and subsequent experience feedback from events: a questioning attitude, prudence and rigour in action, and openness in communication. These principles should 34 International Atomic Energy Agency

not only guide managers and technicians in their everyday work, but also corporate-level managers in their decision making process.I note scope for progress in converting the initiatives taken by the plants into results and lend life to these principles of action. Many nuclear operating safety events could have been avoided simply by applying these principles (see Chapter 2). I encourage managers to make more explicit reference to them.

Assessing safety culture

Safety culture is a living thing and needs to be regularly tended. There are no reliable methods for assessing

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION MAKIng SAFETY cULTURE cEnTRAL TO MAnAgEMEnT

20

levels of nuclear safety culture. At EDF Energy, I have observed that safety culture surveys are conducted every two years in every plant. In France, I am pleased to see the development of assessment means within the Nuclear Generation Division (self-assessment and in-plant watch). I was shown the nuclear safety culture guidelines project, intended to assist the managers in their action, notably by participation arrangements facilitating socio-managerial diagnostics and also by highlighting noteworthy international events. I have taken good note of the work by INPO35 and the Nuclear Regulatory Commission (NRC) to find a common vision of nuclear safety culture, as well as the WANO approach to determine a system for assessing safety culture, to which EDF Energy has provided active support. I wholly encourage EDF SA’s participation.

The Nuclear Generation Division’s nuclear safety culture guidelines

Nuclear Generation Division’s nuclear safety management guide

The Nuclear Operations Department already relies on the EDF Group’s nuclear safety policy and a specific nuclear safety management guide. By publishing its own guidelines, the division is also seeking to give the nuclear power plant staff common reference points in nuclear safety culture.A corporate-level working group bringing together plant representatives produced a set of guidelines and a method for its utilisation in 2014.The development of nuclear safety culture is considered to depend on three factors:

• acquisition of skills,• self-positioning,• communication.

The nuclear power plants began using the guidelines in 2013 after a period of experimentation, which are now being monitored on a corporate level.

35 Institute of Nuclear Power Operations

Organisations dedicated to managing nuclear safety

Like my predecessor, I emphasise the importance of venues where nuclear safety is discussed at plant and corporate levels. These points of intersection foster consistency: plant nuclear safety committees, corporate nuclear safety committees for operations and design in France, the Nuclear Safety Committee (NSC) for EDF Energy, and the Nuclear Safety Council for the EDF Group.I note the creation of Nuclear Safety Review Boards (NSRBs) by EDF Energy for some of the first sites in 2014, as well as the attendance of suitably-qualified outsiders at the NSCs and the NSRBs. This practice, which is very common in the English-speaking world, is recommended by the IAEA and WANO. At EDF SAin 2014, the Operational Safety Analysis Review Team encouraged its adoption. I have observed initiatives by the senior management of the French and British nuclear-power plants to organise reciprocal participation of plant directors during the CSNE36 and Nuclear Safety Review Board sessions.I would like to emphasise the need in France for arrangements such as the Nuclear Safety, Radiation Protection, Availability and Environmental Watch for actual cases where decision-making processes may have compromised nuclear safety. I have found good practices in certain plants, but regret that there are no Nuclear Safety, Radiation Protection, Availability and Environment Watches in many other plants. I invite nuclear power plant directors to re-invigorate this policy.

Managers who develop nuclear safety culture

By their attitude, managers can encourage the development of safety culture. They need support. I have noticed the scope of the EDF Energy leadership programme, its vitality and its positive effect on managerial cohesion. I am struck by the space it occupies in nuclear safety culture, and how it has been extended to technicians in the field whose leadership potential has been noticed. During my visit to Palo Verde Nuclear Power Plant in the US, I was shown the leadership model that made it possible, from 2007, to rebuild nuclear safety management at the plant, which was then in considerable difficulty and is now one of the most efficient ones.In France, I encourage plant and corporate management to promote the recently introduced leadership programme using British experience as a basis and to seek more active participation from human factor consultants.

36 Operations Nuclear Safety Committee


21

I also strongly encourage the use of the nuclear safety management guidelines supplied to all the plants in 2013.

BETTER PRIORITISING OF PROJECTS IN FRANCE

Prioritising and simplifying

Even his last report, my predecessor stressed the need to better prioritise action and hailed the way the Nuclear Generation Division was really focusing on priorities in 2013: nuclear safety and unit outage control. In the plants, I was able to assess the effects of this decision, which are highly positive, primarily felt through the serenity of the staff. I would like to emphasise positive changes in the corporate departments, properly focused on these priorities and providing the nuclear power plants with better support. Furthermore, I note the beneficial effects of a more rationalised organisation for each nuclear power plant individually and for the fleet as a whole, reflecting the Nuclear Generation Division’s IMS37. I would like to draw attention to proper balance in using this tool, which needs to remain simple otherwise it will distance managers from their staff.I hail the initial initiatives to foster simplification (job documentation and rules sets) and I encourage pragmatism, as early victories will inspire confidence.I have noticed scale of the internal changes in the Nuclear Engineering Division, with the DINamic 2020 Project that is intended, by greater cooperation, to strengthen not only the professions and management of projects, but also the effectiveness and coherence of actions launched by the engineering centres.Like my predecessor, I would like to point out to the staff entities of the EDF Group the importance of limiting their demands to allow the line entities to focus on priority issues.

Better support for change: the example of the SDIN38

The deployment of this new computerised system has advanced substantially: four Nuclear Generation Division generating sites and virtually all of the engineering groups now use it. I note with satisfaction the positive feedback from those with this system about how good and helpful it is. I have taken good note of the fact that some eagerly-awaited functions are not

37 Integrated Management System (DPN)38 Nuclear Technical Information System

available (particularly multi-year scheduling). Integrating this capability in the application is not a major problem, and the main difficulties are associated with initialising the data and with accepting new standardised modes of operation, particularly in the field of maintenance.If the standardised maintenance procedure changes are not integrated quickly enough, there is a risk that each plant will return to its own ad hoc procedures. Any such trend would compromise quality, if not nuclear safety.Each plant is to be considered to be the first of a series and I would like to draw attention to providing durable support, until the last plant has been included in 2018. I would also like to alert the plant directors about forward planning for this project which is of a nature to foster profound change in the professions. Furthermore, the quality of standardised operating documents drawn up for the standardised series of nuclear units needs to be assessed and rapid feedback must be provided from the plants. The requirements associated with PIA39 as defined in the ministerial order on Licensed Nuclear Facilities (INB40) must apply. There is also a need to establish the principles of governance for this new technical data system that lends structure to all it encompasses. In 2015, I will make a point of assessing these risks and monitoring the deployment of the Nuclear Technical Information System.

PLANTS WITH MORE RESPONSIBILITY FOCUSING MORE ON THE PROCESS

In France, like my predecessor, I am happy to see greater responsibility being borne by the nuclear power plants in general and their directors in particular. The manner in which the amount of maintenance was reappraised in 2014 and the principle announced for organising the General Refurbishment (plant directors as decision-makers) are clear signs of this change. The same approach is being used for the Nuclear Engineering Division’s DINamic 2020 Project, which assigns responsibility to the engineering centres, notably by managerial innovations (see Chapter 7). In the UK, organisation of the nuclear power plants as a whole is highly decentralised with the plant directors bearing much responsibility, which greatly contributes to corporate level leadership (there is a sponsor station director for every major issue). I can see the positive effects of this approach, but I would like to draw attention to the need to involve the plant engineering forces in complex matters relating to AGR technology.

39 Protection-important activities as defined in the INB Order 40 French abbreviation for Installation Nucléaire de Base (licensed

nuclear facility)


22

During my visits, I noted the positive effects of plant management being centred on operations and equipment (operational focus), while in France those in charge of the plants are becoming increasingly involved in such activities. The plants that organise activities around reactor operation are regularly achieving good results in terms of nuclear safety and power generation, in both EDF SAand EDF Energy. At Palo Verde Nuclear Power Plant in the US, I particularly noticed this in both everyday activities and accident situations.I can only encourage the Nuclear Engineering Division’s engineering centres responsible for the plants in service in their efforts to organise themselves based on the priorities and the constraints of unit outages.

Training in practices to increase reliability

THE ADDED VALUE OF INDEPENDENT INTERNAL OVERSIGHT BODIES IN EDF SA

I would like to emphasise the positive role of the internal independent bodies in EDF SAwhich ensure the oversight of issues important for nuclear safety. Their existence and vitality are signs of the operator’s capacity to bear its responsibilities. Their skills are of the highest levels. Although I am pleased to see that the ASN is promoting them, I would like to say that these bodies must be allowed to take their due places as regards delegated responsibility.

The User Inspection Organisation, an independent internal oversight body

I have met members of the User Inspection Organisation at EDF SA(attached to the Nuclear Engineering Division) whose primary task is checking the manufacture of some equipment for the EPR in Flamanville 3). The ASN keeps a close watch to ensure strict compliance of impartiality of this type of organisation in its technical assessments and rulings; the Inspector General for Nuclear Safety

and Radiation Protection constitutes the highest internal echelon for referral within EDF SA.I have verified the strength and depth of the User Inspection Organisation and the manner in which it has organised the action of its inspectors. I hailed the important work carried out by the User Inspection Organisation relating to its doctrine. Here I would like to reiterate my predecessor`s warning of the risk of seeing the User Inspection Organisation being increasingly side-lined by an overbearing regulatory authority in checking activities where powers have nevertheless been assigned under extremely strict and demanding conditions. This organisation, which represents a major investment by EDF SAfor Flamanville 3 equipment fabrication work, may have its tasks extended to cover the plants in service.

In the plants: the Authorised Internal Inspection Departments

I have met members of the Authorised Internal Inspection Departments and found them to be keen and confident in technical management of risks associated with pressure, well supported by the plant directors and integrated in the industrial landscape for some 10 years. However, I am surprised to see that the Authorised Internal Inspection Departments in the power plants do not have same scope of responsibility as their counterparts in conventional power plants with respect to the equipment. Staff members are finding their inability to carry out periodic requalification inspections increasingly hard to understand. I suggest that a review be made with the different stakeholders (the ASN’s DEP41, accredited organisations) to plan ahead. This being the case, I am left wondering about the need to extend the remit of the Authorised Internal Inspection Departments in the light of the ministerial order on Nuclear Pressure Equipment, the provisions for the application of which are not yet finalised.

In the Nuclear Generation Division: the internal licensing system

In 2014, the ASN authorised the introduction of an internal licensing system for certain temporary modifications to the technical specifications for operation requested by the nuclear power plants. This system which lays responsibilities on the operator is based on a clear organisational system and the skills of the corporate engineering staff in the Operations Engineering 41 Pressure Equipment Directorate


23

Unit and the Power Plants Operations Engineering Centre (CIPN). I would like to draw attention to the role played by the internal oversight body, headed by the nuclear safety director of the Nuclear Generation Division or a person delegated by it, all members of the independent corporate-level network.

Commission for the configuration of non-destructive testing applications

This is a staff body attached to the Nuclear Engineering Division responsible for qualifying non-destructive tests on the reactor coolant system and secondary cooling system of nuclear power plants in-service. It is certified by COFRAC42.I hail these arrangements relating to activities that are particularly important for nuclear safety, as regards both the reactors in service (240 applications qualified to date) and for the future operation of Flamanville 3. I call for the equipment qualification work carried out for Flamanville 3 to be put to good use in the plants currently in service.

INDEPENDENT INTERNAL NUCLEAR SAFETY OVERSIGHT IN FRANCE

Official Safety Engineer bodies

Willingness to heed the Safety Engineers depends on closeness of their relations with the plant director. I encourage certain practices being made universal, such as monthly face-to-face meetings, which are highly appreciated by the Safety Engineers.I note that many of the Safety Engineers are young, almost all being newly-qualified engineers. There are still ongoing difficulties for recruiting Safety Engineers, particularly in plants with two nuclear units. Some directors have increased the manning levels beyond that required: I encourage this type of initiative.Although I am happy to see the beginning of more balanced profiles among the Safety Engineers (50% are newly-qualified engineers, where as in 2013 the proportion was 60%), I would like to draw attention to the regular drop in the number of Safety Engineers coming from the operating departments (operations shift managers and assistant operation shift managers) depriving them of manpower diversity conducive to nuclear safety. The profession lacks attractiveness and I call on the plant directors to take action.I would also like to stress the collective strength of the Safety Engineers and the way they function in an 42 French official accreditation body

open manner to regularly combine all skills available to properly ground their nuclear safety analysis. I encourage such practices that help reinforce the legitimacy of Safety Engineers who are often, by the nature of their job, obliged to defend their nuclear safety position single-handed.

Maintenance activities that the Independent Internal Nuclear Safety Oversight Networks do not challenge enough

The auditors who verify the maintenance activities always have a difficult job in the nuclear plants, with very mixed teams in terms of numbers and profiles. I emphasise the need to reinforce these teams, which in some cases can only correctly perform their work with the support of Safety Engineers to the detriment of their primary mission. Many of the plants thus deprive themselves of an excellent means of challenging the maintenance services and raising standards in a field now in difficulty (see Chapters 2 and 6). I encourage initiatives to raise the profile of these functions, particularly through greater career recognition.

Implementing practices to increase reliability

Independent Internal Nuclear Safety Oversight managers are under constant pressure

At the highest echelon of the Independent Internal Nuclear Safety Oversight networks in the plants, the heads of the Quality and Nuclear Safety Advisory Units, referred to as the nuclear safety directors, lead the network’s staff in the plant (nuclear safety engineers, auditors etc.) and assess the nuclear safety levels in the plant on behalf of their director, giving independent second opinions. I have noticed their commitment and their close relations with the plant directors. However, like my predecessor, I deplore the fact that they are not


24

more frequently called to assist with operational-related matters. I would like to emphasise the risk of them no longer being able to step back from situations and fully exercise their primary mission, centred on nuclear safety in operations. In 2014, the Independent Internal Nuclear Safety Oversight Network at corporate level decided to have a closer look at this situation.At the Nuclear Generation Division, the director for nuclear safety and his team in charge of Independent Internal Nuclear Safety Oversight, are also in high demand. For the benefit of the plant director, they provide an independent view and jointly organise the plant Independent Internal Nuclear Safety Oversight players whose activities must intersect regularly. I make a point of regularly meeting them and note their presence in many decision-making situations. Work on important issues, such as site security and attacks, nevertheless threatens their ability to take stock of situations, something which is vital to the role of any director.

Periodic assessment of the nuclear plants by the Nuclear Inspectorate and by WANO

The Nuclear Inspectorate (NI) is responsible for conducting periodic Overall Assessments of Excellence of nuclear safety at each plant in France. They do this every four years, together with follow-up visits in between these assessments. In addition, WANO also assesses the French plants, which are inspected every four years.The visits and inspections scheduled in 2014 were duly carried out, providing precious pointers for the continuous improvement of nuclear safety. I would also like to emphasise the need to properly allocate resources for this important work because the plants need personnel with the required skills. After two years of deterioration, as emphasised in 2013 by my predecessor, I’m pleased to see a perceptible improvement in 2014 as regards the proportion of recommendations acted upon after Overall Assessments of Excellence and WANO peer reviews (see Chapter 2). This reflects the strong demand at corporate level and the better expressed recommendations from the Nuclear Inspectorate as they are less numerous and more precise. I also note the important work carried out in 2014 by WANO, the Operations Engineering Unit and CEIDRE43 to better express the requirements in important areas (reactivity control and chemistry).

43 Construction and Operation Expert Appraisal and Inspection Centre

Periodic assessment of the Nuclear Engineering Division’s engineering force

The Directorate for Quality, Nuclear Safety and Radiation Protection provides independent overview of the Independent Internal Nuclear Safety Oversight for the director of the Nuclear Engineering Division. Every three years, EGCI44 evaluates the engineering centres. This is carefully organised by the managers of the Nuclear Engineering Division. I am happy to see that peers from the engineering centres are called in to staff the inspection teams. I am pleased to see cooperation with the Nuclear Inspectorate, which even involved providing assistance in the Overall Assessments of Excellence of a Nuclear Generation Division engineering unit in 2014. A rule set for assessing the modification processes and the maintenance of engineered structures has also been established by joint Nuclear Engineering Division and Nuclear Generation Division teams as part of the Overall Assessments of Excellence in the nuclear power plants: this enables a comprehensive assessment that is useful for directors of both the engineering centres and the nuclear power plants. I am watching with interest the possible extension of the missions of the Assessment and Support Units, in liaison with the Nuclear Inspectorate, to assess the operator’s control over the technical configurations of its installations, in a manner identical to the changes in progress at WANO.

INTERNAL NUCLEAR SAFETY CHECKING AT EDF ENERGY

I would like to highlight the role of the Technical and Safety Managers (TSM) in the British sites, who I meet during all my visits. These are generally are experienced members of staff who see themselves as the nuclear safety conscience of the directors, to whom they report directly and are carefully listened to. Their mission is a similar to that of the heads of the Nuclear Safety Advisory Units in France; they make use of the skills of a considerable pool of staff (some 60 individuals) and cover a wide spectrum of requirements (nuclear safety, radiation protection, fire, industrial safety and environmental issues). Their skills originate from their operating experience, which are insufficient and the daily challenge of the operational departments is not included in what is expected of them. Corporate-level organisation of the TSMs is handled by one of the plant directors (referred to as the TSM station director sponsor). However, I am not certain that it always satisfies the expectations of those 44 Assessment and Support Unit for the engineering centres


25

concerned. Although priority is to be given to having these independent views directly available to the plant directors, I would nevertheless encourage EDF Energy to make sure that promotion of the system at corporate level is adequate, for proper experience sharing of experience and to clearly determine the role to be played by INA45.This new body in charge of independent nuclear safety checking at EDF Energy basically has the same remit as the former Safety and Regulation Department. At local level, the Independent Nuclear Assurance (INA) has three resident inspectors, called Engineers for Nuclear Safety Review (ENSR). One of them, with operational experience, carries out a daily check (not at weekends) and handles the daily challenge with the operations shift supervisor. The Engineers for Nuclear Safety Review are not on-call and therefore their role is not equivalent to that of the Safety Engineers in France in accident situations. They report to the corporate-level echelon of the Independent Nuclear Assurance and regularly meet the station director and plant manager.

45 Independent Nuclear Assurance (formerly the Safety and Regulation Department)

My predecessor emphasised the difficulty in filling safety engineer posts, particularly with individuals with operational profiles. I note the effort of EDF Energy in 2014 to re-establish proper situations in all of the plants and I commend the secondment two Independent Nuclear Assurance teams of French engineers with nuclear safety oversight experience. I have noticed how much this type of background is appreciated.I would like to emphasise EDF Energy’s excellent use of the findings from the regular WANO peer reviews of its plants (see Chapter 2).

Questioning attitude in the control room

MY RECOMMENDATIONS

Maintaining and developing strong nuclear safety culture at all decision-making levels and in every work team needs to be the subject of special attention by the EDF Group managers. I encourage setting in place arrangements that can foster the development and the assessment of nuclear safety. I recommend broader cooperation between EDF SAand EDF Energy concerning this vital issue.Like my predecessor, I consider that, in France, our managers do not always have the time to organise, support and listen to their teams. Although the priorities announced in 2014, which were tightly focused and inspirational, met the expectations expressed over the years, the managers and their teams need to apply “simplification shock treatment” if effectiveness is to be enhanced and confidence won. We must continue to prioritise this and assign more responsibility to the nuclear power plants. This must help foster the indispensable simplification at the very lowest echelons.The departments in charge of internal nuclear safety checking need to contain staff recognised as having solid experience. In the EDF Energy plants, where the Independent Nuclear Assurance teams were reinforced with process skills in 2014, I recommend strengthening the operating skills of the teams placed under the Technical and Safety Managers. In France, I once again recommend significantly reinforcing the plant teams of the Independent Internal Nuclear Safety Oversight Network with skills derived from maintenance. I consider that this can provide decisive leverage with regard to the current weaknesses, while improving the quality of maintenance operations.


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TOWARDS An InTEgRATED APPROAcH TO RISK MAnAgEMEnT THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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4 / TOWARDS AN INTEGRATED APPROACH TO RISK MANAGEMENT

Risk management training in a practical training school

Radiation protection and industrial safety culture are counterparts of nuclear safety culture.

EDF Energy is a world leader in the field of industrial safety and radiation protection.

At EDF SA, there is room for improvement in terms of international industrial safety, and risk management needs to be more strongly promoted by the managers.

SLIGHT PROGRESS WITH THE INDUSTRIAL SAFETY RESULTS IN FRANCE

Unlike in 2013, I am pleased to report that no fatal accidents occurred in 2014. The results are still improving gradually; the accident rate46 was 3.3 in 2013 whereas it now stands at 3.2 for the French plants as a whole, including the Nuclear Generation Division and contractors. Disparity between the plants remains considerable, with accident rates that vary between 1.5 and 8.5. The objective set by the EDF Chairman in 2013 to reduce the accident rate by half over four years for EDF SAstaff appears to be within reach. However, the industrial safety results for EDF SAand its contractors are still far behind

46 Defined as the number of industrial accidents requiring sick leave per million hours worked

those corresponding to best international practices in nuclear operations.There is no correlation between the disparity in the plants’ nuclear safety results and the nature of the unit outages and hence the number of activities performed.The increased number of nuclear safety related events suggests that tag-out needs to be better conceived in terms of the consequences for industrial safety. I would like to draw attention to the detection and management of near-miss events in this context. A tag-out error can be fatal to workers. When managing industrial safety, it is vital to carefully plan the work, to be rigorous in conducting tag-out operations, to properly organise upstream and downstream tagging, and to properly check all key points. I call on all those involved - senior management, tagging supervisors, work supervisors and those in charge of EDF and contractor

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION TOWARDS An InTEgRATED APPROAcH TO RISK MAnAgEMEnT

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teams - to be highly vigilant, particularly during the busy unit outage periods.I have observed the involvement of the workers and tagging supervisors in the plants in taking into account experience feedback within the context of the COLIMO47 project with a view to reorganise tagging by 2017.

SCOPE FOR IMPROVING CONTROLLED AREA CLEANLINESS DURING UNIT OUTAGES

In France, although there may have been overall improvements in housekeeping, I have observed that there is scope for improvement of controlled area cleanliness during unit outages. This lack of rigour directly impacts the accident risk and the quality of work. Conversely, unlike the situation in the controlled areas, I observed seamless rigour in the control room maintenance work areas.I encourage operational leaders to be more demanding regarding the cleanliness in controlled areas throughout the unit outages. They must not hesitate to clearly define hold points for monitoring work areas and when resuming normal operations, relying more heavily on COMSAT48. At the end of unit outages, all the controlled areas, like the other parts of the installation, must be cleaner and tidier than they were at the beginning of the outage.

Cleanliness of the installations

FLAMANVILLE 3 EPR: OPERATING WITH OPTIMAL INDUSTRIAL SAFETY

The need for priority to be given to workplace safety has now been properly enshrined in the work practices by all the worksite players, and the 2014 goal of an accident rate below 8 was met (the actual accident rate was 7). We must continue to strive for highest possible level of

47 Project intended to modernise alignment and packing methods and practices

48 Unit Outage Nuclear Safety Committee

industrial safety on a worksite of this size at the present state of progress.I note the intention expressed by worksite management to closely involve the senior management and supervisors of contractors carrying out the work, with special regard for contractors and staff working there for the first time.I have seen how effective the arrangements are to ensure cleanliness and industrial safety, in particular with a clear separation maintained between work areas liable to generate dust and swarf contamination and the mechanical and electrical equipment work areas. Such cleanliness contributes equally to industrial safety and nuclear safety by preserving the packaging of electrical and mechanical equipment already erected pending start-up tests. These efforts have resulted in Flamanville 3 being one of the best kept new-build sites visited by the Inspector General for Nuclear Safety and Radiation Protection in recent years.It is vital to give due priority to industrial safety and cleanliness in light of the increasing number of overlapping jobs at the worksite where testing with fluids is being carried out in areas alongside equipment erection areas.I note so far that the operator is only very marginally involved in tagging and provisional operations in areas where working fluids are present after conducting the initial system tests. In view of the many handovers to come (see Chapter 11), I would like to draw attention to the demands of industrial safety during this phase, which will have to be dealt with carefully.

EDF ENERGY SETS THE INDUSTRIAL SAFETY STANDARD

The industrial safety results for 2014 again showed significant improvement with the overall accident rate halved for EDF Energy and its contractors compared with 2013 (0.7 in 2013 and 0.2 in 2014). These excellent results, consistently obtained, are due to managerial insistence in achieving the zero-accident goal, inspiring the commitment of every worker and fostering checking in the field. EDF Energy won an award49 in the UK in 2014 for being the company in the electrical power industry with the best industrial safety record. Its commitment to minimising risks has been recognised by WANO. Here within the EDF Group, we have high-performance practices at our disposal. Like my predecessor, I regret the lack of better interaction - apart from some sporadic contact - between EDF SAand EDF Energy.

49 Awarded by the Royal Society for the Prevention of Accidents (RoSPA)


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GOOD RADIATION PROTECTION RESULTS UPHELD IN FRANCE

There has been further progress with individual doses. At the end of 2014, the number of workers totalling a level of exposure above 10 milliSieverts (mSv) over 12 months (204) was less than in 2013 (385) and 2012 (263). Five workers received a dose greater than 14 mSv (eight in 2013) and none exceeded 15 mSv.The collective dose (0.7 man-Sieverts per unit) benefited from better control of unit outage durations in 2014, and met the target of 0.82 man-Sieverts per unit maximum. There has, however, been an upward trend over the past four years that may correlate with the increased amount of work carried out during the unit outages. In 2014, there were also considerable differences between the planned doses and actual doses during the partial inspections (ranging from -37% to +16%) and during outages for refuelling only50 (ranging from -41% to +44%).This raises the issue of allowing for radiation protection in the preparations for the General Refurbishment and I will seek to have the planned arrangements presented to me in 2015.

