nuclear safety our overriding priority

“Nuclear Safety: our overriding priority” - EDF Group’s file responding to FTSE4Good nuclear criteria.

“Nuclear Safety: our overriding priority”

EDF Group‟s file

responding to FTSE4Good nuclear criteria

Disclaimer

This document is provided for information purposes only and is not, in particular, intended to confer any legal

rights on you.

This document does not constitute an invitation to invest in EDF or any other company’s shares and/or

bonds. Any decisions you make in reliance on this information are solely your responsibility.

Although due care to a standard of a limited assurance has been taken in compiling the contents of this

document, EDF or any of other company accepts no liability in respect of any errors, omission or

inaccuracies contained or referred to in it. EDF provides this document in good faith but no warranty or

representation is given by, or on behalf of EDF or any of its directors, officers, employees or advisers or any

other person that the content is accurate, complete or up to date. Any use of, or reliance on, the content of

this document is at your own risk. The situation of policies and systems is the current one in December 2011.

The situation of the datas is at December 2010.

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permitted to download and print content from this document solely for your own internal business purposes

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EDF accepts no responsibility for any information on other websites that may be accessed from this site by

hyperlinks, or any use of personal data by such third party websites.

Date: February 10th

, 2012.

Preparation of this document was led by Claude JEANDRON, Generation and Engineering Department of

EDF.

Registered Company Details: French société anonyme with a share capital of €924,433,331

Registered head office: 22-30, avenue de Wagram, 75382 Paris Cedex 08, France

Registration reference: 552 081 317 RCS Paris


Contents

1 Nuclear activities of EDF Group

1.1 Overview of the Group

1.2 Description of nuclear assets

1.2.1 EDF SA

1.2.2 EDF Energy

1.2.3 CENG

1.2.4 TNPJVC

2 Nuclear Safety and Radioprotection

2.1 The Safety Policy and its global implementation

2.1.1 Definition

2.1.2 EDF Group Policy

2.1.3 Overview on general provisions made at Group level to implement

this Policy

2.2 Incidents and events

2.2.1 Policy

2.2.2 Systems

2.3 Unplanned shutdowns

2.3.1 Policy

2.3.2 Systems

2.4 Safety assessment

2.4.1 Definition

2.4.2 Policy

2.4.3 Systems

2.5 Risk assessment

2.5.1 Policy

2.5.2 Systems

2.6 Radiation exposure (to workers and the general public)

2.6.1 Overview on the regulatory context

2.6.2 Policy

2.6.3 Systems

2.7 Security

2.7.1 Policy

2.7.2 Systems

3 Waste

3.1 Overview

3.2 Policy

3.3 Systems for radioactive waste

3.4 Spent fuel

3.4.1 Policy

3.4.2 Systems

3.5 Decommissioning and waste

3.5.1 Policy

3.5.2 Systems

4 Training

4.1 Overview on Human Resources and training policy

4.2 Systems

5 Reporting

5.1 Policy

5.2 Systems

Appendix


1 – Nuclear activities of EDF Group

1.1 Overview of the Group

EDF is the world’s leading nuclear energy company, with solid positions in major European

countries (18% of world’s nuclear installed capacity, 160,000 employees worldwide, 630 TWh

of electricity generated by all types of generation, 109 gCO2/kWh: a quarter of European

average).

As the world is facing a triple challenge -responding to growing energy needs competitively,

while tackling climate change and the depletion of easily accessible resources- EDF Group's

strategy is to meet these challenges by developing competitive and low carbon energy

solutions. Building a sustainable energy future requires considerable efforts and investment:

fostering decarbonised electricity generation by developing low-carbon

technologies,

promoting demand-side management and developing environmentally friendly

end-uses,

ensuring the competitiveness of the solutions that are chosen, to maintain

employment and ensure affordability for households ,

investing in R&D to prepare for the energy of the future,

exploiting opportunities presented by the latest technologies,

helping with the development of carbon capture, transportation and storage

technologies,

seeking out major hydroelectric infrastructure projects within a local

sustainable development policy.

EDF has been involved in the development and operation of clean and peaceful use of nuclear power for more than 40 years. EDF is currently present in three continents as a nuclear owner and operator:

- in France, where the mother company owns and operates 58 reactors and is building a new one using the most modern technology - the European Pressurized Water Reactor (EPR)

- in the UK, where EDF Energy owns (with minority share partner Centrica (20% ownership)) and operates15 reactors. It also has plans to build four new ones (EPR)

- in the US, where CENG, the joint venture between Constellation Energy Group (CEG) and EDF, owns and operates five reactors; EDF also aims to develop the EPR technology in USA with its affiliate Unistar Nuclear Energy (UNE)

- in China where TNPJVC, the joint company between China Guangdong Nuclear Power Holding Company (CGNPC)(70%) and EDF (30%), will own and operate two new EPR reactors currently under construction.


EDF has other investments in nuclear companies, but without operational involvement. These

are:

Tihange 1 in Belgium. EDF has a 50% investment in the plant and the sole operator of

the plant is Electrabel. EDF’s responsibility is to ensure that it provides 50% of the

funds necessary to ensure the continued safe operation of the plant (1). This clarity of

responsibility is in line with internationally (Euratom, IAEA) recognised organisational

standards and with Belgian law. EDF takes every opportunity possible within this

context to ensure that the operation of Tihange 1 is in line with accepted best practice

and its own nuclear policies. EDF has four representatives on the Liaison Committee

and one on the Technical Committee, which together provide suitable fora for sharing

the best practice developed across EDF Group and Electrabel, monitoring the

development and implementation of operating practices and launching joint studies

(such as undertaking stress-tests, efforts to reduce radiation exposure, etc). EDF has

reviewed Electrabel’s policies and considers that they are sufficiently in-line with its

own. Moreover, EDF has of course free access to the reports which are disclosed by

the operator itself (2) or by safety authorities (

3). These reports are equivalent to the

ones published by EDF or by French authorities. As operational performance is the

responsibility of the sole operator, Electrabel, performance indicators are not

consolidated into EDF Group figures.

part ownerships of companies like EDF Luminus (4) in Belgium or ALPIQ in

Switzerland, but these investments do not provide an opportunity for influence over

operational practices.

In Belgium EDF owns 63.5% of EDF Luminus which owns 10% of the investment of

Tihange 2-3 and Doel 3-4. EDF Luminus has no operational involvement or

responsibility in those plants which are fully operated by Electrabel.

In Switzerland EDF owns 25.1% of ALPIQ which owns 40% of Kernkraftwerk Gösgen-

Däniken AG which is the operating company of Gösgen station, and 32,4% of

Leibstadt AG which is the operating company of Leibstadt station. ALPIQ has no

involvement or responsibility in the operation of Gösgen and Leibstadt NPP. However,

information made public or provided to board members or to international

organisations give EDF a good visibility on the safety performances of the related

plants. If some safety concern were to appear, EDF board members would be able to

intervene.

EDF also has held and currently holds services contracts for nuclear power in China

mainly technical assistance services contracts (e.g. nuclear plants of Daya-Bay, Ling-

Ao) but EDF is not the operator of these power stations.

1 Signature of a General Agreement on December 16th, 1996. EDF contributes 50% to all operational expenses

and investments during operation and post-operation (following final shutdown), but not decommissioning itself. 2http://www.electrabel.com/assets/content/whoarewe/Declarationenvironnementale211_8938400CB3F44A0

C9DE32C1D5BEA4F99.pdf 3 http://www.belv.be/images/pdf/rapport_annuel_belv_2010_fr.pdf et

http://www.fanc.fgov.be/GED/00000000/2900/2989.pdf 4 SPE became EDF Luminus in november 2011

http://www.electrabel.com/assets/content/whoarewe/Declarationenvironnementale211_8938400CB3F44A0C9DE32C1D5BEA4F99.pdf


http://www.belv.be/images/pdf/rapport_annuel_belv_2010_fr.pdf

http://www.fanc.fgov.be/GED/00000000/2900/2989.pdf


1.2 Description of nuclear assets

1.2.1 EDF SA

EDF SA owns and operates in France the largest nuclear fleet in the world, of which it has

been the architect-engineer.

OPERATING UNITS

SITE TYPE POWER (MW)

COMMISSIONING

YEAR

Fessenheim 1-2 CP0-PWR 880 1977

Bugey 2-5 CP0-PWR 910-880 1978-79

Dampierre 1-4 CP1-PWR 890 1980-81

Gravelines 1-4 CP1-PWR 910 1980-81

Gravelines 5-6 CP1-PWR 910 1984-85

Tricastin 1-4 CP1-PWR 915 1980-81

Blayais 1-4 CP1-PWR 910 1981-83

St Laurent B 1-2 CP2-PWR 915 1981

Chinon B 1-4 CP2-PWR 905 1982-87


Cruas 1-4 CP2-PWR 915 1983-84

Paluel 1-4 P4-PWR 1,330 1984-86

Flamanville 1-2 P4-PWR 1,330 1985-86

St Alban 1-2 P4-PWR 1,335 1985-86

Cattenom 1-4 P’4-PWR 1,300 1986-91

Belleville 1-2 P’4-PWR 1,310 1987-88

Nogent 1-2 P’4-PWR 1,310 1987-88

Golfech 1-2 P’4-PWR 1,310 1990-93

Penly 1-2 P’4-PWR 1,330 1990-92

Chooz B 1-2 N4-PWR 1,500 1996-97

Civaux 1-2 N4-PWR 1,495 1997-99

EDF SA is currently building a new 1,600 MW EPR on the site of Flamanville and intends to

build another at Penly. The newest design of that reactor contains several main improvements

in safety and radiation protection: probability of severe accident reduced by a factor of 10,

reinforced management of severe accidents with fewer potential consequences for people and

the environment, reinforced protection against a plane crash, less fuel used for the same

energy produced so 26% less waste type B produced, half the radiation exposure for

workers,…(5) See more details in § 2.4.

EDF SA is also currently dismantling 9 reactors:

REACTOR UNDER DECOMMISSIONING

SITE NUMBER TYPE OF

REACTOR COMMISSIONING

YEAR FINAL

SHUTDOWN

YEAR

POWER (MW)

Brennilis 1 Heavy water Reactor

1967 1985 70

Chooz A 1 REP 1967 1991 305

Creys-Malville 1 FBR 1986 1998 1,200

Chinon 3 UNGG 1963-65-66 1973-85-90 70-120-480

St Laurent 2 UNGG 1969-1971 1990-92 480-515

Bugey 1 UNGG 1972 1994 540

EDF SA also owns a nuclear subsidiary, Socodei, which operates Centraco, a facility for solid

and liquid waste treatment in the Marcoule industrial complex (Gard department).

Regarding special regulations applicable to nuclear facilities, EDF SA is subject in France

to the law of June 13th, 2006, concerning Transparency and Security in the Nuclear field (“TSN

law”). The law created the Nuclear Safety Authority (NSA), an independent administrative

authority. The law is completed with the decree of November 2nd

, 2007, concerning

authorization of facilities and control; it includes transport of radioactive materials, for which

5 ENEL, the italian leader in energy, holds a 12.5% participation in the investment and operation costs of Fla3

and an industrial partnership contract, but the only nuclear operator is EDF


emitters are responsible. In addition, the conditions for water pumping, liquid and gaseous

releases and their associated limits are set by the NSA. Limits are approved by the Ministers

in charge with nuclear safety. The application file for an authorization includes a safety report

which contains a description of the measure to reduce the risks and to limit the consequences

of any accident, a study of the impact of the plant on the environment and health, a

decommissioning plan and a risk management study. The TSN law does not set a limit on

service life but requires a safety review of the plant every ten years. After the 10-year

inspection of each reactor, the NSA issues an opinion for the continuation of the operation for

a new 10 years period. If needed, the NSA adopts complementary requirements.

The TSN law also includes provisions concerning public information and transparency,

such as a High Committee for Transparency and Information on Nuclear Safety, a Local

Committee for Information in the vicinity of each nuclear facility. Each facility has the legal

obligation to provide and publicly display each year a report describing the measure taken in

terms of safety, radiation protection and the environment. These documents are available for

consultation on the EDF web-site.

The final shutdown and decommissioning of a nuclear facility are authorized by the

Ministers in charge of nuclear safety; on that basis, the NSA can define specific requirements.

EDF SA’s business is subject to French regulations for the handling, storage and long-term

management of nuclear waste. EDF is legally responsible for the nuclear waste resulting from

its operations. In France, radioactive waste is managed by the National Agency for

Radioactive Waste Management (ANDRA), an industrial and commercial public entity created

by the French law of December 30, 1991.

Regarding radiation protection regulations, all nuclear activities containing a risk of

exposure of people to ionizing radiation fall under the authority of the French Nuclear Safety

Authority (NSA). French regulation is compliant with European directives of 1996 and 1997

which sets the maximum exposure by the general public at 1 mSv per year and impose a limit

on exposure of workers of 20 mSv for 12 consecutive months 6.

1.2.2 EDF ENERGY (for more details, read « Our journey towards zero harm » on EDF Energy’s web

site7)

EDF Energy holds 80% of Lake Acquisitions Limited (the other 20% is held by Centrica) which

owns the eight nuclear sites (15 reactors under commercial operation) of former British

Energy. The acquisition process was completed in 2009. Centrica holds also a 20%

participation in NNB Holding Company Limited, another division of EDF Energy which aims to

build four EPRs in the UK.

6 For more details on regulations , see the Reference Document §6.5.4.2

7 http://www.edfenergy.com/about-us/energy-generation/nuclear-generation/documents/EDF-Energy-

NuclearGeneration-Our-Journey-Towards-Zero-Harm.pdf


OPERATING UNITS

STATION NUMBER

OF

REACTORS

TYPE OF


YEAR

SCHEDULED DATE OF

DECOMMISSIONING(8)

NET

CAPACITY

OF

STATION Hunterston B 2 AGR 1976 2016 820

Hinkley Point B 2 AGR 1976 2016 820

Hartlepool 2 AGR 1983 2019 1,190

Heysham 1 2 AGR 1983 2019 1,160

Dungeness B 2 AGR 1983 2018 1,040

Heysham 2 2 AGR 1988 2023 1,235

Torness 2 AGR 1988 2023 1,230

Sizewell B 1 PWR 1995 2035 1,188

Each nuclear power station is subject to a Nuclear Site Licence, which is issued by the Office

for Nuclear Regulation (ONR). The licence has 36 strict conditions, which govern all aspects of

safe operation of the station. The ONR monitors the performance of the power station

operator, and appoints a site inspector for each station. All significant changes to the plant or

8 Based on currently agreed accounting lives; one of EDF Energy’s expectations is to extend the lifetimes of its

nuclear power stations where it is technically and economically viable to do safely


to its operating procedures are subject to approval by ONR. EDF Energy has no facility under

decommissioning.

In the following text, the provided information about the governance of nuclear safety and

waste is for EDF Energy’s Nuclear Generation business only. Unless specified, this

information does not apply to the Nuclear New Build project (NNB Generation Company

Limited) given the current stage of development of the project.

1.2.3 CENG

EDF Group co-owns (49.99%) Constellation Energy Nuclear Group (CENG), along with

Constellation Energy Group (CEG)9, but CEG holds the majority of shares (in accordance with

American law, a foreign company cannot exercise responsibility on a nuclear plant). The

acquisition process was completed in 2009. Being co-owner of CENG, the fleet operator, EDF

is fully involved in designing and putting in place nuclear policies and systems in partnership

with its co-owner. CENG’s policies are therefore consistent with, and have informed, the EDF

Group approach.

CENG owns and operates five nuclear reactors in the states of Maryland and New York, USA

(10

). CENG has no facility under decommissioning.

