on nuclear safety and radiation protection - energie edf

2012

The Inspector General’s report

on Nuclear Safety andRadiation Protection

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

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FOREWORD

This report is destined for the Chairman of EDF with the purpose of informing him of my judgement of nuclear safety and radiation protection within the

EDF Group. The continuous improvement of nuclear safety results is a fundamental commitment of the EDF Group. In 2012, this notably took the form of the adoption of a group-wide nuclear safety policy.

This report is also intended for all who, in any way, contribute to improving nuclear safety. It may also prove useful to those outside the company who work in the nuclear field and any other branches of industry where there are risks to be managed and who wish to contribute to the debate. It highlights the need for sharing experience feedback between all the nuclear operators in the EDF Group and as well as more broadly via WANO.1

It offers a view from outside the organisational structure and is based on facts and findings gathered in our contacts with field staff and during discussions with the decision makers, managers, medical personnel and trade unions as well as outside stakeholders, especially contractor companies. The resulting view of the situation in the field is particularly instructive.

Emphasis is therefore placed more on difficulties and weaknesses than strengths and progress, which may appear unfair to those working hard at running our complex and demanding nuclear power generating facilities on a daily basis. When it comes to nuclear safety, only mentioning what is going well is the first step towards complacency. It is therefore essential to share any difficulties and corresponding warning signals.

1 WANO: World Association of Nuclear Operators

I would like to thank all those I met, both inside and outside the EDF Group in France and elsewhere, for the probity of their welcome, for discussing matters so frankly and creating the conditions for fruitful interchange. Their openness, vital to the relevance of this report, continues to reflect the spirit of nuclear safety culture. Their contributions may not always be found in this report as the range of subjects has had to be restricted. The year saw the departure of André-Claude Lacoste, who has been replaced by Pierre-Franck Chevet at the head of the French nuclear safety authority (ASN). Mr Lacoste was the face of nuclear safety at the service of the general public for two decades.

I would also like to thank my advisers Jean-Paul Combémorel, Bruno Coraça and Peter Wakefield who, once again this year, were unstinting in their efforts. Thanks also to Bernard Maillard who has just joined us and Christian Thézée who left the team after twelve years of contribution.

Finally, although this document has not been written for the purpose of public relations, as in previous years, it will be available to the general public on the EDF website in both French and English (www.edf.fr). Two years after the Fukushima accident and in the midst of intense debate about the future of energy supply, I hope it will bring a contribution to all readers interested in nuclear safety.

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

Jean Tandonnet Paris, 18 January 2013

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

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CONTENTS

01/ My view of 2012 5

02/ Nuclear operating safety: contrasting results 11

03/ Nuclear safety management: remaining vigilant 15

04/ Safety in the workplace: France rises to the challenge 23

05/ Radiation protection: need for ambitious goals 27

06/ Training updated and better led by line managment 31

07/ Maintenance, a strategic domain 39

08/ Nuclear technical information system: still a long road ahead 45

09/ Attention to chemistry needed in operations 49

10/ A new impetus for the EPR-type reactors 53

11/ Plant life extension is conditioned by nuclear safety 59

12/ Post-Fukushima: the nuclear operators are mobilised 65

13/ Noteworthy operating events 73

14/ Appendices 79

Result indicators :

14.1 EDF SA nuclear power plants __________________________________________________ 80

14.2 EDF Energy nuclear power plants ______________________________________________ 81

14.3 Constellation Energy Nuclear Group nuclear power plants _______________________ 82

Maps:

14.4 EDF SA nuclear power plants __________________________________________________ 83

14.5 EDF Energy nuclear power plants ______________________________________________ 84

14.6 Constellation Nuclear Energy Group nuclear power plants _______________________ 85

Technical key dates:

14.7 EDF SA nuclear units __________________________________________________________ 86

14.8 EDF Energy nuclear units_______________________________________________________ 87

14.9 Constellation Nuclear Energy Group nuclear units _______________________________ 87

14.10 Table of abbreviations ________________________________________________________ 89

MY VIEW OF 2012 THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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01/ MY VIEW OF 2012

Chinon nuclear power plant

AN EVOLVING CONTEXT

2012 was marked by the aftermath of the Fukushima accident. Beyond some changes in nuclear policy in some European countries, 2012 was a year of transformation and development in the nuclear industry worldwide. Most countries have confirmed that they will be continuing with their nuclear programmes, with the exceptions of Germany and Italy, as well as possibly Switzerland and Belgium where reactors have been and will be taken out of service early on political grounds. No less than sixty reactors are currently under construction, some by countries which are entering the industry for the first time. The United Kingdom, where the EDF Group is firmly established, is continuing its nuclear revival.The year 2012 was also a year rich in international exchanges to disseminate the lessons learned from the Fukushima accident and to consolidate operator commitments. The effects of the accident have been perceptible everywhere and even if no immediate emergency measures needed to be taken, the response (underway or pending) has varied substantially from one country to another, depending on the views of the different nuclear safety authorities, governments and operators. The stance of each country

reflects the history of its energy needs, its public opinion and policy considerations. Despite the commendable harmonisation work that has taken place in Europe via WENRA (West European Nuclear Regulators Association) and ENSREG (European Nuclear Safety Regulators Group), acting as forums for the nuclear safety authorities of the European Union member states, the response has mainly been a national matter.

In France, the recently announced early closure of Fessenheim Nuclear Power Plant in 2016 has been a source of incomprehension and even apprehension, considering the first reactor had just been authorised by the ASN to operate for up to forty years. This has been a serious concern first and foremost for the plant staff. I will be focusing on this issue. This needs to be considered in the light of debate on the energy transition and energy policy reviews of France’s neighbouring countries. I am also interested in the ability of the company to provide funding to preserve its assets and improve safety levels in the future.In Europe, the United Kingdom has made a firm commitment to nuclear power in its energy policy. In December 2012, the Office for Nuclear Regulation (ONR) granted EDF Energy a site license allowing the NNB

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION MY VIEW OF 2012

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Generation Company (NNB GenCo) to build and operate two EPR units at the Hinkley Point site. This is the first license of this type granted for 25 years. Furthermore, the EPR-type received a positive outcome to the Generic Design Assessment (GDA) at the end of the year.I observe that, in Japan, fundamental changes are in hand to reinforce the authority of the regulator, to consolidate the nuclear safety commitments of the operating organisations in a way similar to INPO (Institute of Nuclear Power Operators) in the USA and to reinforce nuclear safety within TEPCO (Tokyo Electric Power Company). Looking at the situation around the world, I am concerned about the shortcomings in safety culture in South Korea, despite the Fukushima alert. The lack of transparency on the incident that occurred in February 2012 at Kori Nuclear Power Plant and the malpractice concerning spare parts are particularly striking. I would like to emphasise that, despite differences in national culture, operators need to make sure that safety culture is always of paramount importance.This 2012 report is thus appearing at a time of change; in France, it is also a time of massive renewal of skills and preparation for the General Refurbishment. In the United Kingdom, this has been a period characterised by plant life extension for the AGRs (Advanced Gas-cooled Reactors) and by the decision-making leading up to the construction of four EPRs.In this context, what overall picture can be had of the year as concerns nuclear safety and radiation protection within the EDF Group? My assessment reflects my analysis of the results and events, as well observations in the field in France, in the UK and in the USA. The findings confirm that there are firm commitments and solid skills among the players in the nuclear industry at this challenging and complex juncture. What is encouraging is that the incoming generation of new recruits is a real asset for the Group. They are open to change and readily adapt to the new requirements of the different professions. I would like to, once again, reiterate my support for the plant managers, who are faced with a complicated situation and are showing a remarkable level of application.

CONTRASTING PERFORMANCE IN THE FIELD OF NUCLEAR SAFETY

First and foremost, I note that no major event occurred in any of the Group’s nuclear power plants. The continuous improvement of nuclear safety levels remains the goal of the company, with a number of issues having caught my attention. Some of these issues need to be resolved while others need to be kept under surveillance.Within the EDF Group, there was one event that was graded Level 2 on the INES (International Nuclear Event

Scale), relating to a case of an equipment discrepancy in France with no direct nuclear safety implications. I would also like to mention that there has been an increase in the number of noteworthy events, which need to be seen as warning signals and treated with due regard. I am concerned that, in France, there has been an increased amount of sub-standard maintenance work and insufficient proficiency in the management of unit outages. These are covered in further detail in the report. As concerns nuclear safety, I note that the commitment is flagging to the action plans begun some years ago, resulting in a substantial increase in the number of events that are significant in terms of nuclear safety.In the UK, the indicators are encouraging as a whole. I did however observe that improvements are needed in the fields of reactors trips and fire control, which are not up to French standards.In the USA, CENG (Constellation Energy Nuclear Group) has indicators that reveal considerable disparity between their three sites. I note that the operability of the standby diesel generators is well below the international levels achieved in France and the UK, and I welcome the action recently begun by INPO to make progress in this area.In France, the independent internal nuclear safety organisations remain solid and professional, although the somewhat limited professional experience of some of the staff shows that vigilance must be maintained. In the UK, work on introducing a new organisational structure is continuing. I am glad to see the deployment of the EDF Group’s nuclear safety policy and the now regular review of the safety indicators at the highest level. This appears to reflect the positive effect of emulation. As concerns radiation protection exposure has been stable in the EDF Group, yet international comparisons show that there is still room for improvement. I wish to draw attention to the increasing number of significant incidents in France. In the lead-up to the General Refurbishment, I would like to again emphasise the need to give new life to drives to ensure ALARA (As Low As Reasonably Achievable) approaches are being followed.Finally, despite a slight improvement, industrial safety levels in France are neither up to international standards, nor as good as the results achieved by EDF Energy.


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The General Refurbishment at EDF SA

The Generation 2020 Project is designed to increase the reliability of organisation and equipment (maintenance and replacement of key components) by 2015 and subsequently to make sure that the installations are renovated with due regard for what has been learned from the Fukushima accident to further increase nuclear safety at the time of the third ten-yearly inspections of the 1,300 MWe nuclear units and the fourth ten-yearly inspections of the 900 MWe

nuclear units. Dubbed the General Refurbishment, the investment programme forms part of the overall plant for operations of the plants for up to sixty years and will multiply the number of maintenance operations by a factor of four in the coming decade.

SEVEN ISSUES NEEDING ATTENTION

My visits and encounters in the field have provided me with first-hand information helping me to identify any nuclear safety concerns. The differences between the different nuclear plant types in the EDF Group and the disparity between the sites render comparison a complicated matter. At the end of 2012, I find that seven key issues need the attention of the corporate management. Some of these issues are covered in more detail in subsequent chapters of this report. These essentially relate to the French plants, but I have made a point of putting them into perspective by comparison within the EDF Group as a whole and with other plants throughout the world.

Teams heavily loaded

Last year, I highlighted in France the need for better task prioritisation, particularly among front-line managers, planners and outage staff, who have been finding it difficult to focus their efforts when faced with an ever increasing workload. This is also true for the engineering centres, which need to simultaneously deal with plant support, planning of ten-yearly outages (French acronym VD), studies for plant life extension and post-Fukushima measures. As target dates are being brought forward, the task is made more complex and much harder at a time when the renewal of skills is in full swing. I am worried that we are attempting to do too much and too quickly, and that the required quality levels or everyday nuclear safety in the plants may suffer. To rise to the challenge, it is necessary to work with the ASN to target priority actions where there is significant effect on nuclear safety. I am also concerned about the number of requirements issued during the past year. The timetable established, particularly in the heat of the action during the Fukushima crisis, cannot realistically be adhered to by either EDF SA and its suppliers on the one hand, or

the ASN and its specialist adviser, the institute for nuclear safety and radiation protection (IRSN) on the other.I consider that the volume of technical and documentary modifications in the existing plants is excessive. In view of what I have observed at other nuclear operators, I wonder whether there is not an unfortunate French tendency to seek to permanently modify the installations. Also, too often, the supporting documentation is not up to standard.This year, once again, I wish to highlight the urgent need to deal with the increased bureaucratisation and complexification of the life of work teams. I was glad to note and strongly approved of the warning about this issue given by the President and CEO of INPO during a recent conference bringing together the heads of the nuclear operating organisations affiliated to INPO.

An unprecedented effort, but skills still in short demand

As mentioned in my past reports, in the prevailing industrial context, the French nuclear power plants are facing the unprecedented challenge of renewing more than half of their manpower by 2017. This year, recruitment has accordingly continued with some 2000 new arrivals at the EDF Nuclear Operations Division and Nuclear Engineering Division. I would, however, like to draw the attention of the maintenance professions to this situation as their needs are ever increasing and I have observed cases where supernumerary arrangements to cope with the demand appear to be insufficient. Provision of planning staff has always been problematic. It is to be remembered that, in the coming years, the lessons of the Fukushima accident will need to be addressed (Nuclear Rapid Response Force, reinforced operations staff etc.).I appreciate the roll-out of the skills programme and the excellent synergy between the EDF Group’s teams in France and the UK. In the plants visited in France, I noted the increased autonomy of the managers and the


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commitment of the staff who are indeed the best placed to determine their requirements.As regards training, I am happy to see the increase in the physical resources and the hiring of instructors, although I would like to point out that the number of experienced instructors is still too low.

Reinforcing relations with the ASN and building a common vision

In France, in the aftermath of the Fukushima event, the promulgation of the Nuclear Safety and Transparency Act and associated ministerial orders, particularly the order on licenced nuclear facilities issued in February 2012, and the large number of cases to be processed, I have noticed that, in general, the relations between the operator and the safety authority are becoming more strained. The staff on both sides are under considerable pressure and close scrutiny, not least from the media. The post-Fukushima case files, the case files for the forthcoming ten-yearly outages, and future ones relating to plant life extension cannot be considered separately. The investment of considerable human and financial resources is therefore required, with major industrial constraints.I believe that such a situation calls for dialogue at the highest level between the operating organisation responsible for the nuclear safety of the facilities and the nuclear safety authority. This dialogue, which needs to include the IRSN, while respecting the roles of all the parties, needs to foster agreement on a method and timetable that is as full and detailed as possible covering all the work planned. I would like to draw attention to the importance of the plan being truly realistic, in a context where resources are strictly limited, including for expert appraisal by the ASN’s specialist adviser.In the field, I have observed good practices in certain plants to help build up very positive relationships with the ASN at plant level and with the IRSN: the independent nuclear safety channels are given recognition, the engineers liaising with the safety authority are especially experienced and the plant manager has been able to establish close relations with the head of the local ASN branch. Dealings with the safety authority are therefore of better quality and more effective. I would like to see such practices developing in all the plants.

Now part of the laws relating to the environment, the Nuclear Safety and Transparency Act puts the ASN in charge of monitoring discharges into the environment, even if not radioactive. The rules are now so extensive and complex that I am not certain the plant managers

have realised the growing significance of this difficult issue. As a result, legal challenges are being faced more often by plant managers together with considerable media pressure, even though they may sometimes appear disproportionate.I would also like to highlight the increasing difficulty of finding common ground with the government labour inspectors, in their role of industrial safety advisers. This may lead to the staff losing confidence in the inspectors and their credibility being diminished. The legitimacy of the questions is not an issue, but the risk of drifting towards a situation where checking is simply based on documentation without due prioritisation. I am not persuaded that this situation leads to greater transparency.

Industrial safety in EDF Energy Nuclear Generation: setting a good example

Industrial safety must not become the poor relative of nuclear safety and radiation protection, as it is fundamental to nuclear plant operating performance. I consider that industrial safety should be given higher priority by the front-line managers in the French power plants, as is the case in the UK. EDF Energy Nuclear Generation, which has focused on the issue for many years, produces results that are ten times better than those of the French plants.

Despite progress made in 2011, I had already warned about the industrial safety situation in France. Although I noted clear signs of progress in response to my concerns on the EPR worksite at Flamanville, the slight improvements elsewhere do not meet my expectations. The results reveal considerable differences between plants. I therefore urge that intentions be clearly announced in France to rectify the situation, as the improvements in certain plants show that this is perfectly possible. When it comes to industrial safety, the desired behaviours are the same as for good nuclear safety culture.

In the USA, I noticed that the Constellation Nuclear Energy Group’s industrial safety results did not match its ambitions. The management has taken note of the difficulties encountered and has set an action plan in place.

EPR projects: key milestones that remain to be passed

Twenty years after the last new nuclear plant was built in France, the difficulties in 2011 have provided


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experience feedback on a project of this scale, for both EDF and its suppliers. The way the EPR project has been conducted and the associated organisational structure have been completely changed and I am pleased at what I now see, in particular as regards the Nuclear Design & Construction Centre (French acronym CNEN). Nonetheless, the detailed planning - the scale of which was under-resourced for all too long - has not yet gained the confidence of all staff. This needs to be emphasised. Progress is also being made in the UK. As regards the Hinkley Point EPR project, the year was marked by the newly clarified division of responsibilities between Nuclear New Build (the owner-operator) and EDF Nuclear Engineering Division (French acronym DIN) the designer. A joint steering committee was also appointed and the Project Execution Plan was approved, resulting in the granting of the site license.At the Flamanville 3 construction site, 2012 was marked by the episode involving the reactor building crane bracket, but work is continuing. I note with satisfaction that, at the end of the year, 93% of the civil engineering work and 37% of the electrical and mechanical equipment erection work was completed. I also appreciated the orderliness of the worksite and the industrial safety results which will need to be kept up. I still regret the lack of close cooperation between the Nuclear Engineering Division staff and the staff of the Nuclear Operations Division, the future operating organisation.At a time when the four EPRs under construction in China, Finland and France are progressing at a rate which should see them commissioned around the same time, I have observed a stronger EPR community, particularly via the EPR Family which has been joined by the Finnish electricity company TVO (Teollisuuden Voima Oy).Finally, I would like to draw attention to the considerable amount of work that remains to be done, in a limited time span, to qualify the equipment for accident conditions and supply the nuclear safety studies.

The challenges of an ambitious business policy

The General Refurbishment programme commencing with the first third Ten-Yearly outage (VD3) outage of the 1,300 MWe series plants at the Paluel site in 2015 will be a major challenge. With twice the number of tasks and increased levels of complexity, it will be necessary to accordingly adapt the business policy and the purchasing strategy with the suppliers and workers. Announcing the contractual arrangements at an early stage of the programme to enable contractors to properly plan

ahead with their investments and to form their teams appears to be indispensable.Over the past decade, a number of provisions have specified the working conditions for contractor staff in the nuclear industry. In 2012, the strategic committee for nuclear engineering (French acronym CSFN) drew up a social charter which forms part of every tender package sent by the nuclear operators to the contractor companies. This document was hailed by the High Committee for Nuclear Safety and Transparency (HCTISN) as “a clear advance in relations between operator clients and contractors”. During my future inspections, I will make a point of checking its application.I continue to believe that contractors all need to be more aware of the requirements of nuclear safety and to improve their safety culture. I would also like to draw attention to the EDF internal pre-requisites relating to work management and increased hands-on fieldwork time.Throughout the year, I have also noted the importance of logistics, a field all too often seen as secondary and disregarded, resulting in lack of equipment, as well as slowness to respond and reduced availability of certain players. Proper selection of the companies in charge of logistics is vital for the effectiveness and the safety of an entire site. I call for great care in the selection process, with due regard for the quality of the management to be provided and allowance for the opinion of the plant management.

Leadership for nuclear safety: a collective commitment

The largest nuclear operator in the world, EDF is faced with very different contexts in France, the UK, the USA and China. Operation of nuclear plants calls for recognised leadership in the field of nuclear safety. “Leadership is not about management. On the contrary, it is a rampart against a type of management that ‘distracts’ from operations”. I fully endorse this definition of leadership by Robert F. Willard, President and CEO of INPO.

Leadership requires all those in control, at corporate and plant level, to determine the nuclear safety goals for operations and to establish and apply the corresponding priorities. I have frequently observed good examples of leadership, buttressed by on-going, transparent communication, both inside the company and with external players. Yet, I have also sometimes noticed major projects with no clear goals and over-complicated annual plans. Leadership also requires the regular on-job presence of the front-line managers for their


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intentions to be enforced. I would like to comment on EDF Energy’s commitment in this area, which was favourably highlighted in a recent WANO Corporate Peer Review. In France, I hope that the Nuclear Operations Division will succeed with its “operational re-focusing”, particularly in the form of increased subsidiarity and delegation of powers to the plants. In accordance with the nuclear safety policy of the EDF Group, I would like to draw attention to the fact that leadership must also find its expression at the highest levels, particularly in corporate governance situations and in public fora.The EDF Group also has responsibility as a leader in international bodies such as WANO and the European Nuclear Installations Safety Standards initiative. I am glad to see it participating in actions such as those adopted by WANO in Shenzhen in 2011. The EDF Group will be reinforcing its team of engineers on secondment to WANO in Paris from 25 members at the end of 2012 to 60 in 2015. I also hail the nomination of Jacques Regaldo who succeeds Laurent Stricker as Chairman of WANO.

NUCLEAR OPERATING SAFETY: CONTRASTING RESULTS THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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02/ NUCLEAR OPERATING SAFETY: CONTRASTING RESULTS

An operator in the control room

The year 2012 was marked by contrasting nuclear safety results in the French plants while those of the EDF Energy plants were mostly unchanged. The results for Constellation Energy Nuclear Group in the USA also varied.

OPERATIONAL RESULTS

In the French plants

I would first like to mention the declaration of a nuclear safety significant event ranked 2 on the International Nuclear Event Scale (INES) after discovering a discrepancy in early 2012 that had been present since construction in the anti-siphon systems of some of the fuel storage pools. This event, which had no immediate nuclear safety repercussions reflected shortcomings in our management of discrepancies and in the speed at which they are rectified. Secondly, I note the substantial increase (+16%) in the incidence of nuclear safety significant events (11.9 per reactor) compared with 2011, as well as the number of events ranked 1 on the INES (1.55 per reactor). Although I still consider EDF SA’s level of transparency to be good, this deterioration calls for in-depth analysis and

corrective action. This trend - contrary to the progress in 2011 - is mainly due to an increase in the number of events occurring during maintenance activities (+40%), the increase in discrepancies in operation of the installations being more limited (+10%).

Real grounds for satisfaction

At 0.55, the number of scrams was comparable to that in 2011 (the best result in French plant history), confirming the progress in previous years and showing that the highest international standards had been reached. In 2012, there was not a single scram in any of thirty six reactors for the whole year.

In other areas with major nuclear safety implications, such as administrative lockout and reactor control (remaining within the authorised operating envelope), the progress recorded in 2011 has been consolidated.

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION NUCLEAR OPERATING SAFETY: CONTRASTING RESULTS

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I also confirmed the continued good results achieved in 2012 in the field of fire hazards (fighting, organisation and training), with few outbreaks and no major fire-related events. An event that occurred on 5 April 2012 relating to a Penly 2 reactor coolant pump warranted my attention. It was not considered as a major outbreak of fire according to the definitions in force, but it did occur in the reactor building near equipment important for nuclear safety, which constitutes a noteworthy event. Firstly, I note the responsiveness and efficiency of the plant response team, which was rapidly backed up by the Civil Accident Response Services (French acronym SDIS). Secondly, analysis of the event revealed sub-standard maintenance followed by sub-standard operation. I observe increasing care in observing the fire rules with players that are motivated and respected: plant response staff, Risk Management Department technicians, and fire brigade officers. Once again this year, I would like to emphasise the care needed in replacing the first generation of fire brigade officers, and I encourage the plant managers to focus on fire prevention as a priority matter.I also note the forced loss rate (during reactor operation) which confirms the progress made in 2011. With an average rate of 2.8%, the French plants are now at a good international level. I see this as the combined effect of the very substantial investments begun some years ago to address the aging of some main components (alternators and transformers) and the progress with rationalisation of the activities performed with the reactor in operation, together with far stricter management of the technical hazards. These results, recorded over the last two years (was above 5% in 2010) are contributing to nuclear safety by reducing the number of unplanned reactor transients. Nonetheless, I regret that we are not yet seeing comparable progress with the extension of unit outages, which is also highly prejudicial to nuclear safety.Finally, I would like to emphasise the high availability of the engineered safety systems such as the safety injection system, the steam generator auxiliary feedwater system, and emergency diesels with the very low unavailability factors of 0.13%, 0.01% and 0.04% respectively (WANO indicators). The operating organisation must be constantly vigilant to minimise the outage time for maintenance and testing of this indispensable equipment to minimise accident risks and mitigate their consequences. The results for the French plants are also among the best in the world.

Subjects for attention

The nuclear safety significant events detected during unit outage activities and during activities conducted with the reactor in service are similarly numerous in both cases, but

their impact on nuclear safety is substantially greater during unit outages (events classified as nuclear safety significant and violations of the technical specifications for operation).More generally, I am still concerned about the degradation of some of the lines of defence essential for the proper execution of our operating activities, despite the actions taken. In 2011, I already drew attention to this issue affecting our core activities, at a time of staff generation turnover. As regards maintenance work, pre-job risk analysis, technical checking and requalification of equipment after maintenance have not been up to standard. As regards operations-related activities, I still observe weakness in the configuration and alignment of systems, as well as in conducting surveillance tests to test the operability of our nuclear safety equipment. Control room surveillance remains, to a lesser degree, a subject of concern, especially during unit outages.

It is noteworthy that the results for surveillance tests and violations of the technical specifications for operations, our highway code, which had been improving for a number of years, slipped back perceptibly in 2012. I would like to emphasise that, for the latter in particular, excursions outside the authorised operating envelope are in themselves serious, and undermine the credibility of the operating organisation in the eyes of the nuclear safety authority. In particular, there has been a significant increase in cases of failure to comply with the actions laid down in waivers that needs to be resolved.Again this year, I note that equipment modifications have been the cause of an excessively large number of nuclear safety significant events, and that the trend is a worrying one. During my visits to the plants, I have found the motivation of the joint Nuclear Engineering Division and Nuclear Operations Division teams to be good. However, all too many matters are still being sent to the plants at a late stage, preventing proper planning, particularly during unit outages. The quality of the case files for certain modifications is not up to standard and can result in severe constraints on operations, if not discrepancies, mainly during unit outages. I believe this issue needs to be analysed in depth by the Nuclear Engineering Division and the Nuclear Operations Division so as to reverse the trend.

