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2015

The Inspector General’s report

on Nuclear Safety andRadiation Protection

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FOREWORD THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

FOREWORD

This report, written for the Chairman of EDF, gives my assessment of nuclear safety and radiation protection within the EDF Group.

The report is also intended for all those in the company who contribute in any way to nuclear safety and radiation protection through their day-to-day actions and decisions. It will have achieved its purpose if it provides food for thought on their contributions in these areas and how performance levels can be improved.

It also aims to identify any early warning signs and recommend areas for improvement. It therefore focuses on difficulties and weaknesses rather than strengths and progress. This may seem unfair to those who spare no effort to ensure that complex and demanding nuclear power facilities are operated safely on a daily basis.

My assessment is based on information gathered and observations made during the year, both in France and the UK, whether from workers in the field, or during visits to plants and meetings with the main stakeholders: managers, staff representatives, members of the medical profession, and contractors. It also makes use of comparisons with several other international players on the nuclear scene and dialogue with WANO1 and the nuclear safety authorities.

1 World Association of Nuclear Operators

I would like to thank all those I met for their unstinting help and frankness, not to mention the breadth of our discussions. Their openness, which determines the relevance of this report, is fully in keeping with the spirit of the nuclear safety culture.

I would also like to thank my assistants, Jean-Paul Combémorel, Bernard Maillard, Jean-Jacques Létalon, Jean-Michel Fourment and John Morrison. As always, they have spared no effort, particularly in drafting this report. I would like to give a special mention to François Hédin and Mike Lavelle who left the team in 2015.

In 2015, the General Inspectorate for Nuclear Safety & Radiation Protection moved from its premises on Avenue de Messine where it had been based for almost fifteen years, to offices at 33 Avenue de Wagram. The new offices, which are close to those of the EDF Chairman, will make our inspection duties easier, while maintaining our independence.

Finally, although this document has not been written for public relations purposes, it is available to the general public in both French and English, as in previous years, on the EDF website (www.edf.fr).

EDF Group Inspector Generalfor Nuclear Safety and Radiation Protection

François de LasticParis, 20 January 2016

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

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CONTENTS THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

Contents

1 / My view of 2015 5

2 / Operational safety: mixed results 13

3 / Nuclear safety clearly prioritised 19

4 / Risk prevention: progress in France 25

5 / Reinforced emergency preparedness post-Fukushima 31

6 / Fire prevention: still a weak link 37

7 / Continuous investment in training and careers 43

8 / Using maintenance to leverage improved operational quality 49

9 / Chemistry in France: a transition in need of strong support 55

10 / Decommissioning projects are progressing 59

11 / EPRs in China, France and the UK 65

12 / Preparing for the future 71

13 / A window on the world 75

14 / Appendices 79

Results for the nuclear fleets

14.1 EDF SA �� 80

14.2 EDF Energy �� 81

Maps of the nuclear power plants

14.3 EDF SA �� 82


Key dates for the nuclear units

14.5 EDF SA �� 84


14.7 - Abbreviations �� 86

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

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My viEW OF 2015 THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

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1 / MY VIEW OF 2015

Paluel nuclear power plant

THE INTERNATIONAL SITUATION

The shock wave of the Fukushima accident in 2011 is still being felt. This has been demonstrated over the last few years with the early shutdown of reactors as well as a slowing down in the launch of new build projects and work to upgrade plants that are in operation, the scope of which varies from country to country. Nevertheless, there are clear signs of recovery throughout the world. In Japan, authorisation has been given for the local population to start returning to some of the areas evacuated after the accident. Two reactors (Sendai 1 and 2) which were shut down after Fukushima resumed production in 2015, after the work required by the nuclear safety authority had been completed. Three others should be able to restart fairly soon and more than twenty are currently undergoing the same process.The only early reactor shutdowns in the world that have been announced or are being considered in 2015 are for economic reasons. These are older,

relatively low output, more often boiling water reactors and are fairly often the only ones on their sites. This is notably the case in Sweden (Ringhals and Oskarshamn) and in the US (Pilgrim and Fitzpatrick). I visited the Ginna2 reactor which could suffer the same fate due to its isolation and output level, which make it less competitive. I was however very impressed with this PWR, which has been in operation for over 45 years (see Section 13).Conversely, several new plant life extensions beyond 40 years have been announced: Tihange 2 and Doel 3 in Belgium, and Krško in Slovenia where I had the opportunity to assess the scope of the post-Fukushima modifications (see Section 13). What is more, initial notification of an application for extension up to 80 years has been sent to a nuclear safety authority (for the Surry reactor in the US). In late 2015, this safety authority distributed two draft documents explaining how it will assess the requests to extend plant service lives beyond 60 years.

2 580 MWe PWR, 49.9% owned by the EDF Group, located in New York State in the US.

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION My viEW OF 2015

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Across the world around 70 reactors are currently being built, over twenty of which are in China, where 8 reactors started commercial operation in 2015. While those reactors that are currently being commissioned are Generation II, all new projects started since Fukushima are Generation III reactors which have an even safer design. A number of building challenges have been encountered with the first-of-series Generation III reactors (AP 10003, EPR4 and AES-20065). I have however noted very fast progress with the two EPRs in Taishan (see Section 11).The UK is the first western country to restart a nuclear power generation programme since Fukushima. Based on five reactors and an installed capacity of 8 GWe (four EPRs and one Hualong6), it is possibly the forerunner of future projects in the world which will often call upon international companies – here EDF and its historical Chinese partner CGN7 – as investors or even as operators. Such projects have been widely reported in the media. Some of these are in countries with no previous experience of the nuclear industry: construction is well advanced in the UAE, and there are projects in Turkey, Egypt, Saudi Arabia, Poland and Belarus. These countries must be supported over time to help them build an industrial and institutional environment, and develop a strong nuclear safety culture. Fukushima reminded us of the interdependence of those involved in the nuclear industry due to the major consequences of any nuclear accident for every operator. WANO, the association which brings together all the world’s nuclear operators, has thus seen its responsibilities increase. Its aim is to improve the safety of all nuclear power plants, by means of assessments, benchmarks, exchanging information and implementing good practice. I note the higher frequency of site visits, the implementation of assessments leading to classifications and pre-start-up peer reviews, as well as the inclusion of certain aspects associated with design during peer reviews. I therefore commend the changes undertaken by WANO since Fukushima, designed to take better account of this new situation.

NUMEROUS CHALLENGES FOR THE EDF GROUP

In France, the “Energy Transition and Green Growth Act”, passed in August 2015, stipulates that nuclear energy’s share in the national electricity production must be reduced to 50% by 2025, and that nuclear

3 1000 MWe PWR developed by Toshiba-Westinghouse (Japan – US)

4 1650 MWe PWR developed by AREVA (France)5 1200 MWe PWR developed by Rosatom (Russia)6 1000 MWe Generation III Chinese PWR7 China General Nuclear Power Corporation

power production is to be capped at its current level. This law contains many other provisions which will have consequences on the operation of reactors, including rules regarding modifications, safety reviews after 35 years, decommissioning, the use of contractors, etc.In accordance with French government guidelines, AREVA and EDF are to operate more closely. They have entered into an agreement which provides for EDF to eventually take over control of AREVA NP, the company which is, in particular, responsible for the design and manufacture of nuclear steam supply systems. The agreement also provides for close cooperation in the design and management of new reactor projects. This partial incorporation should result in more efficient control of major nuclear projects in France and other countries, with better incorporation of operating experience and increased safety.The new Flamanville 3 roadmap, announced in September 2015, will lead to the reactor being started up at the end of 2018. Taishan will therefore probably be the first-of-series EPR (see Section 11).The General refurbishment project, which is designed to extend the service life of French reactors beyond 40 years and incorporate the post-Fukushima modifications, requires substantial resources. To meet these challenges, EDF’s new strategic plan, CAP 2030, is focusing on three objectives:• Development of low-carbon energies• Safety and performance of existing and new nuclear

power plants• Extension of the service life of French nuclear power

plants beyond 40 years and that of British plants beyond 8 years

The EDF Group has been reorganised, with the creation of two major nuclear directorates, the DPNT (Nuclear and conventional fleet directorate) and the DIPNN (Engineering and new-build projects directorate), to strengthen the management of major projects. In France, in the DPNT, the DPN (Nuclear generation division) has developed Generation 420, its new, clear and concise initiative. I would like to underline the importance given to nuclear safety and the clear definition of priorities. I note too that it makes simplification one of the levers for achieving progress. (see Section 3).I would also like to highlight the increasing openness of the EDF Group, particularly in its investment in WANO and the EDF R&D’s many international collaborations. I commend the strong relations between the DPN and EDF Energy, instilled by the management of both fleets, and the development of the DPN’s benchmarks with operators in other countries (China and the US).During my visits, I met a great many men and women working in both operation and engineering in the


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nuclear power industry, at EDF SA and EDF Energy. I have frequently been struck by their motivation and their overall confidence in the company.I would like to emphasise once again the attractiveness of the EDF Group, the high quality of the staff and the effectiveness of its recruitment and training methods, which have enabled it to deal with the high turnover in its teams (see Section 7). Although the age pyramid is showing a more favourable outlook for EDF SA, it is important to continue the throughput of recruitment as the management of human resources is a long-term process which cannot react easily to sudden changes, notably in the nuclear area.I believe that keeping young recruits motivated involves establishing rewarding career paths, in particular through exchanges between the two nuclear fleets and between the fleets and the engineering teams.

MIXED NUCLEAR SAFETY RESULTS

For the third year running, the EDF Group has not experienced any nuclear safety events rated level 2 or above on the INES 8 international scale.In France, the results show an overall negative trend against 2014 which was, it must be said, a good year.One of the positive points is the continued improvement in the management of unit outages, in particular those with a limited programme of work. This has been achieved by better forward planning, good preparation and stability of the outage schedule. It contributes directly to the nuclear safety results as indicated by the marked decrease in non-compliance with technical specifications, the “highway code” for nuclear operators.Negative points include the increase in the number of automatic reactor trips (38, which is 7 more than in 2014), the same level of sub-standard operation and maintenance as in 2014, which I consider to be high, and the decline in fire safety results.Without being too concerned at this stage, these results require an appropriate response. I noted the analyses carried out and the work started by the DPN at the end of 2015. I will be monitoring the progress of this in 2016.In the UK, I observe a clear recovery in the results including the spectacular improvement in the unplanned unavailability rate: 2.3% in 2015 (10.7% in 2014). This reflects improved reliability of equipment, which is favourable to nuclear safety. I commend the good results obtained in the WANO corporate review follow-up. This improvement demonstrates the effectiveness of EDF Energy’s support for those sites in greatest difficulty. EDF Energy seems to have resumed the positive trend

8 International Nuclear Events Scale

that started five years ago. I will be carefully monitoring its continuation. In 2014, when four AGRs were shut down for several months due to a crack detected on one of the boilers, I called for vigilance with regard to these boilers and also in the monitoring of the graphite cores. I commend the technical measures taken, with national-level support, to prevent the recurrence of such boiler events and to strengthen the in-service inspection programme, as recommended in my last report.

PROGRESS IN RISK PREVENTION

The industrial safety and radiation protection results in the UK remain excellent, making the EDF Energy fleet a global reference.In France I applaud the substantial improvement in the industrial safety results in 2015. They lag behind those of the world’s best operators, but the improvement augurs well for achieving the Group’s objectives. I also note that the concept of shared vigilance is growing: it involves a cultural shift and seems likely to lead to a real change in the industrial safety results, as within EDF Energy.With regard to radiation protection, individual doses are continuing to improve, which is essential. The collective dose meets the target and is slightly lower than last year at 0.71 man-sieverts per unit (0.72 man-Sv per unit in 2014). Control of the individual and collective doses still needs to be carefully monitored in the context of the General refurbishment programme.

THE RIGHT LEVEL OF INDEPENDENT INTERNAL NUCLEAR SAFETY OVERSIGHT

At the DPN in France, I note that the independent nuclear safety teams are well-positioned and listened to; this continues to improve. The proportion of experienced nuclear safety engineers still remains too low, but the skills of the younger engineers are improving. They are well supported by the safety and quality managers (MSQ) who are closely linked to the core of the site management teams. I note that the maintenance skills within the safety departments need to be strengthened.The reorganisation of the engineering teams in 2015, divided between the in-service fleet and new projects, has meant that some aspects of their internal nuclear safety oversight and quality processes are being re-examined. We must also ensure that the partial incorporation of AREVA does not impact the monitoring activities, particularly those concerning nuclear safety cases. These subjects are currently being clarified and I will be monitoring them closely in 2016.


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In the UK, the Independent nuclear assurance (INA) teams I met this year are experienced and are very actively involved in the life of the sites, via their resident inspectors. The site management teams must ensure that the INA teams continue to be well-integrated. I believe that the topic-based reviews carried out by the INA teams are very useful in challenging the sites and spreading good practices.The Technical and safety support managers (TSSMs), who act as the nuclear safety “conscience” of the directors, play a vital role in taking safety requirements into account. It is therefore important to ensure that they have strong, sufficiently experienced teams. Finally, I commend the important role played by the Fleet managers in checking and leading the incorporation of nuclear safety, each in their own area.

FIVE POINTS WHICH REQUIRE ATTENTION

Simplification: a process that is indispensable for safety

Nuclear safety requires that everyone understands what they are required to do and they should be placed in situations that allow them to rigorously meet these requirements. However, analyses of nuclear safety events too often show that those involved are not always placed in such situations.As in my last report, I am still surprised by the complexity of requirements and procedures. While they are all relevant, their effectiveness and even their consistency decreases when there are too many. Excessive numbers of rules and too much detail make it difficult to assimilate them, with the risk that they lose their meaning. This complexity can lead to people becoming “automatons” as a result of blind trust in a procedure, or “freezing up”, even worse, to breaking rules. I therefore believe that it is essential to strive for simplicity in operating and maintenance methods, and also in organisations, technical designs, studies, etc.I have seen some encouraging signs this year. The Group’s strategic plan, CAP 2030, emphasises simplification as a lever for change. The DPN’s Generation 420 project is also committed to simplification, in order to achieve efficiency and safety, as are some of the engineering centres. I also note good practices in British plants, such as the Decision-making process.I too often hear it said that increased complexity is inevitable given the external requirements – the increasing demands of regulation – and the specific nature of the nuclear industry. Without denying the importance of these factors, I have observed that much of the complexity

originates internally and that other sectors, which are just as complex, for example the aircraft industry, know how to come up with simple solutions.

Simplification

Simplification is difficult because the nuclear industry has very stringent requirements. As Generation 420 points out, what is needed first and foremost is managerial courage, which involves taking educated risks and removing certain actions. Everyone has a role to play at their own level while also considering the collective aspect. Simplification is primarily about situations specific to the plants, because it is here that the damaging effects of complexity are ultimately seen. A willingness to reconsider and an imaginative approach are essential and must be encouraged by first-line managers, who must be prepared to listen. More effective organisation and working methods and making use of modern information tools will all help to achieve this simplification. Everyone wants simplification, and it must be supported by every level of management. It is a continuous process which must be accompanied by a cultural change so that simplicity is prioritised every time there is a change, incorporating that change in the existing process rather than beside it.

Fire: a prevention culture that needs to be strengthened

All the fire-fighting and prevention measures constitute a major part of nuclear safety because fire is one of the most likely risks.


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In France, the company has made considerable efforts over the past fifteen or so years, such as increasing the training of the response teams with realistic and frequent exercises. It has also committed some significant investment in sectorisation, detection and fire-fighting. I also note that there is a fire brigade liaison officer at each site, who has forged closer links with local fire and rescue services (SDIS). I also commend the very positive nature of the MEEI process (maintaining exemplary housekeeping) in the prevention of fires.All these efforts have resulted in significant progress, in particular towards reducing the number of fires. Even so, the deterioration in the results in 2015 and some significant fires (see Section 6) call for fresh action. What is more, I retained the impression from my plant visits that less attention is being paid to fire risks. That is, fire prevention measures are being implemented in a routine, unquestioning way and that there is some scattering of responsibilities, people and resources. The dynamism that brought about the progress mentioned above has faded and it must be rekindled.The situation in the UK is a little different, but it also justifies renewed effort. The organisation of the sites in the UK is clearer, with a Technical and safety support manager in charge of this and with the appropriate resources available. Here too I note that housekeeping could be improved, and there are still too many oil leaks. I note improving results this year, but will remain vigilant with respect to their continuing progress.The response capabilities are good on both sides of the Channel, however it is clear to me that effort is needed with respect to fire prevention. It is important to maintain compliance (fire loading, oil leaks, sectorisation, etc.) on the sites. The management of maintenance work, a large proportion of which is carried out by contractors, requires particular attention. In this context, I would stress the importance of risk analysis. More generally, in both EDF SA and EDF Energy, it is vital that all EDF staff and contract partners are more aware of the fire risks in their day-to-day activities. The aim must be to develop a fire prevention culture in order to change behaviour at plant level. I encourage site management to demonstrate a simpler, firmer requirement with regard to the risk of fire and its nuclear safety aspect.

Relations with the ASN: improved methods for better interaction

Once again, I would like to draw attention to the relations between EDF SA and the ASN, the French nuclear safety authority. The situation remains concerning even though a number of subjects have progressed.

The sticking points mentioned for the last two years with respect to applying the Nuclear pressure equipment order (see box) have been partially overcome, due in particular to the involvement of corporate management. This has enabled AREVA and EDF to draw up a three-year work plan, approved by the ASN board of commissioners. However, the success of this plan cannot be taken for granted: it must be given the necessary resources and level of priority. On a positive note, this issue has meant that EDF, as a nuclear operator, has resumed its place in the discussions with manufacturers and with the ASN.

The Nuclear pressure equipment order and the three-year action plan

The French ministerial order of 12 December 2005 covers pressure equipment that is specifically designed for nuclear applications. It introduced changes in how the design, manufacture and assembly of nuclear pressure equipment is substantiated and monitored. It came into force gradually, and there have been considerable difficulties with its application. Following a hearing in which the chairmen of AREVA and EDF SA appeared before the ASN board of commissioners, a three-year work programme to develop methods for substantiating compliance with the regulatory requirements was presented to the ASN in 2015.

The quality of the dialogue is important as the number and scope of the cases to be discussed with the ASN (VD4 900, Post-Fukushima, Flamanville 3, EPR New Model, etc.) mean that priorities must be established based on the nuclear safety issues. To examine the cases properly and avoid the sticking points of previous years, I believe it is necessary to formalise a process of constructive discussions with the nuclear safety authority and its technical counterpart, the IRSN (Institute for Radiological Protection and Nuclear Safety). I therefore propose that we start working with the ASN without delay on the quality and effectiveness of the technical discussions and the arbitration arrangements, with the aim of dealing with problems at the appropriate level while providing arrangements for moving up to the next level.Last year, I called for an “urgent step change in regulatory simplification”, as the complexity and proliferation of regulations were having such a negative effect on their being understood and taken into account by operators. It is clear that the situation has not improved very much: I am still seeing the same confusion amongst operators who are nevertheless experienced and committed. Writing everything down and planning everything can be impractical, and would be


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beyond the capacity of those involved. Regulations that are too difficult to apply do not promote nuclear safety. Conversely, regulations that are simple to implement do not necessarily lead to any additional risk.I would like to reiterate my appeal: a compromise must be found between being exhaustive and implementation that is realistic, limiting the regulations to the objectives, while the operator is responsible for the means.Finally, while I have assessed the importance and the difficulties of dialogue with the ASN since I took over this job in 2014, I would again like to stress the priority it must be given as it is in the interests of every nuclear operator to have a strong, recognised nuclear safety authority.

EDF SA to bolster its re-emphasis in engineering

The IAEA recommends maintaining the integrity of reactor design throughout its life cycle and emphasises the need for each operator to have a Design authority9. This requires high-performance engineering teams, who demonstrate nuclear safety, from design through to decommissioning and whose organisation clearly identifies everyone’s responsibilities. For the EDF Group, a designer-operator which designs and constructs most of the reactors it operates, this means having engineering teams that manage the entire reactor cycle from design through to decommissioning. This is an advantage for nuclear safety as the proximity of those involved makes the mutual exchange of ideas between designers and operators easier. The Fukushima accident reminded us how important it was for nuclear operators to embrace the design. In France, as part of the Group’s reorganisation in 2015, nuclear engineering, which was previously grouped together in a single dedicated entity (DIN10), was divided into two new directorates: the DIPNN (Engineering and new-build projects directorate) responsible for new nuclear projects, and the DPNT (nuclear and conventional fleet directorate) responsible for production. The DPNT incorporates the DIPDE (Nuclear fleet engineering, decommissioning and environment division) responsible for some of the engineering for the in-service fleet. This new organisation gives nuclear engineering greater influence within the Group’s board. Its purpose is to improve the control of major projects, including Flamanville 3, and to strengthen the links between the fleet and the engineering teams in charge of the

9 As defined in INSAG 19: “maintaining the design integrity of nuclear installations throughout their operating life”

10 Nuclear engineering division

modifications on existing plants within the context of the General refurbishment, all of which I commend. However, I note that some engineering centres which are now attached to the New build directorate are still carrying out a great deal of work for the in-service fleet: in this situation it will be important to clarify working methods that are as simple as possible (arbitration, exercising Design authority responsibility). I note also that there is a risk of the existing fleet and future reactors becoming distanced from one another, with a possible failure to take operating experience into account adequately in reactor design. I urge vigilance, especially as these changes are happening in the context of the current partial incorporation of AREVA into EDF, which also concerns the engineering teams.In this transitional phase, I would like to draw attention to the importance of those with roles in the previous organisation in enabling the new organisation to continue operating smoothly.

Inspection work

Better incorporation of operations in reactor design

The aim of the EPR NM project is to simplify and optimise EPR design in order to devise a high-power reactor that is safe, competitive and efficient, to prepare for the future of nuclear generation in France and for export. Like the EPR, the nuclear safety objectives of this


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reactor are based on Generation III criteria incorporating what has been learned from the Fukushima accident and formalised in WENRA’s11 safety levels. This solid base will make it a particularly safe reactor.In addition to this design-level safety, I believe that the EPR NM must take account of the operating issues of previous reactors to further improve safety. The desire for optimisation in the EPR NM must therefore apply not only to the design and construction phases, but also to the future operating phase.There are two areas which I believe merit further work: simplicity of operation and ease of maintenance. The design of facilities and the installation of equipment must aim to further reduce the risk of human error, but more importantly, they must limit the work required and make it easier: improved inspectability, simplified site organisation and logistics (cranes, access points, etc.), especially during unit outages.By simplifying the activities of those involved, such provisions will reduce sub-standard maintenance and as a consequence will be beneficial for safety. This could no doubt lead to additional requirements, the costs of which must be compared with the savings to be made during operation, taking care to ensure that the assumptions made are realistic.The incorporation of operating experience and operating requirements in the EPR NM project means involving the operator at an early stage. I believe that the operator must be involved in all aspects of the project now.

11 Western European Nuclear Regulators Association


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OpERATiONAl SAFETy: MixED RESulTS THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

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2 / OPERATIONAL SAFETY: MIXED RESULTS

Hunterston nuclear power plant

The year 2015 saw results stall in the French fleet in several key areas, most notably fire safety.

EDF Energy results improved considerably compared with 2014, including a narrowing of performance between sites.

OPERATIONAL RESULTS

French fleet

I would first like to mention that for the third year running, not a single nuclear safety-significant event rated Level 2 or higher on the INES scale occurred. Compared with 2014, the number of Level 1 INES events remains steady (1.16 per reactor). The total number of Level 0 nuclear safety-significant events recorded (10.03 per reactor) reflects the high levels of detection and transparency achieved at EDF SA. I am mindful, however, of the deterioration observed in several areas, including fire safety and automatic reactor trips. There has nonetheless been a determined response from the sites, led by the DPN, to rectify these issues and I will be monitoring the effectiveness of corrective actions very closely.