OPERATING UNITS

SITE LOCATION TYPE OF


YEAR SCHEDULED FINAL

SHUTDOWN YEAR POWER

Calvert Cliff 1 Maryland PWR 1975 2034 878 MW

Calvert Cliff 2 Maryland PWR 1977 2036 872 MW

Nine Mile Point 1

New York BWR 1970 2029 620 MW

Nine Mile Point 2

New York BWR 1988 2046 1,148 MW

Ginna New York PWR 1970 2029 581 MW

In the United States, the nuclear fleet’s quality and safe operation are monitored by the

Nuclear Regulatory Commission (NRC) which delivers the license to build and to operate,

establishes the rules and controls their strict compliance, through inspections and with the

help of a representative on site. The NRC regularly assesses safety performances and

publishes a rating for all plants. CENG’s nuclear business is undertaken in a predictable

regulatory environment. Licenses are initially granted for 40 years of operation. They can be

extended by additional 20-year periods, provided that the operators commit to adequate

monitoring of the key components and structures of their plants. All CENG units applied for the

extension of their license from 40 to 60 years, and they have all been granted.

9 A merging process between CEG and Exelon is ongoing

10 Long Island Power Authority owns 18% of Nine Mile Point 2


In addition, the Institute of Nuclear Power Operations (INPO), created after the Three Mile

Island accident of 1979, aims to promote operational excellence through safety assessments,

peer-reviews and support activities. The INPO assesses all sites every 2 years and also

publishes a rating (used by insurance companies); it is also the prescriber and the controller of

training processes: it delivers accreditation of the plants every 4 years.

The Electrical Power Research Institute (EPRI) brings an important technical support to

American nuclear operators, thanks to research in laboratories and experience feedback from

the operators.

EDF Group has been a permanent member of INPO and EPRI for many years and has an

inspector inside INPO in Atlanta and an engineer in EPRI in Palo Alto.

1.2.4 TNPJVC

EDF owns 30% of the shares of Taishan Nuclear Power Joint Venture Company limited

(TNPJVC), the goal of which is to construct and operate two EPR reactors in Taïshan, in the

province of Guangdong (China). CGNPC Group holds the majority of the equity interest in line

with PRC law. For the first time the Group is an investor in nuclear power generation in this

country11

. The first concrete casing for unit 1 was constructed in the last trimester 2009, and

the first concrete was poured for unit 2 in April, 2010. The first unit should be commissioned at

the end of 2013 and the second in 2014.

The design, equipment manufacturing, construction, commissioning and start-up of nuclear

facilities in China are performed on the basis of the applicable laws and regulations in force in

China as well as on the basis of codes and guides on nuclear safety and industrial guidelines

and standards. The National Nuclear Safety Administration ("NNSA") is the regulator for

nuclear and radioactive safety in China. The NNSA is responsible for (i) the administration of

nuclear safety, and making relevant guidelines, policies and regulations; (ii) participating in

emergency response to nuclear accidents and radiation environmental accident; (iii) carrying

out integrated supervision and administration of the safety of nuclear facilities, application of

nuclear technology; and (iv) carrying out safety supervision of nuclear materials restriction and

nuclear pressure retaining components. Another important role of the NNSA is its

responsibility for issuing licenses in relation to the activities of the NPP, in particular, the

approval of the nuclear safety aspects of the feasibility study report. The Ministry of

Environmental Protection ("MEP") is responsible for the supervision and administration of the

nationwide environmental protection, including that for the nuclear power plants, radiation

environment and radioactive waste. The Safety Guides established by NNSA are based on

the IAEA safety guides. The compliance of Taïshan project with Chinese regulatory

requirements will be developed in the Final Safety Analysis Report. It has to be noted that

Taïshan Phase 1 power plant is based on Flamanville 3 design for which the French

regulations are applicable.

11

EDF has also support contracts with CGNPC in Daya-Bay and Ling-Ao plants but no responsibility as an

operator


Given the current stage of the Taïshan Phase 1 project, the nuclear safety policy and

management issues are at a very early stage, compared to those at other sites. The focus is

for the moment on designing-in and building-in nuclear safety. Indeed the reference

documents regarding safety and waste management are yet to be produced, and no indicators

are available although an internal Nuclear Safety Management Policy is already in place within

TNPJVC. Therefore the description of safety policy and management practices in the

following paragraphs is only partially applied to TNPJVC. This current file will be

reviewed when the construction site becomes a nuclear facility under commissioning

tests.

Nonetheless, EDF and CGNPC have been partners in nuclear activities for 30 years, since

they have cooperated in a very comprehensive way for the success of the power plants of

Daya-Bay and Ling-Ao I and II. A lot of Chinese operators and engineers of these power

stations have been trained in France and numerous French systems, practices, and technical

improvements have been imported by Chinese managers and executives and are applied or

were adapted for the Chinese system. A Chinese version of the RCC-M was released in

November 2010. CMIF (China Mechanical Industry Federation), CNPRI (China Nuclear Power

Research Institute), AFCEN, EDF, DEC (Dongfang Electric Corporation) and NEA (National Energy

Administration) participated to this project. The publication of RCC-M Chinese version will

facilitate the cooperation between Chinese manufacturers, international nuclear actors and

inspection entities. China’s own nuclear Codes & Standards establishment is still under

progress and AFCEN is interested to continue cooperation with CNPRI to further translate and

update the RCC codes. Today the operating performance (including safety) of French and

CGNPC plants are very similar. A close cooperation is in place in Taïshan Phase 1 between

the two engineering services to control the quality of the construction of the two EPRs and the

quality of all equipments and pieces from all the suppliers. Thirty EDF staff work on a

permanent basis on the Taïshan site. EDF intends to gain a large experience feedback from

that project to the benefit of EPR standard.

2– Safety and Radioprotection

2.1 The Safety Policy and its global implementation

2.1.1 Definition

Nuclear safety, as defined by international organizations, is the various provisions made at all

stages in the design, construction, operation and decommissioning of nuclear facilities to

protect people and their environment against the dispersal of radioactive substances under all

circumstances, or in other words:

Ensure the facilities are operating normally

Prevent incidents and accidents

Mitigate the consequences of incidents and accidents that may occur.


2.1.2 EDF Group Policy:

We all, within EDF Group, share the same vision that nuclear safety is the overriding

priority in the sustainable use of nuclear energy, recognising that nuclear energy needs

also to be efficient, affordable and environmentally friendly. It is an indispensable

precondition when providing energy to humanity.

Nuclear safety inside the Group rests on the principle of clarity of responsibility and

control.

Each nuclear operating company inside the group acts under the framework of legal

obligations and regulations specific to its country and must comply with them. Each

guarantees and continuously improves its safety performances with its own methods, skills

and values.

EDF respects national differences, across the Group, whilst developing common principles

to deliver the highest level of incident prevention and protection of the public, workers, and

the environment. This policy covers all aspects of nuclear – for example, new build,

architecture, design and construction - and all aspects of the existing stations – operation,

maintenance, waste management, decommissioning and off-site support. The Group

works closely with its industrial partners to deliver this.

Each company is responsible for, and assigns adequate delegation at, each level of

management or operation: clear organisation, the required skills and decision-making

capacity, access to support and resources. The Group guarantees the allocation of

resources needed to ensure nuclear safety.

An in-house independent nuclear safety assessment function is put in place at power

station level, company level and Group level. Each report independently of all line

functions and have not only the right, but also the duty, to notify senior management of

inappropriate or inadequate line management response.

Common commitments for all nuclear companies of the Group

An overriding priority is placed on nuclear safety at every stage of the plant lifecycle:

design, construction, operation and decommissioning. That priority is the responsibility of

all and is demonstrated via the individual commitment of all staff within the Group. Each

company ensures that its contractors enforce that requirement, and employ well-trained

and professional staff.

The Group recognises that excellence in everything we do is underpinned by equipment

reliability, human performance and efficient work management, as these are the main

drivers of nuclear safety and reliability.


The Group recognises the importance of establishing a good nuclear safety culture among

its staff and contractors. This is characterised by people having a questioning attitude and

being free to raise safety concerns, using error prevention techniques, reporting in a timely

and transparent way, being conscious of risks and continuously assessing them. The

Group values highly, and encourages, independent oversight and challenge.

Although it is mobilized to minimise the risk of any incident or accident, the Group must respond adequately to such an event with the aim to protect public health and safety. The Group’s companies maintain comprehensive emergency plans at a high state of readiness, including carrying out regular emergency drills with local and national authorities. The Group uses these opportunities to reinforce its communication towards the public and to enhance the safety culture of its staff.

Continuous improvement is promoted and organised using the full range of knowledge and

services within the Group and within international organisations. Operational experience

is collected, analysed, reported, and acted on.

International experience enriches continuous improvement and the drive for excellence:

the Group’s companies commit both to receive regular international peer reviews and

provide suitable peers for such reviews in other companies. All recommendations are

considered and acted on.

Openness and transparency: we aim to build openness and trust internally and externally

by creating an open culture and actively engaging with our stakeholders and communities

through clear and timely communications on nuclear safety issues and incidents. We

strive for a constructive, open and trusting, relationship with our Stakeholders, including

our staff, our suppliers’ staff, regulators, trade unions and local communities.

Application

The responsibility for the deployment of this policy, and the overall operation of the business

unit, lies unambiguously with the line management. Group is responsible for checking, using

appropriate mechanisms, that the policy has been adequately deployed and the standards and

quality for the delivery of nuclear safety are being adequately maintained by the line

management.

2.1.3 Overview on general provisions made at Group level to implement this policy:

In 2009 EDF acquired renowned existing nuclear companies after having built its own fleet

and accumulating at the same time, vast experience at three stages: (i) designer and

architect-assembler, (ii) operator, (iii) dismantler. Each EDF Group company had previously

put in place its own safety policy and management system and remains responsible for its

safety. Each one, beyond compliance with national laws and regulations, strives for excellence

and has implemented long-term adapted programs to continuously improve its safety

performance; each one uses its own competences and expertise and benefits from national

and international support. The aim of EDF Group is so to encourage this attitude and to

reinforce it by using all possible synergies within the Group in the framework of its common

nuclear safety policy.


The continuous reinforcement of nuclear safety is built on three pillars, chosen and

implemented in a manner consistent with international guidelines (IAEA SF-1 and GRS-3,

INSAG 4 for safety culture, INSAG 13 for safety management, INSAG 18 for changing

management) and best practice:

the permanent reinforcement of the reliability of organization, through the

implementation of best practice, and striving for excellence

the permanent reinforcement of the reliability of equipment

the permanent reinforcement of human performance and professionalism of all actors,

acting right at the first attempt.

Bringing complementary means and processes, EDF Group aims to develop strong synergies

between nuclear companies and to ensure that its common policy is fully implemented

everywhere. With that objective, EDF Group:

implements special programs to share experience, for existing fleets and for new

projects (see §2.2, 2.4, 2.5, 2.6, 2.8)

brings additional support from its engineering division if needed (e.g. in case of

incident or maintenance)(see §2.4),

has extended crisis organization (see §2.5),

promotes the use of international benchmarking and the implementation of best

practice, and puts in place cross-programs for training

EDF has also defined its own requirements in the case of a new acquisition in, or a

new partnership with a nuclear company.

EDF has had in place for many years a dedicated organization and high competencies to

monitor the compliance of its safety policy inside the company, led by the General Inspector

for Nuclear Safety and Radiation Protection (GINSR), directly reporting to the CEO of EDF

Group, and the Nuclear Safety Council. Following the international development of nuclear

activities, EDF is progressively extending the scope and the role of the General Inspector and

those of the NSC, opened now to representatives from EDF Energy and EDF Inc (12

). Today,

the GINSR implements safety assessments and controls across the Group (13

). With his team

of senior experts, he verifies that safety performance and practices remain efficient and

extensive, regarding requirements and public expectations, as well as the company’s policy.

He verifies that behaviour and culture are consistent all over the Group. He warns executives

if necessary and presents recommendations. He produces an annual report which he presents

to the NSC and which is available to the public (on web site). His recommendations are

recovered if needed by the CEO to the intend of the concerned executive.

12

EDF offices in Washington DC, whose some executives are members of CENG board

13 These assessment visits can take place only in the operating companies where EDF is involved (if specified in shareholder agreement in

the case of minority share) ; in the other companies, the GINSR can make visit with the authorisation of the operator in the framework of

experience sharing


The governance of each nuclear company of the Group is adapted to its share and to

national obligations. By its representation in different boards and committees, EDF is aware of

a high number of information and reports, complemented by the assessments of the GINSR,

and can impulse or promote safety improvements.

Within EDF Energy Nuclear Generation Group Ltd, the board is responsible for the

management monitoring of EDF Energy Nuclear Generation, the business unit which holds the

license. Several representatives of EDF (a part being senior executives of Generation and

Engineering Division EDF) are members of this board. Inside EDF Energy Nuclear

Generation, a Nuclear Safety Committee is constituted, in compliance to the license; a Safety

and Regulation Division regularly reports to this Committee in the area of safety. EDF GINSR

is a member of the committee.

Within CENG, the Nuclear Safety and Operation Committee (NSOC) is a committee of the

Board dedicated to safety; it reviews safety performances reported by INPO and by the quality

organization of each plant; EDF has two members (parity with CEG). On each site, a Nuclear

Safety Review Board monitors safety management; a member of INPO and external experts

are members of this board, with representatives of the plant; a senior vice-president of CENG,

coming from EDF, is a member as well. NSRB makes a report every three months which is

displayed to the INPO.

Within EDF SA, the overall compliance to regulations and to the safety policy and the safety

management are assessed at each level of the organization. At the company level, the

Nuclear Safety Council, of which the GINSR is the secretary, is composed in particular of all

the executives of the mother company and it reports to the Chairman of the company. At the

immediate lower level, the Operational Safety Review Committee of the Nuclear Generation

Division reports to its director. Also the Design Safety Review Committee reports to the

directors of Nuclear Engineering Division. At each station, a Safety Technical Committee

reports to the plant director. An independent line of engineers and senior advisors is

permanently assessing safety and reports to these committees (for more details, see § 2.4)

2.2 Incidents and events

2.2.1 Policy

Recognizing that the most harmful consequences arising from nuclear facilities can come from

the loss of control over a nuclear reactor core, the nuclear chain reaction, or uncontrolled

radioactive discharge, EDF Group aims to reduce the likelihood of an accident having harmful

consequences to the lowest level as possible, and takes measures:

To prevent the occurrence of failures or abnormal conditions that could lead to such a

loss of control;

To prevent the escalation of any such failures or abnormal conditions that do occur

and mitigate their consequences;

To prevent the loss of, or the loss of control over, a radioactive source or other source

of radiation.


2.2.2 Systems

The primary means of preventing and mitigating the consequences of accidents is „defence in

depth‟. Defence in depth is implemented primarily through the combination of a number of

consecutive and independent levels of protection: some of them could replace others in case

of failure and would prevent any harm caused to people or to the environment.

In line with this fundamental IAEA principle and with local regulations, EDF Group companies

have all put in place local processes to detect (14

) and prevent such failures/events (15

) of any

origin (human or technical), to mitigate them and to implement experience feedback. That

process consists of:

o Identifying conditions that have or could have an undesirable effect on performance of

equipment, programs, or organizations

o Ensuring necessary immediate actions are implemented to place plant/situation in a

safe and stable condition

o Reporting the condition to a supervisor or the control-room, as appropriate, including

immediate corrective actions taken

o Promptly initiating a condition report and providing sufficient information so that the

condition can be properly evaluated for operability and compliance with safety rules.

The conditions and limits necessary for safe operation are described in Operating Technical

Specifications (OTS), or the licence conditions, validated by the national safety authority.

These specifications are more or less detailed, depending on the way risk analysis may be

used in conjunction. On one hand in France OTS are largely extended and they describe in

detail the list of actions to implement in case of a failure on a safety-related equipment; risk

analysis is not used as a complement to day-to-day operation (16

). On the other hand, risk

analysis is used extensively in USA, for example in the case of a simple (or a combined)

unavailability of safety-related equipment(s). The two approaches are internationally

recognized as efficient.