In the plants in the UK

In EDF Energy, the number of nuclear safety significant events declared in 2012 dropped slightly (to 4.6 per reactor from 4.7 per reactor), with different declaration rules in France and the United Kingdom reflecting the requirements of their respective nuclear safety authorities.A better yardstick is the number of events ranked level 1

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on the International Nuclear Event Scale in 2012. This also decreased to 0.8 per reactor and is now lower that for the French plants. The events corresponding to violations of the technical specifications for operation substantially increased (1.67 per reactor), partly due to the way in which such events are defined to facilitate comparison with the results of the French plants. I note that, faced with this deterioration, EDF Energy NG has mobilised an inspection team to determine the exact causes. The first indications point to the increasing difficulty with procedure adherence (compliance with process rules) confirming the necessity - also in the UK - to simplify procedures wherever possible so the profession of nuclear operator is made easier.Plant alignment errors were also the subject of the same initiative and I will make a point of having progress reported to me during my visits to these plants in 2013.At EDF Energy, automatic scrams need to be considered with manual reactor trips as the British procedures more frequently require the operators to manually trip the reactor before the automatic functions operate. The 2012 results show progress (1.48), but are still too far from the best international levels.As concerns fire, the increase in the number of outbreaks, even though minor, confirms that fire hazards need to be the subject of increasing vigilance and determined action. During my visits to the plants, I found that the condition of the fire protection systems could be improved and noted that there was a management alert (an internal oversight Level 2 Advice) on one of them. I already pointed out in 2011 that the WANO peer reviews had been finding the level of fire prevention to be insufficient for a number of years. The corporate peer review carried out by WANO at EDF Energy in October 2012 reiterated this point. I am happy to see that the comparison was launched in 2012 with the French plants and is focusing on the state of fire protection systems to properly address the needs. I would like to emphasise the good levels of availability of the engineered safety features in the Advanced Gas-cooled Reactor plants with unplanned capacity loss factors of 0.3%, 0.1% and 0.3% respectively (WANO indicators) and the exceptional results for the Sizewell B pressurised water reactor for which the unplanned capacity loss factor for these safety systems has been zero for a number of years. This year, I also observe a reduction in the forced loss rate (units in service) that has been reduced to 8.9% (compared with more than 19% in 2010).Finally, I would like to draw attention to the improved operating results for the fuel route machines of the advanced gas-cooled reactors, which have a close correlation with nuclear safety. The significant progress, confirmed in 2012, has resulted from the effective use of a composite performance indicator and the considerable work performed by the staff.

In the Constellation Energy Nuclear Group plants

The number of significant nuclear safety events declared by Constellation Nuclear Energy Group (CENG) remained stable at close to 11 per reactor in 2012, the declaration rules being different in the USA where INPO handles filing and analysis.None of the events graded on the INES exceeded Level 1 in 2012, the factor slightly increasing to 0.8 per reactor.At CENG, as at EDF Energy, it is necessary to consider scrams combined with manual reactor trips as the American procedures more frequently require the operators to manually trip the reactor before automatic functions operate. The results for 2012 represented a slight deterioration (0.87 per reactor), far from the achievements of the period between 2006 and 2009. The results differed considerably between the Calvert Cliffs, Ginna and Nine Mile Island plants.I would like to draw attention to the capacity loss factors for the engineered safety functions consisting of the safety injection system (0.2 to 0.45% depending on the plant), the auxiliary feedwater system (0.1 to 0.9%) and the standby diesel generators (0.7 to 1.5%). Although these results are broadly comparable to those of the other reactors in the USA, they are well below European levels (by a factor of 5 to 10). I am left wondering about the appropriateness of operating modes for equipment so important for safety such as the standby diesel generators, and I commend the action recently begun by INPO to make progress in this area.I note the good forced loss rate (units in service) for 2012 for the three pressurised water reactors at around 1.5%. However, with an average factor of 3.1%, the CENG reactor results are in the lower half when compared with those of other American operators and vigilance is required.Although the combined unplanned capacity loss factor covering units in service and outage extension is very low compared with the figure for the French installations with different operating conditions, they have been worsening slightly over the last five years. I would like to once again emphasise the positive effect on nuclear safety, for the entire group, of such a capacity level with as few unit outage extensions and hence disturbances for the operators.I would also like to point out the existence of chemistry and fuel indicators which are given the same importance by the plant managers as the above.Finally, I am pleased to see the role played by INPO which is challenging plants on their performance levels and setting in place an effective benchmarking system. I must highlight the significant number of indicators for the CENG nuclear units which are in the INPO last quartile.

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION NUCLEAR OPERATING SAFETY: CONTRASTING RESULTS

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Fuel performance

I would like to emphasise the importance of nuclear fuel reliability, as it is the fuel cladding that constitutes the first technical barrier of the defence in depth. In France, the special “foreign material exclusion” policy designed to protect the fuel cladding integrity has made progress, but lags far behind what I have observed in the USA. I emphasise the importance of due regard for this policy in maintenance work.Although I am pleased to see the stability of the fuel management policy in recent years, which is what the operators needed, I wonder about the impact of the fuel cycle adopted for most French 900 MWe reactors on the operating aspects. Adopted for technical and commercial reasons which are mostly related to fuel recycling, this choice results in one outage a year for these reactors, representing a major challenge for the plants with four and six nuclear units. This is at odds with the practices of most other operators in the world, who have adopted cycles of 18 to 24 months, such as Calvert Cliffs Nuclear Power Plant operated by CENG where there is only one outage every two years. Have we properly assessed all the consequences, not least in terms of nuclear safety, of our policy which determines our capacity to carry out increasingly busy outages at such a frequency?I commend the existence of the “fuel community” headed by the Nuclear Fuel Division, linking up many bodies with the EDF Group. This provides the impetus needed to inspire this profession so vital to nuclear safety and maintaining a high level of expertise, offering rich and varied careers while fostering professionalism in our experts. I would like to highlight the need for commitment by all those involved to ensure full success of this enterprise.

Receiving a new fuel assembly

NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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03/ NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

An operating team briefing

Nuclear operating safety depends on three aspects: equipment, organisation and skill. Inside the EDF Group, the state of the equipment essential for nuclear safety is carefully monitored. In France, the organisation of operations-related activities, particularly those performed during unit outages, still lags behind the best international practices. In a context of massive renewal of skills, this situation is highly detrimental to the quality of operations and, as a result, compromises nuclear safety.

DEPLOYING THE GROUP’S NUCLEAR SAFETY POLICY

I commend the fact that the first overall EDF Group nuclear safety policy statement was approved by the EDF President in February 2012 and circulated in the nuclear plants. I particularly hail the initiatives taken at a very early stage by EDF Energy to deploy the policy. In France, the Nuclear Operations Division has also been taking action (integration into training schemes, the Nuclear Safety Memento, the new Licensed Nuclear Facility Order and the Nuclear Safety and Management Guide). This is an opportunity to be grasped by all managers in the nuclear industry to give meaning to the actions to be

taken and for nuclear safety to be paramount in everyday action. During my visits to the plants in 2013, I will verify the continued application of the campaigns in progress and announced in 2012.

THE MANAGERS: FOCUS ON PRIORITIES AND LEADERSHIP

Overall, the outlook of the plant managerial staff is correctly centred on the essentials; the priority of nuclear safety is unambiguously stated by the plant managements. This year, I once again met many operating shift managers in France and the UK. Inside EDF SA, the situation is relatively unchanged since last

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

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year as regards their freedom to step back and put things in perspective, their clearly recognised authority in operations and the reinforcement of their managerial authority. I would like to once again emphasise the need for the plants to address this issue, which is of the highest importance, affecting the last line of defence, which all too often has to play its role in operations. I nevertheless observe progress in the organisation and content of the daily safety analysis confrontations between the operations shift managers and the safety engineers, and I am also pleased to see that these are now covered in a corporate rule set.The situation of the front-line managers is not improving either. They are, however, now better trained, due to the presence of the highly-appreciated management academies, and their commitment is unflagging. Yet they are still facing the same everyday difficulties which involves fully devoting their time to their staff, who are all too often physically distant and distracted from their core profession by numerous tasks of little actual added value. I have been calling attention to this situation for a number of years.It has now become indispensable to make many of the work processes more meaningful, as some have become routine administrative matters, and to use simple good sense in operational implementation. Success in this area will depend mainly on getting the managers behind it. But there is a need to free them from tasks that all too often keep them away from their core work, their staff and their working conditions.The recent words of Robert F. Willard, the new CEO of INPO, reflects this when he emphasises that “there is an urgent need to tackle the question of the operator’s job becoming increasingly bureaucratic and over-complicated and the quality of leadership, the determining factor in the standard of operations”. His definition of leadership needs to be borne in mind: “what constitutes a rampart against the type of management that distracts from operations”. I encourage the plant managements to take action to reinforce leadership at all levels, using what has been begun at EDF Energy as inspiration.

THE CORE PROFESSIONS IN FRANCE ARE IN DIFFICULTY

Last year, I warned about preserving skills in France with operations and maintenance confronted with a massive turnover in professional staff: insufficient management presence in the workplace and, in the case of maintenance, the still inconsistent monitoring of jobs entrusted to contractor staff. The findings in 2012 once again confirmed the need to consolidate our technical know-how.

The observations in my 2011 report on the operating profession remain true. Turning the considerable investment in human resources initiated by the EDF Group into a success remains vital for nuclear operating safety. It depends on making the recently-initiated major changes to the professional skills by substantially improving the training provision and by increasing the availability of operating staff to other areas. I reiterate my call to the managers on all levels to give more thought to operating when making decisions.Just like the operating profession, the maintenance professions (including control and instrumentation) affected by the massive turnover of skilled staff are also being destabilised by change and innovation, such as new methods of equipment maintenance (such as the INPO equipment reliability process, AP- 913, for the continuous improvement of the reliability of equipment and systems), review of all the operating modes in the interests of standardisation for the new nuclear technical information system SDIN, a new directive on multi-year maintenance, the AMLIE spare parts management campaign, and the new organisational structure for units either in service or outages (including the continuous monitoring of installations during unit outages). Maintenance services are faced with the need to upgrade the requirements in terms of monitoring tasks entrusted to contractors and to devise new activities, such as those to be performed by surveillance staff.The weaknesses discovered in recent years are indeed still present this year as regards many basic aspects of maintenance (risk analysis, erection, spare parts management, technical checking and requalification) and of operating (reactivity control, surveillance of work in the field and in the control room). I devote Chapter 7 to this topic, which needs to be considered in detail.I am carefully monitoring the situation as concerns maintenance in the EDF Energy plants which, before the French plants, set in place a reliability improvement system based on INPO’s AP-913. During my visits to the EDF Energy plants, I was surprised by the slowness of progress concerning the reliability of equipment affected by the system. At the current stage, it is hard for me to say whether this weakness results from incomplete deployment or insufficient data from the process for guiding maintenance decisions.

BETTER MANAGING THE DESIGN BASE

I once again emphasise that, in France, we need to make up for the considerable delay in eliminating as-built discrepancies relative to the design base. With the support of the Nuclear Engineering Division, the Operations Engineering Unit has devised a proactive action plant


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which was shown to me, and I was pleased to see the substantial progress made. I encourage them to persevere with their efforts.As regards the stability of the operations rule set in France, I regret that there has been no substantial progress. I observe that EDF is, according to the ASN, the operating organisation that makes the greatest number of changes to its operations rule set and technical specifications. I note that EDF considers these changes are essential as they reflect the ASN’s requirements. Although allowance for experience feedback for our plants is an obligation and fosters progress, I hope that a reasonable balance can be found.

THE INDEPENDENT INTERNAL NUCLEAR SAFETY ORGANISATION (FIS)

Skills to be preserved in the plants

In France, the staffing numbers of safety engineers satisfies the requirements, barring a few exceptional cases. These engineers nevertheless permanently work on a just-in-time basis and their actions are vulnerable to unplanned events, as is the case for the operating shift managers. The initiative taken by the director of a two-unit plant (the most exposed to this type of situation) to increase the number of safety engineers is instructive. Furthermore, more than 80% of the safety engineers are from the young engineers’ recruitment route and those that were previously in operating teams (operating shift managers and their assistants or simulator instructors) are now becoming increasingly rare in the plants. I consider that the alert needs to be given about this trend.I would also like to draw attention to the situation in the auditor centres in the nuclear safety and quality departments, where numbers and skills vary greatly. They are not always able to correctly check maintenance work and do not yet play a role of guiding the maintenance services in a way similar to that of the safety engineer with regards to process-related services.

Nothing is acquired once and for all

The willingness of the Independent Nuclear Safety Organisation to listen has been satisfactory in most of the plants visited, despite the fact that their relationship with the management was not always close enough. The safety engineers - who have a difficult and challenging job - need to maintain a close relationship to establish their authority. I encourage the Station

Directors to develop close, special relationships with their safety engineers.At plant level, the Nuclear Safety Authority may be tempted to position itself as the “party to call” when there is unwillingness to listen to the nuclear safety advice given by the Independent Nuclear Safety at the plant. It is, however, absolutely necessary to go through the referral levels inside the company, at both plant and fleet levels.This year, the Directors of Operations (DDO roughly equivalent to a Chief Nuclear Officer in the UK or the USA) have met FIS staff from every plant, which is an excellent practice. The independent voice must feel that it is being listened to by the fleet-level management.I also observe that for most of the significant events that occurred in 2012 and which led to setting up a plant or corporate emergency management organisation, the role of the safety engineer was insufficient. Their mission in such a situation is laid down in the incident response procedures which, it seems to me, guarantees their role. Furthermore, they provide the emergency response staff (particularly for the No. 1 Management Command Post personnel and the shift operating manager) with valuable assistance in diagnosis and putting the event in perspective, which is indispensable for proper functioning of the organisational defence in depth. The latter point merits special attention.

The Independent Nuclear Safety function at fleet level

I would like to draw attention to the lack of clarity surrounding the Independent Nuclear Safety function at fleet level, essentially due to the large number of players responsible for nuclear safety (the Director Delegate for Nuclear Safety, senior advisors, the Nuclear Safety Performance Group members and the Nuclear Inspectorate). I observe with satisfaction this situation is being reviewed and recommend that the remit also extends to the difficulties in managing skills at corporate level in this context. Sorting out this issue, which merits close attention, should help the players in the plant Independent Nuclear Safety Organisation in their task. The results of the overall assessments of excellence are now the subject of reporting to the Directors of Operations (DDOs), a change that duly clarifies their roles. The associate director for nuclear safety at fleet level takes action with more distance, in the true spirit of an independent nuclear safety function, alongside the DDOs who are well aware of the actual situation in the plants and in charge of integration and monitoring of performance.


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THE OIU: AN INDEPENDENT INTERNAL CHECKING ORGANISATION

This year I met the staff of the User Internal Organisation. This body, which is part of the Nuclear Engineering Division, operates in accordance with the legal provisions relating to pressure equipment. The regulations require that all such equipment be subject to “essential requirements” from the manufacturing stage and imposes conformity assessments. In France, supplementary requirements were introduced under the nuclear pressure equipment order in 2005. The ASN keeps a close watch over such organisations to ensure strict compliance of the requirement for impartiality in its technical assessments and rulings, and the Inspector General for Nuclear Safety constitutes the highest internal echelon for referral within EDF SA. This year I verified the strength and depth of the EDF User Internal Organisation and the manner in which it organised the roles of its inspectors.

A DEVELOPMENT IN THE INDEPENDENT ORGANISATIONS AT THE EDF ENERGY PLANTS

At EDF Energy, one of the three safety engineers in the Nuclear Independent Oversight plant inspection service has progressively become dedicated to checking the safety of the nuclear units by technical confrontation with the operating shift manager on a daily basis. Acceptance of this daily confrontation by the operating shift manager warrants firm backing. I note, however, that these developments remain somewhat different from the practices in the Nuclear Operations Division in France. These UK engineers do not have the same roles in the emergency plan as their French counterparts.

Heysham 1 power plant

The local Nuclear Independent Oversight chief also reports to the Plant Manager once a week, to the Station Director once a week, as well as to the Technical and Safety Director at corporate level. The Nuclear Independent Oversight teams in the plants report organisationally to

the corporate Safety and Regulation Department (the internal regulator). I note that the quality of their relations with the plant management is not equal in all the plants.I still wonder why these internal inspection services are not directly attached to the Station Directors. Although the concept of resident inspectors may offer substantial advantages, I also think that the director of a plant needs to be able to count on a dedicated checking service that can independently report on the state of nuclear safety in the plants.Finally, I have noticed in this context the existence of a progressive alerting system, or escalation process, in which alerts are passed upward from the Nuclear Independent Oversight team, through the different management levels at plant then at corporate level if the response at plant level is tardy.

IN FRANCE, RELATIONS WITH THE ASN NEED TO BE STRENGTHENED

A full-time activity for the nuclear plants

The engineers in charge of relations with the ASN, a key group with vital skills, have been found to vary greatly from plant to plant in terms of numbers and abilities: this is in my opinion an issue that calls for vigilance.Having proper daily relations with the ASN and its specialist advisor (IRSN) means that the plants must possess the solid skills needed to guarantee a top-level fully-transparent technical dialogue. I have seen in some plants that this type of team has been set up, being close to the management and recognised by the ASN. The situation is still too variable between sites and I encourage the plants to acquire the resources needed in terms of engineers liaising with the ASN so they are sufficient in numbers and quality.I have also noticed in some plants that the practices are very good, with regular meaningful contact between the Plant Directors and the ASN regional branch directors, making it possible to better prioritise the issues and avoid misunderstandings.

Developing internal licensing at corporate level

I would like to emphasise the need for developing this system in accordance with Article 27 of the Nuclear Safety and Transparency Act, which may be demanding for the operating organisation but is empowering and can make relations with the ASN far simpler and effective. Although progress is still modest, I am pleased to see that the


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campaign on temporary modifications to the technical specifications for operations is to bear fruit early in 2014.

FACILITIES UNDER DECOMMISIONING IN FRANCE

There are two different situations: facilities on sites where there are nuclear plants in service (the most frequent case) and the others. I would like to draw attention to the manner in which the nuclear operating organisation exercises its responsibility where the stakes are high as concerns industrial safety, radiological safety and environmental protection, necessitating clear division of responsibilities. I recognise the role played by the Decommissioning, Waste Management & Environmental Engineering Centre (French acronym CIDEN) and motivation of the staff supervising the work, which may be highly specialised. During my visits, I have also noticed the excellent cooperation between such workers and the nuclear power plant staff.

Decommission work on the Superphénix FBR installations

THE NUCLEAR OPERATIONS DIVISION’S NUCLEAR INSPECTORATE AND DEVELOPMENTS IN THE INTERNAL CONTROL PROCESS

In 2012, the Nuclear Inspectorate (French acronym IN) began the new Overall Assessments of Excellence and its inspection programme is now scheduled to alternate

with WANO peer reviews, every four years. During the follow-up visits two years after the main visits, the plants are now the subject of an in-depth inspection every two years and, each time, the Nuclear Inspectorate and WANO visits coincide. This considerable tightening of checking conducted in the nuclear plants results in a substantially increased workload for them and for the Nuclear Inspectorate. The plants will benefit fully from this, insofar as they take the new arrangements on board, both in the plants and the fleet-level departments.I have been able to verify that the resources allocated to the Nuclear Inspectorate enable it to perform its mission and properly cover all fields needing attention, which are now extended to operations (multi-year maintenance, units in service and during unit outages) as well as industrial safety. I stated in my previous report that this extended scope needed to be the subject of special vigilance. Considering the results of a first year of functioning, I see no undesirable trends.I note that the take-up factor of recommendations resulting from an overall assessment of excellence has slipped back to 55% this year. This calls for vigilance and I will be monitoring the situation during my forthcoming visits.I am also pleased to see that the Nuclear Inspectorate has established closer relations with its counterpart at EDF Energy in Barnwood, the Safety and Regulation Department.The Nuclear Inspectorate also greatly contributes to the international dissemination of EDF’s control and verification practices; it also effectively provides training support for Chinese and Russian operating organisations with which EDF is increasingly cooperating in the field of nuclear safety inspection. It also provides an indispensable link with INPO.

A WANO CORPORATE PEER REVIEW MUCH APPRECIATED AT EDF ENERGY

I hail the initiative taken by EDF Energy to host another international peer review of its nuclear operations activities at corporate level. This assessment by WANO in October 2012 was taken very seriously by the managers and was the subject of massive preparations. Although I agree with the final assessment, firstly I notice the strong points identified, such as the high level of expertise and support provided by the corporate engineering services to the advanced gas-cooled reactor plants in response to the Fukushima accident, the training accreditation system, the leadership training programme, the good organisational alignment and the dynamic publicity campaign about making nuclear safety a top priority.


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From the results of the review, I also see the following scope for progress:• the reliability of the equipment and systems is not yet

sufficient,• the performance goals are not sufficiently ambitious,

nor do they correspond to the best international standards,

• not enough credit is given to the use of independent networks, at either plant or corporate level,

• the impact of the corporate campaigns on the plant resources are not being adequately assessed.

I made good note of the fact that the EDF SA plants will also be the subject of a corporate peer review, which is to be carried out by the IAEA in the autumn of 2014, the first such review since a WANO corporate peer review carried out ten years earlier.

THE ASSESSMENT AND SUPPORT UNIT OF THE NUCLEAR ENGINEERING DIVISION: A POWERFUL TOOL

The Assessment and Support Unit (French acronym MAE) has been provided with the skilled personnel needed to properly perform is checking mission. I am also pleased to see the work being carried out in cooperation with the Nuclear Inspectorate, ranging from the participation of Assessment and Support Unit inspectors and civil engineering experts in the engineering centres to assessments of joint Nuclear Engineering Division and Nuclear Operations Division teams during overall excellence assessments. I also consider that the arrangements for the engineering centre overall assessments every three years are solid and well organised by the Nuclear Engineering Division managers.

A SECOND WIND NEEDED WITH THE OPERATING RIGOUR PLANS

Although I welcome the existence of the fleet-level support arrangements for the plants facing problems, I sometimes wonder about their effectiveness. During my visits to the plants, I have noticed that they are only rarely mentioned as powerful means of improving the situation, which is often ascribed to the fact that they have been in place for too long. No second wind was found. I would also like to draw attention to the fears expressed in the plants that have recently achieved better results that the fleet level may consider them to have been “cured too quickly”.

THE NEED FOR ANALYSIS OF NUCLEAR SAFETY VERSUS PRODUCTION

The technical events in 2012 and the usual tension between nuclear safety and generation goals make it all the more necessary to lend vigour and meaning to such arrangements, at fleet and plant levels. I note that, for instance, time is no longer taken for debriefing and analysing the technical decision-making after contingencies. The here-and-now often takes all the attention, and time out is not being taken often enough to think things over and draw conclusions on the situations encountered. Communicating about and explaining decisions relating to nuclear safety calls for special care and taking the time to make sure that all involved have the basic minimum of information needed to understand. Indeed, when it comes to nuclear safety, things cannot be taken for granted and I have met staff who feel left out.In 2011, at Ginna Nuclear Power Plant in the USA, I was shown a presentation on this type of post-event analysis which had highlighted inappropriate trends in the operational decision-making process. It subsequently led to the re-design of the technical contingency management process. I encourage the development of similar practices in the French plants.I have also taken note of the EDF Energy campaign launched in 2006-2007 after the discovery of cracking in the boilers of Hinkley Point B and Hunterston Power Plants. After thorough technical review, it was decided to reduce the power of the reactors by around 25% nominal. After a number of years of operation at this level, the positive effects for nuclear safety have been confirmed by checking, as the cracking has ceased. Furthermore, this mode of operation is positive for the lifespan of the graphite and hence of the four nuclear units. I commend this type of decision as a good example of proper balance between nuclear safety and power generating.

THE HUMAN FACTOR, FROM DESIGN TO OPERATIONS

In France, I still see too little change in practices to increase reliability and reduce human errors. This does not appear to be a priority for the managers; the matter is rarely mentioned and, finally, the application to activities identified as important is neither widespread nor properly done.This situation differs sharply from what can be observed in EDF Energy and the Constellation Energy Nuclear Group, in both operations and maintenance. It is, however, a major line of defence for reducing the incidence of sub-standard operations and maintenance. The path successfully taken


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by most of the control and instrumentation departments and often by the fuel handling departments is there as a good example.I would also like to emphasise the role that can be played by human factor consultants in the plants. They are now well trained yet not utilised fully by the plant managements. I would encourage the site directors to rely more on their skills which can often helpfully complement the “engineers’ view” alone. During my visits in 2013, I will make a point of meeting them. I have also noticed the limits of the socio-organisational and human factors analyses recommended by the IAEA in INSAG 18. All too many projects, e.g. the Nuclear Technical Information System (French acronym SDIN) (see Chapter 8), or changes in the operating procedures, have been deployed in the plants without sufficient regard for the impact on the operator. By contrast, I have found excellent work - from the design stage - which unites operators, human factor consultants, ergonomists and designers: at the Nuclear Design & Construction Centre (French acronym CNEN) for the future control room for the EPR and at the Power

Plants Operations Engineering Centre (French acronym CIPN) for the modifications to the control rooms of the 1,300 MWe series plants to be integrated during the third ten-yearly outages (VD3). I encourage the general adoption of this type of approach.

HOUSEKEEPING

The state of the French plant continues to improve, with sixteen rated as in “good condition”. I would like to draw attention to the need to continue devoting the necessary resources so these plants can reach the campaign objective to achieve ratings of “exemplary” and to keep them at this level.At EDF Energy, I observed during my visits in 2012 that there was some backsliding in this area. EDF Energy is aware of this and has decided to implement a plan to rectify the situation. I am pleased to see the cooperation between the two sets of plants in this domain, with the introduction of assessments and marking in accordance with the exemplary conditions plan.

MY RECOMMENDATIONS

I consider that our managers are not yet sufficiently available to heed their staff and tackle the real problems: let us allow them to act, provide them with professional support and simplify their lives.

I also note persistent weaknesses in our operations and maintenance professions, where a massive turnover of skilled staff is now taking place and where too many simultaneous changes in work practices are happening. I recommend that, in France, there should be greater investment in studies to determine the impact of these numerous changes, with due consideration of human, social and organisational factors. Similarly, I would like to once again emphasise the need to deploy human performance tools, the impetus to do so appearing to be lost in the plants.

I also emphasise the need clearly felt for operating competence in many other departments, such as nuclear safety engineering, training, unit outages and engineering. Such resources are generally in place at EDF Energy and Constellation Energy Nuclear Group; they need to be reinforced in France.

I would also encourage the managers to systematically determine ambitious nuclear safety goals, the driving force for progress, as was highlighted in the recent WANO corporate peer review at EDF Energy.

Finally, in a context of increasing tension about operational results, I consider more than ever that we need independent nuclear safety organisations that are respected and heeded by the plants, as well as the corporate/fleet and Group levels.


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SAFETY IN THE WORKPLACE: FRANCE RISES TO THE CHALLENGE THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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04/ SAFETY IN THE WORKPLACE: FRANCE RISES TO THE CHALLENGE

Personal protective equipment worn in the turbine hall

Industrial safety is fundamental in performing nuclear operations. The unavoidable continuous increase in the number of requirements concerning nuclear operations must not be at the expense of the physical or mental health of our staff, or that of the contractor companies working in our facilities. Although the industrial safety results in France have improved somewhat in recent years, they are still not nearly up to the best results worldwide. International experience feedback, within the EDF Group itself, reveals that we need to be more ambitious in making industrial safety an integral part of overall plant operating performance.