In 2015, as in 2014, all sites took on board the recommendations issued as part of the Overall excellence assessment process conducted by the Nuclear inspection department (approximately 75% of recommendations have already been implemented) and the WANO12 peer reviews. I am pleased to report an improvement in the adoption of findings from SOERs13 (77%), which summarise international operating experience on the most significant incidents.

Grounds for satisfaction

In my 2014 report I highlighted the prevalence of nuclear safety-significant events corresponding to breaches of technical specifications. I am pleased to report that considerable progress has been made on this key safety issue. This is due, among other things, to

12 World Association of Nuclear Operators13 Significant Operating Experience Report issued by WANO

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION OpERATiONAl SAFETy: MixED RESulTS

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improved management of operations, thus avoiding excursions outside the safe operating envelope. The Reactivity control guidelines have recently been updated to be more easily understood and played their part in this success. I also note that very few discrepancies were recorded with respect to plant configuration control. Drawn from operating experience of the Three Mile Island accident, this latter point is fundamental in guaranteeing the effective availability of the engineered safety features required in the event of an accident.I am pleased to see a major improvement in the management of unit outage times, particularly for refuelling-only outages, which fell from an average of 10 outage extension days in 2013 to just 2.8 days in 2015. The same is also true for partial inspections outages (VP), which saw a drop from 22 to 9.1 outage extension days. This improved outage management has had a positive effect on operational quality and overall operator peace of mind. At the same time, however, we encountered difficulties during the ten-yearly inspection outages (VD); 55 outage extension days were recorded in 2013, falling to 22.6 days in 2014 but rising again sharply to 47.8 in 2015. Experience sharing at the end of 2015 between sites involved in a ten-yearly inspection outage in 2015 and 2016 was certainly a promising start to addressing this issue. I also want to draw attention to the long-standing low unplanned reactor unavailability rate of 2.48%. This demonstrates the long-term relevance of the maintenance carried out in accordance with the AP 913 method14. The number of outstanding work requests remains low. I encourage everyone to keep up the good work and sustain this positive impact on safety.

1,7

2,48

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1

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3

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6

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

Unplanned unavailability rate

US PWR fleet French EDF fleet

Un

pla

nn

ed u

nav

aila

bili

ty %

Comparison of PWR unplanned unavailability rates in France

and the US

It is also worth mentioning the excellent availability of the engineered safety features (i.e. those of the safety

14 Method designed to increase equipment reliability and enhance system performance

injection system (RIS15), the auxiliary feedwater system and the standby diesel generators). With unplanned unavailability rates of 0.03, 0.01 and 0.03 respectively, the French fleet still ranks amongst the best in the world. This result is testament to operator vigilance in terms of minimising outage periods for servicing or testing this vital equipment so as to prevent the risk or mitigate the consequences of an accident.

Areas of concern

The improvements in fire safety performance made in 2013 and 2014 regrettably did not extend into 2015. The number of fire outbreaks rose from 10 in 2014 to 18 in 2015 and 3 significant fires broke out on sites in service (see Section 6). The fleet’s response has been to analyse the performance gaps and share experience between sites, and I will be monitoring the actions taken by each plant.The number of automatic reactor trips is also on the increase, rising from 31 in 2014 to 38 in 2015. This puts us back at 2009-2010 levels, but is slightly above that of plants in the US fleet based on the same technology. Vigorous action is now required to reverse this trend, especially since the human performance element in these events remains high (approximately 50%).

0,630,71

0,2

0,4

0,6

0,8

1

1,2

1,4

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

US (65 reactors) France (58 reactors)

Number of automatic + manual reactor trips per year and per reactor

Comparison of the number of automatic and manual reactor

trips in PWRs in France and the world

I am surprised by the difficulties encountered in trying to reduce the number of significant events as a result of operation and maintenance non-conformities. In-service non-conformities remain at 2014 levels whilst maintenance non-conformities have risen by 5%. That said, these non-conformities have fewer consequences, which reveals not only a concentrated effort to eradicate non-conformities, but also a more effective rate of detection. These mixed results have been achieved since the campaign to raise the standards in maintenance and operations (the MQME16 project) was launched in

15 Reactor safety Injection System for injecting water into the reactor16 French acronym for Maîtriser la Qualité des activités de

Maintenance et d’Exploitation


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2013. I have seen new impetus given to this initiative, with the recent introduction of an individual tasked with driving these actions forward and coordinating all parties centrally. I look forward to receiving the 2016 results.

Maintenance work

UK fleet

As is the case in France, not a single nuclear safety-significant event rated Level 2 or higher on the INES scale has arisen for several years in the UK.The number of Level 1 events is stable compared with 2014. With 0.47 nuclear safety-significant events per reactor per year, the British fleet continues to achieve better results than the French fleet. This difference can be put down to the different declaration procedures in France and the UK, reflecting the requirements of the respective nuclear safety authorities. Particular mention should be made here of the promising progress made by the UK fleet in compliance with technical specifications, with 1 non-compliance recorded per reactor for 2015 versus 1.53 in 2014.In my previous report, I drew attention to the widening gaps in results between the 8 sites operated by EDF Energy. I welcome the progress made in 2015 and encourage the continued efforts.

Grounds for satisfaction

There has been a net decrease in the number of automatic and manual reactor trips. With 9 automatic reactor trips in 2015 (equivalent to 0.57 trips per reactor per year), the British fleet has returned to 2012-2013 levels and has made substantial progress since 2014 which saw a total of 17 trips, equivalent to 1.17 trips per unit per year. This overall improvement is also replicated for manual trips, which fell from 9 in 2014 to 3 in 2015. I would like to commend the sites on their achievements, particularly in terms of identifying and correcting

single point vulnerabilities (SPVs) as part of the AP 913 equipment reliability programme.There have also been some initial signs of progress in terms of fire safety: no major fires, only one minor fire outbreak and an overall reduction in minor events. This is the result of the work undertaken to improve general housekeeping and equipment reliability. During one of my plant visits, for example, I was shown the long-term oil leak prevention initiative which will involve future plant modifications. I will, however, be keeping a close eye on fire safety over the coming months as it remains the principal common mode risk.The progress made in power generation capability is also worth noting, where unplanned unavailability has fallen to its best rate ever (2.3% in 2015 versus 10.7% in 2014). I am delighted with the groundwork laid regarding equipment reliability, in terms of automatic reactor trips, and work planning, which has also had a positive impact on safety. I have noticed that unit outages have taken longer, but this can mostly be explained by the modifications necessary to the Heysham 1 and Hartlepool boilers.

Areas of concern

The number of alignment errors (2.87) remained similar to last year (2.8 in 2014), but still remains higher than the 1.79 errors recorded for the French fleet. I urge those involved to keep driving the learning initiated between EDF Energy and EDF SA.As with the French PWRs, the availability of engineered safety features at Sizewell B has achieved particularly good results. The work carried out by a Plant manager’s peer group (PMPG) on the AGRs has made sound progress, especially through the proactive monitoring of performance indicators. I am still conscious, however, of the high level of power supply-related events (SSP5 WANO); the unplanned unavailability rate was 0.26% in 2014 and 0.27% in 2015. International feedback on precursor events has also called for vigilance in this area (see the 2014 report). I am also aware of the problems with the quality of maintenance encountered by the British fleet and the work launched to make such tasks more reliable. This is reminiscent of the findings at EDF SA in many respects and is all the more significant as the British fleet is striving to reduce unit outage times and therefore needs to further concentrate on maintenance activities. I recommend that this work, especially given the recently revived MQME project, be carried out in conjunction with French plants.I note that main-population graphite brick keyway root cracking was detected in one of the Hunterston B reactors while conducting a routine inspection during the last unit


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outage. However, this level of cracking is still well below the limits stipulated in the safety case. As mentioned in previous reports, this remains one of the weaknesses of AGRs and merits significant attention.

ANALYSIS OF PRECURSOR EVENTS

Early warning signs or precursor events17 are analysed in-depth worldwide based on operating experience. They are the subject of an EDF SA programme led by the 17 Events for which the conditional probability of core meltdown is

greater than 10-6 per reactor per year Events with a probability greater than 10-4 are termed “important” whilst those with a probability greater than 10-3 are termed “significant”.

Operations engineering unit (UNIE), the quality of which I commend. The improving trend recorded since 2000 is continuing. Over the last period examined (July 2014 to July 2015), 7 precursor events were identified out of a total of 610 nuclear safety-significant events, all graded below the “important” precursor event level. These studies and international operating experience both show that this year again, loss of electrical power remains the main area of focus, accounting for 50% of precursor events. It is therefore essential that the key components in this area are monitored, namely transformers, standby diesel generators and standby turbine-driven generators (see inset).

Two issues related to power supply

Simultaneous loss of two standby diesel generatorsIn 2015, two reactors on a site in the US were in service when a voltage drop on the grid caused an automatic reactor trip and triggered a simultaneous command to restart equipment using the standby generators (two per reactor and one reserve generator for the site). Both generators started up normally on the first reactor and power was duly restored. On the second reactor, however, two anomalies occurred; one with the load sequencer (replaced in 2013) on the first generator, and the other with the speed sensor (modified in 2007) on the second generator, which meant that power could not be re-established. Operators resorted to the reserve generator and the circulation pumps were back in service within 12 minutes.

Prolonged operation on one diesel generatorDuring refuelling in a French reactor, the power needed to maintain fuel cooling in the pond was supplied by the main transformer. At the same time, planned maintenance work, lasting 3 weeks, was being carried out on the auxiliary transformer due to leakage on cooling circuit No.12. Whilst this work was being carried out, a leak was also discovered on cooling circuit No.11. Several non-conformities arose during this maintenance:

• a different type of mounting was used from that identified during planning • work was carried out on cooling circuit No.11 without a specific work package and without taking account of

operating experience from work carried out on No.12. With the main transformer required for operation, along with one of the two diesel generators, the auxiliary transformer was recommissioned despite a new leak being identified in cooling circuit No. 11. This leak worsened over subsequent days and eventually resulted in the unavailability of the auxiliary transformer. The only diesel generator available automatically restored power until the auxiliary transformer was repaired 65 hours later. Tighter equipment monitoring procedures and additional measures to combat diesel generator failure were put in place shortly thereafter.

My analysisNeither of these events impacted nuclear safety in any way and there was a good level of responsiveness from operators and maintenance staff in both cases to implement compensatory measures. The lines of defence-in-depth were, however, breached in both cases due to maintenance non-conformities relating to component qualification, task preparation, technical checks, spare parts management and elimination of defects.


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FUEL PERFORMANCE

Fuel plays a significant role in safety. The fuel cladding, which contains uranium pellets, forms the first barrier between the radioactive material and the environment.I referred in 2014 to the worsening failure rate of fuel assemblies at EDF SA, which increased from 0.11% in 2013 to 0.21% in 2014, and the concurrent rise in handling events, some of which were rated Level 1 on the INES scale. This year I am pleased to report that progress has been made in both these areas.

AGR fuel assembly overview and a fuel element

The fuel assembly failure rate has returned to 0.11%; 9 assemblies were found to be no longer leaktight out of more than 8,267 unloaded in 2015. Work is well

under way on pin design (type of cladding), fuel supplier diversification and enhanced risk assessment regarding the presence of foreign material liable to damage the cladding. There is, however, a need to characterise events precisely and maintain vigilance with respect to the risk of FME18. During my visits, I have noted how well operating experience from 2014 handling events has been taken into account and how involved managers are in this respect. I was particularly impressed with the presentation given by the Operations engineering training unit (UFPI) on the tablet-based refuelling sequence simulation tool, and on the work undertaken by CETIC19. This tool, which takes account of human performance methods, seems particularly relevant.The progress made in the EDF SA and AREVA studies on the deformation behaviour of fuel assemblies was also presented to me. Even though this complex phenomenon may not yet be fully explained, the actions undertaken to make assemblies more rigid and to abandon GALICE20 management seem to be heading in the right direction, resulting in fewer deformed assemblies. However, there is still much work to be done to eradicate this phenomenon, which has the potential to reduce the effectiveness of control rod drops and thus compromise safety.The impact of cladding failure in EDF Energy AGRs is less significant since the fuel can be unloaded quicker. With each failure, the assembly containing an element that is no longer leaktight is unloaded and dismantled. All these complex actions have been optimised to limit the risk of excessive flux at each step. Each element is placed in a leaktight flask stored in a pond before being sent to Sellafield for analysis.The fuel assembly failure rate remains satisfactory with a maximum of 6 elements out of the approximately 40,000 loaded in the AGR fleet over the past 4 years or so. A new type of assembly using robust fuel has been developed over the last 5 years and is progressively being loaded into all the reactors. This fuel’s new pin support grid technology and reinforced cladding allows it to mitigate against the problems of fretting 21 and carbon deposition encountered on some assemblies.I commend the excellent coordination by EDF Energy in this area. All sites now have the same indicators which are thoroughly scrutinised centrally. This central support promotes a cross-site sharing of experience and problem solving.18 Foreign material exclusion 19 French acronym for Centre d’Expérimentation et de validation

des Techniques d’Intervention sur Chaudière Nucléaire à eau Pressurisée

20 Fuel management mode for 1300 MWe reactors intended to achieve high burn-ups

21 Friction between the fuel cladding and the element grid due to the gas flows, resulting in localised wear of the cladding


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3 / NUCLEAR SAFETY CLEARLY PRIORITISED

An operator in the control room

Nuclear safety sits well with the tightening of operational priorities.

We need to go further in simplifying and giving more meaning to actions so as to reinforce nuclear safety.

It is in the field, nearest to the plant and with the plant touchers, where it is essential that progress is made.

NUCLEAR SAFETY ALWAYS TOP OF THE AGENDA

Safety is, and must always remain, everyone’s priority. I am delighted to say that this principle was thoroughly reaffirmed in 2015 on many occasions.The EDF Group’s CAP 2030 project confirms the importance of nuclear energy in low-carbon electricity production “…while guaranteeing the safety and performance of new and existing nuclear technologies”. I also note the executive committee’s intention to monitor an integrated a nuclear safety indicator. The Nuclear generation division’s (DPN) Generation 420 project emphasises the pre-eminence of nuclear safety in France (see box), while in the UK fleet, I have been heartened by

the visibility of the slogan Nuclear safety is our overriding priority on all the sites I visited. WANO’s Follow up of the EDF Energy corporate peer review was a success. Four out of five of the AFI (Areas for improvement) recommendations have been fully implemented, and the fifth is on track.In all the departments visited in France and the UK, whether production or engineering, I am pleased that the nuclear safety priority is thoroughly embodied by the management teams, leaders and first-line managers I met, who communicate it on a daily basis.I also note with satisfaction that the organisations dedicated to managing nuclear safety are working well. At the highest Group level, the Council for nuclear safety

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helps share and define common policies and priorities in nuclear safety. In France, the Operations nuclear safety review committee (CSNE)22 encourages sharing between the DPN sites. The new engineering organisation has led to the creation of two bodies supporting the Nuclear and conventional fleet directorate (DPNT) and the Engineering and new-build projects directorate (DIPNN): the Technical standards committee (CRT)23 and the Safety standards committee (DRS)24 in charge of drafting and ensuring application of the standards respectively. I have also noted the role of ‘Design authority’, now assumed by the Nuclear fleet engineering, decommissioning & environment division (DIPDE), for the operational fleet which relies on other engineering departments, some of which are in the DIPNN.In the UK, the Design authority belongs to the Engineering division and the Nuclear safety committee validates changes to nuclear safety cases at fleet level. The Safety oversight delivery team (SODT), led by a Plant Director, ensures the in-service monitoring of the fleet’s nuclear safety. I am pleased to see how well the periodic reviews carried out by the Nuclear safety review board (NSRB), set up in 2014, are working for each site. Opening them up to qualified experts from outside the organisation is an excellent sharing opportunity.

RESULTS-BASED CONTROL INCREASING

During my visits, I was able to gauge the strength of operational focus both at fleet and plant level. By this I mean the capacity of leaders to focus staff on operations to be undertaken and on equipment, to achieve good nuclear safety results. This approach is, in my view, essential if we are to continue to make progress.In the UK, I noticed intensive use of indicators, doubtless linked to older, established practice. These indicators are displayed in managers’ offices, in the field – where visual management is very well-developed, and in meetings – where the attention given to results is considered to be extremely important. In France, I saw that this approach is developing, especially in the engineering centres. However, there are still not many visible examples of results being displayed in the teams. Use of results in operations meetings is more visible, in both France and the UK. Conversely, I very often hear criticism from managers in France about there being too many meetings, which go on too long and are insufficiently focused on achieving results.

22 French abbreviation for Comité Sûreté Nucléaire en Exploitation 23 French abbreviation for Comité des Référentiels Techniques 24 French abbreviation for Directoire des Réexamens de Sûreté

I encourage following the British example in order to improve meeting organisation and promote visual management.

Generation 420

The new DPN project, Generation 420, will continue until 2025. Its aim is to: “Generate 420 TWh sustainably, without compromising nuclear safety, with a target of less than 25 reactor trips/ year”. It is divided into four areas:Mobilising staff working

in the nuclear sector by simplifying wherever possible, and empowering everyone in strong professions, where operating performance is everyone’s focus.Achieving high operating quality by following the Skills programme and making workers’ life easier: getting it right the first time using a variety of ways of making work safe. Better project management (unit in service, unit outage and multi-year scheduling) will support this.Ensuring longevity of the industrial facility by controlling future work and being involved in regulatory changes. Establish Flamanville 3 as a model of excellence.Encouraging openness by mobilising synergies in the EDF Group, strengthening relationships with overseas French territories, and boosting the Group’s standing on the international stage.

PRODUIRE DURABLEMENT EN TOUTE SÛRETÉ 420 TWH PAR AN

SCOPE FOR IMPROVING LEADER PRESENCE IN THE FIELD

I always place a lot of importance on meeting first-line managers. I was struck by how difficult they find it, especially in the DPN, to create the time to talk unhurriedly with their managers. Among the reasons given, the time spent by the latter in meetings takes them away from the field and prevents them from developing high-quality dialogue that enables shared understanding.In France, an increasing number of sites are setting up dedicated field teams to counter this trend. Taking priority over any other activity, they ensure a significant amount of time can be spent by leaders in the field. At times, teams can spend several whole days in the field, which


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include all management levels and sometimes contract partners. I encourage this type of initiative and, more globally, I invite all plants in the Group to boost manager and leader presence in the field.

COMPARING SITES TO BETTER TARGET SUPPORT

The DPN has set up a system which gives it a good overview of the plants. It provides a sound assessment since it is based on the available feedback (indicators, assessments by the EDF Nuclear inspectorate and WANO, presence in the field). The DPN also includes a self-assessment of each site with regard to performance-improvement enablers. EDF Energy has implemented numerous indicators in all areas as well as a summary document, The safety dynamic, published every three months. In France, no plant appears to be subject to a recovery action plan. Despite a tightening up in performance

across the sites in recent years, I am still seeing variable results which are often associated with the partial, or even poorly understood, deployment of the performance improvement levers recommended by the DPN. In the UK, I was struck by the speed with which performance recovered across the sites in 2015, and it remains to be seen if this will continue into the long term.I note some examples of good practice by the UK fleet in providing help to the weakest plants: • Significant operational support from the corporate

departments • Strong influence of leaders in each area upheld by the

various Oversight delivery teams who are highly focused on performance, challenging sites which fall behind and encouraging sharing of good practice, leading to little victories.

I would encourage everyone to take advantage of the synergy between the two fleets so we can continue to share information on this topic.

Franco-British meeting

SYNERGY WITH HEALTHY PROSPECTS

In both France and the UK, I have seen good progress in the dialogue between the two fleets. This is led by two directors and their teams. Structured meetings are held regularly to update everyone on successes and problems and to develop this interaction on ten identified topics. These discussions, which are clearly visible at managerial level, would benefit from being more integrated at team level.In addition, the quality of these discussions in operations, R&D and engineering is an advantage at a time when new reactors are about to be built in the UK. I will therefore be watching this work very closely.

SIMPLIFICATION IS MAKING SLOW PROGRESS

Like last year, during my visits to the DPN departments, I found that both workers and first-line managers were keenly looking forward to more simplification. For first-line managers, complexity is

synonymous with tedious administrative tasks which take them away from the field. Workers’ complaints mainly concern too many demands, job documentation which does not sufficiently meet their expectations, or the difficulties of change support in keeping up.If I were to gauge the positive effects of focusing our priorities as implemented at the end of 2013 (nuclear safety and management of outages) in the DPN with regard to serenity in the teams, I still detect a keen desire for prioritisation in the engineering centres.I saw the many efforts made to improve this situation, starting with the senior managers of the EDF Group who are making simplification one of the focus points of the CAP 2030 project. The DPN also chose this topic to inspire its staff and set up an action programme combining company-wide and field initiatives, some of which have already begun. As a result I saw the first visible effects at Paluel, the first site involved in the General refurbishment, where the logistics project is making life easier for workers. Similarly, sites which have deployed the nuclear technical information system (SDIN) are starting to reap the benefits of standardised documentation.


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At EDF Energy, I have not heard about the same difficulties, probably due to a more pragmatic, field-oriented approach to problems.Being well aware of how hard this work is, requiring a high level of managerial commitment, I salute the initiatives undertaken already at all levels and encourage everyone to continue to pursue them doggedly.I am weighing up the risk of increasing complexity arising from the reorganisation of the EDF SA engineering division through additional cross-functional processes affecting nuclear safety (controlling margins, treatment of discrepancies, etc.). In 2016, I will closely review how well its implementation is working.

INDEPENDENT NUCLEAR SAFETY OVERSIGHT IN FRANCE

Robust independent nuclear safety oversight at corporate level

In France, I have seen a robust organisation where responsibilities are clearly defined. With the help of his team, the Director for nuclear safety plays his part in reminding the fleet management of such matters. The Operations engineering unit - Nuclear safety performance group (UNIE GPSN)25 offers very effective support to the plants and the fleet management. This group organises the nuclear safety professions nationally and its efforts are appreciated by the plants.

Information-sharing in the field in the UK

25 French abbreviation for UNité d’Ingénierie d’Exploitation - Groupe Performances Sûreté Nucléaire

Well-positioned safety & quality managers

I like to meet the safety & quality managers during my visits. I found them to be balanced, knowing when to appropriately question when they believe a nuclear safety problem is not being resolved in an effective manner, and additionally motivating the local staff responsible for promoting nuclear safety. Always in demand to assist with operational matters (site security, Nuclear rapid reaction force (FARN)26, etc.), I observed that they respond willingly and conscientiously. That said, I would highlight the importance of the post’s initial support and familiarisation.

Respected nuclear safety engineers

On the plants, I saw tight-knit teams of nuclear safety engineers. They are listened to by staff and by management, with whom they are in regular contact. However, this community still lacks experience and maintenance skills: practices such as pairing up a nuclear safety engineer with a maintenance department can help compensate for this shortcoming by encouraging shared experience. Once again, I feel that initiatives need to be taken to add maintenance skills and experienced staff to these groups.

Auditor teams who do not sufficiently challenge maintenance

Last year I detected that a number of audit teams did not provide enough challenge to maintenance, due to a lack of suitably qualified staff. This year, I have seen some progress but not enough in a year where there has still been a large amount of sub-standard work and the volume of maintenance activities is increasing. I did see some examples of good practice - such as integrating an auditor into a maintenance team for several days to observe, understand and challenge what actually goes on – but I repeat my recommendation to strengthen these teams’ maintenance skills.

Nuclear inspectorate (IN) remains solid

I checked that visits and inspections in 2015 had indeed been made and resources were always correctly allocated to this entity, which plays an essential role in improving nuclear safety, alongside the fleet management and site leaders. I noted that the number of sites taking up the IN’s recommendations remains stable at a good level (75%). This result should be compared with WANO’s view following the Peer reviews which recorded 26 French abbreviation for Force d’Action Rapide du Nucléaire


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a take-up rate of its recommendations slightly below 75% (79% in 2014) and compliance with SOERs of 77%, which is improving (68% in 2014).