The incident or accident procedures used to place the plant in a safe condition have been

widely improved everywhere since the accident of Three Miles Island which highlighted the

difficulty to make a correct diagnosis of the situation and to carry out the appropriate corrective

actions. A large international experience feedback program has been implemented. Several

steps have been taken to and currently all the French procedures are state-oriented

procedures, used simultaneously by operators and supervisors on the one hand and safety

engineers on the other. These evolutions are closely linked to license conditions and can only

be implemented with the agreement of safety authorities in a consistent way with all the

14

The detection and self-report of errors by their authors is promoted and recognized as a positive contribution

to safety; on the contrary, the fact of hiding an error is a fault in the safety culture and has to be disciplined

15 In the safety culture, an “event” does not necessarily have a direct consequence on equipment or on the

installation globally. It can only be constituted on a decline in the lines of defence with no material

consequence.

16 The required attitude has been determined by risk analysis when the OTS have been established


nuclear industry and following thorough tests and qualifications on a simulator. All operators

and supervisors are often trained on full-scale simulators to be well prepared to face an

accident situation. In some sessions, severe accidents caused by important and combined

failures beyond the referential are simulated to prepare the shifts to face complex situations.

According to its permanent safety assessment and its experience feedback program, EDF SA

uses detailed safety indicators and assessment tools to determine and monitor

improvement programs or projects launched to correct weaknesses and to look for excellence.

These indicators are, beyond the number of significant events or incidents, for example the

number of non-compliances with Operational Technical Specification (OTS), number of line-up

errors, number of breakings out of fire, etc. EDF also implements a risk analysis of the most

significant events and on “precursors”. That process is an accurate and objective tool to check

if the safety is really improving and to rank all the events to determine the most significant.

These indicators are also instruments to monitor the various projects, such as:

Project “Deployment of Human Performance tools”: that project is based on two

approaches: (i) ensure that every operational employee does the right thing at the first

time by using standard practices and (ii) ensure that every manager conducts an on-

site visit with its staff. At the end of 2010, 30,000 managers and field workers (EDF

employees and contractors) had been trained in reliable practices, of which 20,000

were during dedicated workshops; 1,300 instructors were also trained to maintain and

demonstrate good practices within the work teams. More than 60,000 on-the-ground

monitoring visits are performed each year by managers. Each station has its own

human factor consultant.

Project “AP 913 implementation”: launched by INPO around 2000, this initiative aims

to obtain excellence in the reliability of equipment. EDF decided to use this program to

reinforce its maintenance strategy. All the maintenance programs have been re-

assessed, dedicated organization and staff have been put in place and the project is

under active deployment

Project “Put fire risk under complete control”: this project combines the 4 conditions for

success which are (i) fire risk management, (ii) training, (iii) prevention and (iiii) fire

fighting. EDF uses two training centers to regularly train its fire-fighting teams and

operating teams; partnerships are effective in all plants with local fire-brigades with

numerous fire-drills; prevention is also reinforced by the presence of a professional

fire-officer within each local organization

Project “Experience feedback”: that project aims to complement the already strong

and efficient centralized process with local information and feedback, to make each

manager and each operator more aware of its role, and therefore more efficient; it

uses the US process called the “Corrective Action Program” (CAP), required by law in

the US (10CFR50), and also promotes a deeper use of WANO reports (SER and

SOER)

Project “Implement an attractive industrial strategy” (17

): this project consists of the

reinforcement of the partnership with contractors by improving the activities and skills

of staff. It also focuses on Industrial Safety for contractors, working and living

conditions for on-the-go personnel, long term contract visibility...This project was

17

The project’s name is MOPIA in French (“Mettre en Oeuvre une Politique Industrielle Attractive”)


launched after an agreement was signed in 2004 with contractor representatives. The

contractual conditions have been reviewed (18

) and a program put in place in favour of

recruitment and skills. A complete training course has been put in place in partnership

between “Education Nationale”, EDF and contractors; all stations have their workshop

for training.

At EDF Energy there is a particular emphasis on oversight to monitor performance and

conformity to both its internal standards and external regulations. They operate a multi-layer

model with increasingly independent oversight being exercised through:

• Management accountability - the exercise of leadership;

• In-process oversight through self checking, peer checking and self assessment as part of its

internal controls process;

• Functional oversight – review and audit by company experts;

• Independent internal oversight from its Safety and Regulation Division who reports to the

Board independently of the operating arm of the company

• External oversight from its Nuclear Safety Committees with their external members, from

peer evaluations by teams from other utilities and WANO/INPO, from standards accreditation

bodies, e.g. Lloyds Register Quality Assurance, and from the Government’s Office for Nuclear

Regulation.

Specifically for incidents and events, EDF Energy also undertakes the following processes:

The continuous improvement model which is based on the INPO excellence model and is

enshrined in company processes. Issues and emerging trends are identified and

analysed; solution options are studied, prioritised and implemented through business

processes.

The Corrective Action Programme which is used to identify, document, evaluate, and

trend undesirable conditions (problems) and to take actions to correct problems and their

causes. The aim is to proactively identify sub standard conditions and practices at a local,

low consequence level and take positive action to prevent more significant consequence

events arising and adverse trends developing.

The Operating Experience processes cover the reviewing, screening and disseminating of

internal and external nuclear industry event notices or other operating experience for

applicability of lessons learned to specific EDF Energy Nuclear Generation facilities.

For more details, on EDF Energy processes and systems for incidents and events, see “Our

journey towards zero harm”.

18

To promote the preference to the best bidder (“Most Economically Advantageous Tender”) than to the

cheapest one


CENG has established 6 “Fleet Initiatives” which are identified and defined below:

Nuclear Safety and Security: CENG drives for proactive elimination of vulnerabilities in nuclear safety and physical plant security. CENG accomplishes this through improvements in cyber security, emergency planning, fire protection systems, environmental performance, containment sump performance, and Fukushima lessons learned.

Personal Safety Excellence: CENG drives for fundamental improvements in industrial and radiological safety. CENG accomplishes this through improvements in hazard recognition, mitigation and elimination; employee engagement; leadership support; and source term reduction.

Operational Excellence: CENG drives for excellence in nuclear safety, human performance and generation reliability. CENG accomplishes this through improvements in Operations fundamentals, INPO Performance index, refuelling outage performance, human performance and risk management.

Performance Improvement: CENG drives for improved prevention, detection and correction of problems. CENG accomplishes this through improvements in the Corrective Action Program, self-assessment and trending; and by using significant operating experience.

Equipment Reliability: CENG drives excellence in generation reliability and predictability. CENG accomplishes this through improvements in performance monitoring, maintenance strategies, work management, and productivity.

Organizational Effectiveness: CENG drives achievements of CENG’s strategic goals

through effective leadership and alignment. CENG accomplishes this through

improvements in leadership, communications, training effectiveness, and measure and

incentivized fleet performance.

2.3 Unplanned shutdowns

2.3.1 Policy

A significant number of automatic Reactor Trips will generate pressure and temperature transients on components and structures that may be detrimental to the long term operation of the plant, requiring additional inspections and maintenance; unplanned shutdowns for maintenance or repair may increase worker radiation doses and volumes of liquid and gaseous wastes. Consequently EDF Group is committed to their reduction and eventual elimination in order to promote Nuclear Safety, Radiation Protection and Public Safety performance. 2.3.2 Systems

EDF Group’s companies adopt international best practice in this field. The international

standards and performance criteria defined in the INPO (Institute of Nuclear Power

Operations) and WANO (World Association of Nuclear Operators) constitute the foundation

used by EDF.

EDF respects, however, different practices promoted by safety organizations and national

requirements: in some countries the reactor operator is asked to anticipate the automatic

protection (this is the case in USA and UK) by undertaking a “manual scram”, in others the


operator is asked to leave automatic protections to do their job. The different approaches give

rise to differences in the comparison of indicators.

Each company regularly defines and implements action plans depending on its own strengths

and weaknesses highlighted during their safety reviews.

EDF SA‟s current action plans are focused on three aims:

Improve reliability of organization: the situations more likely to cause a scram are

identified in activity planning, risk analyses are done and responses are put in place

Improve the reliability of equipment: every failure at the origin of a scram are

analyzed, corrected and the experience is integrated into the continuous improvement

loop (AP 913 project: see §2.2)

Improve human performance: situations presenting a potential risk of scram are

identified and the efficient ways to manage them are part of the EDF project “Improve

Human Performance” (see §2.2).

At EDF Energy, according to worldwide industry accepted best practice, the implementation of

a rigorous process-based approach to plant operational management is the most effective and

robust means to ensure sustainably high safety and environmental performance including

avoidance of Unplanned Shutdowns. Three of the most important processes are:

Work Management

Equipment Reliability

Nuclear Professionalism (human error prevention)

EDF Energy Nuclear Generation has implemented Work Management best practices following

the Institute of Nuclear Power Operations (INPO) guideline AP-928 and has implementation

plans in place for Equipment Reliability best practices following the INPO guideline AP-913.

The Nuclear Professionalism program, which includes both human performance and nuclear

safety culture components, is in place throughout EDF Energy Nuclear Generation. This

program focuses on minimizing the frequency and consequences of human errors through

training, effective use of human error prevention tools, performance coaching and the

identification and reduction of organizational weaknesses through investigations into events,

incidents, near misses and performance trending of sub standard conditions.

CENG continues with strong performance in Unit Capability Factor. As a fleet it is top quartile

based on two and three year averages. This performance is due to its focus on Equipment

Reliability which results simultaneously in advantage on safety and availability. Site and fleet

level engagement in Plant Health Committees, Reactivity Management Committees and

Configuration Control Oversight reduce the challenge to Operations and provide a plant that is

less susceptible to transients.

Coupled with Equipment Reliability are Human Performance initiatives which use Dynamic

Learning Activities designed to instruct CENG staff and vendor support personnel in

behaviours needed to mitigate challenges to the plants.


Actions that CENG is currently taking are:

Plant Health Committee which focuses on the performance of systems important to

safety and brings their status to the attention of the leadership team to understand

how performance can be improved.

Reactivity Management Oversight Committee evaluates systems impacting Reactivity

Management and the aggregate effect of degraded components on the reliability of

the units.

Responding to IER L2 11-02, Reactor Trip Performance. A high impact team has been

developed to study the issues around the industry related to Reactor Trips and

developing actions to mitigate at the sites

Reporting by the sites during the daily fleet call on issues important to system health

and challenges due to emergent issues.

2.4 Safety assessment

2.4.1 Definition

A “safety assessment” is a general process used in nuclear industry to identify and to evaluate

the efficiency and the effectiveness of all the provisions implemented where safety is

concerned; it is used in numerous situations, from design to dismantling, through the

management of operation activities and many others. The assessed items can be safety

issues, means and provisions for prevention and for mitigation, provisions for control and

monitoring. A safety assessment frequently includes a risk assessment of various hazards

generated by the facility/activity itself or external hazards. So these two notions are closely

linked and it is difficult to present them separately. In the following two paragraphs the use of

safety assessment in EDF Group will be described in a large list of situations, including or not

a risk assessment; and the use of risk assessment regarding external hazards will be

described in § 2.5, as well as probabilistic risk analysis.

2.4.2 Policy

As noted in the nuclear safety policy section, the nuclear companies of EDF Group, as

operators of commercial nuclear power plants, are responsible for the safety of their workers

and the public and aim to minimize risks arising from normal operation and from any

nuclear accident due to its installations or to natural events (e.g. flooding, earthquakes,

extreme winds, climate change, fires, loss of coolant, loss of power...) to an acceptable and

achievable level in line with national and international standards and industry best practices.

The Group promotes the use of safety assessment and risk analysis in the largest variety of

situations as adequate. Its Engineering Division is fully involved in that approach.

2.4.3 Systems

Day-to-day safety assessment

In day-to-day operation, each company of EDF Group has put in place a safety assessment

process; it is a key point of an efficient organization and management (inspired by GS-R-3

and INSAG 13 of IAEA) , as well as a key point of a safety culture (inspired by INSAG 4).

As nuclear safety is the result of all the provisions made to protect people and the environment

against the release of radioactive material, the principle of successive barriers is applied for

this purpose: the fuel cladding, the reactor coolant system and the containment. To preclude


the failure of the barriers or to mitigate the consequences, the three following safety functions

must be maintained: control of reactivity, control of fuel cooling and control of the containment

of radioactive materials.

The day-to-day safety analysis during operation consists of a frequent monitoring of the

efficiency of these barriers and safety functions; it combines self-assessment by operators,

internal control by supervisors and independent verification by safety line (safety engineers of

safety-quality specialists); it is applied in every domain of work (operation, maintenance,

periodic testing). Comparing the results of verification safety tests with those carried out by

plant operators (those responsible for operation and day-to-day safety) is a very effective

means to maintain a high level of safety as well as a good way for developing a questioning

attitude and for identifying malfunctions. These safety assessments play a dominant role

during daily meetings where managers and supervisors express the safety requirements and

ensure compliance.

In EDF SA, several safety management tools have been developed over several years to

facilitate and to encourage managers and workers to carry out high level safety assessments

and to reinforce the prevention of errors during activities. These tools include:

risk analysis: identifying the plausible scenarios which might lead to a wrong result or

degradation of the plant conditions and in setting up the appropriate measures to

prevent and manage the identified risks

self-assessment: a structural and objective comparison performed by an entity

(working team or service) in order to assess its performance with respect to defined

requirements

self diagnosis: a reciprocal questioning process between for professional staff who

carry out a comprehensive review of certain joint activities (for developing individual

and team effectiveness)

safety-availability-Radiation-Protection-environment observatories (SAREOs): being

aware that the arbitration between safety and other performance factors is essential,

SAREOs analyze in each station the quality of the decision-making process and

propose actions to improve it and to guarantee compliance with rules in any

circumstances

additional inspections and audits are performed by international teams of

organizations such as the IAEA (with its OSART missions) and WANO (with its Peer-

Reviews and Follow-ups) (see below).

For CENG, the safety management system is comprised of day-to-day safety reviews

embedded in plant operating processes and periodic meetings of safety oversight committees

required by 10 CFR 50. In addition, CENG participates as a member of INPO and WANO to

receive evaluations of plant operational safety.

The attributes of the safety management system include, as examples:

Safety review of changes to plant operating licenses and technical specifications by

plant staff and NRC in accordance with 10 CFR 50.90

Safety review of changes to plant design and procedures in accordance with 10 CFR

50.59


Review of plant activities and planned configuration changes to support maintenance

using probabilistic risk analysis

Review of certain plant changes, tests, and experiments by the Plant Operations

Review Committee (PORC)

Periodic review of station safety effectiveness by the Nuclear Safety Review Board

(NSRB)

The nuclear safety culture of CENG stations is monitored and assessed in accordance with

NEI 09-07, “Fostering a Strong Nuclear Safety Culture,” implemented consistent with the 2010

NRC policy statement on safety culture.

At EDF Energy, the company vision and associated strategic objectives are implemented

through a defined organizational structure and 36 interlocking processes. For each process

there is an identified champion in the business who owns the process definition and

documentation and is charged with its continuous improvement. The whole is underpinned by

the values, standards and expectations that should inform and permeate all activities

throughout the company.

Based on the standards the processes include all the elements necessary to manage and

control nuclear power stations safely and efficiently. Alongside the processes for specific

technical activities there are processes for securing sufficient suitably qualified and

experienced staff (including training), for improving human performance and nuclear safety

culture, for implementing and monitoring governance procedures, for ensuring adherence to

regulations, for securing independent assessment of our activities, for investigating departures

from expected plant and personnel behaviour and preventing their recurrence (CAP – the

Corrective Action Program) and for driving improvement in all aspects of performance.

As you would expect for a high-hazard industry there is a particular emphasis on oversight to

monitor performance and conformity to both the internal standards and external regulations.