IN FRANCE, THE RESULTS ARE MEDIOCRE AND VARY GREATLY BETWEEN PLANTS

The frequency of workplace accidents resulting in absence from work per million hours worked for EDF and contractor staff has improved over the last ten years. It stood at 3.5 at the end of 2012, which is slightly better than the figure of 3.9 for 2011. It is still well below the best worldwide standards in the sector, which currently stand at less than one. I also note great disparity between the plants, and that there is little correlation with unit outage activities. The difference in the frequency between the best and the worst plants has remained unchanged for a number of years, ranging from 1 to 6. I consider that a difference this great is unacceptable: it is a sign of shallow industrial safety and risk management

culture unworthy of the responsible nuclear operator we strive to be.

0

1

2

3

4

5

6

7

8

9

TF INF 1 TF 1 à 3 TF 3 à 5 TF 5 à 7 TF 7 à 9

2010

2011

2012

Scatter of the overall “lost time accident frequencies

per million worked hours” in the French nuclear power plants

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION SAFETY IN THE WORKPLACE: FRANCE RISES TO THE CHALLENGE

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THE RESULTS IN THE UK AND THE USA ARE FIVE TIMES BETTER THAN IN FRANCE

In the UK the frequency of accidents resulting in absence is 0.5, which is nine times lower than the median frequency in France. For the broader situation comprising accidents that did or did not result in absence per million hours worked for EDF Energy and its contractors, the frequency has been below 2 for a number of years. I note that it remains above 11 for the French plants as a whole, with comparable openness and traceability requirements. At Constellation Energy Nuclear Group in the USA, the frequency is 0.78 (INPO’s Total Industrial Safety Accident Rate figure), slightly worse than the figure for 2011 which was 0.75, after seven years when it was below 1.5.Management involvement at all organisational levels, combined with strong and determined motivation from each employee can durably improve the situation, as shown by the results of EDF Energy over the years. Constant promotion of the zero-accident ideals by management as part of the “incident and injury free” approach, is contributing to maintaining motivation among all involved.

KEEPING SIGHT OF THE ESSENTIAL, HEEDING WEAK SIGNALS

As in the case of nuclear safety, there needs to be general awareness that focusing on the indicator alone does not result in disregarding any weak signals, forerunner events and narrowly averted accidents.Although there may be progress in debriefing after fieldwork and narrowly averted accidents, as well as the

use of experience feedback and the dissemination of good practices, this is not the case in all the plants that I have visited. I consider that narrowly averted accidents, particularly in tagging and de-tagging (permit to work) situations are highly important forerunner events that need to be analysed by all involved to learn from them.I was accordingly struck be such an event that occurred at Saint Laurent Nuclear Power Plant during diving operations in an intake channel. In view of how important tagging is for both nuclear safety and industrial safety, I will be focusing on this issue in 2013, particularly during unit outages. I also note a narrowly averted accident in April 2012 during a temporary storage operation of a high-pressure turbine casing at Nine Mile Point Nuclear Power Plant. Three technicians were working under the casing when the temporary structure on which the 100 tonne high-pressure casing slipped. The immediate quest for experience feedback made it possible to raise awareness among the staff at the Constellation Energy Nuclear Group of the dangers of lifting operations and to question the temporary storage methods for heavy components.I am pleased to see that EDF Energy has a system of overall monthly reporting of narrowly-averted accidents and forerunner events. The good practice of learning from narrowly-averted accidents is now adopted by the French Nuclear Engineering Division and the Nuclear Operations Division where monthly reviews of them are systematically made at Division level. I would like to encourage these periodic assessments with the individuals involved, wherever work is carried out and decisions are made.

The Nine Mile Point 2 event

On18 April 2012 during the refuelling outage at Nine Mile Point Unit 2, the 107-ton high pressure turbine casing fell 39 inches to the turbine floor while being supported on stands. Three workers who were performing work under the shell at the time received minor injuries and were able to exit from under the casing on their own. The four metal stands used to support the casing had been specially designed and fabricated for this application to allow work to be performed in connection with the extended power project. The cause of this event was

that uneven loading between the four stands caused by an uneven floor, along with other factors, allowed the stands to “walk” as work was performed on the casing. The investigation revealed that CENG did not have standards and procedures to control the guidance on the use of cribbing or other methods to temporarily support heavy components. Corrective actions included establishing standards, procedures and training in this area.

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THE CONTRACTORS: PARTNERS IN PREVENTION

The results achieved by the contractors working in our facilities are the result of our clearly-stated requirements as much as their own commitment.During my visits, I have found that the willingness of the contractors to listen and rise to the industrial safety challenge facing everyone varies greatly from one plant to the next. Agreement on avenues of improvement would help to address the needs identified.Stricter surveillance of contractors with high accident rates or insufficient management of prevention and industrial safety issues would be an appropriate approach. I regret that it is not seen as more important and better exploited in the field.

THE DRIVING FORCE OF PREVENTION STAFF NEEDS SUPPORT

During my visits to plants in France, I have met keen, motivated prevention staff in close support at the work areas. I am not convinced that the prevention staff is given sufficient backing. The creation of the risk prevention services has all too often been at the expense of industrial safety, seen as the poor relation of risk management, compared with radiation protection which is a legitimate focus of attention.I am glad to see the work begun this year at a number of plants that I visited between those involved in prevention, logistics and coordination with a view to simplifying and facilitating field work. I would encourage the plants to support this approach, particularly in the lead-up to the General Refurbishment.In risk management training and the associated refresher courses, the role of conventional risk management is still too limited. I note with interest the updating in progress of the initial and refresher training content, with special provision for training in prevention management.

THE AUTHORISED INTERNAL INSPECTION DEPARTMENTS (SIR), PLAYERS IN THE FIELD OF SAFETY

In France, this year, all the authorisations for the SIRs at all the plants have been renewed. The staffing of these departments with highly skilled workers must continue to be the subject of special attention and can continue to contribute to the career trajectories of engineers focusing on prevention and industrial safety.

SIGNIFICANT IMPROVEMENT IN INDUSTRIAL SAFETY AT THE FLAMANVILLE 3 CONSTRUCTION SITE

The improved industrial safety results at the Flamanville 3 worksite, with an industrial safety action plan strongly backed by the management and closely associating the contractors and the operational staff in the field represents an encouraging situation in terms of the ability to maintain quality and industrial safety levels at the construction site. This illustrates the importance of management involvement in industrial safety. Extremely strict requirements in the worksite stage will foster, from the outset, the highest levels of nuclear safety and industrial safety for start-up and commercial service.

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Comparing the “lost time accident frequencies per million

worked hours” of most recent construction sites in France

SPECIAL ATTENTION FOR INSTALLATIONS UNDER DECOMMISSIONING

I would like to draw attention to the importance of risk management, industrial safety and radiation protection in view of the types of hazards and their persistence, with periods of intense activity, in decommissioning worksites. This is the case with the Chooz A PWR and the Superphenix SFR.Despite the initiatives to improve risk management, I note that the “lost time accident” frequency for the contactors has remained high (11.3 in 2012 and 8.3 in 2011). This deterioration calls for vigorous action in close liaison with the contractors involved.Training workshops, such as the one at Saint Laurent A site to prepare for the work in the reactor vessel (with a full-scale mock-up, replication of the working conditions, briefing and debriefing with each worker, and strong commitment by the contractor), constitute good practices, which needs to be emphasised.

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MY RECOMMENDATIONS

The excessive disparity in our industrial safety results is being caused by the extremely hesitant involvement of the operations management. The pressure needs to be kept up at all organisational levels, rejecting fatalism by promoting good practices and laying down high standards and strict requirements.

Our involvement must be expressed by resolutely projecting the idea that performance in industrial safety cannot be disassociated from the global performance when exercising our responsibility as a nuclear operator. It may be a duty, but it is also a big opportunity.

As part of tightening the requirements and increasing the number of jobs being performed in the nuclear facilities, I consider that a meeting of minds about industrial safety (bringing together the EDF and contractor staff, the employers, the prevention staff and those for whom

the work is performed) offers an opportunity to rally round common goals, adopting behaviour that fosters joint progress on a permanent basis.

I encourage setting up risk management services in the plants to provide managers with solid support.Concerning this point, I consider that upgrading the status of prevention in the professional career paths (at both technician and engineer levels), reinforcing training on workplace safety management, and fully using systematic peer reviews in the field of industrial safety are the managerial levers available to us.

This will not only lead to maintaining a very high level of vigilance with the attendant results in terms of industrial safety and risk management, but also to fostering confidence in operational performance.

RADIATION PROTECTION: NEED FOR AMBITIOUS GOALS THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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05/ RADIATION PROTECTION: NEED FOR AMBITIOUS GOALS

Checks at the entrance to the reactor building during a unit outage

In France, individual dose results are improving while collective dose results have been stagnating for several years. The increased number of significant radiation protection events and the lead-up to the General Refurbishment call for greater vigilance and initiatives to keep exposure as low as reasonably achievable (ALARA). In the UK, the operating organisations are focusing on contamination control. In Constellation Energy Nuclear Group, attention is being drawn to the source term in boiling water reactors and the management of individual doses.

THE INDICATORS

An overall decrease in individual doses

In France, the number of workers (EDF and contractor staff) for whom the dose over twelve months exceeded 10 mSv has continued to diminish: 263 in 2012, 424 in 2011. Meanwhile, only three workers received an individual dose above 14 mSv and none received greater than 16 mSv. I approve the decision to reduce the pre-alert threshold to 14 mSv, which has contributed to this progress. The reduction in individual doses should be able to continue. I would like to emphasise the grass-roots contacts now taking place with all of the 56 contractors with employees who have exceeded and annual dose of 10 mSv. I also note that the contractors performing jobs with the highest exposure (heat lagging, valve

maintenance, cleaning etc.) continue to be the subject of extremely close vigilance by the plants.At EDF Energy, the efforts to reduce individual doses are also bearing fruit: the maximum individual dose was 8.18 mSv in 2012.At Constellation Energy Nuclear Group, after a number of years in which the number of salaried workers with a dose of more than 16 mSv was low or zero, 2012 saw nine with doses between 16 and 20 mSv, essentially the result of a special job involving divers during a Nine Mile Point Nuclear Power Plant modification.

Collective doses stabilise

From 2000 to 2010, the French average collective dose per reactor in service dropped from 1.08 man-sieverts to 0.62 man-sieverts, combined with an increase of 50% in the number of hours worked in controlled areas, from

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4 million to 6 million. The collective exposure for all the French nuclear power plants has stabilised in recent years, with an increasing disparity between the 900 MWe series and the others. In 2012, with six ten-yearly outages, the collective dose in France was 0.67 man-sieverts per nuclear unit, in line with the dose objectives.In the UK, for AGRs and PWRs combined, collective exposure has been properly under control and the results were better than predicted. It stands at 0.06 man-sieverts on average for the AGRs and 0.04 man-sieverts for Sizewell B, the only British PWR. The operational challenges for the AGRs essentially relate to radiological cleanliness, with comparisons between plants used to determine the priorities for any action to be taken.At Constellation Energy Nuclear Group, the collective exposure in the PWR units has been halved over ten years, and remains stable at 0.68 man-sieverts. However, the collective exposure in the boiling water reactor went back above 2 man-sieverts per reactor in 2012 (2.27 man-sieverts). Figures have not been this high seen since 2005. The year 2012 was marked by chemical decontamination operations and the continued removal of materials liable to be activated, with a view to reducing the source term.

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Significant events more frequent in France

In France, the year was marked by a substantial increase in the number of radiation protection significant events (+24%) compared with 2011, mainly as a result of radiography work (twelve related to it). The events associated with work in red and orange radiation hazard zones remained very numerous (4 for red, 30 for orange). I would like to draw attention to the increased number of violations with respect to cordoning off and disregard for dose rate alarms by both EDF and contractor staff. This issue requires a firm, prompt managerial response.It also seems important to encourage willingness to listen and to be attentive to weak signals and forerunner events. Reporting events and near misses remains a key

factor in prevention, enabling stricter behaviour to be introduced and appropriate corrective action to be taken. I would also like to mention a rare case of a radioactive source being jammed which occurred at Blayais Nuclear Power Plant on 19 March 2012, with no consequences for the workers in terms of exposure. This event took an unexpectedly long time to rectify, but was correctly managed by the nuclear operator.

RADIATION PROTECTION STAFF KEPT BUSY IN THE PLANTS

In France, the UK and the USA, most of the staff I met were devoted to the cause of radiation protection and radiological cleanliness. Process maps are properly drawn up, staff involved are empowered and regular in-depth reviews are carried out by the nuclear inspectorate in France, by WANO peer reviews in France and the UK, by INPO reviews in the USA, and by the regulatory authorities in each country.Everywhere, the radiation protection and radiological cleanliness are clearly announced and managed as key performance goals in the organisation of unit outages. The utilisation and the dissemination of experience feedback, operation by operation, with the players involved and the contractor staff workers should make it possible to better determine practices sometimes differing widely between the plants and to put forward high-performance innovative practices for radiation protection and radiological cleanliness.As the work intensifies, including last-minute jobs which are more commonplace in France, I fear that job planning and associated feedback will not be up to scratch and that the plant ALARA committees will flag. I consider that the voice of radiation protection has to be clearly enunciated and heard at every stage of planning, execution and experience feedback management throughout the unit outage and in every activity where there is a radiation hazard.The dose forecasts for the Major Refurbishment in France necessitate special attention plant-by-plant and operation-by-operation, beginning now. As regards the replacement of the steam generators in the 1,300 MWe nuclear units, I consider that the experience feedback from the 900 MWe units and from nuclear operators outside France will make it possible to determine, from the outset, goals that are both realistic and ambitious. This approach will necessarily require the close involvement of the Nuclear Engineering Division the Nuclear Operations Division, the plants involved and the contractors in a properly-devised plan to ensure doses are ALARA. The average dose per hour of work in controlled zones has regularly diminished, dropping from 16 microsieverts

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per hour in 2000 to 7 microsieverts per hour in 2012. I am pleased to see that this indicator is being taken into account in the planning for the General Refurbishment, making it possible to better determine priority actions, and to reduce the individual and collective doses for each profession.In the plants visited, I also observed that radiation protection and radiological cleanliness were progressively becoming integrated into work management for plant operations and outages, alongside specific activities such as fuel handling and the treatment of solid waste and effluents. I nevertheless regret that radiation protection is still not formerly part of the continuous management organisation team (Outage Coordination Centre manning) during unit outages (French acronym COPAT).

THE EVEREST CAMPAIGN: EXTENSIVE EXPERIENCE FEEDBACK NEEDED

I have always underlined the relevance of the EVEREST Campaign which aims to enable entry into controlled areas in conventional work clothing. By controlling the sources of exposure and contamination, it sets out to free most nuclear zones of excessive radiation and contamination. It is now necessary to supplement the experience feedback from the first three plants where this campaign has been in place (data mainly derived from C2 monitors triggered at controlled area exits) and from periods of intense activity during unit outages for each site with the contractors working there. It is appropriate to clearly distinguish between improvements specific to each of the three plants versus those which cover contamination control practices applicable to all plants.

NINE MILE POINT: THE IMPORTANCE OF THE SOURCE TERM

In 2012, at Nine Mile Point Nuclear Power Plant which comprises two boiling water reactor nuclear units, I was shown the chemical decontamination operations which have reduced the source terms and exposure dose rate by a factor of ten. The source term reflects the materials chosen during the design phase and the quality of the chemistry and operations. It directly affects the exposure of the maintenance staff. It needs to be the subject of close attention throughout the service life of the installations, and not only in boiling water reactors.Targeted clean-up operations are also carried out in France. Integrating these operations into unit outage planning shows the operating organisation’s commitment to radiation protection. During my forthcoming visits, I will make a point of assessing the application of these arrangements in the plants.

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Dose rate mSv/h close to one of the main circuits at Nine Mile Point 2

Dose rates at Nine Mile Point 2

RISK MONITORING STATIONS: DEPLOYMENT NEEDED WITHOUT DELAY

Risk monitoring stations, equipped with cameras and radiation meters for radiological monitoring, are already deployed at Gravelines and Chooz Nuclear Power Stations, as well as in EDF Energy and Constellation Energy Nuclear Group. They combine the unit outage supervision team, field workers and radiation protection technicians, illustrating the value added by new technologies and new organisational arrangements. The time taken to deploy these new arrangements in France will need to be carefully watched.

EDF ENERGY: EFFECTIVE RADIOGRAPHY PRACTICES

In two years, EDF Energy has considerably reduced the impact of radiography by systematically using collimated sources in its AGRs. In 2012, these were used in 82% of the radiography work. I strongly commend this action which reduces the risk of exposure to ionising radiation, making use of improved radiography equipment and new non-destructive testing methods.

MAINTAINING A STRICT WATCH FOR ALPHA RADIATION IN DECOMMISSIONING WORKSITES

Certain special decommissioning jobs involve major alpha particle contamination hazards, such as at the Chooz A and Saint-Laurent A sites.I have seen that the staff are watching the situation closely and I can only encourage them to maintain their vigilance in the long term.

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MY RECOMMENDATIONS

The continuing quest to build on the good results in radiation protection and radiological cleanliness achieved in the last decade calls for a second wind, a development that I strongly encourage. This is needed if we are to cope with the increasing number of activities associated with plant life extension and the forthcoming General Refurbishment. This will require ambitious, targeted goals.

I feel that the level of radiological performance we are entitled to expect from a nuclear operator must be grounded on proper arrangements to ensure doses are ALARA. I consider that vigilance is needed to ensure that the radiation protection services are assigned sufficient staff with appropriate qualifications. Higher status needs to be given to the

radiation protection specialists, particularly during the key phases of job planning and experience feedback. Prevention in the fields of radiation protection and industrial safety needs to be regularly promoted as being fundamental to high performance in nuclear power generation.

Given the excessive infringement of the basic rules of radiation protection recorded this year once again, I encourage once again the managers to reiterate the requirements to their staff and in the field.

The influence of the source term on exposure leads me to recommend maintaining a careful watch over chemistry and the cleanliness of the systems during operation as they govern the long-term situation.

TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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06/ TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT

Learning about diesel engines at the Bugey Nuclear Power Plant training centre

The quality of training nuclear plant operating staff is of paramount importance for nuclear safety. The current massive turnover of skilled staff at EDF SA constitutes an opportunity to strengthen the managers’ commitment to training and renew the methods by which skills are handed down to future generations. The development of synergy with EDF Energy - competent in this field - can facilitate this process.

A TURNING POINT IN FRANCE

I am glad to see the good start of the Nuclear Operations Division’s skills programme and of the skills project at the Nuclear Engineering Division. With excellent synergy within the EDF Group (France and UK), the efforts are being concentrated on two key factors: managers’ commitment and effective training.The deployment of this programme is consistent with the initial timetable, with four pilot nuclear plants until 2012, and the addition of a second set of six by mid-2013.At fleet level, I have seen that those in charge of the nuclear power plants and their specialist advisers are putting their weight behind this innovative project by setting reasonable but ambitious goals: promoting the use of the international rule set constituted by INPOs Systematic Approach to Training (SAT) and making possible training management accreditation by 2015. The company has devoted considerable resources to this objective, matching the scale of the announced ambition with considerable scope for innovation.To reach its goals, this programme will need to be given unflagging support. I observe with satisfaction the large

number of key players and decision-makers at corporate levels that are involved (deputy director, directors of operations, training director, human-resources director and profession supervisors), which of course calls for proper overall coordination.

At corporate level, active promotion of training and the professions

Corporate promotion of the professions has been greatly intensified since 2010. This innovative approach at corporate level is undeniably highly favourable for the cross-fertilisation of the different professions with a set of plants of this size. After exchanges for a number of years with INPO and numerous nuclear plants in the USA, 2012 saw the emergence of a rule set for managing skills, according to which each plant will make a self-assessment this year. In 2013, a first assessment of the plants will be carried out by a joint team combining the Operations & Engineering Training Unit (French acronym UFPI), the Nuclear Inspectorate (French acronym IN) and EDF Energy and, from 2014, the Nuclear Inspectorate

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with integrate the results of these assessments in the Overall Assessments of Excellence.I also note signs of change for the better. For instance, the human resources committee of the Nuclear Operations Division is now devoting a substantial amount of time to training (30%); the Directors for Operations have intensified their involvement in promoting the professions and enshrining these requirements in the NPP annual performance contracts. I also note the excellent relations established between the corporate profession supervisors and their UFPI correspondents at Lyon and Bugey. To be effective and pertinent, the supervisors need to devote a substantial amount of time to the plants and to the UFPI. I wholeheartedly support the recent overall review of the maintenance professions common core knowledge, which clearly illustrates what such a team can provide.I am also pleased to see new impetus in linking between the heads of departments and the training advisers (operating, control systems and maintenance) under the leadership of the Nuclear Operations Division’s Skills Advisory Centre (PCC) with the active participation of the UFPI. The Skill Programme now systematically plays a role in providing these managers with insights and information.I wonder about associating the definition and promotion of the nuclear safety professions with a body other than the PCC, namely the Nuclear Safety Performance Group in the Nuclear Operations Department (French acronym UNIE/GPSN). The promotion of other professions is missing an opportunity to better incorporate the basic tenets of nuclear safety.The revival of corporate-level training of maintenance engineers is to be commended: it is designed to increase the potential of the nuclear power plants with regards to “technical” engineers, for whom the greatest need is in maintenance. Training schemes for unit outage engineers and project managers are now in place and common core knowledge academies for incomers are also providing special training for the main professions, thus confirming their pertinence as well as being highly esteemed by all the staff I have met in the plants.I also note with satisfaction the confirmed success, from the front-line managers to the Station Directors, of the management academies, which now include dedicated training advisers. I would nonetheless like to draw attention once again to the basic training of the operating shift managers, which has been updated but is still leaving the main parties involved somewhat unsatisfied, particularly concerning nuclear safety as directly applied in the exercise of their profession.

Motivated managers in the plants

During my visits I have seen the increasing commitment of the plant managers in training. More widely, the managers appear to have properly understood their vital role in the success of this programme and support it. Those in charge of human resources in the nuclear power plants are also being brought in to play a part in this programme by the corporate promotion team. I am, however, still wondering whether they are sufficiently free to attend to training which now has high priority. I have indeed noticed the influence and effectiveness of the training directors present in all the EDF Energy and Constellation Energy Nuclear Group plants, many coming from more technical backgrounds.The training committees (site, departments, teams) are being set in place in the first pilot plants, headed by managers provided with dedicated support (the new profession mentors). I am pleased that the connection between operations information (discrepancies, good practices and performance) and the content of the training are thus strengthened. These committees and, more generally all the in-plant training promotion, require the presence of these advisers who need to be sufficient in numbers and of different professional profiles. They are in place in four pilot plants, all visited within the last eighteen months. For the rest of the programme, I note that it will be necessary to recruit 150 to 200 staff for these functions, with strict requirements concerning the past professional career (experience in core profession).I am also pleased to see the increased trainer staffing (UFPI and part-time instructors in the nuclear power plants). I was struck by the level reached in training resources in the foremost plants, where they represent some 10% of the personnel. Concerning this issue, I encourage the development of short-term training secondments, which has been successfully used in the UK and shows considerable potential.The simulator training of operating staff has major implications for nuclear safety. In France, simulator training reached twelve days on average per operator in 2012. Despite the efforts made, I once again find that the goal of 15 days per year per operator is still far from being reached. Despite a very high usage factor for the simulators (more than half the plants now have evening sessions), the manner in which the operating departments are organised is still not very compatible with the training demands. This situation is not satisfactory and far from the best international standards. Furthermore, training for accident situations with complete teams handling situations on a simulator specially designed to test communication within a group under tension, appears


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to take place too rarely, at a frequency of only one week every two years.I have duly noted the commissioning of five additional simulators, beginning in 2014, to cope with the heavy increase in training requirements, mainly stemming from the current levels of new recruits. It is now a question of abiding by the timetable.The corporate training programme leaves too little space for plant-level initiative and I still regret the insufficient time devoted to normal operations and the problems specific to each plant. This situation does not tend to empower the operating shift managers and the heads of the operating departments. The construction by 2016 of local training centres (the first at Golfech Nuclear Power Plant in 2012) containing new training and simulation mock-ups is also a promising development. I insist on the need to bring these core profession investments to term; they are not just tertiary arrangements as I sometimes hear stated. They are just bringing us up to international nuclear industry standards.I commend the increasing opening-up of our training facilities to contractor staff (practical training schools and Bugey Nuclear Power Plant maintenance training centre) and the continued training of their management staff (team leaders). Concerning this, I would like to once again emphasise the possibilities opened up by e-learning for our contractors, as is being practiced in the USA with INPO’s NANTel system. I am surprised to see so little initiative being taken in this domain.