Significant radiation protection events: vigilance needed in red and orange areas

In 2014, there were 3 significant radiation protection events graded Level 1 on INES and none graded Level 2 (there was 1 in 2013).The number of events in red areas increased (2 in 2013, 4 in 2014). Although they may be few in number, they reflect multiple cases of failure to comply with the basic rules of radiation protection: failure to seal the red area, failure to recognise the associated risks and proper operating modes, and intentional crossing of lines of defence in some cases, which is totally unacceptable. It is to be borne in mind that, in a red area, the regulatory exposure limit can be reached in less than 12 minutes.The number of significant radiation protection events diminished in orange areas (33 in 2014, 38 in 2013) but still represents one third of such events. Detecting and eliminating hot spots, managing access issues and using experience feedback on significant radiation protection events, all need to be carefully examined by the plant management to avoid work in orange areas being considered as routine.The number of significant radiation protection events associated with radiography (50,000 shots per year) diminished (6 in 2014, 11 in 2013, 12 in 2012, 7 in

50 Known as ASR in France (Arrêt de tranche à Simple Rechargement)

2011), progress being associated with better organisation of the unit outages.The 22 cases of failure to wear a dosimeter in a controlled area may be considered to be very low, given the 80,000 controlled area crossings every week. However, the number of cases doubled compared with 2013 and represented 90% of the significant radiation protection events. This trend constitutes a weak signal which calls for more detailed analysis.Significant radiation protection events related to radiological cleanliness (15 in 2014) continued to increase (10 in 2012, 13 in 2013). I would like to raise the question as to whether this is a warning sign of disregard for the issue, particularly in view of the numerous observations mentioned above relating to the upkeep of work areas and controlled areas during outages. There were 89 cases in France where the C351 portals at the plant pedestrian exits were triggered (116 in 2013). It is to be noted that there were no cases of C3 portal triggering at the Creys-Malville or Brennilis decommissioning sites, where I found the work to be progressing perfectly safely and cleanly in 2014.

Before After

The Brennilis Nuclear Power Plant decommissioning worksite

EVEREST: a participative project fostering a virtuous circle

The EVEREST52 project is extremely positive in controlling contamination at source and is beginning to bear fruit (no significant radiation protection events associated with triggering a C3 portal) at the four plants where the project is deployed. This places them at the top international level in terms of nuclear cleanliness. The project creates a situation favouring the commitment of all. I note experience sharing between the plants at Golfech with the contractors in September. I can only encourage the

51 Monitoring contamination at site exits52 Project to enable entry into controlled areas in street clothes


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EVEREST project and have seen staff satisfaction as a result of it. Yet I regret the regulatory problems with its implementation, which need to be overcome to boost the serenity and health of the workers.

Reducing exposure to radiography

I would like to highlight the work carried out by the CEIDRE53 with the contractors to find alternative processes to radiography without compromising the associated nuclear safety implications. In France, the increased use of collimated sources, which have long been used in UK, has contributed to significantly reducing the risks of exposure in the vicinity of radiography by reducing the space affected. The use of selenium-75 instead of iridium will also reduce the risks, once the methods have been approved.

Source term reduction

Source term control is an important part of radiation protection (making a 10 to 20% contribution to the collective dose), as are the management of activities, the behaviour of players, the exposure time and the management of temporarily biological shielding. The reactor system clean-up programme (elimination of hot spots, purification, etc.) is now an integral part of the multi-year programme of each plant. Due allowance remains to be made for this programme in outage schedules. I have noticed the introduction of an annual unit clean-up programme for the worst units, which is to run until 2021, allowing for the multi-year General Refurbishment programme.

Fuel: the zero-fault target

I can see the significant impact of finding leaktight fuel assemblies in a unit outage, in terms of managing both the alpha radiation risk and the opening of the reactor coolant system. I would like to call to mind the importance of setting a zero-fault target for the fuel, which the US has achieved in 95% of their PWRs over the last two years.

Better work area supervision

The deployment of risk management supervision stations is finally beginning in the French plants and is

53 Construction and Operation Expert Appraisal and Inspection Centre

to continue until 2018. This technological innovation will foster effective practices that increase the protection and industrial safety for workers, with real-time ALARA54 monitoring of effective exposure. In 2014, experience feedback on work on the AGR steam generators illustrated the usefulness such systems, which contribute to workplace safety and the quality of activities.

A new radiation protection guide

EDF SAhas published a new radiation protection guide for workers. This guide is designed to instil practical, general information, assist in understanding reasons for the requirements and reiterate the basic principles on which the procedures are based. It promotes the ALARA approach and reiterates the goal of proactively limiting the number of individuals exposed to more than 10 mSv.

FURTHER PROGRESS WITH RADIATION PROTECTION IN THE UK

Limited as a result of the AGR design, collective doses remain very low compared with international levels. The large number of entries into the Heysham 1 reactor vessel in 2014 (see Chapter 10) has contributed to a rise in the collective dose. Ambitious goals have been set for entries into vessels and a training centre equipped with a large-scale mock-up has been built at Gateshead. A device for remote dose monitoring, rigorous and prudent procedures and the training of numerous workers have all helped to significantly reduce individual and collective exposure. These arrangements have made it easier to carry out high-quality expert appraisals, important for the nuclear safety of these reactors.

Heysham 1 Nuclear Power Plant, training on a mock-up

before entering the reactor vessel

54 As Low As Reasonably Achievable


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I note the ever more ambitious radiation protection goals set for the AGRs with the support of WANO, as well as the extremely positive input from sharing both experience and the best practices among the plants, promoted at corporate level by the fleet manager for radiation protection, the value of whose support is widely recognised in the plants.In 2014, the teams at Sizewell B PWR carried out a refuelling outage in 45 days, with six days being over schedule. The total dose amounted to 0.325 man-Sieverts, within 2% of the initial target. WANO emphasised the quality of the professional radiation protection practices during the unit outages in this plant.

FOR MORE INTEGRATED RISK MANAGEMENT

I have encountered varying levels of support among operational managers in France; support is often very weak for radiation protection and industrial safety in the fields of operations, control, maintenance and technical support. I would like to emphasise the need, in every profession, for formal and organised management of experience feedback to make sure that signals are heeded and necessary action to improve the situation is taken. This is because it is the professions that take ownership of industrial safety and radiation protection. Projects also need to be able to rely on professional experience feedback.I also encountered keen, responsive Risk Management Department staff but note considerable disparity in their integration in the plants and in the support they receive from senior management. I encourage them to be more assertive with the professions and projects and call upon the senior management of the plants to support them in their initiatives.At some plants, I note action towards an integrated approach to risk management and logistics focusing on the worker. This approach features the joint involvement of plants and contractors to optimise hands-on working time and the flows associated with maintenance work, while improving the working conditions. I encourage action on a corporate level to promote the dissemination of good practices and the consolidation of methods. I observe that there is much in common between risk management culture and nuclear safety culture which both require regular, questioning attitudes, openness, weak signal detection, foresight and continuous improvement. Respect for people, their physical and psychological integrity, as well as a healthy working environment constitute the preconditions for working well. This is substantiated by the experience

feedback both inside the EDF Group and outside it worldwide.

Checking for contamination in a controlled area

THE GENERATION CHANGE OPPORTUNITY

The high rate of staff turnover in EDF SAand its contractors represents an opportunity for strengthening culture in the work teams. The incoming generation may view physical risks differently or have a different attitude towards risks than the previous one. They may have a fresh and critical view of long-established professional practices that may be potentially dangerous. The older generations provide experience. I call upon the managers to make the most of this crossover situation to help develop a culture of prevention.

THE NEED FOR VIGILANCE IN THE PREVENTION OF SUBSTANCE ABUSE

Like my predecessor, I have been surprised to observe that spot checks to prevent alcohol abuse are not performed in a uniform manner in all the plants, despite the existing rules. As concerns the use of drugs and other substances, I note that there has been no special alerting by the occupational health professionals. Protective action needs to be developed and the terms and conditions of treatment, whenever required, need to be the subject of pre-established protocols applied at the earliest possible stage in consultation with all the stakeholders: managers, physicians, staff representatives, human resources advisers, and health and safety inspectors. In the UK, such practical arrangements are more widely deployed than in France.


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MY RECOMMENDATIONS

I encourage the plant managements in France to adopt an integrated approach to risk management by using the best international practices as a basis so as to put industrial safety on the same footing as radiation protection. I call for the development of a risk management culture equivalent to nuclear safety culture.The pooling of experience by the EDF plants in France and the UK can foster progress with workplace safety. I recommend intensifying such exchanges of information, at both plant and corporate levels.The plants need to enrich experience feedback on industrial safety and radiation protection after every unit outage or major maintenance operation, with the participation of all EDF and contractor players.I encourage the risk management staff to develop closer contacts with the professions and the projects, and ask the plant managements to support their initiatives.

RELYIng On PROFESSIOnAL UnIFIED OPERATIOnS THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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5 / RELYING ON PROFESSIONAL UNIFIED OPERATIONS

Training in the simulator

To perform their mission of controlling and monitoring the installations, the operation departments need to develop their professionalism, focus the professions to meet the demands of operations and make even greater contributions to the major projects.

The authority of the operations shift managers, with close support from management, focusing on operation, is one of the determining factors for further improving nuclear safety in operations.

CRUCIAL RESPONSIBILITIES IN NUCLEAR SAFETY AND QUALITY OF OPERATIONS

The key issues in nuclear safety always start and end with the control room. The results in terms of nuclear safety and output greatly depend on the actions of the operation professionals, guiding the daily activities, and whose authority is recognised by the other professions. This authority primarily reflects the competence demonstrated by the operation staff in conducting their activities: surveillance and control.In the US, the Institute of Nuclear Power Operations (INPO) has made extensive studies of the operations profession: knowledge, skills, behaviours and practices of operators for controlling the installations in a manner that is safe and effective. This work was taken over by WANO which issued a document entitled Operator Fundamentals

Weaknesses (Significant Operating Experience Report 2013-1) in 2013.I share this concern and note that EDF Energy began focusing on this issue at a very early stage, hence their reference to this Significant Operating Experience Report when drafting the new guidelines to support fundamental operations. I can only encourage the plant senior management staff to take note of it.

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION RELYIng On PROFESSIOnAL UnIFIED OPERATIOnS

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WAnO Significant Operating Experience Report 2013-1 Operator Fundamentals Weaknesses

The WANO Significant Operating Experience Reports facilitate the pooling of lessons derived from operating experience by WANO members. Significant Operating Experience Report 2013-1 is based on event report IER L1-11-3 published by INPO. This is called Operator Fundamentals Weaknesses and is based on an analysis of 16 international events considered important. It describes loss of focus on the fundamentals of operations that may lead to serious events. This report contains recommendations for immediate discussion and action.

The Fundamentals of Operator Professions Worldwide

• Careful monitoring of the parameters and the condition of the installation.

• Conscientiously following any changes in the installation.

• Adopting a prudent approach in the operation of nuclear units.

• Carrying out teamwork effectively.• Having a solid understanding of the design of

the nuclear units and the interaction between the systems.

The objectives

A total of twelve recommendations were divided into five main categories relating to the fields of nuclear safety, training, management, the corrective action programme and the rule set.

Operations activities not yet sufficiently mastered

In France, control room surveillance and the organisation of fieldwork is improving but instances of sub-standard functioning, of which 90% are due to operator control, increased by 20% in 2014, revealing important weaknesses:• Violations of the technical specifications for operation • Excursions outside the authorised operating envelope • Discrepancies in tagging work• Failure to comply with procedures.I have noticed the same recurrent weaknesses at EDF Energy, in particular violations of the technical specifications for operation and the configuration requirements.Most of the plants in France are also finding it difficult to implement human error reduction practices, both in the control room and in the field. This is despite the considerable investment allocated to training in the plants, with both practical training schools and simulators. All are now aware of these practices. But the penny has still not dropped and we are still far from the conditions I have observed in the British control rooms. I would like to draw attention to this situation, which is sometimes seen too optimistically, and I call on the managers to use their initiative to bring this change about.I would also like to emphasise the expected role of operators in monitoring the conformity of the physical condition of the installation with regard to major hazards (external events such as earthquakes, fire, flooding,

etc.) and the requirements related to upholding the good condition of the installation (fire loads, radiation protection, housekeeping, etc.). I encourage the operator teams to be more proactive regarding these issues.

With a stronger role in projects, operators sometimes seeing their authority challenged

In France, operator skills assigned to unit-in-service55 platforms are being reinforced and brought closer to those maintained by the Work Execution Centres in the EDF Energy plants. Even these centres, I have observed the operator’s role in organising the teams in charge of diagnosis and first-line maintenance whenever a discrepancy is detected. I have attended operational meetings in the morning and appreciate the role that the operations shift managers play in them. However, I am not persuaded that the scheduling of the units in operation gets the full recognition it deserves in the control room.Action to improve the organisation of operations work, inspired by the best international practices (AP92856) is a step in the right direction, providing the operations shift manager with greater support: unit-in-service platforms, dedicated teams for unit outages.Among the unit-in-service teams, there are many operation-related workers, who are strongly attracted to this type of inspiring job. The operations shift managers assigned to unit outages find their authority increased by

55 Known as TEM in France (Tranche En Marche)56 INPO Advanced Process 928, which details the standards and

the organisation for units in services and during outages


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becoming the right arm of the outage supervisor. They can provide support that is generally much appreciated by their fellow operations shift managers hard at work.Yet, I would like to draw attention to the risk of imbalance between these two platforms which have gained much authority, sometimes making it difficult for operations shift manager to properly position themselves in the new context. In particular, I was struck by what the operations shift managers when they referred to the “steam roller effect” of an outage organisation, carried along by a motivation that is now very strong. I can see tension between the different objectives, with the operations shift managers all too often feeling that they are left to bear the burden of proof. I consider that the shift operations managers should have the last word, being able to impose their authority and ensure that the requirements of nuclear safety and industrial safety are met. Their control over changes in reactor modes and their primary role in the decision-making process in the event of complex technical contingencies needs to be the subject of due support by the plant directors.I emphasise the importance of operator skills playing a greater role in plant projects affecting multi-year scheduling and equipment reliability. They can contribute their knowledge of operations and there view of functioning, and can in return benefit from a long-term perspective and better understanding of the equipment. I note the initial changes in this direction, but these initiatives are still, all too often, limited by the ability of the operator departments to assign sufficient resources to them.

TRAINING: AN ACTIVITY IN ITS OWN RIGHT

Theoretical and practical training in normal and accident situations are what characterise operator professions. The initial training and accreditation programme is long and demanding, e.g. a year of training for future operators, including three months on a simulator. Refresher training has been stepped up in France and the entire system now features minimum requirements, which are assessed by UFPI57. These arrangements are also the subject of periodical assessment by the Nuclear Inspectorate during the Overall Assessments of Excellence.Many challenges still remain:• rapid wholescale renewal of skills in France, with the ratio

between experienced staff and newcomers in the teams of less than 2 to 1 (the ratio was 7 to 1 in 2007),

• Installations that are increasingly reliable which means that fewer lessons are learned direct from experience than in the past,

57 Operations Engineering Training Department

• The amount of time the operators spend in simulator training is still insufficient (8 days on average in EDF Energy, 11 days on Average in EDF SA), with this time being considerably complicated by unsuitable organisation.

Nevertheless, I noticed some real opportunities:• A new generation with a fresh eye,• Training arrangements that are constantly being

reinforced (new simulators in France and the UK, mock-ups, practical training schools, etc.), run by keen instructors,

• The Skills Programme in France and SAT58 at EDF Energy, which assigns more responsibility to managers concerning this issue.

The basic training of the operator staff is improving, with a substantial syllabus for the reactor operating personnel. It should also be noted that specialist knowledge academies for technicians and field staff are becoming universal. These academies, co-organised by highly-experienced technicians, fulfil the requirements and ensure that knowledge is properly passed on to the next generation. I note that the increasing proportion of training devoted to training for normal operating conditions, which was insufficient up to now. Simulator training shortly before unit outage is now nearly universal. I am pleased to see these changes, which were called for by my predecessor.I had the opportunity of speaking to two instructors who were passionate about their profession; they mentioned difficulties in passing on knowledge to enable a clear conceptualisation of the physical phenomena and a fundamental understanding of the behaviour of the machine. I found this extremely interesting and would encourage managers to regularly keep in touch with them to understand such difficulties.More generally, I consider that managers are not always present and involved in simulator usage in France, particularly for operator departments and plant management staff. Such close links, forged after interactions in training or during simulator observations, are, however, very prevalent in the EDF Energy plants. Strengthening the links with operations is a source of progress and helps to improve the effectiveness of training.

Operating technicians monitoring a standby diesel generator

58 Systematic Approach to Training


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Operator staff need to have a solid understanding of the design of the installation they are operating to properly comprehend its overall functioning. Excellent arrangements had been made to provide support for the major modifications scheduled for the third 10-yearly inspections of the 1300 MWe plants, yet I consider that insufficient care is being taken with respect to existing modifications.

THE IMPORTANCE OF TEAM WORK

The collective dimension of operator activities, provided by rolling shifts, greatly helps to maintain proper control over operations, and thus over nuclear safety.This exists on two levels:• In the shift operator teams, which bring together

control room operators and fieldworkers under the operations shift manager and his advisers,

• In the management team of each operator department, bringing together the operations shift managers under their head of their department.

In the operator teams, which can be termed “learning communities”, individual and collective skills are built up, grounded in team spirit, solidarity in the face of contingencies and correction of errors. I have observed the ability, and on occasion the difficulties, of operations shift managers to instil strong nuclear safety culture in this context. Many working methods reflect collective practices and require suitable approaches to develop: shift turnover, continuous service, briefings, pre-job briefings, secure communication, cross-checking, shift experience feedback sessions, etc.I would also like to stress the importance of the operations shift manager community, built up during management meetings and led by the head of the department. I recognise the importance of their team work and their efforts to develop a more coherent organisation of operations, making use of input from other departments. I note the great expectations of the department heads and the difficulties expressed by the operations shift managers for making progress in this context. In France, I regret the small number of on-call days carried out by the teams outside their shift work. These represent excellent occasions for developing work communities and for the manager to build up close relations with his team. The all too real difficulties with the work organisation, which make such practices all too rare, need to be reassessed and I call on the plant directors to address this difficult question.

COMMITMENT OF OPERATIONS MANAGERS

Indispensable close links with the plant management

The plant director assigns operational responsibility to the operations shift managers, who are in charge of nuclear safety in the front line. The manager needs to develop a rigorous, comprehensive approach to the world of operations, to “think like an operator”. I can see how powerful and effective relations of confidence and willingness to listen can be, as built up by the plant managers with their operations shift managers.In an increasing number of plants, the management organise regular meetings, frequently on a weekly basis, with the shift managers, who tell me that this helps to make sure their concerns are heard. I have observed that they are able to raise nuclear safety priorities during the daily morning meetings, which take place in all the plants, thus setting the tone for operations activities for the day.

Being present in all aspects of operation

Operating activities are carried out in two very different environments in terms of position and means of access to information and controls: on one hand the control room and on the other hand the rest of the installation. It seems that the so-called field activities, performed outside the control room throughout the plant under possibly difficult conditions, merit greater attention from the plant and operation managers. Closer observation of the field activities, which are not always well understood, and the daily difficulties faced by those working there can help to sort out many of the unresolved problems. I have observed that the presence of control room managers is becoming more frequent and regular, making it easier for the operators to get themselves heard.

An operation technician in a decentralised control room


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In France, operations shift supervisors are gradually gaining more authority

The operations shift supervisors ensure operations are proceeding smoothly, supervising all the activities relating to the nuclear unit, determining the best trade-offs on a daily basis and allowing for maintenance service constraints. They manage an operator team and have the task of setting the standard for rigour in operations for each staff member and creating highly-professional work communities cooperating with the others around them.I hail their everyday commitment to nuclear safety. Younger than most of their foreign counterparts, they rise to the challenge of their difficult job and show promising enthusiasm. I am left wondering about their workload, seeing so much of their time taken up with activities that could be done by others. The operations shift managers that I have observed in nuclear power plants in other countries and belonging to other companies, particularly in the US and the UK, appear calmer and more available to conduct their everyday tasks. They have broad and effective support and are able to step back from the situation to the benefit of this line of defence preserving nuclear safety. I can also see the scale of difficulties they face in bringing about changes in professional practices. I encourage the plant directors to pay greater attention to the managerial dimension of the operations shift manager profession where authority needs to be maintained and initiatives encouraged.

The head of the operations department is a manager unlike the others

The head of the operation department leads the operations shift management communities, and the management meetings are important moments when cohesion and coherence can be furthered. The mission is a very complex one, calling for talent and special qualities. This person must durably foster the proper levels of skills in the shift and non-shift staff.The head of the operation department has the decisive task of maintaining a proper level of skills and training. Here leadership is too disparate and relations with the Operations Engineering Training Department are too sporadic, if any at all. I can see the expectations of the instructors who want to develop stronger links.Although I am pleased to see closer relations develop between the plant directors and the operations shift managers, I can see how this places the head of the operation department in an awkward situation. I encourage the directors and the operation department

heads to build stronger ties which are essential to maintain good overall balance.

THE OVERRIDING NEED FOR OPERATING SKILLS

The need for operating skills is very great in projects (unit in service, unit outage59 and multi-year). These skills, which are very useful in building a rich and varied career, are also in strong demand for selling positions as safety engineers, simulator instructors, and plant- and corporate-level engineering personnel, in both EDF SAand EDF Energy. They remain in short supply, directly weakening the Independent Internal Nuclear Safety Oversight Network, the simulator teams and the engineering force.Yet the GPEC60 Initiative is continuing in the plants in France and the UK, with horizons extending up to 10 years in some cases. The aspiration to diversify careers and profiles is also clearly expressed, and the amount of basic training taking place is still considerable. Nevertheless, despite this unprecedented effort, I would like to draw attention to the weakness of these initiatives. Filling the different positions in accordance with the scheduling – as regards technicians, operators and team leaders – has substantially improved, but will require more time and sustained efforts. I had been shown certain cases of forward planning of jobs and skills relating to plant operations which will prevent the plant requirements from being met before 2017.In France, project requirements are more easily satisfied than obtaining adequate numbers of operations shift staff skilled in the post-Fukushima requirements. In the UK, shift personnel are better protected and have the advantage of a more flexible work organisation, but the needs of projects and of other professions requiring process skills are not properly met.I note the similarity in the situations in the EDF Group concerning this issue and, like my predecessor, emphasise the need for stronger corporate action to satisfy these requirements for skills that are fundamental to the profession and that take long to acquire. They are forged in operations and are indispensable in gaining full control over the process.

STILL SCOPE FOR IMPROVING ORGANISATION

To properly address these missions and requirements, the operation departments, which focus on shift work, must have an organisation enabling them to manage the different operational work timetables in a flexible

59 Known as AT in France (Arrêt de Tranche)60 Advanced Planning of Jobs and Skills


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and effective manner. I would like to draw attention to the fact that there is still scope for improving this organisation, which has been flawed in certain cases. At one EDF Energy plant, I observed a work organisation system reflecting the training needs (one week of training per shift cycle, providing 20 days of simulator training per year per operator), the needs of unit outages (2×12 hours shifts) and the need for periods of rest and holidays. I regret that this type of arrangement is not more prevalent in the French and British plants.It is difficult to make headway with these work organisation issues; I call on all those involved to give thought to pragmatic solutions to assist the operating professions. improving performance, primarily by high-level training.

CORPORATE-LEVEL ORGANISATION OF THE OPERATIONS PROFESSION

In France, this has been reinforced and, like my predecessor, I would like to emphasise the role of the Associate Directors for Operations and the Skills Advisory Centre of the Nuclear Generation Division. The Common Core for Operations, defined some 10 years ago, states the responsibilities and contributions of the operations professionals, its professional requirements

and its professional career paths. It lays down the principles of organisation and specifies new key jobs which will enhance nuclear safety in operation. I would like to draw attention to the small number of plants that conformed to the Common Core for Operations in 2014, and the fact that some have not even started on the changes expected. I call on the corporate and plant management to take measures to actively ensure that these changes take place, which can be supported by the recent guidelines issued for the Common Core for Operations.At EDF Energy, I observed the Operations Fleet Manager promoting these initiatives and my predecessor has already noted this contribution.

Control room operators in an AGR nuclear power plant

The guidelines for the Common Core for Operations issued by the Nuclear Generation Division

The Nuclear Generation Division established an operation rule set in the 2000s, a common core specifying the role of operations in power generation and of the roles of all the professions and jobs involved.After an operating experience review bringing together all the nuclear power plants (particularly the heads of the operations departments) and including exchanges with other operators outside France, the Common Core for Operations was updated and corresponding guidelines

were issued for the operation department managers and the many new arrivals in the corresponding professions. The guidelines cover five areas:

• The guidelines cover five areas: • The fundamentals of the profession• The management of operations• The organisation of shift-work operations• The organisation of non-shift-work operations• Operational leadership in projects


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MY RECOMMENDATIONS

Mastering the fundamentals of the profession is what underlies the authority of operators in power generating. WANO has given its recommendations to worldwide nuclear operators on these issues. In France, I have observed new impetus in profession-related initiatives to better manage some of these fundamentals. This action is all the more worthy of support because the operator profession is going through a period of very high turnover of skilled staff. Like my predecessor, I observed difficulties in France and in the UK to maintain skill levels in operating jobs, in a profession where training time is particularly lengthy. The ambitious goals to reinforce some of the jobs (e.g. lead operators) and the expectations of other departments regarding the availability of skills from operation making the situation strained. I recommend maintaining the effort to find a long-term solution to this issue which is of the highest importance for nuclear safety in operation and achieving the performance goals.I also call for more professional career crossover to not only open up the operation teams and their knowledge to other professions, but also to consolidate process skills in the other professions. I encourage plant and corporate management staff to accelerate these trends that have not fully borne fruit.In the French plants, in a context where there is strong focus on nuclear safety and outage priorities, the decision-making authority of the operations shift managers is challenged and sometimes needs to be backed up. I call on the plant directors to pay particular attention to the exercise of this authority, which is vital in ensuring priority is given to nuclear safety.Work organisation in the operation departments of EDF Energy and EDF SAis not always well suited to the training goals and the contributions expected of units in service and outage projects. It is hindering performance improvements and even, at times, weakening the work communities. I call on all the stakeholders in the plants to tackle these issues.


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THE QUEST FOR RObUST MAInTEnAncE THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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6 / THE QUEST FOR ROBUST MAINTENANCE

Requalification tests

In France, more robust management of the volume of maintenance during unit outages has met nuclear safety requirements and is now starting to pay off. Reinforcement of the multi-year projects is the key to making this initiative a permanent process.

Intensification of the efforts of all involved - EDF and contractors - is necessary to eliminate sub-standard maintenance which still continues to arise all too frequently.

In the UK, equipment reliability necessitates a more proactive commitment to reach the expected levels of reliability.