EDF Energy operates a multi-layer model with increasingly independent oversight being

exercised through:

Management accountability - the exercise of leadership;

In-process oversight through self checking, peer checking and self assessment as

part of its internal controls process;

Functional oversight – review and audit by company experts;

Independent internal oversight from the Safety and Regulation Division who reports to

the Board independently of the operating arm of the company

• External oversight from Nuclear Safety Committees with their external members, from peer

evaluations by teams from other utilities and WANO/INPO, from standards accreditation

bodies, e.g. Lloyds Register Quality Assurance, and from the Government’s Office for Nuclear

Regulation.

Specifically for safety assessments in EDF Energy, as part of its adequate arrangements to

comply with nuclear site licence requirements, there are the following processes:

The Maintain Design Integrity process ensures that the design intent is met and that, where changes are made to the design, this is done in a controlled manner

The Modification Process (nuclear site licence condition 22) is used to control changes to the plant and/or safety case against deterministic and probabilistic nuclear safety principles.


The Technical Governance process ensures that appropriate engineering policies, codes and standards are provided and applied.

The Periodic Safety Review (nuclear site licence condition 15) process is a periodic holistic review of the condition of the plant and of any changes to standards.

For more details on EDF Energy safety assessment processes and systems, see “Our journey towards zero harm”.

Overall safety assessment

At high management levels or for whole organizations, a safety assessment of the functioning

of the organization and its management is a process developed and promoted inside EDF

Group, while using international organizations which contribute to improve efficiency.

In EDF SA an annual safety review is carried out by the plant manager, leading to an annual

safety report. It presents the safety state of the plant (or of an engineering unit) through:

the top manager’s view on the safety management diagnosis of his site/entity

a detailed analysis based on the review of safety results, safety events analysis

(significant as well as low level), self assessment of the site and technical state of the

installations

the safety action plan.

The report is sent to the corporate level and to the NSA.

Some elements are used to prepare the safety part of the annual public report which is

presented to the Local Commission for Information and publicly displayed.


As indicated on this chart, the results of an external assessment are included in this process;

indeed such an evaluation takes place almost every year:

a WANO peer-review takes place every 4 years on each of the 19 nuclear sites in

France

one IAEA OSART takes place each year at one of EDF’s stations

and every 4 years each station receives an Overall Excellence Assessment carried

out (for the part regarding nuclear safety, radiation-protection and environment) by the

Nuclear Inspectorate Department of the Nuclear Generation Division.

The result is that each station welcomes nearly every year (19

) an overall safety assessment

which gives it an external vision and recommendations fed by international experience.

The Overall Excellence Assessment process carried out by the Nuclear Inspectorate

Department is a specific process that has been put in place for about 20 years and which has

been continuously improved. Its aim is to assess the safety level based on a comparison

between actual plant results and the reference guidelines based on the requirements of

corporate level, and to provide recommendations to the line management to improve safety

level. The areas covered by an OEA are: housekeeping, operation, maintenance, technical

support, radiation protection, fire protection, environment and chemistry, and safety

management, plus decommissioning management if appropriate.

All these process are a deep and exhaustive assessment which allows, at the corporate level,

to define orientations for enhancing nuclear safety, to benchmark and compare plants and to

improve the safety management and the global results of the fleets. They are also a good

opportunity for engineers and managers of the companies to participate in peer-reviews and

OSARTs abroad and to observe other good practices. That’s why EDF Group promotes them

and aims to increase the number of managers involved in the process.

In EDF Energy, an annual report is produced to review nuclear and radiological performance

over the year. The report presents the safety state of the plant and processes through use of

results, analysis and insights. The report is reviewed by the Safety and Oversight Delivery

Team which is a key governance body within Nuclear Generation, and the Nuclear Generation

Executive Team, and is then presented to the Licensee Board and the EDF Energy Nuclear

Generation Group Board. It is also sent to the Office for Nuclear Regulation.

CENG uses performance assessments to determine current-state performance, as well as to

define performance levels consistent with CENG’s stated vision of recognized industry

leadership. CENG performs internal assessments to critically evaluate their organizations.

CENG uses external assessments, where they are evaluated by independent organizations,

and industry benchmarking. External assessments are a resource to identify the best practices

of others, and provide a full data set to evaluate both CENG’s performance and capacity.

CENG’s internal assessment processes include quarterly Management Review Meetings

(MRM) and monthly Touch Point MRMs, structured review of Key Performance Indicators

(KPI), Quality and Performance Assessments (QPA) and audits, and self assessments. An

Integrated Performance Assessment Process (IPA) is used to synthesize all the information

from internal assessments into a comprehensive performance picture. The output of the IPA

19

Taking into account the post peer-reviews and post-OSARTs


drives performance gap closure through continuous improvement, governance and oversight,

and training activities. Each of these processes is governed by a common CENG fleet

process.

The involvement of engineers and managers from EDF Group companies in the

international organizations is a good way to learn more in term of safety management and

more largely to develop the openness to the best practices in the industry.

One of the paths to international exchange is the training of our executives within international

organizations; several dozens of executives participated this year in seminars of the Training

Academy of the INPO and to University Sessions of the WNA.

In EDF our contribution to the WANO Peer-Reviews and Technical Support Mission (TSM)

involved nearly 100 executives in 2010. More than 120 have also been involved in WANO

technical seminars. The Group aims to involve more and more representatives in international

actions, beyond the permanent secondment of 12 executives within WANO and 3 at INPO,

EPRI and IAEA. These participations allow better use and greater interest for an extensive use

of all the supports provided by these organizations in our experience feedback process.

In EDF Energy, WANO Peer Reviews are held at each of its nuclear power stations on a 3

(max 4) year frequency with an interim follow up visit to review progress. The Company

therefore typically receives 2 or 3 peer reviews per year with a similar number of follow up

visits. Corporate peer reviews are also held periodically.

Each peer review has two primary outputs:

A report which identifies areas for improvements (AFIs) which describe gaps between current performance and excellence. These are supported by factual evidence and an analysis of the causes which underlie performance gaps.

Since 2010, a separate report which reviews station progress in addressing WANO Significant Operating Experience Reports (SOERs) recommendations.

During follow up visits, WANO assesses progress made by stations in addressing AFIs

identified during the previous Peer Review.

In conjunction with WANO, INPO and IAEA, EDF Energy also provides support to, and is

supported by, technical support missions, self assessments, operating experience feedback,

benchmarking, workshops and seminars, performance indicators and secondments.

The EDF Group Engineering Division of EDF is fully involved in safety assessments and

improves the capacity of the Group to look for excellence and to study and implement

solutions to the main technical issues, specifically:

in expertise and design of the new generation of reactors, including technical progress

in safety and environment areas (studies on Generation 3 and Generation 4)

in construction of new plants and new projects; e.g. EDF has put in place a dedicated

organization to take the best advantage of consistency between all EPR projects

(Finland with AREVA, France, UK and China), including relationships with safety

authorities concerned by these projects, and also experience gained during

construction and coming tests


in supporting existing fleets when needed in operation (e.g. to find and implement

solutions when failures occur or to replace main components in the case of life

duration issue) including relationship with safety authorities

in the assessment and review of safety within periodic safety assessments or through

feedback generated by significant events and accidents, including the assessment of

natural risks (e.g. 400 engineers have been involved in safety assessment and

reinforcement studies following the Fukushima accident)

in decommissioning studies (within the licensing process, or during operation)

EPR, our third generation reactor

The EPR, a PWR type, belongs to the third generation. This new reactor is even safer, more

environmentally sound and more powerful than its predecessors. Thanks to its evolutionary

design, it is able to incorporate the operating experience accumulated by French and German

designers and operators over more than 30 years. With a capacity of 1,650 MW, it will

consume 17% less fuel, thanks to the use of more efficient fuel assemblies and greater turbine

efficiency.

Although the likelihood of a severe accident with core melt occurring in existing reactors is

extremely small, it is further reduced by a factor of ten in the EPR. If such an accident were to

occur, a facility especially designed to recover, contain and cool the molten core has been

installed below the reactor vessel. This facility would mitigate the environmental

consequences of such an accident.

Four parallel and physically segregated safeguard systems fulfil a triple function: they prevent

loss of control over the nuclear reaction; they maintain the reactor cooling function in any

circumstances, and in the event of an accident, they control pressure and temperature

increase in the reactor building. That building is more tight and resistant than its predecessor

(double wall and metallic skin).

Similarly, in order to guard against external hazards, a concrete shell covers the most

sensitive parts of the facility: the reactor building, the fuel building, the main control room, two

of the four safeguard buildings and two trains in the pumping house.

The environmental objectives set for the EPR are ambitious, calling for measures to minimize

the impact of plant facilities on the environment. During normal operation, chemical and

radioactive releases (20

) to the environment will be reduced by at least 30% per MWh

generated. Furthermore, the reactor’s higher burn-up rate, and core design will reduce the

quantity of radioactive waste on a like-for-like basis. The EPR will generate about 30% less

(21

) radioactive waste than 1,300 MW reactors.

20

Excluding tritium and carbon 14, which will be released in the same quantities as they are on existing plants

(quantity proportional to energy produced)

21 In volume, which is the dominant criteria for the design of the final storage; the higher power capacity and

higher radioactivity has to be taken into account in the duration of intermediate storage in pools


2.5 Risk assessment

2.5.1 Policy

The nuclear safety case includes risk assessments of:

Plant based faults, e.g. loss of coolant, loss of power…

Internal hazards e.g. steam release, fire…

External hazards, e.g. climatic conditions, flooding, earthquakes…

There is a fundamental legal requirement for risks to be ALARP (As Low As Reasonably

Practicable). Some countries impose a maximum risk level (e.g. probability of core melting).

The responsibility to conduct thorough and deep risk analysis is fully recognized by the Group

which uses the process as a fundamental tool to continuously reinforce the safety standards in

its nuclear power plants.

2.5.2 System

Managing the risk as an overall process

For many years EDF Group has pursued a policy of managing its operational, financial and

organizational risks. In 2003, the Group decided to implement an overall process for managing

and controlling its risks and reinforcing existing plans, in particular by creating the corporate

Risk Management Division (RMD). The objectives of the management and control policy are

to allow identification and ranking of risks in all domains to gain increasingly firm control over

them, under the responsibility of operational management; that policy allows officers, directors

and the Group’s governance bodies to have a consolidated view, regularly updated, of the

major risks and their level of control. RMD implements an annual program of audits on a large

range of issues, linked to the previous ranking of risks.

That approach is put in place in each division and company of the Group. In EDF SA Nuclear

Generation Division, the approached is applied to almost (22

) all processes and projects. Each

risk is identified and assessed and mitigation actions are undertaken.

Periodic safety assessment in nuclear plants including risk analysis: The nuclear power

stations were constructed to the best contemporary advice, including national and international

standards and guidelines, and each entered service with a single document summarizing its

safety case. The stations are expected to operate for a number of decades, during which

guidelines have and will change. In addition there are numerous changes to plant and

procedures at each station, each of which is separately documented and represents a small

evolution in the safety case.

The entire safety case, including risk assessments of plant based, internal and external

hazards, is therefore reviewed at intervals against current national and international standards

which set industry best practice e.g. IAEA. The review also encompasses operating

experience gained within the company, the global nuclear industry (e.g. following TMI,

Chernobyl and Fukushima) and through global high hazard industry events. The review

process, which is referred to as Periodic Safety Review, is carried out at intervals of

approximately 10 years (23

) under the control of safety authorities. These reviews may identify

22

17 among 22 processes and projects

23 In France and UK


shortfalls with respect to current guidelines. All reasonably practicable improvements identified

by the review are implemented, to bring the stations within the current guidelines. In the UK,

the review is submitted to Office for Nuclear Regulation (ONR), an agency of the Health and

Safety Executive (HSE) for their consideration and, if appropriate, agreement to any proposed

changes to the safety case. In France, the safety improvement targeted by the NSA is

previously established and is the basis for the NSA to deliver its opinion and the eventual

complementary requirements in order to operate the unit for a further 10 years. That process

allows the oldest plants to be compliant (or quite compliant) with the current guidelines applied

to new reactors.

In USA, risk is addressed both through the regulator (NRC) and each reactor operator. The

NRC’s Reactor Oversight Process (ROP) assesses plant performance continuously through

use of performance indicators and inspections which are based on risk with respect to public

health and safety. Performance indicators include availability of key systems and unplanned

reactor scrams. Inspections include detailed evaluations of the design, maintenance, and

operation of risk significant structures, systems, and components once every 3 years.

Performance indicators that do not meet pre-described criteria and significant findings that

result from inspection activities require a detailed response to the NRC. The NRC’s

assessment of performance is provided to each reactor operator once every 6 months.

In addition to the regulator, each reactor operator assesses risk on a daily basis through use

of risk assessment tools and consideration of industry operating experience. This ensures

that activities are planned and coordinated to minimize unavailability of key equipment. Plant

improvements are also identified (e.g., modifications, procedure changes) and implemented as

appropriate to further reduce risk.

Adaptation to climate change

As a part of its Sustainable Development Policy, an overall climate change adaptation

strategy was adopted by the EDF Group in 2010. The strategy aims to bring together in a

consistent way all the works, actions, studies and research to implement across the whole

Group in order to identify all the activities impacted by climate change and all the means and

processes by which to reinforce our robustness and our resilience to extreme climatic

phenomena. We recognize that we have to adapt our existing industrial facilities and networks

that will have to remain safely operational over several decades, and to design our fleet and

new installations now to cope with the coming effects of climate change that will be seen

during their life. That strategy will include all studies and modifications done or to be done on

nuclear facilities regarding main sensitivities, such as:

robustness of our networks, following damage caused by storms since 1999

robustness of our plants during heat waves: after hot summers in 2003 and 2006, a

specific program of modifications called “Hot Conditions” was launched on all the

French plants, which a short-term program already implemented, and a medium-long

term program to be integrated in periodic safety reviews

robustness against flooding: after the flooding of Blayais nuclear plant, in 1999, a

safety review was launched for all nuclear facilities, taking into account increased

water level and new combinations of effects, and some protections have been

reinforced on French sites (both coastal and those on rivers); that program has

anticipated the post-Fukushima review and will merge with it


management of water resource: EDF laboratories have been working closely with

climate and meteorology experts to better forecast the availability of water resource

for our hydro plants and thermal stations (including nuclear ones). Special

organizations are already in place to manage water and to better coordinate all the

water users during dry periods (in order to prioritize support of flow or reduce power

generation during critical periods). Studies are on-going to find less sensitive cooling

systems and to find temperature regulations which would be better adapted to the

coming conditions.

Lessons learned from the Fukushima accident

Although all the details of the accident are not yet fully known, it is clear that it revealed

several important failures in the design of the Fukushima station and in the management of

the situation caused by the tsunami:

The magnitude of the earthquake was greater than the design assumptions. While the

reactors appear to have suffered little damage from the seismic shocks (scram

shutdowns and start-up of emergency diesel generators functioned as planned), the

earthquake caused a total failure of external power supply

The magnitude of the tsunami was also greater than the design assumption. It caused

the destruction of heat sink and the total loss of back-up power systems

The operating team met great difficulty managing the reactor containment dry well in

a situation of severe accident; that led to major discharges of radioactivity and

hydrogen explosions

Ultimate external resources in sufficient quantity were missing and prevented the

operating team from quickly recovering the situation.

The companies of EDF Group have mobilized their engineers in France, in the UK, in the USA

and in China, in close relation with the respective safety authorities and under their control,

and in relation with all the international organizations involved in experience feedback (INPO,

NEI, IAEA). According to the processes put in place by the safety authorities, they have

provided reports analyzing the capacity of their plants to resist comparable situations

(earthquake and/or flooding, more likely than tsunami, except in China) and to face the loss of

cooling and power in a severe situation.

In France the NSA asked these reports for mid September, in the framework of the European

“stress tests”. Reports have been provided on time, thanks to the involvement of 300

engineers during four months; these reports are public (24

). They present a reassessment of

the existing resources and responses, and a further analysis, beyond the referential, of the

efficiency of protections (e.g. existing margins) and of the capacity to face extremes situations.