Instructors on a simulator

The Operations & Engineering Training Unit, technical support for the plants

I observe with satisfaction that the Operations & Engineering Training Unit (French acronym UFPI) it now proving its worth with the services it is providing to its two main clients: the Nuclear Operations Division and the Nuclear Engineering Division. Plant-level relations between the training departments and UFPI and the nuclear power plants are good. Accordingly, all the heads of the training departments are now full members of the

extended plant management teams. At corporate level, I am pleased to see that relations of confidence and cooperation have been established. The creation of a Nuclear Safety Advisory Section (MSQ) within the UFPI, closely connected to the nuclear power plant MSQs, needs to be emphasised. The avenues of progress that have been identified closely correspond to the expectations regularly expressed to me in the plants: faster response to new training requirements and greater willingness to listen to the trainees.Although the training centres are now properly staffed in terms of numbers, the profiles of the simulator instructors remain worrisome as a result of the increasing imbalance between instructors originating from the operating professions and newly-qualified engineers. In 2012, eight training departments out of twenty had more than 50% of their trainers who were of the latter type. They will be eleven in 2013 despite considerable reinforcements of the Nuclear Operations Division staff transferred to the training centres (65 in 2012 and 44 in 2010).The significant increase in training relating to post-Fukushima action (more than 300 people in the Nuclear Rapid Reaction Force teams plus reinforcement of the operating teams in the plants) will put pressure on instructors and simulator time. The decision to commission five additional operations simulators from 2104, benefitting from the latest technical innovations (full-scale digital/tactile type) was widely expected and corresponds to a need that I have mentioned a number of times. This will, of course, need to be supported by a new recruitment drive.I note with satisfaction that the UFPI has introduced a system for assessing the work methods of each of the nineteen training centres; this assessment will eventually be conducted every two years. This internal checking will notably make it possible to confirm compliance with the rule set for assessment of skills on simulators and the results could well be subjected to independent checking by the Nuclear Inspectorate during the overall assessments of excellence.The UFPI also possesses a substantial maintenance training capability that compares well with the best worldwide. I have visited the installations of the Bugey Nuclear Power Plant training centre, dedicated to the professions of maintenance, I&C and chemistry. I observe with satisfaction the scope of innovation in the teaching methods, with e-learning, serious games and learning software. I also regret that these tools, which include the valve software FOROB, are still not being sufficiently promoted in the plants. The motivation of the trainers and the quality of the mock-ups and equipment make the centre outstanding, its slogan being “where the


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professionals train the professionals”. I hail the solid links that have been built up with a number of technical colleges, such as André Malraux Lycée in Montereau and Blaise Pascal Lycée in Saint Dizier. I would also like to draw attention to the perceived mismatch, which is resented by those in the field, between these innovations and the state of our computer systems, with the capacity of our installations and local networks to cope with these applications not being guaranteed. The utilisation factor of this training centre is very high. The projected extension therefore appears absolutely necessary to meet the requirements. The introduction of mobile training installations for fuel handling in the 1,300 MWe nuclear units is also noteworthy, usefully complementing the PWR Nuclear Steam Supply System Fieldwork Technical Validation Experimental Centre (French acronym CETIC).The opening of numerous mock-ups and equipment to contractor staff is noteworthy. Although this has been done in an increasing number of domains (valves, waste, reactor coolant pumps etc.), I regret that it is only marginal in terms of overall training time. I have taken good note of the centralised management of training in industrial safety and radiological protection at Bugey Nuclear Power Plant training centre. I see this as an opportunity to link up this training to special requirements in the maintenance profession and to reinforce the industrial safety aspects of training, which is currently insufficient.I have also seen the need for greater willingness to listen to the needs of the Flamanville 3 maintenance staff, in the same way as this has been possible in the case of operating training.

The Operations & Engineering Training Unit (UFPI)

The UFPI has 22 training centres. It is coping with an exceptional increase in activity with 3 million hours of training provided in 2012. The number of instructors has increased from 350 in 2007 to some 700 in 2012 (1,150 in 2014). The Nuclear Operations Division represents about 80% of its work, and the Nuclear Engineering Division about 10%.

Training an operating team on a simulator

The Safety and Protection Training Institute and its fire training centres

I visited the Avenières centre of the Safety and Protection Training Institute (French acronym IFOPSE), a company belonging to EDF. Together with the Roche-Bernard centre, there are some 60 staff who are indispensable to EDF SA for training its personnel in fire prevention and fire fighting in the nuclear power plants. The value of this training, which is mainly intended for the second-line response staff of the plant operating and security departments, is now widely recognised. It has enabled considerable progress to be made in the plants. I am pleased to see the increasing opening up of these centres for training of risk management departments, fire supervisors and engineers from the Nuclear Engineering Division; by focusing on prevention, these centres can cater for other branches of industry, with which the Safety and Protection Training Institute also works.

New developments at the Nuclear Engineering Division

The Nuclear Engineering Division also began a Skills Project in 2012 as it is confronted with large numbers of staff taking retirement and the need to take on more than 400 young new arrivals a year, most of whom are engineers. The nuclear engineering professional academy is in place and I am happy to see that the Nuclear Engineering Division and the UFPI have established an initial partnership to prioritise training initiatives to be set in place and developed. The Nuclear Engineering Division training, much of which is at engineer level, necessitates the secondment of skilled personnel and even experts from the Nuclear Engineering Division. I have observed that such transfers are still too infrequent.I hail the RACINES programme (French acronym meaning to succeed with activities by inter-generational skill in engineering and the employability of all the employees) rolled out this year. It is intended to transfer key skills by


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creating solidarity between the incomers and outgoers and by upgrading the work methods. In the Nuclear Engineering Division’s engineering centres, I have also met young engineers that were highly motivated as they had been entrusted with important tasks. This practice needs to be encouraged and I will be watching how it develops. Nevertheless, I regret that the young engineers of the Nuclear Engineering Division are not far more exposed to the plants or seconded to them, in departments other than the joint plant and Nuclear Engineering Division teams. This situation is very regrettable and does not prepare for the future properly; I feel that there is a lack of ambition concerning this point. Are we not about to miss a historic opportunity for bringing engineering and operations together? I see this as a chance to foster better understanding of the operator’s needs while disseminating the designers’ intentions. The engineering centres, which are severely challenged by the short-term workload, need to give greater thought to the long term.I am left wondering about the absence of training departments in the engineering centres. Perhaps corporate departments this size e.g. 1,400 engineers at the Power Plants Operations Engineering Centre (CIPN) alone, merit having special arrangements, in liaison with the UFPI.

Training logistics: the weak link in the chain

I deplore the absence of the significant progress in this domain which is indispensable for proper overall functioning (management of the courses available, scheduling, enrolment, attendance invitations etc.). Far from simplifying the work of the managers, the current system has saddled them with an increasing bureaucratic workload. Here again, comparisons with international practices do not show us in a good light. This has become a sensitive issue in the nuclear power plants, problems with the Shared Services Division (French acronym DSP) remain plain to see and apparently very hard to solve. The approach adopted would appear to concentrate too much on seeking to rationalise and reduce costs, and not enough on the quality of the service rendered to the clients (UFPI and the managers of the nuclear power plants). I encourage all involved to resolve this without delay.

EDF ENERGY, A ROBUST TRAINING SYSTEM

The system in place, which is based on a Systematic Approach to Training (SAT), is a solid one. It is supervised

by an accreditation board comprising a number of personalities from outside the company. I have nevertheless found that some plants are faced with difficult problems when organising training in their operating departments because of ill-adapted work schedules, a situation broadly comparable to that in EDF SA. Simulator training is also insufficient, with an average of 11 days per operator per year, much the same as in France.I am pleased to be able to report excellent synergy between the EDF Energy and EDF SA staff in this field. This cooperation takes the form of cross-checking on numerous occasions, the sharing of experiences and the secondment of personnel. In particular, I note the participation of EDF SA representatives in the Sizewell Nuclear Power Plant training accreditation review, as well as the contribution of EDF Energy mentors in assessing the progress of the Skills Programme in the French nuclear power plants in 2013.

AT CONSTELLATION ENERGY NUCLEAR GROUP

As mentioned in my previous report, the Constellation Energy Nuclear Group plant training programmes are properly provided for and are accredited by INPO. The system in each plant is based on self-assessments and regular external assessments, scheduled after INPO overall plant assessments to make sure that the training programmes correspond to the needs of the plant. In the USA, I noticed that training is frequently and spontaneously mentioned as a means of improving operational performance. One of the strategic orientations of the Constellation Energy Nuclear Group, relating to the quest for excellence, clearly identifies training goals and the INPO accreditation system. I also note that the average on-simulator training time is a little over 12 days per operator per year. During my visit to Nine Mile Point Nuclear Power Plant, I was shown the situation concerning the renewal of skills. I found that special attention was being given to supernumerary staffing, with priority focusing on the professions of operating, maintenance and control systems, radiation protection and chemistry. The need for highly-specialised engineering skills had been identified and taken into account.

RENEWAL OF SKILLS IN THE EDF GROUP

At EDF SA, succeed with generation turnover

The recruitment is substantial and normally guaranteed for the next three years at the Nuclear Operations Division and the Nuclear Engineering Division on the basis of diagnosis


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and the path laid down by the Nuclear Technology Division in 2010. I would like to draw attention to the vital need to maintain the effort. I am struck during my plant visits by the concern still expressed on this point, the fear of seeing the “tap re-closed”, despite the unprecedented recruitment that has taken place over the last five years. The memory of recent historical staff reductions has still not faded.Not all the professions at the plants are in the same situation. I would like to draw attention to the need for sufficient supernumerary staff, clearly identified as such, in the maintenance departments, which is not always the case. In the operating departments, recruitment is in full swing and should make it possible to achieve proper staffing levels in the medium term. However, the demand for skills derived from operating is currently high: safety engineers, simulator instructors, engineers for work management for both units in operation and during outages, and corporate engineering centres and post-Fukushima work. I consider that a special effort needs to be made for a few years to satisfy the needs as they are vital for good operational performance.I am pleased to observe the increasing success with inter-organisational training, highlighted in my 2011

report. I note that, in the nuclear power plants, this is starting to work well in many departments, including engineer training. I have, for instance, been introduced to trainee engineers from the Ecole des Mines de Douai engineering school on work-study contracts in the official inspection departments.I would also like to emphasise the situation in the newest nuclear plants which are not yet experiencing massive departures of staff on retirement. With little recruitment currently authorised, they could well find themselves in the same predicament as the first 900 MWe plants were five years ago, with insufficient overlap between generations. Careful planning is needed here to avoid replicating the same difficulties as in the older plants.I regret the absence of a clear overall policy for meeting future staffing needs and engineering skills, and more generally for coordination between the two main players, the Nuclear Engineering Division and the Nuclear Operations Division. The difficulty in satisfying the demand for resources probably explains this situation to a certain extent but I consider the two divisions would gain greatly from promoting career paths including time in both divisions.

0

1

2

3

4

5

6

2007 2012 2017

Operating

Experienced sta Inexperienced sta

0

1

2

3

4

5

6

2007 2012 2017

Maintenance

Experienced sta Inexperienced sta

Trends in the proportion of experienced to new staff in the operating and maintenance professions

EDF Energy, a situation under control

The management of skills in EDF Energy is in no way comparable to the situation in France (the annual departure rates are lower), and recruitment has been regular over the last ten years. Nevertheless, some 470 incomers are now in supernumerary positions, corresponding closely to the need for skills renewal. The basic common-sense principle appeared to be respected in the plants visited: on departure of an incumbent from a position, the replacement is present at the plant and already trained. The system for planning and monitoring the renewal of skills at the Barnwood centre is straightforward, featuring realistic allowance for basic training time and looking forward to the long term (five to ten years). I was also

pleased to see the good relations established with the Nuclear Decommissioning Authority which manages the Magnox-type reactors while they are being closed down, enabling the judicious redeployment of the staff involved. I would however like to draw attention to the particular situation regarding the operating resources which I consider will be stretched at some AGR plants which have to perform multiple unit outages per year. These plants, due to the changes in the technical characteristics of their reactors which cannot be refuelled and defueled when on power, need up to five unit outages per year. The operating staff are under considerable pressure during the outage planning and execution phases alike (they are also responsible for handling the reactor fuel).


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I would like to once again emphasise the importance of technical expertise for the AGR plants, where high-level resources will be needed to meet the demands of the

plant engineering services, the Design Authority and the Safety and Regulation Department until the end of their operational lives.

MY RECOMMENDATIONS

Training inside the EDF Group is now benefitting fully from the synergy and comparisons with EDF Energy and American operators, who are setting the standard when it comes to implementing the Systematic Approach to Training (SAT). At EDF SA, I am pleased to see something of an epiphany with recognition of the role and the responsibility of managers in the development of skills. I encourage continuing along this path by making the most of the opportunity for opening up and making comparisons within the EDF Group, especially with regard to EDF Energy.

I consider that the company resources invested in training are very substantial. I would, however, also like to draw attention to the need to maintain the investment over time as it prepares for the future, not only for human resources but also for modern training equipment with associated computer systems and networks.

In France, I encourage the development of career trajectories spanning both the Nuclear Operations Division and the Nuclear Engineering Division, for both experienced and young engineers. I emphasise that it is important to seize the opportunity constituted by the massive arrival of young engineers in our engineering centres to give them a proper understanding of the realities of operations at the earliest opportunity. They could thus become powerful exponents of mutual openness and discovery between these two organisations.

Finally, to better address the generation turnover challenge, I would like to draw attention to the need to further develop maintenance supernumerary positions in France, and better integrate the basic training time, as is now the case in the operating profession. It is also necessary to accept the need for temporary additional investment in operations skills to be able to eventually satisfy the needs expressed concerning a number of key areas (simulator instructors, safety engineers, outage managers, engineering etc.).

MAINTENANCE, A STRATEGIC DOMAIN THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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07/ MAINTENANCE, A STRATEGIC DOMAIN

Maintenance work in the turbine hall

The next ten years will be decisive for the future of the French plants. There are many challenges to be faced, such as the post-Fukushima activities, plant life extension, maintaining competitiveness and nuclear safety re-assessments. With the plants at mid-lifespan, maintenance is acquiring strategic importance for guaranteeing the level of nuclear safety and preserving the company’s assets. As regards this vast and complex issue which involves a large number of different players, EDF SA is still well below the highest international standards and must continue with the changes it is making.

As I have previously mentioned, I have noted a perceptible increase of more than 40% in the number of nuclear safety significant events originating in maintenance activities, with the units in service and during outages. During outages, these events frequently cause disorganisation and delay, and generally have more serious consequence

for the installations which, although not in service, need to be the subject of permanent reactor monitoring. I am concerned by these results, redolent of slowly declining quality in maintenance work, and I find myself wondering about the organisation, resource availability, rigour and means.

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION MAINTENANCE, A STRATEGIC DOMAIN

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Trends of categories of sub-standards maintenance events from 2009 to 2012

ORGANISATION

For many years, the plants have had a policy of rationalising the maintenance work by focusing on the key equipment in terms of nuclear safety and operability. This has led to specifying maintenance programmes and the means for carrying them out. At present, there are three types of means: 1) establishment of a multi-year maintenance programme, 2) planning and execution of unit outages, and 3) management of the nuclear units when in service. I am surprised to observe that although the rules concerning these means have been in place for a number of years, they are not producing the desired effects and that the standard of maintenance is regularly dropping in the meantime.The forced outage rate for the units in service have been improving for a number of years, and are now at a satisfactory level of around 2.8%. I see this as the result of renewed investment in the main components. At present, it is during unit outages that most of the sub-standard maintenance work is occurring, and causing the most serious events in terms of nuclear safety.For a number of years, outages have been regularly extended by more than twenty days, and by more than twenty five days in 2012. Regardless of the cause, outage extensions are periods of vulnerability as they upset the planning and scheduling. They thus foster sub-standard work and events with nuclear safety implications. As can be seen from international experience, they must not be seen as unavoidable, an attitude I have on occasions observed in the plants.Yet, the best practices I have observed outside France concern maintenance, logically based on multi-year forward planning right through to everyday unit operation, and covering unit outages. The multi-year organisation establishes a framework and a basis for a medium-term plan, the unit outage organisation manages heavy maintenance, and the unit in service organisation manages everyday maintenance.

The multi-year organisation

This was originally part of the unit outage organisation and is accordingly often overshadowed by the “mighty war machine” that the latter constitutes, and I observe that it has at last found its due place in the plants. I am pleased to see this because a clear multi-year plan with proper foresight is the key to successfully conducting outages and ensuring that the nuclear units function safely. This year, I note that the organisation’s workload is building up, and that the resources in some of the plants are being stretched.Accordingly, I would like to mention the many rules laid down at corporate level that have to be taken into consideration in the plants. Faced with so many rules and constraints, I feel sure that the staff in the field are in danger of losing their sense of proportion. In the oversight that they exercise, the corporate departments need to take care to optimise rule-making, especially by better forward planning, and thus make fewer rules.I have also noticed that the multi-year programmes in the plants make little or no allowance for scheduling the work of the Nuclear Engineering Division and its constraints. The Nuclear Engineering Division will be responsible for a substantial amount of the General Refurbishment work over the next ten years. It seems to be necessary for its activities to rapidly appear in the plant multi-year programmes. Accordingly, I am happy to see that the Nuclear Engineering Division and Nuclear Operations Division joint project is continuing, having been temporarily delayed by the post-Fukushima activity, which overlaps this work.

The “unit outage” organisation

The corporate directive that specifies the organisational structure to be set in place in the plants for successfully carrying out unit outages is broadly inspired by best international practices, and is now in its third edition.


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Despite this, the plants are continuing to report significant outage extensions. It is to be remembered that proper, successful, timely execution of a unit outage means good-quality work and fosters nuclear safety.For outages, the required tools appear to be at hand, the required teams are in place and adequately staffed, the inter-professional committees are functioning, and the necessary resources are available. It seems that the weakness stems from the fact that outage planning is not held in sufficient regard and that the planning resources and detail are lacking. In the two-unit plants, I have often heard it said that the next outage will be prepared when the current one is finished, sometimes with a holiday period separating them. Even if efforts are made, particularly with the visibility provided by the multi-year plan for industrialising planning and scheduling, the outage schedules must be considered sacrosanct and the milestones met. I am surprised to learn that, sometimes, as many as 60% more jobs may be added less than four months before the outage start, and sometimes jobs are added while the outage is in progress. The alert not only needs to be sounded about simple refuelling outages where the planning is upset as is the execution of the outage itself, but also the multi-year programme for the plant.Outages without adequate planning means more pressure for EDF and contractor staff as a result of frequent re-scheduling, time lost waiting and work being carried out in haste. These situations foster sub-standard work, omission of re-qualification and events with implications for nuclear safety. I would like to emphasise the importance of the Unit Outage Nuclear Safety Committees (French acronym COMSAT) as a line of defence against such risks. The rigour with which their agendas are planned by the professions is, in this respect, vital.

Not enough resources and foresight are devoted to planning outages, especially as these are numerous, since core management policy favours short cycles. There is a need to analyse the impact of the refuelling cycle length on workload and resources, as well as the effect on the composure of the staff and the standards of work and nuclear safety.

The “unit in service” organisation

Although this organisation was designed a number of years ago, its degree of implementation in the plants varies. Its goal of seeing beyond the immediate and setting in place a proper organisational structure featuring foresight and adherence to a schedule has yet to be achieved. Three- and six-week schedules are still difficult

to apply. Re-scheduling is still only too frequent due to problems with methods, planning and the availability of spare parts and resources.I appreciated seeing rapid response teams in all the plants visited this year. They are acclaimed by both operations and maintenance. They enable time to be saved in dealing with small defects and facilitated diagnosis of others. They foster mutual understanding between the maintenance and operations professions, especially among the new arrivals.Nevertheless, it remains true that the backlogs of job requests may have got lower but are still high. To make progress with eliminating them, the maintenance departments still need a considerable amount of technical assistance.In the plants, staff are calling for smooth interfacing between the three organisations (multi-year, unit outage and unit in service). I would like to draw attention to the fact that operation at fleet level is not as smooth as it could be between the three organisations; although all are attached to the Production Committee, they are not monitored by the same fleet-level departments. I regret, for instance, that the computerised scheduling tools do not intercommunicate, making re-typing necessary which is a waste of time and an opportunity for errors.Here I was struck by the low quality of the computerised tools used by the unit in service organisation, which are often replaced with Microsoft Excel in the plants. Standardisation of the computerised tools is planned as part of the switchover to the Nuclear Technical Information System (French acronym SDIN). The last plants are to make the change in 2018 and interim solutions need to be provided.The unit in service organisation has not inspired the newcomers, who prefer the unit outage organisation. The former is not in the limelight and is often seen as a bit-player. This impression must be overcome and the management needs to increase the attractiveness of this organisation in the plants.Success will depend on the strong involvement of the operating staff who need a clear medium-term picture and foresight. As I sometimes observed, the lack of consistency in the decisions made by different shift teams is another obstacle in the organisation’s quest for effectiveness. The need for an operating shift manager who can step back from the immediate work to check the scheduling and practicability is a pressing one. Like the conductor of the orchestra, the operating department must take the baton and set the rhythm.I have seen such involvement in the plants at EDF Energy visited this year. The Work Execution Centres, which are the equivalents of our unit in operations systems in France are characterised primarily by the strong presence


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of operating skills, the establishment of the schedule at planning level and the issuing of work permits. These resources, which are seconded from the operating teams for long periods, provide an effective connection with the maintenance departments. The scheduling is considered consensual and legitimate.

SKILLS

In this field, the maintenance departments appear to be in increasing difficulty. The staff are young, the training long and the departures on retirement are many. These factors combined mean human resources will be in short supply for some time to come. In addition, the maintenance departments are constantly being called to play parts in the numerous corporate projects in progress, which frequently results in re-organisation and changing of responsibilities. Wherever I go, maintenance staff are under pressure and becoming disorientated.The deployment of the AP 913 programme intended to increase the reliability of equipment has resulted in the arrival of a significant number of recently-qualified engineers in the plants. Meanwhile, I deplore the insufficient number of technical engineers in the maintenance departments where the technical mentors are still primarily the work package planners, who are ever few in numbers and have many calls on their time. The introduction of reliability departments has in some cases contributed to further distancing the maintenance methods staff from the field and weakening the fieldwork departments. I am not certain that the allocation of significant amounts of resources to the AP 913 programme, in view of the small amount of unplanned capacity loss, is the best way of addressing the current needs for unit outages and planning of the General Refurbishment.If I am sounding the alert about the need for technical engineers and not managers in the maintenance departments, it is because the planners have become a rare resource that is under pressure and subject to demands from all quarters. The position is not considered an enviable one by our workshop technicians, who would prefer quieter jobs for much the same money. As in the operating departments where young engineers have been introduced to the profession, the same needs to be done in the maintenance departments. I hail the re-launch of the maintenance engineer training that had been scaled back for a number of years and which now meets a real requirement.In the maintenance professions, training time is also long, with on-job exposure and the need for mentoring. The lack of supernumerary staff at all levels is still keenly felt, at a time when increasing numbers of staff are taking retirement. I am pleased to note the development of

inter-organisational exchange programmes in the plants for both field workers and engineers. This can go some of the way to addressing the lack of professionals in the maintenance departments by combining apprenticeship in the field with mentoring and theoretical training.

RIGOUR IN EVERYDAY WORK AND SURVEILLANCE

Rigour and quality are hard to obtain when the workers are faced with numerous contingencies on an everyday basis, when they have to handle case files that are increasingly bulky and sometime lack the drawings, and when they need to handle issues outside their range of skills or original profession. The issue of “hands-on time”, which was covered at length in my previous report, remains unsolved and I regret not being able to see progress in the field.Increasingly faced with cases of sub-standard quality in the field, I note that surveillance is not properly playing its role as a line of defence. I have observed that the context is unfavourable: the rule sets are numerous and complicated, risk analysis is often late and too standardised, and the surveillance manager’s position is not held in high regard. Despite this, some plants are on the right track and making progress. I accordingly hail arrangements to promote the surveillance manager position by either an associate director or by the head of industrial relations. I strongly encourage such initiatives.Surveillance managers are still all too often appointed only a few weeks before unit outages, leaving them insufficient time to study the files and draw up their surveillance programmes. Their training remains too orientated towards an apprenticeship consisting of book learning rather than “by learning to see on the job”.Regarding this subject, I would like to recognise the creation of a department at Sizewell B dedicated to surveillance and ensuring both the surveillance of work and the accreditation of in-house checking by contractors.

SPARE PARTS AND THE AMELIE SPARE PARTS MANAGEMENT CAMPAIGN

This year, once again, during my encounters with maintenance staff, the subject of spare parts remains a complex one monopolising much time and energy, with one out of two parts not being procured by the standard process. It is proving lengthy for confidence to be restored between the multi-year organisations in the plants and the spare parts teams of the Central Technical Support Department (French acronym UTO). I think, however, that we are going in the right direction.


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I met the staff of the AMELIE spare parts management campaign at the Central Technical Support Department facilities and at the Velaines spares storage platform. Launched in 2008, the AMELIE spare parts management campaign is now reaching its final stages and the permanent organisation in charge of spare parts in being turned over to the Central Technical Support Department. I consider it most important for the handover to take place in a proper manner without undue haste, with as much plant involvement as possible. The Central Technical Support Department and the plants need to make a point of working in close collaboration for the process to be permanent.With this project, EDF SA has devoted considerable financial efforts to rationalize the management of spare parts for the French nuclear power plants and I insist that theses must be maintained until the project is completed. The new stock management policy has been accompanied by a substantial increase in the stocks, the creation of the Velaines platform and the development of new management tools. The Velaines platform, which was commissioned in 2011, is the strategic centre of the system where all movements are centralised: acceptance, packing, storage and shipping for the 58 French nuclear units. After a commissioning period in 2012, it should be operating at full capacity to back up the outages in 2013. The numerous advantages of having all the spare parts for the plants in one place (except the heavy parts, which remain at Creil) must not lead to underestimating the associated risks. Failure of a conveyor belt, which I witnessed during my visit halfway through the year, is an illustration of this issue.Rationalisation of the corporate stocks also means managing the work on repair and re-conditioning parts. This management, which is just beginning, needs to rapidly come up to speed to close the loop.I note that stock management in the plants has become more complex, requiring far greater competence with the computerised tools for the storekeepers. The latter should have greater support during the changeover.While on the subject of spare parts, it is necessary to once again mention the issue of obsolescence. The component obsolescence project, begun a number of years ago, does not seem to have been allocated sufficient resources to cover all the issues, with the attendant risks.

The Velaines platform

Set up as part of the AMELIE spare parts management campaign, it will house all the spare parts for the French plants except heavy components and standby stocks in the plants. It is on a 15-hectare site in the County of Meuse. The Nuclear Operations Division has asked the Industrial Support for Production Division (French acronym DAIP) to run this platform, via the corporate logistics office. Some seventy people are employed there.Key figures for the Velaines platform:

• Warehouse surface area: 45,000 m2• Number of spare parts: 4 million• Number of items listed: 200,000• Length of shelving: 7 km• Number of storage/retrieval machine cells:

120,000

The Velaines corporate stores

THE CONTRACTORS

When it comes to work in the field, contractor staff are confronted with the same difficulties as our maintenance workers: long waits, tools not always available, frequent re-scheduling and numerous constraints in the work environment. Hands-on time is not increasing. All recognise that it is too short, and this needs to be taken in account when planning the General Refurbishment.For the employers, the problems with the renewal of skills and estimating the work load are the most intractable. The contractors working on the French plants have the same swings in activity as their client EDF. Better working conditions resulting from better planning, more flexible organisation and properly-proportioned resources will help to compensate for shortcomings on the part of the EDF and subcontractor staff, and thus improve nuclear safety in the plants.Our business policy in the field of maintenance, as I have seen during my visits to the plants and encounters with


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the contractors, oscillates between approaches, resulting in confusion and misunderstanding. We do not make a clear choice between on-going relations based on partnership and seeking our advantage in a competitive

market. Both approaches have their advantages and disadvantages. Difficulties arise when we swing from one to the other, as circumstance or markets dictate.

MY RECOMMENDATIONS

The recurrent difficulty for the plants in completing their unit outages on schedule are a source of sub-standard work and discouragement. In the field of maintenance, a clear, multi-year outlook faithfully corresponding to the activities to be scheduled in the medium term is indispensable for success with the unit outages and for reducing the amount of unplanned capacity loss. Yet this not sufficient. We also need to rationalise the unit outages and make meeting our obligations sacrosanct. The company must also accept the consequences of it technical and economic choices in the field of fuel, particularly for the 900 MWe nuclear reactors with short fuel cycles.