BETTER MANAGING THE VOLUME OF MAINTENANCE WORK IN FRANCE IN 2014

In 2013, my predecessor observed how committed the management of the Nuclear Generation Division was to adjusting the volume of maintenance to industrial capacity by properly prioritising nuclear safety and with a view to restoring calm working conditions during the unit outages. This creditworthy attempt to simplify the situation is being made in context where maintenance professions are already having to adjust to numerous changes61. It is particularly pertinent as it reflects how priorities are being refocused on the means of production itself. It is also progressive and realistic, as is shown by the objective of reducing the volume of maintenance work by 10% in 2014.61 See the 2013 IGSNR report

Processes and the skills

I hail the performance achieved in 2014 in managing unit outages, with an average extension of 9 days. The work volume management appears to be excellent in terms of the process: this makes the nuclear power plants the driving force between the initiative to review the situation and the guarantors of the ability to get things done. It joins up the Nuclear Generation Division at corporate level, the Nuclear Engineering Division at engineering centre level, the directorates and committees, and ICT62. At the beginning of 2014, there was much question, if not incomprehension, in the departments about significance of this policy change. The world of maintenance is known for its ups and downs, with a significant reduction in the volume of

62 Committee for Joint Action (between the Nuclear Engineering Division and the Nuclear Generation Division)

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION THE QUEST FOR RObUST MAInTEnAncE

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maintenance work at the turn of the century which, possibly for the best of reasons, was taken too far to the detriment of the reliability of some equipment, such as transformers. This led to a pendulum reaction, with the volume of maintenance increased by around 60% between 2006 and 2012 and a proportional increase in the number of spare parts used.. Analysis by UNIE63 showed that the reasons were corporate-level action (PBMP64 and DP/DT65) as well as, in many cases, plant-level action (contingencies, local programmes, and reduction in the amount of outstanding work requests) mainly in the fields of valves, boilermaking and rotary machines, as well as the late scheduling of maintenance work after outage programmes were frozen.Furthermore, the transfer of more responsibility to the plants in the context of the critical analysis of corporate and plant programmes immediately came up against the problem that corporate programmes were sacrosanct and the feeling that the AP 913 initiative might be called into question. I have seen the effort that managers are making to adhere to this and to create the conditions for a change in attitudes by making good use of the opportunity to improve performance without compromising nuclear safety. I have also seen more comprehension and willingness to join this initiative everywhere. I like to emphasise its virtuous nature (questioning why and the relative priorities) and the need for it (seeing the situation in a multi-year context integrating corporate experience feedback whenever a planned activity has not been performed). This last consideration constitutes an avenue of progress for certain plants. One of the deciding factors in success with the initiative in 2014 is the rapid mobilisation of the engineering and reliability departments, in particular their systems and equipment teams which already partially reflect a multi-year vision. The increased skills of this engineering force to implement the AP 913 method has made it possible to identify scope for delay and cancellation in seeking to make allowance for the nuclear safety factor.In all the plants visited, the director confirmed the delay and cancellation proposals issued at both corporate and plant level by the Independent Internal Nuclear Safety Oversight Network. Yet this was done without always making the in-depth analysis required due to the lack of maintenance skills, as already reported in 2013. About 25% of the nuclear power plant proposals were

63 This analysis confirmed change in the amount of routine maintenance work carried out in 2013 by the EDF SA Nuclear Plant Industrial Program Evaluation Mission, quoted in the 2013 IGSNR report

64 Basic Preventive Maintenance Programmes65 Special Requests and Temporary Arrangements

not confirmed66 by the Operations Engineering Unit for reasons of nuclear safety. Although I note the effectiveness of the corporate-level oversight loop, I question the dependability of the analyses and checks made by some of the plants. Whatever the case, I call for greater attention to nuclear safety in the professions and, once again, increased maintenance skills in the Independent Internal Nuclear Safety Oversight Networks. This situation shows the value of the Operations Engineering Unit, which brings together corporate experience feedback and plant experience feedback. It also plays a role in supporting the sites and checking their proposals against the needs of nuclear safety, as well as waivers relating to corporate requirements.

Field work in a controlled area

Make the process permanent by improving it

This process is due to continue and, in 2015, I will be watching for experience feedback from 2014 on the MVM67 Project relating to the technical management of change by placing it in a multi-year context by:• Reinforcing nuclear safety screening in the plants• Strengthening the link with the AP 913 programme

to check for any regression in nuclear safety relative to the Basic Preventive Maintenance Programmes for the plants using the Nuclear Technical Information System

• Using positives experience feedback (e.g. checks showing no deterioration) that must be better traced and developed with the necessary view of the plants as a whole to take precursors into account

• Establishing the benefits of preventive maintenance that is more inclusive and condition-based (e.g. considering servomotors and valves together), a demanding approach that requiring control over the parameters and the functional criteria of equipment

66 e.g. those relating to protection system sensors, tell-tale equipment maintenance and elastomers

67 Maintenance Volume Management


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• Developing additional tell-tale equipment• Making sure that non-destructive test programmes are

consistent between the plants, as tests for the same purpose may be substantially different.

It would be advantageous for engineers from the engineering and reliability departments to have closer links with the planners, providing their technical know-how so that the planners can better comprehend the reasons for the changes and the nuclear safety issues.

IMPROVEMENTS IN THE QUALITY OF MAINTENANCE STILL AWAITED IN FRANCE

In 2013, my predecessor called for a return to the basics of maintenance to improve the quality of operations, in the run-up to the General Refurbishment. The 2014 results lead me to the same assessment: the quality of maintenance is still not up to the required level. Some actions can take time to bear fruit and I call for a kick-start by all involved, EDF and contractors, at all levels, from senior manager to field worker. This means strong leadership by the plant directors, understanding the situation correctly, rigour in implementing the action plans, and new initiatives.

Bouncing back in 2015 after a disappointing 2014

20

60

100

140

180

2010 2011 2012 2013 2014

102

152

168

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189

French fleet: significant nuclear safety events caused by sub-standard maintenance

Trend in nuclear safety significant events associated with sub-

standard maintenance between 2010 and 2014 in France

In 2014, the number of nuclear safety significant events graded 0 and 1 on the International Nuclear Event Scale corresponding to sub-standard maintenance increased by 85% over four years reaching 3.3 per unit, falling well short of the goal of 2. There were 25 nuclear safety significant events graded 1 on the International Nuclear Event Scale (18 per unit in 2013) and their impact on the length of unit

outages was slight. Cases of sub-standard maintenance represented slightly less than 50% of all NQMEs68.Some cases of sub-standard maintenance had a direct impact on operations: they were the cause of 5 automatic reactor trips and 2 safety injections, irrespective of the sub-standard quality liable to be found later. I would like to stress how important the quality of functional and intrinsic requalification is after maintenance work, for which the maintenance function must bear full responsibility. I encourage the maintenance department managers to rise to the challenge, to back up this change and to maintain close dialogue with operation.I note that the number of nuclear safety significant events is almost equally divided between activities with the unit in service and activities during unit outages. All the professions are impacted — control systems, valves, boilermaking, electrical — and both EDF and its contractors are concerned. Once again this year, the system is important for nuclear safety were affected69. About 60% of the nuclear safety significant events reflected shortcomings in the planning and execution of activities, especially insufficient risk analysis, defective technical checking and requalification. Somewhat more than 20% of the nuclear safety significant events showed a need to improve basic skills: deficient fieldwork not meeting state-of-the-art practices, and lack of proper theoretical knowledge. I call the managers to give a new impulse to training, with the corresponding support being set in place accordingly in certain plants. I also note discrepancies in relation to the procedures and guidelines, as well as failure to implement practices to increase human reliability (one minute hold, self-checking, etc.).Although my predecessor commended the initiatives to better manage the MQME70 approach which began in 2013, I have observed insufficient backing from management on the issues at hand in some plants and an absence of project mode management. I am pleased to see that the plants are being attentive with respect to the two priorities - nuclear safety and unit outages - set for 2014 and 2015 by the Nuclear Generation Division.

Other levers for improving quality

Quality needs strong management commitment, especially in the field, although there are also other levers available. These notably include training, simplification, no wasting time and maximising hands-on time. I note the initiatives to facilitate fieldwork by advancing with the

68 Sub-standard maintenance and operations69 Auxiliary feedwater system, chemical & volume control

system, neutron flux instrumentation system, reactor cooling system, standby turbo-alternator system, etc.

70 Project to improve the quality of maintenance and operations


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single-stop approach (for fire permits, tagging permits, etc.).As part of the project for better quality management in maintenance and operations, I note the commitment to simplify job documentation to help the field workers in 2014. The goal is to review job documentation by focusing on the different fieldwork documents (fieldworker instructions) based on contributions from volunteer plants, UTO71, ULM72, the Operations Engineering Unit, the Skills Advisory Centre, and the documentation series centres. The other documents can be consulted at the jobsite or are available as back-up, including the fieldwork risk analysis, which has been re-focused on the technical moves with due allowance for experience feedback. Some 10 tests were devised together with contractors in 2014, which is encouraging. An industrialisation analysis was conducted based on experience feedback of case drafting guidelines focusing on field workers and developments in standardised documentation. I support of this ambitious yet promising initiative, particularly for new job documentation.

The rule set for Operations Project and Maintenance Professions

This rule set is intended to ensure consistency in the profession, clearly stating the fundamentals that lend order to organisation and professional networks. It clarifies contributions and clearly indicates the potential in terms of jobs and careers. It scope extends to field work professional networks, management of execution, spare parts, nuclear logistics and risk management, reliability/methods/engineering, organising projects, scheduling and management. Its implementation consists in carrying out a self-diagnosis in each plant to determine the difference between the plant’s condition and the rule set, then drawing up an action plan in consultation with the local stakeholders.Intended as doctrine, it is not prescriptive insofar as its principles are intended to lend structure at both plant and corporate levels. Its coherence guarantees the effective introduction of standardised resources, such as the Nuclear Technical Information System, the standardisation of operating procedures, as well as training in connection with the Skills Programme. It is particularly ambitious with regard to the General Refurbishment. It will be backed up by management visits from directors assigned to operations from the Nuclear Generation Division and the Skills Advisory Centre. It is a resource enabling managers to organise things locally and make progress in a manner consistent with the plants as a whole.

71 Central Technical Support Department72 Maintenance & Logistics Unit

Promoting contractor initiatives too

Using tablets in a work area

During my meetings with contractors, I have observed that some are proactive and are developing ways to improve the quality of work for the benefit of nuclear safety. They express hopes that EDF SAwill provide support at corporate level for innovations tested in a few plants, some of which have been successfully introduced in other industries, for instance graphic tablets enabling the fieldworker to access job site work documentation and connect to offsite technical support. This type of arrangement is based on the same logic as the INTEP Project inside EDF, which was terminated at the end of the 2000s, of which follow up action failed to match expectations.

NEW FRAMES OF REFERENCE FOR THE OPERATIONS PROJECT AND MAINTENANCE PROFESSIONS IN FRANCE

The MMPE73 rule set: an opportunity to grasp

The close link between the standard of maintenance and nuclear safety was clearly shown in a corresponding report submitted to the EDF Group’s Nuclear Safety Council in 1990. This has lent structure to the improvements in this domain for a number of years and is still totally relevant. The 2002 Maintenance Project, the NCME74 that was appended to it in 2009 and the NCMP75 have since further enshrined the profession rule sets. Progress was limited in certain professions and the situations differed between the plants. The significant changes76

73 Operations Project and Maintenance Professions74 Operations Maintenance Profession Common Core75 Project Professions Common Core76 Human resources agreement in 2009, continuous monitoring

of installations during unit outages, DTX 96, AP 913, Nuclear Technical Information System, renewal of skills etc.


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that have since occurred complicated the situation and the managerial commitment at corporate and plants levels was insufficient. Faced with major changes in the operations project and maintenance professions, and with the forthcoming General Refurbishment, I would like to stress that we need to seize our chance to apply the new Operations Project and Maintenance Professions rule set, making use of the key features of experience feedback from the plants before gradually phasing it in. I see this as a lever for dealing with certain weaknesses, clarifying missions, establishing career paths and making progress with nuclear safety. In 2015, I will make a point of assessing the uptake of this rule set in the plants.

Maintenance professions and operations projects in the plants

The in-service and outage projects, which are mostly scheduled and staffed, are progressing (planning, modules, forward planning, freezing of operations, etc.). Experience feedback on how unit outages are organised (debriefing, resolution of contingencies, contractors etc.) needs to be enriched. The way the multi-year projects are evolving is significant yet the expected levels have not been reached, and situation varies between the plants. Some plant projects interact strongly with the Nuclear Generation Division’s corporate echelon and with the engineering centres of the Nuclear Engineering Division. The latter is seeking a greater role in the multi-year scheduling and the different stages of the unit outages. Other projects have been launched but with resources that are still insufficient. I have taken good note of the goal set for all nuclear power plants to be up to standard in 2016 with a multi-year project. This project will combine plant maintenance and corporate maintenance or modifications, whether in-service and during outages, for an initial period of five years then a longer period of 10 years.Among the various professions which, as I see it, require improvement, I note the following posts:• Multi-year project manager: this necessitates the

skills combining broad knowledge of the professions and a network to address the multi-year project representatives of the professions and the corporate engineering centres

• Schedulers, including the master scheduler: achieving higher quality and greater serenity means reinforcing your role as client, especially by ensuring schedule reliability and identifying any sensitive activities

• Methods planner: gaining a clearer view ahead as concerns the actions that need to be taken into consideration. Furthermore, work needs to be done

to refocus the respective activities of the planners and supervisors

• Job and surveillance supervisor for activities entrusted to contractors. This profession needs to be made more attractive as some individuals seek to switch to other professions shortly after they have been trained. Job and surveillance supervisors are often seconded to unit outages too late, to the detriment of preparation of the surveillance plans. I can also see the need for greater job and surveillance supervisor promotion by the heads of the maintenance departments, rallying the joint teams and departments of the nuclear power plants around the theme of surveillance

• Spare parts engineer, a new role that I am pleased to see is becoming important in the maintenance function.

I often observe uncertainty about the best career options given the relative attraction of certain professions. This particularly applies to planners, despite the recent introduction of master planners and surveillance supervisors. I also note that much interest in projects is being expressed. The rule set for Operations Project and Maintenance Professions provides a basis for developing careers within one profession or crossing between professions.I note that maintenance benefits from a Skills Programme in the Nuclear Generation Division and that the main training arrangements are consistent with the requirements of the rule set, without excluding the need for further professionalization.

The rise of the corporate-level maintenance teams

In a EDF Fleet Maintenance Agency, I saw the rise of the Maintenance and Logistics Unit in the field of maintenance work (acting as contractor or providing surveillance), with particular reference to sensitive valves. I note the anticipation of a more explicit definition of the surveillance requirements by the nuclear power plants, acting as clients. And like contractors, I expect clearer guidelines on the difficulties of applying corporate-level procedures, which are often considered too complex and differ too greatly between the plants. The move towards standardising the procedures is still on-going and needs to continue receiving support. I note that common ground is being found with the Central Technical Support Department about what surveillance should involve.I support this process which demands excellence and the creation of a standard for contractors. I encourage plant managements to exchange information with the EDF Fleet Maintenance Agencies whose situations are the same as those of the contractors. In Chapter 7, I describe


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the creation of EMAT77 in the Central Technical Support Department (UTO).

BETTER TECHNICAL AND INDUSTRIAL MANAGEMENT NEEDED IN FRANCE

Maintaining the qualification of equipment for accident conditions over time must be improved

Qualifying equipment in operational plants for accident environment conditions

Qualification for accident environment conditions forms part of the safety case to be made under the Ministerial Order of 7 February 2012 on Licenced Nuclear Facilities (Chapter 5 - Important construction issues and activities).Initial qualification is established by tests and analyses proving the ability of the equipment to fulfil its functions under the ambient conditions and the loads to which they are expected to be subjected.In the specific case of electrical equipment important for nuclear safety, there are three qualification categories.

• Category K1: equipment installed inside the reactor containment required to operate in accident situations (loss of coolant)

• Category K2: equipment installed inside the reactor containment required to operate under normal conditions

• Category K3: equipment installed outside the reactor containment

The ambient conditions are those corresponding to normal, incident and accident situations, as well as earthquake loads, depending on the equipment and its category.Proof of qualification throughout service life must be provided, notably by complying with the rules for qualifying equipment and by using qualified spare parts.

Qualifying equipment78 for accident conditions and durably maintaining such qualification, including after 40 years, is vital for the safety case. This is particularly true when managing qualification in manufacturing which is based on reference documentation for existing equipment

77 Unit Outage Joint Team78 Electrical power and control equipment, active mechanical

equipment, as regards nuclear safety of the design basis and complementarity

and spare parts, as well as when checking the in-service compliance of plants with the RPMQ79 provisions for plant equipment. This confers responsibility on the corporate engineering centres of the Nuclear Engineering Division (the Units Responsible for Qualification), as well as on the Nuclear Generation Division, the standardised-series managers, the manufacturers and the plants. Initial proof of qualification applies over many decades. I note the progress made for the Flamanville 3 EPR which is due to start up with qualified equipment. This qualification was obtained by the suppliers with EDF acting as client, inverse to the process followed in nuclear power plants that are in service.Certain aspects of the situation need to be improved. There many cases where the reference documentation needs to be formally established. Work on these cases is progressing and the corresponding workload is heavy. We need to pay more attention to the circulation of information between manufacturers and the EDF staff checking major changes in fabrication (materials, process and even design, etc.), as well as to the impact of changes on qualification. I call for more responsibility to be placed on manufacturers as regards the traceability of changes which may be seen as unimportant.As regards operations, I would like to emphasise the importance of keeping up to date i) the Qualified Equipment Rules, ii) the corporate-level procedures relating to feedback-related maintenance and iii) the equipment modifications. Although the meaning of “durability of qualification in service” is generally understood, the implications of the Qualified Equipment Rules are not always clearly perceived by the planners in the plants, and any connection with the reference material may be hard to establish.Although I observed that qualification is being integrated in the training of the maintenance engineers with the Operations Engineering Unit acting as client, this needs to be given more focus among other players (operators and supervisors of design, projects and manufacturing checks).I am pleased to see the positive action of senior management from the Nuclear Engineering Division and the Nuclear Generation Division at the end of 2014 to better manage the Equipment Qualified for Accident Conditions (see Chapter 9).

Vigilance in managing obsolete equipment

Long-term management of equipment obsolescence that takes into account the disappearance of the original suppliers is a major issue for nuclear safety 79 Qualified Equipment Rules


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during operations. This is clearly illustrated by the case of the instrumentation and control equipment (I&C): an I&C equipment ageing watch has been set up by the Nuclear Generation Division and the Nuclear Engineering Division, electronic components are being stored, and arrangements are being made to renovate the I&C equipment during the third 10-yearly inspections of the 1300 MWe units and the fourth 10-yearly inspections of the 900 MWe units. I would like to emphasise the benefits of long-term partnerships with suppliers to ensure that design and manufacturing skills are not lost and to keep equipment serviceable. Improvement of spare parts management by the Central Technical Support Department remains to be confirmed. In many cases (valves, cables, solenoid valves, etc.), a spare part was not installed because it was not serviceable, which meant that the maintenance operation was either changed or delayed. I note the Nuclear Engineering Division’s requirement of maintaining technical mastery, with young staff often faced with old technology. I am left wondering about the adequacy of the current process involving the Nuclear Engineering Division and the Nuclear Generation Division which is responsible for operational control. I also wonder about the arrangements to prepare for operation beyond 40 years. I will be paying special attention to this issue during my visits in 2015.

Importance of exceptional maintenance

After the discovery of a defect in a reactor vessel bottom penetration (welded tube for neutron probe entry) during a check80 in a 900 MWe reactor in 2011, a temporary repair was made. This was accompanied by special requirements for in-service monitoring. The final solution, devised by Westinghouse for EDF, was to be integrated in 2015. I note that EDF asked for the repair to be postponed until 2016 due to technical problems, even though the teams had been reinforced. I am aware of the technical difficulty of such an operation. Experience feedback from the treatment of such defects in the South Texas nuclear power plants in 200381 needs to be fully exploited, as does feedback from the Palo Verde event in 201382 where the final repair was made during the actual outage in the course of which the fault was discovered. This example leaves us wondering about how exceptional maintenance

80 One reactor vessel bottom penetration found to be possibly faulty out of the 1700 inspected in the plants in mid-2014 to check for any stress-corrosion faults in the areas potentially vulnerable made of Alloy 600 or an equivalent

81 The repair was carried out by Framatome and lasted 4 months82 The repair was carried out by AREVA and lasted 1 month

between detection of the fault and completion of the repair work

operations are actually managed and what the regulatory requirements are in France. More generally, it is important that the Nuclear Generation Division makes reasonable efforts to plan ahead so as to have industrial assurance case files.

Encouraging developments for spare parts

As soon as the AMELIE spare parts management project ended in 2013, the Central Technical Support Department took over the operational leadership and promotion of the campaign. At the Velaines corporate warehouse managed by the Maintenance and Logistics Unit and in the nuclear power plants, I noted an encouraging development by those involved in the management of spare parts and the processes to improve their methods and results. It cannot be denied that the plants have expressed their dissatisfaction with sub-standard spare parts and incomplete documentation. But overall, progress has been made thanks to the efforts of corporate players (from the Central Technical Support Department, the Maintenance and Logistics Unit and those in the plants) and in particular the spare parts engineers and technical directors. I encourage the Central Technical Support Department to continue its action so the plants gain more confidence in it. I note the increased stocks of industrial-safety-related items at corporate and plant levels.I note a positive trend in the placing of orders four month ahead by the plants. Yet, there is also the overbooking of parts, which needs to be rectified by the maintenance departments. In certain plants, spare parts management has been relegated to the general services departments, yet I think it would be beneficial for them to be linked directly to the maintenance departments as spare parts are vital to the maintenance function. I would like to underline the advantages of the approach focusing on costs, quality, functionality and deadlines. This approach was developed at the request of the plants to address discrepancies occurring with spare parts. More action is required to further reduce the time taken to obtain them. I have noticed the small number of items returned from the plant stores, which are still very full, to the Velaines centre where the capacity is now greatly reduced. I have taken good note of the project to extend the storage capacity there, yet I question whether it has been adequately sized in view of the experience feedback and the plans to extend plant life to 60 years.


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The nuclear plant maintenance worker guidelines

INDUSTRIAL RELATIONS AND CONTRACTORS IN FRANCE

The Nuclear Engineering Division, the Nuclear Generation Division and the purchasing directorate have carried out important work relating to the General Refurbishment to assess the capacity of the supplier portfolio. Some service providers, while announcing that they are willing to engage with EDF, are waiting for information on the operations associated with the General Refurbishment (see Chapter 9).The forming of partnerships can conflict with the “lowest bidder” policy, yet I consider that it is advantageous to develop durable special relations with key players to ensure continuity in the nuclear power plants (e.g. using the same contractor to make the same modification in each unit of a four-unit plant). I have observed this practice at EDF Energy. Some of the larger contractors consider that EDF should encourage the commitment of their suppliers and feel that their initiatives tend to be disregarded.As concerns relations with contractors in the plants, I have observed good practices fostered by those in charge of industrial policy. It is worth citing the annual meetings between the plant’s senior management and the contractor companies which lead to a progress action plan jointly defined by the senior staff of EDF and the contractor companies, or the existence of a contractor manager network intended to increase the professionalism of the contractor company’s team

supervisors. I encourage the industrial policy managers, the key players at plant level, to engage more with the joint Nuclear Engineering Division and Nuclear Generation Division teams in the plants; this would offer a more coherent dialogue to the contractors, while maintaining their commitments with the professions.I note the work to assess the suppliers in the plants and at corporate level by the Nuclear Engineering Division and the Nuclear Generation Division, with the Central Technical Support Department handling integration83. Contractor assessment records are not always submitted within the 30 day target, and strong and weak points are not always shared systematically. A unit outage can be a very hectic time, but it is important to pool this type of information in a timely manner.

Reorganisation of nuclear contractor training

I am pleased to see that the nuclear safety, quality and radiation protection arrangements were reorganised by the PIRP84 Commission in September 201485. I note that there is a new nuclear safety and quality module relating to the new Licensed Nuclear Facility regulations.I also note the 2014 publication of the EDF guidelines for maintenance workers in nuclear power plants, written in cooperation with contractors. This document contains precious information on the planning and execution of activities: nuclear safety during maintenance, industrial safety and radiation protection.

MAINTENANCE NEEDS TO BE IMPROVED IN THE UK

I note the high number of defects (3,000 on average per plant) affecting equipment and that the number is increasing at three plants. EDF Energy has begun an initiative to rectify defects, particularly those which keep occurring. I have observed that the fault repair priorities are not always optimal. If they had been optimal, the consequences of a grid disturbance in April 2014 may have been limited (see Chapter 12).The high level of automatic trips in 2014 appears to have been caused by equipment faults rather than human error. EDF Energy has launched a programme to examine and reclassify these faults, associated with a new result indicator system at corporate level. The excessively high number of persistent faults - also occurring in the plants with the best generating results - suggests a level of defect tolerance potentially harmful to nuclear safety.

83 810 suppliers, 8,000 contractor assessment records84 Contractor Industrial Relations and Industrial Policy 85 Refresher training is now required every three years


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High priority must be given to rectifying these faults with a level of urgency proportional to their seriousness. The reliability of the plant equipment was identified as an avenue of progress in the WANO Corporate Peer Review in 2012. A programme to improve maintenance is underway with four key objectives: • Quality• Culture of leak prevention• Incorporation of requirements such as: foreign material

exclusion management or torque tightening techniques• Contractor performance.I encourage EDF Energy to intensify this programme, making full use of the AP913 and AP928 methods, and to monitor the results. Cooperation between EDF Energy

and EDF SAon equipment maintenance methods and feedback analysis practices would be extremely profitable.

Heysham 1 Nuclear Power Plant: entering a steam generator

MY RECOMMENDATIONS

In France, durably improving the management of maintenance volumes is an important issue for nuclear operating safety. I recommend that nuclear power plant managers pay special attention to the nuclear safety issues attached to operations that are made to fit into a timetable or have been abandoned. Instead, a strict multi-year project should be deployed without further delay.A kick-start is necessary to obtain the expected level of quality in maintenance. I recommend that the plant management promote and permanently use a process designed to better manage the quality of maintenance and operations together with the contractors.I strongly recommend re-establishing a common core for the project and technical professions, combined with a skills programme, to improve safety and quality in a harmonised manner across the fleet. I invite senior managers and heads of departments in the power plants to make good use of this common core to bring about changes.In the UK, like my predecessor in 2013, I recommend focusing action on AP913 and AP928 methods to improve equipment reliability. Furthermore, I call for greater sharing of maintenance experience between EDF Energy and EDF SA.


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nUcLEAR EngInEERIng: A MAjOR ASSET FOR THE OPERATOR THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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7 / NUCLEAR ENGINEERING: A MAJOR ASSET FOR THE OPERATOR

The simulator room in nuclear design and construction centre

Full control over the design and configurations of the installations, associated with a strong sense of responsibility as a nuclear operator, is a major asset for nuclear safety.

The Nuclear Engineering Organisation of the EDF Group is faced with a number of challenges: long-term support of French and British nuclear power plants in operation, start-up of the Flamanville 3 EPR, the project to build EPRs at the Hinkley Point site and new reactor types, as well as decommissioning issues.