Following this work, EDF confirms the presently good level of safety for all nuclear facilities,

mainly thanks to the initial design and to the periodic safety assessments which have led to

improve the robustness of the plants and to integrate the experience learned from previous

accidents and incidents. In order to improve even more the good level of safety, EDF has

presented proposals for the implementation of complementary defences: reinforcement of

protections against hazards (earthquake and flooding), equipment (additional electricity source

and water reserves), and additional measures in case of core meltdown (reinforcement of

24

Available on the web site of the French NSA (www.asn.gouv.fr)


existing filters). EDF also intend to reinforce the crisis management by putting in place a

Nuclear Rapid Response Force (specialists able to intervene within 24h in support of local

teams, with back-up equipment, in particular in the case of a multi-unit emergency situation).

These reports are currently analyzed by the NSA and a response is expected at beginning of

2012.

In the UK, EDF Energy immediately conducted a safety review using formal mandatory

evaluation process, considering within and beyond design basis situations, and reviewing

physical equipment, systems and processes. The initial conclusion was that all EDF Energy

plants were safe to continue to operate. EDF Energy, as EDF SA, based its review on the

scope and methods of the “stress tests” demanded by the European Commission”. It

submitted eight reports, one for each station, on 31th October, after having worked closely

with other British operators and with EDF engineering division, in particular for the case of

Sizewell, the only PWR in the UK, and for Gravelines and Dungeness B stations, the closest

sites on both sides of the Channel, where a consistent approach has been used for

earthquake and flooding. Several proposals have been presented to reinforce the resilience of

the plants and minimize radioactive releases in case of severe accident, and also to provide

back-up equipment. ONR will produce final national report mid 2012. The implementation of

the response phase will start by Q1 2012.

In the USA, the NRC, after three months of work within a task force, assessing the safety

robustness of the US plants with regard to natural hazards and severe accident management,

concluded that they were safe but emitted 34 recommendations to still reinforce their safety.

On its side, the nuclear industry has promptly verified the systems, equipment and procedures

protecting US plants against natural hazards and mitigating potential damages. CENG has

taken a leading role in the United States nuclear energy industry to ensure that lessons

learned from the Japanese events result in safety enhancements at the U.S. plants. A

Fukushima Response Steering Committee was formed comprised of senior U.S. electric utility

executives, reactor vendors and their affiliated Owners Group, Nuclear Energy Institute (NEI),

Institute of Nuclear Power Operations (INPO), and the Electric Power Research Institute

(EPRI). That Committee has drawn consistent conclusions; some items can be addressed in

the short-term, but industry asked for flexibility and performance-based approach, similar to

the one following September 11th, 2001 (orders are in progress for electrical and water

supplies portable equipment). Works are pursued with EDF engineering to assess the

robustness of safety analysis and additional measures.

In China, the government announced in mid-March a series of decisions for the self-

assessment of nuclear power plants as well as national safety inspections of plants in

operation and under construction, to be completed in August. Moreover it has deferred

approvals on any new nuclear project, waiting for a “Nuclear Safety Plan” in early 2012. On

their side CGNPC and EDF, working together, identified possible improvements to implement

on their stations as: seismic and weather forecast and warning systems, reinforcement of the

capacity of existing hydrogen absorbers and filters, power sources and mobile pumps, drills

and training, under a multi-unit emergency plan. In the specific case of Taïshan, the

consistency with Flamanville 3 has been verified and has confirmed the interest of mobile

emergency resources (pumps, EDG, water storage) and the improvement of safety functions.

18 design modifications or topics have been submitted to the NNSA.

Emergency preparedness: inside the global framework of risk management previously

described, RMD is in particular in charge of emergency preparedness and crisis management

organization at Group level, each division and nuclear company in the Group remaining


responsible for its own crisis organization. Exercises are organized regularly (in relation or not

with safety authorities) and give the opportunity to benchmark between the companies.

In France, in the event of an accident, an emergency organization is in place to limit impacts

on the environment and on people. To ensure the safety of the installation and the protection

of people, the system is based on two closely coordinated plans, designed for both local and

national use. These are the Internal Emergency Plan (Plan d’Urgence Interne, or “PUI”),

prepared by EDF and the Special Intervention Plan (Plan Particulier d’Intervention, or “PPI”),

prepared by French prefectures in collaboration with the French state and EDF. In order to

provide greater effectiveness and thus improved protection of populations these plans account

for the risk of malicious acts. The relevance of the system for warning, informing and

protecting people is regularly assessed through accident simulation exercises, which make it

possible not only to ensure the correct operation of the crisis plan, but also to improve upon it,

in particular, by clarifying roles and validating all of the required physical and human resources

(decision making process, centralized technical support, communication capacity, anticipation

capacity,..). Each year, approximately 100 exercises are organized for the entire French

nuclear fleet, i.e., approximately one every three days. Approximately 10 exercises are on a

national level, under the management of the NSA and involve EDF and the public authorities,

in particular the prefectures. As a lesson learned after the first exercises and in order to better

protect children against exposure to radioactive iodine in case of accident, stable iodine

tablets have been pre-distributed in a perimeter of approximately 10 kilometres. As a

consequence of the Fukushima accident, the centralized support will be reinforced in 2012 by

technical equipments and by qualified staff. It will be sent to the station where an emergency

situation is supposed to have occurred.

In the US, America’s nuclear energy facilities are designed and built to safely withstand a wide

variety of natural and other severe events and staffed by highly trained, federally licensed

operators with a five-decade history of safe operations in the United States. The operators

who staff these facilities are capable of taking the actions necessary to mitigate and control

adverse events. An emergency plan provides multiple layers of protection by specifying

additional measures that may be taken in the event of a severe accident.

An effective emergency response is the product of mutually supportive planning and

preparedness among several parties: companies that operate the plants; local, state, and

federal agencies; and private and non-profit groups that provide emergency services.

U.S. federal law required nuclear operating companies to create an on-site emergency

response plan for their nuclear energy facilities and to ensure that emergency preparedness

plans are in place to protect the public. The U.S. Nuclear Regulatory Commission approves

on-site plans, while approval of off-site plans is coordinated between the NRC and the Federal

Emergency Management Agency (FEMA). These plans must be approved for a plant to obtain

and retain an operating license from the NRC.

Emergency plans for nuclear energy facilities continually evolve. This includes incorporating

lessons learned from the terrorist attacks on September 11, 2011. The plans can be

implemented during a wide range of severe natural events or security-related events.

A 10-mile emergency planning zone (EPZ) to protect communities near the facility from

radiation exposure in the event of an accident.

A 50-mile zone within which food products, livestock and water would be monitored to protect

the public from radiological exposure through consumption of contaminated foodstuffs.


Within the 10-mile EPZ, the main, immediate protective actions for the public include

instructions for sheltering in place or evacuation. The slow pace at which an event may unfold

– over several hours or days – provides time for orderly sheltering or evacuation, if necessary.

Supplemental protective actions within this zone might include the distribution of stable iodine

tablets to protect the thyroid gland from radioactive iodine. Within the 50-mile zone, the federal

and state governments may monitor and test all food and water supplies that potentially could

become contaminated and remove from public consumption any found to be unsafe.

While both zones were established for planning and preparedness purposes, state

government response directors have the discretion to designate specific protective actions

beyond these zones, if needed.

The NRC conducts inspections of the CENG emergency plans annually. CENG conducts

continuing training of its emergency response organization and conducts drills and exercises

to test abilities at least four times per year at each site. Every two years at each site, the

NRC, FEMA, and the states participate in integrated exercises to evaluate coordination

between CENG and government agencies during an emergency.

At nuclear fleet level of EDF Energy, Emergency Plans are exercised regularly. Within Nuclear Generation, each shift is exercised at least once per year, and one in-depth exercise is required to demonstrate to ONR the adequacy of the on-site emergency arrangements at each power station. These 'Level 1' exercises are witnessed by the ONR and focus on the actions of the operator. Emergency services are invited to participate to provide a mutual learning opportunity and to add realism to the on-site actions. Level 2 and 3 exercises are aimed at the operation and testing of the off-site emergency plans. Level 2 exercises primarily test the local off-site plan for each station every three years. These exercises enable those agencies with a responsibility in the response to exercise and review their arrangements. Annually one of the national program of Level 2 exercises is selected for the purposes of testing the national level response plan. In addition to the Level 2 activities, this involves the setting up of the Nuclear Emergency Briefing Room in Whitehall, or the Scottish Government Emergency Room. Regulatory exercises are also required to satisfy the nuclear security regulations and the transport of radioactive material. In addition to the regulatory exercises, sites have tested various aspects of the emergency plans during approximately 100 shift exercise and training drills. The lessons from all exercises have been shared across the fleet and used in revising emergency plans and future exercise program.

2.6 Radiation exposure (to workers and the general public)

2.6.1 Overview on the regulatory context

In Europe the current legislation (Euratom Directives 96/29) is inspired by the publications of

ICRP (International Commission on Radiological Protection) which establish the scientific

fundamentals of radiation protection. All the national regulations (including the French and

British ones) based on the European regulation integrate the three fundamental principles of

Radiation Protection), which are:


Justification principle: no practice implying an exposure to ionizing radiation shall be

adopted unless its introduction produces a positive net benefit on population as a whole

(i.e. advantages deriving from the practice shall be greater than disadvantages).

Optimization principle: using the words of ICRP, ‟all the exposures shall be kept As Low

As Reasonably Achievable (ALARA), economic and social factors being taken into

account”. It means that all reasonably practicable measures to reduce radiation exposure

shall be taken.

Individual dose limitation principle: the dose to the individuals “shall not exceed the limits

recommended for the appropriate circumstances”. These limits are chosen and proposed

by ICRP for workers and individuals of population to dose levels corresponding to a

negligible risk level. French and British legislations have fixed the same limits: 1mSv per

year for public and 20 mSv per year25

for the workers.

In the United States of America Title 10 of the Code of Federal Regulations part 20

establishes the standards for protection against ionizing radiation from activities conducted

under licenses issued by the Nuclear Regulatory Commission. It is the purpose of this part to

control the receipt, possession, use, transfer, and disposal of licensed material by any

licensee in such a manner that the total dose to an individual (including doses resulting from

licensed and unlicensed radioactive material and from radiation sources other than

background radiation) does not exceed the standards for protection against radiation

prescribed in the regulations in this part. However, nothing in this part shall be construed as

limiting actions that may be necessary to protect health and safety.

The licensee shall control the occupational dose to individual adults to the following dose

limits:

(1) An annual limit, which is the more limiting of--

o (i) The total effective dose equivalent being equal to 5 rems (50 mSv); or

o (ii) The sum of the deep-dose equivalent and the committed dose equivalent

to any individual organ or tissue other than the lens of the eye being equal to

50 rems (500 mSv).

(2) The annual limits to the lens of the eye, to the skin of the whole body, and to the

skin of the extremities, which are:

o (i) A lens dose equivalent of 15 rems (150 mSv), and

o (ii) A shallow-dose equivalent of 50 rem (500 mSv) to the skin of the whole

body or to the skin of any extremity.

The licensee shall use, to the extent practical, procedures and engineering controls based

upon sound radiation protection principles to achieve occupational doses and doses to

members of the public that are As Low As Reasonably Achievable (ALARA). ALARA means

making every reasonable effort to maintain exposures to radiation as far below the dose limits

in this part as is practical consistent with the purpose for which the licensed activity is

undertaken, taking into account the state of technology, the economics of improvements in

relation to state of technology, the economics of improvements in relation to benefits to the

public health and safety, and other societal and socioeconomic considerations, and in relation

to utilization of nuclear energy and licensed materials in the public interest.

25

More precisely in French regulation: “per period of 12 consecutive months”


Each licensee shall conduct operations so that -

(1) The total effective dose equivalent to individual members of the public from the

licensed operation does not exceed 0.1 rem (1 mSv) in a year, and

(2) The dose in any unrestricted area from external sources does not exceed 0.002

rem (0.02 mSv) in any one hour.

2.6.2 Policy

Despite differences between national regulations, the common approach of the nuclear

companies of EDF Group is to ensure as a minimum, compliance with all applicable

regulations, to continuously improve our practices well beyond the requirements, to

emulate nuclear industry best practice, and to work together with our industrial

partners to a common fleet standard which takes into account technical differences

among our plants. We strive to ensure that any exposure to ionizing radiation is kept as low

as reasonably practicable (ALARP) beyond the requirements, to reduce individual and

collective radiation doses and prevent any worker, with any distinction between company or

subcontractor staff, or any person in the vicinity exceeding a statutory radiation dose limit.

Moreover, regarding more specifically the protection of the environment (including the

minimization of the effects of the operation of the plant on humans), EDF Group has adopted

in 2009 an overall Sustainable Development Policy which contains a target of “minimizing

by continuous improvement the impact of our activities on the environment” (see § 3.1).

2.6.3 Systems

To reach their goal consisting in continuously reinforcing the radiation protection of

workers, the means and processes used by the companies include:

Efficient operation of the facility and all the systems which contribute to the lowest

radiation level inside the premises of the plant (e.g. decontamination phase at the

beginning of an outage in PWR plants, monitoring of the cleanliness of controlled

areas, implementation of protective shields,..)

Specific work preparation when there is a planned exposition to radiation, with risk

analysis, support and control of specialized staff

Adequate radiological protection monitoring instrumentation and personal equipment

provided to staff working inside controlled areas

Wearing of personal dosimeters (eventually doubled by radiological films compliant

with local regulations)

Adequate procedures in case of alarm, concerning both the workers, the field

supervisors, and the operating shift

Adequate mandatory training and good practice promotion for all workers (e.g. on

simulators and specific workshops), whether direct employee or contractor.

Some most recent actions completed or ongoing action-plans, aiming to correct weaknesses

and still improve the performances, include:


EDF has had in place, for some years, a specific program to prevent incident in the

case of hazardous situation (red or orange zone entrance, radiographic tests,..)

EDF, under the “Charte de progrès” signed with subcontractors and professional

organizations, implements actions in order to reduce the number of workers exposed

to more than 10 mSv per year (16 mSv per year a few years ago) and to guarantee

the same quality of medical monitoring. More generally, under that common

agreement, EDF and its industrial partners gave the same priority and the same

commitment to the improvement of radiation protection and exposure prevention

EDF have been implemented for several years a specific program to improve

radiological cleanliness: reinforced rules during works, complementary investments in

more efficient and numerous contamination detectors, benchmarking and rating of the

sites

EDF Engineering Division implements programmes for future reactors to determine

the best technical choices in favour of the reduction of doses (chemical conditions of

reactor coolant, presence of cobalt in steam generator tubes alloy and in valve’s

stellite,..)

EDF Energy launched an instrumentation replacement program, for installed and

portable radiation and contamination instrumentation; the new one is more sensitive

and aligned to international standards

EDF Energy is also currently implementing a program to align radiographic testing

with best practices, together with its contract radiography companies

CENG has had success with reducing source term, improving radiation worker

behaviours and improving its ability to direct work remotely. The programme was

launched to reduce the level of collective dose and has resulted in individual exposure

being much below the mandatory limits, in accordance with its internal policy: no

worker is exposed now to more than 20 mSv (see details in §5.2).

Regarding the minimization of the doses to the public, the companies of the Group use a

wide array of means and processes, from the design itself to the optimization and control of

effluents generation (and also their treatment) and the monitoring of the environment of the

plant (including radio ecological study):

At the design stage, the fission products contained in the core are surrounded by

three barriers: the fuel cladding, the reactor coolant system and the containment. The

tightness of these barriers is strictly controlled during operation; the Technical

Specifications for Operation define the acceptable limits for certain parameters used

to monitor the tightness of these barriers and also stipulate the action to be taken if

these limits are reached. The tightness of the barriers is a fundamental parameter

included in safety assessments carried out as described in § 2.4.3.