Unlike the operating department, who are constantly challenged by the independent nuclear safety organisation, maintenance does not have the benefit of an equivalent external look at its everyday activities. Today, the staff of the independent nuclear safety organisations are young and their training has focused on process considerations with little or no

focus on maintenance. I call for the introduction of maintenance engineers in the maintenance departments and the incorporation of maintenance skills of adequate level into the independent nuclear safety departments.

The desire to reduce outage durations and centralise the maintenance of spare parts needs to be moderated by giving thought to our maintenance policy. Should we still be carrying out repairs in the nuclear units? Would it not be better to perform standard exchanges of entire plant items as many other operators do? The question needs to be posed, especially as it would foster more frequent involvement of the original equipment manufacturers.

Finally, I can state that the staff hands on in the plants are working very hard to improve the overall results. The difficulties in managing the outages and the quality of the field work must not eclipse the motivation and commitment of the EDF and contractor staff.

NUCLEAR TECHNICAL INFORMATION SYSTEM: STILL A LONG ROAD AHEAD THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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08/ NUCLEAR TECHNICAL INFORMATION SYSTEM: STILL A LONG ROAD AHEAD

Blayais Nuclear Power Plant

The renovation of the Nuclear Technical Information System (French acronym SDIN) directly involves four professional divisions of EDF SA: first and foremost the Nuclear Operations Division and also the Nuclear Engineering Division, the Nuclear Fuel Division and the Industrial Support for Production Division. This is part of the initiatives to make progress in the professions, improve operating standards, increase equipment reliability and enhance the performance of the installations. In view of its strong impact on the work organisation and methods, and the attendant risks, I have focused on the manner in which the change is being organised, with particular reference to nuclear safety.

THE DEPLOYMENT CONTEXT

The nuclear plant data system in France is more than twenty years old and due for renovation. EDF decided to choose a tried and tested management model with the goal of backing up and consolidating the initiatives concerning the nuclear professions. Harmonisation of practices between plants and standardisation of the work methods, increasing synergy between engineering and operations, increasing equipment reliability, improving operating performance and developing the use of experience feedback are among the intended objectives of the initiatives to make progress associated with the design and deployment of the Nuclear Technical Information System.I am pleased to see the roll-out of the Operations and Maintenance Methods Programme (French acronym MME) in the Nuclear Operations Division, now in charge of coordination, which will synchronise the different projects associated with the Nuclear Technical Information System. This has also made it possible to establish milestones and deliverables for overall success, while providing assistance for the plants.

The Operations and Maintenance Methods Programme for 2015

The Generation 2020 project organised by the Nuclear Operations Division has set in place an Operations and Maintenance Methods Programme for 2015 combining:

• deployment of AP 913 methodology intended to increase equipment reliability and enhance system performance,

• creation of a standardised activity model library for both operations and maintenance on a plant and corporate level,

• creation, for each group of similar reactors, units for updating the standardised activity model libraries using experience feedback from the plants and updating the rule sets,

• completion of the AMELIE spare parts management project,

• deployment of the Nuclear Technical Information System.

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION NUCLEAR TECHNICAL INFORMATION SYSTEM: STILL A LONG ROAD AHEAD

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BLAYAIS NUCLEAR POWER PLANT: THE LEADER

I visited Blayais Nuclear Power Plant where the staff showed how the project was progressing. I found that the managers and staff of the teams to all be very keen. Blayais was chosen as the first to deploy the SDIN in a plant once the documentation part (the only part available to date) went live in the first corporate departments, namely the Central Technical Support Department (French acronym UTO) and the Operations Engineering Unit (UNIE). The plant had the reputation of having well-ordered processes, a properly integrated multi-year maintenance policy and the rules for unit in service and unit outage situations. The deployment was initially planned for 2010, but actually began in the middle of 2011 and was extended to unit outages in 2012, including a ten-yearly outage. I appreciated the particularly strong involvement of the plant management, beginning with the director and extending through the line management, at a time when the plant was extremely busy.

Proper allowance for nuclear safety by the plant

I also noted the unflagging involvement of the independent nuclear safety organisation at the plant to promote the INSAG 18 initiative and to avoid compromising nuclear safety during deployment in the plant, which was not complete at the time of writing this report. Special attention has been paid at the plant to real-time nuclear safety and the control of state changes during unit outages and start-up.

The professions find common ground on the basics

The plant management took care to engage with both the service-users and service-providers. They were involved in training, planning and analysing the impact of the basic work elements, with managers putting themselves in the positions of the players.The plant management seized the opportunity to get all the professions to work together (operations, maintenance, chemistry, logistics, risk management etc.) on establishing the basics of the activities liable to be affected by the SDIN. This work has made it possible re-examine and update the basic work protocols: functional diagnosis to draw-up a job or fieldwork request, planning of preventive and contingent activities, programming, scheduling and coordination of activities, making allowance for logistical

constraints, drawing-up job permit requests, risk analysis, requalification, rectification of discrepancies, first-line and second-line analyses and experience feedback. In this context, the deployment has strengthened the position of the multi-year initiative in a manner consistent with the unit in service and unit outage initiatives.

A major effort to cope with an underestimated workload

I have discovered that an excessive number of adjustments had to be made which required much time and effort at the plant (still the case), indicating that the system was not properly finalised before deployment, and also that the workload was underestimated from the start, even though the plant had the reputation of being well-organised with good work methods.There was clearly failure to foresee the amount of work required, at programme level and in the plant, for the professions and for the owners of the information system. Although the plant was busy with its routine work to generate power and cope with a ten-yearly outage at the same time as the system was deployed, it nonetheless rose to the challenge and set contingency plans in place without compromising everyday nuclear safety. This, however, required a major effort for the plant staff, particularly as the professionals needed were already busy with many other things, and here it is especially planning that I have in mind.

Insufficient prior consideration of the nuclear safety implications by fleet level

I have also noticed that it was necessary to make major corrections at a late stage, which could well compromise nuclear safety, for instance, operations requests to allow good planning of the agendas for the unit outage safety commission meetings before changing reactor modes during start-ups.I am surprised to see that the new tool allows more laxity and less clear traceability of the lines of defence at this stage than the existing SYGMA system. It has necessitated organisational arrangements that are more complex and stricter in order to prevent degrading nuclear safety in execution, as well as to maintain independence of technical checking, first and second line analysis, and verification work.The nuclear safety analysis was carried out as part of the Nuclear Technical Information System programme at the start using the INSAG 18 approach as a basis and inputs from a socio-organisational and human factors

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analysis but it was not initially sufficiently challenged by fleet level on these considerations. I am therefore raising the question as to the depth of the nuclear safety analysis of the programme as a whole, and suggest that it needs to be more adaptable and responsive as experience feedback on the programme accumulates.

A tool that is not yet mature

I also note that many more software rectifications are still awaited by the users in the new version which was due by the end of 2012 and which will need to be qualified at plant level. I regret that, pending the availability of the new version, the plant is obliged to work with an unfinished tool and draw attention to the risk of premature withdrawal of the SDIN Programme support to the pilot plant, a possibility that was mentioned during my visit.In the case at hand, that plant was able to rise to a high standard of work involving all the stake holders and closely involving both sides of the industry. On the face of it, the new information system appears to have been better accepted by the new generation of staff.It is to be hoped that, now the staff at Blayais Nuclear Power Plant have borne the brunt of the debugging, no more will be needed before further deployment. However I am left still wondering whether the conditions in the other plants are sufficiently robust for its successful deployment.

KEY FACTORS FOR SUCCESS WITH FURTHER DEPLOYMENT

Given the scale of the impact at Blayais Nuclear Power Plant, where a strong and stable situation prevailed, it appears to be vital that the backup of the programme by fleet level is sufficient for Blayais site (where final close-out of all the issues will be complex) and for the other plants. Blayais Nuclear Power Plant will soon be faced with steam generator replacement work, which is why the backup needs to continue until deployment is complete. This should be done with close involvement of the new set of plants concerned. Special attention will be needed for the plants with two nuclear units.Particular care will also be required for the professions most affected. Here I have in mind the planners in particular, who benefitted from relative stability during the deployment of the SDIN at Blayais Nuclear Power Plant. I am raising the alert as to the capacity of the plants to simultaneously cope with the renewal of skills, the passing-on of knowledge and skills to the incoming generation, the start of the General Refurbishment and

the roll-out of the SDIN. The attention paid to the manner in which the change is managed must be particularly careful.The harmonious co-existence of the AP-913 project, the new activity model library, AMELIE spare parts management campaign and the SDIN must be durably guaranteed up to 2018. In this context the MME 2015 programme is playing a vital role that needs to be recognised in its action to orchestrate and set the timeframe for the key stages. I would like to draw attention to the resources required and the need to make sure that this programme is kept going.To manage the change, I consider that tracking nuclear safety and business performance indicators, to make sure there is no deterioration during the deployment phase, and the properly targeted return to steady-state conditions will help to ensure success. To avoid the players becoming discouraged with this lengthy deployment, it will be necessary to regularly set in perspective the performance results and the trends.I have also observed that questions are being raised about the deployment of the SDIN in the engineering centres. Allowance needs to be made in the SDIN for the particularities of the design rule sets and the modifications made by the Nuclear Engineering Department to find new synergy between engineering and operations.The staffing of the organisations for each of the standard nuclear reactor series, their responsiveness, and their connection to the engineering bodies in charge of establishing the rule set and with the plants for the integration of experience feedback will need to be the subject of special attention by the MME staff. Furthermore, I am left wondering about the depth of the standardisation or the work methods that the company will finally be able to achieve for each reactor series and for the plants as whole, as deployment at the pilot plant necessitated integrating many local particularities.

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MY RECOMMENDATIONS

The plants must always be able to fully exercise their responsibility as a nuclear operator making sure that nuclear safety has top priority throughout the deployment of the SDIN. It is vital that they mobilise their independent nuclear safety organisations, by reinforcing skills if necessary. Similarly, the plants must always be able to take full possession of the SDIN.

Faced with a set of projects of this scale, of which the SDIN is only one, I conclude that there is a need for a high-level supervisory body. The MME programme, whose role is currently coordination, could well be made a permanent function with the role of cross-organisational supervision. Similarly, I would like to draw attention to the skills and authority that the future plant-level project managers need to have. Meanwhile, I approve the decision taken at corporate level to proceed with the deployment of this project by stages, allowing for the actual situations in the field.

If carried out properly and in sufficient depth, bringing in all the stakeholders, the work on the fundamentals of the professions and work methods, alongside the deployment of the SDIN, will eventually bring dividends in terms of nuclear safety. I emphasise the need to properly assess the impact of the scale of the change and the necessary support at each individual plant. This means taking into full account the workload and the situations of the professions at each plant, as well as the need for overlap between the plants to facilitate the sharing of experience feedback.

I also note that the plant managers need to get involved in deploying such a project, listening to any difficulties expressed, and be willing to engage in the field to understand the situation and arrange for effective compensatory and corrective measures.

Finally, I emphasise the strong commitment of the Blayais Nuclear Power Plant staff and of the corporate-level teams in the SDIN. Such commitment is indispensable to successfully deploy the system in the other plants.

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09/ ATTENTION TO CHEMISTRY NEEDED IN OPERATIONS

Chemists in a nuclear power plant, key competences

Maintaining proper water chemistry in a PWR reactor is one of the nuclear operator’s basic tasks. Maintaining high chemistry standards make the equipment last longer and greatly contributes to nuclear safety and radiation protection. The changes introduced in EDF SA in recent years merit being extended. The Group also need high levels of expertise to manage the particularities of its AGR and BWR facilities.

This year, I met the chemistry service in each EDF SA plant I visited to assess the skills of the staff and the willingness to heed their advice during the different stages of operations. I also met the staff in charge of chemistry in the Corporate Chemical & Metallurgical Centre of Expertise (French acronym CEIDRE), a corporate department ensuring an innovative technical and promotion function essential for the 58 plants. In the UK, I concentrated on issues associated with carbon deposition in the carbon dioxide systems, while at Nine Mile Point and Hartlepool Nuclear Power Plants I focused on chemical cleaning.

THE FRENCH PLANTS

Skills

I found that chemistry skills are dependable and kept up to standard. Apart from the very understandable apprehension about future departures on retirement, I have found the supernumerary posts well-staffed and experiencing little difficulty with recruitment into

this highly-technical profession, where apprenticeships are becoming increasingly common. The recruiting of chemists by the plants, normally with skilled-technician level qualifications, takes place in a straightforward manner; three quarters of the plants also hire chemical engineers, which is a very positive trend and should be universal.Corporate promotion of the profession is often complicated by the fact that the skills needed are scarce. Training is mainly left to the plants with the Operations & Engineering Training Unit (UFPI) taking little action in this field, although it is an important one.

What the chemists in the plants are saying

I have noticed the situations vary greatly in the field. All too often, little attention is paid to the technical recommendations issued by the chemistry services with little action taken, whether the plant is in service or during an outage.

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The legitimacy and authority of the chemists is still insufficiently established in the plants. Accordingly, fifty percent of the question/answer forms sent by the plants to the CEIDRE for review before a technical decision is made, reflect lack of confidence in the chemist’s opinions on the part of the plants. This situation is very different from the practices of nuclear operators in other countries, where the plant chemists speak with authority. At EDF SA, it is usually the corporate-level engineering echelon that has the last say in operations-related technical matters, very likely in view of the preponderant role of the CEIDRE (formerly the Laboratories Group, French acronym GDL) at the time of commissioning the nuclear units in the eighties.When the unit is in service, they have great difficulty in receiving support, for instance to initiate or expedite searches for the cause of air ingress into the condenser. This important parameter nevertheless governs the durability of the tubes and the lifespan of the steam generators. The chemists encountered generally feel that they receive little support from the operating departments, particularly the shift teams and the operating managers. Identifying the chemical issues and taking related action, often with effects in the medium and long term, is not given the same attention by the operating shift teams as action to deal with real-time nuclear safety requirements. I have also sometimes observed insufficient commitment by the safety engineers in this context.I am surprised to see that, during unit outages, effective practices such as drying and protection of the feedwater train are still as difficult to do (I have only seen this done once during my visits this year). The chemists cannot get the unit outage staff to listen to them. Nevertheless, I observed good cooperation between the unit outage staff and the chemists during the shutting down phase: oxygenation, purification and radiochemical cleaning of the reactor coolant system. Success with these complex operations has a strong effect on our radiation exposure results. Time pressure appears to be properly managed at the plants visited, and some excellent practices were observed such as adding a chemist to the operating shift team in the control room.I met some very keen and motivated chemists strongly aware of their role as custodians for the medium and long term who were well supported by their Plant Managers. I regret that this favourable situation is not the case everywhere.

The equipment

I would like to draw attention to the differences in the demineralisation plants and the ways they are run.

In some cases, the operations department and the chemistry department handle its operation jointly, and in some cases one or the other. I observed an innovative practice that consisted of entrusting operations to an outside company which, although it may not be the only solution to the difficulties encountered, has the merit of clarifying the responsibilities of each department. I also noticed, at one plant, the support given by the Authorised Internal Inspection Department (French acronym SIR) to the chemists’ arguments concerning protection against corrosion in certain vulnerable systems, particularly the feedwater train. I am glad to see such a joint action, and this type of approach could well be adopted in other plants to ensure that those in charge are aware of the long-term implications for preserving the assets.

Promotion of chemistry for the operational fleet

The role of the CEIDRE is to handle technical promotion and be the prime technical adviser on chemistry for the plants. The meetings to pool information on specific issues and the “chemistry roundtable” organised every year help to establish solid links between the corporate engineers and the chemistry staff in the plants. I encourage the existence of such occasions, and recommend that the managers make a greater commitment to them. They are unique opportunities to put the basic messages across and show the importance of appropriate chemistry during operations.The existence of an effective system for finding solutions to the problems faced by the plant operators (doctrine, interpretation of the technical specifications for operation or the results of measurements etc.) is also to be commended. The pertinence and promptness with which the question/response forms are dealt with is universally praised by the plant staff, whether chemists or managers.The corporate-level promotion of the chemistry profession, which is handled by Skills Advisory Centre (PCC) of the Nuclear Operations Division, resumed in 2012 after a year of inactivity. Staffing of this type of function needs to be managed very carefully. The definition of the common core of knowledge for chemistry, which is currently being established, seems to correspond to a real need, as the chemists are now finding it hard to establish their position in the current maintenance professions arrangements. I hail the reinforcing of training with the support of CEIDRE for the team leaders and front-line managers, and the heads of departments. I am wondering about the need for similar reinforcement of the training intended for the safety engineers and operating shift managers, whose chemistry training seems to be barely sufficient.

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I consider that the link between the CEIDRE (Nuclear Engineering Division) and the Operations Engineering Unit (Nuclear Operations Division) is not sufficiently strong, partly due to the absence of a chemistry specialist in the top management team of the Operations Engineering Unit (UNIE). More generally, the responsibility for approving changes in the rule set does not appear to be sufficiently defined. As the chemistry and environmental discharge committees do not deal with these issues, it would be good if the Operations Technical Committee (CTE) could handle them on an ad-hoc basis. It would appear that too little attention is still being devoted to chemistry in the Production Committee.As regards documentation, the chemistry speciality was not included in the initial scope of the project to re-write and standardise the procedures as part of the Methods and Practices Harmonisation Campaign, partly due to the small number of documents to be produced compared with the other specialities. I am nevertheless sorry to the see the opportunity to staff the new nuclear-unit series documentation bodies being lost for chemistry skills. The situation would be greatly helped by making use of the skills and the views of the chemists in drafting the standardised procedures for the field of chemistry and others, such as the normal operating procedures.

The Jean-Jacques Letalon working group

This corporate working group, which between 2009 and 2012, brought together some twenty EDF SA plant managers and experts made a number of recommendations.

• Include chemistry and, more generally the production assets as a whole, in the operational focus, even in the short term

• properly include chemistry in our real-time operations

• include chemistry indicators in our performance reviews

• make sure it has the place it merits in our organisational structure

• clarify and tighten the checking carried out by the Nuclear Inspectorate in this field

• Strengthen the chemistry culture of leaders (at plant and fleet levels)

• Give the head of the chemistry department high status

• Fully review the chemistry training intended for managers

• Reinforce the plant chemistry engineering capability

International benchmarking

The use of dashboards and indicators for monitoring performance is becoming standard practice in the plants. I also note that the WANO indicator intended for profitable international benchmarking is not considered sufficiently pertinent by many EDF experts. Experiments conducted at one plant to test a new indicator dubbed “CEI” by INPO in the USA were shown to me. I encourage the rapid adoption of performance monitoring indicators at EDF SA enabling comparisons with the results of other nuclear operating organisations elsewhere in the world. Indeed, I am struck by the persistent differences in the assessments of our results by our experts and by those of WANO. As I see it, the plants greatly need to have access to benchmarking if progress is to be made.Similarly, WANO assessments of the Peer Review type conducted in France have given rise to highly perceptible differences in conclusions and requirements in this context. The different operating conditions of the French plants, which operate in the load-following mode, do not fully explain the disparity. Although I am pleased that the Nuclear Operations Division’s Nuclear Inspectorate has been including this since 2011, in the periodic overall assessments of excellence, it needs to more closely align its requirements with those of WANO. I would also like to emphasise the importance of preserving chemical engineer skills in its assessment teams.

AT EDF ENERGY

I note the scale of work carried out to better control the carbon deposition phenomenon, which has far-reaching implications for operations and for the lifespan of an AGR.

View of carbon deposition on AGR fuel

AT CONSTELLATION ENERGY NUCLEAR GROUP

I note that in the PWRs belonging to the Constellation Energy Nuclear Group, performance has long been good in this field. In the USA, the nuclear operators have

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developed a set of chemical performance indicators that has proved its worth and is in routine use by the managers. Comparison with other PWRs in the USA shows Constellation Energy Nuclear Group’s performance to lie within the first and second quartiles. The results are substantially worse for boiling water reactors, where chemical cleaning operations have in the past been postponed for short-term financial reasons. I would also like to draw attention to the highly-negative effect of this

postponement on radiation protection (see Chapter 5). I would like to hail the commitment of the current Constellation Energy Nuclear Group management team which, when the plant was bought out, were confronted with this situation and invested heavily in major cleaning operations which are now giving encouraging results. I can see how greatly this commitment has been appreciated and has encouraged the staff.

MY RECOMMENDATIONS

In France, more than two years after release of the Letalon Report containing analysis and proposals, I observe the road to achieving the goals set and best international standards is still a long one. The scant regard by the managers of the plants for the conclusions of the report and the relatively weak corporate-level support, although it was soon as revolutionary when it was published, explain this situation.

The commitment of the nuclear power plant managers remains too uneven and in some instances insufficient: chemistry is all too often at the back of the queue. The counterbalance to the pressure to keep the durations of outages as short as possible is often indecisive, frequently because the culture or awareness of the importance of chemistry among plant decision-makers (directors, operating shift managers, safety engineers and outage supervisors) is still insufficient. Yet, many aspects of nuclear safety and radiation protection depend on it. I encourage the continuation and the broadening of training intended for these key players.

I also consider that CEIDRE expert appraisal and promotion campaigns of operational experience feedback warrant more recognition. CEIDRE is a fleet-level department that has close links with operations but which, because it reports to the Nuclear Engineering Division, often has difficulty in making itself heard. Relations with UNIE accordingly need to be strengthened.

At a time when we are making a massive investment in the replacement of major components, such as the steam generators in France and AGR-type reactor life extension in the UK, higher priority needs to be given, on a permanent basis, to maintaining desirable chemistry in the equipment. Also, as I mention in Chapter 11, I would like to emphasise the need for continuing to invest in research and development work focused on the behaviour of the equipment.

I encourage the development in France of exchanges of international practices and the use of common indicators for chemistry-related performance to keep us in the front running in this high-technology field. This will enable those in charge to make the right decisions, for the long and short term.

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10/ A NEW IMPETUS FOR THE EPR-TYPE REACTORS

The Flamanville site pump station

After a difficult 2011 for the EPR construction site at Flamanville, a new start-up schedule was issued and the project reorganised. In 2012, weld defects were discovered in the main crane support plates, putting the schedule back by at least six months. The countdown to start-up has begun, the worksite has found its enthusiasm again, and the Nuclear Design & Construction Centre (French acronym CNEN) design work is running at full pace. Progress is continuing with the EPRs under construction in other countries.

RE-ORGANISATION OF THE CNEN

Using experience feedback on the difficulties experienced in 2011, the Flamanville 3 project management and organisation were changed. The project is now clearly assigned to the CNEN. The head of the CNEN is responsible for allocating resources, finding common ground on the main issues, relations with the French nuclear safety authority (French acronym ASN) and with the main suppliers, with the head of the Production and Engineering Directorate or his representative acting as the sponsor of the project. I am pleased to see the new clear and simplified organisational structure which has been set up and in which the respective roles are plain to see, and the missions and responsibilities can be readily understood.

To rise to the challenge of starting up Flamanville 3 in 2016 and managing the other EPR projects, in particularly the

Hinkley Point project, the CNEN has totally re-arranged its internal organisation and functioning. In particular, I note: • the creation of a nuclear safety, radiation protection

and environmental issues department guaranteeing the implementation of rule sets in projects and supervising the drafting of the regulatory case files and managing the associated issues, This department is in charge of independently checking answers submitted to the nuclear safety authority. I consider that it now also needs to set itself up as an independent organisation for other departments of the division,

• the re-organisation of the design departments and the creation of technical supervisory units in the project teams, in close liaison with the planning and contracting staff in each project.

• working as a project platform bringing together the different players (worksite management, technical supervision and planning, thus avoiding the inefficiencies that dilute responsibility.

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Under the new organisational arrangements, the CNEN’s EPR project team is responsible for the quality, cost and deadline goals, as well as handling the Level 1 and 2 scheduling for all the activities. During my visit, the priorities of the project team were focused on drawing up a new schedule after the crane bracket welding incident and the organisational structure to set in place, between with the different players including SOFINEL, a joint EDF and AREVA design office, to integrate without delay the numerous modifications required before hot testing and fuel loading. I observe that working in platform mode now makes it possible to fully devote efforts to the real issues. Accordingly, consideration is now being given to producing the testing documents, organising the on-site testing commissions and drafting the regulatory documents required under the Nuclear Safety and Transparency Act for preparing for start-up. I emphasise the need for the future operator to be involved in the forethought and planning at the earliest possible stage.I approve training the teams in project management and using current industry-standard scheduling tools. The size, however, of the project planning teams does not yet seem to be sufficient to make up for time lost since the start of the EPR project.

QUALIFICATION AND FABRICATION

The architecture of the instrumentation and control system of the EPR is now licensed. For more than a year, the Nuclear Engineering Division teams have been actively working on answering the ASN’s questions to reach this goal. Even though there may be changes needed in the software versions to be used, they are confident that this can be done. Justifications about the performance of some of the control units (response times, number of data inputs handled etc.) will probably necessitate further alterations during the start-up tests.I continue to be worried about the process for qualifying the equipment for accident conditions for which the responsibility was transferred to the suppliers in 2005. This transfer, all too often made with little support for the suppliers, has sometimes resulted in their failing to understand what justifications are required and what tests need to be carried out. At the present time, many things are late and the overall process visibility is low. It is to be borne in mind that equipment qualification must be obtained before starting the reactor.On-site erection is often the last line of defence in ensuring the conformity and quality of the equipment provided. The support bracket incident is a very revealing example of this. I hail the responsiveness and responsibility exhibited by EDF concerning this case in

deciding, as soon as the first defects where discovered, to test all the brackets liable to be involved, which led to their being scrapped. The project team has begun checking some fifteen other items of equipment with welds of similar types. This case of sub-standard quality is now behind us and the defects resolved. Qualification and the monitoring of fabrication, however, remain areas where the Flamanville 3 project team is running substantial risks.I note that the issue is finally being taken seriously by the Nuclear Engineering Division, with arrangements to provide suppliers with support, an in-depth reappraisal of the doctrine concerning surveillance of fabrication and strict instructions for their staff in charge of surveillance.

The reactor building crane bracket incident

The reactor building polar crane beams are supported by 45 brackets secured to mountings in groups of three.The combined weight of three brackets and a mounting is around twenty tonnes.The brackets are welded-up from plates and machined using a semi-automatic process, before undergoing a final heat treatment. The surface and the depth of the welds are checked as part of the fabrication process before painting. The testing revealed the presence of unacceptable defects in some of the welds. This resulted in rejecting all the consoles and starting a new fabrication cycle.On 23 November, low wind enabled the installation of the first mounting, using a 600-tonne crane. The fifteen mountings were set in place as they were delivered to the worksite. The last mounting was fitted on 21 December 2012.