The Engineering audit unit (MAE) is adapting to the reorganisation

The engineering internal oversight body, recognised by the IAEA Operational safety analysis review team (OSART), is attached to the Engineering & new-build projects directorate (DIPNN). It conducts its activity in coordination with the Nuclear inspectorate in the supervision of joint teams. I have questions, however, about the organisation planned for oversight of the engineering bodies now attached to the Nuclear & conventional fleet directorate (DPNT): the Nuclear fleet engineering, decommissioning & environment division (DIPDE) and its joint teams. I will be paying attention to this and how the skills associated with internal oversight are maintained.

The Internal inspection organisation (OIU)

This body, which is part of the DIPNN, operates in accordance with the legal provisions governing pressure equipment. It mainly covers equipment compliance assessments at Flamanville 3. The IGSNR has verified the independence of these assessments, to which the ASN pays careful attention. I met staff who were competent and motivated, who demonstrated the expected level of independence. Once again, I would like to emphasise the risk of the OIU being increasingly side-lined by an assertive regulatory authority in areas where powers have been clearly delegated. In addition, faced with the lack of understanding of OIU’s role in certain parts of engineering in EDF SA and in certain manufacturers, I am keen to remind us all of the role and independence of this organisation. In early 2016, the OIU will provide feedback on how it has been working: I will be very interested to hear this.

A recognised internal licensing system (SAI)

This organisation was created in 2014 and handles certain requests for temporary changes to technical specifications. After its first year, the feedback is very positive for nuclear safety. I note a particularly stringent level of demands from the teams at EDF SA responsible for processing these exemptions and strong independence of the internal oversight team. I commend the empowering, educational nature of this process: it fosters high-quality discussions with the French nuclear safety authority, helping to create a climate of trust and gives everyone the option to devote resources to their

own priorities. I encourage the adoption of this method in other fields than just technical specifications.

Vigilant attitude at work

INTERNAL NUCLEAR SAFETY OVERSIGHT AT EDF ENERGY

Good standing of the TSSMs

I noted the important role of the Technical and safety support managers (TSSM) on the British sites. They have an extensive brief (nuclear safety, site security and emergency, industrial safety, radiation protection, environment) and much more significant operational and managerial roles than the French Safety & quality manager (MSQ). Nonetheless they fulfil their role of advising the site on nuclear safety well, while being supported by highly-qualified nuclear safety groups.

Robust independent nuclear assurance (INA)

This year I met INA teams on the sites and at the Barnwood offices. This body conducts independent site assessments in a manner different to the French nuclear safety engineers. It also makes several targeted visits (2 to 3 a year on each site) on a given topic, with the support of resident inspectors from other sites. These visits, made by perhaps a dozen inspectors in a particular field, are similar to those made by the Nuclear inspectorate in France during the overall assessments of excellence. They also make three to four joint inspections each year on each site with inspectors from the British nuclear safety authority (ONR).


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Relevant nuclear safety reviews

As mentioned earlier, regular nuclear safety reviews are carried out by the Nuclear safety review board (NSRB) every two years on each site. This arrangement, set up in 2014 and comprising qualified individuals from outside the organisation, was recognised positively during WANO’s Corporate follow up review in mid-2015.

It complements the corporate-level nuclear safety governance run by a director of one of the sites via the Safety oversight delivery team (SODT).In addition to these in-house reviews, I noted the OSART27 visit made by the IAEA28 teams to the Sizewell site. This is the first site visit to be requested by the British government in 20 years.27 Operational Safety Review Team28 International Atomic Energy Agency

MY RECOMMENDATIONS

In France, given the persistently high amount of sub-standard work in maintenance activities, I recommend continuing to strengthen the local Independent nuclear safety oversight teams with regard to their maintenance skills.Internal nuclear safety oversight of nuclear engineering is an important feature of nuclear safety. In the new organisation of the engineering division in France, I will be focusing attention on its sustainability, both in its standing and the skills allocated.In France, initiatives have been set up to ensure prioritisation and simplification. However, I consider that leaders are still tied up in too many meetings which are not time-efficient. I invite senior managers at corporate and plant level to tackle this question of how to give back time to leaders so they can spend it with their teams.EDF SA and EDF Energy now have highly-monitored performance on their sites. To help the weakest plants catch up quickly, I encourage the implementation of efficient, site-specific tools

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4 / RISK PREVENTION: PROGRESS IN FRANCE

Checking when exiting a radiological controlled area

Firmly supported by leaders, risk prevention at EDF Energy is continuing to achieve good results.

In France, the industrial safety and radiation protection results for EDF and its contractors are improving, due in particular to the increasing commitment of leaders.

Shared vigilance, the key to EDF Energy’s success, is a promising way forward to take risk prevention to a new level in France.

ENCOURAGING SAFETY RESULTS

Improved results for the fleet in France

With an accident rate29 of 2.7 for EDF SA employees and contract partners, the 2015 results for the in-service fleet are the best the company has ever achieved (3.2 in 2014). Although they still have some way to go to reach the best international results, they are significant because they have been achieved in a context in which a great deal of work is being delivered. On the sites, I note strong mobilisation of those involved, which has continued over the last three years, based around key rules30 and improvements in the reporting and analysis of near-miss accidents.

29 Rate of lost-time industrial accidents per million hours worked30 Lifting, electrical hazards, falling from height and radiography

I note that the situation still varies widely between sites. Some are achieving good safety results while managing to control their outages well, including major outages. Others, which had average results in 2014, deteriorated in 2015. What is more, contract partners I meet always tell me about differing requirements between sites. It is regrettable that the results gathered site by site by the DPN do not include the data for those teams responsible for carrying out modifications on the sites (teams working with engineering).

Continuing progress at Flamanville 3

The strengthening of the safety measures and the strong commitment of EDF and contractor managers led to a further improvement in the safety results (accident rate of 6.1 in 2015, 7 in 2014 and over 30 in 2009). I particularly appreciate the coordination of contract partners by

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geographical area and the regular updating of site maps indicating areas of higher risk.The current situation at the construction site is marked by the increasing level of overlapping work, for example the assembly of electromechanical equipment, hydraulic tests, the initiation of the start-up tests involving the first pressurisation or energisation of the equipment, and the first filling with gas (nitrogen, etc.). In this start-up phase, I believe the operator must ensure that the safety expectations are as high as possible in order to begin operation under the best possible conditions.I shall pay particular attention to the means of incorporating safety operating experience from the Flamanville 3 and Taishan construction sites as early as possible into the design of the future Hinkley Point site.

Accident during a hydraulic test

This occurred at a site overseas, where although the test was scheduled to reach a final pressure of 223 bar, a valve opened unexpectedly at 125 bar. This sudden opening caused a powerful jet of water to be released. The engineer monitoring the test was hit by the jet and thrown backwards. He was taken to hospital, suffering from concussion and a number of fractures.

All hydraulic tests were suspended following this accident. They have been gradually resumed, taking operational experience into account. The protocol for using equipment at its hydraulic test limits was reviewed, in particular examining the commissioning methods, including those for their control devices.

This accident reminds us of the importance of risk analyses, in particular for the first time equipment is filled with fluid.

Decommissioning worksites: safety must be a priority

The results are improving, with an accident rate of 4.2 (5.7 in 2014). This long-term work requires those involved to remain vigilant over time with regard to this specific industrial sector. On these worksites, systems that are in service (electricity, pressurised air, etc.) exist side by side with the plant that is gradually being decommissioned and dismantled. This special feature of decommissioning is currently well-managed on the worksites that I have visited. I was also pleased to see that the safety requirements are taken into account in the same way as for operating or new sites.

EDF Energy still exemplary

The accident rate remains very low, at 0.4, for EDF employees and contract partners. With excellent results achieved over many years, EDF Energy stands out above other industrial companies in the UK, and is at the top level of nuclear operators worldwide.

SAFETY MANAGEMENT

The Chairman of EDF places health and safety at work at the forefront31 of his concerns. The targets announced by EDF Energy (zero harm) and by the DPN (accident rate less than 2 in 2018) reflect this.In the UK, both in the field and during meetings, I note a clear, visible expression of the safety priority by both management and staff, including contractor partners. In France, I have observed a comparable commitment from managers on some sites, but although mobilisation in support of industrial safety is certainly improving, it is not consistent or visible enough in the field.

A good example of wearing personal protective equipment

I remain convinced that a nuclear safety culture and an industrial safety culture involve the same mind-sets: rigour, prudence and transparency.

Shared vigilance: a new momentum

During my visits to EDF Energy, I noted a very interesting attitude towards safety: everyone accepts being challenged by others and does not hesitate to challenge others. This exemplary attitude of shared vigilance is part of the culture and took ten years or so to bear fruit. I am pleased to see that the DPN is also going down this road, and I invite the engineering teams to also adopt this approach, which will require a great deal of perseverance.31 Re CAP 2030 collective target


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Prevention of behavioural issues and addiction

The year 2015 saw the tragic Germanwings plane crash which reminded us of the importance of preventing behavioural issues and addiction. I believe that such issues will be easier to detect and manage more sensitively if vigilance and information regarding complex situations is shared: colleagues, risk assessors, managers, human resources, occupational health and staff representatives. Having somewhere so people can express themselves freely and be listened to, in particular within teams, is a line of defence that should be developed.

GOOD RADIATION PROTECTION RESULTS

France

The results are improving: the individual dose is continuing to fall, the collective dose is in line with the targets and sensitive areas are managed (red areas, orange areas and radiography).The improvement in the individual dose is continuing, with the average individual dose halving over the last fifteen years (see graph). The number of workers, both EDF and contractors, receiving a total dose of more than 10 mSv is decreasing, with no exposure above 15 mSv over a rolling 12-month period in 2015. This improvement is due to very close monitoring of contract partners subjected to the highest exposure levels (those installing insulation, fitting valves, or carrying out welding or non-destructive testing) with the support of the Operations engineering unit (UNIE) and the Central technical support department (UTO).

0

0,5

1

1,5

2

2,5

mSv

Average individual dose for EDF and contract partners

French fleet

Average individual dose in France over the last 15 years

The collective dose is in line with the target and has fallen slightly (0.71 man-Sv per unit in 2015, as against 0.72 man-Sv per unit in 2014) as a result of applying the ALARA32 approach and in the context of the work 32 As Low As Reasonably Possible

involved in the General refurbishment. Nevertheless, I believe that in the light of international experience (see graph), and in addition to actions to control the volume of work, it is necessary to continue the efforts made to reduce the collective dose by reducing the source term, eliminating hot spots and working on low exposure.

0

0,2

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1,6

1,8

1995 1999 2003 2007 2011 2015

France

US

China

Russia

Collective dose for PWR fleets (man-Sv/unit)

Comparison of the collective dose in different PWR fleets

The annual hourly dose level within the fleet has decreased by 35% over the last ten years, but has hardly changed since 2010 (6.46 µSv/h): 6.20 µSv/h in 2015. It is a useful indication as it takes the radiological environment into account while disregarding the volume of work. This indicator is controlled by reducing the source term, combined with ALARA approaches and improved worksite logistics to optimise the time workers spend in controlled areas.The control of red areas is improving, with no significant radiation protection events in a red area in the operating fleet (4 in 2014). One significant radiation protection event in a red area was however reported on a site that is being decommissioned. In the AMI33, as a result of failure to comply with access requirements while declassifying a cell.The number of significant radiation protection events in orange areas has decreased (29 in 2015, 33 in 2014). An orange area action plan is currently being deployed. The disparity of results between sites calls into question the control of hot spots and the effective use of operating experience. Additional technical support has been provided by the GPRE34 Operations Engineering Unit to several sites where there is an abnormally high occurrence of significant radiation protection events in orange area.Significant radiation protection events associated with radiography have deteriorated in comparison with 2014, with no dose uptake (9 in 2015 and 6 in 2014). The action plan started in 2013 is continuing. The deployment of selenium 7535 sources is making radiography areas

33 Irradiated material workshop34 Risk prevention and environment group35 Type of source with lower energy and a longer half-life


28

smaller. The use of these sources will require particular attention as it will enable work to be carried out nearer to the radiography area in future.

Overexposure of a technician in the US

This radiation protection event, classified level 3 on the INES scale, occurred in 2015 in a plant producing isotopes for medical purposes.When a device transferring a cobalt-60 source got stuck, the manipulator inadvertently removed the source from its shielding. It quickly put the source back into a safe configuration. The whole body dose estimate for the technician operating the device was 169 mSv, and between 2370 and 9500 mSv for his hands and feet. The technician was wearing a whole-body dosimeter.This event reminds us of the importance of using reliable equipment and maintaining a rigorous, prudent attitude when handling radioactive sources.

The radiological cleanliness indicators are broadly stable:• The trip rate of the controlled area exit radiation

monitors is 0.45%, lower than 2014 (0.52%). This result is all the more positive since all sites now have more sensitive radiation monitors

• The trip rate of the site exit radiation monitors is 0.03% (0.028% in 2014)

• 10 significant radiation protection events at site exits (11 in 2014)

• 1 significant radiation protection event involving contamination of an on-site road (1 in 2014)

• 4 significant events involving transport (1 in 2014)Following a significant radiation protection event classified level 2 on the INES scale (contamination detected on a worker’s chin), the DPN reminded all sites of the worksite containment measures and the importance of immediate checks on exiting contaminated worksites.

The UK

The very low exposure level (0.067 mSv/unit) is mainly due to the AGR design. The maximum individual exposure is 7.8 mSv. I would like to highlight the collective exposure at Sizewell B (0.048 man-Sv/unit), which is excellent for a PWR. I note the good results for controlled area exit radiation monitor trips (0.06%).

MANAGEMENT OF RADIATION PROTECTION

A well-established ALARA approach

There are robust measures in place for promoting radiation protection within both EDF SA and EDF Energy, making full use of operating experience from sites and supported by the corporate departments (GPRE Operations engineering unit in France and Radiation protection fleet manager in the UK).At EDF SA, the ALARA approach is well integrated into unit outage projects, but continues to lag behind for projects on running units. I support the process to develop an up-to-date multi-year collective dose profile for each reactor, initiated as part of the General refurbishment. I would like to point out the close cooperation between the operation, chemistry, risk assessment and site support departments. However, I note that there are still not enough processes specific to operational activities, for example taking the dose uptake into consideration during plant configuration operations.At EDF Energy, I note actions in the craft training schools to prepare trainees for specific work on AGR boilers, as well as the extensive involvement of contractors in a partnership-based approach.

Continuing source term reduction

I am pleased to see in France that actions to reduce the source term are continuing, with control of: • The chemistry of the primary coolant system during

outages • The risk of foreign material entering the primary and

auxiliary cooling systems (FME36 process)• Cleanliness of systems (clean-ups)• Hot spots I note the targeted support of the GPRE Operations engineering unit and I would like to emphasise the need to increase coordination between crafts and projects on-site. I also note the benefit of the CADOR37 process, which is designed to optimise the installation of radiological protection.

Technical innovation for radiation protection

In France, the deployment of radiation monitoring stations has begun, but it will not be completed for some time (2018). I also note many activities supported by EDF R&D:

36 Foreign Material Exclusion37 Decision support code for optimising radiation protection


29

• Better characterisation of the source term to optimise chemical clean-ups

• Virtual visits of the reactor building to improve preparation for work. After an initial demonstrator in 2014, the deployment in France is planned from 2016

• Studies to reduce staff exposure during decontamination operations, in particular when decontaminating ponds

• Automation of operations involving exposure to high doses in the context of the General refurbishment and decommissioning projects

I encourage these approaches which promote taking account of operating experience from worksites and listening to contract partners, who can contribute to innovation through their practical experience.

Checking the radiological cleanliness of a transporter

Gradual deployment of EVEREST in France

I visited Ginna, the oldest PWR in service in the US, which first went critical 47 years ago. It has been operating in

a mode comparable to EVEREST38 in France since start-up: staff can enter radiological controlled areas wearing ordinary work clothes. I would like to underline the benefit of introducing this, which is designed to reduce contamination at source and to encourage workers to act responsibly. It helps to keep reactors clean, and makes them easier to operate and then decommission.Exchange visits in 2015 between sites which have introduced EVEREST have encouraged the sharing of best practices with the help of the GPRE Operations engineering unit. Flamanville 3 will start up in this mode and a 900 MWe site is planning to adopt it. I would like to stress the pragmatic approach of the fleet in which each site is free to implement EVEREST according to its own specific radiological history, its industrial activity and its capacity to take on the considerable commitment of operating such an initiative.

Restoring radiological cleanliness in AGRs

The EDF Energy sites operate based on principles similar to EVEREST. I commend the work undertaken to increase standards of cleanliness in AGRs. Sharing experience between EDF SA and EDF Energy on the ergonomic design of areas must improve the separation between incoming and outgoing flows of workers in controlled areas (“forward flow” principle). I noted the feasibility study for the gradual installation on a case-by-case basis of walk-through radiological scanners at site exits at EDF Energy.

38 EDF project to allow workers to enter controlled areas wearing ordinary work clothes

MY RECOMMENDATIONS

The leadership and the commitment of leaders is vital for risk prevention. I recommend greater sharing of industrial safety experience between leaders of the EDF SA and EDF Energy sites.Shared vigilance is an effective lever for strengthening the safety culture. In France, I call for this approach to be supported at all levels, involving stakeholders, EDF and contract partners.International comparison has shown that there is room for improvement regarding the collective dose in France. I encourage the DPN to implement initiatives to reduce this dose.


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REiNFORCED EMERgENCy pREpAREDNESS pOST-FukuShiMA THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

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5 / REINFORCED EMERGENCY PREPAREDNESS POST-FUKUSHIMA

FARN deployment exercise

The EDF Group has long been committed to ensuring that procedures and plans are in place to respond to a nuclear accident and mitigate its consequences.

The effectiveness and credibility of these measures are underpinned by regular drills and team training on how to deal with extreme situations.

In the wake of Fukushima, the Group consolidated its emergency response strategies for addressing the most severe external hazards liable to affect all reactors on a single site.

Nuclear operators take emergency planning and preparedness very seriously since they represent the last line of defence in depth. They are the subject of specific recommendations in IAEA INSAG 2239.

ROBUST NATIONAL EMERGENCY RESPONSE ORGANISATIONS IN FRANCE AND THE UK

The EDF Group set up emergency preparedness plans as soon as the very first nuclear plants were

39 Recommendations from the INternational Safety Advisory Group on emergency preparedness

built. These plans have been updated regularly and are now well-proven.In France, such measures are based on a rapidly-deployable centralised organisation. This structure unites EDF SA’s entire chain of command and the technical expertise essential for handling a nuclear emergency. The company’s engineering centres (UNIE, SEPTEN, etc.), are therefore heavily involved in emergency planning. Similarly, AREVA is organised to deploy the necessary accident response expertise on EDF SA’s behalf.This emergency preparedness set-up also provides a strong link to the ASN, IRSN and the authorities responsible for public protection.

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION REiNFORCED EMERgENCy pREpAREDNESS pOST-FukuShiMA

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The same level of cooperation is also mirrored in the UK where similar close links have been forged between EDF Energy, the ONR40 and the public authorities.

LESSONS LEARNED FROM FUKUSHIMA

The nuclear accident on 11 March 2011 in Japan underlined how important it was for both the operator and the public authorities to have a well-structured, emergency preparedness plan in place with properly trained teams and suitable resources41. It especially highlighted the need for far greater consideration of the potential impact of external hazards affecting all reactors on a single site, with the simultaneous loss of power supplies and reactor cooling systems.In France, the post-Fukushima stress test requirements issued by the ASN in 2012 include significant equipment modifications (generators, feedwater supplies, emergency response centres, etc.), some of which were to be implemented within very short time frames. They also stipulate new emergency preparedness requirements, including the set-up of a Nuclear rapid reaction force (FARN42).In the UK, although the approach adopted by the ONR invokes similar principles, the high thermal inertia of AGRs allows for substantially longer response times and thereby reduces the need for equipment modifications and organisational changes. All measures in both countries will allow the Group to meet its objective that “no severe accident should result in the long-term contamination of extensive areas of land”.

ACTIONS IN FRANCE

Nuclear rapid reaction force (FARN)

Back in spring 2011, EDF SA sent the ASN a proposal to create a rapid reaction force, with its mission being to restore cooling of the reactor(s) involved in an accident within 24 hours. Dedicated EDF teams would be responsible for reinstating water and power supplies and returning the reactors to a safe configuration. This proposal was ratified by the ASN.As early as 2012, EDF SA also updated its emergency planning standards which now make greater allowance for severe weather events and include response plans for dealing with multiple reactors involved in an accident on a single site.

40 Office for Nuclear Regulation, the UK’s nuclear safety regulatory authority

41 See WANO SOER 2013-2 Rev 1, Post-Fukushima Daiichi Nuclear Accident Lessons Learned

42 French acronym for Force d’Action Rapide Nucléaire

FARN - The Nuclear rapid reaction force

The FARN comprises 330 technicians and engineers all of whom took part in a total of 85,000 hours of basic training between 2012 and 2015.In the event of a nuclear accident, each regional service can deploy a rapid reaction force to the site in question.Each rapid response team comprises a 14-strong group and an emergency response convoy including:

• two 4-wheel drive vehicles• two or three low-loaders• one or two trailer transporters

which is equivalent to a transit capacity in excess of 130 tonnes of equipment (pumps, generators, pipes, power supplies, lighting, etc.).

EDF gradually rolled out these measures on sites between 2013 and 2015. I am pleased to say that the FARN is now deployed across all sites in France as of 1 January 2016. This centrally-managed force is an integral part of EDF SA’s emergency preparedness plans. I would like to specifically highlight the company’s responsiveness and efficiency in setting this force up in just over 3 years. It not only brings together more than 330 trained professionals, but encompasses a range of high-level equipment, including helicopters provided under an agreement with the French national grid company RTE, more than 50 dedicated vehicles, a satellite emergency communication system, and 4 new buildings on each of the regional bases.I was able to witness the force in action during a recent plant training exercise and was impressed by both the equipment and the professionalism of those involved who breathe life into this new force with such enthusiasm. The company’s choice of equipment and resources has also been significant in making this initiative a success.I was particularly struck by the make-up of the FARN teams, which comprise technicians and engineers who spend 50% of their time at a designated plant. Whilst this ensures that teams have the necessary qualifications, I recognise that the long-term administration of such a work allocation system is no mean feat. I have also noted the concerns expressed by FARN teams with regard to their conditions for returning to their plant role once their secondment is complete. The response to these expectations will be key to renewing team skills in the coming years.Numerous actions have been organised by the staff of the FARN to promote international openness and comparison of best practice, especially with the US. I had the opportunity to visit one of the US emergency response centres in Phoenix, Arizona. The robustness of the system


33

put in place in France in the wake of Fukushima is, in my opinion, unparalleled worldwide.EDF SA’s engineering support plans to take into account this high-performance severe accident emergency response system as a means of better supporting nuclear reactor safety cases. Although this is an entirely credible proposition, I advise that a thorough assessment be made of the potential destabilising implications that an extension of FARN’s remit could have on this relatively new set-up.

FARN exercise at the Civaux site

Reinforcement of operations teams

The number of permanent resources assigned to reactor operations teams is set to increase to address accident conditions which could affect more than one reactor on a single site. This investment in several hundred extra staff and their corresponding extensive basic training will be staggered over several years, and is planned to be fully deployed by 2020.

Construction of emergency response centres

Every plant will have its own emergency response centre, appropriately sized and adequately robust (1,250 m², 3-floor, earthquake-resistant containment buildings). The first is being built on the Flamanville site. This major investment reflects the importance that EDF attaches to emergency planning measures.