Moreover several fundamental checks are also implemented within maintenance

programs such as: non-destructive checks of each re-used fuel assembly, resistance

and tightness check of reactor coolant system, periodic test of robustness and


tightness of the containment building (in addition of permanent monitoring during

operation) and of all the isolation devices

Because of the normal activation of water and gas used for reactor cooling, several

types of equipment (26

) are in place to treat continuously that coolant and all the liquid

or gaseous effluents collected in the station, with the goal to re-use them as much as

possible and to minimize the residual radioactivity of these effluents before being

released in the environment. The efficient running of these equipments is strictly

controlled.

All the release lines (ventilation shafts, drainage pipes of effluent reservoirs) are

equipped with measurement devices; compliance with limits imposed by regulations

and by OTS is strictly controlled. Regardless of their origin (Reactor Building, Fuel

Building, Nuclear Auxiliary Building, laundry, Turbine hall, etc.), releases and

discharges that are liable to be radiologicaly contaminated are always stored, and

tested before and during release.

The residual radioactivity released is closely monitored through frequent and accurate

analyses performed on all environmental compartments (terrestrial: grass, milk,

agricultural production, or soils; Aquatic: water (surface and sea), groundwater,

sediment flora and fauna samples, and; Air: atmospheric dust, ambient gamma dose

rate, rainwater) collected from around the stations. Moreover, some stations equipped

with several types of measurement devices and automatic transmissions are installed

in the vicinity of the stations. All the results of that overall monitoring are displayed to

regulation authorities, and to the close community.

All the companies of the Group aims to reach the best environmental performance in

the industry by reducing the radioactivity released as low as reasonably achievable;

they use for that the international experience they found within the Group and through

contact with international organizations. The improvements are found in a wide range

of domains: operational mode, chemistry, maintenance, efficiency of treatments.

Impressive improvements have been made since the first years of operations (by

more than ten in general) and the impact of the operation is currently very well below

administrative limits and is merging with natural variations of the ambient radioactivity

(see § 4). The good results now achieved (ie : Levels of radioactive releases divided

by 100 in France (excluding 3H and

14C) since 1984) testify to the efforts made by EDF

(more rigorous management, reduction at source, improvement of collection systems)

over more than 20 years to optimise discharges and minimise their impact, both on

the environment and on the public. These efforts are obviously being continued to

ensure that the NPPs maintain, or further improve, their performance in this area, as

limiting these releases protects the environment.

26

Filters, storage tanks for natural decreasing of gases radioactivity, evaporators, demineralisators,..


2.7 Security

2.7.1 Policy

EDF Group recognizes the value of the people, physical assets, nuclear fuel, information and

systems that contribute to its business and the need to protect them. Security is about

protecting our physical and intellectual property, our staff and the public from any potential or

actual event which could adversely affect the confidentiality, integrity or availability of our

infrastructure and information as well as the personal security and safety of staff and the

public. Regarding the risk of stealing or misuse of nuclear fuel, the companies respect the

requirements expressed by international organizations (IAEA, EURATOM) complemented by

national regulations and requirements. The companies aim, when it is achievable, to enhance

their protection, taking into account the evolution of threats on the one hand and the

contribution of public security forces on the other hand.

2.7.2 Systems

Based on a large panel of threats, from malicious behaviour to cyber criminality and terrorism,

there is a series of safety and security measures in place at each of our power stations in

addition to the inherent physical security provided by the very robust design of the nuclear

reactors. According to local laws and requirements, access to nuclear power stations is strictly

controlled and armed guards or forces are deployed at all nuclear sites to complement existing

security measures.

Confidentiality on the details of these measures is a key point of its efficiency; the reader shall

understand that it is not possible to describe more. In each country, the efficiency of the

protection measures is strictly controlled by dedicated administration or by the safety authority,

and by international inspectors (IAEA, EURATOM); these measures are periodically reviewed

and eventually reinforced, depending on the threat and on the initial robustness of the

protection (e.g. after 2001 September 11th)

3 Waste

3.1 Overview

The real or potential radiological impact of the operation of a nuclear plant on its environment

is of several forms and origins:

Highly radioactive material being produced inside the fuel assemblies of the core of

the reactor, the first source of radioactive waste is the fuel itself; certain radioactive

materials that are produced are of very high activity and very long life. That is the

reason why the management of that fuel is of very high importance and gives rise to

two issues: the choice of reprocessing (27

), or not, that fuel and the choice of storage

(nature and organization, a decision made by nations) of the solid waste generated

(the fuel assemblies themselves or the ultimate waste generated by the retreatment)

27

Industrial process for separation of different categories of products: uranium (95%) and plutonium (1%) for

recycling, and ultimate waste (4%) for packaging in a sturdy matrix with as low volume and radiotoxicity as

possible


Solid waste are also generated by the equipment that treats and filters contaminated

waters and air (filters, resins, mud) or during maintenance (plastic, rubble and

damaged protective clothing); these wastes are processed and encapsulated in

sealed packages generally on the plant’s site, to prevent any uncontrolled release of

radioactivity into the environment. Levels of radioactivity and life duration are much

lower than in the first category

When treated in a proper and efficient manner, liquid and aerial effluents contain very

low quantities of radioactivity and may be released into the environment under strict

regulation and control (see § 2.6).

In France, the public strategy is to reprocess spent fuel coming from nuclear facilities (mainly

in AREVA NC plant in La Hague (Normandy)) and to re-use fissile material extracted during

that process. The aim is “to reduce the quantity and the harmfulness of radioactive waste,

while recycling the valuable matters as uranium and plutonium”. The method for the storage of

nuclear waste depends on its degree of radioactivity and its nuclear activity period. In addition

to certain temporary storage on EDF sites, very low-level waste produced by EDF (for

example, concrete or metal waste left over after decommissioning a nuclear power plant) is

stored on an ANDRA site opened in 2003 (the “CSTFA”). Short life, low-or intermediate-level

waste that is produced by EDF’s operations is stored above ground at ANDRA’s Aube storage

centre (the “CFMA”). Long life, high-level waste produced from the reprocessing of spent fuel

is vitrified and stored temporarily and safely at the AREVA NC centre in The Hague pending

the adoption of a long-term management solution (public decision expected around 2014 for a

storage centre commissioned around 2025). Long life, intermediate-level waste (for example,

from shells, nozzles, sheeting, etc.) is either cemented or compacted and confined in stainless

steel containers. They are currently in intermediate, temporary storage pending a final

decision concerning long-term management.

In France, as an operator and producer of waste, EDF SA is legally responsible for spent fuel

from the moment it leaves the power plant, during its processing operations and during its

long-term management, and it assumes this responsibility in accordance with guidelines set

by public authorities and under their control. Each year, EDF makes provisions for the back-

end of the nuclear fuel cycle in France which covers the management of spent fuel and the

long-term management of radioactive waste. To calculate the cost of future management of

long-life, intermediate and high-level waste from the processing of spent fuel, EDF assumed

deep geological storage of waste, pursuant to the law of June 28, 2006 which established the

storage of waste in deep geological layers as a reference solution. For long-life, low-level

waste, from the decommissioning of shut-down graphite-gas power plants, provisions are

established by EDF from the schedules of production of these wastes and cost assumptions

relating to the terms of storage defined by ANDRA. The cost of removing and storing short-life

intermediate and low-level waste and very low-level waste is determined on the basis of

contracts entered into with ANDRA and the various carriers for the operation of existing

Storage Centres. The costs of disposal and storage of waste from the decommissioning of

power plants are provisioned, with the charges relating to operating waste being recognized in

annual expenses. The 2006 law on nuclear waste applies to the Government to draw up every

3 years a National Plan on Management of Radioactive Materials and Waste (PNGMDR in

French); under this Plan, EDF, as well as the other producers of radioactive waste, disclose all

the data available on the waste it stores itself or it has sent to ANDRA; the complete plan and


a synthesis are published by the NSA on its web site (28

): in this way, information on quantities

and ways of management of the different categories of waste are available for the public.

In the UK, the public strategy is to give the role of spent fuel and nuclear waste management

to a public agency, the Nuclear Decommissioning Authority. EDF Energy Nuclear Generation,

as owner operator and licensee, remains responsible for ensuring the safe decommissioning

of all its power station sites. The company policy and strategy objective of decommissioning is

to return the power station sites to a state suitable for unrestricted alternative use. The funding

for EDF Energy Nuclear Generation power station decommissioning and waste management

is coming from the Nuclear Liabilities Fund (NLF) and EDF Energy /EDF Group Accounts. The

decommissioning strategy, policy and plans are subject to regular review. At minimum, a 5

yearly review of the plans is undertaken. It should be noted that, no decommissioning has yet

been carried out for any of EDF Energy Nuclear Generation power station sites. Power station

decommissioning, following a planned end of generation, remains some years off. However,

detailed baseline decommissioning plans for each of EDF Energy power stations are in place.

These plans have been developed over a number of years / iterations and have been formally

approved by British regulators and NDA.

In the UK, nuclear waste is classified under three headings: Low Level Waste (LLW),

Intermediate Level Waste (ILW) and High Level Waste (HLW). LLW are either sent for

treatment (e.g. volume reduction by supercompaction) or disposed of at the Low Level Waste

Repository (LLWR) in Cumbria, and a small amount of combustible waste is sent for

incineration at Hythe. ILW is stored for the medium term in safe, purpose built facilities at EDF

Energy’s stations while a longer term National solution is established. Under historic

contractual arrangements spent fuel from the Advanced Gas-cooled Reactors (AGRs) is

transported to Sellafield for reprocessing or storage, and spent fuel from Pressurised Water

Reactor (PWR) remains on site. HLW comes from the reprocessing of AGR spent fuel at

Sellafield. HLW is converted into glass blocks for safe, long term storage at Sellafield, At

Sizewell B PWR station, the spent fuel is stored on site and EDF Energy is planning to build a

further storage facility to allow the station to continue to safely store all of the spent fuel that

will be generated over Sizewell B’s life. The approved strategy for Sizewell B fuel

management consists of an ISFSI Dry Store concept to store spent PWR fuel in HOLTEC

metal flasks held on a concrete pad within a hardened building. To accommodate the 2280

assemblies that make up the current lifetime arising, 80 flasks are required.

In the USA, in accordance with the Nuclear Waste Policy Act of 1982 (NWPA), CENG is a

party to the contracts entered into with the United States Department of Energy (DOE). As

such, CENG has since November 2009 paid the contributions stipulated by the NWPA to fund

the cost of construction by the DOE of a federal storage for final disposal of spent fuel (CEG

having paid these contributions until November 2009). Since the DOE stated that it could not

take possession of spent fuel before 2020 (instead of 1998 as originally called for in the

contracts), CEG and later CENG, has been forced to undertake additional actions and incur

costs to provide on-site fuel storage, allowing the operation of its plants until the availability of

a federal storage facility. CENG has also made provisions for its long-term nuclear waste

management commitments.

28

http://www.french-nuclear-safety.fr/index.php/English-version/References/National-plan-on-management-of-

radioactive-materials-and-waste-PNGMDR


3.2 Policy

Regarding radioactive operational waste, the environmental policy of EDF Group is to

reduce the generation of waste to a practicable minimum and to maintain radiation

doses to the workforce and to the general public from radioactive waste management

operations, including transport and disposal, within legal limits and As Low As

Reasonably Achievable. The management of waste is focused on reducing, re-using, and

segregating waste for recycling in priority (in the framework of possibilities given by the

regulators). Moreover EDF Group has the ambition to contribute to the emergence of an

overall nuclear waste management solution in a long term vision that is safe and

socially acceptable.

That policy, regarding radioactive waste, is consistent with the Sustainable Development

Policy adopted in March 2009 by EDF Group. The Group is committed to taking action to limit

the impacts of its facilities and all its activities on human health and on the environment. EDF

Group will manage and monitor its impact using an environmental management system

certified to ISO14001. This includes giving priority to safety in all hazardous activities,

compliance with existing regulations, pollution prevention and research to support our

commitment of continuous improvement of our environmental performance. The

Environmental Management System as a whole is certified to ISO 14001 (EDF’s EMS is the

largest in the world). In order to facilitate and to monitor the implementation of this policy in all

the companies of the Group, EDF has put in place a Sustainable Development Committee

which reports to the General Secretary of the Group; it is the supervisory board for

environmental issues.

3.3 Systems for radioactive waste

All nuclear companies of EDF Group share the same principles for waste management

namely:

Minimizing operation and maintenance waste arising and use of the waste hierarchy:

“avoid, reduce, re-use, recycle, treat, dispose” while taking account the limitation or

ban prescribed by the regulator (re-use and recycling are in general possible within

the nuclear industry, while recycling outside the industry is limited, even banned in

some cases, in France)

Segregation and streaming of waste;

Processing by efficient use of existing treatment techniques;

Storage, packaging and transport requirements;

Waste radioactivity measurement and/or assessment and accountability procedures.

EDF Group’s main objective is to maintain radiation doses to the workforce and to the general

public from radioactive waste management operations, including disposal, within legal limits

and As Low As Reasonably Achievable (see § 2.6). Under this objective and in compliance

with their certified Environmental Management Systems, EDF Group companies have put in

place and regularly improve management processes such as: optimization of management

and of treatment equipment, maintenance and improvement (e.g. through training) of

practices and behaviours, research for excellence by benchmarking with other operators and

collaboration with international organizations and with providers of services (e.g. for treatment

or for recycling).


The safety of radioactive waste consignments being dispatched to specialized processing

facilities or storage centres relies on the quality of waste packages (concrete, steel or lead

casks), which are designed for specific types of waste and take into account varied hazards

during transportation. Waste shipments are governed by national and international legislation,

the intent of which is to protect the public and the environment from all types of risks. No

shipment may leave a plant or be accepted at its destination prior to the submission of a

comprehensive inspection document.

Significant actions in the past years include:

In EDF SA, the average of radioactive liquid releases is lower than 1% of the required limit (29

)

and has been halved in the last ten years, while the average number of solid LLW packages

didn’t increase; this result has been achieved with actions focused on “reduction to the

source”. EDF had previously (since 1985) cut down by a factor 3 the volume of short-lived

waste produced. Thanks to its reprocessing centre, CENTRACO, EDF cuts down by a factor

more than 10 the volume of metallic waste.

In EDF Energy, a new waste processing route, which enables the decontamination of

radioactively contaminated metal, has been implemented. This substantially reduces the

volume of waste being sent for final disposal at the UK LLWR in Cumbria by up to 95%. The

decontaminated metal is clean enough to be recycled and sold for general use (30

). This route

has been utilized by three of EDF Energy Nuclear Generation’s power stations and is being

rolled out across the remainder of the fleet.

EDF Energy Nuclear Generation’s Advanced Gas Cooled Reactors (AGR) are cooled by

Carbon Dioxide (CO2) which must be maintained within set moisture concentration

parameters in order to comply with the safety case. Moisture control is performed by drying

towers which require periodic desiccant replacements. The options for managing spent

desiccant were reviewed in 2009. This review, which was supported by laboratory scale and

full-scale trials, identified a new method for processing and disposal that reduced the final

disposal volume by approximately 50%. A further 20% reduction is expected.

In the USA, there have been several initiatives over many years to minimize the volume of

solid radioactive waste generated at US Nuclear sites through planning, training and

communication. After generation, CENG segregate waste (resin, filters, DAW, and metal) and

send it to a licensed waste processor where the lowest cost alternative

(compaction/incineration/de-contamination) is used to minimize the volume. The waste is then

sent to a licensed waste burial facility or, as is often the case for metal waste, released for

use. The exception to this is any waste that is Greater than Class “C” and therefore must be

stored as it is not acceptable for burial.

CENG minimizes liquid waste releases by limiting water usage, processing any liquid

radioactive waste, storing for decay of radioactivity when needed, and finally released, if

needed, in accordance with USNRC Federal Regulation 10 CFR part 20 not to exceed public

dose limits. CENG site liquid releases have not exceeded one tenth of the federal limits.