Three reactor building crane support brackets


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THE FLAMANVILLE 3 EPR CONSTRUCTION SITE

“We’ll meet the 2016 deadline” was what I kept hearing this year on the worksite among the site management organisation staff. The year was marked by the support bracket incident, but the work continued. By the end of 2012, 93% of the civil engineering and 37% of the mechanical and electrical equipment work was complete, not to mention that the pumping station intake channel, which is shared with Flamanville 1 and 2, was also flooded.Last year, I pointed out the difficulties that the site management organisation was facing, having a difficult worksite and a heavy and complex organisational structure. This year, I visited a changed worksite and was very pleased to see the general condition and the way the work was being managed. The re-organisations of the CNEN is one of the reasons, but not the only one. I would like to emphasise the commitment of the head of the site management organisation and all the staff concerning nuclear safety and worksite tidiness. After numerous accidents in 2011, two of which were fatal, EDF SA took action involving all the contractor companies at the worksite and their employees. The results are clear to see in the installations and show in the accident frequency factors which, for the first time, have fallen below the threshold of 15. I encourage all those working at the site, whether EDF or contractor staff, to keep up the effort and maintain the trend. It should be borne in mind that good behavioural patterns in terms of industrial safety are generally also good in terms of quality, foundations for good nuclear safety.

This year I commend the orderliness of the facilities which I associate with a commitment to industrial safety and ascribe to the appointment of building supervisors and coordinators, which I have called for in the past, and whose presence is now paying dividends. They are unanimously acclaimed and appreciated.In this context, I would, however, like to draw attention to two risks that appear to be growing. The first is fire, while the second is associated with the extensive radiography work necessary during erection. For these two risks, the site management organisation has planned countermeasures, with the recruitment of a professional fireman and the appointment of two individuals with special skills in radiation protection. I insist that these resources be reinforced, where necessary.An innovative and pragmatic approach to analysis of the protection of equipment in storage at a coastal site for a number of years was shown to me. It is necessary to make sure that the findings are put to good use at future worksites. Despite the intentions announced last

year and the action taken, the planning and scheduling of the project activities from the CNEN, for both site and design work, remains a weakness in managing start-up. Everywhere on the worksite, among Nuclear Engineering Division and Nuclear Operations Division staff alike, there are complaints about the lack of visibility in their activities beyond a horizon of six to twelve months. The main Level 1 milestones have been laid down but the finalisation of the Level 2 (covering more than 10, 000 tasks) and of the Level 3 plans are not yet rationalised.Faced with the workload corresponding to the delay, it would appear that resources engaged by the project team are still insufficient and the confidence that the planning process effort will be sufficient is fading. I have heard questions being raised about the confidence that can be placed in the critical path, in the absence of a sufficiently clear and detailed description of the sequence of events. I am surprised to see that the same tool is not being used by everyone, necessitating copying with the attendant waste of time and risk of mistakes. Concerning this point in particular, action is needed without delay.

Industrial safety, a daily challenge at Flamanville 3

The EPR construction site in figures

• 3,000 people are working at the site, 60% of whom are locals

• 20 million hours already worked• Every night, 30 radiographs of welds are taken• 400 km of pipes and 1,500 km of cables

THE FUTURE OPERATOR OF THE EPR

The future operator, present at the plant from the outset, has not been directly involved in running the worksite, and has had to adapt to the scheduled commissioning date being put back again, now until 2016.Even though the operations staff have gone through a period of discouragement after the announcement of delays in the site work that have meant that they would have to postpone performing their proper work, I note that


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they have now put this behind them. The professionalism of the staff has continued to grow, and secondments to other plants as well as to the worksite or the engineering force have successfully taken place.I approve the choice given to each staff member, in a meeting with their superiors, to determine their own career path and to decide whether to stay at the worksite or work elsewhere, in the power plants. In my opinion, this has greatly contributed to overcoming the disheartenment at the beginning of the year and has completely cleared the air. In addition, it has made it possible to establish a solid system of forward planning of employment up to the time of commissioning. However, the four-year extension of the site work does not help with the operators taking ownership of the facilities, or with the site management organisation, which over time has become too bureaucratic and administrative. I deeply regret that the operating staff are still stationed on the cliff top away from the worksite and the installations, and cannot easily go onto site to follow the erection work and familiarise themselves with their future installations. The explanations that I was given by the staff of the two organisations do not seem to be very convincing.

Concerning this point, I consider that the probable delay of one year in moving all the staff to the future operations building alongside the nuclear unit installations does not encourage the operators to feel that the build-up to commissioning is under way. Even though the operations teams have been re-organised to optimise the transfers of equipment, few systems have actually been transferred and I am left wondering about the ability of the transfer process to cope with the future workload, with the time available rapidly diminishing.

This year, during my visits to simulator facilities at the CNEN, the Operations Engineering Training Unit and the Research and Development Division, I noted the substantial amount of work devoted to determining the composition and organisation of the EPR control room operations teams. In designing the man-machine interface of the EPR control room, the concept was to run the unit by just one active operator and one supervisor. The first tests took place in 2009, but as a result of the degree of progress with the design work, certain scenarios were not yet playable by the operations staff. Meanwhile, other EPR operators (TVO and TNPJVC) have opted for a more conventional system with two active operators and one supervisor. After a number of tests this year, EDF should be in a position to choose the form of organisation and submit it to the nuclear safety authority. In view of the consequences of this choice for the future operator, this matter appears to be a particularly urgent one.

MY VISIT TO TVO AT THE OLKILUOTO SITE

TVO is a Finnish public limited company operating two boiling water reactors commissioned in 1978, of which the power ratings have been upgraded to 860 MWe. The company has some 850 staff, with 500 handling operations. For many years, TVO’s operating results have been among the best worldwide. Despite its size, it possesses wide experience. Its maintenance policy is based on the swap-out of complete equipment items, hence enabling outages to be kept short and has proved its worth.The construction, erection and commissioning of a new EPR nuclear unit (OL 3) is taking place as a turnkey operation by the vendor AREVA. With less than two years to go before commissioning, the company is only now beginning its recruitment of the future operating staff. The approach, which is very different to our own, explains the low-volume of exchanges between EDF and TVO staff about EPR matters: their staff have not been available. Today, I note with satisfaction that exchanges of views and sharing of experience are beginning and the operators are also cooperating. This year, TVO has joined the EPR Family and is actively participating in the various working groups.AREVA alone bears responsibility for the construction site. All the project teams and the decision-making bodies are stationed on-site, and the AREVA France teams only act to provide support on a case-by-case basis. I am glad to see that the exchanges between AREVA’s OL3 worksite staff and the staff of the Flamanville 3 site management organisation and the EDF CNEN are well-established, frank and apparently useful. It is to be remembered that OL3, the first EPR in the family, is specially instrumented to supply a set of readings specified at the design stage for the other reactors of the same type.

The EPR construction site at Olkiluoto

THE EPR PROJECT IN THE UK

The relations between the EDF Energy Nuclear New Build (NNB) staff and that of the Nuclear Engineering Division in France seemed to have been strained last year but have now greatly improved. The successive stages


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of certification of the EPR in the UK and the building licence application process are being worked out and the responsibilities of the owner-operator (NNB) and the designer (the Nuclear Engineering Division and the CNEN) are now clearly established. The site licence for Hinkley Point C was obtained from the Office of Nuclear Regulation in December 2012.The Hinkley Point C project team has set up a Project Execution Plan laying down the principles of the project,

its general organisation and the roles and responsibilities of all involved. The Project Execution Plant re-affirms the responsibilities of NNB as the operating organisation and licence holder.I note the creation of a project technical steering committee designated MODEM (Monitoring and DEcision Meeting) which has made it possible to settle almost all the technical issues identified last year.

The Flamanville 3 social and economic back-up programme: a good practice

Since the worksite opened in 2005, EDF has been running a social and economic backup programme that has won acclaim in France and beyond.The mainspring of success for this type of back-up project is access by local companies to contracting work, with the benefit for the surrounding area that results from it. Local employment is a powerful argument and EDF has set in place appropriate professional training in support of it. Today, as the erection phase begins, some 360 workers have been trained to work in the metallurgy and inspection professions. At the end of 2012, 87% of them were hired and 75% still had their jobs after one year. Facilitating the accommodation of incoming workers makes them feel comfortable and improves their quality of life. The contractors’ association at the worksite is taking care of this. Utilisation of purpose-built living quarters, furnished rooms and local subsidised housing, plus some 1,200 private lodgings and bed-and-breakfast type accommodation provide

a wide range of solutions to meet the needs of everyone. The Flamanville 3 contractors’ association has been a success. What has been learnt from this initiative needs to be put to good use for the ten-yearly outages of the plants and the General Refurbishment.

The old Flamanville iron mine buildings converted.

CHINA AND THE EPR REACTORS AT TAISHAN

In a context of competition between Generation III projects under construction in China, TNPJVC the owner of the Taishan site, is getting ready to become the operator of the first EPRs to go on line. I would like to draw attention to the potential difficulties in supplying the design work. The Taishan schedule, which is now ahead of Flamanville 3, has given rise to a risk of loss of coherence between the reference nuclear unit and its daughter one. I wish to signal the need to reinforce the EDF back-office support team accordingly, as the staff are already very busy.


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MY RECOMMENDATIONS

I consider the proactive treatment of the reactor building crane bracket incident to be exemplary. This incident could have involved us in lasting difficulties with the nuclear safety authority and the general public. EDF has behaved responsibly and handled the matter as an operator conscious of the requirements of nuclear safety. Some lines of defence failed to function properly, but others held. Although rationalisation is always necessary, I am sounding the alert about the danger of having only one line of defence.

The need for detailed, reliable planning and scheduling is universally accepted. But it is difficult for teams to establish it and determine the critical path with sufficient accuracy. The EDF organisation certainly underestimated, from the beginning, what planning resources and skills would be necessary. In setting up such projects, I consider that we pay insufficient attention to the support aspects compared with the technical ones. Making up for lost time consumes even more resources. Concerning this point in particular, it seems that action is needed without delay.

The spectacular turnaround in the Flamanville industrial safety results once again shows the importance of encouraging the managers in the field to focus on safety. This, however, can only be successful if it has the support of those in charge of the main contractor companies. Here, I hail the decisive, unifying role that the F10 plays in this domain, as in others.

From what I observe outside France in other EPR projects, I clearly see the complications that arise in France from having this project managed by two separate divisions; one in charge of design and construction, while the other is in charge of future operations. This has made it difficult to optimise the company’s resources during the construction phase, which involved substantial delays. This year, once again, I emphasise the need to reinforce cooperation between the two divisions.

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11/ PLANT LIFE EXTENSION IS CONDITIONED BY NUCLEAR SAFETY

Replacement of steam generators

In the EDF Group, plant life extension has been authorised in the USA, is progressing towards authorisation in the UK and is being examined in France. The aging of equipment necessitates heavy maintenance work to guarantee nuclear safety. The integration of experience feedback, new nuclear safety objectives, new safety margin assessments and the handover to a new generation of engineers are all factors on which successful plant life extension depends.

AT GROUP LEVEL

For economic reasons and in view of the durability of the non-replaceable components, plant life extension beyond the limits originally planned is now being actively sought in France, the UK and the USA. Throughout the world, many reactors have already been licensed to operate beyond 40 years. This objective involves inspections, refurbishment work and standard replacement of equipment, which may be substantial, as well as major programmes of design or research and

development. In addition, it may be necessary to replace certain items of equipment after decades of operation.The operational history and the successive modifications made to plants and to procedures make it particularly complex to keep updated the safety case for each specific reactor. Furthermore, many procedures are interdependent or interlocking (design safety case, design, construction, spare parts, maintenance, operations, training and engineering) and the modifications incorporated may affect all of these issues.

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I note that the concept of “safety margins” is generally used inside the EDF Group, but with specific methods and a field of application that differs in the UK, the USA and France. These margins need to be reassessed with care in plant life extension studies.

IN FRANCE

EDF has clearly announced that continuing service beyond 40 years is conditioned by a level of nuclear safety that has been precisely defined together with the means of attaining it for all reactors aiming for sixty years of service. This approach is followed “with due regard for the objectives set for the new reactors and the best international practices”, as required by the nuclear safety authority. Operational experience, international experience feedback including that on Fukushima, new data and knowledge about risks and dangers (e.g. seismic and tectonic) are to be taken into account “insofar as this data is actually beneficial to nuclear safety and that their technical and industrial feasibility under acceptable economic conditions can be established, considering reactors in commercial service”.1It is to be borne in mind that, in France, each VD includes a nuclear safety reassessment and a programme of work and modifications approved by the nuclear safety authority. This principle is applied before dividing the work into industrial-scale packages, with a lead plant for each type of reactor. Operating by work packages ensures technical, functional and documentary coherence, which is essential for nuclear safety. The Fukushima accident precipitated the early deployment of some of these modifications in response to ASN technical requirements, at the expense of the initial ten-yearly programme which had already been divided into work packages.I would like to draw attention to the considerable workload resulting for the engineering centre staff, and the increased vigilance required as a result of rearrangements, which is becoming increasingly common in the wake of the technical requirements arising after ten-yearly outages.I have observed that, in this period of unprecedented renewal of the engineering staff, it is difficult to find experienced personnel capable of drafting the high-quality modification case files needed, while the high standards and the short deadlines greatly complicate the task. It will take a number of years to reverse the trend and I note that all too many modification case files prepared by the engineering centres are not complete or as well-structured as they were in the past, when received in the plants. Also in the plants, the staff in charge of implementing the

1 Letter dated 24 January 2011 from the EDF Chairman to the Minister of Industry and Energy.

modifications are generally less experienced, as the older workers retire. This “supplementary line of defence” therefore risks becoming progressively weaker. I would like to emphasise the important role of the EDF Research and Development Division in plant life extension: studies on the long-term behaviour of the reactor vessels and containments, as well as changes made to the computer codes.

The stages of plant life extension in France

• In 2009, EDF informed the nuclear safety authority of its intention to keep the option of operation for 60 years open for all its plants in service in France. The nuclear safety re-assessments already performed in the French plants reflect international experience feedback and have reduced the probability of occurrence of core meltdown while limiting the consequences.

• In 2012, EDF stated its goal of further increasing the level of nuclear safety to continue operation beyond 40 years, carrying out the process in the light of the nuclear safety objectives for new reactors. EDF plans to implement this nuclear safety initiative from the fourth ten-yearly outages (VD4) of the 900 MWe series units as of 2019 and of the 1,300 MWe series units as of 2025. Some modifications will be incorporated in advance during the third ten-yearly outages (VD3) of the 1,300 MWe series units from 2015 as part of the post-Fukushima actions in all the plants.

• The options for plant life extension were the subject of a meeting by the Standing Committee for Reactors on 18 and 19 January 2012. Examination of the options for the VD4 for the 900 MWe series units will take place at another meeting scheduled for late 2013 or early 2014.

IN THE UNITED KINGDOM

Sizewell B, a recent PWR, has had the advantage of sharing information with the worldwide community of PWR operators and the corresponding feedback, for example in the field of steam generators, pressurisers, the primary coolant system welds, and fuel performance.In comparison, the AGRs which are only found in the UK, have given rise to problems which often require unique solutions. Aging of the graphite cores is studied and monitored by a team of some 200 experts who include EDF Energy specialists and staff working under contracts.


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A vast graphite R&D and inspection programme is in progress. I was shown a number of computer models and

saw a number of mock-ups of the cores and the control rod channels , some of which were full scale.

AGR GRAPHITE

Nuclear safety requirements

The AGR graphite cores are designed to fulfil a range of safety functions. The key requirements are moderation of fast neutrons, maintain channel shape for control rod and fuel movement, direct gas flow to maintain fuel and graphite temperatures.

Aging and deterioration of graphite

There are two principal mechanisms affecting the AGR Cores:

• graphite weight loss due to oxidation of the graphite,

• graphite shrinkage leading to brick cracking affecting core geometry and distortion.

Both of these factors compromise the ability of the core to fulfil its key safety functions and therefore there is a

limit to the allowable degradation of weight loss and brick cracking.Since graphite components cannot be repaired or replaced they limit the lifetime of the core. The cracking will go through two phases – gradual cracking in early life, and rapid cracking in late-life to reach the tolerable limit. Weight loss is simply progressive throughout life.

Weight Loss

Tolerable limit

Progressive weight loss

Time

Brick cracking

Tolerable limit

Early-life bore cracking

Late-life keyway root cracking

Time

Current position and forword strategy

The overall strategy to support the safe lifetime for the graphite core:

• Understand the levels of graphite degradation that can be tolerated for brick cracking and graphite weight loss

• Predict, with confidence, the rate of graphite degradation in brick cracking and weight loss

• Carry out a suitable inspection programme to determine with the right confidence the condition of the cores

Graphite core under construction

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Hinkley Point B Nuclear Power Station

In addition, there is a lifetime programme for each AGR which covers operation until its withdrawal from service with a precision of ±2 years. A programme of work and maintenance is in place for each of the twenty main systems to make sure they reach their target service lives. If necessary, research and development work is carried out to obtain the knowledge required to make any decision with nuclear safety implications.At EDF Energy, the Design Authority department maintains visible safety cases to guarantee that the overall nuclear safety case for each reactor is always clearly established so it can be used and understood by a wider group than a small number of highly-experienced professionals, many of whom are due to retire.

IN THE UNITED STATES

My visit to Nine Mile Point Nuclear Power Plant, Constellation Energy Nuclear Group and Nuclear Energy Institute (NEI) this year was not focused on plant life extension, since I covered this issue in 2011 when I visited Ginna Nuclear Power Plant, the oldest Constellation Energy Nuclear Group power plant. Calvert Cliffs, Ginna and Nine Mile Point Nuclear Power Plants have been successively licensed to operate for up to 60 years. However, there are a few points that I believe require special care.First of all, in the USA, the spent fuel storage pools of some plants are now full, including those of Constellation Energy Nuclear Group. This is because the government authorities put off the decision to create a federal spent fuel repository. For the Nuclear Regulatory Commission (NRC) and the operating organisations, I understand that they see this as a business risk that does not affect nuclear safety. Concerning this point, I note that the regulatory nuclear safety requirements differ in the USA and Europe. As I see it, if the operators of a nuclear power plant cannot unload the core because the spent fuel storage pool is full, then that is incompatible with good nuclear safety practices or judicious planning for emergency situations. I have taken good note of

the fact that Constellation Energy Nuclear Group has provided additional storage capacity at Calvert Cliffs and Ginna Nuclear Power Plants, and that this is nearly ready at Nine Mile Point Nuclear Power Plant.Secondly, at Nine Mile Point Nuclear Power Plant, the plant engineering team seems to be particularly busy. The refurbishment required due to plant aging is taking place at the same time as numerous unscheduled activities in the wake of the Fukushima events. In addition, work is being carried out to increase the power rating. In view of the fact that there are limited numbers of skills available at the headquarters, I would like to sound the alert on a situation that may develop in time into a nuclear safety issue.I was also struck by the effectiveness of the methods used by the nuclear industry in conjunction with the NEI, which interacts with the NRC on generic issues. High-level working groups are entrusted with questions such as security and emergency planning. The working groups are assisted by numerous ad hoc committees that develop the necessary clarifications on certain issues, such as the behaviour of buried pipes. A committee called the Strategic Issues Committee deals with strategic questions and includes the Chief Nuclear Officers of all the different operators. If more than 80% of the Chief Nuclear Officers agree on an issue, an action plan for the entire sector is created and all agree to comply with it.Finally, I would like to emphasise the strong links between the American nuclear operators, including Constellation Energy Nuclear Group and the Electric Power Research Institute. As concerns the plant lifespan, I note the Long Term Operation Program which focuses on seven topics, such as reactor coolant system metallurgy, concrete structures and advanced computer codes for accident studies.


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MY RECOMMENDATIONS

For the UKThe publically announced objective of extending the service lives of the AGRs by an average of seven years is ambitious, clear and inspiring. Although there are corresponding associated financial incentives for most of the staff involved, the experts specialised in these programmes need to be given motivating criteria relating to nuclear safety objectives so that they clearly understand the essential nuclear safety phenomena and parameters, and also to guarantee that any plant lifespan proposed to the plant management includes appropriate and properly substantiated margins. Three departments are involved: 1) Design Authority charged with handling the overall nuclear safety cases, 2) the teams in charge of research into graphite and other vital components such as boilers, and 3) the Nuclear Safety Division which provides the internal independent nuclear safety analyses. Each plays its own highly-specific role in the field of nuclear safety. I consider that this arrangement needs protection and support to avoid any untoward pressure to prolong the service lives of the existing reactors beyond what is reasonable in terms of nuclear safety, particularly in the event of delay in building new power plants.I fully approve the integration of young professionals under supervision to prepare and keep up to date the visible safety case files and ensure traceability, under the close watch of experienced professionals to guarantee the transmission of knowledge before the latter retire.As indicated in 2011, successive long delays have occurred in incorporating certain modifications with nuclear safety implications. For each reactor to be able to benefit fully from the safety advantages conferred by a lifetime programme, I reiterate that it is indispensable for there to be proper project management.

For FranceOnce a new modification programme is established, it seems essential to seek functional coherence in new groups of work packages (“lots” in French) to guarantee their durability, in order to ensure the availability in due time of all the associated documentation, spare parts and training.

The post-Fukushima modification files, the case files for the forthcoming ten-yearly outages and future ones relating to plant life extension cannot be considered separately. The investment of considerable human and financial resources is required, with major practical industrial constraints.I consider that such a situation calls for dialogue at the highest level between the company and the nuclear safety authority to determine the priorities and to find common ground concerning strategy, as is practiced in the UK and the USA. This dialogue, which needs to include the IRSN, needs to establish agreement on a method and timetable that is as full and detailed as possible covering all the work planned. I would like to draw attention to the importance of such a programme being truly realistic in a context where resources are strictly limited, even for technical expert appraisal by the ASN. Even if the nuclear safety authority commits itself to plant life extension case-by-case, a plan covering all the interactions and preparatory stages, as well as mobilisation of the resources, the practical methodology and a proposed timetable is now necessary. I recommend rigorously determining the priorities in the interests of nuclear safety.

And more generally for the GroupAfter decades of operation, the nuclear units, even if identical or similar at the time of commissioning, have different service histories. Tracking the nuclear design and safety files; from the pre-construction phase until after decommissioning, spans the professional lives of a large number of players. Certain phenomena of reactor deterioration or wear due to aging are well known but contingencies may arise over time as a result of technical faults.I encourage the development of the following good practices:• guaranteeing that the nuclear safety case files

applicable to each reactor are kept up to date,• planning handovers very carefully and transferring

knowledge between experts,• conducting targeted research and development work,• planning and managing projects rigorously.

POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION

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12/ POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

A Nuclear Rapid Response Force exercise

The EDF Group is taking action at the highest level to make good use of experience feedback from the accident that occurred in March 2011 and is making any necessary modifications. A number of countries are debating the impact of national culture on nuclear safety action, highlighting the need for review by peers from a different culture.

THE SITUATION AT THE FUKUSHIMA SITE

For more than a year at the Fukushima site, all the cores and spent fuel have been sub-critical, cooled and stable. In the surrounding area, the local inhabitants have been authorised to return to some of the evacuated areas.

Access is still limited to some areas, and will continue to be so for some decades.A new independent nuclear safety authority has been in place since September 2012. Most of the nuclear reactors in Japan are still out of service. The political context remains complex, with the debate about energy strategy continuing.

The doses received in the vicinity of Fukushima

Here is some data on the doses received by the residents in three conurbations where the exposure was particularly high (14,000 inhabitants out of a total of 160,000 evacuees):

• 0.7% of those living nearby received doses of at least 10 mSv

• 42.3% of them received doses above 1 mSv but below 10 mSv

• 57% received doses of 1 mSv or less• 60 hospitalised people died as a result of

complications due to evacuation(Source: the official report of the independent inquiry commission on the Fukushima nuclear accident)Note: in Japan, the average radiation dose is 3.75 mSv per year, of which 1.48 comes from natural sources and 2.25 from medical exposure.

THE INSPECTOR GENERAL’S REPORT ON NUCLEAR SAFETY AND RADIATION PROTECTION POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

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NATIONAL CULTURE AND SAFETY CULTURE

The official report of the independent inquiry commission set up by the National Diet of Japan

In December 2011, the National Diet of Japan set up an independent commission which published a report six months later. Here are a few extracts of declarations made by Kiyoshi Kurokawa, the Chairman of the commission.“It was a profoundly manmade disaster – that could and should have been foreseen and prevented.”“For all the extensive detail it provides, what this report cannot fully convey – especially to a global audience – is the mind-set that supported the negligence behind this disaster”.“What must be admitted – very painfully – is that this was a disaster ‘Made in Japan’. Its fundamental causes are to be found in the ingrained conventions of Japanese culture: our reflexive obedience; our reluctance to question authority; our devotion to ‘sticking with the program’; our groupism; and our insularity. Had other Japanese been in the shoes of those who bear responsibility for this accident, the result may well have been the same”“This conceit was reinforced by the collective mindset of Japanese bureaucracy, by which the first duty of any individual bureaucrat is to defend the interests of his organization. Carried to an extreme, this led bureaucrats to put organizational interests ahead of their paramount duty to protect public safety. Only by grasping this mindset can one understand how Japan’s nuclear industry managed to avoid absorbing the critical lessons learned from Three Mile Island and Chernobyl; and how it became accepted practice to resist regulatory pressure and cover up small-scale accidents.”“The goal must be to learn from this disaster, and reflect deeply on its fundamental causes, in order to ensure that it is never repeated.”

The independent commission’s report highlights the considerable impact of the accident on the general population, particularly the extreme stress resulting from the uprooting of families and the overturning of their lives.It also expresses through its Chairman the role of the Japanese culture and he calls for his compatriots to think carefully about its impact. This uncommon suggestion deserves to be highlighted and is also applicable in other countries.

Indeed, in other regions of the world, incidents in nuclear power plants frequently reveal gaps between the actual situation and excellence, both in the fields of design and operations. International peer review teams often pinpoint such areas for improvement (AFI) and propose solutions which have proved their worth elsewhere, such as stricter application of the training requirements and procedures, or openness in reporting incidents to WANO. It is often, however, claimed by the hosts that national or local culture cannot assimilate such good practices, which are seen as problematic or even impossible to implement.I am inclined to think that arguments predicating “local culture” or “special local circumstances” are just excuses for not making continuous progress with nuclear safety, and that nuclear safety professionals must carefully guard against them. This is clearly seen in the case of Onagawa Nuclear Power Plant near Tokyo, where the nuclear operator has adopted the highest level of quality for the nuclear safety design options. The tsunami risk was identified in 1968 and the site elevation was set more than 14 metres above sea level: good nuclear safety culture ensured that the design safety margins were adequate.