The corporate engineering function is being reinforced in France. Meanwhile, the engineering teams in the nuclear power plants are growing in strength, consolidating the link between designers and operators.

THE SCOPE AND MISSION OF THE NUCLEAR ENGINEERING ORGANISATION OF THE EDF GROUP

The engineering organisation of the EDF Group acts in the following areas:• supporting nuclear power plants in service• building new reactors: Flamanville 3, support at Taishan

Nuclear Power Plant, the Hinkley Point C project, • designing new types of reactors: Generation III and IV

(Astrid Project), • decommissioning reactors.

In-service support for nuclear power plants

Support covers design and operations, with particular reference to the nuclear safety rule sets, the documentation, technical, industrial and managerial assistance for the plants, the planning and incorporation of modifications and major maintenance work (including the assessment and selection of suppliers with support from the Purchasing Division), and the analysis and correlation of experience feedback from plant, corporate and international levels.

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At EDF SA, I hail the greater cooperation between the Nuclear Engineering Division and the Nuclear Generation Division (interfaces and joint strategy): i) their joint project in 2011 to bring the engineering centres closer to the generating sites and re-appropriation of the design rule sets by the operators, ii) and work carried out in 2014 to foster nuclear safety during unit outages by reducing the volume of work (maintenance and modifications). As desired by my predecessor in 2013, the corporate-level engineering organisation has positioned itself so as to better serve the nuclear power plants, at management and work team levels. More focus is being given to the plants, a change appreciated in many of them.I also note AREVA’s substantial contribution, with EDF acting as client, to drawing up the licensing documentation and nuclear safety proofs, as well as to properly sharing the engineering priorities with the appropriate departments of the Nuclear Engineering Division (Basic Design Department and Power Plants Operations Engineering Centre).In the UK, the special nature of the engineering support for AGRs needs to be borne in mind as they differ in design between themselves and are unable to benefit from experience feedback from similar installations in the world. The role of the Design Authority86 is accordingly all the more important. I note the efforts and the professionalism of players at both corporate and plant levels, as well as the support of outside engineering and R&D organisations. However, I call for vigilance by the INA87. Firstly, this concerns the conditions applicable to the possible continued operation of certain AGRs regarding nuclear safety margins. Secondly, this concerns the robustness and completeness of actions taken to plan for the future (nuclear safety cases, in-service inspection and modifications). Furthermore, I hail the contribution of the EDF Nuclear Engineering Division, the Nuclear Generation Division and the R&D Division in assessing and resolving the Heysham 1 steam generator event in 2014. The analyses by the Nuclear Engineering Division of the AGR plant life extension case (see Chapter 10) are also worth highlighting. It would be profitable for nuclear safety if the Production & Engineering Directorate (DPI) were to increase its contribution since it offers an outside view. This directorate could help by evaluating the key points of the EDF Energy nuclear safety cases, possibly within the Nuclear Safety Committee while EDF Energy symmetrically participates in the EDF SADesign Nuclear Safety Committee.

86 Defined in INSAG 19 as “maintaining the design integrity of nuclear installations throughout their operating life”

87 Independent Nuclear Assurance (formerly the Safety and Regulation Department)

In France, I consider that this integrated nuclear engineering source to be an asset for industrial programmes. This is because architect engineers in the nuclear industry are generally engineering companies that have neither plants in service nor comprehensive hindsight. In view of the fact that engineering and technical errors have had consequences as serious as the closure of three reactors, INPO emphasised the importance of nuclear operators’ responsibility and their control over the engineering fundamentals in 201488. After the Fukushima accident, WANO developed a process for assessing operator control over design and design changes over time. From my international contacts, it has become clear that the engineering organisation of the EDF Group has become a point of reference and a major asset. Nevertheless, its effectiveness in gaining full control over projects and in optimising solutions can still be improved, as the changes it has introduced have highlighted.

The eight engineering centres of the Nuclear Engineering Division and the Nuclear Generation Division

Six Nuclear Engineering Division centres: 6000 staff, of which 1000 work in the nuclear power plants

Two Nuclear Generation Division centres: 1200 staff.

Together, they represent around 20% of the total staff from both divisions.

Lyon

Paris

Tours

Marseille

UNIEUTOCNEN

CNEPE

CIDENSEPTEN

CIPN

CEIDRE

88 INPO Event Report 14-20 issued Integrated Risk - Healthy Technical Conscience


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The engineering hubs

Between the Nuclear Generation Division and the Nuclear Engineering Division, there are eight engineering hubs in France.

During my visits to the engineering centres, the plants and the division headquarters, I can see the importance of coordination between the teams and complementarity of their work, especially as the processes are complex and demanding. Accordingly, the engineering bodies must be able to fully exercise their responsibilities with proper oversight and optimised reporting when managing the General Refurbishment. I observed cross participation and cross-disciplinary analysis of design and operations. I believe that any modifications proposed by the designer ought to be challenged by the operator and that, by the same token, the designer could make more use of operational feedback to the benefit of nuclear safety.

A HEAVY ENGINEERING WORKLOAD STILL EXPECTED OVER THE NEXT FEW YEARS IN FRANCE

Like my predecessor, I note that the engineering workload remains heavy and that the situation will continue between 2015 and 2020. This workload will include i) supporting the plants in-service, ii) allowing for design improvements with respect to the Fukushima stress tests, iii) planning the fourth 10-yearly inspections in the 900 MWe series in the run-up to plant life extension from 40 to 60 years, iv) integrating additional regulatory requirements (relating to licensed nuclear facilities, nuclear pressure equipment, etc.), v) starting up and licensing the Flamanville 3 EPR, and vi) taking into account new reactor types. This not only applies to the EDF SAinternal teams but also to external engineering functions, particularly those of AREVA.Such a heavy workload should be manageable by optimising the overall organisation and by renewing skills. The skills of the new recruits continue to grow. As emphasised by my predecessor in 2012 and 2013, it is more than ever necessary to prioritise the issues to resolve so as to correctly allocate internal resources and to meet the ASN’s requirements. This being the case, I call for using the resources of the Nuclear Engineering Division discerningly so that it can concentrate on its missions.

THE NUCLEAR ENGINEERING DIVISION PLAYS A DECISIVE ROLE IN FRANCE

I would like to underline the decisive role that the Nuclear Engineering Division plays as architect-engineer

in industrial projects and operations, and the associated demands placed on all its professions.

Demands on the professions

Designing improvements for plants in service

This specifically relates to the Nuclear Engineering Division’s design authority. The Nuclear Generation Division assumes contract ownership while the Nuclear Engineering Division guarantees installation configurations and safety upgrades throughout operations, via its engineering centres (Basic Design Department, Construction and Operation Expert Appraisal and Inspection Centre, Power Plants Operations Engineering Centre and Electromechanical Department). I often hear service providers who would like to have more functional design and operation sophistications enabling them to make proposals and suggest innovations. Like my predecessor in 2013, I note the pressure on the Power Plants Operations Engineering Centre and the Electromechanical Department to provide the plants with modification files and quality test procedures on time. The situation is improving in the joint teams, yet still without safely meeting the target of gaining full control over unit outages and the workload associated with the General Refurbishment. A file that does not comply with plant integration requirements in terms of quality, promptness or documentation cannot be acted upon unless it is particularly important to nuclear safety. I call on the nuclear power plant directors to be particularly vigilant. I will be returning to this matter in Chapter 9.

Post-Fukushima studies in the Power Plants Operations

Engineering Centre


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Incorporating modifications into operations while designing and building new reactors

The engineering capability (Nuclear Design & Construction Centre, Electromechanical Department, Power Plants Operations Engineering Centre and the Basic Design Department) manages all major projects focusing on nuclear safety and quality. This engineering capability is progressing in EDF SA’s fields of internal action. I come back to this issue when discussing new reactor projects in Chapter 11.

Decommissioning

The decommissioning process is extremely demanding and much is to be learnt. It is managed by CIDEN89 with various worksites that are well advanced, such as at Chooz A, Creys-Malville and Brennilis which are particularly impressive in terms of their rigour and the progress made.

Preparing the future

Based on studies and R&D work, the engineering organisation establishes the proof necessary to operate the reactors for up to 60 years. It also determines the technical and nuclear safety options for new Generation III reactor types, as well as those of Generation IV, while watching over international developments. I note the strong involvement of the Nuclear Engineering Division - supported by EDF’s R&D Division - in an R&D programme with safety objectives set at an appropriate level (Chapter 11).

Helping to develop codes and standards

I must stress how important industry codes and associated standards are to nuclear safety in the design, construction, operation and decommissioning of installations. The foundations of nuclear safety are indeed based on codifying tried-and-tested industrial practices, whatever the regulatory requirements. I note the leadership exhibited by the Nuclear Engineering Division in this field with the contribution of EDF’s R&D Division, the Nuclear Fuel Division and industry players. I particularly noticed that the industrial operators

89 Nuclear Environment and Decommissioning Engineering Centre

and NNSA90 in China were interested in French codes91. Nevertheless, the manpower and skill levels are still insufficient with EDF and the main industry players.I note the efforts and the progress made by the AFCEN92 to bring together the main industry players, to update the codes so they are more relevant with respect to experience feedback and expected quality levels, and to assist in proposing solutions to some of the difficult questions raised by the application of the Nuclear Pressure Equipment Order. The experience acquired with the Flamanville 3 EPR, particularly the new civil engineering code and the drawing up of a code for the qualification of equipment could represent an excellent opportunity. There is no contradiction between the codification of industrial practices and the regulations. This is shown by the Nuclear Regulatory Commission’s approval of certain standards issued by ASME93. I call on the stakeholders to envisage a process with the ASN leading to the explicit recognition of all or part of the code - amounting to presumption of conformity. This would help stabilise and clarify the industry and regulatory rule sets.

Organisation, skills, methods and tools are evolving

I hail the progression with the work on important issues identified by the DINamic 2020 strategic plan:• the presence of a team of a dozen nuclear unit

architect-engineers in the Power Plants Operations Engineering Centre since 2012. I consider this to be useful for two reasons: gaining control of the actual condition of the nuclear units with a review of conformity, while securing the planning of unit outages. This would be a good time to reinforce this team in view of the coming General Refurbishment,

• the creation of a system for controlling the nuclear safety margin for operations, associating the Nuclear Engineering Division, the Nuclear Generation Division and the Nuclear Fuel Division with oversight by the Basic Design Department. This illustrates the value in terms of safety of an integrated engineering organisation. It is important to preserve sufficient margins and restore them when necessary, under the supervision of the margins administrator from the Nuclear Engineering Division senior management. I note these strong demands for this work, which relies on the generic review of the nuclear safety margins per standardised

90 National Nuclear Safety Administration91 RCC rules for design and construction, RSE rules for operation

and ETC rules for EPRs92 French Association for the rules of design, construction and

in-service surveillance of nuclear steam supply systems93 American Society of Mechanical Engineers in the US


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series and per fuel management system. It also relies on the nuclear safety and system performance reviews, with special regard to the integration of experience feedback and surveillance tests. I emphasise the importance of updating the systems files, particularly those of the CP0 and N4 series. This process becomes particularly meaningful in the context of the 10-yearly

nuclear safety reassessments. The AP 913 method reflects this. I note the provisional assessment of the nuclear safety margins for MOX parity management in 900 MWe reactors, as well as management of the reactor vessels with regard to sudden fracture between 40 and 60 years, while seeking levers for restoring the margins.

MA

RGIN

S

MA

RGIN

S

MA

RGIN

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MA

RGIN

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Safety case margins

Changes in project management

In the engineering systems, I have noticed a new system of project management and oversight. I support this change, seeing the importance for properly managing the General Refurbishment. It benefits from the Flamanville 3 EPR project, which now sets the standard. In particular, the Project Management Office should improve the management of activities while providing inter-project leadership: for instance, one department of the Power Plants Operations Engineering Centre manages eight large projects (10 ten-yearly inspections and post-Fukushima actions) and 1,600 small projects.

The Product Life-Cycle Management Project

The Project Life-Cycle Management (PLM) Project is an initiative underlying a modern approach to engineering fostered by the rise of digital technology and intended to meet the needs of the projects and professions for data management. Very demanding and with much potential, it stems from the collaborative integration of the players (in-house and external), data systems and processes, for the entire life cycle of the nuclear installation: design, fabrication, construction, commissioning, operation, spare parts, modifications and decommissioning. Experience feedback from other branches of industry (aerospace, transport etc.) is put to good use. The PLM Project started in 2011 and completed its focusing phase at the end of 2014. Solution conceptualisation has begun.

I support the development of the (PLM)94 project by the Production & Engineering Directorate as it can be beneficial to nuclear safety by improving operator control over the installation configurations and associated requirements. Since the start of the Hinkley Point EPR project, EDF Energy has integrated this approach with the support of the PLM Project. The process is also integrated into the basic design projects of the new four-loop reactor, for which an EDF-AREVA unit is preparing the methods and tools. The development of skills specific to EDF relating to the basics of PLM and the prudent application to practical cases appears to be appropriate. I note the interest shown by the Nuclear Environment and Decommissioning Engineering Centre and I encourage the engineering function of plants in service to state its expectations concerning this issue.At the Construction and Operation Expert Appraisal and Inspection Centre (CEIDRE), I note with interest the creation of GIPEC95. This group spot-checks fabrication processes and sensitive repair work both in the workshop and in the plant, on the basis of experience feedback from the Flamanville 3 construction work.

Accumulation of technical know-how

The ‘health’ reports96 issued for twelve technical areas issued by the engineering centres of the Nuclear Engineering Division with the support of UNIE97 make

94 Product Life-Cycle Management95 Polyvalent Non-destructive Testing Group96 Nuclear safety, core fuel, installations, instrumentation and

control, mechanics, electricity, chemistry, civil engineering, operations, reactor control, environment & waste, and project management

97 Operations Engineering Unit


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the situation clear and are much appreciated by the staff. With approval from the technical directors of the engineering centre committee, the intention is to diagnose the in-house and external skills, the technical rule set, the industrial environment and the structuring of costs. These constitute levers for making progress in weak areas, e.g. the recognised need in the field of operations and reactor control to establish a formal doctrine for tests. I encourage this initiative, which needs to be a permanent process.I note the work launched in 2014 to update the main technical rule sets for engineering (notes, guides, codes, etc.), starting with nuclear safety. The foundation stone - corresponding to a set of some 500 documents - needs to be consolidated over time.As regards allowance for experience feedback, it appears that more in-depth work is needed, with more formal processes in the engineering centres and the Nuclear Engineering Division. Priority should be given to French and international operating experience feedback, followed by experience feedback on modifications. I suggest that experience feedback on the plants in service be better shared with the main industry stakeholders.

NUCLEAR GENERATION DIVISION’S CORPORATE ENGINEERING ORGANISATION LINKED TO THE PLANTS IN SERVICE

I note the more flexible organisation of the Nuclear Engineering Division’s engineering organisation dedicated to the plants in service with the complimentary bodies constituted by the Operations Engineering Unit, the Central Technical Support Department and the teams responsible for the standardised series of units. Their contribution to plant performance levels is significant and they have a key position between headquarters and the plants.

The Operations Engineering Unit: a strategic operations-related vocation

Its missions cover i) the operations rule set, ii) the management of corporate and international experience feedback, iii) leadership of the professions, iv) management of projects and casework, v) plant support and vi) support in managing certain requirements.It conducts concrete action to support the plants. For instance in 2014, it supported and handled plant proposals concerning the volume of maintenance work, it provided a new event analysis method, it promoted the AP 913 method, it provided the call centres and task forces, and it sent teams to plants on request.

I note difficulties in finding sufficient nuclear safety and common-core personnel, jobs suitable for former operations shift managers, safety engineers, Quality & Nuclear Safety Advisory Unit heads and nuclear safety and quality department heads. I support the initiative for crossing recruitment with the nuclear power plants.I encourage the long-term initiative to simplify the rules by separating the reasons and the goals from the comments. This is illustrated by the drafting of the rule set for events, which is intended to reinforce operator back-up to overcome the plants’ difficulties in risk analysis, for instance with regard to earthquakes98.I was shown work carried out as part of experience feedback management, particularly international events with nuclear safety and radiation protection implications, as well as WANO Significant Operating Experience Reports. I would like to highlight the proactive nature of the initiative which uses benchmarks and pools both experience feedback and EDF practices in international groupings. I appreciate the rigour and the quality of the on-going processing of 15 Significant Operating Experience Reports. I encourage continuing the promotion of the subject in the plants and incorporating the lessons derived from the operations rule set. It is essential that the processes and related oversight - at corporate and plant levels - take into account the lessons derived from international experience feedback, as well as the findings of WANO peer reviews and IAEA Operational Safety Analysis Review Team inspections. This constitutes an avenue of progress that I will be assessing during my forthcoming visits.I appreciate the maturity of the strategic leaders for equipment in place in the Operations Engineering Unit and in the Nuclear Engineering Division (Power Plants Operations Engineering Centre and Electromechanical Department) under the supervision of the Nuclear Generation Division’s management. They show skill in their role of leading the experts and establishing a high-level strategic vision for the benefit of performance, particularly as regards nuclear safety. I note their help in assessing suppliers, while emphasising need to find the necessary staff for the 12 categories of equipment concerned.I call on the Operations Engineering Unit to be more willing to challenge the options put forward by the engineering centres of the Nuclear Engineering Division, especially as regards drawing up modifications. I would like to raise the question of the future involvement of this body in the work on the Flamanville 3 EPR, beyond that of the operators’ local engineering team. Indeed, including

98 Analysis of the potential consequences of an earthquake on the installations, supplementing the equipment design approach based on load cases, considering the risk of damage to protection-important components by non-seismic grade equipment


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this reactor in the Operations Engineering Unit’s scope of work with plants in service makes sense in terms of nuclear safety in many regards.

The Central Technical Support Department: an operations-related vocation

Its missions relate to scheduling, maintenance operations, spare parts, logistics, unit outages, supplier vetting and waste management in the plants (see Chapter 6).In 2014, I noted the support given the nuclear power plants for unit outages (good practices, diagnosis, etc.) and the refocusing on renewed contract ownership for certain professions with respect to certain issues left to contractors: particularly the creation of EMAT99 within the Central Technical Support Department, a joint body responsible for zones, schedulers and coordinators with four regional bases that second teams to the plants. Furthermore, support relating to the fundamentals of unit outage management needs to continue, particularly as regards the multi-year programme and modular planning.There has been progress with spare parts and logistics engineering, associating the Central Technical Support Department, the Maintenance and Logistics Unit and the plants. I consider that scheduling of engineering needs to be brought back in-house (methods and skills) in the run-up to the General Refurbishment and for managing outages.Contractors that I met were deeply interested in how they are being assessed and the corresponding process. They are hoping for better-drafted Job Assessment Records that will improve action plans drawn up in the light of experience feedback. I call on the Central Technical Support Department, in liaison with those in charge of industrial policy in the plants, to provide stronger leadership on this process considering the numerous cases of substandard maintenance.

Teams responsible for the standardised reactor series at Tricastin (900 MWe), Paluel (1300 MWe) and Civaux (N4) Nuclear Power Plants

These teams draw up standardised Class 4100 procedural documents, such as maintenance instructions and they incorporate prescriptive material. I note that much

99 Unit Outage Joint Team (UTO)100 Under the Nuclear Generation Division’s rule set for

documents, the classes are as follows: 1 for policy, 2 for doctrine, 3 for Basic Preventive Maintenance Programs and associated rules, 4 for maintenance and operations procedural documents

is expected in terms of obtaining updated quality maintenance documents in due time. As I understand, the plant professions under plant management oversight have a crucial role to play in ensuring information feedback to these teams and in coordinating the change proposals.

THE RISE OF LOCAL ENGINEERING TEAMS IN THE PLANTS

The engineering centres and their representatives in the plants are focusing more on operations, which I am pleased to see. This trend must be strongly encouraged to ensure that it bears fruit when it comes to managing outages and the General Refurbishment. In particular, I note: • the maturity of the engineering and reliability

departments in the plants: the teams are well aware of what is at stake for the systems and equipment and are drawing benefit from the AP 913 method. I can see their vital contribution, in terms of nuclear safety, in managing the volume of maintenance work and integrating the requirements. They assist the plant management in deciding how to identify and reorganise maintenance activities and what improvements are needed from a multi-year viewpoint. Accordingly, they have an important role to play in fostering exchanges with the maintenance departments when it comes to the content of the rule set, and the significance and utilisation of operating experience feedback. I note their help in producing the DAPE101 Files for the reactors, overview documents drafted during the 10-yearly inspections.

• a stronger role for the engineering centres in supporting the nuclear power plants: reinforcement of the joint Power Plants Operations Engineering Centre and Electromechanical Department teams in the plant is continuing. This is to ensure that the unit outages can be properly planned and carried out during the General Refurbishment and is set to begin in 2015. This will involve deploying a Plant Liaison Engineer for each site at the Power Plants Operations Engineering Centre and the Electromechanical Department, as well as deploying local design engineers in the plants. Nuclear Generation Division staffing is not at the required levels in certain plants. I note with satisfaction that the engineers and technicians are now in place for the civil engineering maintenance work on these installations. Their contribution is particularly important as regards service life.

101 Aptitude for Continued Operation Case Files


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ENGINEERING SKILLS REQUIRING SUPPORT

The engineering skills management process is generally of good quality in the corporate bodies: mapping, forward planning of jobs and skills, key skill development plans and training.I would like to draw attention to the importance of the technical expertise professionals which need support if they are to compete in terms of attractiveness with management and project professions. I emphasise the need to forward plan for the needs, in the Nuclear Generation Division and the Nuclear Engineering Division, in particular for positions requiring abilities relating to operations shift managers and safety engineers, process engineers, test specialists, pressure equipment specialists and chemists. I note the sharing of a common list of experts by the Nuclear Engineering Division, the

Nuclear Engineering Division, the Nuclear Fuel Division and EDF’s R&D Division. I also note the efforts made to standardise the associated criteria concerning the levels of expertise. At AREVA, I observed a process that is well organised and developed at plant and corporate levels to find younger experts, intended to make this profession as attractive as a management position.We must remember how important it is to provide crossover careers between the Nuclear Engineering Division and the Nuclear Generation Division, as stipulated in the joint agreement the two divisions. The acquisition of the respective culture and experience is beneficial for collaborative functioning and for nuclear safety. In 2014, the annual transfer rate rose to a satisfactory level after a number of years of low rates. I would also like to draw attention, at the highest level, to disparities in the staffing of the Paris-based departments with individuals with suitable skills.

MY RECOMMENDATIONS

To fully exercise its responsibility as a nuclear operator, I call on the senior management of the EDF Group to make sure that the engineering skills are maintained throughout EDF SAand EDF Energy, at the levels necessary to ensure functional and physical control over the design of the installations and their changes over time.At EDF SA, I encourage the senior management of the Nuclear Engineering Division and the Nuclear Generation Division to continue their work on improving their collaborative functioning and to support the trend towards a corporate engineering organisation that is more focused on operations.There is an absolute need for simplification in operations (in prescriptive material, maintenance files, etc.) which requires major efforts. I recommend that senior management at corporate and plant level in the Nuclear Generation Division support this trend more forcefully. I encourage division managers to promote the technical expertise professions more forcefully, seeking to develop crossed professional careers, which are indispensable for having experts with broad-reaching skills.The codes and standards are vital to nuclear safety and quality in operations. I also call upon the Nuclear Engineering Division, the Nuclear Generation Division, and the Nuclear Fuel Division, in liaison with EDF’s R&D Division and our industry partners, to reinforce the teams working on codes and standards. Priority must be given to providing support to the AFCEN (French Association for the rules of design, construction and in-service surveillance of nuclear steam supply systems). Furthermore, I encourage all involved to examine the benefit of gaining the ASN’s recognition of all or part of the codes, and this being tantamount to regulatory conformity.

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8 / NUCLEAR MANAGERS - CONFIDENCE BUILDERS

Dialogue between a nuclear power plant manageress and an employee

Nuclear managers - whether working for EDF and for or contractors - lend meaning to and embody the priority of nuclear safety in the context of far-reaching renewal of skills and high societal demands.

They provide the driving force behind the development of nuclear safety culture, in a branch of industry where risk control is required on a daily basis.

Their leadership and their coherence as a group, unremittingly focused on the demands of the nuclear process, foster the commitment of employees and the confidence of stakeholders.

They are in the front line and need support.

MANAGERS THAT ARE COMMITTED YET EXPOSED

They need support

During my visits, I encountered many managers: those in charge of operations alongside their teams, project managers, managers of managers, and members of the management teams within plant and corporate bodies.The profession of a nuclear industry manager is an absorbing one that is difficult and demanding. It requires strong leadership, courage and tenacity, but also

willingness to listen and ability to lead, conscious of the need to explain and to foster nuclear safety.The manager provides operational supervision and leads change at a time of extremely high pressure in the nuclear industry: broader and more rigorous operating constraints, higher rates of change, increasing demands (at times paradoxical), new societal expectations and unprecedented staff turnover. And this at a time when progress needs to be made with nuclear safety.The managers I meet are strongly committed. In France, the substantial progress in 2014 with the management of unit outages is contributing to confidence in the future, confidence that is fostered by these managers. I

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also meet managers who tell me that they are sometimes overwhelmed with work, for some to the point of discouragement. I sometimes note the absence of the solid support which would assist the managers in understanding and relaying the requirements, and even lack of confidence in colleagues. In the UK, I noticed that the support for managers is more effective than in France. I observe their more cooperation between colleagues, more willingness to provide each other support, and greater backing by headquarters.

Where requirements interconnect

Faced with ever increasing requirements that are sometimes contradictory, managers often speak to me very frankly about the increased complexity and the risk of their functions becoming increasingly bureaucratic. The situation demands that they concentrate on the human aspect of their responsibility and on their work teams. At the same time, they must take care not to lose sight of the realities, the risks and the priorities dominating the short and medium-term.

Contractor managers faced with similar difficulties

I note the commitment of front line management at contractor companies in obtaining the final quality required. This can vary from one plant to another for the same contractor company. The industrial partners and service companies also work in other branches of industry and often find it difficult to take on board the very special nature of the technical requirements that provide nuclear safety. This kind of attitude is prevalent among some managers in contractor companies who find that EDF’s demands, if not those of the French nuclear safety authority, do not correspond to normal industrial practices, even in sectors of industry where risk management is highly important. It is dissipated when there are strong links between EDF and contractor managers.

Too many demands on managers

Rising bureaucracy resulting in preoccupation with details and losing sight of the essential. When managers lose their frame of reference, they can end up losing their focus on operations and continuous improvement of nuclear safety levels. In 2012, INPO was already warning

about bureaucratic inflation and complication of the lives of the work teams.