Radioactive waste release reports are generated annually by CENG sites. The reports are

prepared using site release, and shipping data in accordance with USNRC Regulatory

29

Except for tritium and C14 which are linked to the energy produced and can’t be easily separated and treated

30 This process is not yet authorized in France


Guidance 1.21. Releases and waste shipments are carefully accounted for and reported to

either the NRC or to the state, as required by existing licenses and permits. Releases, spills,

or other environmental events are reported promptly to the appropriate agencies using well-

defined reporting standards. All reports are available for public review.

3.4 Spent fuel

3.4.1 Policy

Our overall commitment is to play a leading role in the drive for continuous

improvement in spent fuel management across the worldwide industry. That

improvement deals with several issues, on existing fleet and on new reactors:

The fuel behaviour during normal operation and in case of accident with the aim

of minimizing radiological exposure

The safe management of spent fuel

The optimisation of the fuel cycle with the aim to minimize the quantity of fuel

used per unit of power generated

The reprocessing (when possible within the regulatory and industrial context)

with the aim to reduce the consumption of natural resources and to better

manage the long-life waste.

We work with governments and NGO‟s and others to complete and to demonstrate a

long term radioactive waste solution for the nuclear industry.

3.4.2 Systems

Spent fuel management:

Because fuel assemblies contain the highest quantity of radioactive products, we put a primary

focus in delivering safe operation by a safe management of spent fuel.

Spent fuel is handled under carefully controlled conditions and the process is managed and

operated by suitably qualified and experienced personnel (trained on handling machines with

model of assembly or on simulators). The spent fuel management on station includes

handling, management of spent fuel pools and specific tools, temporary storage, containment,

loading for transport and control, and finally dispatch off-site. All of these processes are

carried out under controlled procedures to ensure safety and compliance at all times and

under continuous improvement which is present in all companies’ activities including Spent

Fuel Management.

A process for loading, cleaning and monitoring the casks, to verify that they are compliant on a

safety and radiological protection point of view, is followed as the fuel enters the public

domain.

Fuel-cycle optimization and fuel behaviour:

We work closely with fuel designers and suppliers on these two related aspects, both by

searching for, then experimenting with, new alloys for the cladding which are more corrosion-


resistant and more resilient in case of accident, and to extend the duration of the life-cycle of

an assembly, by increasing in a safe manner their burn-up. These improvements need time

and arrangements with suppliers, re-processors and safety authorities. They may have some

consequences on re-processing and storage, so an optimization has to be found.

Long term management and reprocessing:

In France, EDF made the choice of spent-fuel re-processing and materials re-cycling, with the

target of reducing the volume and the harmfulness of the final part of radioactive waste. We

reprocess each year about 1,000 tons of spent fuel and the recycled part of our fresh fuel we

reintroduce in reactors represent 17% of the energy we produce. To avoid Plutonium

accumulation, the reprocessing flow rate (1,000 tons/year) is consistent with the recycling

capacity (number of power plants authorized to receive MOX fuel). The volume of Long Life-

High Level waste generated in the reprocessing plant of La Hague each year is of 150 cubic-

meters. The Long Life-Medium Level waste generated represent 200 cubic-meters per year.

In the U.S. spent fuel management is dictated by a law titled the Nuclear Waste Policy Act of

1982 (“NWPA”). The NWPA -- and the regulations implementing the law -- call for the U.S.

government to eventually build a federal repository for the fuel and to take title to the fuel after

the facility is licensed and placed into service. The federal repository project is to be funded

by the users of the fuel at a rate calculated per electrical megawatts generated. The fund has

grown since 1983 and this far a repository has not been licensed and built. The standard

contracts entered into between the U.S. nuclear generator licensees described how the project

was to be funded and when the government was first scheduled to accept the spent fuel –

which was 1998. The repository is not licensed and completed: the subject of how the spent

fuel will be taken and processed by the government is still under debate.

Since the U.S. government did not achieve its 1998 milestone, U.S. nuclear licensees, such as

the five CENG reactors, filed a law suit for partial breach of the standard contracts. Since

then, CENG has entered into settlement negotiations with the government to recover its

additional costs incurred by having to construct and operate on-site dry cask storage facilities

called: Independent Spent Fuel Storage Installations (“ISFSIs”). The ISFSIs are safe, long-

term and robust storage options that require no powered cooling support mechanism.

In the UK the nature of EDF Energy Nuclear Generation’s business and its historic

government link, mean that the strategy for spent fuel and radioactive waste management

from EDF Energy Nuclear Generation’s power stations is owned and managed by the Nuclear

Decommissioning Authority. This does not mean that EDF Energy does not have policies to

continually improve and minimize the spent fuel and waste arising but this is done through our

wider safety, sustainability and environmental policies.

New reactors:

The new EPR reactor will have a larger core than in existing plants. Composed of 241

assemblies, its cladding will be of new alloy which is more resilient. The cycle duration will be

18 to 22 months with an average burn-up of 60 GWd/tU (compared to 45 in the existing

French plants) and the use of MOX will be possible but not yet foreseen (31

).

31 See §4.1 of the Flamanville3 safety report on http://energie.edf.com/nucleaire/carte-des-centrales-nucleaires/epr-flamanville-

3/publications-48527.html


Beyond its performance and capability, this core presents advantages in term of waste

generation. Thanks to its size, to the number of assemblies, to the use of neutron shields, and

to the efficiency of the steam turbine, the efficiency of fuel use is 22% higher compared to a

current type of PWR reactor and the generation of long-life waste is 26% lower (32

). Due to its

highest activity, the impacts of spent fuel on transport, re-processing and storage had to be

assessed before its use in EPR. These impacts have been predicted by safety institutes in

France and UK to be compatible with current arrangements even if, in some cases, some

arrangements in the current provisions are to be made (e.g. ILW packaging, cooling period,

requirements for disposal..)(33

)

3.5 Decommissioning and waste

3.5.1 Policy

The common policy within the Group is to decommission each station following its

permanent shutdown in compliance with local laws with the aim to return the site to a

state suitable for an alternative use. In FRANCE, the only country where nine reactors

previously operated by the Group have been permanently shut down, EDF has chosen

to completely dismantle the nine first generation reactors.

EDF takes full financial and technical responsibility for the decommissioning of its nuclear

power plants. For EDF, the issue is to demonstrate, through the decommissioning process, its

control of the entire life cycle of the means of nuclear power generation.

3.5.2 Systems

In France, the decommissioning of nuclear power plants involves three levels, according to a

classification defined by the International Atomic Energy Agency (IAEA) in 1980:

Level 1: shutdown of the plant, fuel unloading, draining of circuits (99.9% of

radioactivity is eliminated), followed by final shutdown: dismantling of non-nuclear

facilities that are permanently decommissioned, with access limited to monitored

facilities;

Level 2: dismantling of non–nuclear buildings and nuclear buildings excluding the

reactor building, conditioning and evacuation of waste to storage facilities, isolation –

containment – the section of the facility surrounding the reactor is kept under

surveillance;

Level 3: complete dismantling and removal of the reactor building, and of materials

and equipment that are still radioactive; surveillance is no longer necessary; following

these operations, the site may be re-used for industrial purposes.

In practice, the operations leading from Level 1 to Level 2 are conducted consecutively over a

period of time of approximately 10 years after the reactor ceases production. A waiting period

may occur between the end of operations leading to Level 2 and the beginning of operations

leading to Level 3, in order to allow the radioactivity in the irradiated materials to decay. The

length of this waiting period may vary, depending on the comparative interest of radioactive

decay and the length of time the facility must be monitored and can depend on the re-use

32 See §11.3.2 of the Flamanville 3 safety report

33 See http://www.epr-reactor.co.uk/scripts/ssmod/publigen/content/templates/Show.asp?P=340&L=EN


envisaged for the site. At the end of this waiting period, the length of time spent on operations

leading to Level 3 is estimated to be approximately 10 to 15 years.

EDF has launched the decommissioning program of the nine reactors that have been

definitely shut down (one PWR: Chooz A, one heavy-water reactor (HWR): Brennilis, one fast

breeder reactor: Creys-Malville and six NUGG-type reactors in Bugey 1, Saint-Laurent A and

Chinon A) by 2035, following the delay by ANDRA in commissioning the long-life LLW storage.

The sites remain the property of EDF, and they will remain under its responsibility and

monitoring. With regards to the other PWR power plants, certain decommissioning options,

including those relating to the timeframe, have not yet been finally decided. Given its role as

responsible owner, EDF will act as the contracting authority for the decommissioning.

The regulatory framework for decommissioning was renewed in 2006. It is characterized, for a

given power plant, by:

a single decree, following the NSA’s opinion allowing for complete decommissioning.

Three decrees were obtained in 2010: decrees for the complete dismantling of the

NUGG reactors Saint Laurent A and Chinon A3 in May 2010, and the decree

authorizing the construction of an interim storage facility for radioactive waste in April

2010 (ICEDA)

key meetings to be held with the French NSA, integrated in a safety reference system;

an internal authorization procedure for the operator, independent of the operational

staff and audited by the French NSA, and allowing the beginning of the work within the

limits of the safety reference system authorized.

The decree to dismantle Bugey 1 was published in the Journal Officiel on November 20, 2008.

Regarding the Brennilis site, at the end of July 2008, EDF made a new request to the

ministers in charge with nuclear safety for authorization to decommission. This new request

follows the decision of the French Council of State of June 6, 2007 to cancel the decree

authorizing the reactor to be fully dismantled, because the results of an impact study on the

decommissioned work had not been issued publicly before the publication of the decree. The

decree authorizing the next steps of the dismantling had been published on July the 28th 2011.

A decree, to be adopted around 2013 should authorize the complete dismantling.

The decommissioning program of the nine plants is progressing normally. The global progress

ration is of 33% at the end of September 2011 (Three projects are around 50%: Brennilis,

Creys-Malville and Chooz A):

At Chooz A, the dismantling of the primary circuit has begun in 2011; the two steam

generators have been cut and decontaminated; the reactor vessel will be cut by the

end of 2016

At Creys-Malville, the facility for the treatment of sodium has been commissioned in

2010; at the end of August 2011, 25% of the sodium (5,500 tons) is yet treated

At Brennilis and Chooz A, several nuclear auxiliary buildings have been totally

dismantled.

The decommissioning of EDF’s nine shutdown first-generation units will produce

approximately 1,000,000 tons of primary waste materials, of which 80% is standard waste

material and none is high-level waste. The remaining 20% comprises very low to intermediate-

level waste including about 2% waste requiring the availability of an LLW storage centre.


The following waste evacuation projects are currently being implemented in order to

complement those already in place (very low-level waste and low-to-intermediate-level waste):

the project to build a packaging and interim storage installation for radioactive waste,

launched at the Bugey site. The commissioning is expected in 2014.

the low-level waste storage facilities (Centre de Stockage des déchets FAVL)

provided for under the law of June 28, 2006 concerning the long-term management of

radioactive material and waste. Because the search for sites launched by ANDRA in

2008 yielded no results, and in order to allow time for consultation, the French state

decided in 2010 to lift the deadlines on the LLW storage project and asked ANDRA to

continue discussions with the regions where municipalities had come forward as

candidates in 2008.

In the UK:

Radioactive wastes that arise during decommissioning will either be stored or disposed of

depending on the availability of appropriate disposal routes, in accordance with Government

policy that radioactive wastes will be disposed of where a disposal route exists.

The Low Level Waste Repository (LLWR) site in Cumbria is currently available for the disposal

of operational and decommissioning LLW within the constraints of its acceptance criteria and

is expected to remain operational until at least 2050. It is Government intent that a National

Repository (Geological Disposal Facility (GDF)) for ILW will be constructed, although it is

presently not expected to be available before 2040.

EDF Energy’s decommissioning plans detail the sequence for dismantling the stations and

calculate the amounts of radioactive and non-radioactive material that will be created. These

plans use sustainability and recycling principles to ensure materials created are stored,

recycled and disposed in manner consistent with safety and environmental legislation. In this

context "disposed of" reflects the strategic end point assumption for the waste when the waste

has been conditioned /packaged, emplaced within the GDF and the GDF facility is closed. For

the waste strategic end point - waste disposed of to GDF - there are no alternative strategic

options - this is the end state.

The inventory of materials projected for EDF Energy during decommissioning periods is

contained in the latest publication of the National Inventory Statement34

.

EDF Energy document specifies the arrangements by which decommissioning of its power

stations will be controlled to ensure compliance with all statutory and mandatory requirements.

It describes the regulatory compliance (Site License), interface requirements and

arrangements necessary for managing decommissioning at EDF Energy Nuclear Generation’s

power stations.

Radioactive wastes will be managed in accordance with the Corporate Radioactive Waste

Management Strategy and the Integrated Company Practice for Environmental Compliance

and Management.

In the United States, decommissioning activities for commercial nuclear facilities are done

pursuant to U.S. Nuclear Regulatory Commission (“NRC”) regulations at 10 CFR 50.33(k), 10

CFR 50.75, and 10 CFR 50.82 (35

).

34

http://www.nda.gov.uk/ukinventory/the_inventory/2010-inventory.cfm


CENG has planned for decommissioning the each unit using the most feasible option to

minimize low-level waste (“LLW”). The facilities will be placed in a “SAFSTOR” configuration

(“delayed deconstruction”) per NRC guidance to allow shorter lived activity to decay and then

will use methods to remove the remaining contamination from the facilities. Regarding

decommissioning funding assurance, CENG must submit a report to the NRC once every two

years demonstrating how amounts deposited in protected trust funds will ensure that

decommissioning activities will be fully funded at the appropriate time. CENG has already

contracted with a Utah-based company, EnergySOLUTIONS, to accept the LLW. Once the

LLW is removed and surveys confirm that levels are less than regulatory minimums, the NRC

will then terminate the license.

Currently decommissioning of nuclear plants is underway only in France. As we decommission other nuclear sites operated by the EDF Group we will publish relevant information, including decommissioning waste figures, in an open and transparent way.

Enhancement of the design of new reactors, taking decommissioning into account

While the initial design of the past generation of reactors had not taken into account the

prospect of decommissioning, it has become a mandatory condition now in many countries.

The design of the EPR has particularly integrated the best international knowledge in that

point of view.

The provisions taken during the design phase aim at two targets at an acceptable cost: the

reduction of collective doses and of generated waste. The main provisions are (36

):

Less use of materials which can easily be activated during the operation (e.g. stellite,

less cobalt in metallic alloys...)

Implementation of shields and barriers preventing the activation of materials

Easy dismantling of equipment, areas for handling

Circuits and premises especially designed to prevent the accumulation of

contamination and to facilitate its removal.

4. Training

4.1 Overview on Human Resources and training policy

In the EDF Group culture, economic and environmental performance is strongly linked

to social performance

Historically, EDF has always clearly expressed its ambition around both an industrial,

economic project and a social project, that is to say a human adventure in which the absolute

priority is given to the development of competencies.

35

For an overview of the NRC’s regulatory requirements for decommissioning activities and decommissioning funding

assurance, please see: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/decommissioning.html

36 For more details please consult the safety report for Flamanville3 at the following address:

http://energie.edf.com/nucleaire/carte-des-centrales-nucleaires/epr-flamanville-3/publications-48527.html

http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/decommissioning.html


The human resources policy of EDF is thus based on three key priorities shared by all

businesses and companies within the Group:

People development: develop the skills required for business and, at the same time,

place people at the heart of the industrial project, with a recruitment policy and a

dynamic training approach, relying in particular on apprenticeships,

Set up recognition, quality of life at work, health and safety as levers regarding all

employees’ commitment to sustainable performance, fulfilling the EDF Group

commitments to quality of life at work, work-life balance, diversity,

Introduce more diversity and strengthen our common culture, especially among

managers and experts in order to build an integrated Group in France and on the

international stage.

The EDF Group ambition is to continue to invest heavily in human resources and skills

development through vocational training. The demanding goals, the introduced innovations

and the means committed through the Training agreement signed in 2010 with all the Unions

reflect the intensification of this effort, which must find its counterpart in an improved

performance for each of the Group companies.