IN FRANCE

Action by EDF SA

The company decided to upgrade nuclear safety to limit the risk of major radioactive discharges with regard to substantially worse contingency cases, situations combining station blackout with loss of the heat sink for a long period of time.This substantial upgrade of nuclear safety is based on physical arrangements and extra resources for emergency planning and response. The experience feedback from Fukushima indicates the need for:• reinforcing the protection against external hazards to

avoid possible cliff-edge effects,• having sufficiently robust and diversified electricity and

water supplies,• having a suitable organisational structure covering means

of transport, logistics, protection and communication,• having identified last-resort resources for the case

where a situation deteriorates,• having an emergency management centre that is

sufficiently well protected.To meet these goals, EDF has committed itself to four major action plans.Firstly, an analysis of whether the operating teams are sufficient in numbers to apply the post-accident


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operating procedures in the event of a severe accident, particularly one involving more than one reactor. The recent conclusions suggest reinforcement of these teams, to provide for the additional equipment proposed in the wake of the stress tests and to be able to cope with accidents affecting more than one nuclear unit. This reinforcement is to be completed by 2020 at the latest.Secondly, the incorporation of major modifications, in a progressive roll-out forming part of the continuous improvement of nuclear safety and foreshadowing the plant life extension project requirements. In addition, stress tests have revealed shortfalls in conformity that also need to be resolved.Thirdly, the creation of a hard core of robust physical and organisational arrangements. This is to guarantee nuclear safety beyond the original design base, as a final line of defence against certain highly-improbable situations. The physical and organisational arrangements, which are limited in number, should prevent any sustained, massive radioactive discharges into the environment. The hard core also includes arrangements for emergency management, notably emergency management centres, means of communication, dosimetry and measurements in the environment.Fourthly, the Nuclear Rapid Response Force, a corporate-level EDF unit integrated into the EDF emergency management system. It will rapidly provide a plant in difficulty with backup consisting of equipment and personnel, taking over from the plant staff and fielding additional emergency response resources within 24 hours, with operations on-site beginning within 12 hours of being summoned. Since 1 January 2013, the Nuclear Rapid Response Force is ready to deploy a reconnaissance team and a flying column to any plant to take action in the case of an incident involving a single reactor. At the end of 2014, it should be able to cope with four reactors in difficulty at a single site, and by the end of 2015 with the six reactors at Gravelines site.Finally, on 13 September 2012, EDF submitted its assessment reports on the sites of lower priority than the nuclear power plants, i.e. the six decommissioning sites. As in the case of the plants in service, a standing committee will handle these stress tests in mid-2013.

Key dates

• May 2011: ASN requirement for a stress test and validation of the European stress test specification

• September 2011: EDF stress test reports• November 2011: Standing Committee review of

the stress tests• January 2012: National report on ASN nuclear

safety supplementary assessments• March 2012: on-site review by European safety

authority peers• April 2012: presentation of peer reviews to

ENSREG (European Nuclear Safety Regulators Group)

• June 2012: setting up of the steering committee on social, organisational and human factors organised by the ASN

• June 2012: stress tests - additional ASN requirements (more than 600 technical requirements)

• August 2012: extraordinary IAEA Convention on Nuclear Safety meeting

• September 2012: EDF stress test reports for the decommissioning sites

• December 2012: Standing Committee meeting on determining the hard core of the stress report requirements

The stages of incorporating modifications

• In the short term and until 2015, implementation of provisional means for covering long-term station blackout and loss of all heat sinks situations using local and mobile safety resources (pumps, generating sets etc.). Additional resources with one generating set per nuclear unit, wells drawing from the water table and connection points for water, air and electricity.

• Between 2015 and 2019, installation of the first hard-core items. Incorporation of final modifications of the installations, last-resort diesel generator, last-resort water make-up with dedicated supply. Construction of a hardened local emergency management centre.

• From 2019 to 2025, completion of the hard core items to cover the most extreme situations.


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Actions and standpoints of the nuclear safety authority

The French national report on the stress tests was submitted to the European Commission in early January 2012. It was widely distributed and there was a peer review by the European nuclear safety authorities organised by ENSREG before the end of March 2012. On that occasion, Tricastin Nuclear Power Plant was inspected by an international team. A report was produced by ENSREG in April 2012, which was submitted to the European Commission.On 26 June 2012, the French nuclear safety authority published its decisions in the form of technical requirements relating to the mitigation of natural risk, as well as risks relating to other industrial activities. In the context of its decisions, the ASN “considers that the safety level of the facilities is sufficient and thus no request for immediate action is required in any of them. Meanwhile, it considers that their continued operation requires increasing without delay their ability to resist external events beyond the existing nuclear safety margins.”It also reiterates that an accident can never be ruled out and that the operator bears prime responsibility for the nuclear safety of its facilities. The ASN therefore imposed a set of measures on the operators to address:• combinations of natural phenomena of exceptional

amplitude exceeding the levels considered at the time when the design was established,

• severe accident situations after prolonged station blackout or loss of cooling capability.

EDF SA’s contribution to WANO

In October 2011, at the WANO Biannual General Meeting held in Shenzhen, China, it was unanimously voted to increase the human and physical resources by increasing the secondment of competent persons by the members. Seventeen EDF SA engineers joined the staff at the Paris centre in 2012, and the number is due to increase to 32 in 2013, 40 in 2014 and 47 by the end of 2015. This is an opportunity for a certain number of engineers to be exposed to international practices. I note that EDF has done all it can to reinforce WANO at a time of massive renewal of skills. I am glad to see this commitment as I believe the nuclear industry needs such an organisation that is strong, recognised and coercive when necessary to achieve progress in the field of nuclear safety.This year, seven peer reviews were hosted in EDF SA plants.

IN THE UNITED KINGDOM

The main actions of EDF Energy

The stress tests were completed on schedule. In the UK, the beyond-design-basis risk considered most probable is a violent storm (rather than an earthquake and/or a tsunami). The damage by water can occur at any height and not only at ground level. Once the electrical systems are damaged, their repair and return to service may take a long time (such as in Fukushima), which is why the basic cooling system features pumps that are directly-driven by diesel engines.It is of fundamental importance to be able to control emergency measures from outside the plant, keeping most of the staff at a safe distance from the hazards on the site. In the case of Fukushima, the emergency measures were, and still are, hindered by the closeness of the emergency centre.The first eighteen months after the accident were devoted to analysis of the existing nuclear safety margins, assessment of the possibilities of improving the situation and establishing an integrated solution (modifications, new equipment, emergency procedures etc.).

Sizewell B Nuclear Power Plant

The execution phase to follow will be completed by mid-2014. This will include many hundreds of actions relating to:• the resilience of the installations (protection of the

buildings including access to the plants and the emergency centres, emergency installations, data management systems, satellite technology, interfaces for the reception of emergency equipment and supplies), as well as the construction of additional emergency centres in the plants where necessary; it will also cover the reinforcement of the plants from outside via mobile emergency management centres and reinforcement of the central emergency centre at Barnwood,

• the storage of emergency equipment at four strategic points (dewatering pumps, high-pressure pumps, off-road vehicles some of which would be for the transport of large special-equipment containers, mobile generating sets and accommodation units),

• modification of the way in which the emergency


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response is organised (new roles and new knowledge requirements),

• the following modifications at Sizewell B: introduction of auto-catalytic hydrogen recombiners inside the containment (April 2013), remote control of the filtered containment venting system (October 2014).

For the Hinkley Point C EPR project, proposals regarding the lessons learnt from the Fukushima event were submitted to the Office of Nuclear Regulation (ONR).

Key dates

• April 2011: immediate reports from the operators describing the state of the facilities with regard to the design basis

• May 2011: provisional report by the chief inspector of the ONR

• October 2011: final report by the Chief Inspector of the ONR

• October 2011: submission by the licensed nuclear operators of the final stress test reports

• April 2012: on-site review by European safety authority peers

• August 2012: extraordinary IAEA Convention on Nuclear Safety meeting

• October 2012: rapport by the Chief Inspector of the ONR on the state of progress with implementation

The actions and standpoints of the Office for Nuclear Regulation

In October 2012, the ONR Chief Inspector published a report on the implementation of lessons learnt by the British nuclear industry from the earthquake and tsunami in Japan. Here are some of his conclusions:• “all relevant stakeholders have shown an appropriate

level of commitment to address the Chief Inspector’s recommendations and the relevant findings of the Stress Test reports”,

• “there is clear evidence that adequate progress is being made, with improvements either in place or planned”,

• “However, more needs to be done and it is important that all involved sustain their efforts to ensure that all recommendations, considerations and findings are closed out, and that the intended safety benefits are realised”,

• “ONR will press for the industry to complete the more significant improvements arising from learning from the Fukushima event by the end of 2014.”

EDF Energy’s contribution to WANO

Since the decisions taken in Shenzhen, EDF Energy now has eight staff seconded to the WANO centre in Paris (four in 2011, thirteen in 2013). The purpose is to set the example by meeting the goal set for the number of seconded staff in 2015 by the end of 2013. The company has set in place a cycle of WANO reviews in its plants every three years, with intermediate follow-up every eighteen months.Every year, six to eight technical assistance missions are carried out, with forty to fifty employees participating in peer reviews and thirty to forty contributing to other assistance missions. A chief nuclear officer directed the WANO internal assessment of all the five WANO centres worldwide.

IN THE UNITED STATES

The main actions of the Constellation Energy Nuclear Group and the American nuclear industry

Through the NEI and INPO, the American nuclear industry rapidly organised itself to draw the first lessons from the accident. The presence of a number of boiling water reactors on its soil and the similarity of some of them to those at Fukushima have facilitated the analysis made. I observed that, by April 2011, a steering committee had been set up in response to the Fukushima event which included the industry players, EPRI, INPO and NEI, with the spheres of action entrusted to seven working groups. NEI remains the main coordinator of exchanges between the nuclear industry and NRC for generic issues.The industry and NRC have agreed on a set of actions to be taken without delay. These notably include diverse and flexible coping strategies (designated FLEX) designed to maximise the safety improvements within the shortest time possible. The electricity companies purchased mobile FLEX equipment (pumps, diesel generators etc.) before the end of March 2012, with on-site deployment and training to begin shortly afterwards. An NEI policy document describes the deployment and protection of the equipment, its utilisation as part of operational procedures associated with accidents and incidents, its maintenance, its testing and the associated training requirements.I would also like to highlight the decision to create regional centres - one in Tennessee and the other in Arizona - intended to store equipment vital for preserving nuclear safety should an extreme event occur. Created in mid-2012, they will supplement the mobile equipment at the sites and are to be operational before the end of 2014.


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Key dates

• April 2011: immediate reports from the operators describing the state of the facilities with regard to the design basis

• July 2011: publication of the NRC Near-Term Task Force’s report

• December 2011: determination by NRC of three categories of action to be taken: Level 1 “to be done immediately”, Level 2 “in the event of limits imposed by critical skills or resources” and Level 3 “when studies in greater depth are necessary to substantiate regulatory action”.

• March 2012: publication by NRC of directives for resilience strategies for coping with station blackout, hardening containment venting systems and instrumenting spent fuel storage pools. It requires additional information on the assessment of seismic risks and flooding, on-site verifications, and also specifies requirements concerning staffing levels for emergency situation planning, as well as the reinforcement of the means of communication.

A timetable has been defined for the regulatory requirements, which indicates the key dates of the different stages of the work. Apart from FLEX strategies, these stages cover station blackout, hardening containment venting systems, and spent fuel pool instrumentation and filters. The scheduling also covers organisational matters, including major accident management directives, measures relating to industrial safety in the event of accidents in numerous plants, as well as increasing the resistance to earthquakes and floods.In America, the industry is in the process of reassessing the seismic risks using models and data updated for the plants in the central and eastern areas of the USA. The goal is to determine the need for updating the nuclear safety rule set for the main systems, structures and components. I have taken good note of the fact that a decision is due concerning the necessary scope of probabilistic analysis of the seismic risks for the Constellation Energy Nuclear Group plants.

The modifications to be made at Nine Mile Point 1, a Mark-1 design reactor similar to Fukushima-Daichi 1

• A decision concerning the filtered venting systems for boiling water reactors is pending in February 2013.

• Installation of two wide-range measuring channels for the water level in the storage pools (2014)

• Providing uninterruptible power supplies for the site communication systems and those of the emergency centre (2014)

• Reinforcement of the reliability and operability of the containment venting system (Spring 2015)

• Provision of tappings and connection points on mobile equipment for the supply of air, water, fuel oil and electricity (Spring 2015)

• Construction of a storage area protected against external events for mobile emergency equipment (2015)

• Installation of barriers to mitigate the risk of the diesel generators being flooded in the event of extreme and protracted precipitation (Spring 2015)

IN CHINA

For the two EPR nuclear units under construction at Taishan, I note that a close link is being maintained with the Olkiluoto and Flamanville projects, which is extremely positive. This sharing of experience, which has covered the manner in which the project staff have responded to the post-Fukushima regulatory requirements, has contributed to the promotion of nuclear safety at design, construction and operations levels. I remain attentive to the tsunami risk in the geographical area in which the Taishan plant is located. During my inspections in 2013, I will be focusing on this aspect.


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Key dates

• March 2011: decision by the State Council to put the approval and licencing of new reactors on hold but continuation of power generating in the existing nuclear facilities and the construction of the 25 nuclear units already under way

• October 2012: announcement that the construction of nuclear power facilities will be resumed, with a small number of Generation III projects over the next five years, probably at coastal sites

In conclusion, I think that rapid adoption of the stress test route in Western Europe has enabled operators and regulatory authorities to begin reassessing the design bases in terms of natural hazards and to conduct the corresponding nuclear safety studies more promptly there than in the USA. Nonetheless, after 9/11, the USA has probably progressed further and faster as concerns the availability of mobile response equipment for emergency situations.

Without knowing the details of the American regulatory arrangements, I remain convinced that the periodic reassessment of nuclear safety is definitely positive. This exists in France and the UK, with ten-yearly reassessment of the risks in the light of new data and knowledge.I note that “hard core” requirements (robust physical and organisational arrangements intended to guarantee nuclear safety beyond the design basis, an ultimate line of defence against highly-improbable situations) are as yet limited to France.

I would like to call to mind the letter sent in July 2012 by the Chairman of EDF to Li Ganjie, the president of the extraordinary meeting on the IAEA Convention on Nuclear Safety in August 2012. This letter forcefully states the standpoint of the EDF Group which is that “no severe accident will entail a consequence long-term contamination of large territories”. It also emphasises the importance of periodically reviewing the nuclear safety options. It seems highly desirable for all the reactors in the world to meet these two requirements.Finally, I hail the active manner in which the EDF Group managers in France, the UK and the USA have drawn lessons from the Fukushima accident and influenced world governance of the nuclear industry.

MY ANALYSIS AND RECOMMENDATIONS

For FranceI observe that the programme of physical and organisational modifications is particularly ambitious. EDF is clearly one of the operators to have taken action most promptly in the areas of physical and organisational arrangements to resist external hazards. I emphasise the importance of dealing with cases of non-conformity as top priority.The creation of the Nuclear Rapid Response Force (French acronym FARN) has increased the sustainability of response by being available to support the plant emergency teams and the ability to deal with an accident situation affecting a number of reactors at the same site. Its staffing and specialisation began at Civaux Nuclear Power Plant to prepare for deployment in early 2013 of an national reconnaissance team and a flying column ready to be sent to any nuclear power plant. I emphasise the need for training, maintaining skills and motivating the Nuclear Rapid Response Force staff.The project also calls for promptly creating a number of connection points for equipment in the plants in a coordinated manner. This is accompanied by modifications to the installations affecting systems that are important to nuclear safety. I would like to draw the

attention of the ASN and EDF to the very short time available for settling all these matters. The electrical resupply points can raise design questions that can be difficult, particularly in the field of instrumentation and control, as it is needed to guarantee that the existing situation is not negatively impacted. This is an important nuclear safety issue.As in 2011, I insist that the Nuclear Rapid Response Force which is part of the EDF accident response organisational structure, is the subject of due consideration with the government authorities: the Nuclear Risk Support Team (MARN), the defence zone prefectures and the National Committee of Public Safety and Defence. I note that an experiment is planned with the public authorities of South-East France.In view of these major changes that come in addition to the General Refurbishment work, I will be carefully watching how these modifications are made without overloading the skills in the plants and the engineering centres. I would like to once again hail the way all the players mobilised to deal with a task this great while respecting the time limits and quality requirements.I recall the need to establish a strategic plan with the ASN as soon as possible, including the ten-yearly nuclear safety upgrades that are now enshrined in French law.


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For the UKIn beyond-design-basis scenarios corresponding to extreme situations that combine the loss of all electrical power supplies and the loss of all heat sinks, the temperature rises more rapidly in a pressurised water reactor than in an advanced gas-cooled reactor, as the power density of the latter is forty times less. The consequence of this is that the deterioration steps during an accident and the measures to be taken are different in both reactor types. The time available can be measured in days for an AGR, while only in hours for a PWR. In both cases, I am pleased that the mitigating measures to be implemented take cognisance of the view of the emergency managers, the operating staff and the emergency response staff in the field.I also note that the players, operator and Office of Nuclear Regulation, have a process for continuously improving safety, which will make it possible to integrate all existing and future post-Fukushima experience feedback.

For the USANone of the plants in the USA were shut down in the wake of the Fukushima accident and the self-assessments and checks required under the regulations gave rise to corrective action.The organisation of relations between the safety authority and the industry is consolidated by the NEI as concerns generic matters. This division of roles has proved highly effective. Meetings are generally held in public; they are frequent and clearly focused, having made it possible to make progress in a country where respect for the judicial system is of primary importance.I have also observed the usefulness of a high-level strategic plan, established with the mutual agreement of the regulatory authorities and the industry and that is widely known and respected. This contributes to nuclear safety as the priorities are laid down with care, taking due allowance for nuclear safety and business constraints. The companies and plants can thus schedule these changes and modifications to ensure minimum impact on nuclear safety during the implementation phase.

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

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13/ NOTEWORTHY OPERATING EVENTS

Kori Nuclear Power Plant in South Korea

The events singled out this year have connections with the main operations professions. Of very different natures, they show the need for continuously consolidating safety culture and the human and organisational lines of defence.

A SERIES OF CASES OF SUB-STANDARD QUALITY DURING UNIT OUTAGES

The facts

The nuclear unit was in the hot shutdown mode (155 bar and 297°C) pending restarting after a planned inspection, scheduled three months earlier. The operations field team in the reactor building was re-filling with water and venting the Loop 2 cold leg bypass line. This operation followed on from operations carried out on the same day on the orifice plate of the loop (opening for visual inspection).After venting, when closing the valve (RCP 426VP) which connects to the nuclear island vent and drain system, the drain flow sight glass of the latter system broke. This resulted in a major reactor coolant leak of 7 m3 per hour. The three operations staff present left the area without being wounded or contaminated. The operations team, in accordance with the procedures, initiated transition of the nuclear unit to the safe cold shutdown state (27

bar and 90°C) and the leak was stopped after a few hours by closing the valve on the spot. There was no discharge into the environment. The analysis ordered by the corporate director of the plants and the director of the plant in question after the incident revealed that the handling of the event (nuclear safety, industrial safety, radiation protection and protection of the environment) had been managed in accordance with the emergency management instructions but that there were weaknesses and shortcomings that needed to be corrected.

The sequence of events

This event had serious consequences due to the loss of primary coolant inside the reactor building which lasted a number of hours and endangered the field staff. It resulted in a ten-day extension of the outage at considerable expense. It resulted from a string of cases of sub-standard quality and the crossing of lines of defence.In the sequence of events, I note that:• the planned replacement of 11 primary coolant

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

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temperature measuring probes during the outage was managed by the plant instrumentation and control department,

• the job was out-sourced to a prime contractor (this was a Case 1 Situation where the service provider had its own quality assurance system and working procedures). Replacement of the probes necessitates changing the adapters. When the adapter is seized, it needs to be drilled out to extract it. This was the case with ten of the eleven adapters.

• the prime contractor entrusted the work to a sub-contractor: the instrumentation and control department put the valves and metal fabrications department in charge of technical surveillance of the drilling.

• the procedure calls for drilling a 20 mm blind hole and vacuuming up the cuttings. If it proves impossible to unscrew the adapter after making a first hole, a 22 mm diameter through-hole can be made on the condition that the cuttings are vacuumed up and an endoscopic examination of the header is performed with a flexible probe that is at least one metre long,

• the sub-contractor took the initiative of making a through-hole straight away, using a 20 mm diameter drill, without following the procedure and without informing either the prime contractor or EDF. This was done with the eleven adapters in succession.

• the endoscopic examinations were carried out by the sub-contractor with an unsuitable endoscope (too short and rigid) which failed to detect the presence of cuttings in the header,

• the EDF inspector replicated the check by the sub-contractor, with the same result,

• two months after the job, when restarting the nuclear unit, an insufficient flow in the Loop 4 temperature bypass was detected. An inspection of the loop orifice plate was decided upon and scheduled for handling with the unit at shutdown state with the steam generators in service,

• two days later, inspection of Loop 4 indicated the presence of cuttings in the header. The raising of the primary system temperature and pressure continued without the two other loops being inspected (although similar drilling operations had been performed),

• a week later, it was decided to inspect the two other loops. The nuclear unit was in hot shutdown mode. After the inspection of Loop 2, the event occurred when the bypass line was put into service.

My analysis

I have picked this event as it illustrates some of the current maintenance difficulties with their actual and potential consequences. In the case of the probe replacement work, however, I do not see what are usually the causes of sub-standard quality: the need to change probes is not a new one, the maintenance instructions date back a number of years, the unit outage spanned a number of months and there was no urgency about the job, the main contractor was properly qualified (Level 1) by the Central Technical Support Department and had previously carried out this work, as had the sub-contractor.This being the case, I am struck by the succession of cases of sub-standard work of all types and the weakness in the lines of defence, which failed to perform their roles.I am left wondering about the deliberate and repeated disregard for a procedure important to nuclear safety. I consider that the sub-contractor demonstrated a real lack of nuclear safety culture, compounded by lack of staff training. The question must be raised as to the reliability of Case 1 qualification of a contractor as a line of defence when its checking and surveillance systems can let such discrepancies through.Nowhere in the reports about the event is there any mention of the risks for the ALARA approach, the importance of which I would like to underline for the operatives and inspectors.Neither was EDF surveillance of the work a sufficiently strong line of defence. This was done by each profession without considering the wider implications of the work. In multi-speciality services such as this, it is desirable to have a single inspector watching the contractor.Finally, after first discovering cuttings in the Loop 4 line, I am surprised that a week went by before inspecting the two other loops.In conclusion, it is to be borne in mind that this event had no consequences on the environment or on the operators and that incident was properly managed. What needs to be remembered is that we need to question the confidence we place in certain lines of defence which may not be as strong as we imagine. It is there to remind us, once again, that analysis of the risks and checking and inspection in the field are necessary for obtaining proper quality and dependable nuclear safety.


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A DIAGNOSIS ERROR DURING START-UP

The facts

The annual outage for maintenance and refuelling was coming to a close and start-up was beginning. The reactor pressure vessel was closed, the core was still sub-critical, the pressure in the reactor coolant system was 3 bar, the primary coolant pumps were stopped and venting of the reactor coolant system was in progress.At the end of the afternoon shift at around 20:00, the control room operators noticed a drop in the level of the chemical and volume control tank for the reactor coolant system, which they interpreted as being due to a primary coolant outflow and estimated it at 5 m3/h. Actually, the venting operations performed that afternoon had destabilised the pressure regulation action of the chemical and volume control valve of the reactor coolant system, a phenomenon of which the operators were unaware.They saw neither a change in the levels of the reactor building sumps, nor in the charging and letdown flows. Unable to explain the chemical and volume control tank level change after analysis, it was considered that one of the nuclear steam supply system parameters was not under control, indicating the need to operate the reactor in accordance with an incident situation procedure using what is termed as a symptom-based approach. The operations team applied the procedure and alerted both the safety engineer and the duty Emergency Controller (known as PCD1 in France).Between 20:00 and 21:00, the control room shift changed. In accordance with the procedures, the operators manually started the low-pressure safety injection pumps to compensate for the loss of primary coolant. The automatic protection function isolated the containment, resulting in isolation of the main reactor coolant system makeup lines. As a result of the absence of an actual outflow from the nuclear steam supply system and the starting of the low-pressure safety injection, the pressure in the reactor coolant system rose to around 10 bar as injections at the reactor coolant pumps seals were maintained. The incoming operations shift manager then decided to stop injection at the reactor coolant pump seals so the decay heat removal system safety valves would not open.Meanwhile, the PCD1 decided to muster the plant emergency response team capable of dealing with such a case. In the control room, the outgoing team stayed to support the incoming team, and the two operating shift managers were present at the same time.At 21:10, application of the symptom-based approach resulted in opening the zero-flow valves of the low-pressure safety injection pumps to the safety injection

sumps inside the reactor building. Five minutes later, the operators in the control room observed that the level in the reactor coolant tank (PTR) was dropping and the levels in the reactor building sumps were correspondingly rising. This valve opening led to an outflow of some 120 m3 into the sumps.Around 21:40, the operations shift manager decided to send a team into the reactor building to identify the reason for the flow of coolant into the sumps, and it was soon determined that it was the safety injection systems sump levels that were affected.The PCD1, in the control room around 22:00, assessed the situation with the two operating shift managers present. He confirmed that the incoming operating shift manager was the one in charge of operations. The latter suggested closing the zero-flow lines valves of the low-pressure safety injection pumps. The strategy was adopted and the level in the reactor coolant system tank rapidly stabilised.At 22:30, the parameters had stabilised and the integrity of the reactor coolant system was confirmed. The low-pressure safety injection pumps were stopped.The operating team exited the incident. procedure in the middle of the night shift as the primary coolant balance had returned to conformity with the technical specifications for operation.

My analysis

• An error of diagnosisThe decision to operate the reactor using incident and accident situation procedures resulted in an error of diagnosis by the operations teams, who mistakenly believed that there was a primary coolant leak. I would like to point out that the team, in difficult circumstances, re-established functioning in accordance with the technical specifications for operation, adapting the incident situation procedures to the events as they occurred.

• Lack of mastery of physical phenomenaI observe that the physical phenomena involved in this event are rarely encountered in operations and the operating staff and their technical advisers found it hard to handle them although they were all experienced. It would also appear that too much confidence is being placed in leak balance calculations carried out under abnormal thermal-hydraulic conditions and there is insufficient awareness of the uncertainty of the calculations for such situations. Also, the procedure contained no warnings about the risk of making too much of a somewhat unreliable result.


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• An operating shift manager taking initiativeI am pleased with the initiative taken by the operating shift manager, who was able to ask the right questions and to promptly suggest pertinent courses of action to the PCD1, even if this involved departing from procedures which were being followed.