The new legal dimension

The increasing legal complexity of French society has resulted in plant directors trying to make sense of matters as best they can. This can result in them feeling lost and losing sight of the real industrial issues and the actual situations in the field. I call upon the senior management of the EDF Group to give careful thought to these new situations. The increasing scope and complexity of the nuclear regulations can result in them being viewed in a strictly legal manner, at the risk of losing sight of the why and wherefore of their intentions.

SOME HIGHLY POSITIVE AND ENCOURAGING POINTS

In my exchanges with managers, I have also found positive signs that bode well for the future.

Managers close to their teams

Managers who remain in close contact with the field and their teams remain more confident than others. Willing to listen to the difficulties and the suggestions for improvement, they reflect the purposes behind the requirements. In their willingness to recognise efforts and by supporting initiatives but refusing the status quo as concerns the quality of nuclear safety, they inspire confidence and maintain serenity. These observations relate equally to the power plants, the engineering centres, the expertise centres and the support centres.

Control room briefing at Tricastin Nuclear Power Plant,

Managers who give priority to nuclear safety

I note the priority widely given to nuclear safety and general recognition of the importance of nuclear safety

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culture. Openness, which is one of the key components, is a first step towards mutual confidence. Openness alone is not sufficient and I call for rigour and a questioning attitude as other fundamental components of nuclear safety culture. After the corporate Operational Safety Analysis Review Team inspection of EDF SAat the end of 2014, I note with satisfaction that the IAEA recognises the general commitment of the managers to this priority.

The opportunity represented by generation change

The generation change in progress in EDF SAprovides managers with the opportunity to influence the collective skills of the teams and to encourage initiative and questioning attitudes among the new arrivals. Their seniors can thus take pride in explaining the best professional practices acquired by long experience, pass on unwritten implicit knowledge, aid and help newcomers to integrate the company. In the power plants, I note the increasing commitment of managers to developing skills, with the rise in training support which reflects the well-established practices of EDF Energy. In the Nuclear Engineering Division, I have observed the action of the RACINES102 initiatives to transfer knowledge relating to health checks of skills that assist managers in their role of developing skills.

Training a team at Nogent Nuclear Power Plant

Collective dimensions of management

The management teams within the departments and units play an important role in expressing problems, sharing understanding, unravelling conflicting situations, and handling the inflow and processing of suggestions and event precursor reports. I note that the Nuclear Engineering Division is developing a more visual style of management referred to as “lean”, which is more direct and effective, thus fostering debate and putting

102 An initiative that loosely translates as “Success by ensuring inter-generational engineering skills and the employability of all employees”

priorities into perspective. Introduced as part of a proactive approach, this initiative has now spread to many different levels of management.I would also like to stress the usefulness of peer networks (front-line managers, heads of departments, profession promotion managers, etc.) in and between the operational units. These networks foster openness and experience sharing. I have seen the value of such networks focusing on professions, such as that concerned with operations in the Rhine-Rhône region. I encourage plant directors to promote these practices which necessitate backing if they are to be durable.In the Nuclear Generation Division, the deployment of an integrated management system in plants and at headquarters level strengthens and facilitates control. In the UK, I note the positive effects of the delivery teams. All these arrangements, which strongly lend structure, may however prove to be time-wasting and of little value if the managers find themselves in situations where they lose contact with their teams and the ability to explain.In the generating plants in the United Kingdom, enrolment in the leadership programme is not limited to managers and involves not only the direct line staff, but technical mentors and partners in the dissemination of the nuclear requirements. I note the intention, with support from fleet managers, to promote solidarity between peers and between plants with pragmatic, effective cross-organisational actions. I am aware of, for instance, some extremely relevant initiatives in the field of radiation protection with sustained dialogue between the plants, support and mutual assistant promoted by personally appointed plant directors.

The leadership program at EDF Energy

The Nuclear Leadership Academy at EDF Energy is founded on three basic principles.• Nuclear Focus: leadership focuses primarily on the

demands of nuclear safety culture “incorporating the 10 traits of a healthy nuclear safety culture”

• Leaders Teaching Leadership: senior managers, plant directors and experts on key subjects are very broadly and personally involved in the teaching actions

• Action Learning Groups: learning relates to leadership action in the field

• The Diagonal Slice: design and engineering groups combining different professions and different hierarchal levels are formed to develop teamwork

• Strong Business Support: the Academy is supported by the highest level of management.

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MANAGERIAL COHERENCE TO BUILD CONFIDENCE

The remarkable achievements mentioned above ensure progress is made with nuclear safety through composure and confidence, dispelling any fatalism.From these different findings, I can see the main lines of force enabling managers to reinforce their confidence in the ability to make everyday progress with nuclear safety:• managers central to their teams• managers who develop skills• managers who are players, alongside their peers,

developing collective effectiveness. Managerial coherence at all levels of the organisation also contributes to having strong, shared nuclear safety culture

• managers that support an approach of continuous improvement.

PERFORMANCE AND RECOGNITION

Beyond the need for managerial coherence as regards the demands of the nuclear process and its fundamentals, I note two conditions of success, one relating to ambition in nuclear operations, the other to the employees.The role of managers is to promote an integrated approach to performance that encompasses nuclear safety, risk management, environmental protection and competitiveness. Such an ambition appears to rally the EDF Group around what it is seeking to achieve and facilitate the expression of a dynamic vision that is both positive and forward looking. This must be supported by

the managers, helping to maintain confidence between the stakeholders, both inside and outside the company.I can see how managers, in their teams, seek to develop situations that encourage employee participation. As it is of vital importance for nuclear safety, individual and collective participation must be recognised by managers. This is equally true for the employers of the EDF Group and those of the contractor companies.

CONFIDENCE AND NUCLEAR SAFETY CULTURE

I would also like to emphasise how important it is for nuclear safety to ensure the emergence of collective practices and individual attitudes conducive to self-expression, emulation, self-diagnosis and experience sharing. I can see the demands and the risks that such a process implies, yet I encourage managers to take corresponding initiatives at all levels. Such practices embody nuclear safety culture and contribute to the development of confidence and serenity.Such relations of confidence, established and maintained by managers, form a powerful line of defence: they are essential in developing employee commitment, while making sure that the requirements are scrupulously taken into consideration, beginning with those relating to nuclear safety.It is the operator’s responsibility to develop such managerial practices. There are no regulatory or in-house rules that could describe the intricacies of human behaviour; it is managers that need to take every day action to develop such confidence for the benefit of nuclear safety.

MY RECOMMENDATIONS

The unanimity of the managers on the demands of the nuclear process forms a powerful line of defence. In the interests of nuclear safety culture, I encourage managers - at all levels - to develop different means of facilitating the expression of priorities and the particularities of the process within their communities. Within the EDF Group and the contractor companies, nuclear managers are in a particularly exposed position. I would particularly like to draw attention to the support they need to be given, making sure to protect them against any other demands distancing them from their teams and their priorities.Their leadership ability is a determining factor and I encourage the programmes to develop this. In France, I call for more decisive action in this area, taking the EDF Energy leadership programme as an example.The nuclear managers are not alone in supporting such requirements. I call for greater openness and experience sharing with managers in other high-risk industries.

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9 / ON COURSE FOR REACTOR OPERATION BEYOND 40 YEARS IN FRANCE

Steam generator replacement at Blayais Nuclear Power Plant

The General Refurbishment is mobilising in-house resources and those of our industry partners at a level that has not been seen since the commissioning of the nuclear power plants.

Accordingly, everyday priority given to nuclear safety in the plants must be the subject of especial vigilance.

Since the Fukushima accident, EDF SAhas taken measures defined according to the best international practices to upgrade accident prevention and mitigation, as well as the resilience of the installations and the organisational systems.

SCOPE OF THE GENERAL REFURBISHMENT

This industrial-scale programme was began in 2009 and is to span two decades. Its goal is to enable operation of the reactors for more than 40 years, with 60 years as the target, with an even higher level of nuclear safety and more effective power generation. An ASN licence will be needed for the first reactor by 2019. Execution of the programme will involve projects, internal and external engineering, component manufacturing capability, as well improvements and maintenance work carried out with the plants in service and during unit outages. There are many challenges: technical, industrial, organisational, human-factor related and financial. Above all, nuclear safety is fundamental.

The amount of work associated with the second 10-yearly inspections103 in the N4 series, the third 10-yearly inspections104 in the 1300 MWe series and the fourth 10-yearly inspections105 in the 900 MWe series will be considerable from 2019. Some of the work carried out during the 10-yearly inspections will need to be done in advance during one or more prior partial inspections106. To guarantee nuclear safety and trouble-free outages, the major maintenance operations must be carefully scheduled during the unit outages, which will depend on the effective availability of replacement equipment. The

103 Known as VD2 in France (2ième visite décennale)104 Known as VD3 in France (3ième visite décennale)105 Known as VD4 in France (4ième visite décennale)106 Known as VP in France (visite partielle)

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programme is proceeding in a context of uncertainty: the impact of new legislation on the sourcing of energy, licensing by the ASN, which is still pending, non-stabilised application of the regulatory requirements (nuclear pressure equipment order from 2005 and the order on

licensed nuclear facilities from 2012, etc.). This means that the programme has to be started progressively. I note the contribution, which is currently generally favourable, to the quality of operations and the level of nuclear safety.

The general Refurbishment Programme

• The 10-yearly nuclear safety reassessments: ✓ carrying out the third 10-yearly inspections on the 1300 MWe series, beginning with Paluel 2 in 2015 and continuing until 2024, followed by the fourth 10-yearly inspections of the 1300 MWe series between 2025 and 2034,

✓ continuing the third 10-yearly inspections of the 900 MWe series begun in 2009 up until 2020,

✓ planning, licensing and then carrying out the fourth 10-yearly inspections of the 900 MWe series between 2019 and 2030,

✓ planning followed by carrying out the second 10-yearly inspections of the N4 series between 2019 and 2022, then the third 10-yearly inspections of N4 series.

• Continuation with the major maintenance operations (the steam generators of 900 MWe and 1300 MWe series, transformer replacement, condenser refurbishment and work on the containment buildings) carried out during 10-yearly and partial inspections.

• The post-Fukushima work carried out with either the units in service and during outages.

• The work on asset protection, frequently linked to the nuclear safety rule sets, including improvements in resistance to extremely hot weather, fire protection, the reliability of the heat sink, etc.

I note that 41 reactors of the same type have been operating for more than 40 years in Europe and the US (see Chapter 1). The technical feasibility of such plant life extension is proven. Work by the operators and the US Nuclear Regulatory Commission is in progress for licence extension to 80 years, with the regulatory process remaining unchanged. The practical arrangements concerning the nuclear safety requirements depend on the nuclear safety authority of each country. In Europe, the process can benefit from the harmonisation of certain basic principles, as under the Safety Reference Levels defined by WENRA107. I would like to highlight the fact that in France, the stringent requirements are embodied in the ‘hardened safety core’108 safety systems which was established after the Fukushima accident, itself a solid guarantee of nuclear safety in plant life extension beyond 40 years.

107 Western European Nuclear Regulators Association108 Stringent organisational and physical provisions intended to

preclude, even under extreme conditions, a core meltdown accident or at least limit its progression and enable the operator to duly carry out its emergency-management missions

900 MW REACTOR SERVICE LIFE EXTENSION BEYOND 40 YEARS IN THE POST-FUKUSHIMA CONTEXT

A view that developed before the Fukushima event

In 2009, EDF began reassessing nuclear safety of the 900 MWe series at the time of the fourth 10-yearly inspections, well before the Fukushima accident which occurred in 2011. The safety review of the changes in the installations since their commissioning indicated that the improvements made relating to events internal to the nuclear steam supply system had considerably reduced the risk of core meltdown. It was then necessary to focus on improving the arrangements to counter and mitigate the risks associated with external events109 by reinforcing cooling water and electrical power availability. Experience feedback from the Fukushima accident confirmed the pertinence of this approach, particularly as regards the following two points: • the need to periodically review the solidity of the

assumptions and accident-related operating procedures associated with external events, which is carried out in a formal manner in the context of the 10-yearly

109 Such as fire, flooding, earthquake extremely hot and cold weather, extreme winds, etc.


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reassessments of nuclear safety or in the light of operating experience and feedback110

• the need to give due consideration to all the nuclear units in a plant, and no longer only one of them, in determining what provisions should apply.

In 2009, EDF SAinformed the ASN of its intention to “extend plant life significantly beyond 40 years and retain the option of plant life extension to 60 years for all reactors”. Exchanges between the ASN and EDF SAbegan on the basis of a proposal for a generic programme by EDF SA. In mid-2013, the ASN provided EDF with its remarks and requests, considering the methodology of the overall programme to be satisfactory. I note that its demands are particularly stringent, unparalleled in the world of operational reactors, in particular that “nuclear reactors must therefore be improved, in view of the latest nuclear safety requirements (EPRs and equivalents)”.

Major investment to reconcile nuclear safety with industrial realities

I consider the policy of continuous improvement to be one of the foundations of nuclear safety insofar as the process is a pragmatic one, reflecting what improvements are reasonably feasible and consistent with what is at stake and the unavoidable industry lead times. We also need to avoid overcomplicating the installation and its daily operation.I note the great difference in this approach from regulatory practices in the US where the Nuclear Regulatory Commission conducts nuclear safety analyses to ascertain that there is a reasonable assurance with regards to extending operation 20 years beyond the initial 40 year period as considered in the initial licensing and using ‘current licensing’ as a basis. Particular attention is paid to the effects of ageing of static equipment and the environmental impact, including the mitigation of severe accidents using what is termed a ‘risk-informed’ approach.I would like to stress the approach chosen by the chairman of EDF SA, as stated at the special IAEA conference in 2012 and mentioned by my predecessor during the IAEA nuclear safety convention in March 2014. In the programme to improve nuclear safety during operations, the approach advocates that “no severe accident must result in the contamination of large areas in the long term”. I accordingly support research to find measures to avoid breaching the containment building and to avoid the associated releases in the event of an accident involving core meltdown, by means of a last-resort containment

110 Example of feedback from Blayais NPP in 1999 with respect to the risk of flooding

cooling system. I note that the filters installed at the end of the 80s already prevent contamination in a large number of scenarios, including severe accidents, unlike the situation in many countries.I noted the importance of there being no delay in improving the nuclear safety of spent fuel interim storage. I find that many improvements - made and pending - are intended to better protect against and mitigate severe accidents in the reactor building, ranging from active measures by the Nuclear Rapid Reaction Force to physical arrangements corresponding to the hardened safety core.The provisions relating to the spent fuel pools such as improving the instrumentation, and water and electrical power supplies (with mobile and/or fixed equipment), and improving fuel assembly management to reduce the space taken up in the pools constitute priority matters in view of the associated nuclear safety implications.I am pleased to see that re-racking is being abandoned and work is being carried out to manage interim storage in the long term.

Spent fuel pool at Saint Alban Nuclear Power Plant

SUCCEEDING WITH THE GENERAL REFURBISHMENT SAFELY

I support the approach deployed by the Nuclear Generation Division’s management which makes the nuclear power plants responsible for guaranteeing that the work and quality standards are integrated in service and during outages. This represents a break with past policy when, only too often, the action of the corporate bodies took place in parallel with that of the plants, to the detriment of unit outage management. With regard to this point, I note the demands placed on plant directors as decision-makers for feasibility and guarantors of nuclear safety within the scope of their remit. It is important to ensure that the right conditions prevail for success: strong commitment from the technical director and the Independent Internal Nuclear Safety Oversight Network, a clear arbitration process with the corporate bodies regarding issues with implications that extend


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beyond the plant and, in particular, ASN commitments. Meanwhile, the corporate engineering bodies need to provide their support and oversight. In the same way, the Independent Internal Nuclear Safety Oversight Network needs to perform its mission at management level.Certain policy issues remain to be determined by EDF, e.g. when processing cases with the ASN related to the content of the 10-yearly inspections, starting with the first of the 900 MWe nuclear units for the fourth 10-yearly inspections in 2019.Three key factors of success appear to have been brought together.• The deployment of a sound multi-year project in

each plant for 2016 (clear view of the next 10 years), benefiting from the multi-year asset-protection plan and comprising corporate operations (maintenance and improvements). I note differences between the plants, some of which do not yet have a project team or sufficient skills. I also note with satisfaction the plans of the Nuclear Generation Division’s management for 2015 which allows for this issue.

• Leading change relating to project risk management (in the plants and for the General Refurbishment programme) and keeping a close watch over nuclear safety at all levels (plants, engineering centres, directorates, committees, joint technical body, operational committee and General Refurbishment directorate), along with representatives from the Independent Internal Nuclear Safety Oversight Network, the Nuclear Generation Division and the Nuclear Engineering Division.

• Close relations with service providers so issues are mutually understood with respect to the activities to be carried out (improvements or maintenance operations) and the organisational system set in place by EDF SAlocally (plants and engineering centres) and at corporate level. Information was exchanged in 2012 and meetings have been held since then. I often hear contractor staff expressing the hope for up-to-date medium-term horizons so it is clear what has to be done and so to plan ahead properly. Some have taken early action and began recruitment and training, and even entered into partnerships.

The supervision system for the General Refurbishment programme was implemented in 2014 and will continue its build-up until 2016. The system will be rapidly assessed to ensure optimum interfacing between projects and programmes. The task is a difficult one and I am going to see that attention focuses on the responsibility of the corporate engineering teams, while providing cross-organisational leadership of this programme which is key to achieving an overall optimal situation.

The 2015-2020 period will be marked by a heavy workload not only for the internal and external engineering forces working on the preparations (licensing, finding solutions, etc.), but also for the ASN and its technical advisers (the Institute for Radiological Protection and Nuclear Safety and standing committees). I fully understand the challenge faced by the Nuclear Engineering Division teams - representing the architect-engineer - and I will be making a point of checking that the workers in the field are calm and composed in 2015. I also note the heavy design workload for certain departments within AREVA, being for instance 60% greater in 2015 than in 2011, which clearly reveals the need to plan ahead for the rising demands in skilled staff.

Territorial organisation of the Nuclear Rapid Reaction Force

THE THIRD 10-YEARLY INSPECTIONS OF THE 1300 MW SERIES: THE FIRST STEP TOWARDS OPERATING BEYOND 40 YEARS

The objectives

The safety reassessments for the third 10-yearly inspections of the 1300 MWe series that ended in 2014, formed part of the continuous improvement process and a first step in preparing for operation beyond 40 years. In practical terms, the third 10-yearly inspections of the twenty 1,300 MWe reactors each required 100 days of outage (excluding steam generator replacement) and more than 60 improvement cases for nuclear safety. This represents twice as much work as that generated during the second 10-yearly inspections of the 1300 MWe series.Here I observed certain nuclear safety objectives.• Reducing the radiological consequences of design-

basis accidents associated with steam generator tube rupture111 by reducing the risk of water discharge or

111 Known as RTGV in France (Rupture de Tube de Générateur de Vapeur)


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a theoretical LOCA112 by improving the containment. These modifications are intended to avoid having to introduce measures for public protection (sheltering, iodine tablets and evacuation), thus representing a substantial improvement over the original design.

• Reducing the radiological consequences of accidents involving core meltdown and the risks of early, widespread discharges.

• Reinforcing the safety of interim fuel storage (risk of rapid draining or loss of cooling) by physical means to make it possible to consider the risk of fuel assembly dry-out as residual.

• Continuing reinforcement against external events and carrying out post-Fukushima actions.

The third 10-yearly inspection of the 1300 MWe series includes modernising the digital instrumentation and control systems related to nuclear safety, after 30 years in use. This refurbishment of the reactor protection systems involves replacing dozens of electrical cabinets and upgrading the control room. I can see the progress made with collaborative work between the designer and the operator, with dedicated working groups, joint socio-organisational and human analysis and a full-scale mock-up.I am also aware of the work carried out by the team combining EDF SA, AREVA and Rolls-Royce on designing hardware and software, carrying out workshop and platform tests, and subsequently performing tests on site. I hail the creation of a full-scale digital control simulator in only 14 months, faithfully replicating the control room with the third 10-yearly inspection standard rule set. This enables operator training to prepare for new procedures and equipment. It is remarkably representative with its 220 tactile feedback digital screens. It was designed by the Power Plants Operations Engineering Centre ’s engineering staff together with the Operations Engineering Training Department, with work oversight handled by the Paluel Nuclear Power Plant joint team.

Paluel 2, the first of the 1300 MW series to undergo a third 10-yearly inspection

The Power Plants Operations Engineering Centre, the Electromechanical Department and Paluel Nuclear Power Plant - whose joint work has been exemplary - have drawn up a protocol between their managements to prepare and plan ahead for work on Paluel 2, the first of the series, in April 2015. The first steam generator replacement operation on a 1300 MWe unit is also to take place during this 10-yearly inspection. On meeting the plant 112 Loss-Of-Coolant Accident

and Power Plants Operations Engineering Centre staff, I saw the everyday reality of their work, with everyone involved being focused on joint success. I encourage them to continue in this way for the third 10-yearly inspection in 2016 (Cattenom Nuclear Power Plant) and for all the other 10-yearly inspections afterwards. I note the excellent planning of the Nuclear Engineering Division with 100% of the modification documents being available four months before the start of the unit outage.Concerning the ASN’s processing of applications for licensing, the standing group of experts started its examination process rather late. This process was finalised in October 2014 for a first-in-series reactor programmed to start operating again in 2015, and requests were still being received right up to the end of 2014. Such tardiness could affect operation or require modification work to be speeded up or deferred.

SECOND 10-YEARLY INSPECTION OF THE N4 SERIES FROM 2019

The staff members at the N4 plant that I visited were keen for the headquarters’ Electromechanical Department and the Power Plants Operations Engineering Centre’s engineering centres to be more willing to listen and to provide more active support. The Nuclear Engineering Division and the Nuclear Generation Division need to be particularly attentive to how the operational needs are expressed for the second 10-yearly inspection beginning in 2018. This is because, after a first 10-yearly inspection of limited scope, questions remain as to the design and the difficulties of the associated maintenance work, prejudicial to the serenity of operations. More generally, I would like to draw the attention of the engineering centres to the support needed for the CP0 series (Fessenheim and Bugey) and the N4 series (Chooz and Civaux) which, although they may have a small number of nuclear units, represent nuclear safety and operations issues, of which are some are specific to them.

FOURTH 10-YEARLY INSPECTION FOR THE 900 MW SERIES: BIG STEPS TOWARDS 60 YEARS

The process associated with the strategic planning of the fourth 10-yearly inspections for the 900 MWe series, in which the ASN is involved, is on a very tight schedule for Tricastin 1 (first-in-series) in 2019. The nuclear safety objectives and the options proposed by EDF need to be the subject of a ruling by the ASN in the first half of 2015. I would like to draw attention to the need for securing this project. At this stage, this should be done without excluding deployment in batches if this is required to


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ensure the quality of the work. I am satisfied to see the creation of a process and a monitoring group associating EDF and the ASN, as was done for the licensing of the Flamanville 3 EPR.The main approaches considered at this stage for the nuclear safety reassessment appear to correspond to continuous improvement: reduction of design-basis accident discharges, prevention and mitigation of severe accidents (utilisation of the Fukushima hardened safety core), better allowance for external events, and reinforcement of the fuel building.Some of the nuclear safety case studies are particularly vital in the context of this reappraisal as they must be resolved, in essence, by the fourth 10-yearly inspection of the 900 MWe series.• Proof that non-replaceable equipment is serviceable:

reactor vessels and containment buildings. From the outset, much has been invested by EDF SAto determine and monitor the effects of ageing of materials,

structures and active components both in situ and in laboratory conditions, which is extremely helpful for identifying the priorities and the action need.

• Proof of equipment qualification for accident conditions beyond 40 years, beginning with the original equipment originally intended for a 40-year service life and which are not to be replaced. I note the process adopted, based on the progressive qualification of the materials: measuring ambient conditions, taking material samples from mechanical and electrical equipment in situ, and tests on sampled and new materials. I saw how stringent the requirements are for obtaining i) high-quality technical case files, ii) replacement equipment if necessary, iii) updates of the Qualified Equipment Rules, with a very tight schedule that must be met.

• The elimination of safety-significant discrepancies. This appears to have been done promptly, without awaiting the next 10-yearly inspection.

Post-Fukushima measures deployed in the EDF plants in France

In 2012• Satellite phones installed in every control room• Last-resort make-up water capability demanded

by the ASN for the third 10-yearly inspection at Fessenheim Nuclear Power Plant

• New emergency rule set for managing a number of reactors in the event of a severe accident in the same plant

In 2012 and 2013• Earthquake drill training for the reactor control

teams and earthquake event mentors• Reinforcement of emergency centre resources

In 2013 and 2014• Emergency power supply for the reactor coolant

system release valves in the event of a blackout• Installation of a standby generating set for each

reactor, pending the availability of a last-resort diesel generator and mobile back-up equipment

• Provision of connection points for back-up water and compressed air supplies

• Operational Nuclear Rapid Reaction Forces in all the plants, except one, at the end of 2014.

Post-Fukushima measures

By June 2011, EDF SAhad integrated all the post-Fukushima feedback. I note the changes already operational in the plants corresponding to the first phase and compliance at the end of 2014 with the ASN requirements. This was at the cost of a remarkable effort by the Nuclear Engineering Division and Nuclear Generation Division staff. I would like to particularly emphasise the operational status of FARN113, which will eventually consist of 300 EDF nuclear professionals capable of taking action within 12 hours of being mobilised in a four-reactor plant configuration at the end of 2014 (six-reactor configuration at the end of 2015).

113 Nuclear Rapid Reaction Force

I can the efforts made by the staff to plan and integrate the basic measures of the hardened safety core for the second phase of the post-Fukushima programme between 2015 and 2020 (2025 for the plant emergency centres), allowing for the particularities of each plant. The time limits for implementing the requirements are extremely constraining if the quality work is to be provided in serene conditions, in view of the arrangements already made in the plants and concerning the Nuclear Rapid Reaction Force. These improvements consist of design and organisational measures to increase plant resilience in the face of extreme external events that are considerably more severe than those taken into consideration in the design.• Installation of a last-resort diesel generating set rated at

3 MWe in every nuclear unit in a dedicated bunker-style building, connected for the end of 2018. In view of the


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short time available and the amount of work in hand, we must focus on the priority to give to risk analysis of the conditions of taking action with the unit in service for this job, and connection during a unit outage.

• The installation of a last-resort feedwater supply for steam generators, the reactor coolant water tank and the fuel pool, with a new heat-sink and mobile emergency equipment.

• Construction of a plant emergency centre in every plant for managing emergencies, the first of which is to be commissioned at Flamanville for the start-up of the EPR.