ACTIONS IN THE UK

Deployable back-up equipment

EDF Energy’s 14 AGRs have an advantage over PWRs in terms of response times and thus do not require measures comparable to the French FARN. In the wake of Fukushima, EDF Energy nevertheless set up a back-

up system based on mobile equipment known as deployable back-up equipment (DBUE).

Deployable Back Up Equipment

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Hunterston BTornessHeysham 1 and 2HartlepoolSizewell BHinkley Point BDungeness B

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Map of deployable back-up equipment sites in the UK

All the necessary technical back-up equipment (generators, pumps, means of communication, HGVs, mobile emergency response centre, etc.) is assembled at 4 regional bases located near EDF Energy’s 8 nuclear sites (including one dedicated base for Sizewell B). These resources are deployed by EDF Energy TSG43 in conjunction with the contract partner responsible for each of the regional bases.In contrast to the FARN, it is plant personnel who are responsible for deploying back-up equipment once it has been installed on site by TSG, since TSG does not have the necessary competence to take control of reactors during accident conditions. Two actions remain to be implemented before mid-2016; issue of the update to the Emergency preparedness handbook and installation of the emergency back-up connection points at Sizewell B.

Construction of a new emergency response centre

In 2014, an off-site emergency response centre housing a dedicated regional base and local emergency centre was built for Sizewell B, EDF Energy’s only PWR. Plans are now under way to provide the future Hinkley Point C site with a similar facility.

43 The Turbine Support Group is also responsible for the maintenance of EDF Energy turbine / generator plant


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Construction of the Flamanville emergency response centre

TEAMS TRAINED TO DEAL WITH EMERGENCIES

The quality and frequency of nuclear emergency response training is subject to increasingly stricter requirements both at corporate and plant level, involving the operators, public authorities and safety authorities.In 2015, my team and I observed an emergency response exercise (an on-site nuclear emergency plan, PUI-SR44) from each of the command posts mobilised (EDF, ASN, IRSN, local authority) as well as a FARN exercise.I was struck by the know-how and effective cooperation between all parties involved and was particularly impressed by the experienced EDF SA corporate teams who receive regular training (more than 10 national exercises a year) and can very quickly offer support and advice to site teams. I am also pleased by the strong role of simulators which now offer more realistic exercise scenarios thanks to closer collaboration between EDF SA and IRSN scenario experts.At EDF SA and EDF Energy alike, every nuclear facility conducts a dozen or so site exercises a year, covering all aspects of radiation protection, fire safety, environment protection and site security. Although the effectiveness of these emergency plans has been proven by how well real emergency situations have been handled over recent years, I am aware that WANO has identified areas of improvement regarding the diversity and complexity of the scenarios used in plant exercises in France. Similarly, although progress is being made with on-site resource deployment exercises, all too often both WANO and EDF’s Nuclear inspection department are critical of how they are managed at plant level. I believe this to be a matter for concern.FARN teams in France have undergone intensive training, completing a total of 21 exercises in the 3 years they have been together and validating the measures across 15 plants in the fleet. Added to this are smaller-scale ongoing training exercises designed to refresh skills. The 44 French acronym for Plan d’Urgence Interne – Sûreté Radiologique

importance of operating experience amassed from these exercises and real-life situations cannot be overlooked. There is still room for improvement at both plant and corporate level and leveraging the expertise of the on-site emergency response teams should provide an effective means of doing so. Making greater use of international operating experience should also be a priority.There is still plenty of scope for improvement on the part of DBUE teams in the UK. Although their mission is primarily one of logistic support, only 3 exercises have been carried out in the past 2 years, so not yet covering exercises on all sites.Emergency preparedness is becoming increasingly important within the Group, not just in terms of nuclear safety, fire safety and rescue, but also in relation to site security and the environment. There has been considerable interest in conducting exercises which address all of these issues and I welcome the actions taken on individual sites.

RELATIONS BETWEEN EDF SA AND THE PUBLIC AUTHORITIES

In France, operational relations between the operator and the public authorities is critical to nuclear emergency planning. The French government Nuclear risk management support team (MARN45), established in 1995 with the support of the ASN and EDF SA, is tasked with drawing up special nationwide contingency plans (PPIs46) and supporting local authorities to plan and carry out emergency response exercises as they would in real-life situations.I want to highlight EDF SA’s sustained efforts to keep this entity running smoothly; a special advisor from EDF has now been permanently appointed to the support team. MARN helps promote the incorporation of operating experience into PPI updates and, more generally, monitors the degree of commitment from local authority departments in this respect. I am aware that some budgetary decisions made by regional government agencies have the potential to undermine the power of these teams.I also urge plant management and emergency response teams to forge closer links with the local authorities, specifically local council leaders and officials from the interdepartmental service for civil defence and civil protection (SIDPC47).

45 French acronym for Mission nationale d’Appui à la gestion du Risque Nucléaire; French government office attached to the Ministry of the Interior

46 French acronym for Plan Particulier d’Intervention, an emergency response plan drawn up by the relevant local authorities in France

47 French acronym for Services Interministériels de Défense et de Protection Civile, which have staff in each prefecture


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I am pleased to report that the close collaboration between EDF sites and other local agencies involved in emergency planning in the field (such as the fire and rescue services, hospitals and the ambulance service) has been formalised in binding ongoing agreements.I am monitoring the current European discourse, particularly under the aegis of WENRA48 and ENSREG49, about extending the scope of PPIs (to cover supply of iodine tablets and evacuation of local populations). I understand the need to harmonise these measures in Europe, but I question the relevance of expanding them to a point where they may translate poorly in reality. Numerous measures have already been taken or are in the process of being deployed to ensure that no severe accident results in the contamination of extensive areas of land in the long term. Moreover, it is clear that mass evacuations can also put the local populations at risk, as came to light in the Fukushima accident.

INTRA - A UNIQUE ECONOMIC INTEREST GROUP

In the wake of the Chernobyl disaster, EDF SA, AREVA and the CEA decided to set up an economic interest group (EIG) called INTRA in 1988. The group pools resources capable of being deployed in an emergency if a similar situation were to occur in France. The Group is based at the Chinon NPP and operates a fleet of remotely-operated equipment capable of being deployed in less than 24 hours in the event of a large-scale nuclear accident. It employs 20 permanent staff from the three founding organisations and works together with a team of 25 volunteers trained in how to operate this equipment who are stationed at plants across the French fleet.48 West European Nuclear Regulators Association49 European Nuclear Safety REgulators Group

The volume and type of equipment being used by INTRA is impressive. Their fleet includes bulldozers, radiation mapping drones and robots designed to operate in hostile environments and capable of climbing stairs. The wealth of innovative technologies is apparent, as is the importance of the qualification work accomplished since the group’s inception. I was also shown the operator training system, which is awaiting final approval, and now features a robot control simulator.I am pleased that such a group exists, although its scope of action is currently limited to France. I would encourage EDF Energy to engage with the INTRA group whose tasks could potentially be extended to cover EDF Energy facilities if our CEA and AREVA partners agree with such a proposal. Some equipment does in fact need to be renewed. Prior to replacing any equipment, it would be well worth discussing how it may be possible to incorporate the tasks and scope of this valuable entity into the Group’s wider emergency planning measures.

INTRA EIG: environmental monitoring and locating robot

MY RECOMMENDATIONS

The EDF Group has an emergency preparedness plan which sets a high standard and constitutes a solid last line of defence in depth. I urge both plant and corporate management to maintain their focus on this topic so commitment is maintained by all parties involved at all levels. I also encourage everyone to resort to more networking across fleets so better use is made of internal and external operating experience.Emergency response team training has been the focus of increasing attention within the Group in recent years. In France, I encourage building on the progress already made and to make emergency exercises more challenging while improving on-site resource deployment drills.At EDF SA, the FARN further consolidates the robustness of the company’s emergency preparedness. I would like to draw particular attention to the sustainability not only of the skills offered by this new entity, but also of its remit over the years to come.


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FiRE pREvENTiON: STill A WEAk liNk THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

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6 / FIRE PREVENTION: STILL A WEAK LINK

Fire-fighters and EDF staff taking part in a fire drill at an NPP

Fire is the most prevalent industrial risk, which is why the EDF Group takes this issue very seriously in terms of nuclear safety.

Our fire-fighting procedures are well-organised and effective, the EDF teams are well trained and working links with the external emergency services are constantly improving.

Within the Group, the scope for improving the condition of sites and the fact that there are still too many outbreaks of fire illustrate shortfalls in the culture of fire prevention. Synergies between EDF SA and EDF Energy provide an opportunity to make further progress.

Controlling the risk of fire remains a challenge for any nuclear operator, whether on operating, construction or decommissioning sites. How the facilities and equipment are designed, together with how they are used (organisation, training, prevention), all provide ways of countering the fire risk.

NOTEWORTHY EVENTS IN 2015

In France, three major fires occurred in plants in service:• The first occurred in the non-nuclear area of a plant

when the titanium in the condenser caught fire during cutting operations. This had never happened in the

French nuclear fleet before (see box). I was able to gauge the extent of its impact first-hand during a visit there. It is currently the subject of an in-depth analysis.

• The second also occurred in the non-nuclear area of a facility when the electrical cabinet of an alternator exciter caught fire.

• The third occurred in the nuclear part of a plant and concerned the auxiliary chemical & volume control system (CVCS). Though it did not impinge on nuclear safety, this event nonetheless caught my eye because the hydrogen risk was insufficiently factored into the task at hand and the external emergency services were not alerted quickly enough.

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION FiRE pREvENTiON: STill A WEAk liNk

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METAL FIRE ON A CONDENSER

In the early evening, a fire broke out in the turbine hall (non-nuclear area) of a plant that was shut down for maintenance. During the re-tubing of a condenser, one of the condenser compartments containing more than 95,000 titanium tubes, caught fire.

There were no consequences for nuclear safety or the environment, nor any injuries, but it did cause a great deal of damage. An on-site emergency plan for fires outside the controlled area was put into action and the external emergency services were called.

The fire seems to have been caused by the ignition of the titanium dust resulting from cutting the tubes. This ignition would have been initiated by the plasma torch used to cut the steel tube holders. The fire then spread to the titanium tubes.

Still ongoing, the analysis of this rare event (metal fire) will provide extremely useful operating experience not only for the work planning and implementation phases, but also for fire management.

I also want to mention a fire that occurred on a decommissioning site during a metal waste conditioning operation. Though there was no environmental impact, it is a reminder to us all that this type of work must equally receive our careful attention.Although these fires were very effectively brought under control thanks to the professionalism and level-headed composure of the plant’s own staff and the local fire and rescue services (SDIS), they should remind everyone of the reality and potential consequences of this risk.Within the Group, I also noted that the number of fire-related events (outbreaks of fire and other anomalies) in 2015 fell at EDF Energy and rose slightly at EDF SA. In both fleets, an analysis of precursor events shows that the main cause has predominantly been electrical equipment (over 50%) for many years. In France, human error is also a significant cause (25%). In the UK, although the number of oil leaks is still too high, I see that the number of outbreaks of fire due to these leaks is falling. Efforts to improve equipment reliability and promote best practices (more rigorous worker behaviours, a feeling of ownership) have also produced encouraging results in this field.

A ROBUST FIRE-FIGHTING SYSTEM

Within the Group, significant efforts have been made over the past decade to control the risk of fire, especially in the field of fire-fighting.

Fire-fighting equipment in a UK power plant

Numerous improvements

In France, I have seen the following improvements:• Close links with the local fire and rescue services,

which continue to grow within the context of agreements which are regularly renewed or expanded. Personal commitment of the management, numerous drills and reciprocal visits to heighten familiarity with the facilities, are a good illustration of this tighter relationship. At Belleville for example, plants are also encouraging staff to become volunteer fire-fighters

• Creation of first-line response teams comprising staff from the operations teams and sometimes the site security teams, who are on-site 24 hours a day and are well trained

• More frequent training and drills completed by the teams and involving more extensive scenarios (including a major fire), based on operating experience

• Positive role of the Fire safety & prevention training institute (IFOPSE)50 in training EDF SA staff responsible for preventing and fighting fires

• Major programme of preventive maintenance and upgrading of fire detection and fire-fighting equipment, implemented across the board

• Recruitment of fire safety supervisors (CAI) at each NPP who work for the nuclear safety & quality function

• Contribution of fire brigade officers (OSPP), who have been in place on each NPP for more than five years. Highly skilled, motivated and well integrated into the plants, they simplify operational relations with the local fire and rescue services

50 French acronym for Institut de FOrmation à la Prévention et à la SEcurité, a company owned by EDF.


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Fire safety: 15 years of continuous improvement at EDF SA

• 2000-2006: The fire action plan deals with weaknesses in facilities and reinforces their initial design (investment of several hundred million euros)

• 2005: Start of the Fire risk management (MRI) campaign, which ended in 2012. This marked the beginning of consolidated agreements with the local fire and rescue services

• 2006: Strengthening of regulatory changes with the environmental ministerial order called RTGE1

• 2007: Construction of the EPR begins with a revised fire prevention standard (ETC-F2)

• 2009: Each NPP is given its own professional fire brigade officer. Refurbishment of the fire-fighting water systems and start of a programme to upgrade the fire detection system (still ongoing)

• 2012: New regulatory standard laid out in the INB3 ministerial order, consolidated by the publication of the ASN decision on fire prevention in 2014

1 General technical rules intended to avoid and mitigate the off-site interferences and hazards associated with the operation of licensed nuclear facilities

2 EPR Technical Code for Fire protection3 Licensed Nuclear Facility

In the UK, many of the positive improvements made echo those in the EDF SA fleet and I was impressed by some specific examples of good practice: • A Fire safety coordinator, attached to the Technical &

safety support department, who is recognised on the site and supported by effective fleet leadership via the Fire safety fleet manager

• Training and practice facilities for staff on site or at fire brigade training centres.

Issues requiring attention

In an overall picture where progress is being made, which inspires confidence, some issues have nonetheless attracted my attention. In France, I noticed flaws in the implementation of the first-line response procedures, such as: not systematically calling 1851, delay in calling the external emergency services from the control room, and not adhering to the timescale for first responses. These are weaknesses

51 Use of the dedicated telephone line so the call is routed correctly and immediate mobilisation of the control room

which need to be analysed and corrected. It must be stressed that the effectiveness of EDF SA’s fire-fighting procedures relies greatly on how quickly the local fire and rescue services are contacted. The same goes for assisting the injured.I have also noticed that recruiting fire brigade officers has proved hard in certain regions.In the UK, I must underline how much work remains to be done to improve the reliability of fire detection and suppression equipment. These essential upgrading actions are justified by the initial design of the AGRs, the ageing equipment and an increased level of expectation. They need to be actively implemented.

A fire engine at a nuclear plant

PREVENTION: NEED FOR NEW IMPETUS

The old adage Prevention is better than cure is particularly relevant in the field of fire risk management. Prevention is involved at every stage of the process: design, construction, operation and decommissioning.

Prevention needs more momentum

The Group’s plants seem to be struggling to make significant progress in this area.In France, I still believe that the guard has dropped and a box-ticking approach has taken root when it comes to applying prevention measures. I particularly noticed:• Scope for improved management of fire loads

(conditions for using solvents, packaging, excess grease, soaked lagging, work area tidiness, waste left lying around, etc.)

• Incomplete risk analyses upstream of sensitive activities (cutting, grinding, welding, etc.)

• Management of fire permits, which is still difficult to oversee from the control room

• Insufficient adherence to fire compartmentalisation rules (integrity of fire doors, ducts, use of cat flaps, etc.)


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• Insufficient adherence to the rules in permanent work areas (laboratories, workshops, etc.)

My observations have been confirmed by the assessments conducted by the EDF Nuclear Inspectorate and WANO, who have highlighted recurrent shortcomings for several years.The enthusiasm of recent years, underpinned by projects (MRI,52 OEEI53) which have been implemented in each NPP, is running out of steam. Although it led to undoubted success in terms of general organisation, fire-fighting and training, it left prevention on the sidelines. I would like to see discussion of new initiatives to revitalise this dynamic.The UK is also faced with similar problems, as discussed in my previous reports, which are confirmed in assessments conducted by the EDF Energy internal nuclear safety oversight teams (INA, NSRB) and WANO. In particular, I noticed a level of housekeeping which has progressed in 2015, notably through information-sharing with the DPN on housekeeping standards. However, it is still falling short of the best standards, for example oil leaks and temporary storage sites which are proving inadequate. Although I am pleased that some proper action plans are being implemented by the plants, I think that, as in France, there is room for more proactive initiatives.

Fire prevention culture: a lever for driving up standards

I find that too many of the performance gaps I observed in the plants are proof of insufficient attention to the fire risk. Although there has been significant progress in how the risks are perceived with respect to nuclear safety and radiation protection in recent years, the risk of fire is still not yet perceived at the same level. The parallel with industrial safety in France is striking.I would like to stress the importance of the plant operators, who are “the eyes and ears” in the field for the control room operator. Day and night, they ensure facilities remain compliant and constitute a strong defensive line in the event of a fire. It seems to me that this role is currently better recognised in the EDF Energy plants.This also affects maintenance technicians, both from EDF and our contract partners, who must take fire prevention requirements into account when maintaining the condition of worksites. I am aware of the problems this represents in a context of much increased levels of maintenance work (General refurbishment, busy partial

52 French abbreviation meaning fire risk management (a DPN project)53 French abbreviation referring to a Better housekeeping campaign

(a DPN initiative) which is now called MEEI: Maintaining exemplary housekeeping

inspection outages, ten-yearly outage inspections). I also wish to draw attention to decommissioning sites in France, which represent a major fire hazard and must be treated with the same caution.

EDF staff and the fire brigade cooperating during a drill

Everyone should consider the benefits that could be obtained if all parties focused on becoming more familiar with the risks and countermeasures involved. It would probably be one of the most effective levers in changing behaviour and aiming for what the Anglo-Saxons call Fire safety awareness for all. I wonder how effective the training methodology is with regard to this requirement, considering its requirements were revised in 2014. I would also like to emphasise the role of first-line leaders in promoting and consolidating these changes and developing a prevention culture. I hope to see the initiatives launched in these different fields during 2016.

Scope for an improved organisation to foster better cooperation

Fire prevention relies on the contributions of many people.In France, I wonder about the way responsibilities are split between a large number of people (deputy director in charge of fire protection, safety & quality manager, fire safety supervisor, risk prevention department, fire brigade officer, facility housekeeping manager, etc.). These players often express a desire for stronger coordination which is easier to understand. I often meet fire safety supervisors on the plants who tell me how isolated they feel and how much they need support.I also wish to stress the importance of corporate-level governance, acknowledged by those in the field for its capacity to offer the necessary support and advice, and also its role in driving progress with regard to modifications and corporate-level improvement initiatives.In the UK, the plants appear to follow a more simplified organisation, led by the Technical & safety support manager (similar to the Safety & quality manager at


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EDF SA). With the appropriate resources, this manager is able to establish fire prevention standards and ensure overall coordination of their implementation.Again, corporate-level governance is welcomed by the plants, under the leadership of the Fire safety fleet manager. The implementation in recent years of a Fire safety focus index caught my attention: this user-friendly tool, developed with the fire safety coordinators from across the fleet, is used to assess performance and the level of priority to assign to areas of fire prevention.

Analysis of events: a line of defence in need of strengthening

Within the EDF Group, it is apparent that too many fire events are repetitive in nature. In particular,

the stubbornly high number of outbreaks of fire caused by failure of electrical components (coils, contactors, cabinets, etc.) deserve more attention. In the French plants, gaps caused by human performance errors are worthy of reflection. It is important to conduct a rigorous analysis of these faint signals to clearly define the causes and reduce their occurrence. To this end, I would encourage more widespread use of the event analysis methods and practices used in nuclear safety.I would like to emphasise a significant reduction in oil leaks in recent years at EDF SA, and more recently at EDF Energy. This encouraging success, which can be mainly attributed to component reliability analysis, illustrates how effective this type of approach can be.

Fire safety focus index at EDF Energy

This index is used in all the plants and is updated monthly. It allows the plants to compare how well they are controlling their fire risks and to identify examples of good practice. The data fed into this index is maintained by each plant. It is used by the various operational committees responsible for fire prevention (Safety oversight delivery teams, Fire safety action teams) to manage their improvement initiatives. The data used to calculate this index comprises:

• Number of fire loads identified by the plant• Number of oil leaks• Frequency of facility housekeeping inspection visits• Reliability of detection and fire-fighting equipment• Outstanding defects on fire safety equipment• The number of unplanned unavailability losses (as defined by the technical specifications) due to equipment or

actions related to fire prevention.This index provides an excellent overview of plant performance in fire safety and helps target the areas where support is required.

MY RECOMMENDATIONS

The EDF Group has just come through a cycle of significant improvements in fire safety (training, fire-fighting, etc.), and the prevention approach to this major industrial risk needs to be revitalised in light of its significant potential impact on nuclear safety. Within the company and at contract partners, fire prevention theory has not yet been sufficiently translated into behaviours. I encourage senior managers at corporate and plant level to take the initiative and develop a prevention culture.In France, I wonder about the way responsibilities are split between people in the various fire prevention services on the plants. I invite the plant management team to clarify this situation so the organisation is easier to understand, and to strengthen coordination between departments. Dialogue through benchmarks and evaluations between NPP operators is an area for improvement. In recent years, EDF Energy has benefited from this dialogue with EDF SA and I encourage the management of both companies to continue pursuing this avenue as a way of making progress in the key area of prevention.


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CONTiNuOuS iNvESTMENT iN TRAiNiNg AND CAREERS THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

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7 / CONTINUOUS INVESTMENT IN TRAINING AND CAREERS

Full-scale simulator at the Paluel campus in Normandy

Nuclear safety relies first and foremost on the competence of the workforce.

Leadership commitment is vital in developing these skills, supported by the considerable resources that the EDF Group devotes to training.

In light of the recent recruitment drive, developing attractive career opportunities and motivating employees merits greater attention.

Jobs in the nuclear industry demand long periods of highly specialised initial and continuous training. Control room operators, for instance, follow an initial 2-year higher-level training programme and are then required to refresh their simulator training annually as recommended by international standards. This requires substantial investment in training and a coordinated recruitment strategy.Following the warnings of my predecessors and indeed myself on skills development and renewal, I am pleased to report that the recruitment and training effort has been sustained at both EDF SA and EDF Energy.

LEADERS WHO ARE COMMITTED TO ENHANCING SKILLS

In France and the UK alike, there is a far-reaching vision with clearly identified pools of resources for critical jobs.I cannot stress enough how important the role of leaders is in developing the skill base of their teams, from identifying needs and selecting the appropriate training methods to assessing the level of competence reached.I am pleased with the degree of ownership exhibited by leaders, examples of which include the Skills programme

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION CONTiNuOuS iNvESTMENT iN TRAiNiNg AND CAREERS

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rolled out at the DPN and the Systematic approach to training (SAT) at EDF Energy.

Well-coordinated development of skills

Skills and training are the subject of regular assessments by the Nuclear safety council (CSN). EDF SA and EDF Energy both have skills and training committees which are operational at all levels, not to mention well-established employment and skills plans in place.The recruitment policy is well-structured and I am pleased to say that it spans international borders. I would encourage leaders in France and the UK to recruit candidates who have completed an apprenticeship or similar form of vocational training whereby young people gain hands-on experience under the tutelage of experienced instructors. “Co-recruitment”54 is practised in limited numbers, especially with R&D.I note the desire to recruit experienced personnel; this serves not only to boost the overall level of competence but also helps balance the age profile of the workforce (see chart below).I have seen presentations during my visits illustrating how well key job networks are coordinated within the various divisions with EDF SA (DPN, Nuclear fuel division (DCN55) and Engineering) and EDF Energy.