• Weakened organisational lines of defenceI would like to draw attention to the need for proper functioning, under all circumstances, of the organisational lines of defence which are vital for defence in depth. The simultaneous presence of two shift teams with their managers in the control room, the presence of the executive management echelon in the control room, and not in the emergency centre provided for such contingencies and giving the players space for thought, as well as the role of the safety engineer, are all issues than need to be carefully considered in the context of unsettled situations.As I see it, mustering the emergency management staff in events of this type where they are not formally required nonetheless constitutes an excellent practice, with its effectiveness having been demonstrated on a number of occasions. Furthermore, even though the decisions made by those involved, in real time and under difficult conditions, finally proved to be the right ones, there is no reason not to perform an in-depth analysis of the human and organisational factors aspect of the event. I accordingly encourage the plants to establish, in advance, the respective roles of the key players in such circumstances: operating shift manager, PCD1 and safety engineer, using the analysis of actual events as a basis.

• Confidence of the operating staff in the incident and accident proceduresFinally, I have noticed that there are inaccuracies, and even omissions, in the symptom-based incident and accident situation procedures when the nuclear unit is in this plant state. Without questioning the benefits in terms of nuclear safety that these instructions afford, which have long been established and are recognised throughout the world, I would like to draw attention to the necessity to quickly correct procedures. Promptness is the price that must be paid to ensure that confidence in these important documents is preserved.

In conclusion, this event highlights the need to continuously improve our accident situation procedures, as regards the underlying physical phenomena and the proper functioning of our accident management organisational arrangements.Clear understanding of the roles of all the key players, decision-makers and advisers, using pooled experience

as a basis, merits close consideration at all levels of responsibility.Finally, I consider that although the symptom-based incident and accident situation procedures, which are by their very nature overarching, may suggest action that may appear to be radical or even disproportionate and costly (in terms of equipment and availability), they are nevertheless undoubtedly extremely beneficial in terms of nuclear safety, and those engaged in the field need to place their confidence in them. The nuclear operator must always be ready to pay the price.

TWO EVENTS IN SOUTH KOREA

Falsified spare part quality certificates

In 2012, the government of South Korea condemned the use of spare parts with falsified certificates of authenticity. This related to some 230 types of components (including relays, fuses and fans) and around a dozen suppliers in South Korea and internationally. Five of the twenty three South Korean nuclear power plants were affected and the national Nuclear Safety and Security Commission (NSSC) ordered the shutdown of two reactors (Yonggwang 5 and 6) to bring them up to standard. Although the NSSC considers the impact on nuclear safety to be under control, the shutdown is liable to have major consequences for the electrical power supply in the country in the months to come. Legal action has also been instigated by the government authorities.

Major shortcomings in nuclear safety culture at Kori 1

• The factsKori Nuclear Power Plant is one of the four nuclear power stations in South Korea, all of which are operated by the publicly-owned company KHNP and its subsidiary KEPCO. Twenty three nuclear units are in service and five others are under construction at two other sites. Most of them are pressurised water reactors.Kori 1 is a PWR with two loops and a power rating of 610 MWe. It entered commercial service in 1978 and was the first of a number of such nuclear power generating facilities in South Korea.On 9 February 2012, a scheduled outage was taking place for maintenance and refuelling. One of the two diesel generator sets (Group A) was out of service for scheduled maintenance.The fuel building pool was full of water and


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preparations were being made for fuel unloading. Cooling was provided by one of the two shutdown cooling system pumps designated Pump B. Pump A was undergoing maintenance.The electrical power supplies then available were the off-site 345 kV mains supply, the Train B step-down transformer and the site standby diesel generator, in accordance with the technical specifications for operation at this stage of fuel handling. The site standby diesel generator was available, but connected to Nuclear Unit 4.The Train B site auxiliary transformer (154 kV) and the Train A standby diesel generator set were out of service for scheduled maintenance too, while maintenance work was just finishing on the Train A site auxiliary transformer.Human error during execution of tests on the main turbine generator resulted in loss of the off-site power supplies. The Train B diesel generator could not be started, which resulted in loss of all the electrical power supplies to Nuclear Unit 1.The operators managed to re-establish an electrical power supply 12 minutes later from Train A, and 19 minutes later for the Train B pump cooling the shut-down reactor.Cooling during shutdown was accordingly lost for nineteen minutes and the maximum water temperature reading in the hot leg of the reactor coolant system went up from 36.9 to 58.3°C, while that of the storage pond went up from 21 to 21.5°C.There was no observed damage to the fuel as a result of the transient. The incident thus has no actual consequences in terms of nuclear safety, the environment or the plant staff. The potential consequences could have been very serious.

• Lack of transparencyIgnoring the applicable requirements, the management of Kori 1 (Nuclear Units 1 and 2) did not report the event to the NSSC, the South Korean nuclear safety authority, and also failed to call the alert for the event as provided in the plant’s emergency plan. The Kori 1 management did not report the event to the NSSC until 12 March 2012, more than a month later.The NSSC immediately ordered the reactor to be shut down, announced the event to the general public and sent in a special technical inspection team to make a full inquiry.Together with the government authorities, the company KHNP organised an expert appraisal mission by the IAEA, which was carried out in June 2012 using operational safety review team methodology, with the assistance of experts, most of whom were European.

• The main conclusions of the IAEAThe IAEA team announced that the NSSC had completed it provisional inquiry and was continuing its technical assessments and investigations. On the basis of this provisional inquiry, the NSSC demanded corrective action in the following areas:

• reinforcement of safety culture,• greater reliability of the standby diesel generator

sets,• checking of configurations and risk management

during the refuelling outage sequence,• testing and maintenance procedures,• declaration of alerts and emergency actions.The IAEA team confirmed that some of the corrective action had already taken place and some was in progress. The management and staff of Kori 1 were found to be keen and working hard to integrate all the improvements. Analysis of the root causes of the event is continuing and is to lead to further corrective action intended to improve safety culture, processes and design.The IAEA team made its own technical analysis of the event and also focused on the failure to report the event to the safety authority and on the violations of technical specification for operation, which were constituted by the absence of immediate measures to make the standby diesel generating set operable, as well as beginning the fuel unloading process the day after the incident though neither of the two standby diesel generating sets were yet serviceable.This analysis enabled the team to identify other causes that contributed to the event and determine supplementary corrective measures for Kori 1. Some examples of important contributing causes:

• “The safety culture at Kori 1 NPP was unable to counter neither the errors committed in the station blackout event, nor the subsequent leadership failures in communication and reporting. The Kori 1 NPP safety culture needs to support leadership in decision making and develop stronger defenses when facing unexpected or difficult situations,

• Human factor: the disregard of instruction associated with overconfidence of contractor’s worker during generator protection test,

• Kori 1 plant manager and other staff in the control room decided not to report SBO. The plant manager opted to hide this event due to heavy feelings of a burden to preempt public critics and a fear of worsening the plant’s credibility. In light of the prevailing high respect for authority of supervisor the staff involved were unwilling to disagree with plant manager, although several elements of safety


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policy and administrative procedures of the plant were violated,

• Rescheduling outage work (generator protection system test was started earlier than the original schedule, maintenance of station auxiliary transformer A was started although station auxiliary transformer B was not returned to operation). The approval and risk assessment for this unusual lineup was inadequate in that the potential consequences were not considered,

• Kori 1 NPP internal oversight failed to reveal the station blackout event.”

The expert mission gave their recommendations to address these contributory factors.

Proactive policy decisions

In the light of these serious shortcomings, I note that the South Korean authorities have announced that they have initiated far-reaching reforms and taken vigorous action to reinforce the powers and independence of the NSSC, the nuclear safety authority. I have also noted numerous changes in the operator’s management team, which need to be accompanied by changes in their practices, as the IAEA highlighted.In conclusion, barely one year after the Fukushima accident, I see from these events that the need for proper safety culture and transparency is not yet universally acknowledged. Nuclear safety in operations, which alone can win confidence in the nuclear industry, will always depend on two things: a responsible nuclear operator and a strong nuclear safety authority.

I consider that a nuclear safety event of this nature challenges the nuclear community, as concerns both the collective responsibility of each operating organisation with regard to its peers and the effectiveness of the international watchdogs.

Incident sequence (1)

7:30pm on Feb 9 : Tes ng of generator protec on relay started8:34pm : During the relay test, due to the failure of rese ng the test- nished relay,

345kV main power circuit breakers tripped open due to 2/3 logic signal resu in LOOP

8:34pm : EDG “B” failed to start on demand due to star ng solenoid valve failure resuin SBO, and subsequent loss of shutdown cooling and SFP cooling (RHR)

Kori 1: electrical power supply system diagram 1

Incident sequence (2)

8:46pm : 154kV Standby offsite power “A” recovered by closing and re -racking SAT “A”

circuit breaker exiting SBO condition in 12 minutes

8:53pm : Recovered shutdown cooling via RHR “B” by establishing a crosstie from Bus “A”

to Bus “B” because RHR “A” was under maintenance in 19 minutes

4

5

Kori 1: electrical power supply system diagram 2

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

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14/ APPENDICES

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

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14.1 - RESULT INDICATORS FOR THE EDF SA NUCLEAR POWER PLANTS

Indicator 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Number of events classified on INES as 1 or greater, per reactor1 1,20 0,88 0,76 1,22 0,80 1,15 1,17 1,17 0,91 1,55

Number of significant nuclear safety events, per reactor1 8,14 7,62 9,54 10,21 10,80 10,34 10,93 10,45 10,57 11,90

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

1,57 1,16 1,48 1,55 1,70 1,70 1,39 1,55 1,36 1,52

Number of alignment errors, per reactor2 0,93 0,50 0,66 0,69 0,57 0,62 0,53 0,77 0,71 0,70

Number of scrams, per reactor and per 7,000 hours of criticality3

• Automatic 1,13 1,01 0,93 0,89 0,87 0,51 0,71 0,69 0,50 0,55• Manual 0 0 0 0 0 0 0 0,01 0,05 0,03

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

0,89 0,79 0,78 0,69 0,63 0,66 0,69 0,62 0,71 0,67

Exposure of individuals:• Number of individuals with doses

above 20 mSv 1 0 0 0 0 0 2 0 0 0• Number of individuals with doses

between 16 and 20 mSv74 73 28 17 20 14 10 3 2 0

Number of significant radiation protection events

160 177 173 112 99 107 102 91 92 114

Availability (%) 82,7 82,8 83,4 83,6 80,2 79,2 78,0 78,5 80,7 79,7

Forced Loss Rate (%) 3,0 3,5 3,2 3,3 3,7 4,4 4,6 5,2 2,2 2,8

Accident Frequency Rate (Tf)4 7,5 5,5 5,5 5,6 4,6 4,4 4,3 4,1 3,9 3,5

1 Excluding generic events, i.e. events due to design defects.2 Any configuration of a system or its services that deviates from the expected situation and is the cause of a significant

event.3 The average value of all reactors which differs to the WANO value which takes into account the value of the median

reactor.4 Tf: frequency of occupational accidents with sick leave for 1 million hours worked.


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14.2 - RESULT INDICATORS FOR THE EDF ENERGY NUCLEAR POWER PLANTS

N° Indicateurs 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

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

5,27 5,53 5,67 3,13 1,13 1,13 0,80 0,87 1,26 0,80


10,80 9,60 9,13 7,53 4,93 4,53 5,47 5,70 4,6 4,6

3Number of events of highest level declared to the ONR, per reactor

5,47 3,60 2,67 1,53 0,40 0,67 0,33 0,67 0,46 0,20

4

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

- - 1,00 0,73 0,13 0,27 0,13 0,60 0,33 1,67

5Number of alignment errors, per reactor

- 0,40 1,00 0,60 0,13 0,27 0,13 0,60 0,33 3,07

6

Number of unscheduled reactor shutdowns, per reactor and for 7,000 hours of criticality• Automatic 1,51 1,30 0,74 0,73 0,44 1,13 0,82 0,58 0,74 0,64• Manual 1,39 2,18 1,28 2,54 1,48 1,04 1,44 1,68 1,22 0,84

7

Average collective dose in operations, per nuclear unit in service (in man-sieverts)• PWR 0,351 0,032 0,352 0,524 0,045 0,264 0,337 0,271 0,537 0,037• AGR 0,073 0,026 0,055 0,152 0,071 0,167 0,100 0,018 0,084 0,063

8

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 16 mSv 0 0 0 0 0 0 0 0 0 0

9Number of significant radiation protection events

192 184 368 249 58 38 31 43 43 50

10

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

78,286,177,6

69,989,468,5

71,983,771,0

66,185,364,7

62,898,460,2

51,289,248,5

71,087,469,8

65,745,667,1

72,082,571,3

78,089,276,3

11

Forced Loss Rate (%)• EDF Energy plants• PWR• AGR

11,72,412,4

15,59,715,9

12,30,013,1

17,00,318,2

20,30,421,7

20,42,121,8

13,20,914,0

19,654,317,1

13,03,413,7

8,910,08,7

12Accident Frequency Rate (for 200,000 hours worked)

- 0,51 0,37 0,22 0,27 0,35 0,11 0,007 0,12 0,10

13 Accident Frequency Rate (Tf)1 - 2,6 1,9 1,1 1,4 1,8 0,6 0,4 0,6 0,5

1 Tf : Frequency of occupational accidents with sick leave for 1 million hours worked.

Factors to be taken into account in comparing the results of EDF SA with those of EDF Energy: • Lines 3. 4, 5 and 9: 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 7: the reactors of the two sets of plants do not share the same technology (mostly AGRs in the UK and PWRs in France). The AGR design means that radiation exposure is some ten times lower (source: WANO).


82

14.3 - RESULT INDICATORS FOR THE CONSTELLATION ENERGY NUCLEAR GROUP NUCLEAR POWER PLANTS

N° Indicator 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012


0 0,6 0,2 0,8 0,4 0,6 0,2 0,8 0,6 0,8

2Number of significant nuclear safety events, per reactor1 15 8 12 9 12 13 9 11 11 10,8

3Number of NRC Notices of Violation

1 1 3 1 1 1 4 2 1 1

4Number of alignment errors, per reactor2 2,3 1,3 1,7 1 2 1 0,67 0,33 0,33 0,67

5

Number of unscheduled reactor shutdowns, per reactor and for 7,000 hours of criticality • Automatic 0,70 0,51 0,51 0,34 0,34 0 0,17 1,02 0,70 0,70• Manual 0,17 0,17 0,17 0,17 0,17 0,17 0,17 0 0 0,17

6

Average collective dose in operations, per nuclear unit in service (in man-sieverts)• PWR 1,14 0,49 0,81 0,80 0,46 0,61 0,46 0,44 0,68 0,68• BWR 1,85 2,24 2,01 1,15 1,65 1,51 1,19 1,88 1,22 2,27

7

Exposure of individuals:• Number of individuals with

doses above 20 mSv• Number of individuals with

doses above 16 mSv

0

8

5

12

0

6

0

2

1

3

0

4

0

0

0

4

0

1

0

9

8Number of significant radiation protection events

- - - - - 8 12 8 4 4

9Availability (%) :• CENG 89,5 93,9 94,2 93,1 93,9 95,4 95,2 94,2 91,4 87,3

10 Forced Loss Rate (%)• CENG 2,96 1,11 0,81 1,79 1,70 0,52 1,10 2,31 3,07 3,10

11 Accident Frequency Rate (Tf)3 - - - 0,30 1,47 1,18 1,02 0,57 0,75 0,78

1 Derived from events screened as “Significant” and “Noteworthy” by INPO Events Analysis Department.

2 INPO Component Miss-positionning events (Consequential).

3 Frequency of occupational accidents with sick leave for 1 million hours worked.

Factors to be taken into account in comparing the results of EDF SA with those of Constellation Nuclear Energy Group:• Lines 2, 3, 4 and 8: the event declaration procedures are not the same in the USA and France as a result of

the respective nuclear safety authority requirements.• Line 6: the reactors of the two sets of plants do not share the same technology (three PWRs and two BWRs

for Constellation Nuclear Energy Group and all PWRs in France). The design of the BWR results in higher exposure than in the PWR (source: WANO).

• Line 9: the four reactors at Calvert Cliffs and Nine Mile Point are refuelled every 24 months while that of Ginna Nuclear Power plant is refuelled every 18 months.


83

14.4 - MAP OF THE EDF SA NUCLEAR POWER PLANTS

Construction/Project

Operation

Decommissioning

300 MWe 900 MWe 1300 MWe 1450 MWe 1600 MWe

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


84

14.5 - 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

Edimbourg

AGR : Advanced Gas cooled ReactorEPR : European Pressurized Reactor


85

14.6 - MAP OF THE CONSTELLATION NUCLEAR ENERGY GROUP NUCLEAR POWER PLANTS

Nomber of reactorper type Engineering

PWR600 MWe

PWR900 MWe

BWR620 MWe

BWR1 300 MWe

Operational 1 2 1 1

Head Office (CENG) 1

GinnaNine Mile Point 1

Nine Mile Point 2

Washington DC

New-York

Atlanta

Calvert Cliffs

Baltimore

BWR : Boiling Water Reactor


86

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

Year com-missioned

Nuclear Unit

Powerin

MWe(*)VD1 VD2 VD3

Year commis-sioned

Nuclear Unit

Powerin

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 1984 Paluel 2 1330 1995 2005

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

1979 Bugey 5 880 1991 2001 2011 1985 Gravelines 6 910 1997 2007

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

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

1980 Gravelines 1 910 1990 2001 2011 1986 Cattenom 1 1300 1997 2006

1980 Gravelines 2 910 1991 2002 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 2 135 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 1987 Chinon B4 905 2000 2010

1981 Dampierre 4 890 1993 2004 1987 Nogent 1 1310 1998 2009

1981 Gravelines 4 910 1992 2003 1988 Belleville 2 1310 1999 2009

1981 St-Laurent B1 915 1995 2005 1988 Nogent 2 1310 1999 2010

1981 St-Laurent B2 915 1993 2003 1990 Cattenom 3 1300 2001 2011

1981 Tricastin 4 915 1992 2004 1990 Golfech 1 1310 2001 2012

1982 Blayais 2 910 1993 2003 1990 Penly 1 1330 2002 2011

1982 Chinon B1 905 1994 2003 1991 Cattenom 4 1300 2003 -

1983 Blayais 3 910 1994 2004 1992 Penly 2 1330 2004 -

1983 Blayais 4 910 1995 2005 1993 Golfech 2 1310 2004 -

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

1983 Cruas 1 915 1995 2005 1997 Chooz B2 1500 2009 -

1984 Cruas 2 915 1997 2007 1997 Civaux 1 1495 2011 -

1984 Cruas 3 915 1994 2004 1999 Civaux 2 1495 2012 -

VD1 : First ten-yearly outageVD2 : Second ten-yearly outageVD3 : Third ten-yearly outage (*) Net continuous power


87

14.8 - TECHNICAL KEY DATES FOR EACH OF THE EDF ENERGY NUCLEAR UNITS

YearCommissioned

Nuclear UnitReactor Number

Reference Unit Power (MW)

(1)

Planned date of withdrawal from

service(2)

1976 Hinkley Point B R3 435 2023

1976 Hinkley Point B R4 435 2023

1976 Hunterston B R3 460 2023

1976 Hunterston B R4 430 2023

1983 Dungeness B R21 520 2018

1983 Dungeness B R22 520 2018

1983 Heysham 1 R1 585 2019

1983 Heysham 1 R2 575 2019

1983 Hartlepool R1 595 2019

1983 Hartlepool R2 585 2019

1988 Heysham 2 R7 610 2023

1988 Heysham 2 R8 610 2023

1988 Torness R1 595 2023

1988 Torness R2 595 2023

1995 Sizewell 1191 2035

(1) Reference Unit Power means the rated electrical power of the generating unit as declared by EDF Energy in its daily transactions on December 2012.

(2) Dates of withdrawal from service, including all life extension decisions made on 15 January 2013.

14.9 - TECHNICAL KEY DATES FOR EACH OF THE CONSTELLATION NUCLEAR ENERGY GROUP NUCLEAR UNITS

YearCommissioned

Nuclear UnitReference

Unit Power (1)Planned date of with-drawal from service (2)

1969 Nine Mile Point 1 621 2029

1970 R.E. Ginna 581 2029

1975 Calvert Cliffs 1 875 2034

1977 Calvert Cliffs 2 875 2036

1988 Nine Mile Point 2 1304 2046

(1) Net continuous power(2) Date of withdrawal from service approved by NRC on January 2013


88


89

14.10 - TABLE OF ABBREVIATIONS

AAAR Automatic reactor shutdownAGR Advanced Gas-cooled ReactorALARA As Low As Reasonably AchievableAMELIE Project to transform spare part logisticsAMT Thermal Maintenance AgencyANDRA French National Radioactive Waste

Management AgencyASN French Nuclear Safety Authority

BBMA Standardised activity model libraryBWR Boiling water reactor

CCAP Annual Performance ContractCEFRI French committee for the certification

of companies in training and monitoring radiation workers

CEIDRE Corporate Chemical & Metallurgical Centre of Expertise

CENG Constellation Energy Nuclear Group (USA)CGNPC China Guangdong Nuclear Power Company

(China)CIDEN The Decommissioning, Waste Management

& Environmental Engineering CentreCIEST Inter-Contractor Work Conditions and Safety

CommitteeCIPN The Power Plants Operations Engineering

CentreCLI Local Stakeholder CommitteeCNEN Nuclear Design & Construction CentreCNEPE Electromechanical & Plant Engineering

Support CentreCOMSAT Unit outage safety meeting for operational

state changesCOPAT Unit Outage Operational Control Centre CSN Nuclear Safety CouncilCSNC Design Nuclear Safety Committee (Nuclear

Engineering Division)CSNE Operations Nuclear Safety Committee

(Nuclear Operations Division)

DDAIP Industrial Support for Production DivisionDCN Nuclear Fuel DivisionDIN Nuclear Engineering DivisionDNMC Daya-Bay Nuclear operation and

Management Company (China)DPI Production and Engineering DirectorateDPN Nuclear Operations Division

EEGE Overall Excellence EvaluationEGS Overall Nuclear Safety AssessmentENISS European Nuclear Installations Safety

StandardENSREG European Nuclear Safety Regulators GroupEPR European Pressurised ReactorEPRI Electric Power Research Institute (USA)ESR Significant radiation protection eventESS Significant nuclear safety eventEVEREST EDF campaign to allow entry into controlled

areas in street clothes

FFARN Nuclear Rapid Reaction ForceFME Foreign Material Exclusion

GGDA Generic Design Assessment (UK)GPEC Advanced planning of manpower and skillsGPSN Nuclear Safety Performance Group

HHCTISN High Committee for Transparency and the

Supply of Information Concerning Nuclear Matters

IAEA International Atomic Energy AgencyICRP International Commission for Radiological

Protection

IIFOPSE Industrial Safety and Prevention Training

InstituteIN Nuclear Inspectorate (part of EDF Nuclear

Operations Division)INB Licensed Nuclear FacilityINES International Nuclear Event ScaleINPO Institute of Nuclear Power Operators (USA)INSAG International Safety Advisory Group (IAEA)INTEP EDF Research and Development Division

initiative to introduce new technologies in the plants in service

IOP Operations EngineeringISOE Information System for Occupational

Exposure of OECD NEA

KKEPCO Korea Electric Power Corporation (South

Korea)KHNP Korea Hydro & Nuclear Power (South Korea)


90

MMAE Assessment and Support Unit of the Nuclear

Engineering DivisionMARN Nuclear Hazard Management Support TeamMME Operations and Maintenance MethodsMOPIA Project to set in place an attractive business

policyMPL Front Line Manager

NNDA Nuclear Decommissioning Authority (UK)NEA OECD Nuclear Energy Agency NEI Nuclear Energy Institute (USA)NIO Nuclear Independent Oversight (SRD / EDF

Energy)NNB Nuclear New Build (EDF Energy)NNSA National Nuclear Safety Administration

(China)NPP Nuclear Power PlantNRC Nuclear Regulatory Commission (USA)NSSC Nuclear Safety and Security Commission

(South Korea)

OO2EI Better Housekeeping Campaign (a Nuclear

Operations Division initiative)OIU User Internal OrganisationONR Office of Nuclear Regulation (UK)OSART Operational Safety Analysis Review Team

(IAEA)

PPARTNER Ecologically-sensitive nuclear plant

administrative facility refurbishmentPBMP Basic Preventive Maintenance ProgrammePGAC Worksite General Assistance ServicesPHPM Methods and Practices Harmonisation

Project PUI EDF Emergency PlanPWR Pressurised water reactor

RR&D Research and Development DivisionRET Exceptional Work PermitREX Experience feedbackRTE Power gridRTGE General Technical Rules intended to avoid or

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

SSDIN Nuclear Technical Information SystemSDIS County Fire and Emergency ServicesSEPTEN Basic Design Centre SGDSN National Committee of Public Safety and

DefenceSIR Official Inspection DepartmentsSOFINEL Joint EDF and AREVA design officeSPR Risk Management DepartmentSRD Safety and Regulation Department (EDF

Energy)STE Technical Specifications for OperationSYGMA Computerised maintenance management

system

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

CGNPC (70%) and EDF (30%)TSM Technical Support Mission by peers

organised by WANOTSN French Nuclear Safety &Transparency ActTVO Teollisuuden Voima Oy (Finland)

UUFPI Operations & Engineering Training UnitUNGG Gas-cooled graphite-moderated reactorUNIE Operations Engineering UnitUTO Central Technical Support Department

VVD3 Third Ten-Yearly OutageVP Mid-length outage

WWANO World Association of Nuclear OperatorsWENRA West European Nuclear Regulators

Association


91

Jean-Paul COMBEMOREL, Jean TANDONNET, Bruno CORAÇA, Peter WAKEFIELD, Bernard MAILLARD

PHOTO CREDITS

Cover : © EDF Médiathèque - Laurent VAUTRINChapiter 01 : © EDF Médiathèque - Marc MORCEAUChapiter 02 : © EDF Médiathèque - Alexandre SARGOSChapiter 03 : © EDF Médiathèque - Philippe ERANIANChapiter 04 : © EDF Médiathèque - Stéphane LAVOUEChapiter 05 : © EDF Médiathèque - Jean-Luc PETITChapiter 06 : © EDF MédiathèqueChapiter 07 : © EDF MédiathèqueChapiter 08 : © EDF Médiathèque - Marc DIDIERChapiter 09 : © EDF Médiathèque - Philippe ERANIANChapiter10 : © EDF Médiathèque - Alexis MORINChapiter 11: © EDF Médiathèque - Olivier BLAISEChapiter 12 : © EDF MédiathèqueChapiter 13 : © Ho New / Reuters

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