Local Emergency Operations Centre

Upgraded site-

boundary protective measures

Electrical supply to one ASG [EFWS] pump

Ultimate Diesel Generator

Ultimate water make-up system

Schematic diagram of the Phase 2 post-Fukushima hardened

safety core

The third phase will complete the measures with the deployment of all the hardened safety core means from 2019.

FITNESS FOR SERVICE OF COMPONENTS: A PRIOR CONDITION

Proof that non-replaceable components, the reactor vessel and the containment building are fit for service is a prior condition for pushing operations beyond 40 years.

A favourable prognosis for reactor vessels

I was shown the work carried out by the Basic Design Department, the Construction and Operation Expert Appraisal and Inspection Centre, the Operations Engineering Unit, EDF’s R&D Division and the Nuclear Fuel Division on reactor vessels in liaison with AREVA, the French Atomic Energy Commission (CEA), a few specialised laboratories and even international experts.These French-made reactor vessels have metallurgical and mechanical properties that resist embrittlement by neutron bombardment better than some foreign-made vessels of similar age. The mechanism of deterioration was taken into account in the original design. Each vessel is the subject of a radiation monitoring programme that checks that the actual embrittlement of the reactor vessel is less than forecast. This excellent

monitoring programme is handled by the CEIDRE laboratory at Chinon, with the support of the French Atomic Energy Commission for measuring the neutron dose. A few reactor vessels have manufacturing defects, all located below their linings; they are the subject of ad hoc in-service monitoring using a qualified NDT114 method to check that these defects are not evolving in service.

Neutronics: Fuel management Fluence absorbed by the vessel

Materials Embrittlement due to irradiation

Knowledge of manufacturing process

Defecttime

Fluid temperaturein the vessel

Transient

BRITTLE DUCTILEToughness

Initialtransition temperature

ToughnessNeutron flux

Vessel wall

Fluence(irradiation)

T(x, t) and (x, T)

Stress intensity factor K computation at crack tips

Toughness K computation atcrack tip

1C

K / K orP(K / K > 1)

1 1C

Finite Element software for thermomechanicalanalysis

Dét. / Prob.software

Cladding

Temperature of the vessel steel

1

1 1C

Thermohydraulics Pressure & temperature loads

Mechanical loads

Material resistance

Different loads on a pressurised water reactor vessel

I emphasise the importance of the experience collected by EDF SAbetween 1967 and 1991 during the operation of the Chooz A 305 MWe PWR. Such experience was integrated into the design of reactor vessels now in service. I observe the comprehensive validation of the processes and methods of the irradiation monitoring programme, and the ability to ascertain the RTNDT115 for the vessel by means of expert appraisals and tests on vessel material samples.Experience feedback on the detection of signs found in 2014 in two Belgian reactor vessels (Doel 3 and Tihange 2) has been given due consideration. I note that, at this stage, there is no impact on the service-life prognosis of EDF reactor vessels, as a result of the special precautions taken in the fabrication of the EDF SAreactor vessels and the non-destructive testing carried out during service. I nevertheless call for continuing analysis of the experience feedback in the light of recent expert appraisals by Electrabel116.I note the coherence of the generic-case full assessment of the brittle fracture margins with consideration of i) the materials, ii) neutron bombardment, iii) thermal hydraulics, iv) operation, v) mechanics and vi) probabilistic approach data. The conventional deterministic safety case for the margins used in France is a demanding one, calling for conservative measures at every stage and allowance for regulatory margins with regard to transient loads.

114 Non-destructive testing115 Reference Temperature for Nil Ductility Transposition -

characterising the toughness of the reactor vessel material, which increases under irradiation. This constitutes a vital reactor vessel nuclear safety indicator

116 Belgian electricity company


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I am confident about the results of this study. There will be the positive effect of the decision to reduce the radiation flux to reduce embrittlement of the 900 MWe reactor vessels starting from the fourth 10-yearly inspection by placing hafnium control rods at the extremities of the core. Other arrangements are possible, such as preheating the safety injection water to reduce cold shock in the reactor vessel. The case study justifying the use of 900 MWe reactor vessels for up to 50 years will be submitted to the ASN in the first half of 2015, with a ruling expected in 2016. Whatever the case, I note that all the 900 MWe reactor vessels meet the current nuclear safety criteria of the Nuclear Regulatory Commission for a service life of 60 years.

Some containment buildings require special attention

Work on the containment buildings was shown me by the Power Plants Operations Engineering Centre (CIPN), the Basic Design Department (SEPTEN), the Construction and Operation Expert Appraisal and Inspection Centre CEIDRE (Geological, Geotechnical & Civil Engineering Technical Tests Department), the EDF’s R&D Division and the DTG117 in charge of the trials. I would like to spotlight the major programme of studies and lab tests using scale models on the mechanisms of concrete ageing (shrink and creep) and the technical means for restoring the leaktightness of certain containment buildings. This programme is up to standard in terms of the nuclear safety issues. I also note the level of quality in preparing and executing the containment trials.At the end of 2014, I observed that single-wall containments had no difficulty in meeting the leakage requirements when provided with a metal liner (one containment has been the subject of a special study). I find a more varied situation for double-wall containments that depend on the leaktightness of the inner wall and the collection and filtering of leaks in the gap between the containment walls. As concerns the regulations, the reactor construction licence criterion - included in the General Operating Rules - states that the inner containment wall must assume the leaktightness required for both walls, as well as the leak collection and filtering system. At the end of 2014, all these containments met this criterion, although some with only a small margin.The measures consisting in applying composite linings qualified for 60 years on the inner side of certain containments has already been implemented. I encourage the development of supplementary technical 117 General Technical Division (DPIH)

solutions for the outer side of the containment wall for possible implementation during the third 10-yearly inspections of some 1300 MWe nuclear units. I would like to draw attention to the industrial safety conditions and the quality of the operations, with a view to contingent implementation. Concerning this point, I have taken good note of the usefulness of the MAEVA118 mock-up.The construction of the VERCORS mock-up at the Renardières site is due to be finished in 2015. This is a third-scale model of a double-wall containment vessel, bearing witness of EDF SA’s efforts to establish the safety case, particularly as regards ageing, leak rates over time and corresponding forecasting, as well as robustness in a severe accident.

Construction of the VERCORS mock-up at the EDF R&D centre

at Renardières

A well-organised R&D programme for aging

During my visits to the engineering centres under EDF’s R&D Division and under the General Technical Division, I was able to see the adequacy of the support programme for plant live extension. These engineering centres determine the topics and goals of R&D work to provide nuclear safety proofs. The skills and resources for simulation and experimentation are being implemented in a complementary manner. EDF SAalso benefits from much R&D work, especially that conducted by EPRI119 and that carried out in France conjointly by EDF, AREVA and the French Atomic Energy Commission.I visited the Materials Ageing Institute (MAI) at the Renardières R&D site. This facility was created in 2008 and brings together 11 operators and industry players. It is internationally recognised for the quality of its studies

118 A third-scale model of a reactor building created in 1995 and reused in 2014

119 Electric Power Research Institute in the US


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on material ageing. I was shown a number of test loops intended to provide benchmarks for the behaviour of materials, for instance: • Secondary-side test loops for overall management of

chemistry• Loop for studying the fatigue behaviour of austenitic

steels in the reactor coolant environment• ENERGIEI loop of the MAI life extension facility, which is

under construction.This last installation, which is unique in the world, comprises three test mock-ups. Designed to replicate the physical, chemical and thermal-hydraulic conditions in the primary and secondary sides of the steam generators, it will provide a clear understanding of their fouling and enable us to assess discharges and waste arising in the different chemical environments.

I emphasise the value of the SHERLOCK project conducted by the Construction and Operation Expert Appraisal and Inspection Centre together with other engineering centres from the Nuclear Engineering Division and the Nuclear Generation Division, as well as EDF’s R&D Division, to carry out an expert appraisal between 2014 and 2021 on two removed steam generators (one from Paluel 2 and one from Cruas 4) to improve understanding of non-destructive testing, steam generator internals and material degradation mechanisms.The leaktightness of containment buildings is another key nuclear safety issue. I call for continuing to actively improve our understanding of the degradation mechanisms liable to affect the leaktightness of certain double-wall containment buildings and to develop industrial-scale arrangements for repairing them, making use of the best available skills.

MY RECOMMENDATIONS

Success with the General Refurbishment requires firm governance of the programme without compromising nuclear safety, better project management and the definition of a high-quality multi-year programme by the plants. I recommend that the directors of the Nuclear Engineering Division and of the Nuclear Generation Division make sure that their Independent Internal Nuclear Safety Oversight Networks are present in the teams in charge of operational and strategic control of the programme.I support the request made by the senior management of the Nuclear Generation Division that the plants are up to standard as with their multi-year scheduling in 2016. I recommend that the plant directors and the director of the Nuclear Generation Division mobilise their respective independent internal nuclear safety oversight networks to challenge the maturity of the multi-year programme for each nuclear unit (organisation, dedicated skills for projects and professions, integration of plant and corporate activities in the elimination of discrepancies).I also call on the director of the Nuclear Engineering Division to support its Independent Internal Nuclear Safety Oversight Network to challenge, as regards nuclear safety, changes in project organisation and management.Forming partnerships with contractors is another factor that will determine the success of the General Refurbishment. I call on the EDF SAbodies involved to organise appropriate exchanges with contractors to achieve a shared up-to-date view of the programme’s operations and related issues.Reinforcing the arrangements to ensure the safe operation of spent fuel interim storage pools in the plants and seeking solutions to manage the interim storage of spent fuel over time appears to be a vital nuclear safety issue. I call on the Nuclear Technology Division to pay the greatest attention to the improvement cases to be processed, using appropriate engineering resources.The leaktightness of containment buildings is another key nuclear safety issue. I call for continuing to actively improve our understanding of the degradation mechanisms liable to affect the leaktightness of certain double-wall containment buildings and to develop industrial-scale arrangements for repairing them, making use of the best available skills.


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10 / SERVICE LIFE CHALLENGES IN THE UK

Reactor hall at Hinkley Point B Nuclear Power Plant

Unlike the pressurised water reactors (PWR) in Sizewell B and in the French nuclear power plants, the advanced gas-cooled reactors (AGR) in the UK do not benefit from extensive worldwide international experience feedback. Furthermore, the AGRs differ significantly from each other, necessitating specific nuclear safety analysis.

AGR graphite and steam generator ageing phenomena are the subject of special attention within the EDF Group as part of work to better plan for and maintain substantial nuclear safety margins in service with a view to plant life extension.

The improvements determined by EDF Energy after the Fukushima accident have been integrated in all the AGRs, with only a small number left to be completed at Sizewell B.

CHARACTERISTICS OF THE PLANTS IN SERVICE IN THE UK

EDF Energy has 14 AGRs120 commissioned between 1976 and 1988 which are located at seven different plants, plus one PWR at the Sizewell plant. The dates of commissioning and closure are listed in a table in Appendix 13.These AGRs are characterised by design differences between them. Six of the AGRs may soon be due for plant life extension beyond the current licenced limit: 2018 for Dungeness B (two reactors), 2019 for Heysham 1 (two reactors), and 2019 for Hartlepool (two reactors). The nuclear safety case for plant life extension of Dungeness 120 Advanced Gas-cooled Reactor

B was submitted to the ONR121 in 2014. An answer is expected in early 2015.AGRs have a pre-stressed concrete pressure vessel that contains a core which is made up of graphite bricks serving as the moderator. Under the effect of neutron bombardment and oxidation, this non-replaceable graphite becomes thinner and starts to crack. These observed phenomena could prevent the control rods from dropping to automatically shut down the reactor and they may impede the circulation of the gas that cools the core, particularly in the event of a major earthquake. The steam generators are made according to a complex metallurgical process. They represent a potential weakness since they 121 Office of Nuclear Regulation

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are required to operate at high temperatures around 600°C, tending to cause structural damage by creep. By design, inspectability of many of the components is limited. Another characteristic of AGRs is that they have high thermal inertia, which is favourable to nuclear safety.I observe that AGR nuclear safety in operation and service life are maintained by a major R&D programme on which the safety case is partly based. This programme relies on maintaining and managing in-house skills, with individuals who are both experienced and specialised in this particular technology. I was able to verify this point at Barnwood122 and at the plants, not to mention with the network of skills outside the company in engineering companies and universities. In the absence of reactors sharing a similar design, I note that information is regularly exchanged between EDF Energy and Rosenergoatom123 concerning their respective experiences with graphite.

AGR EXPERIENCE FEEDBACK SHOWS THE EVER-PRESENT NEED TO PLAN AHEAD

The year 2014 was marked by two major events which affected the steam generators and the graphite.

The steam generators

Extensive cracking in a boiler spine supporting the tube bundles in one of the eight steam generators, placed symmetrically in four quadrants, in Reactor 1 at Heysham 1 was discovered in August 2014. The reactor was accordingly shut down. It is worth pointing out that nothing was noticed during a regular check in 2010, but that an identical check showed some evidence of a fault in the autumn of 2013. While additional investigations were being planned, the reactor was restarted at 75% rated power with the faulty quadrant having been isolated after the other steam generators were found to be unaffected. In 2014, further investigations revealed a crack. I commend the conservative decision in terms of nuclear safety to immediately shut down the three other reactors equipped with steam generators of the same design (Reactor 2 at Heysham 1 and the two reactors at Hartlepool) as soon as the safety case could not be guaranteed, pending understanding of the event and its implications (root causes, common modes, etc.).I would like to emphasise the quality and the comprehensiveness of the work carried out in 2014 to deal with this event, which combined the analysis and expertise

122 Headquarters of EDF Energy senior management and the power plant engineering centre

123 Russian nuclear power company

capabilities of the EDF Group (the different professions, the International Nuclear Academy, EDF Energy’s Nuclear Safety Committee, the Nuclear Engineering Division and EDF’s R&D Division), as well as the expertise of outside companies, comprising inspections of the boiler spines in every reactor. This work involved seeking the root causes,

solutions to limit loading of the structures, arrangements to mitigate damage and repair the spine, while taking a conservative approach within the bounds of the safety case. The development of NDE124 methods and their utilisation to find defects using ultrasounds, radiography, eddy current and video methods made it possible to identify and characterise the defects in the boiler spine of the Reactor 1 steam generator at Heysham 1, in particular a long crack located near a weld. I would like to emphasise that it was necessary to take a sample to fully characterise the crack and its history by expert metallurgical appraisal. A unique feature of the fabrication of this part (weld buttering) would appear to explain the initiation of a crack in the heat-affected zone resulting from this buttering and the propagation of the crack by creep.Checks on the other 31 boiler spines in the four reactors did not reveal any significant defects. This needs to be substantiated by examination of the fabrication documentation.

The boiler spine of a Heysham 1-type steam generator

As of the event shows, inspection constitutes an important part of defence in depth, alongside theoretical work and experiments in laboratories and on mock-ups. This is borne out by detection of defects in the reactor vessels of Doel 3 and Tihange 2 in Belgium in areas where non-destructive testing is not usually 124 Non-destructive examination


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conducted. This being the case, we must bear in mind the importance of non-destructive testing of components that are important to nuclear safety and the formal independent qualification of their performance. In particular, we must be able to compare the smallest defects detectable to the critical defect size for accident conditions, considering the possible deterioration of the defect during operations and the associated uncertainty. I will be examining the qualification case files and the plans for checking equipment and structures important for nuclear safety in the AGRs during my forthcoming visits.I have taken good note of the acceptability and the ALARP125 character of the analyses made to establish the safety case for the three reactors - Reactor 2 at Heysham 1 and the two reactors at Hartlepool - which enabled them to be restarted in November 2014. In particular, operation at reduced temperature seems sensible in view of the risk of propagation by creep of any undetected defects. The associated consequences of boiler spine failure on nuclear safety show how important it is to have reliable lines of defence in protection and mitigation. I note in-service monitoring has been stepped up, including the installation of special instrumentation and appropriate inspection.In January 2015, the Office of Nuclear Regulation authorised Reactor 1 to be restarted at Heysham 1 based on the nuclear safety case drawn up by EDF Energy.

The graphite and the core

Cracks in the graphite of keyed bricks were found for the first time in an AGR in October 2014. These cracks were found in two bricks playing a structural role in the core of Reactor 4 at Hunterston B.Due to the mechanical properties of these bricks, such cracking had already been predicted by established behaviour models. The safety case for operating the reactor until the next scheduled outage in 2017, took this situation into account.Cracking in the bores of graphite bricks has already been observed in several reactors, whereas in others it is virtually absent. More generally, the experience feedback since having restarted the installations indicates degradation in i) the graphite core (weight loss, cracking and geometry), ii) the internals of certain reactors, iii) the steam generator tube bundles (creep and corrosion) and iv) the leaktightness and integrity of boiler closure unit (Heysham 1 and Hartlepool). As emphasised by my predecessor in 2012, EDF Energy has sought to limit temperature of the reactor hot box dome in view of this

125 As Low As Reasonably Practicable

creep risk by modifying the gas flows in the control rod channels so this gas can cool the insulation.In the light of the experience feedback, I consider that forward planning needs to be reinforced, particularly through inspections, sample taking and more proactive expert appraisals, as well as by tracking initial fabrication defects in structures that are important to nuclear safety.

Bristol University mock-up of a graphite core on a seismic

table

MANAGING THE SAFETY ISSUES ASSOCIATED WITH AGR CORES AND STEAM GENERATORS

The safety case for AGR operation with due regard for nuclear safety is based on extensive research and studies. I observed that the key service life factors relate to behaviours associated with the centre of the core126 and the steam generators. This centre of the core must maintain its integrity and its geometry during an earthquake so the control rods can be inserted and the gas can flow in the fuel to maintain cooling. The presence of defects may reduce the margins and necessitate repair.The current safety case allows 10% cracking of the keyed bricks in the core, with proof that there is no cliff edge effect up to 30%. I note the goal of increasing these limits and emphasise the need for prudence in the presence of such a discrepancy relative to a new core. Tests are planned on a quarter-scale model of a graphite core at Bristol University on a shaking table. I emphasise the need for the model to be representative and of adequate quality in terms of preparing the tests of which the results will feed the safety case (overall and local behaviours). Combining calculations and experience would appear to be appropriate for a matter this complex. This scale model offers an opportunity for finding the boundary conditions of a degraded core with regard to earthquake loading.Steam generator tube failure has consequences for reactivity (associated with water ingress into the core) and

126 The active part of the core being surrounded by a graphite shield


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radiation doses (associated with opening the pressure vessel relief valves). This represents a major part of the operating risk for certain reactors. The margins depend on the particularities of the core, the steam generators and the available protection trains. I can see the fundamental importance of accurately knowing the actual condition of the tube bundles and there supports.I am well aware of the compensatory measures that have been taken to preserve the safety margins in certain AGRs, particularly:• super-articulated control rods able to engage with

core bricks that are not perfectly aligned, and the supplementary nitrogen gas system which is earthquake-qualified, as well as the secondary means of shutting down the nuclear reactor and/or providing cooling

• a system for protection against overpressure in the pressure vessels

• water ingress alarms and means of automatically stopping or restricting the steam generator water feed

• a tertiary shutdown system by injecting boron beads or flooding the core when the core is cold, which can be used as a last resort to close down the reactor permanently with it never being possible use it again

To keep an overall view of the AGR steam generator situation and have the information necessary for predicting future performance, EDF Energy has formed a project team for inspecting and monitoring the steam generators. The programme is called BLIMP127. This programme features detailed analysis of the stream generators: additional instrumentation, monitoring of operation covering chemistry, and prediction of future damage, e.g. creep degradation.I recommend that, in the safety case, the margins for nuclear safety in operation be expressed with allowance for combinations of discrepancies known in the equipment or structures (graphite core, steam generator and internals in particular).

SERVICE LIFE OF THE SIZEWELL B REACTOR

It is planned to withdraw the Sizewell B PWR from service in 2035 as its design lifetime being 40 years. EDF Energy is working on a safety case to extend its operation to 60 years. The reactor is robustly engineered, with four nuclear safety equipment trains, multiple cooling systems for essential functions and a double-wall containment with an internal steel liner.Based on operating experience feedback from this reactor and other PWRs throughout the world and in the light of the 10-yearly safety reassessment, I am confident that 127 Boiler Lifetime Inspection and Monitoring Programme

the outcome will be favourable, with the approval of the ONR.I note that a dry spent fuel interim storage facility is under construction at the site and is due to be commissioned in 2015. Other measures will need to be taken to guarantee reactor nuclear safety during operation while the work is in progress. Before any spent fuel is handled, all the procedures and arrangements for interim storage will need to be validated.

MOST OF THE POST-FUKUSHIMA MEASURES ARE IN PLACE

At the end of 2014, EDF Energy made all the post-Fukushima modifications required for its reactors, except for one relating to Sizewell B.Connection points for emergency equipment have been installed in the installations. Protection against flooding has been upgraded in certain AGR sites, notably Dungeness B. At Sizewell B, auto-catalytic recombiners have been installed in the reactor building and a new emergency management centre has been built. Mobile equipment has been readied at strategic points in the UK at the disposal of the plants. To demonstrate mobilisation capability, exercises were carried out in three plants in 2014, combining plant staff and outside emergency services. Post-Fukushima training of plant personnel is included in the normal syllabus.Studies are continuing on the possible installation of a filtered discharge system for accident situations in the Sizewell B containment building. I call upon EDF Energy to provide proof consistent with that of EDF SAto meet the goal that “no severe accident must result in the contamination of large areas in the long term”, with due allowance for the particularities of this reactor design. It differs from EDF SAreactors in that it has four trains of nuclear safety electrical equipment, two diesel generators for recharging the batteries and a last-resort water/air heat exchanger capable of cooling the engineered safety equipment (safety injection and containment). The reactor was designed for 0.25 g earthquake resistance, higher than the reference earthquake for the location (0.14 g) with a return time of 10,000 years.


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The new emergency nitrogen injection system at Hinkley Point B Nuclear Power Plant

MY RECOMMENDATIONS

From the beginning, a number of nuclear safety significant events have occurred in the AGRs, such as that at Heysham 1 in 2014.I recommend special vigilance by the EDF Group over the decision-making process for the service lives of these reactors, particularly as regards reinforcing the provisions that guarantee the margins of nuclear safety.These reactors require special engineering skills and cooperation needs to be intensified between the engineering and R&D sources of the EDF Group to maintain their nuclear safety. I note the observed effects of ageing on components that are both important to nuclear safety and non-replaceable. It is clear that studies and R&D will not make it possible to fully determine the state of these components or to unequivocally predict their behaviour. Although I have taken good note of the high responsiveness of the staff to events in operations, I recommend a defence-in-depth measure wherein EDF Energy takes a more proactive approach to its forward planning and monitoring efforts.I hail the efforts to develop non-destructive testing methods. Forasmuch, I recommend an ambitious plan of inspection and expert appraisal be drawn up for equipment important for safety — with top priority for steam generators, the core, reactor internals and pressure vessels — by substantially upgrading the checking process, increasing its frequency, taking more in situ samples and formally qualifying the non-destructive testing procedures.I would like to draw attention to the importance of setting up, without delay, the improvements decided upon, by strong management of the corresponding projects.


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11 / PREPARING THE FUTURE: FROM THE EPR TO OTHER NEW MODELS

The Flamanville site

Submission of the application for commissioning to the French nuclear safety authority marks a significant step forward in the Flamanville 3 EPR project, a third generation design.

Flamanville 3 and Taishan 1 and 2 in China will benefit from each other’s feedback during the start-up period, which is important for nuclear safety.

Studies on new reactor designs are preserving the skill levels of EDF SAas an architect-engineer, particularly in the perspective of the Hinkley Point C project and the preparations for renovating the existing plants.

FLAMANVILLE 3: NUCLEAR SAFETY DEMONSTRATED BY ACCIDENT STUDIES

The commissioning licence application for Flamanville 3 was submitted to the ASN in due time and in accordance with the mutually agreed goals and conditions. In-depth accident studies have confirmed the reactor’s high level of nuclear safety.I also note the extensive work carried out to provide proof the equipment’s qualification for which the manufacturers are responsible, with support from EDF SAacting as the client. Additional information will be provided during the start-up phase. I will be making sure in particular that the new equipment qualification tests are completed

properly, particularly as regards the core instrumentation during the physics tests.

Manufacturing quality issues and operator monitoring

There have been difficulties with manufacturing (reactor vessel head and internals) and applying the new nuclear pressure equipment regulations with respect to erecting the reactor coolant system and the auxiliary nuclear systems. These difficulties have made it necessary to adjust the Flamanville 3 schedule. After two decades with no new-build work in France, these difficulties confirm

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the need to reconstitute the industrial know-how in view of staff renewal and regulatory changes.This being the case, I call upon the manufacturers and service providers to focus more closely on their skills and the intrinsic quality of their fabrication and erection work.For the nuclear operator, I emphasise the importance of the technical specifications and for monitoring the quality of fabrication and erection, with due regard for the regulations for Licensed Nuclear Facilities. It is also important to make sure that the widest possible range of technical rule sets available is used. I note, as regards cleanliness and welding, the relevance in terms of nuclear safety of getting the ASN to accept and officially recognise the French RCC-M rules for the design and construction of nuclear equipment. These rules reflect the best industrial practices and requirements derived from French and international experience feedback.

Reactor coolant system welding operations at the

Flamanville 3 EPR worksite

Worksite cleanliness meeting the highest international standards

The erection schedule provides a timeline for six months. Drawn up with the main contractors, this schedule ensures more effective coordination between the different trades.I also note the early commitment to a separation between that zones where the predominant activity is civil engineering and painting work and the zones of electronic and electrical equipment installation, with different coordination responsibilities in the geographical zones. This is extremely positive for the quality of installation work and maintaining the equipment in a

state of cleanliness that corresponds to the nuclear safety requirements.I have also seen the priority given on the worksite to industrial safety, with due allowance for the increasing risks corresponding to the development of parallel activities, and to the planning for the coexistence of zones of erection and testing. I noted the involvement of the worksite and power plant management and the contractor management (wearing of personal protection equipment, observance of industrial safety standards, relating to lifting for instance, the level of worksite orderliness etc.). Although the accident rate may be higher than in the reactors in service, it is improving in accordance with the goals (10 in 2013, 7 in 2014).I call on all players to observe the highest industrial safety requirements. It is extremely important to begin operation meeting the highest levels of international standards by achieving a zero-accident situation.

Managing the operator handover configuration with care

Handover to the operator

The system is divided up into 229 main systems, which are successively handed over from the site management organisation to the operator.

• The tagging takeover report: takeover for tagging by the operator, making it possible to physically separate the erection zones (height welding and cable drawing) from the testing zones with live systems (filling with water, energisation and pressurisation), preceded by an inspection when a checklist is used to verify compliance of the direction work. In the zone under testing, one functional loop of a main system can be tested, e.g. checking the output of a pump through a heat exchanger and the pipes that connect them to the valves, the electrical power supply and the associated instrumentation and control.