1200

1000

2014 2005

800

600

400

200

018 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 62 64

Evolving age profile at the DPN

Evolving age profile at the DPN

Of particular note here is the important role played by the Skills advisory centre at the DPN. Under the supervision of an operations director, this function coordinates the job networks which facilitate the transfer of experience to ensure consistent development across roles.At EDF Energy, jobs (in operations, maintenance, etc.) are coordinated by a peer group of leaders, with the support

54 Practice whereby a person employed by a department, such as engineering, occupies a position in another EDF entity beforehand to gain further experience before returning to their original role

55 French acronym for Division Combustible Nucléaire

of a Fleet manager, to ensure an effective, coherent approach is implemented across the fleet.

EDF Energy apprentices training at HMS Sultan (Royal Navy

training centre)

I also commend the initiatives to facilitate knowledge transfers across the age groups, like the buddy system introduced at the DPN, the RACINES56 programme in the French engineering centres and its equivalent in the UK, or the subject matter workshops designed to share knowledge and experience.

Where vigilance is required

Although leadership teams in France and the UK are actively involved in skills development, I would urge EDF SA to follow the example set by EDF Energy to broaden the role of leaders in evaluating the effectiveness of training with respect to the results achieved.At EDF SA, production and engineering jobs have high skill requirements similar to those necessary in operations (for positions such as safety engineers, shift managers, instructors, etc.). Hence my renewed emphasis on the need to ensure there are sufficient numbers of people with the relevant skills and qualifications in these core posts. Given the importance of maintaining technical skills, I encourage the development of networks of experts to ensure that career paths are organised in such a way as to facilitate skills development. I am aware of challenges in some of the engineering centres regarding the design engineering skills required to tackle the General refurbishment work and the simultaneous expansion of international activities.

56 French acronym for Réussir nos Activités grâce aux Compétences Intergénérationnelles de l’ingénierie Nucléaire et par l’Employabilité de tous ses Salariés; skills programme launched in 2012 and aimed at boosting intergenerational skills and workforce employability


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The key skills development plan (PDC57) offers an effective solution to both of these issues. It is important, therefore, that this initiative is maintained through into the new nuclear engineering structure.

57 French acronym for Plan de Développement des Compétences

Although there is an employment and skills plan in place at EDF Energy, I would like to highlight the need for forward-planning of recruitment and retraining to assure a smooth transition between the existing AGR competencies and those which will be necessary for Hinkley Point C.

Operations engineering training unit (UFPI)

Established in 2007, the UFPI, which is part of the DPNT, designs, develops and delivers the training provision for technical roles in production and engineering. Its remit covers all aspects of operations, maintenance and production from nuclear, fossil-fuelled and hydro sources.The unit boasts 800 instructors who are either highly-respected skilled in-house professionals, generally from operations, or young trainers recruited externally. After undergoing training, they become accredited instructors.

Vocational campuses located across FranceUFPI campuses offer a wealth of equipment, including craft training centres, simulators, mini power plants, valve rooms, diesel generators, etc.:

• 1 campus dedicated to maintenance training located at Bugey• 20 campuses devoted to operations, each located at a nuclear power plant, providing custom training on one

or more simulators replicating the control rooms at the plant• 1 training campus dedicated to nuclear fuel at the PWR training centre in Chalon-sur-Saône (CETIC)1

A constantly evolving training packageTraining needs have increased due to the large numbers of new staff. More than 3 million hours of training were delivered by the UFPI in 2015, compared with 1.2 million in 2008.The UFPI offer evolves year-on-year to adapt to advances in applications and techniques. For instance, training sessions have already taken place on the EPR simulator at the Flamanville campus to prepare future control room operators.

1 French acronym for Centre d’Expérimentation et de validation des Techniques d’Intervention sur Chaudière nucléaire à eau

STRUCTURED TRAINING PROVISION

Robust arrangements

The role of the Operations engineering training unit (UFPI - see inset) is key to training at EDF SA. This unit primarily supports the DPN, accounting for 80% of its activity. The relationships developed between the UFPI and individual power plants have also helped to address site training needs more effectively.Engineering requirements, which are generally highly specialised, have been the subject of a rationalisation process to significantly reduce the number of courses provided and ensure that they are better tailored to expectations.The UFPI now has the nuclear resources it needs. Following the recent recruitment drive, almost half the workforce is under 30. I expect this balance to shift to accommodate a higher proportion of experienced

personnel more in line with general international trends.In France, the onboarding process set up for new recruits to acquire core knowledge has seen continued success, as have the specialist knowledge Vocational academies. The Nuclear power academy - EDF Energy’s equivalent in the UK - is also enjoying similar success.The DPN’s industrial training centres have achieved clear on-plant improvements in quality, but I am disappointed with the disparities in their use, which should be analysed and corrected. The mock-ups used in the UK certainly have a beneficial impact on cooperation and unity by providing a more effective platform for staff and contract partners to work together towards the same common goal.Stronger Franco-British synergies would also be fruitful, building on initial successes like the benchmarks established in skills development practices, the cross-functional training opportunities, and the trainer exchange programmes.


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I have been shown a few of the many multimedia teaching solutions used by some of the Group entities, including self-learning videos, e-learning programmes, role play, and augmented reality technologies. I support the use of yet more of these tools to enhance the range of training aids.

Some points to consider

The DPN still struggles to fulfil its secondment commitments for experienced trainers. I urge the DPN and UFPI to work together more closely to address this issue.It has also come to my attention that maintenance leaders are not always present at training sessions and that mock-ups and industrial training centres are underutilised. I suggest that plant leadership teams investigate these issues to improve the quality of delivery. In my last report I stressed the importance of the collective dimension of operations activities. This year again I am calling for the need for training provision in France to incorporate hands-on scenarios for whole teams.The highly specialised nature of nuclear training demands a high trainer-to-trainee ratio. Indeed, some simulator training exercises require two instructors for four trainees. This very specific characteristic must be taken into account in current training budget reviews.

CETIC training centre

EXPECTATIONS IN FRANCE OF A BROAD CAREER PATH

Varied career paths help improve Group performance and motivate staff.

Good practices…

Practices in France, as in the UK, are well-established and effective. At least once a year, plant directors examine the succession plans for key positions and relocation coordination committees meet regularly at both plant and corporate level. In addition to the annual appraisals conducted by managers, I commend the quality of the work accomplished by the careers advisers (CPPs58) at EDF SA in providing career development guidance to engineers and their leaders.I have also been shown the communication tools for advertising jobs in the nuclear field and the tools designed to help with relocation. At EDF SA, the Mon parcours Pro community on the company intranet and the Votre parcours Pro practical guidelines published online in November 2015 provide helpful information and career path examples. Similar tools are available at EDF Energy, accessible via the My Campus intranet site.

… with EDF SA engineers looking for opportunities in their careers …

The EDF Group is an attractive employer and the new recruits I meet are dynamic and highly motivated. New employees are quickly placed in positions of responsibility under the guidance and support of one or more experienced colleagues. Yet some young recruits, particularly in engineering, shared their concerns with me about the extended term of service required in a specific role and the slower career progression associated with the large numbers of new employees recruited in recent years. They also mention how hard it is to reconcile the needs of the business with their own personal aspirations, citing geographical location as one of the main considerations when it impacts their partner’s work. It seems essential that new recruits have greater visibility on the careers development programme to boost motivation and foster employee loyalty.

… which should promote cross-career paths within the Group

I recommend that more open career paths are developed between the various disciplines - between engineering and production in the first instance - to align them more closely with the needs of the business and offer greater motivation and enrichment opportunities to staff. Although mobility within divisions is well

58 French acronym for Conseiller Parcours Professionnels à l’ingénierie, engineering careers advisers under the Head of Careers at the DPN


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coordinated on the whole, I urge leaders to implement measures to make it easier to move between entities. This year again I have been made aware of several examples of international mobility. The French and British operators decided to exchange 10 secondments each way. However, there is still some way to go to achieve this and I urge the leadership teams on both sides of the Channel to develop cross-career pathways and to capitalise on the experience gained when participants return to their home countries. In engineering, the Hinkley Point project has facilitated secondments between France and the UK.

In Taishan, I met several enthusiastic expatriates. They bring with them experience and in return they gain an understanding of other practices which will be extremely beneficial not only to the company but also for their own career. In this increasingly global and multicultural context, I am keen to promote the role of overseas secondments in career development. I would like to draw attention to the efforts made in France and the UK to marry the needs of the Group’s international projects with the skills base required for both the in-service fleet and the projects in progress.

MY RECOMMENDATIONS

The Group’s professional training initiatives - such as the aforementioned Skills programme and the Systematic approach to training - are well underway. I urge local senior management in France to maintain this energy, particularly against the backdrop of team turnover and greater demands.The company needs diverse and highly specialised skill sets. It is important to sustain the motivation of young recruits and foster their loyalty. To this end, I advocate the development of open career pathways both within the Group and internationally, and that employees are made aware of all opportunities.I particularly recommend that the DPNT and DIPNN forge cross-career pathways between operations and engineering, especially in the area of process skills.


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uSiNg MAiNTENANCE TO lEvERAgE iMpROvED OpERATiONAl quAliTy THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

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8 / USING MAINTENANCE TO LEVERAGE IMPROVED OPERATIONAL QUALITY

Maintenance work on a valve

There are all too many examples of sub-standard maintenance work at EDF Energy and EDF SA, which highlight continuing problems with preparing for and carrying out work.

Multi-year planning, a cornerstone for managing the quality of maintenance and modification work, is gradually being deployed on the sites.

Simplification of the work environment, for both EDF staff and contract partners, together with better application of the basics of their crafts, are essential ways forward.

QUALITY IS STILL NOT GOOD ENOUGH

Chronic issues

I believe that the quality of maintenance work at EDF SA and EDF Energy is below the required level for nuclear safety during operation. At EDF SA I note the increased number of automatic trips due to maintenance between 2014 and 2015. More generally, too many significant nuclear safety events have been caused by sub-standard maintenance. This number has increased between 2014 (189) and 2015 (198).Maintenance quality is also judged by the reliability of the plant. The unplanned unavailability rate in France remains acceptable (2.48%) with regard to the international references for in-service reactors. At EDF Energy, I note a good unplanned unavailability rate (2.3%), which is a marked improvement.

I also want to emphasise the need to get things right first time. Having to repeat work can lead to temporary arrangements that can be detrimental to the plant. I note the value of the Rework indicator, deployed at EDF Energy, which measures the amount of maintenance work that has to be repeated.Taking hazards into account (fire, earthquake, etc.) during maintenance work is also a factor for quality. For example, at EDF Energy and EDF SA, I regularly see too much scaffolding very close to required safety-related equipment, often even on redundant systems.

Inadequate defence in depth, particularly at EDF SA

The principle of defence in depth applies just as much to maintenance, where it is based on the quality of risk analyses, technical inspections, requalification and verification.

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION uSiNg MAiNTENANCE TO lEvERAgE iMpROvED OpERATiONAl quAliTy

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I am pleased to note that in the opinion of the EDF Nuclear inspectorate, the COMSATs59, which rule on the availability of equipment during unit outages before restarting, are robust: well-prepared meetings, including shift operations, limited number of reservations at start-up. Very few defects are now detected60 after a COMSAT.

Maintenance work in a UK plant

For units that are in service, the management of non-actioned work requests (outstanding work requests at EDF SA, backlogs at EDF Energy) has significantly reduced the number of defects that are not dealt with in plants.I would like to draw attention to the very positive contribution made by the AP 913 initiative, which increases the plant reliability through the use of equipment and system-based reports. The AP 913 roadmap for 2016–2018 will enable EDF SA to develop a method utilising a combination of monitoring reference equipment, making use of operational experience based on “as found”, and analysing any damage.However in 2015, too many operational events were caused by incomplete risk analysis prior to maintenance operations. EDF SA’s nuclear inspectorate also reports a deterioration in the quality of requalifications which the maintenance teams still have a great deal of difficulty handling. I observe long delays, sometimes of several months, in carrying out the verification of results, which may lead to late reporting of defects. I encourage maintenance team managers to address these issues, supported by independent nuclear safety engineers and inspectors to consolidate these basics.

Simplification for quality

I would like to reiterate the need for simplification for the benefit of workers, in both the preparation phase and when carrying out maintenance work. Simplification contributes directly to the confidence of teams and the

59 Unit Outage Nuclear Safety Committee60 It was the non-compliance of a seal, detected by a sub-contractor

but dealt with inadequately by the decision-making body for the launch of the Challenger space shuttle, which led to its explosion in 1986

Failure of a pipe containing pressurised CO2

The facts While two AGRs were running at full power, a steel pipe containing pressurised CO2 fractured. The pipe was connected to the CO2 reserve supply tank. This gas is used to transfer heat between the fuel elements and the boilers and to cool the reactor.The CO2 reserve supply tank is located outside the reactor buildings and exposed to a saline environment (plant located on the coast). The fracture in the pipe was caused by corrosion resulting from a non-leaktight protective insulator. Analysis also showed that the protective paint on the pipe was unsuitable for the variations in the pipe’s temperature.The event led to loss of CO2 reserve capacity, but did not necessitate the shutdown of the reactors. No-one was injured as a result of this incident, which caused 30 tonnes of non-radioactive CO2 to be discharged into the atmosphere, triggering alarms in the control room.

My analysisI believe that this event, associated with organisational weaknesses, was the result of:

• Too much confidence placed in the leaktightness of the protective insulation on the pipe

• An oversight programme which focused too much on moving equipment (pumps, valves, etc.) to the detriment of static equipment (pipes, etc.): this pipe had not been inspected for 9 years

• Inadequate traceability of inspection reports • Failure to complete actions identified following

previous inspections • Inadequate communication within the

engineering team, both locally and nationally, on discrepancies requiring more in-depth action

• Inadequate incorporation of operating experience from other sites on similar events

• A lack of clarity in the standards and arrangements necessary for pressure equipment

This incident has enabled the weak points revealed by the analysis to be corrected, and monitoring and modification to be extended to other equipment subjected to the same stresses. It illustrates the importance of dealing with early warning signs, incorporating operating experience and taking action plans through to completion.


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quality of their work, as well as making it easier to understand requirements. I note the work being carried out by sites to simplify job documentation and to group together the issuing of various permits (hot-work permit, etc.).I stress the importance of logistical support to make things easier for workers. Considerable effort has been made to improve the logistics within the framework of the General refurbishment (creation of changing rooms, car parks, familiarisation for incoming workers, single points for issuing permits, etc.) at Paluel, which is carrying out the first VD361 of the 1300 MWe plants. A number of sites have also taken very practical steps to ensure that spare parts and equipment are available as close as possible to the work areas. This enables teams to better focus on the preparation and running of their work areas.I commend the easier access to summary information at sites. In France, the MOSAIC62 approach makes the general objectives for outages, progress and main points for vigilance accessible to every worker. I also note that a specific action is under way in the DPN to develop digital interfaces (3D/4D simulation of worksites, tablets, Wi-Fi points, etc.).Standardisation of operating procedures, currently being implemented across the fleet, is also a way of introducing simplification, in particular for maintenance preparation teams. This change, which requires considerable upfront investment, especially on data quality, is supported by the SDIN63. I will be carefully monitoring the continuation of this standardisation and the correct incorporation of operational experience in order to arrive at simple procedures.By promoting similar methods on all sites, these simplification processes will also help to make things easier for contract partners, who regularly tell me about difficulties they experience arising from differences in practices between sites.

MULTI-YEAR PLANNING, THE CORNERSTONE OF INDUSTRIAL MANAGEMENT

The multi-year approach ensures compliance with nuclear safety requirements and evens out workloads over the medium and long term. Its purpose is to coordinate routine maintenance operations, periodic compliance testing, replacement of major components and all modifications. It is thus easier to balance work between unit outages and units that are in service.

61 Third ten-yearly inspection outage62 MOSAIC: approach developed out of an R&D programme to

improve supervision during unit outages63 Nuclear Technical Information System

Maintenance work

The management challenge of busy outages

It should be remembered that correct management of outages affects not only nuclear safety and radiation protection, but also industrial safety. A unit outage completed within the planned timescales is a sign of quality and confidence both in the preparation and execution of the maintenance work. Good preparation for an outage is the key factor in its success.I note very good management of refuelling-only outages, less consistent management of partial inspection outages (VP) and still greater issues with ten-yearly inspection outages (VD). Part of the success is due to the limited amount of maintenance work required on refuelling-only outages and an effective relationship between operations and the project.For outages involving a large volume of maintenance work (partial inspections and ten-yearly inspections), I again stress the importance of technical operating experience, but above all, organisational operating experience including that of contract partners. The speed of the analysis being carried out for the ten-yearly inspection outages since the end of 2015 is encouraging. The sharing of experience to improve the management and delivery of outages is also promising. This includes peer reviews and inter-site reviews in France, benchmarking with EDF Energy and with CGN in China, and the support of WANO (TSMs64). I will be carefully monitoring these advances in 2016.

More and more work on units in service

To improve the management of unit outages, maintenance work is increasingly being transferred to units that are in service. Preparatory work is also carried out on units while they are in service in order to be ready to conduct maintenance or modification work during unit outages 64 Technical Support Mission


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(ten-yearly inspections and post-Fukushima work). Work that was both complex and disruptive for the operator had to be incorporated in the unit in service for the first of the third ten-yearly inspections of the 1300 MWe plants (Paluel 2). I am pleased with the way that operating experience is being acted on quickly with respect to work that is sensitive in terms of nuclear safety (for example, the ventilation of control rooms).

Multi-year projects are starting to become embedded

I commend the widespread introduction of multi-year projects on French sites which now all have a dedicated team. However the teams’ positions within the plants are not always central to the projects for units in service and unit outages. I still too often hear about a lack of availability of the maintenance preparation teams. These teams are already having problems with writing up equipment reports, and are often mobilised by the work management system or by having to deal with a plant problem in real time. They are thus struggling to find time for this work. This situation varies from site to site depending on their organisation.I stress again the importance for each site to have a forward plan covering at least five years, which is still not the case on the sites I have visited. I noted good progress of the AP 913 initiative in France and the UK. By optimising the replacement of components, AP 913 evens out workloads. Although all the sites also showed me their long-term investment plans led by the local engineering teams, it is regrettable that these plans are not adequately coordinated with the multi-year planning. This illustrates the scope for improvement in coordination between the engineering teams and the multi-year projects.

Forewarning: preparation of VD4 900 and VD2 N4

I note a problem with integrating the major work involved in the fourth ten-yearly inspection outages for the 900 MWe plants, and to a lesser extent the second ten-yearly inspection outages for the N4 plants, in this multi-year approach. I can see that the Fukushima accident has had a significant impact on the initial examination schedule65, but I would draw attention to the fact that the work programme has still not been fully defined. It is only three years away from the deadline for the

65 The letter of referral from the ASN to the expert review group for nuclear reactors on guidance for the reactor service life extension programme was dated 8 March 2011, three days before the Fukushima accident. The standing group met on 18 and 19 January 2012

first-of-series fourth ten-yearly inspection outages for the 900 MWe plants (Tricastin 1), which is far from what is required for good multi-year planning. As in my last report, I would encourage the stakeholders (EDF, ASN and its technical support) to carefully consider the very restricted nature of such an examination schedule, both from the point of view of work scope feasibility and its impact for nuclear safety during operation.

EDF Energy: the same need for visibility

I have already emphasised the importance of a proactive approach to in-service inspection throughout the life of AGRs. I note EDF Energy’s interest in a ten-yearly approach which puts periodic nuclear safety assessments, investments to extend the life of plants, and the requirements of the ONR, into perspective in a coherent manner. I applaud the promising discussions that have been initiated with the French fleet.

Maintenance work in electrical facilities

MAINTENANCE PLAYERS

A dynamic organisation of maintenance professions

In France, in 2014 I commended the MMPE66, the new arrangements for the maintenance professions. This guide explains the requirements of the professions and gives a clear description of the roles and careers in maintenance. Arrangements have been put in place to implement this in the fleet, including skills advisory centres, effective organisation for the professional 66 Maintenance and project roles for operating plant


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networks and GMAP67 in the operations engineering unit for maintenance technical support. Training courses have been developed covering basic maintenance knowledge common to all engineers, including a key component on nuclear safety during unit outages.This reference system is tailored to cover the issues described above. Its deployment is progressing well on the sites, with a few remaining weaknesses with regard to maintenance preparation teams and field supervisors. I recommend that maintenance team leaders use this guide as an opportunity to promote quality requirements more forcefully and support the changes to the preparation team and field supervisor roles. In the UK, I note a strong organisation of the professions, led by the Maintenance fleet manager. It is shared across the sites and at corporate level, with key milestones, targeting quality and nuclear safety. The equipment reliability performance levels are still lagging behind those of EDF SA, and I will be closely monitoring the benefits of deploying this transition.

In France: partnerships with contract partners to be expanded

Contract partners I met at the EDF Energy sites told me that they appreciate having clear medium-term information. It enables them to plan ahead better for changes in requirements and the development of skills. They are involved in the industrial objectives at a very early stage. 67 Fleet maintenance and support group

In France, I still too often meet contract partners who are waiting to receive information about the future. I believe it is important to involve them more closely in the preparation of work and in feedback. In this regard, I would again like to stress the importance of the contractor assessment sheets, which must be used as a tool for dialogue, prepared and discussed with the companies closest to the work being carried out.

In France: increased support for sites

I noted the clear desire of the Central technical support department (UTO) and the Operations engineering unit (UNIE) to provide better support for sites. In particular, the Operations engineering unit has chosen to broaden the scope of the Fleet maintenance and support group, from being a simple maintenance specifier to providing support for the site engineering teams. I also noted that the UTO has set up shared teams providing support during unit outages. The other engineering centres are also assisting with maintenance, supporting the DPN’s sites: civil engineering, major component replacement, managing obsolescence, dealing with accumulations of defects, etc. We must ensure that the new engineering organisation within the Group really does make this contribution easier. I will be carefully monitoring all these changes in 2016.In particular, I would like to mention the management of obsolescence which is becoming increasingly important in connection with reactor life extension. It involves all engineering units. I will be watching closely to see that the resources required by the engineering centres are firmly managed and mobilised.

MY RECOMMENDATIONS

In France, the mobilisation associated with the multi-year planning process is clearly visible, but there is still some way to go with scheduling and preparing for maintenance work:

• I encourage the national engineering support to continue moving towards true multi-year planning of modifications which meets the requirements of the sites

• I would like to draw attention to the very restricted nature of the examination schedule for the fourth ten-yearly inspection outages for the 900 MWe plants, which calls for special provisions

• I call on local management to better protect their maintenance work preparation teams so that they can devote sufficient time to this long-term work

The quality of maintenance work is key to nuclear safety. In France, I recommend that site management teams, in close collaboration with contract partners, use the new MMPE guidelines as an opportunity to increase understanding of the basics of maintenance.Keeping things simple helps to get things right first time and contributes to quality and nuclear safety. I encourage taking further steps in simplification orientated towards the plant touchers, whether they are EDF employees or contract partners.


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9 / CHEMISTRY IN FRANCE: A TRANSITION IN NEED OF STRONG SUPPORT

Measuring chemicals

Nuclear safety and radiation protection results benefit greatly from the work accomplished in the field of chemistry, and it supports plant durability.

Although the 2010 working group’s conclusions have allowed the fleet to make progress, the initiatives have been implemented inconsistently across sites.

In 2016, the Chemistry core competency guidelines will be published and laboratories will be refurbished, which will strengthen chemistry’s place in operations.

NB: This section only discusses chemistry in PWRs and therefore excludes British AGRs. The only British PWR, Sizewell B, boasts good results.

Maintaining correct water chemistry in a PWR is a key requirement for nuclear operators. It contributes to nuclear safety via compliance with the chemical and radiochemical technical specifications. It plays an important role in radiation protection, specifically by minimising radioactive deposition in the systems during unit outages. A high level of performance as regards chemistry will extend the service life of equipment68. The latter is a concern in the long term, as the consequences of poor chemical conditions are only felt over time due to an accumulation of performance gaps.

68 Though not discussed in this report, chemistry also has a hand in environmental protection

There is thus a high risk of prioritising an immediate result to the detriment of an issue which only becomes apparent in the long term.This year, I made a point of meeting the chemistry services in all the plants during my visits. I also went to the Expertise and inspection department for manufacturing and operation (CEIDRE), in addition to visiting the Skills advisory centre (PCCEO)69.

ENCOURAGING RESULTS

I would like to commend the excellent progress of the results in this field. In 2012, I encouraged the implementation of performance monitoring tools. As the EDF Nuclear inspectorate has confirmed, the IPC indicator

69 An entity of the Nuclear Generation Division (DPN) in charge of organising the professions

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(see box) is in widespread use: it improves monitoring in this field and facilitates comparison between plants. I believe it could be combined with more accurate or specific management indicators in some plants for monitoring particular problems such as managing scale build-up. WANO has given an encouraging assessment of the French fleet’s results. Nonetheless, I still see too great a disparity between sites and I would like to see more cross-site sharing of good practices.

The IPC indicator

In use throughout French plants, the monthly chemistry performance indicator (IPC) ensures that any deterioration in the chemistry is noticed quickly. It incorporates a number of typical chemistry parameters of the primary and secondary systems and scores reactors on a scale from 1 to 100:

• 0 to 10, perfect chemistry• 11 to 50, average chemistry• 51 to 100, degraded chemistry

CHEMISTRY’S PLACE IN THE PLANTS

Unequal position of chemistry across projects

Greater focus is given to chemistry as regards the operation of nuclear units. The situation has certainly changed from the time, not so long ago, when chemistry was left to the chemists. It is now much more associated with plant operations.Some plants integrate it into running plant projects (chemistry indicator present in the unit-in-service project control centre) and unit outages (source term reduction taken into account during shutdown). It is starting to carve

out a place for itself in the integrated plant management systems. I have observed much good practice: the standard practice of talking about chemistry during the morning operations meeting, involving a chemist once a week in the daily face-to-face safety meeting between the shift manager and the nuclear safety engineer.This situation varies too much from one plant to another. On some plants, chemistry staff are still isolated, due to insufficient managerial support. I note that the chemistry culture in the management teams is often still weak. Although the 2010 chemistry working group recommended the creation of a local engineering team, some plants only achieved this in the second half of 2015. I have observed improvement in the relationship between operations and chemistry but some fragility is still evident, for example sharing responsibilities when aligning nuclear sampling systems and boron monitoring. These two important nuclear safety issues deserve greater scrutiny. Chemists are clearly struggling to get their requests for maintenance or modifications carried out with respect to these systems.Unit outage teams are now listening more to the chemists with respect to chemical specifications and radiation protection issues, but more effort is required as regards plant service life. For example, I would point out that too rarely is there effective protection of the feedwater systems during outages. Yet the durability of steam generators, important equipment for nuclear safety, is dependent on this aspect.

Measuring chemicals

Laboratories in need of refurbishment

I regularly visit the laboratories, which were often built at the same time as the plants. They are usually too small

PRINCIPLE OF THE MONTHLY CHEMISTRY PERFORMANCE INDICATOR

• The IPC is calculated every month and gives an instant overview of the quality of chemistry

• It is set back to 0 every month• The monthly IPC represents the sum of 5 conditions

CONDITION 5: Primary source term (Co-58 and Co-60)100 – degraded

chemistry

0 – perfect chemistry

CONDITION 4: Chronic Na pollution in the SGs (NaAPG)

CONDITION 3: Meeting B-Li coordination and primary-side H2 speciation requirements

CONDITION 2: Metals transported into the SGs (Fe, Cu and suspended materials in ARE)

CONDITION 1: Event-related pollution in the primary and secondary systems

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and run-down, which makes it difficult to install the new measuring equipment more than often required to comply with the latest environmental requirements. In the administration buildings where they are often installed, their refurbishment poses a major problem, particularly with respect to ventilation. I have also noticed that their geographical distribution does not encourage good cooperation between the various chemistry teams.In 2015, all the plants I visited told me about their plans to build a new laboratory. I am pleased about this company-wide project, which is being led by a deputy director of the DPN. A steering committee has been set up to approve ongoing projects and guarantee their financing. In my view, this approach should remedy the situation in a reasonable time scale.

The Chemistry core competency guidelines

GUIDE DU NCCE

NoyauCohérence

ChimieEnvironnement

DPNPCCEO

Génération 420

In 2015, the DPN finalised chemistry guidelines called the Chemistry core competencies, which specifies the place of chemistry in operations and the roles of all the professions and jobs involved. This work was undertaken jointly between the majority of the plants, the CEIDRE, UNIE/GPRE, the GPSI and the PCCEO. Aimed at leaders and plant touchers:

• It outlines the ambition• It specifies the role of chemistry • It covers the fundamentals of the profession• It defines the jobs, skills and career paths

Circulated from 2016 onwards, these guidelines ask for a commitment in all fields such that by mid-2017 each plant will have a site-specific roadmap in place.

A PROPERLY RECOGNISED PROFESSION

New professional guidelines: the Chemistry core competency

In 2012, I flagged up in my report how difficult it was for chemists to establish their position in the current

maintenance profession set-up. I am therefore pleased that the Chemistry core competency guidelines have been drawn up on the same principle as the guidelines for the operations and maintenance professions. These guidelines were finalised by PCCEO in 2015. They are based on recommendations from the 2010 chemistry working group, feedback from the other core competencies and significant experience-sharing between plants, CEIDRE and UNIE (see box). They will be deployed from 2016.The Skills advisory centre can rely on these guidelines to better organise the profession. In addition to leadership meetings, it is important that presence in the field is maintained.

Newly-polished skills

As in all the professions, the average age of the chemistry staff has fallen considerably, without any reduction in the overall skill level. Since chemistry is organised by equipment (measuring devices), occasional gaps in experience can appear and be compensated for pooling resources between sites. The CEIDRE can also help the plants, for example, when installing a new device. In line with the skills academies, chemistry academies have been created and are proving to be a success. I have noticed that most sites have added specific chemistry equipment (glove boxes) in the practical training schools so chemists too are able to practise methods which increase reliability. Recruitment is going well, pipelines are in place and the large number of staff retiring up until 2016 should slow down, ameliorating a sensitive situation.

A chemist making a measurement

Increasing constraints

I have noticed a significant increase in constraints on the profession. An initiative is underway to improve effluent management compliance with ISO 17025 (see box); the environmental aspects are already compliant. Rationalisation and simplification of methods and equipment are underway. The aim is to have the same analytical equipment in all the plants. I can see it is a

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promising initiative, but it places a heavy burden on the teams involved.I am aware of the determination but also of the problems on these worksites, which is why I would like to underline the cumulative effect of these changes, which can be challenging for relatively inexperienced teams.

Standard ISO 17025

Laboratories which monitor radioactivity in the environment have been certified for many years by the French nuclear safety authority (ASN) based on the criteria of the ISO 17025 standard. This requires regular monitoring by an external accreditation body: COFRAC1. Laboratories which measure effluent discharges have adopted a working approach equivalent to this standard, although they are not aiming for accreditation. They therefore need to demonstrate the quality of their measurements by:

• Inter-laboratory tests and cross-checking• Compliance with the standards for sampling

and analysis procedures• Calibration process • Demonstrating the skills of their staff• Integrating their organisation in a management

system

1 French official standards accreditation body

CHEMISTRY AT CORPORATE LEVEL

Acknowledged technical leadership

The CEIDRE is doing an excellent job of technical leadership and is still, according to the site staff, the go-to source for technical advice. Plants really appreciate

its approach: sharing experience and offering real-time support such as that given at the start of unit outages. The Chemistry peer meeting, organised annually, remains a strong symbol of the dynamism of this group which is increasingly supported by the DPN managers. This should help transform it into a forum for technical discussion and promote the chemistry profession.Once again I would like to point out the difficulty that the CEIDRE has to fill its vacancies with skills from the plant chemistry services.The Operations engineering unit - Standing advisory group for nuclear power reactors (UNIE-GPRE) is providing stronger leadership for plants in the area of effluents by trying to align organisation and methods with those that cover monitoring radioactivity in the environment. It is also overseeing the project associated with deploying the new laboratories.

Organisation still bound up in complexity

On each plant, deployment of these projects (core competencies and laboratories) should help clarify and simplify: common management, methods and workplace.At corporate level, however, I am struck by the complexity of the organisation. Chemistry is shared between environment, radiation protection and operations, with the engineering departments for chemistry and the environment actually split between the CEIDRE (DIPNN), UNIE (DPN), the DIPDE (DPNT) and UTO (DPN). Within UNIE itself, activities are shared between the GPRE and the GPSI70. From a plant viewpoint, there is very little evidence of overall coordination. This does not encourage integration of the various technical, regulatory and managerial aspects. I would like to encourage reflection on this topic in order to simplify the organisation and reinforce work prioritisation.

70 French abbreviation for Data Systems Process Group

MY RECOMMENDATIONS

At a time when the French plants are investing in the renewal of major components to extend the service life of reactors, closer attention should be paid to chemistry’s place in production, a factor contributing to nuclear safety and radiation protection in the long term.In 2015, the Chemistry core competency guidelines were defined, which revitalised this profession. In tandem with plans to build new laboratories and work on methods, they should help improve the performance of the French reactors and put them back in line with the best international standards. I would encourage the relevant plant leaders to take on board these guidelines so the changes can be implemented successfully.I would like to draw attention to the difficulty of implementing all these changes in teams which are still young, and I recommend that the DPN provides specific support to each plant.At corporate level, the organisation of chemistry and environment is still excessively complex, especially in terms of engineering support. I invite the DIPNN and the DPNT leaders to review this situation.

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10 / DECOMMISSIONING PROJECTS ARE PROGRESSING

Plants being decommissioned at the Chinon site

Responsible decommissioning is a condition for the acceptance of the nuclear industry by society. EDF has set up a dedicated structure and the nine French decommissioning projects are progressing satisfactorily.

Experience of these projects has shown the need for decommissioning to be properly integrated through the operating phase and for strong control of waste management.

The availability of final decommissioning waste repositories and the development of treatment systems are major challenges.

IN FRANCE, A SYSTEM THAT WORKS

An ethical approach

The IAEA recommends that dismantling is carried out as soon as operation ends71. In 2001, EDF SA decided to start decommissioning reactors that are at the end of their operational lives, so that this burden is not left for future generations. This decision means that the skills and equipment used for operation can also be used for decommissioning. It also provides experience that is useful for the design of new reactors. EDF intends to demonstrate its control of the entire life cycle of its plants.

71 General safety requirements Part 6 (2014 Edition): “The preferred decommissioning strategy shall be immediate dismantling”

Organisation strengthened in 2015

In 2001, EDF SA acquired dedicated skills, with the creation of an engineering unit, the CIDEN72, to control and manage all aspects of the decommissioning of nuclear plants. A new directorate, the DPDD73, was created in 2015, bringing together decommissioning and waste management skills to strengthen project management and develop industrial waste management systems, for the future dismantling of reactors that are currently in service.Decommissioning is also supported by a great deal of R&D work, such as establishing the strength of the core support structures in reactors being dismantled or

72 Nuclear environment and decommissioning engineering centre73 Decommissioning and waste projects division

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characterising the source terms of UNGG74 reactors. Assessments carried out during dismantling can also be useful for the in-service fleet.Funds based on dedicated, secure assets have been set up to cover expenditure relating to decommissioning. 74 Gas-cooled natural uranium fuelled reactor with graphite

moderator

They are audited regularly, in particular by the Court of auditors and the DGEC75.I note the coherence of this long-term approach, which will require the provision of the appropriate resources over time.75 Directorate-General for energy and climate change at the Ministry

for sustainable development

Definitions and general framework of decommissioning

The French environmental code mainly refers to the concept of dismantling (démantèlement), defined as technical operations carried out in order to achieve a final state enabling the site to be removed from the list of nuclear facilities, i.e. declassification (déclassement). Dismantling follows the final shutdown phase which, as far as the regulations are concerned, is still part of the plant’s operating phase. The final shutdown mainly consists of unloading the fuel and draining all the systems. EDF uses the term decommissioning (déconstruction) to describe all the final shutdown and dismantling operations.The “Energy Transition and Green Growth Act” of 17 August 2015 states that, when a nuclear facility is finally shut down, “its operator must carry out its dismantling as quickly as possible, under economically acceptable conditions”. This is what is usually referred to as immediate dismantling, which starts straight after the final shutdown.Dismantling a reactor involves a series of complex operations spread over several decades, marked by milestones set by regulatory authorisations. Thus the start of dismantling operations is dependent on obtaining an authorisation order, issued after a public enquiry and the ruling of the ASN. As in the operating phases, the ASN sets nuclear safety objectives and checks that the user complies with them.

Interior of the Chooz A plant

Feasibility already demonstrated

EDF SA has started dismantling nine Generation I reactors (see the map in the Appendix). Experience and know-how gained on these projects will be invaluable for dismantling other reactors. The feasibility of decommissioning pressurised water reactors has been established. Chooz A was the first French PWR. The reactor vessel, its last major component, will start to be cut up in 2017. This operation

has already been carried out on PWRs in other countries (Spain and the US). The standardisation of the in-service fleet will have a positive impact on these operations, making it easier to develop effective industrial solutions.

Specifics risks to be managed

The risks associated with dismantling are very different from those connected with in-service reactors. Once the spent fuel has been extracted from the core and taken off-site, 99.9% of the radioactivity has been removed. The need to provide cooling and to control the radioactivity of the fuel is thus removed. However, there are still very small quantities of radioactive substances in the plant which require appropriate protective measures for workers and for the environment.A dismantling project involves a great many conventional operations (cutting, handling heavy loads, disassembly, etc.), often in confined spaces. Facilities dating from the initial reactor are used (lifting equipment, ventilation, lighting, etc.) which sometimes have to be redesigned or even supplemented with new facilities. The worksite environment and the conditions for carrying out the work are always changing, which entails regular examinations and risk analyses.Although decommissioning operations might initially seem relatively simple, the risks associated with the presence of radioactive residues mean that methodical,


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rigorous processes, similar to those for operation, must be adopted. I would also like to draw attention to the risk of casualties and fires. This leads to the need to implement even stricter preventive measures as some operations can take a very long time (several years).

Monitoring at the Chooz A site

My observations on the sites

During my visits to Brennillis, Chooz A, Creys-Malville and Chinon A3 I observed considerable attention to safety and radiation protection, good radiological condition of the sites, and significant progress with the work. I understood the long periods of time associated with these dismantling operations, due in particular to their complexity, the regulatory obligations and legal requirements. I also noted more complex support for plants which do not have the local support of generating sites.I was impressed by the quality of the teams. The competent, well-motivated staff are conscious of their pioneering role and aware of the innovations that these operations are introducing. I was shown techniques contributing to safety and radiation protection, including 3D/4D job planning, laser cutting, and automation of cutting, extraction and final conditioning activities, etc.I also noted the satisfactory operation of the internal licensing system (SAI). This has been in place for ten or so years and is regularly checked by the ASN. It enables the operator to be responsible for certain steps in the decommissioning process and to validate updates to meet the nuclear safety and operating standards. It is based on a decommissioning nuclear safety committee which includes external partners (CEA and CEPN76).At Brennillis, I noted that the nuclear auxiliaries and fuel buildings had been completely removed, and that the dismantling of the effluent treatment plant was in

76 CEPN: research centre for the assessment of radiological protection in the nuclear industry. It includes the CEA, the IRSN, AREVA and EDF and is a centre for research and studies on assessing the protection of people against the hazards of ionising radiation

progress. The metal structure which contained the core is still to be dismantled, followed by the reactor building. At Chooz A, the decommissioning is also progressing well. The wall of the containment in which the reactor was located has undergone in-depth radiological cleaning and the primary system has been dismantled and removed. Preparation for the operation to cut out the reactor vessel – scheduled to start in 2017 – has started.At Creys-Malville, the dismantling of the major components of the reactor building (primary and secondary pumps and intermediate heat exchangers) has been completed, apart from the reactor vessel. The treatment of the 5,000 tonnes of sodium was completed in October 2014 (conversion to sodium hydroxide, then encapsulated in very low-level waste concrete blocks). The success of this difficult operation has enabled the gradual dismantling of the reactor vessel to be started in a favourable radiological environment. The site has the particular feature of having its own dedicated fuel storage pond.At Chinon A3, the dismantling of the heat exchangers in the first area has been completed, and that of the second area is well-advanced. I noted the benefit of having started the first decommissioning operations on this reactor as soon as it was shut down, making the subsequent steps easier.

Inside the Bugey 1 plant: the reactor block

A DIFFERENT APPROACH IN THE UK

EDF Energy wants to be responsible for decommissioning the reactors it operates77. However, the British government could decide to take over control when operation ceases and to assign their decommissioning to a third party, in principle the NDA78.The decommissioning of existing plants is financed by the Nuclear liabilities fund, owned by and managed on behalf of the government, which guarantees its availability and

77 This differs from the situation of the reactors that have already been shut down (essentially the ten or so Magnox reactors), the ownership of which has been transferred to the NDA

78 Nuclear Decommissioning Authority


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adequacy. The decommissioning of future plants would also be financed by a fund managed by an independent body.EDF Energy has chosen a deferred dismantling strategy for decommissioning its AGRs, following the example of the NDA for the MAGNOX79 reactors. This strategy is an option initiated by the IAEA and authorised by the UK regulator. This was chosen due to the fact that there is currently no disposal arrangements in place for certain types of waste, in particular graphite. The dismantling operations will therefore not initially concern the reactor core. A monitoring period of approximately 75 years will then follow. Dismantling will be carried

79 MAGNesium OXide, British reactors which were the forerunners of AGRs

out at the end of this period, benefitting from natural radioactive decay. The strategy chosen for Sizewell B (PWR) is immediate dismantling, as in France The fourteen AGRs operated by the EDF Group in the UK will be shut down between 2023 and 2030 according to current predictions. In agreement with the British authorities, EDF Energy will start to prepare for the end of operation six years before the final shutdown, i.e. in 2017. I note that a decommissioning strategy will be finalised in 2016. A model of work, adapted to suit the British context, will be developed with the support of EDF SA’s DPDD, and an organisation put in place. Preparatory work could therefore start in 2017 (requirements of the fuel route, characterisation, inventories, possible investment at Sellafield, etc.).

Decommissioning waste

For the nine reactors currently being decommissioned:• Very low-level waste VLLW (less than 100 Bq/g) accounts for 115,000 tonnes.• Short-lived (half-life less than or equal 31 years) low-level and intermediate-level waste (LILW) (100 to 1 million

Bq/g and 1 million to 1 billion Bq/g respectively) accounts for 53,000 tonnes.• 2% of the radioactive waste is long-lived (half-life more than 31 years). This is made up of 17,100 tonnes of

graphite, low-level waste (LL-LLW) specific to the six UNGG reactors, and 300 tonnes of intermediate-level waste (LL-ILW).

The French national radioactive waste management agency (ANDRA) is responsible for the long-term management of radioactive waste produced in France. It has to find storage solutions for all final radioactive waste, and operate and monitor repositories that are safe for the public and the environment.Waste therefore is or will be sent to different ANDRA repositories depending on its level of radioactivity:

• VLLW-LLW and SL-ILW will be stored at the Morvilliers and Soulaines repositories.• The final site for graphite (LL-LLW) has not yet been determined.• Long-lived intermediate-level waste (LL-ILW) will be sent to the CIGEO1 geological repository, which is due to

be commissioned in 2025. It will be stored on a temporary basis in the ICEDA2 storage facility (EDF) on which work was resumed in 2015.

1 Deep geological repository operated by ANDRA (French national radioactive waste management agency)2 Active waste conditioning and interim storage facility

A PHASE TO PREPARE FOR DURING OPERATION

In France, the reactors currently in service (Generation II) will be subject to actions aimed at extending their plant life to sixty years. Irrespective of the extension granted, they will have to be dismantled in a few years’ or a few decades’ time, and it is advisable to prepare for this now.In 2006, one of my predecessors pointed out the difficulties encountered with the clean-up of the 56 interim storage boreholes in the AMI80. He hoped that these difficulties would make people realise that “sloppy practices in the past will result in problems in the future”. It has to 80 Irradiated material workshop, at Chinon

be said that in 2015, these clean-up operations have only just been completed, and the AMI is shortly to move into the dismantling phase.I note from this example that a responsible operator must ensure that the plant is kept as clean as possible. The EVEREST and MEEl initiatives are particularly effective in this area. During my visits, I saw how keeping a correct record of operating events makes dismantling operations much easier.In the case of the Flamanville 3 EPR, preparation for the decommissioning of reactors has been incorporated right from the outset: a decommissioning plan is drawn up at the design stage then kept up to date during operation. It covers two objectives: reduction of


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the dose for workers and reduction of the volume of radioactive waste and hazardous substances.The number of staff required for decommissioning a reactor is, on average, around one tenth of that required during operation. Decommissioning makes extensive use of subcontractors. I would like to draw attention to the benefit of also having an industrial policy in this area, which develops subcontractor loyalty and gives them adequate information about the future.

DECOMMISSIONING WASTE IN FRANCE

Dismantling produces waste, the majority of which (approximately 80%) is non-radioactive and will be recycled. Radioactive waste, mainly low or very low level waste, is subject to precise characterisation before being conditioned in order to be permanently stored by ANDRA81 in dedicated centres which must be available. Since there is no clearance level as in many other European countries, France has implemented a very comprehensive, dedicated system to manage very low-level waste (VLLW). I am surprised with the differences in practices between comparable countries. The national inventory of waste and the plan for its management (PNGMDR82), drawn up by ANDRA, highlight that the existing repositories (Soulaines and Morvilliers) will be unable to cope with the dismantling waste from all the reactors that are in service. It is therefore essential to identify other solutions.81 French national radioactive waste management agency82 French national plan for managing radioactive materials and

waste

A specific solution must also be found for graphite (long-lived low-level waste LL-LLW) from UNGG reactors.NB: Long-lived high-level waste (LL-HLW) is not decommissioning waste. It is the result of fuel reprocessing and is covered in Section 12.

Clearance levels

The nuclear waste clearance level is the radioactivity value below which the waste can be considered as conventional.Such thresholds, established by the IAEA and Euratom, exist in most countries. In France, the ASN decided not to introduce such unconditional clearance levels. Therefore, waste from a radiological controlled area will be managed within a nuclear context, even if there is no evidence of it being radioactive. For this reason France, unlike other countries, has a specific system for managing very low-level waste (VLLW).The existence of a clearance level significantly reduces the volume of final repositories (by a factor of three in the case of Germany). However, even below this threshold there is a problem of acceptability of the waste cleared. Discussions are under way to look at accepting a threshold for this waste, subject to special precautions (dispensation from the ASN, traceability in the systems for re-use, etc.).

MY RECOMMENDATIONS

In France, as in the UK, the EDF Group will have to decommission the reactors it operates. Experience with reactors already being decommissioned in France shows that good forward planning right from the operating phase makes this work considerably easier. I therefore call on operators to liaise with the Decommissioning and waste projects directorate, created in 2015, and to prepare for decommissioning. In France, the successful completion of decommissioning operations will depend on the adequacy of the waste storage capacities. Even though the search for repositories is not the responsibility of EDF, I encourage the stakeholders concerned within the Group to make an active contribution to the development of these systems and their commissioning.More generally, I call for consideration of the benefit and limits of a radioactive clearance level with regard to protection of the public and the environment.Decommissioning a reactor is a long operation, which requires forward planning and continuity. I would like to draw attention to the benefit of also having a supply chain policy in this area, which develops sub-contractor loyalty and gives them adequate information about the future.


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11 / EPRs IN CHINA, FRANCE AND THE UK

Taishan (China)

Taishan is progressing at a steady pace and is now leading the way.