• The provisional operation report: this enables the operator to carry out monitoring and conduct normal operation control actions on the system with its own procedures. The system may still be part of an overall test zone for supplementary tests.

• The minor maintenance handover report: this enables the operator to carry out routine servicing with its own maintenance procedures


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The current phase of the worksite is very important for future operation as it enables conjoint:• checking, as erection work proceeds, that the expected

levels of quality and cleanliness have been achieved,• progressively carrying out the tests, on main systems

individually then together, to ensure that the functional nuclear safety criteria established at the design stage are met,

• progressively handing over the installation and its configurations to the operator, via the gradual transfer of the 229 elementary systems of the installation.

This period is marked by the late introduction of a large number of modifications as detailed in the commissioning licence application. These modifications are integrated in sets that are coherent in terms of functionality with the main overall test phases. Temporary equipment is also installed for the test phase, e.g. filters for flushing.Rigorous management of the configuration by the operator implies:• identifying the modifications incorporated, or partially

incorporated, and the associated design rule set,• the availability of operations and maintenance

documentation that is consistent with the as-built status (mechanical equipment, electrical equipment and software),

• updating the list of tagging points in a manner consistent with the confirmed tests,

• managing the equipment temporarily installed for testing.I note the joint role of the Nuclear Design and Construction Centre and the Basic Design Department in establishing and managing the configuration at design level, as well as the particular care taken to manage the configuration during the successive phases: • at the level of the Nuclear Engineering Division, between

the engineering centre design and worksite erection work, then between election work and testing,

• then between the teams in charge of testing and the operator.

Involvement of the operator during the final check-list inspections at the end of the erection work, particularly the organisation of joint checking between the erection supervision teams and the future operators is good practice. This makes it possible to resolve any reservations and residual discrepancies as transfer proceeds.Care must be maintained concerning three points: configuration management during the design stages, erection work and testing compliance, and resolving reservations.I note the importance of being able to transfer the main systems at an early stage to get the organisation running smoothly and make sure that the requirements match the standards. During my visit to the worksite in mid-2014, the number of handovers was still small (10%), which should encourage the Nuclear Generation Division and the Nuclear

Engineering Division to smooth the workload corresponding to the forthcoming handovers to avoid any risk of bottlenecks. Planning of the overall tests will be at a time when many handovers will be taking place and I call upon the operator to maintain the highest standards.I would also like to emphasise the fact that an independent nuclear safety network will soon be set in place, made up of worksite staff and the future operator’s staff, with the participation of the nuclear safety department of the Nuclear Design and Construction Centre. This will challenge configuration management and resolution of the reservations and discrepancies important for safety, throughout the start-up period. In China, at the Taishan site, I notice the same attention to detail in managing the configurations and the handovers. This site’s organisation has benefited from experience feedback from the Chinese plants recently started up (2 in 2013 and 4 in 2014).

The overall test sequence for start-up

The start-up testing consists of the following sequences.

• Before fuel loading ✓ Vigorous flushing of the reactor coolant system and all the auxiliary systems into the reactor vessel.

✓ Functional tests with the reactor vessel open: verification of all injection flow rates into the reactor vessel.

✓ Cold tests: hydro-testing of the reactor coolant system and first start-up of the reactor coolant pumps.

✓ Hot functional tests: checking proper functioning of the nuclear steam supply system under rated temperature and pressure operating conditions, checking of behaviour during incident transients (e.g. loss of the instrumentation and control power supplies).

• After fuel loading ✓ Pre-critical cold tests: checking of proper cold thermomechanical behaviour in the presence of fuel.

✓ Pre-critical hot tests: checking of proper thermomechanical behaviour at working temperature and pressure in the presence of fuel.

✓ Physics tests: checking its proper behaviour at different power levels with the core critical for the first time.

✓ Major transients: checking proper overall behaviour of the installation in the event of major transients (e.g. automatic reactor trip at full power, house-load operation).


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Ramping up operator skills

I note the considerable staff refreshment in the nuclear power plant teams and the continued high motivation of the players inspired by this major industrial challenge. However, I regret to see that there is currently an insufficient number of operators, operations shift managers and safety engineers with operations experience. I note the extensive simulator work, the new organisation of the reactor control team now having been established. I also note that six experienced French operations managers will be available to provide assistance during the start-up tests at the Taishan site.Involvement in the start-up tests gives the operator the opportunity to develop its skills and take ownership of the installation. In order to build up skills in operator staff seconded to erection and testing work, the work site management and the future operator have drawn up a joint timeline that that appears to be well conceived.With the start-up tests approaching, interaction between the worksite and the future operator is intensifying. The teams work together in what will be the definitive operations building, in the immediate vicinity of the installation. Training of maintenance staff, with the support of the Corporate Engineering Training Department and the contractors, is to be stepped up and focus more on the particularities of EPR equipment.I am pleased to see the attention paid to deploying practices to ensure reliability so that things are done right the first time, a guarantee of nuclear safety and high quality.The increasing synergy with Flamanville 1 and 2 is helping young inexperienced staff to assimilate the core issues of operations shift work and a common understanding of logistical support (supply of utilities, security, etc.). It facilitates planning the following tasks with contractors:• Remaining start-up tests at Flamanville 3• Conducting the first operating cycle • First full inspection• General Refurbishment at Flamanville 1 and 2 with

steam generator replacement and the future third ten-yearly inspections.

Testing the electrical buses at the Flamanville 3 EPR worksite

Towards integrating Flamanville 3 with the other plants in service

When it was planned to build Flamanville 3, it was decided that the supporting engineering force would be posted onsite, make it relatively isolated from the engineering forces at the other plants. I recommend that the Nuclear Generation Division’s corporate level carry out an in-depth review of the areas of support, expert appraisal and monitoring in which the plant should now play a part.The rules for the EPR surveillance tests and general operation need to be taken on board by the operator, with the scope and cumulative rules that may be more stringent than for the existing plants. The framing of these new rules will be analysed in-depth by the Nuclear Engineering Division and the Nuclear Generation Division (Operations Engineering Unit).Until the tests are completed, certain special and new equipment cannot be considered as qualified, e.g. core surveillance system, pressuriser relief valves, steam isolation valves, etc. Their qualification for accident conditions, required before start-up, will necessitate operator vigilance to ensure that they are carried out in due time. Here, I call for the support of the engineering force from the plants in service.The EPR was designed to enable some maintenance work to be performed with the unit in service, making it possible to reduce the outage workload, which is favourable to nuclear safety. I was shown the work being carried out to prepare the maintenance activities, and am wondering if it is possible to achieve the objectives of the initial design.


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Planning the start-up

The planning for the fuel loading and operation reflects the highest international standards. The plant will be aided in its preparation by the forthcoming joint internal audits by the Nuclear Inspectorate of the Nuclear Generation Division and the Assessment and Support Unit of the Nuclear Engineering Division, together with the pre-start peer review by WANO and that of the IAEA. I attach special importance to action to implement all their recommendations by start-up time.I noted the build-up by AREVA to prepare for the start-up tests. We need to be attentive to the availability of the AREVA resources, particularly of test technicians, in view of the possible simultaneous start-up of the French, Chinese and Finnish EPRs.The future permanent presence on the site of the Institute For Nuclear Safety and Radiological Protection (IRSN) during the start-up tests will facilitate early examination of the test results, as well as the quality of the chemical exchanges beforehand relating to the licensing applications for the key stages of start-up.The Flamanville 3 core is a new design and special care will therefore be required during the first operating cycles to validate the neutronic and thermohydraulic assumptions. Two key points will be the subject of special consideration: the new core protection and surveillance system, and the deformation behaviour of the fuel assemblies with regard to experience feedback.

Constructing the reactor building dome at the Flamanville 3

EPR worksite

SYNERGY BETWEEN FLAMANVILLE 3 AND TAISHAN IS BENEFICIAL FOR NUCLEAR SAFETY

At Flamanville and Taishan, I noticed the well-organised pooling of experience, with identification of the technical issues that need to be examined and the staff put in charge of the work. I noted the sharing of information with Taishan on the modifications before start-up, with

consideration given to all issues with nuclear safety implications. I note that the number of modifications integrated in Flamanville 3 and Taishan is not the same, corresponding to different industrial policy, but in both cases fully answering the needs of nuclear safety. I also note our sharing of experience on the terms and conditions for protecting equipment installed pending start-up.This synergy between the start-up teams of the two sites makes it possible to accumulate experience feedback beneficial in terms of both quality and nuclear safety. Particular attention will need to be paid to the operator, fully taking the results of the tests into account. The flow of experience feedback between the sites must be very responsive, as the test periods are short.In the case of special first-of-a-kind tests, particularly the vibration tests on the reactor vessel internals, the operator will need to be vigilant about the representativeness and the conformity of their results, wherever they may be located.I was shown the main first-of-a-kind instrumentation and control systems of at Flamanville 3, reflecting experience feedback on situations encountered in the plants in service and the supplementary particularities of the EPR technology. I also noted the monitoring of pipes with the heaviest fatigue loading.

FORTHCOMING OPENING OF THE HINKLEY POINT EPR WORKSITE IN THE UK

The execution phase of the project is due to begin, with a responsible designer contract for the Nuclear Engineering Division and the Nuclear New Build Generation Company acting as the intelligent customer.I will be paying careful attention to the clarity of the roles and interfaces, as well as to the quality of the design and construction work, as soon as the investment decision is made. I will also make sure that the allocation of resources and skills to this project is not detrimental to Flamanville 3.I will be paying special attention to the integration of nuclear safety modifications derived from Flamanville 3 and to the management of the configuration in service.

NEW MODELS: INNOVATION BENEFITS NUCLEAR SAFETY

Together with EDF SA, AREVA has begun work on the basic design of a simplified and optimised EPR with a power rating suitable for most European power generators. This project benefits from EPR experience feedback and meets the nuclear safety objectives for


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Generation 3 reactors (WENRA and EUR128), with the absence of durable territorial consequences in the event of a severe accident, while integrating all the lessons of the Fukushima accident.I also note the plans to begin working on the basic design of a three-loop reactor before the end of 2015, which would be more suitable for smaller European power generators.I would like to emphasise the importance of the work began with the strong support of the Research and Development Division to review the options for new designs strengthening defence in depth: direct injection into the core further reducing the risk of core meltdown, and in-vessel retention increasing mitigation capability in the event of a hypothetical accident. I support the studies underway on the design of passive and active intrinsically-safe systems that are supplementary to the existing active systems.I also note the benefit of a careful watch over any changes in materials and components, and of digital simulation that can reinforce nuclear safety in terms of prevention and mitigation. The digital simulation and modelling of cores - coupled with mechanical, thermodynamic and neutronic models - are key assets for understanding physical phenomena and their interaction. By using such models, full allowance is made for uncertainty and nuclear safety margins are better assessed.I observe with interest the watch over the design of accident-tolerant fuel with a higher ability to withstand core meltdown situations.I note the key work on Generation 4 reactors throughout the world. The experience feedback on sodium and the core physics of sodium fast reactors, the integration of lessons learned from the Fukushima disaster and the ability to go beyond the Generation-3 nuclear safety requirements are all the subject of in-depth analysis by the stakeholders.Preserving experience feedback from the Rapsodie, Phénix and Superphénix facilities, and contributing to the Astrid project studies conducted by the French Atomic Energy Commission enable EDF to retain its nuclear safety know-how relating to such sodium fast reactors which remain important for nuclear safety in the long term with regard to the nuclear fuel cycle. I call for maintaining a watch over the different possible technologies for Generation 4, with particular reference to light-water designs.The new options offered by SMRs129 rated at less than 300 MWe offer scope for innovations in nuclear safety, given their low thermal power. Various design projects throughout the world are making it possible to assess

128 European utility requirements129 Small Modular Reactor

their potential in terms of nuclear safety and industrial feasibility. I have taken good note of the fact that EDF is participating in the project to develop French technology in this area, led by the French Atomic Energy Commission, with AREVA and DCNS130.

New reactors and the plants in service

As both an operator and an architect-engineer, it is extremely important for the EDF Group to work on new reactor designs to maintain a strong design capability consolidated by experience feedback and to remain open to innovation. This will have direct spinoffs for both periodic upgrading of the plants in service and progress in nuclear safety. Meanwhile, these studies and watch for new reactor types are developing in the light of operating experience feedback. I note the recent regain in interest in experience feedback from the plants, reviews of functions and systems, and studies of precursor events by the Nuclear Generation Division and the Nuclear Engineering Division.In particular, I see a new energy situation. On the one hand, there is a reduction in the amount of power produced from fossil fuels producing carbon dioxide, which have their part to play in the balance of electrical power generating in Europe. On the other hand, there is the increasing use of intermittent and renewable energy supplies. This means that existing and future nuclear power plants will need to operate in a more flexible manner, while continuing to meet the needs of nuclear safety.

130 French naval construction and energy company


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MY RECOMMENDATIONS

The EPR, which is a Generation 3 technology, reflects the long operating experienced with pressurised water reactors. I recommend the Flamanville 3 operator to reinforce its tried-and-tested operating skills for the start-up operations.Management of EPR configurations is all the more important because of its new design. I would like to draw attention to the long-term management of the Flamanville 3 EPR configuration by the design departments and the worksite on the one hand, and the website and the plant on the other hand.The EPR design should enable some maintenance work to be carried out while it is operating, reducing the maintenance workload during outages. In view of the remaining questions on the feasibility of this, I recommend that the scheduling of the maintenance operations be re-assessed for Flamanville 3 and that maintenance arrangements be determined for future EPRs and new types so the work can be conducted efficiently with the unit operating.The EPR brings innovation in design and operating modes. I encourage synergy among the EPR users as soon as Flamanville 3, Taishan 1 and 2 and Olkiluoto 3 are in service to accumulate experience feedback that will help detect any precursor events and foster nuclear safety in operation.The work on new reactor designs focuses on finding reliable solutions. If these designs are to rely on skills and methods developed in operations, I strongly encourage the R&D and engineering forces to also give more consideration to innovative solutions.


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nOTEWORTHY OPERATIOnAL EVEnTS THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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12 / NOTEWORTHY OPERATIONAL EVENTS

Fuel handling operations in the reactor building

The events described this year relate to operational events in service and during outages, as well as to the operator’s management of the radiological risk.

Of very different natures, they show the need for continuously consolidating safety culture and the human and organisational lines of defence.

INAPPROPIATE FUEL HANDLING DECISION IN A UNIT OUTAGE

The facts

Fuel handling operations had been begun during an annual PWR outage.While unloading the third fuel assembly (out of 193 in the core) at the start of the night shift, faults were discovered which automatically placed the unloading machine in the safe position (brakes suddenly applied). These problems became worse. The manufacturer’s technician rapidly identified failure of an electronic rotation speed sensor. This technician provides the machine operator with technical assistance and is permanently present in the reactor building during this type of operation. At 1:00 am, he suggested shunting out the failed component to the loading supervisor. The loading

supervisor questioned the nuclear safety consequences of taking such action, as it was clearly in violation of the general operating rules131. The loading supervisor decided not to install a shunt. The discussion and the decision were not recorded. After having stopped unloading, the loading supervisor approached the duty maintenance staff to obtain a replacement sensor. While waiting for the replacement sensor to arrive, at 2:45 am he decided to resume unloading operations in the low-speed mode, which limits the number of faults. Meanwhile, the duty maintenance technician ordered the replacement, which was due to arrive at 1:00 pm. He was unaware that the replacement was no longer the right type for the unit’s fuel unloading machine. This was because the machine had recently been modified. The unloading teams and the manufacturer support technicians went off shift at 5:00 am. Many faults were still occurring and were very troublesome (sudden braking of 131 Known as RGE in France (Règles Générales d’Exploitation)

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION nOTEWORTHY OPERATIOnAL EVEnTS

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the refuelling machine). The new manufacturer assistance technician convinced the new loading supervisor to fit a shunt until the sensor could be replaced. The latter did not question the potential consequences of the unavailability of the protection device, as required under the general operating rules. He did not analyse the regulatory situation as required for any temporary modification of the installation. He considered that it amounted to a standard operating shunt, which he is authorised to do for shunting out unserviceable equipment. Yet such analysis would have revealed violation of the general operating rules. Neither did he consult the maintenance department duty worker whose opinion is required on any modification to any equipment for which he is responsible. The loading supervisor therefore approved the shunt pending the arrival of the new sensor. The sensor was installed at 12:00 midday and this was recorded in the shift log. The unloading operations continued and no further faults occurred. This modification disabled the protection of functions which stop lifting fuel assemblies if the speed of operation is abnormally high and protects against the risk of load drops which can give rise to a fuel assembly drop accident (Category IV).Unloading team shift turnover took place at 1:00 pm. No mention was made of installing the shunt, which had nevertheless been recorded in the shift log. The afternoon shift was therefore unaware of the situation. It discovered that the new sensor was of the wrong type when it was delivered (2:00 pm). The correct type was then ordered.Loading team shift turnover took place at 9:00 pm. The night shift, which had been present the previous night, was not informed of the fitting of the shunt either. The manufacturer’s assistance technician was the same one as the night before.At 22:30 pm, after briefly speaking to the loading supervisor and in the absence of any fuel loading machine faults, the unit outage supervisor decided to cancel replacement of the sensor. The manufacturer’s assistance technician then informed the maintenance department duty worker and mentioned, as he had done the night before, the consequences of not replacing the sensor on nuclear safety. The loading supervisor, warned by the maintenance department duty worker and the unit outage supervisor, checked the shift logbook and learned of the temporary modification of the installation which involved fitting the shunt, during the morning shift. He then informed the safety engineer and the unit outage supervisor. The latter decided to suspend unloading operations at 00:00 midnight and informed the duty management of the situation. The unloading machine was there brought up to standard by immediately removing the shunt and the electronic rotation speed sensor was replaced the next day at 10:00 am. The

unloading operations with able to continue under the proper conditions. The shunt remained in place for somewhat more than 12 hours, overlapping three shifts. There was no observed fuel damage during this time. The incident thus had no actual consequences in terms of nuclear safety, either for the environment or the plant staff.

My analysis

The incident began and ended with a proper questioning attitude.I note the correct reactions of the first people involved: the leading supervisor and manufacturer’s assistant. They took the right approach and called in backup. Initially, questioning attitudes made it possible to identify the potential consequences for nuclear safety and make the correct decision. But failure to note the decision in the shift turnover log meant trace of it was easily lost. I note that the same people, again with questioning attitudes, discovered the shunt on the loading machine the next day and immediately called for back-up of the correct level (safety engineer and outage supervisor) which enabled the situation corresponding to the nuclear safety requirements to be restored. A decision was made under the pressure of a faulty machine and on the basis of an incorrect technical opinion.The repeated malfunctioning of the loading machine, which was very troublesome for the machine operators (frequent sudden stopping) led the incoming shift to rapidly seek a solution. The new manufacturer’s assistant suggested shunting out the failed speed sensor to the loading supervisor to preserve the integrity of the loading machine. When questioned by the latter, he claimed there would be no consequences on nuclear safety. I note that the erroneous opinion expressed by the new manufacturer’s assistant was a sign of insufficient skill. I also note that the loading supervisor fully accepted the opinion of the manufacturer’s assistant and did not seek a second technical opinion. He did not conduct any real risk analysis. I am left wondering about the exact definitions of the roles of the loading supervisors, the manufacturer’s assistance and the maintenance department in charge of the loading machine. Important information was lost from one shift to another I note that neither the correct decision by the first team nor the wrong decision by the second team, were properly noted in the shift log or the shift handover log. I also note that the shift turnovers did not result in the right questions being raised and, for instance, reveal the presence of the shunt on the machine. I would like to emphasise the


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importance of formal procedures for operational decision-making and the full use of the shift logs for all activities of a continuous nature, where shifts work teams follow one after the other in the same operational position. I would also like to emphasise the importance of shift turnover activity in fuel handling teams. As is the case for the operations teams, this activity represents a major line of defence as regards nuclear safety.Operations staff were called in too late.Management of this contingency lasted more than 24 hours before the operations shift was called in or even informed. It was only at the end of the incident that the operations shift manager found out about the fault. I emphasise the importance for the few handling teams always reporting back to the control room and the operations teams. The latter, having an overall view and being skilled in nuclear safety, also constitute an important line of defence. Finally, I would like to emphasise the need to strengthen management of the process by which decisions are made by the loading supervisors, in liaison with the operations supervisors. Insufficient oversight exercised by the maintenance department in charge of the machine.I would like to highlight the fact that the maintenance department staff in charge of the faulty machine were very much left to themselves. Similarly, I note the lack of machine configuration by this department (no mention in the operating documents of a recent modification).In conclusion, this incident reveals the need for greater rigour in conducting fuel handling operations. These operations require the plant directors’ upmost attention and must be subject to the principles of organisation and execution expected in operations. I emphasise the importance of clearly specifying the roles of all involved - EDF and contractor staff - in this process and that everyone clearly understands their duties. Solid training of staff, including in matters relating to the general operating rules and the traceability of actions and discrepancies, a questioning attitude and proper management of the decision-making process are expected of the teams in charge of these operations with major nuclear safety implications. Smooth relations and operational communication between loading supervisors and operations supervisors also represent a line of defence that needs to be developed.

INADEQUATE MAINTENANCE RESULTS IN AUTOMATIC TRIPPING OF A REACTOR IN SERVICE

The facts

A PWR was in service at 100% rated power (950 MWe).The operations team was carrying out the weekly changeover of two pumps in the control circuit of both feed turbopumps for the steam generators. After the operation, a leak was found in one of the control circuit pumps: pump 1 of feed turbopump 1. The operations staff decided to give priority to operating the other control-circuit pump assigned to feed turbopump 2. One month later, the functional situation of the two control circuit pumps was the same, with control circuit pump 2 still assigned to feed turbopump 1. At the end of the morning shift, an operations technician observed an increase in the discharge pressure of the control circuit 2 pump and issued a maintenance request for the valve that regulates the discharge pressure. The technician then drew up the job documentation, with the assistance of his deputy shift operations manager, for action by the fast-response maintenance team of the unit in service the next day. This type of job follows a standard procedure including risk analysis. The author did not include risk analysis, which was therefore not submitted to the operations shift manager as required.During the next night shift, the job documentation was validated by the deputy operations chief manager. The job was carried out sometime after four o’clock in the morning, and thus escaped the review of pending jobs made by the unit in service task force teams every morning (including the maintenance job supervisor). The next morning, during the fast-response maintenance team meeting before starting work, the operations technician together with the maintenance supervisor and technicians accordingly discussed their different views about the need to take action. The need expressed by the operations team was validated and the documentation for work on the control circuit valve was forwarded to the fast-response maintenance for action during the morning. Its content was not clearly announced (diagnosis and/or adjustment). Without sufficient discussion with his maintenance job supervisor, the fast-response maintenance team technician interpreted the term “diagnosis” as a request to operate the valve for adjustment.In the control room, the operations staff began a surveillance test on the control rod drop availability (partial insertion of each set and subset of control rods) at 9:30 am. When the N2 subset of control rods


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was inserted, a fault signal appeared, which required switching the power compensation sets (grey set) to the manual mode. Temperature regulation group R remained in the automatic mode.At 10:00 am, the fast-responsive maintenance team’s technician proceeded to operate the control circuit adjustment valve in the turbine hall. The discharge pressure of the control circuit 2 pump dropped. A signal was automatically sent to control circuit 1 pump to start compensating for the loss of pressure in the control circuit, but unsuccessfully as the pump was faulty. Feed turbopump 1 tripped 30 seconds later due to the low pressure in the control circuit, resulting in an automatic reduction in the unit’s power (at 550 MWe). The grey-set control rods remain stuck in the up-position due to the fault in the N2 subgroup. Leakage from the discharge non-return valve in feed turbopump 1 prevented feed turbopump 2 from compensating for the inability of feed turbopump 1 to provide the normal water feed to the steam generators. The water level in the steam generators rapidly dropped until, after 15 seconds, an automatic reactor trip signal was triggered.The incident had no actual consequences on nuclear safety, the environment or the plant staff. After analysis of the causes behind this automatic reactor trip and repairing the faulty equipment, the reactor was put back in service.

My analysis

No risk analysis in the job documentationI noted that, on the basis of a maintenance request issued after detecting an abnormally high circuit pressure, the operations technician wrote an incomplete document calling for “diagnosis or action” intended for the fast-response maintenance team with no risk analysis. He nevertheless wrote this with the support of his deputy operations shift manager. The next day, the night-shift deputy operations shift manager considered that urgent action was required on the only available control circuit pump to guarantee operation of feed turbopump 1 (as loss of one of the two turbopumps leads to a rapid nuclear unit power drop of around 40%). The document was therefore forwarded to the morning fast-response maintenance team without prior discussion with the morning-shift operations shift manager. Operations control team non-compliance with the process for issuing maintenance requests while the unit is in service and defective communication in the maintenance departmentI note that the night operations team validated the maintenance request relating to control circuit 2 pump

after four o’clock in the morning, thus making it impossible for the maintenance supervisor to take it into consideration as per the daily procedure for an incoming shift with the unit in service. This important feature of the organisational system is not properly understood by the operations teams. I also note that during the fast-response maintenance team start-up meeting, the operations technician assigned to the fast-response maintenance team interceded between the team maintenance technician and his supervisor, managing to convince them to carry out the operation. There was therefore no direct communication between the two maintenance workers at that time. There was no common understanding between the people three involved about goal of the operation, which was marked “diagnosis or action”. The maintenance worker saw no point in making a basic visual check of the valve and relied on the description in the maintenance request that called for adjustment and not verification. I would like to emphasise the importance of rigorous operational communication between all fast-response maintenance team members. An operation finally carried out without the expected pre-requirements I note that the maintenance worker, who took action without due consideration, risk analysis or a maintenance job permit, did not contact the control room before operating the control circuit valve. I would like to emphasise the importance of the strong line of defence always constituted by communication with the control room operators before any action on a system in service. The complex situation that the operators then had to manage with the grey-set control rods should have at least led them to report this action and thus avoid an automatic reactor trip.In conclusion, this event shows the importance of rigour in all stages of handling a technical contingency, even if it is considered to be a minor one. Carrying out risk analysis of good quality associating operations and maintenance people, proper knowledge of and compliance with the established organisational systems, and the importance given to operational communication, are all key issues. I am pleased to see that fast-response maintenance teams are now in place in most plants, making it possible to rapidly resolve any discrepancies in the unit and helping to keep running the unit to schedule. I would, however, like to emphasise how important it is to always make sure that operations involving any potential risks are under the total control of the shift operations teams, particularly by the operators in the control room.