This progress is beneficial to the Flamanville 3 site which is starting afresh with a new schedule and stronger ties with Taishan.

As well as the two EPRs to be built at Hinkley Point C, the Group has embarked on a new EPR model, called the EPR NM.

THE TAISHAN PROJECT IS PROGRESSING AT A SOLID PACE

In line with the 30-plus year partnership between EDF and CGN83, TNPJVC84 (30% owned by EDF) is building and will operate two EPR units on the Taishan site in China. EDF teams are involved in the different phases of the project, from design through to operation.I was impressed by the pace at which the construction activities were advancing for the two reactor units, which are progressing at similar paces. There are many activities taking place in parallel on the site, and I can see the project management team are doing everything they can to achieve a good level of housekeeping before commissioning, using international standards as their guidelines. The benefit of building twin reactors at the

83 China Guangdong Nuclear Power Company84 Taishan Nuclear Power Joint Venture Company Limited

same time on the same site is measurable in terms of the advantages not only for work optimisation, but most importantly for quality and nuclear safety.Key milestones were reached in 2015 for Taishan 1: primary system flushing in September and start of the cold tests in December.

Project milestones managed safely and efficiently

I was pleased to see the teams all mobilised and focused on the same objectives. TNPJVC and its main project partners, including AREVA, are now all working assiduously to meet the next key milestones set for the site. The motto “One team, one goal, we commit, we win”, which proved its worth during the previous phases of the project, is now being applied to the preparation for the start-up tests.

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As part of this approach to support the schedule, a rigorous process is under way to decide on any modifications to be made before reactor fuel loading. For changes coming from Flamanville 3, their analysis is supported by EDF’s Nuclear engineering department. I encourage such configuration management practices which are used without compromising nuclear safety.

Robust preparations for testing and operations

Preparation for the start-up phase makes extensive use of CGN’s operating experience from all its sites.I would first like to note the future operator’s close involvement in the management of the hand-over of the reactor systems and the start-up tests, as well as its close ties with the engineering teams, who have a strong presence on-site.I found the process described to me by TNPJVC for training and assessing its future control room operators to be robust. It is centred around training on a full-scale EPR simulator which has been in use for several years. Long training periods will also be spent on sites that are in their start-up phase or are already in service. To comply with a requirement issued by the Chinese nuclear safety authority, each operations team will be supported by an experienced shift manager who has worked for EDF. The initial training period will be validated by a strict assessment process, after which the Chinese nuclear safety authority will give its authorisation.I noted that the six processes to increase work reliability, similar to those used by the DPN, will soon be extended across all CGN sites. The strong commitment of the leaders driving these practices was tangible at Taishan.TNPJVC has opened its doors to international organisations (IAEA, INPO, WANO, EPRI, etc.) and has welcomed the use of globally recognised practices, including: • Self-assessment of the site launched in May 2015• Pre-OSART review between the hot functional tests and

fuel loading• Self-assessment of control room operator teams

according to the CPO85 concept• SOER review

A promising independent nuclear safety oversight organisation

I was given a presentation on the recruitment and professionalisation processes for the independent nuclear safety oversight team whose duties and organisation are similar to those used by EDF. The considerable

85 Crew Performance Observation: self-assessment of the team as a whole and each member separately during a simulator session

professionalism of those I met was clear: they generally have ten years’ experience in their company. Their training courses cover operations, tagging/ blocking and human performance, with maintenance to be incorporated shortly. Shadow training is also organised on other CGN and EDF sites.I would like to commend the practice in which safety engineers are assigned to shift work during the first year of operation, as determined by CGN for all its plants.

A NEW MASTER SCHEDULE FOR FLAMANVILLE 3

A new schedule was unveiled in September 2015 and has been endorsed by the EDF Chairman. Despite the delays, I encourage all teams whose expertise and dedication is an example to all, to maintain their motivation so they can overcome any obstacles prior to start-up.

Flamanville 3 site

New governance for the project

I would like to underline the commitment, right up to the highest level, focused on the success of this project: there is now a dedicated project director reporting to the DIPNN director who will assume the nuclear operator’s responsibilities up to reactor fuel loading, the construction site has been placed under the authority of this project director, and a new project team organisation has been implemented, making those involved more accountable.I would also like to draw attention to the impact of the engineering reorganisation and to a lesser extent, that of future closer operation with AREVA. Support will be needed to help accommodate the changes to the CNEN’s duties and responsibilities, as well as the decisions on resources allocated to engineering centres that are still overstretched. The future system for monitoring the quality of design and manufacturing at AREVA remains to be defined.

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Thorough preparation for the start-up tests

During my visit to the site, I noted the good general condition of the equipment and the exemplary state of housekeeping on the site as a result of the unwavering involvement of the site management and contract partners. I saw how the operator was actively contributing to protecting equipment pending start-up. The testing process is well structured. The second test review in April 2015 concluded that the organisation in place on the site and in the engineering centres had progressed well. This process still needs refining in real conditions and is dependent on the progress of construction work.I also noted that international practices were being welcomed with open arms. For example, the pre-OSART review will include a group-based self-assessment process for the reactor operations teams, using the WANO crew performance observation concept.For the start-up tests, two-thirds of the test specialists will come from the construction site and 20% will be provided by the DPN, with the remainder being support staff from the engineering centres. The teams have yet to be fully established. Once again, I feel the need to raise the core/fuel issue: I am concerned that with a reactor of a new design and with the time required to produce suitably qualified and experienced personnel for the neutronic tests, there could be a shortage of qualified test specialists for the start-up.

Points where vigilance is required

I noticed that construction operations and hand-overs of systems to the operator are not always making sufficient headway, during the testing phase, to allow the operator to progressively take over the facilities.There are still too many modifications appearing after the design was frozen in June 2013. Again I would like to stress the importance of configuration management for design, assembly, testing and operation. I have seen that project management has duly taken this priority into account.The nuclear pressure equipment regulations are still being incorporated, in particular through the deployment of the “3-year work programme” that EDF and AREVA presented to the ASN, though it remains a sensitive issue. I am conscious of the fact that the relevant teams will have to be dedicated in their efforts for this to succeed.Having acknowledged receipt of EDF’s request to commission the plant, the ASN is in the process of listing the additional documents they require before deciding whether to give EDF the green light. I do wonder

whether the teams (EDF, ASN and IRSN) will be able to process such a substantial workload.During my visit to Flamanville, I was shown several examples of cooperation between the construction site teams and the NPP teams, such as staff secondments. I encourage this approach which makes it easier to ramp up the operator’s skills on the particular features of the EPR and its involvement in system handovers for tagging/ blocking, and then for temporary operation. Though I commend this cooperation initiative, which is appreciated by all, I believe that it could still be strengthened at all levels. I am well aware of the new series of actions initiated late in the second half of 2015 and I will be following them closely.

Preparing to integrate Flamanville 3 into the French fleet

I believe an integrated approach between Flamanville 1-2 and Flamanville 3 to be an appropriate solution for certain aspects. For example, I would encourage finalising and testing the emergency preparedness organisation shared by all three units, to confirm its efficiency. Another example is a multi-year approach to the modifications and logistics required for the site, covering the third 10-yearly inspection outages for Flamanville 1-2 scheduled for 2018 and 2019.The links between this NPP and the DPN also need to be strengthened. A coherent approach to the numerous issues at hand would indeed be advantageous for nuclear safety: General operating rules (RGE86), spare parts, operating experience, involvement of equipment strategy leaders (PSM87), stance as regards the ASN, simplification programmes, etc. This will require the development of additional skill sets, in particular within UNIE.

CAPITALISING ON TEST EXPERIENCE BETWEEN TAISHAN AND FLAMANVILLE 3

As Taishan moves towards commissioning the first EPR, cooperation between the two sites must be stepped up to learn from this new status in the fields of engineering, construction, relations with the nuclear safety authority, testing and operation.

Many examples of cooperation...

During my time at Taishan, I met many highly motivated and committed EDF staff members who were all well integrated into the Chinese teams. I was also shown how the back office was operating satisfactorily in France,

86 French abbreviation for Règles Générales d’Exploitation87 French abbreviation for Pilotes Stratégiques de Matériels

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particularly in the field of nuclear safety: the CNEN is now in a strong position and ready to support the site.I saw several examples of cooperation between Flamanville 3 and Taishan in various fields, to the benefit of nuclear safety for both projects, which I support: organisation of several technical workshops, improved sharing of operational information, dialogue between nuclear inspectorates in preparation for the pre-OSART review, etc.The areas in which EDF is supporting Taishan were also pointed out to me: closure of the reactor vessel, reactor containment testing in collaboration with the General technical department (DTG)88, and preparation for fuel delivery.I also found the TNPJVC approach to optimising maintenance volumes to comply with unit outage deadlines very relevant, and I encourage EDF to look at it more closely.

... to be further developed

I want to stress how important it is to capitalise on the experience from the start-up tests at Taishan. This will contribute to better detection and handling of any precursor events that occur during the Flamanville 3 tests.I encourage strengthening of the dialogue between EDF and TNPJVC staff so their participation in the tests is most effective. Dialogue between these entities will also be seen as good for the motivation of the DPN teams. I am pleased to note that CGN also seems to be interested in continuing this type of cooperation during operation.More generally, experience sharing between the first EPRs is a key issue for the operators. Taking into account operating experience from the different EPRs is also an ASN requirement. The new cooperation agreement signed by the EPR operators in November 2015 in the context of EPROOG89 covers the areas of design, construction, licensing, commissioning and operation. It should be an effective lever for experience sharing.

THE HINKLEY POINT C PROJECT IS UNDER WAY

In the agreement signed by EDF and CGN on 21 October 2015, CGN is expected to have a 33.5% share in the construction of two EPR units at the Hinkley Point site in the UK. This agreement also lays the foundations for continued cooperation with CGN during the construction of two additional EPRs at Sizewell, and the adaptation of

88 French abbreviation for Division Technique Générale in charge of overseeing the progress of large engineered structures including reactor buildings

89 EPR Owners Operators Group, comprising EDF, EDF Energy, TNPJVC and TVO

the Chinese Hualong90 Generation III reactor technology to meet the British nuclear safety authority requirements before its construction at the Bradwell site.

Signing of the EDF-CGN agreement

During my visits to the EDF SA engineering centres, I was shown the adjustments made to the organisation of Responsible designer teams, integrated teams and command centres, at the CNEN (ECC91), the CNEPE, the CEIDRE and SOFINEL92. Visual management is widely used. By promoting collaboration between those involved (EDF SA, EDF Energy and the main suppliers), these new organisations encourage the pooling of issues and simplify interface management. I encourage such an approach, which is conducive to high-quality design.I want to draw attention to the value of incorporating experience from Flamanville 3 and Taishan in all fields (safety, industrial organisation, design, construction and operation) and adapting it to the British context, especially with respect to the demands of the ONR. I call for this approach to be consolidated to enhance the quality of projects implemented in the future.

LAUNCHING EPR NM - THE OPTIMISED EPR PROJECT

The aim of this project is to design a high-power reactor that meets the nuclear safety requirements for Generation III reactors, in preparation for the renewal of the French fleet and for export. I was impressed by the excellent integration of the EDF and AREVA staff I met at the integrated team office. This project pulls together almost 300 people divided between this office and the EDF SA and AREVA engineering centres.I noted that an organisation has been established to incorporate operating experience. To ensure that

90 1000 MWe reactor with 3 loops91 Engineering Command Centre in charge of running and

coordinating engineering activities for the Hinkley Point C (HPC) project

92 French abbreviation for SOciété Française d’INgénierie ELectronucléaire pour l’exportation which is an EDF SA–AREVA design engineering office

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operating requirements (operations, in-service inspection and maintenance) are incorporated correctly, and because a user-friendly and easily maintainable facility is always the safer option, I would like to stress the need to get experienced operators involved in this integrated project office at the right level.

Project team office for the EPR NM

I believe it is also necessary to make the most of experience from Flamanville 3 and Taishan in order to adopt the best industrial organisation from the start: project governance, the role of the operator, assignment of contracts, integration of suppliers into the project, construction site management, etc.I note that the engineering methods have changed considerably, which necessitates support within the

engineering teams as well as for contractor partners and the future operator. This is the case, for example, with the plant lifecycle management approach (PLM) which is designed to help the operator achieve better control over plant configurations and the related requirements. The same applies for the management of nuclear safety and operating margins, which has been ongoing since the start of the project. I would like to underline the relevance of these methods for nuclear safety.The codes and methods are also changing in line with the power increase. Furthermore, new requirements must be taken into account, particularly for the electrical network (ENTSOE grid codes93). All of these changes will need to be examined in depth with the ASN and its technical support body.EDF SA will submit a safety options file to the ASN in 2016. Although this is a positive approach, I can see that the planned schedule is ambitious. It will be paramount to correctly estimate the time needed to examine all the documentation provided as part of demonstrating the robustness of the main changes in relation to Flamanville 3 (reactor containment, number of nuclear safety trains and power increase) and to validate the nuclear safety standards and any changes made to the codes and methods.

93 European Network of Transmission System Operators for Electricity

MY RECOMMENDATIONS

To ensure better sharing of the objectives of the Flamanville 3 project, I urge the DPNT and DIPNN managements to strengthen cooperation between the plant teams and the construction teams so the assembly work can be finished swiftly, preparations can be made for the start-up tests, and the tests can be carried out. I recommend increasing the sharing of experience between Flamanville 3 and Taishan, especially through the use of more secondments during the preparation for the start-up tests and their execution.To better integrate operating experience from Flamanville 3 and Taishan into the EPR NM project, I call for the DIPNN and DPNT management to continue reinforcing the simplification of operations and maintenance for the benefit of nuclear safety. The DIPNN is committed to numerous large-scale projects, for both new reactors and reactors in service. I am concerned about the availability of design resources in the engineering centres, as well resources and skills for managing major projects.

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12 / PREPARING FOR THE FUTURE

EDF R&D laboratory at the Renardières site

By exploring innovative reactor technologies, improved nuclear safety features can be identified.

Programmes led by EDF R&D in this field, such as research on rare natural events, can also have a direct bearing on reactors in service.

International cooperation in nuclear R&D is flourishing in fields that are increasingly broader in scope, requiring experts with the latest technical skills.

Preparing for the future is all the more important since the nuclear industry has to deal with very long time scales: the lifecycle of a reactor usually stretches across a century, from design through to decommissioning. EDF’s R&D programmes form the backbone of this strategy for the Group, focusing on issues that concern both the operational fleet and future reactors. These R&D actions rely on the wealth of experience accumulated by the operator and on work carried out within the scope of international cooperation. They are based on applied research to ensure an industrial end-purpose. They are also complementary to the more fundamental research programmes carried out by the CEA and IRSN in France. Such R&D is needed to better characterise the safety margins available and to explore new possibilities so as to consolidate these margins.

EDF’s R&D centres are hubs where highly specialised skills cross paths with many other career paths leading to the various operational units. A specific committee defines and runs the research activities according to the needs expressed by the operational divisions within EDF SA (DIPNN and DPNT) and EDF Energy. There were no particular issues for me in these areas in 2015.This section of the report focuses on how natural marine-related hazards are handled, as well as on the management of severe accidents, future nuclear fuels, radwaste, and new reactors.

ANTICIPATING CLIMATE CHANGE

I would like to stress how important it is to characterise the risks of internal (fire, flooding, etc.) and external (tornadoes, earthquakes, tsunamis, surrounding industrial

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environments, etc.) hazards with respect to design-basis criteria. Such characterisation is not only necessary for units in service, but also for new build; it carries even more weight in light of the Fukushima accident.By integrating the greenhouse gas effect and its impact, we have had to review how we qualify marine-related hazards to make sure there are no cliff-edge effects94 involved. This year I was given a presentation on the work that has been instigated on this subject.I noticed that EDF SA and EDF Energy are using the same methods to better understand this hazard on French and British coasts. Feedback is collected after severe storms to build up the numerical simulation models. EDF has partnerships with IFREMER95, SHOM96 and Météo-France to gather historical data, which is relatively limited at this stage.I visited EDF’s R&D centre at the Chatou site which boasts a number of excellent mock-ups used to simulate the combined effect of swell and wind on large man-made structures. I would like to stress the importance of such experiments when combined with simulation.

Mock-up of NPP intake at EDF’s Chatou R&D laboratory

MITIGATING THE CONSEQUENCES OF SEVERE ACCIDENTS

Nuclear safety is devised to prevent accidents and limit their consequences. The partial or total melting of nuclear fuel is covered under the defence-in-depth strategy: such situations are considered as severe accident scenarios. In such cases, the corium97 may melt through the reactor

94 A significant change in the scenario resulting from a small perturbation

95 French abbreviation for Institut Français de Recherche pour l’Exploitation de la MER, French research institute for exploitation of the sea

96 French abbreviation for Service Hydrographique et Océanographique de la Marine, hydrographic and oceanographic office of the French navy

97 Mixture of molten fuel and cladding whose temperature can exceed 2,000°C

vessel and come into contact with the reactor building basemat98 which is the last barrier before the environment. Generation III reactors have been designed to spread, cool down and contain the corium in what is known as a core catcher. This device was developed following a series of experiments begun in the 1990s in the US (Argonne National Laboratory under the DOE99) and supported by simulation from the CEA, AREVA and EDF.For the current fleet of Generation II reactors, the aim of research is to demonstrate that corium can be cooled to prevent it from going through the basemat. Work is focusing on heat transfers between the corium and the cooling water. Other research programmes are investigating steam explosions which can occur when water comes into contact with the corium, and threaten the integrity of the reactor building. A level of safety close to that of the Generation III reactors could be achieved by combining this feature with changes resulting from the post-Fukushima stress tests. I see that a new test facility called PLINIUS II has reached design stage at the CEA with the aim of conducting tests that reflect the current configuration of the fleet in service. The R&D and Nuclear and conventional design department (SEPTEN)100 at EDF are closely involved in this project, particularly via a simulation and test programme.The next step in severe accident research will be to find a solution wherein the corium is kept inside the reactor vessel, i.e. in-vessel retention (IVR). This measure will be given priority in new reactors (see below).

FUTURE NUCLEAR FUELS: AIMING FOR IMPROVED MARGINS

The reactor core is where the nuclear reactions take place and where the heat is removed. It is a complex task to model the core since it requires knowledge in many fields: neutronics, thermohydraulics, structural dynamics, and material science. Such modelling relies on both experimental data and numerical models whose qualification is key to nuclear safety.A great many international research programmes are underway to design efficient fuels such as ATF101 which can delay core meltdown under accident conditions and thus better mitigate the consequences. New options are being explored, such as the use of ceramics for the fuel pellet, sandwich fibres for the fuel cladding, and new geometries for the fuel. I want to emphasise the time needed (more than 10 years) to design and qualify such new fuels.

98 Foundation on which the reactor building is erected 99 US Department of Energy100 French acronym for Service d’Etudes et de Projets Thermiques Et

Nucléaires 101 Accident-Tolerant Fuel

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Fuel studies are synonymous with tests which need to be performed in experimental reactors. Following the 2015 closure of the OSIRIS reactor (CEA) in France, I note that tests are being continued in the Halden reactor (Norway) until the JHR102 (CEA) is ready to take over. I would also like to mention the importance of test loops and hot laboratories for irradiated fuel studies. The three-party research institute comprising AREVA, EDF and the CEA has a key role to play in this field.On a broader front, I appreciate the sustained international cooperation on nuclear fuel R&D, as well as the involvement of EDF’s R&D and SEPTEN teams within the framework of OECD103 and EPRI104 initiatives.

Research by means of simulation

A LONG-TERM SOLUTION FOR NUCLEAR WASTE

The future also lies in the final treatment of long-lived high-level waste (LL-HLW). The reprocessing and recycling of reprocessed plutonium and uranium makes it possible to reduce the volume of final waste. The reference solution for EDF remains the closed fuel cycle which first involves burning plutonium in MOX fuels in PWRs, before using other reactors, such as fast reactors as mentioned below, in the long term to continue this recycling process. LL-HLW is separated and conditioned in a glass matrix (vitrification105). Pending the availability of a final repository, this waste is managed and stored at the AREVA plant in La Hague. To free future generations from this responsibility, France confirmed the relevance of a deep geological repository. The CIGEO project led by ANDRA provides such protection by ensuring the passive safety of this waste in the very long term.

102 Jules Horowitz Reactor on the Cadarache site which is currently scheduled for start-up around 2020

103 Organisation for Economic Cooperation and Development104 Electric Power Research Institute (US)105 Just like the vitrification in rocks of radioactive waste produced by

the natural nuclear reactors in Oklo (Gabon) which operated more than 2 billion years ago

A LOOK AT NEW REACTORS

Beyond the EPR NM

I note with interest that studies on more innovative reactors - under SEPTEN leadership - beyond the EPR NM are being progressed along the same lines as pressurised water reactors. With support from EDF’s R&D and partners, this project is exploring new options and available techniques that may provide improved safety margins and competitiveness for the reactors.I will be retaining an overview of the development and testing of new measures likely to improve safety margins, such as the use of combined active and passive systems for core cooling in extreme conditions, the direct injection of cooling water into the reactor vessel, or the in-vessel retention of corium. I believe this innovative approach must also focus on the way operations and maintenance are tied in with design as early as possible.

The LIDEC laboratory in Chinon where irradiated materials are

analysed

SMRs106: an innovative solution

For several years, many small modular reactor (SMR) projects (below 300 MWe) have been put forward around the world, such as in the US, Argentina, China, Russia, Japan or South Korea. The British government highlighted its interest in this type of solution in 2015. These projects are based on compact reactors that are simpler to build and increase standardisation. The objective is to achieve a sufficiently competitive system that is easy to integrate into any electric system.In my previous report I pointed out that the low-power feature of this reactor technology opened the door to novel solutions that could improve current safety 106 Small Modular Reactor

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margins: better reactivity control without using boron, or the removal of decay heat using passive systems.The advantage of these compact reactors must not be lost through an excessive level of complexity during operation, in particular due to requirements of in-service inspection or maintenance. For this reason, I believe here again that the operator should be involved in design studies for the benefit of nuclear safety.

Fast reactors

This reactor technology makes it possible to close the fuel cycle by recycling all fissile and fertile materials. The fast reactors operated throughout the world - Beloyarsk 3 & 4 in Russia, Kalpakkam in India and CEFR107 in China - all comply with the safety standards defined for Generation II reactors.In France, following on from the Rapsodie, Phenix and Superphenix reactors which are now shut down, the CEA is leading the ASTRID project in which EDF is involved. This 600 MWe industrial demonstrator is aiming to achieve the safety levels defined for Generation IV reactors. EDF’s contribution consists in providing its operating experience from the first reactors of this type to simplify operations and maintenance, while exploring in-service inspection possibilities.

Fusion reactors

Every single industrial-scale reactor either in service or under construction throughout the world is, without exception, a fission reactor. The industrial-scale deployment of fusion reactors is expected to take place in the distant future. Many fundamental research programmes remain to be completed and experimental reactors such as ITER108 at Cadarache need to be commissioned before nuclear safety can be examined from an operator’s viewpoint.

107 China Experimental Fast Reactor 108 International Thermonuclear Experimental Reactor

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13 / A WINDOW ON THE WORLD

Krško power plant

Since the Fukushima accident, WANO has increased international cooperation between operators at a time when new countries are considering embarking on nuclear power programmes.

Visiting nuclear facilities in other countries and observing how the same nuclear safety principles are applied in different contexts broadens our outlook and helps us to reassess our convictions.

In China, the start-up of a large number of reactors is giving all the operators involved an opportunity to share the safety challenges of this sensitive stage.

HEIGHTENED IMPORTANCE OF WANO

The World association of nuclear operators, WANO, was formed in 1989 following the Chernobyl nuclear accident on 26 April 1986. Nuclear operators throughout the world decided to work together to ensure that such an accident could never happen again. The aim of this organisation, which has four centres (Atlanta, Moscow, Paris and Tokyo), is to improve the nuclear safety of its 130 members. Following the Fukushima accident on 11 March 2011, the association increased its resources and expertise in order to improve the safety level of the world’s nuclear plants even further. Site assessments in particular were enhanced, including improved plant classifications and better targeting of AFI109. The incorporation of safety at design level by operators was established and peer 109 Area For Improvement: areas identified by peer review

reviews were introduced. With the development of Chinese nuclear power plants, WANO is considering setting up a fifth centre.The Fukushima accident reminded us all of the fact that those involved in the nuclear industry are interdependent: a severe accident anywhere in the world has major consequences for all operators. The increasingly widespread awareness of this is particularly relevant as more and more new countries embrace nuclear power, or are planning to do so. Export, which has until now focused mainly on the sale of reactors, is now moving towards their operation too110. Now more than ever, WANO has an important role to play in helping these newcomers become part of the nuclear family and promoting a strong nuclear safety culture from the outset.

110 As in the case of Russian support to Iran for the Bushehr VVER-1000 or the four APR-1400 at Barakah in the UAE

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EDF Nuclear Performance Model

EDF SA has developed the EDF Nuclear Performance Model to share its experience in managing nuclear power plants. This solution is designed to make it easier for newcomers to the nuclear industry to follow the steps necessary to build projects that comply with the performance standards, starting with nuclear safety.

I commend the EDF Group’s commitment to WANO, both through the secondment of staff, including almost 50 engineers at the Paris centre, and through its involvement in peer reviews. I also note a greater awareness of WANO’s requirements. This has led to an improved compliance rate with respect to Significant operating experience reports (SOER), reaching 94% within EDF Energy.At the WANO biennial meeting, I met members of the international nuclear community, and was struck by their dynamism and openness, which is, to my knowledge, unequalled in any other industry. Away from the aspects of competition or geopolitics, this community fosters cooperation between nuclear operators to promote safety.

GINNA NUCLEAR POWER PLANT

Subsequent to the WANO biennial meeting in Toronto, I decided to visit the Ginna nuclear power plant in the US, not only because of its age (45 years’ operation) but also to assess the changes made since the last IGSNR visit (2011), in particular the implementation of the post-Fukushima modifications.The Ginna nuclear power plant is located near Rochester, New York (US). It comprises a single two-loop PWR built by Westinghouse. With a capability of 580 MWe, it started commercial operation in 1970 (first criticality:

1969). It is therefore one of the oldest nuclear power plants in operation in the world and the oldest PWR in the US. The plant is operated by Exelon and is owned jointly with the EDF Group (49.9%). It works on an 18-month refuelling cycle, with an annual production of approximately 4.7 TWh. It employs 700 staff, with an extra 800 to 1000 people during refuelling outages. It also has a dry fuel store.

Ginna nuclear power plant

I was impressed by the good safety results achieved at this plant, in which the management principles advocated by Exelon have been implemented. What is more, plant availability was 97% in 2014 and it has not been below 92% since 2000, demonstrating the high quality of maintenance in the facilities and their reliability, ensuring their safety. I noted that the facilities were in good condition.I also appreciated the quality with which the post-Fukushima modifications have been deployed in line with US standards. They have been implemented pragmatically and in a way that is specific to the plant, doubtless because the work has been carried out by a local engineering team, with a close relationship with the US nuclear safety authority (NRC). In addition to the installation of mobile equipment, the plant also has increased the cooling and injection capacity at the primary pump seals using permanently installed equipment.Yet this plant is threatened with closure despite its modernisation, its good results, the fact that it is licensed to operate up to 2029 (60 years), and that it enjoys a good level of acceptance by the local population. Like other sites in the US (Oyster Creek, Fitzpatrick and Pilgrim), it could be forced to close on economic grounds, as the low price of gas is pushing down prices on the electricity market. Its operation is optimised, but it is having difficulty matching the lower electricity prices due to its low capacity and the heavy burden of its fixed costs. Despite this difficult situation, I noted the professional operation and ongoing investment to continue improving the safety level of the plant.

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VISIT TO KRŠKO

The purpose of my visit to the Krško nuclear power plant was to assess how an isolated operator (a single reactor) was dealing with the post-Fukushima accident modifications.

Operator at the Krško nuclear power plant

Krško is the only nuclear power plant in Slovenia. It is located on the Sava River, a tributary of the Danube, 78 km east of Ljubljana, approximately 10 km from the border with Croatia. The decision to build the plant was taken in the 1970s, before the breakup of the former Yugoslavia. It is equally owned by Slovenia and Croatia. It has one two-loop PWR built by Westinghouse. Its gross capacity is 727 MWe. The plant was commissioned in 1983 and based on a service life of 40 years. It supplies around 6 TWh per year (2014 figure).I noted that the facilities are well-maintained. A great deal of new equipment has been installed, demonstrating the rigorous maintenance programme, as indicated by the investments made in electrical power supplies (replacement of a transformer and the high-voltage substation). This has made it possible to consider extending the plant’s service life up to 60 years, which was being examined at the time of my visit.The high-quality Periodic safety review approach, implemented via healthy and constructive relations with the Slovenian safety authority (SNSA111), was explained to me. It resulted in several modifications being recommended to increase the reactor’s safety (for example, changes to the primary temperature sensors, and enhancement of the fire detection and suppression system).Following the Fukushima accident, in-depth work, similar to that done by EDF SA, was carried out on the Krško 111 Slovenian Nuclear Safety Administration

plant. In line with the ENSREG112 recommendations, as in the French plants, this work led to responses that had to be implemented immediately, in the medium term, or staggered over time, but all have to be completed by the end of 2018. These include the installation of autocatalytic recombiners, the adoption of a dry filter for the reactor building depressurisation system, and a last-resort diesel generator.As with the Ginna nuclear power plant, I was impressed by the ability to work both in-depth and in a way that is specific to the plant, which I believe is due to two factors: a strong on-site engineering team and high-quality interactions with the safety authority. This dialogue takes into account both European standards and the actual situation in the field. I also noted the culture of openness at the site, which has close links with WANO and INPO.The management also shared their difficulties with me in the face of ever more stringent requirements. It is not easy for an isolated operator to exert much influence in discussions on changes to regulations, or to implement responses on the same scale as an operator the size of EDF SA. The management underlined the role of EDF SA as a leading expert in Europe and asked it to take the situations of small operators into account, in particular when taking a position on subjects.

PARTNERSHIP WITH REA

EDF SA and the Russian operator Rosenergoatom (REA) have been working in partnership since 1994. Within this framework, there is an ongoing programme of discussions between the EDF SA inspector general for safety and his Russian counterpart. This year’s discussions, held in France, included a visit to the Flamanville 3 EPR construction site. One subject in particular caught the attention of the Russian inspector general for safety: the management of safety on a large construction site. Rosatom, the parent company of REA, is a designer-operator like EDF SA and has built many new reactors, including some for export, an area in which it is very active. Discussions between specialists will continue in 2016.

OVERVIEW OF NUCLEAR POWER IN CHINA

Nuclear power was first introduced in China in the 1970s. It was mainly built up by integrating technologies from other countries (France, Russia and Canada). The first Chinese-designed nuclear power plant, Quinshan I, started up in 1994. Daya Bay 1 and 2, also commissioned in 1994, are examples of the former cooperation with 112 European Nuclear Safety REgulators Group

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION A WiNDOW ON ThE WORlD

78

France. A number of Chinese reactors, as well as several based on French 900 MWe plants, Russian VVER and Canadian Candu reactors, were started up around the same time in the early 2000s.

Overview of Russian nuclear power plants

Rosenergoatom, the second largest operator in the world in 2015, operates 36 reactors on ten sites. It has four reactor types:

• 11 RBMKs: graphite-water reactors• 4 EGPs: small 12 MWe reactors which are

scaled-down versions of the RBMK • 19 VVER1: PWRs• 1 BN 600 (1980) and 1 BN 800 (2015): sodium-

cooled fast reactorsVVERs have also been exported widely (around 35 reactors). Six reactors are currently being built in Russia:

• 1 Generation II+ 1000 MWe VVER in Rostov• 2 Generation III 1200 MW VVERs in

Novovoronej, 2 in Leningrad and 1 in the BalticThere are also many export projects involving these reactors.

1 Vodo Vodensi Energetiketsky Reactore

In 2000 it was decided to speed up and rationalise the programme in response to the high demand for electricity. Apart from two new VVERs and an HTGR113 demonstrator, all the reactors are Chinese 1000 MWe PWRs114 derived from the French 900 MWe PWR, built based on a similar organisation to that adopted for French plants: standardisation and a designer-operator approach. The Fukushima accident delayed their deployment and led to some design changes for those plants that were at an earlier stage of development. Twenty-eight reactors of this type are currently in operation or being built, with four to six start-ups a year. Nuclear power is being developed by a number of companies, the main ones being: CNNC115 and CGN. Since 2004, the country has been preparing to move over to Generation III reactors by importing and integrating the various technologies available on the market (Westinghouse AP1000, French EPR and Russian AES-2006) and then developing its own technology: CAP-1400 and Hualong 1000 MWe. Four AP1000s are currently

113 German-designed high-temperature gas reactor with pebble-bed modules

114 CPR-1000 for CGN and M310+ for CNNC, Generation II reactors115 CNNC: China National Nuclear Corporation, the historic national

operator

being built in Sanmen (CNNC) and Haiyang (CPI116), two EPRs in Taishan (TNPJVC117) and a first Hualong in Fuqing (CNNC). At the end of 2015, there were more than 50 reactors in China, half of which were operational (see map). Nuclear power represents a very small fraction of the country’s electricity production (around 3%), a long way behind hydroelectric (over 20%) and coal-based thermal power production (over 70%). At the current rate of construction, China will have the second largest number of nuclear power plants in the world by 2020, and will move into first place in the following decade.China is also actively involved in the entire nuclear cycle: construction, maintenance, fuel, transport and waste. It has developed a heavy industry and manages the construction of its own nuclear power plants. It is now entering the nuclear export market, for example to the UK. It is also looking to close the fuel cycle by developing a fuel reprocessing industry and the China experimental fast reactor (CEFR).

Map of Chinese nuclear power plants

My visit to China started in Beijing, where I met the Chinese nuclear safety authority (NNSA) and the EDF SA teams working there, as well as the nuclear department of the French Embassy. This gave me a good overview of how nuclear power is developing in this country and enabled me to understand the issues at hand, particularly with respect to the acceptability of nuclear power (all the nuclear power plants are currently located on the coast). I also noted China’s ambitious national and international nuclear power programme. I then visited the construction site of the two EPRs in Taishan (see Section 11).Like EDF in the 1980s, China is starting up a large number of reactors every year and has sound know-how, which favours fruitful cooperation between operators.

116 China Power Investment corporation117 Joint venture between CGN (51%), EDF (30%) and Guandong

Guoha Yuedian Taïshan power company (19%)

AppENDiCES THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION

79

14 / APPENDICES

THE INSPECTOR GENERAL’S REPORT 2015 ON NUCLEAR SAFETY AND RADIATION PROTECTION AppENDiCES

80

14.1 - RESULTS FOR THE EDF SA FLEET

Indicator 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

1 Number of significant nuclear safety events graded 1 or greater on INES per reactor1 1.22 0.80 1.15 1.17 1.17 0.91 1.55 1.19 1.14 1.16

2 Number of significant nuclear safety events (0 or greater on INES), per reactor! 10.21 10.80 10.34 10.93 10.45 10.57 11.90 11.60 10.8 10.03

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

1.55 1.70 1.70 1.39 1.55 1.36 1.52 1.34 1.55 1.24

4 Number of alignment errors2, per reactor

0.69 0.57 0.62 0.53 0.77 0.71 0.70 0.66 0.60 1.03

5

Number of trips per reactor (for 7,000 hours of criticality3) • Automatic 0.89 0.87 0.51 0.71 0.69 0.50 0.55 0.59 0.53 0.66

• Manual 0 0 0 0 0.01 0.05 0.03 0.03 0.07 0

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

0.69 0.63 0.66 0.69 0.62 0.71 0.67 0.79 0.72 0.71

7

Exposure of individuals 4: • 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 17 20 14 10 3 2 2 0 0 0

• Number of individuals with doses between 14 and 16 mSv - - - - 60 43 22 18 5 2

8 Number of significant radiation protection events

112 99 107 102 91 92 114 116 113 109

9 Availability (%) 83.6 80.2 79.2 78.0 78.5 80.7 79.7 78.0 80.9 80.76

10 Unplanned unavailability (%) 3.3 3.7 4.4 4.6 5.2 2.2 2.8 2.6 2.4 2.48

11 Occupational accident rate with sick leave (per million hours worked)5 5.6 4.6 4.4 4.3 4.1 3.9 3.5 3.3 3.2 2.7

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

2 Any configuration of a system or its utilities that deviates from the expected situation and is a cause of a significant event

3 Average value for all reactors, unlike the WANO parameter which is based on the median value

4 Maximum dose reached in the year

5 Accident rate for EDF SA and its contractors


81

14.2 - RESULTS FOR THE EDF ENERGY FLEET

No. Indicator 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

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

3.13 1.20 1.13 0.80 0.93 1.33 0.80 0.80 0.33 0.47

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

7.53 4.93 4.53 5.47 5.60 4.7 4.6 5.1 4.5 7.40

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

0.73 0.13 0.27 0.13 0.60 0.33 1.67 0.67 1.53 1.00

4 Number of alignment errors, per reactor 0.69 0.13 0.27 0.13 0.60 0.33 3.07 3.33 2.80 2.87

5

Number of unscheduled trips, per reactor (for 7,000 hours of criticality) • Automatic 0.73 0.44 1.13 0.82 0.58 0.74 0.64 0.45 1.17 0.57

• Manual 2.54 1.48 1.04 1.44 1.68 1.22 0.84 1.03 0.62 0.19

6

Average collective dose, per unit in service (in man-Sv) • PWR 0.524 0.045 0.264 0.337 0.271 0.537 0.037 0.386 0.365 0.048

• AGR 0.152 0.071 0.167 0.100 0.018 0.084 0.063 0.034 0.074 0.067

7

Exposure of individuals: • 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

249 58 38 31 43 43 50 27 27 18

9

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

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

77.30 100 73.7

10

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

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

10.7 0.7 12.3

2.3 0

2.7

11 Occupational accident rate with sick leave (per million hours worked)1 1.1 1.4 1.8 0.6 0.4 0.6 0.5 0.7 0.2 0.4

1 Accident rate for EDF Energy and its contractors

Factors to be taken into account in comparing the results of EDF SA with those of EDF Energy:• Line 2: the procedure for declaring events to the UK safety authority changed in 2015, which means more

events are now declared than in the past• 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)


82

14.3 - 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


83

14.4 - 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


84

14.5 - KEY DATES FOR THE EDF SA NUCLEAR UNITS

Year commissioned

service

Nuclear unit

power in MWe*

vD1 vD2 vD3Year

commissioned service

Nuclear unit

power 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 2015

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 2015 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 2015 1992 penly 2 1330 2004 2014 -

1983 Blayais 4 910 1995 2005 2015 1993 golfech 2 1310 2004 2014 -

1983 Chinon B2 905 1996 2006 - 1996 Chooz B1 1500 2010 - -

1983 Cruas 1 915 1995 2005 2015 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 - -

vD: First ten-yearly inspection outagevD2: Second ten-yearly inspection outagevD3: Third ten-yearly inspection outage

*Net continuous power


85

14.6 - KEY DATES FOR THE EDF ENERGY NUCLEAR UNITS

Year commissioned

serviceNuclear unit

Reactor Number

powerMWe Rup

(1)

planned date of withdrawal from service

(2)

1976 hinkley point B R3 480 2023

1976 hinkley point B R4 475 2023

1976 hunterston B R3 480 2023

1976 hunterston B R4 485 2023

1983 Dungeness B R21 525 2028

1983 Dungeness B R22 525 2028

1983 heysham 1 R1 580 2019

1983 heysham 1 R2 575 2019

1983 hartlepool R1 595 2019

1983 hartlepool R2 585 2019

1988 heysham 2 R7 615 2023

1988 heysham 2 R8 615 2023

1988 Torness R1 590 2023

1988 Torness R2 595 2023

1995 Sizewell B 1198 2035

(1) Reference unit power (Rup): 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 officially made on 1 january 2015.


86

14.7 - TABLE OF ABBREVIATIONS

A AGR Advanced Gas-cooled ReactorALARA As Low As Reasonably AchievableAMELIE Project to transform spare part logisticsAMT EDF fleet maintenance agencyANDRA French national radioactive waste

management agencyASG Steam generator auxiliary feedwater supplyASN French nuclear safety authority

B BMA Standardised activity model library

C CAP Annual performance contractCEFRI French committee for the certification

of companies in training and monitoring radiation workers

CEIDRE Expertise and inspection department for manufacturing and operation

CENG Constellation Energy Nuclear Group (US)CETIC PWR NSSS fieldwork technical validation

experimental centreCGN China Guangdong Nuclear Power Company

(China)CLI Local information commissionCNEN Nuclear engineering departmentCNEPE Electromechanical & plant engineering

support centreCOLIMO A campaign to modernise tagging and

alignment practices and methodsCOMSAT Unit outage safety commissionCOPAT Unit outage operational control committeeCRT Technical standards committeeCSN Nuclear safety councilCSNE Operations nuclear safety review committee

(DPN)

D DAIP Industrial support for production divisionDCN Nuclear fuel divisionDIPDE Nuclear fleet engineering, decommissioning

& environment division DIPNN Engineering & new-build projects directorateDMES Commissioning documentationDPDD Decommissioning & waste projects divisionDPNT Nuclear & conventional fleet directorate DOE Department Of Energy (US) DPN Nuclear generation divisionDRS Nuclear safety standards directorate DTG General technical department

E EIPS Equipment protected for nuclear safety

reasonsEGE Overall nuclear safety assessmentENISS European Nuclear Installations Safety

StandardESPN Nuclear pressure equipmentEPR European Pressurised ReactorEPRI Electric Power Research Institute (US)ESR Significant radiation protection eventESS Significant nuclear safety eventEVEREST EDF project to allow workers to enter

controlled areas wearing ordinary work clothes

ENSREG European Nuclear Safety Regulators GroupEXELON Electric utility (US)

F FIS Independent nuclear safety oversightFME Foreign Material Exclusion

G GDA Generic Design Assessment (UK)GIEC Intergovernmental panel on climate change

(UN)GPEC Advanced planning of jobs and skillsGPSN Nuclear safety performance group (UNIE)

H HCTISN High committee for transparency and

information on nuclear mattersHLW High Level Waste


87

I IAEA International Atomic Energy AgencyICRP International Commission on Radiological

ProtectionILW Intermediate Level WasteIN Nuclear Inspectorate (DPN)INA Independent Nuclear Assurance (EDF Energy)INB Licensed nuclear facilityINES International Nuclear Event ScaleINPO Institute of Nuclear Power Operators (US)INSAG International Safety Advisory Group (IAEA)IOP Operations engineeringIRAS Plant engineer interface with the ASN (NPPs)

J JANSI JApan Nuclear Safety InstituteJNES Japan Nuclear Energy Safety organisation

L LLS Turbo-alternator last-resort power supplyLLW Low Level WasteLWRS Light Water Reactor Sustainability

programme

M MAE Engineering audit unit at the DIPNNMARN Nuclear hazard management support teamMDEP Multinational Design Evaluation ProgrammeMOPIA Project to set in place an attractive business

policyMME Operations and maintenance methodsMQME Campaign to raise the standards in

maintenance and operation (DPN)MRI Fire risk management

N N4 French Generation II 1400 MWe NCC Operating professions common coreNCME In-service maintenance professions common

coreNDA Nuclear Decommissioning Authority (UK)NEA OECD Nuclear Energy AgencyNEI Nuclear Energy Institute (US)NNB Nuclear New Build (EDF Energy)NNSA National Nuclear Safety Administration

(China)NPP Nuclear Power PlantNRA Nuclear Regulatory Authority (Japan)NRC Nuclear Regulatory Commission (US)NSOO Nuclear Safety Oversight Office (TEPCO,

Japan)

NSSC Nuclear Safety and Security Commission (South Korea)

O O2EI / OEEI Better housekeeping campaign (DPN

initiative)OIU Internal inspection organisationONR Office for Nuclear Regulation (UK)OPEX OPerating EXperienceOSART Operational Safety Analysis Review Team

(IAEA)

P PARTNER Ecologically-sensitive nuclear plant

administrative facility refurbishmentPBMP Basic preventive maintenance programmePCCEO Skills advisory centre for organisational

effectiveness at the DPNPDC Nuclear engineering key skills development

planPGAC Worksite general assistance servicesPHPM Methods and practices harmonisation

project PUI Onsite emergency planPWR Pressurised Water Reactor

R RCE Campaign to reinforce design capacity

(SEPTEN)RCP Main primary cooling system of the reactorRCV Chemical and volume control system of the

reactor’s main primary systemR&D Research & Development directorateREB Boiling Water ReactorRIS Emergency water injection system for

reactor coolingRET Exceptional work permitRGV Steam generator replacementROSATOM Russian federal atomic energy agencyRPN Neutron flux instrumentation systemRTE Power grid companyRTGE General technical rules intended to avoid or

mitigate the off-site nuisances and hazards associated with the operation of licensed nuclear facilities

RTGV Steam generator tube rupture


88

S SAT Systematic Approach to TrainingSDIN Nuclear technical information systemSDIS Local fire and rescue servicesSGDSN French national committee of public safety

and defenceSEPTEN Nuclear and conventional design department SIR Authorised internal inspection departmentSMI Integrated management systemSOER Significant Operating Experience Report

issued by WANOSOFINEL Joint EDF and AREVA design officeSOH Socio-organizational and human approachSPR Risk management departmentSRD Safety and Regulation Department (EDF

Energy)STE Technical specifications SYGMA Computerised maintenance management

system

T TEM Unit in serviceTEPCO Tokyo Electric Power Company (Japan)TNPCJVC Joint venture between the Chinese company

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

TSM Technical Support Mission by peers organised by WANO

TSN French nuclear safety & transparency actTVO Teollisuuden Voima Oy (Finland)

U UFPI Operations & engineering training unitUNIE Operations engineering unitUNISTAR EDF Group company in the USUNGG Gas-cooled graphite-moderated reactorUTO Central technical support department

V VD Ten-yearly inspection outageVP Partial inspection outage

W WENRA West European Nuclear Regulators

AssociationWNA World Nuclear AssociationWANO World Association of Nuclear Operators


89

Jean-Jacques LÉTALON, Bernard MAILLARD, Jean-Paul COMBÉMOREL Jean-Michel FOURMENT, François de LASTIC, John MORRISON

Mike LAVELLE, Bernard MAILLARD, François de LASTIC, François HÉDIN, Jean-Jacques LÉTALON, Jean-Michel FOURMENT, Jean-Paul COMBÉMOREL

PHOTO CREDITS

Cover : © Monty Rakusen’s Studio - Anthony Rakusen Chapter 1 : © EDF Mediathéque - Chapter 2 : © EDF Médiathèque - Chapter 3 : © EDF Médiathèque - Chapter 4 : © EDF Médiathèque - Bruno CONTY Chapter 5 : © EDF Médiathèque - Cyril CRESPEAU Chapter 6 : © EDF Médiathèque - Chapter 7 : © EDF Médiathèque - Bruno GAVARD Chapter 8 : © EDF Médiathèque - Laurent VAUTRIN Chapter 9 : © EDF Médiathèque - Olivier GUERRIN Chapter 10 : © EDF Médiathèque - Marc DIDIER Chapter 11 : © Centrale de Taishan Chapter 12 : © EDF Médiathèque - Philippe ERANIANChapter 13 : © Centrale de Krško

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