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EXTERNAL ELECTRICAL POWER SUPPLY FAULT (ONE PHASE OPEN) CAUSES THE LOSS OF COOLING IN TWO REACTORS AT AN AGR PLANT

Lack of acting on operational experience feedback associated with offsite electrical power supplies resulted in the loss of cooling in two reactors at an AGR plant.

The facts

On 27 April 2014, following a scheduled power switchover by the operator, a negative phase sequence compromised the cooling of two reactors at an AGR plant. Reactor A was already in a routine shutdown situation, while Reactor B was in service. This deterioration in the local system was subsequently identified as being caused by an open circuit on one phase of a 400 kV circuit breaker of the grid. The fault remained latent as a parallel power supply was available. When the power supply was lost after switchover, the local 275 kV system only powered two phases (no current on blue phase). The 11 kV power supply of the plant is derived from the 275 kV supply via three transformers, making it possible to subsequently supply 3.3 kV for the essential and back-up systems. Within two minutes and as a result of the negative phase sequence protection, the alternator and then Reactor B both tripped without the alarms associated with the negative phase sequence being triggered.Initially, operation after the automatic trip was normal. A few minutes later, all the cooling fan motors and pressure vessel cooling pumps tripped as a result of the protection logic. An automatic shutdown of the turbine auxiliary oil pump resulted in manual shutdown of the main boiler feedwater pump since the oil feed was compromised. The boiler emergency feed pump was started up (the feed starter pump was unavailable due to loss of cooling because the main cooling pumps had tripped). For some 15 minutes, Reactor B had no forced-draft gas cooling and was supplied with water, so the core was cooled by natural circulation. The core gas outlet temperatures increased (550°C), remaining within the operating limits.For Reactor A, tripping the boiler feed pumps and the fan motors resulted in loss of forced-draft circulation and feedwater supply to the boilers for some 15 minutes. No significant change in the temperature was observed as the reactor had been shut down for a number of weeks, with the decay heat being residual. Equipment common to the two reactors was also affected. The absence of an alarm associated with the negative phase sequence meant that the alarm management

system was of little use to the operators in this type of degraded grid power supply situation. Some 10 minutes after tripping, a member of the operations team saw in the control room that the reading for the 11 kV power supply phases showed a 10.9 to 11.8 kV difference, indicating a continuous grid disturbance (subsequently determined to be due to the loss of one phase of the 400/275 kV grid supply). At this stage, the operations shift manager had sufficient information to determine that outside power supplies were unstable and not dependable. The decision was taken to isolate supplies of the 3.3 kV bus grid supplies of the standby diesel engines, to start up the standby diesel generators and to supply the main equipment with a stable, balanced three-phase power supply. The 3.3 kV diesel generators on standby were then also disconnected from the grid and started up. This action was carried out to avoid any tripping due to the protection logic.Failure of the circuit breaker was diagnosed six hours later by the National Grid, and the station was reconfigured to withdraw it from use. The plant electrical power supplies returned to the normal configuration a few hours later. The decision was taken to place the emergency centre in operational alert status during this event to provide the operations team with support.The incident had no actual consequences on nuclear safety, either for the environment or the plant staff.

My analysis

Disturbances in outside power supplies, including imbalance between phases, are frequent events that the operating procedures and equipment need to handle without compromising nuclear safety. In particular, detecting the loss of a single phase between the power grid and power distribution system of the plant needs to be scrutinised more closely due to its potential consequences, as the present example shows. As the power grid ages and as a result of the increasing variations in energy flows due to the intermittent nature of renewable energy, such faults are liable to become more frequent. The potential consequences in terms of degradation and loss of cooling after unit shutdown require careful detection, operation of the installation and design arrangements where necessary.I note that this event in 2014 was not the plant’s first experience with this type of problem (two such events have occurred in the last eight years, in 2007 and 2013). I note that examination of the corresponding experience feedback has been insufficiently rigorous. In 2007, the periodical nuclear safety review had identified that the safety case did not take into consideration this


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type of severe disturbance, seeing that such an event was considered to be exceptional at the time. In 2009, a review recommended installing alarm systems in the plant transformers. However, I see that the safety case did not make allowance for this and that the action recommended was not acted upon in a timely manner. More generally, other events need to be considered in the light of international experience feedback: WANO significant operating experience report 1999-1 (station blackout); the noteworthy events at Forsmark Nuclear Power Plant in Sweden in 2006 which was graded Level 2 on INES; and Byron 2 in the US on 30 January 2012 for which corrective action is either being determined or has already been integrated in many installations. This situation is a sign of insufficient general awareness of the links between outside grid disturbances and the nuclear safety of installations on the same site, as a result of common-mode effects and the potential vulnerability of the electrical power system as designed. It also shows insufficient consideration of experience feedback.I note that the operators played a key role in identifying the fault and in managing the consequences, despite there being no precise alarm signals or clearly-established predetermined procedures. Managing the shutdown of numerous items of equipment was a challenge to which the operators overcame. Here, I would like to emphasise the importance of training so operators are prepared to control the installations after severe outside grid disturbances, with training on simulators and in the control room.In conclusion, this event showed the importance of rigorous, in-depth monitoring of experience feedback, from the individual plant, from the set of plants and from plants worldwide. It highlighted the care that is needed, for reasons of nuclear safety. This is particularly true as regards the risk of common-mode failure at the plant and the design and operating arrangements to deal with outside electrical power supply faults. These can be of different natures, for example voltage degradation (affecting all the power circuits) or one or two open phases (only affecting the circuits downstream of the failed component). Finally, training of the operations staff to detect and manage associated disturbed situations constitutes a line of defence that still needs to be strengthened.

A RADIOLOGICAL EVENT: FAILURE TO RESPECT A RED ZONE CORDON

The context

In France, a nuclear facility is divided into five separate zones corresponding to different risks of radiation exposure. Each risk is represented by a colour, with blue being the lowest risk and red the highest. Zoning may change with the state of the reactor. In the red zone, the dose equivalent rate to which an individual can be exposed maybe higher than 100 mSv per hour. Therefore, a dose of 20 mSv which corresponds to the regulatory annual limit for exposure to ionising radiation, can be received in less than 12 minutes. Entry into a red zone requires a special nominative permit, approved by the department that applied for it and also by the radiation protection department responsible, as well as the head of the establishment. Double padlocks prevent access into a red zone. Entry requires a key held by the operations department (which knows the current configurations of the installation) and a key held by the risk management department able to characterise and manage the radiological hazard.

The facts

Maintenance work was due to take place on a reactor after an unplanned outage. This required tagging a device located in a red zone. With the installation in this state, it is normally possible to downgrade the red zone. The following activities were scheduled to take place:• downgrading of the red zone, after the measurements

and checks required, with joint action by the operations and risks departments to open the two padlocks,

• fitting of a tagging sign by the operations department in the former red zone,

• perfomance of the maintenance work. The red zone was not downgraded in accordance with the schedule. The field operators in charge of tagging began the operations without previously checking the radiological conditions of the work. They reached the access door to the cage surrounding the equipment to be tagged. There was a padlock preventing them from opening the door. In this ill-lit place, they did not see that it was a special red-zone padlock requiring two keys. And they failed to see a small non-standard placard beside the padlock indicating the presence of a red zone. They took it to be an ordinary security padlock without questioning. One of the two workers stepped over the barrier to gain access and took an unsafe path to the equipment to be


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tagged. He went down to a lower level to carry out the tagging. The worker was equipped with a dosimeter which did not signal when the ambient dose rate was exceeded. The dose received by the worker was 2 µSv over the entire shift. At the end of their shift, the workers did not mention any difficulties being encountered. The discrepancy was identified by the next shift during de-tagging.

My analysis

This event of no actual consequences, but of which the consequences could have been severe, shows a number of failings: • insufficient planning of a contingent activity • the absence of briefing before the work and debriefing

afterwards• absence of the minute of safety • lack of rigour in red zone grading • failure to comply with basic industrial safety and

radiation protection rules • the absence of questioning attitudes in the workers • the lack of proper coordination of activities.The health and safety of the workers is the core issue when it comes to strict adhering to the basic rules of industrial safety and radiation detection. Although I recognise the careful organisation of matters relating to red zones, I would like to draw attention to the vigilance that needs to be maintained to make sure all involved fully understand and respect the rules.The other issue relates to nuclear safety as the basic rules for risk management, rigour, questioning attitudes and operational communication essentially relate to nuclear safety culture.


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APPEnDIcES THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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13/ APPENDICES

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION APPEnDIcES

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13.1 - RESULT INDICATORS FOR THE EDF SA NUCLEAR POWER PLANTS

Indicator 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014Number of significant nuclear safety events graded 1 or greater on INES per reactor1

0.76 1.22 0.80 1.15 1.17 1.17 0.91 1.55 1.19 1.14

Number of significant nuclear safety events (0 or greater on INES), per reactor!

9.54 10.21 10.80 10.34 10.93 10.45 10.57 11.90 11.60 10.8

Number of cases of non-compliance with the operational technical specifications, per reactor

1.48 1.55 1.70 1.70 1.39 1.55 1.36 1.52 1.34 1.55

Number of alignment errors2, per reactor

0.66 0.69 0.57 0.62 0.53 0.77 0.71 0.70 0.66 0.60

Number of reactor trips per reactor (per 7,000 hours of criticality3) • Automatic 0.93 0.89 0.87 0.51 0.71 0.69 0.50 0.55 0.59 0.53• Manual 0 0 0 0 0 0.01 0.05 0.03 0.03 0.07

Average operational collective dose, per nuclear unit in service (in man-sieverts)

0.78 0.69 0.63 0.66 0.69 0.62 0.71 0.67 0.79 0.72

Personal exposure: • Number of individuals with doses

above 20 mSv 0 0 0 0 0 0 0 0 0 0• Number of individuals with doses

between 16 and 20 mSv 28 17 20 14 10 3 2 2 0 0• Number of individuals with doses

between 14 and 16 mSv - - - - - - - - 8 2Number of significant radiation protection events

173 112 99 107 102 91 92 114 116 113

Availability (%) 83.4 83.6 80.2 79.2 78.0 78.5 80.7 79.7 78.0 80.9Forced loss rate (%) 3.2 3.3 3.7 4.4 4.6 5.2 2.2 2.8 2.6 2.4Occupational accident rate with sick leave (per million hours worked)4 5.5 5.6 4.6 4.4 4.3 4.1 3.9 3.5 3.3 3.2

1 Excluding ‘generic’ events (ones due to shortcomings in design)

2 Any system configuration or system auxiliary that differs from the expected conditions, and which is also the cause or one of the causes of a significant event.

3 The average value for all the reactors, contrary to the median value adopted by WANO.

4 Accident rate for EDF SA and its service providers


97

13.2 - RESULT INDICATORS FOR THE EDF ENERGY NUCLEAR POWER PLANTS

No. Indicator 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

1 Number of events ranked 1 or greater on INES, per reactor

5.67 3.13 1.20 1.13 0.80 0.93 1.33 0.80 0.80 0.33

2 Number of nuclear safety events ranked 0 or greater on INES, per reactor

9.13 7.53 4.93 4.53 5.47 5.60 4.7 4.6 5.1 4.5

3Number of cases of non-compliance with the technical specifications for operation, per reactor

1.00 0.73 0.13 0.27 0.13 0.60 0.33 1.67 0.67 1.53

4 Number of alignment errors, per reactor 1.09 0.69 0.13 0.27 0.13 0.60 0.33 3.07 3.33 2.80

5

Number of unscheduled reactor shutdowns, per reactor (7,000 hours of criticality) • Automatic 0.74 0.73 0.44 1.13 0.82 0.58 0.74 0.64 0.45 1.17

• Manual 1.28 2.54 1.48 1.04 1.44 1.68 1.22 0.84 1.03 0.62

6

Average operational collective dose, per nuclear unit in service (in man-sieverts) • PWR 0.352 0.524 0.045 0.264 0.337 0.271 0.537 0.037 0.386 0.365

• AGR 0.055 0.152 0.071 0.167 0.100 0.018 0.084 0.063 0.034 0.074

7

Personal exposure: • Number of individuals with doses

above 20 mSv 0 0 0 0 0 0 0 0 0 0• Number of individuals with doses

above 15 mSv 0 0 0 0 0 0 0 0 0 0

8 Number of significant radiation protection events

368 249 58 38 31 43 43 50 27 27

9

Availability (%): • EDF Energy plants • PWR • AGR

71.9 83.7 71

66.1 85.3 64.7

62.8 98.4 60.2

51.2 89.2 48.5

71.0 87.4 69.8

65.7 45.6 67.1

72.0 82.5 71.3

78.0 89.2 76.3

78.9 83.0 78.2

72.1 84.1 70.2

10

Unplanned inoperability (%) • EDF Energy plants • PWR • AGR

12.3 0.0 13.1

17.0 0.3 18.2

20.3 0.4 21.7

20.4 2.1 21.8

13.2 0.9 14.0

19.6 54.3 17.1

13.0 3.4 13.7

8.9 9.9 8.7

6.9 0.2 7.9

10.70.7

12.3

11 Occupational accident rate with sick leave (per 200,000 hours worked)

0.37 0.22 0.27 0.35 0.11 0.07 0.12 0.10 0.04 0.05

12 Occupational accident rate with sick leave (per million hours worked)1 1.9 1.1 1.4 1.8 0.6 0.4 0.6 0.5 0.2 0.2

1 Accident rate for EDF Energy and its service providers

Factors to be taken into account in comparing the results of EDF SA with those of EDF Energy: • Lines 3, 4 and 8: the event declaration procedures are not the same in the United Kingdom and France

as a result of the respective nuclear safety authority requirements. EDF Energy and EDF SA harmonised their event classification practices in 2012.

• Line 6: the reactors of the two fleets do not share the same technology (mostly AGRs in the UK and PWRs in France). The AGR design means that radiation exposure is some 10 times lower (source: WANO).


98

13.3 - MAP OF THE EDF SA NUCLEAR POWER PLANTS

Construction/Project

Operation

Decommissioning

300 MWe 900 MWe 1300 MWe 1450 MWe 1600 MWe(EPR)

FlamanvillePaluel

Penly

Gravelines

Chooz

Cattenom

Nogents/SeineDampierre

Belleville

Fessenheim

Chinon

Civaux

Blayais

Golfech

Bugey

St-Alban

Creys-Malville

Cruas

Tricastin

St-Laurent

Brennilis

Clermont-Ferrand

Nîmes

Grenoble

Lyon

Bordeaux

Bourges

Paris

AmiensCherbourg

Tours

Strasbourg

Marseille


99

13.4 - MAP OF THE EDF ENERGY NUCLEAR POWER PLANTS

Construction or Project

Number of reactor per type AGR PWR EPR Engineering

Operational

Engineering Centre

4

14 1

2

Hunterston B

Hinkley Point B

Hinkley Point C

Barnwood

East Kilbride

Dungeness B

Sizewell B

Sizewell C

Hartlepool

Torness

Heysham 1

Heysham 2

LondonCardiff

Edinburgh

AGR : Advanced Gas cooled ReactorEPR : European Pressurised Reactor


100

13.5 - TECHNICAL KEY DATES FOR EACH OF THE EDF SA NUCLEAR UNITS

Year commissioned

nuclear UnitPower

in MWe*VD1 VD2 VD3

Year commissioned

nuclear UnitPower

in MWe*VD1 VD2 VD3

1977 Fessenheim 1 880 1989 1999 2009 1984 cruas 4 915 1996 2006 -

1977 Fessenheim 2 880 1990 2000 2011 1984 gravelines 5 910 1996 2006 -

1978 bugey 2 910 1989 2000 2010 1984 Paluel 1 1330 1996 2006 -

1978 bugey 3 910 1991 2002 2013 1984 Paluel 2 1330 1995 2005 -

1979 bugey 4 880 1990 2001 2011 1985 Flamanville 1 1330 1997 2008 -

1979 bugey 5 880 1991 2001 2011 1985 gravelines 6 910 1997 2007 -

1980 Dampierre 1 890 1990 2000 2011 1985 Paluel 3 1330 1997 2007 -

1980 Dampierre 2 890 1991 2002 2012 1985 St-Alban 1 1335 1997 2007 -

1980 gravelines 1 910 1990 2001 2011 1986 cattenom 1 1300 1997 2006 -

1980 gravelines 2 910 1991 2002 2013 1986 chinon b3 905 1999 2009 -

1980 gravelines 3 910 1992 2001 2012 1986 Flamanville 2 1330 1998 2008 -

1980 Tricastin 1 915 1990 1998 2009 1986 Paluel 4 1330 1998 2008 -

1980 Tricastin 2 915 1991 2000 2011 1986 St-Alban 2 1335 1998 2008 -

1980 Tricastin 3 915 1992 2001 2012 1987 belleville 1 1310 1999 2010 -

1981 blayais 1 910 1992 2002 2012 1987 cattenom 2 1300 1998 2008 -

1981 Dampierre 3 890 1992 2003 2013 1987 chinon b4 905 2000 2010 -

1981 Dampierre 4 890 1993 2004 2014 1987 nogent 1 1310 1998 2009 -

1981 gravelines 4 910 1992 2003 2014 1988 belleville 2 1310 1999 2009- -

1981 St-Laurent b1 915 1995 2005 1988 nogent 2 1310 1999 2010 -

1981 St-Laurent b2 915 1993 2003 2013 1990 cattenom 3 1300 2001 2011 -

1981 Tricastin 4 915 1992 2004 2014 1990 golfech 1 1310 2001 2012 -

1982 blayais 2 910 1993 2003 2013 1990 Penly 1 1330 2002 2011 -

1982 chinon b1 905 1994 2003 2013 1991 cattenom 4 1300 2003 2013 -

1983 blayais 3 910 1994 2004 1992 Penly 2 1330 2004 2014 -

1983 blayais 4 910 1995 2005 1993 golfech 2 1310 2004 2014 -

1983 chinon b2 905 1996 2006 1996 chooz b1 1500 2010 - -

1983 cruas 1 915 1995 2005 1997 chooz b2 1500 2009 - -

1984 cruas 2 915 1997 2007 1997 civaux 1 1495 2011 - -

1984 cruas 3 915 1994 2004 2014 1999 civaux 2 1495 2012 - -

VD1: first ten-yearly outageVD2: second ten-yearly outageVD3: third ten-yearly outage

*net continuous power


101

13.6 - TECHNICAL KEY DATES FOR THE EDF ENERGY NUCLEAR UNITS

Year commissioned

nuclear UnitReactor number

PowerMWe RUP

(1)

Planned date of withdrawal from service

(2)

1976 Hinkley Point b R3 435 2023

1976 Hinkley Point b R4 435 2023

1976 Hunterston b R3 460 2023

1976 Hunterston b R4 430 2023

1983 Dungeness b R21 520 2028

1983 Dungeness b R22 520 2028

1983 Heysham 1 R1 585 2019

1983 Heysham 1 R2 575 2019

1983 Hartlepool R1 595 2019

1983 Hartlepool R2 585 2019

1988 Heysham 2 R7 610 2023

1988 Heysham 2 R8 610 2023

1988 Torness R1 595 2023

1988 Torness R2 595 2023

1995 Sizewell b 1191 2035

(1) Reference Unit Power means the rated electrical power of the generating unit as declared by EDF Energy in its daily transactions at the end of 2014.

(2) Dates of withdrawal from service, including all life extension decisions formally made on 20 january 2015.


102

13.7 - TABLE OF ABBREVIATIONS

AAGR Advanced Gas-cooled ReactorALARA As Low As Reasonably AchievableAMELIE Project to transform the logistics of spare

partsAMT EDF Fleet Maintenance AgencyANDRA French National Radioactive Waste

Management AgencyASG Steam Generator Auxiliary Feedwater SupplyASN French Nuclear Safety AuthorityASR Outage for refuelling onlyAT Unit outage

BBMA Standardised activity model libraryBWR Boiling Water Reactor

CCEFRI French committee for the certification

of companies in training and monitoring radiation workers

CEIDRE Construction and Operation Expert Appraisal and Inspection Centre

CENG Constellation Energy Nuclear Group (USA)CETIC PWR Nuclear Steam Supply System

Fieldwork Technical Validation Experimental Centre

CGN China Guangdong Nuclear Power Group (China)

CIDEN Nuclear Environment and Decommissioning Engineering Centre

CIPN Power Plants Operations Engineering CentreCLI Local Information CommissionCNEN Nuclear Design & Construction CentreCNEPE Electromechanical & Plant Engineering

Support CentreCOLIMO A project to modernise tagging and

alignment practices and methodsCOMSAT Unit Outage Nuclear Safety CommissionCOPAT Unit Outage Operational Control CommitteeCSN Nuclear Safety CouncilCSNE Operations Nuclear Safety Committee (DPN)CSNC Design Nuclear Safety Committee (DIN)

DDAIP Industrial Support for Production DivisionDCN Nuclear Fuel DivisionDEP Pressure Equipment Directorate (ASN)DIN Nuclear Engineering DivisionDMES

Commissioning DocumentationDP/DT Special Requests and Temporary

ArrangementsDPI Production and Engineering DirectorateDPN Nuclear Generation DivisionDTG General Technical Division

EEIPS Equipment Protected for Nuclear Safety

ReasonsEGCI Assessment and Support Unit for the

engineering centresEGE Overall Nuclear Safety AssessmentENISS European Nuclear Installations Safety

StandardESPN Nuclear pressure equipmentEPR European Pressurised ReactorEPRI Electric Power Research Institute (USA)ESR Significant radiation protection eventESS Nuclear safety significant eventEUR European Utility RequirementsEVEREST EDF campaign to allow entry into controlled

areas in street clothesENSREG European Nuclear Safety Regulators GroupEXELON Electric utility (USA)

FFIS Independent Internal Nuclear Safety

OversightFME Foreign Material Exclusion

GGPEC Advanced planning of jobs and skillsGPSN Nuclear Safety Performance Group (UNIE)

HHCTISN High Committee for Transparency and

Information on Nuclear MattersHOF Human and Organisational FactorsI


103

IIAEA International Atomic Energy AgencyICRP International Commission for Radiological

ProtectionIMS Integrated management systemIN Nuclear Inspectorate (DPN)INA Independent Nuclear Assurance

(ex SRD, EDF Energy)INB Licensed Nuclear FacilityINES International Nuclear Events ScaleINPO Institute of Nuclear Power Operators (USA)INSAG International Safety Advisory Group (AIEA)IOP Operations EngineeringIRAS Plant engineer assigned to relations

with the ASN

JJANSI Japan Nuclear Safety Institute

LLLS Turbo-alternator last-resort power supply

MMAE Assessment and Support Unit of the DINMDEP Multinational Design Evaluation ProgramMME Operation and Maintenance MethodsMPL Front Line ManagerMQME Project to raise maintenance and operation

standards (DPN)

NNCC Operating professions common

coreNCME Operations Maintenance Profession Common Core

NCMP Project Professions Common CoreNDA Nuclear Decommissioning Authority (UK)NDT Non-Destructive TestingNEA Nuclear Energy Agency (OECD)NEI Nuclear Energy Institute (USA)NNB Nuclear New Build (EDF Energy)NNSA National Nuclear Security Administration

(China)NPP Nuclear Power PlantNQME Sub-standard maintenance and operationsNRA Nuclear Regulatory Authority (Japan)NRC Nuclear Regulatory Commission (USA)

OOIU User Internal OrganisationONR Office of Nuclear Regulation (UK)OSART Operational Safety Analysis Review Team

(IAEA)

PPBMP Basic Preventive Maintenance ProgrammePDCC Nuclear engineering key skills development

planPGAC Worksite General Assistance ServicesPHPM Methods and Practices Harmonisation

ProjectPIA Protection-Important ActivityPIRP Contractor Industrial Relations and Industrial

PolicyPUI Onsite Emergency PlanPWR Pressurised Water Reactor

RRCE Project to reinforce design capacity

(DIN-SEPTEN)RCP Reactor coolant systemRCV Chemical & volume control system of the

reactor coolant system R&D Research and Development DivisionRGE General Operating RulesRIS Emergency water injection system for

reactor coolingREX Experience feedbackRGV Steam generator replacementROSATOM Russian federal atomic energy agencyRPN Neutron flux instrumentation systemRTE Power grid companyRTGV Steam generator tube rupture


104

SSAT Systematic Approach to TrainingSDIN Nuclear Technical Information SystemSDIS County Fire and Emergency ServicesSGDSN National Committee of Public Safety and

DefenceSEPTEN Basic Design Department (DIN)SIR Authorised Internal Inspection DepartmentSMR Small Modulated ReactorSOER Significant Operating Experience Report

(WANO)SOFINEL Joint EDF and AREVA design office

EDF-AREVASPR Risk Management DepartmentSRD Safety and Regulation Department

(EDF Energy)STE Technical Specifications for Operation

TTEM Unit in serviceTNPCJVC Joint venture between the Chinese company

CGNPC (51%), Guangdong Guoha Yuedian Taishan Power Company (19%) and EDF (30%)

TSM Technical and Safety Managers (EDF Energy)TSM Technical Support Mission carried out by

WANO peersTSN French Nuclear Safety and Transparency Act

UUFPI Operations Engineering Training Department UNIE Operations Engineering UnitUTO Central Technical Support Department

VVD Ten-yearly inspectionVP Partial inspection

WWENRA West European Nuclear Regulators

AssociationWNA World Nuclear AssociationWANO World Association of Nuclear Operators


105

Bernard MAILLARD, Jean-Paul COMBEMOREL, François HEDIN, Michael LAVELLE Jean TANDONNET, François de LASTIC

PHOTO CREDITS

Cover : © EDF Médiathèque - Christel SASSO Chapter 1 : © EDF Médiathèque - Jean-Louis BURNOD Chapter 2 : © EDF Médiathèque - Cyrus CORNUT Chapter 3 : © EDF Médiathèque - Mario FOURMY Chapter 4 : © EDF Médiathèque - Guillaume Murat Chapter 5 : © EDF Médiathèque - Sophie BRANDSTROM Chapter 6 : © EDF Médiathèque - Antoine SOUBIGOU Chapter 7 : © EDF Médiathèque - Stéphanie JAYET Chapter 8 : © EDF Médiathèque - Stéphanie JAYET Chapter 9 : © EDF Médiathèque - Julien GOLDSTEIN Chapter 10 : © EDF Médiathèque - Philippe ERANIAN Chapter 11 : © EDF Médiathèque - Antoine SOUBIGOU Chapter 12 : © EDF Médiathèque - Thoma D’ARAM DE VALADA

The photographs contained in this report are from the EDF media library.

Translated from French by Simon Vickers with the assistance of Caroline Purcell.

E.D.F.Présidence IgSn21, avenue de Messine75008 Paris✆ : +33 (0)1 40 42 25 20

www.edf.com

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