Business growth and sustainable performance thanks to development of competencies

The EDF Group is now facing new challenges:

The businesses and activities evolve, in line with the technological, economic,

environmental stakes in the energy sector, with the continued strengthening of the

requirements (regarding nuclear safety in particular) and with the EDF Group

ambitions for business development in France and on the international stage,

The recovery of industrial investments in all sectors and the development of nuclear

engineering activities which will dramatically increase the need for skills,

In France, between 25 and 30% of the total EDF workforce could retire by 2015, a

figure that rises 1.5 times when considering the number of maintenance and operation

staff in the fields of production, engineering and distribution.

In addition EDF intends to be recognized as a company responsible for the control of the

environmental impacts (i.e.: human, flora and fauna) of its activities.

A strong and sustained investment in training and apprenticeship

The EDF Group, which operates in a context of high-tech professions, has always devoted a

large budget to the training of its employees in order to accompany the technological or

organizational evolutions and career paths. So, every year, EDF spends about 8% of its

payroll on training in France. The EDF Group intends to pursue this investment in vocational

training (apprenticeship, professional training contracts, internal promotional training) with the

necessary resources to match its ambition. EDF also benefits from tools in line with the

expectations of current and future employees (e-learning, serious games, on-site training

tools, the Group Intranet, edfrecrute.com Web site etc).


To anticipate and guarantee that EDF will have, in the long-term, the right number of

employees with a high level of relevant qualification, a set of collective devices for training and

professionalization, the “Académies des métiers” (Business Academies) has been set up.

The objective is to seek excellence in operational and technical control, to integrate current

and future challenges for every Division or Business Line in the programs of

professionalization and to ensure the optimal quality level. After an assessment by the

Business Academies Council (composed of executives, HR and training professionals), a

training proposal developed by a Division or by a Business Line, meeting the requirements

receives an official ''label'', accompanied by recommendations for improvement.

Meanwhile, EDF conducts significant recruitment programs, especially in the fields of power

generation (nuclear, hydro and thermal) to support its projects in France and on the

international stage and to meet the challenge of competencies renewal.

The EDF Group intends to recognize and promote the ability of its employees to acquire,

develop and maintain their skills connected with the competencies required for business

needs in order to be able to find or preserve a satisfying employment in their company or any

other in the EDF Group. Mobility is encouraged with appropriate means, including between the

different companies of the EDF Group, when satisfying Group international mobility policy. The

EDF Group supports mobility because it enables employees to acquire new skills, in different

contexts, and to enrich their personal and professional experience, that is considered a major

key to employability.

4.2 Systems

The level of competency of EDF staff and its contractors is a vital and cross-cutting issue for

nuclear safety, operational safety, radiological protection, and environmental protection,

including waste management. Training is one of the principal tools available to managers to

maintain and improve competencies. From the various means available for improving the

competencies of the operators and technicians of their teams (mentoring, training, immersion,

career path, etc), the managers choose the most relevant and efficient in order to meet each

competency need.

Training on activities related to nuclear safety, industrial safety, radiological protection, waste

management and environment must, in general, comply with legal requirements which take

several forms, from assessment made by instructors and/or managers, to external statutory

accreditation. All are submitted to a quality assurance system and to external control by the

NSA.

The three nuclear companies of the EDF Group have to face issues of different types:

EDF Energy launched an ambitious and well-resourced program, with the objective to

respond to a difficult situation its fleet had to face in 2003-2004: resources for training

reinforced (instructors and equipments at the training center at Barnwood),

management of the training process under the control of local Committees involving

the top management of stations, accreditation process reinforced under the control of

the Training Standards and Accreditation Board. The TSAB members sit in judgment

of the capability and demonstrated performance of the evaluated line and training

organizations to ensure nuclear personnel are being trained and qualified to perform

their assigned activities safely, reliably, and efficiently. EDF Energy considers training

an effective tool to improve the professional performance of individuals and, as a


consequence, maintaining and improving safety, reliability and efficiency of EDF

Energy’s operating nuclear power plants.

EDF SA is at a milestone of its history: after having operated the largest nuclear fleet

in the world for around thirty years, without any major incident, EDF has to renew the

generation of its engineers and operators (we are in a period of numerous

retirements), reinforce its operating performances and prepare the second half of the

lifetime of its fleet with an expectation of 60 years. Therefore EDF has established its

project « Generation 2020 » of which the reinforcement of workforce professionalism

is one of the five key-programs. EDF has adopted a policy compliant with international

standards of INPO (ACAD02-001), and has added to them skills management and the

“anticipated management of jobs and skills”:

o Skills management:

Performance improvement through training management

Management of training processes and resources

Initial training

Continuous training

Implementation of training programs and skills assessments

Assessment of training efficiency

o Individual involvement in training management

To support the ambitious program for initial training, EDF has created a centralized

unit with local groups on each site; the unit is composed of more than 500 instructors,

a large center in Le Bugey with simulators, workshops, and a computerized tools.

Another center will be built in Saclay, close to the new research center of EDF. Each

station has its own operating full-scope simulator and its workshop dedicated to

maintenance training which is opened to sub-contractors. These systems constitute

the “Academy of nuclear jobs” which is one of the “Jobs academies” put in place in the

framework of the agreement signed in 2010 with trade-unions and the aim of which is

to bolster a large project for training at the whole perimeter of the Group.

All contractors have to complete mandatory nuclear training courses within a programme that covers a range of nuclear operating issues including nuclear waste, nuclear safety, industrial safety, radiological protection and environmental protection. It is mandatory for both staff and contractors, who are checked when entering a nuclear station. Courses include :

o “Quality and Safety” course (5 days)

o “Nuclear accreditation” course (1 to 3 days)

o “Industrial Safety Risks” (5 days)

o “Radiation Protection” deepening course (6 courses of 1 to 5 days)

o A new course for executives has been recently created (9 days).

These training courses are delivered by bodies accredited by EDF and by an external

certifier (CEFRI). Several workshops have been created in the vicinity of nuclear

stations to facilitate and promote good training for contractors, simulating the

conditions they face when they are at work.


Today training management is one of the areas of the continuous assessment of the

management of each nuclear unit; training management is also controlled by the NSA.

By 2015, EDF Nuclear Generation Division aims to put in place an overall assessment

process of skills management in each plant, comparable to the one of EDF Energy.

CENG has accredited training programs established at the 3 nuclear sites for the

following classification of worker:

o Senior Licence Operators

o Licenced Reactor Operators

o Non Licensed Operators

o Shift Managers

o Shift Technical advisors

o Engineers

o Mechanics

o Electrical Technician

o Instrument and Control Technician

o Radiation Protection Technician

o Chemistry Technician

These training programs go through accreditation renewal every four years. The

programs include initial qualification of workers and annual continual training.

Accredited training is provided to workers in several different settings throughout the

year. These settings include classroom, laboratory, in field training, simulator training,

dynamic learning activity, and computer based training.

Training is also provided for contract workers in the areas listed above. Contract

workers are task qualified for the specific work they will be performing.


5 Reporting

5.1 Policy

EDF Group, as a whole, promotes a transparent communication on incidents and

events, and on performance indicators, including safety, radiation protection and

environment. Each company of the Group has put in place a process to provide information

to the public, adapted to local practices, generally using part of the data (the most suitable for

public understanding) it provides to safety authorities. Requirements of these authorities being

specific to each country, it is sometimes difficult to compare different indicators, and therefore

different performance levels. It’s also difficult to consolidate common indicators at the Group

level, for the same reason. Some of them are included in some reports which are produced

regularly: the Annual Report of Activities and Sustainable Development and the annual Report

of General Inspector for Nuclear Safety.

5.2 System

We use these indicators as an improvement tool for the managers, but not as an end in itself.

It is a way to measure a global safety performance and its evolution, but not a safety level.

Each company uses a lot of indicators, some of them are linked to the ongoing projects or

processes, launched to undertake improvements in the prevention process (see § 2.2) and to

reach excellence. They are not reported in the following pages because they are too specific

to a company and to an action-plan.

The main differences in practices are the following:

In some countries the reactor operator is asked to anticipate the automatic protection

(this is the case in USA and UK) by undertaking a “manual scram”, in others the

operator is asked to leave automatic protections to do their job. The different

approaches give rise to differences in the comparison of indicators, because in the

USA and the UK, the number of automatic scrams is, for that reason, lower than if it

would include manually anticipated scrams.

The practice for rating an event in the INES scale is different from a country to

another; one NSA can express stronger requirement and severity, for example by

using specific criteria; the French NSA, for example, has defined additional factors

that can affect the level of an incident (e.g.in the case when an event or failure can

potentially affect several identical units) (37

)

In the US, event reporting is governed by 10 CFR 50.72 and 50.73, as well as the

plant technical specifications in the operating licenses. That reporting doesn’t use

International Nuclear Event Scale but the INPO uses a specific tool to assess the

more or less significant potential impact of an event. Plant safety performance is

measured as a composite of event severity, significance of inspection findings by the

regulator, and the safety performance of important systems and programs. This

composite safety assessment is presented to the licensee and the public in the US

Reactor Oversight Process (ROP).

37

The number of events and their severity cannot strictly represent safety performance indicators, as assumed

by IAEA itself


The numerous indicators used in environment (releases and solid waste) are closely

linked to the requirements of safety and environmental authorities(38

). The methods for

measurement, for calculation and for categorization are imposed by them but are not

strictly the same from a country to another one. It makes impossible or pointless any

consolidation at the Group level for a large part of them.

Please note that in the following paragraphs “EDF Group indicator” is a consolidate

one: EDF SA at 100%, EDF Energy at 100% (since 2009), CENG at 49.99% (since 2010).

Unplanned plant shutdowns

The unplanned automatic trip rate is the number of unplanned automatic trips per 7,000 hours

of operation as defined by the World Association for Nuclear Operators (WANO). A low figure

indicates that the reactor is controlled well within its safety limits and is operating reliably.

At EDF SA, the UATR is one of the safety performance indicators used for many years and

specific action plans are implemented to continuously improve it. The result in 2010 is the

second best historically, after the best level which was achieved in 2008.

At EDF Energy, following the indications of a deteriorating trend in the 2008/2009 UATR

performance, a comprehensive fleet level review was conducted into the reasons for this

adverse outcome and improvements plans were put in place. This has resulted in significant

improvement. The overall UATR for all the British nuclear stations at the end of the calendar

year 2010 was 0.58. The long term trend since 2003/2004 continues to improve.

At CENG (39

), following indications of a significant rise in the 2010 UATR, an assessment was

made to determine the reasons behind the large change. Corrective actions (see further)

38

In France each station produces an annual public report according to the TSN law

39 The indicator presented here includes manual scrams in addition to automatic ones and done by anticipation

to them

0

0.2

0.4

0.6

0.8

1

1.2

1.4

2000 2008 2009 2010

Reactor trip rate (nbr/reactor/yr)

EDF SA

EDF Energy NG

CENG

EDF Group


were put into place across the CENG fleet which has resulted in UATR improvement in 2011

to date.

Incidents and events (INES level 1 or more, for EDF and EDF Energy, or INPO level 1 for

CENG) (impossible to consolidate)

The International Nuclear Event Scale (INES) is a rapid alert system used for consistent

communication of events across the nuclear industry. These are categorized between Level 1,

which is an anomaly with no impact on the safety of the general public or workforce, and Level

7 which represents a major accident. There has been no nuclear safety events rated above

INES Level 2 from any of EDF Group companies power stations in the last three years (40

).

The number of events scaled to minimum level 1 is presented hereafter but, for the reasons

formerly evocated, the safety performances of companies or plants are not directly

comparable. On the other hand, it can show a trend. Each company in the Group has defined

its own key-indicators more linked to their continuous improvement methods or to their

corrective action plans (see § 2.2 and the GINSR annual report) (41

).

Nuclear Safety Events

2008 2009 2010 2011

Level 1 (nbr) 67 67 68 n.a.

EDF SA Level 2 (nbr) 0 1 (Cruas) 0 1

(Tricastin)

Level sup or eq 1 INES (nbr/reactor/yr) 1.15 1.17 1.17 n.a.

Level 1 (nbr) 17 11 14 n.a. EDF Energy NG Level 2 (nbr)

1 (Dungeness) 0 0

Level sup or eq 1 INES (nbr/reactor/yr) 0.8 0.93 n.a.

EDF+EDF Energy

Level sup or eq 1 INES (nbr/reactor/yr) 1.09 1.12 n.a.

CENG Level 1 INPO (nbr/reactor/yr) 0 0.4 n.a.

40

This corresponds to FTSE exclusion criteria

41 For Tihange 1, see main events and automatic shutdowns at the following addresses:

http://www.belv.be/images/pdf/ar2008-public.pdf page 4 (2 events lev1, none lev2) http://www.belv.be/images/pdf/rapport_annuel_belv_09_fr.pdf page 6 (3 events lev 1, none lev2) http://www.belv.be/images/pdf/rapport_annuel_belv_2010_fr.pdf pages 10 and 11 (none event lev 1 nor 2)


At EDF, the number of events is checked as a part of safety indicators but is not, if considered

alone, a safety target or a criteria for comparison (42

); its stability or increase can be due firstly

to the normal toughening of rules, notably regarding the permanent extending of Technical

Specifications during Operation (OTS), and secondly to the effect of the permanent

improvement of detection and reporting capacity, which is promoted by the management. For

several years, the event rate has been quite stable at around 1 per unit per year. In order to

have a better vision of improvements or deterioration of performances, EDF uses

complementary indicators as such the number of discrepancies to the OTS, number of line-up

errors, number of breaking out of fire, etc, and implements risk analysis on each particularly

significant or precursory event (see § 2.2.2). These indicators allow EDF to verify that safety is

globally in progress and to focus on main improvement programs.

Two INES level 2 events have occurred in the past two years, the first in Cruas on 2009,

December 2nd

, the second in Tricastin on 2011, February 17th.

The event in Cruas 4 is due to the massive increase in vegetation carried by the waterway

following heavy rains, which partially blocked the water intake and affected the heat sink of the

plant during few hours, but with no direct consequences neither on the cooling of the reactor

(which had been stopped and cooled by another system anticipated in that case) or on the

environment. The pumping station was promptly cleaned. The heat sink (water intake,

pumping station, filters, pumps) has been re-assessed and modified 43

(procedures too) and

the experience has been extended to the other sites. EDF has linked that case to other

failures occurred in France and abroad (using WANO report) and carried out a safety review of

the heat-sink on all sites completed at early 2011. This approach shows the will to anticipate

and not to react individually at each event. The conclusions concern several domains: a watch

of environmental evolutions, an improvement of the supervision of pumping station

(procedures and instrumentation) and of the maintenance programs (AP913 approach), and

the launching of modifications (additional instrumentation and improvement of the capacity of

42

On the other hand, if this number would be a strong safety target, the temptation to minimize, or even to

hide an anomaly or a discrepancy, would be high and would affect the safety culture

43 Mainly the capacity of filters to face a rough arrival of floating plant waste

1.7

1.15 1.17 1.171.13

0.80.93

0 0

0.4

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2000 2008 2009 2010

Nuclear safety event rate (nbr/unit/yr)

EDF SA

EDF Energy NG

CENG


automatic trash rakes). The first wave of actions is on-going and a second wave will be

integrated in the periodic safety reviews.

The event in Tricastin 3 and 4 consisted of the premature wear of bearings in the back-up

diesel generators (DG). That wear had been recorded during the periodic maintenance

process on these equipments; the DG would have started if needed but their function would

have been affected after several hours or days of continuous operation. It had no

consequences on the reactor but has been declared at level 2 because the problem could

potentially affect all 5 DGs simultaneously. The failing parts have been replaced, as well as on

the same DG in place on other plants (as prevention measure) and the maintenance program

has been reinforced. A modification of the lubrication system has been implemented. More

widely, the development of new types of bearings has started in 2011; their qualification will

occur in 2012.

At EDF Energy, over the last 5 years, the reactors have seen an overall safety improvement

linked to a major effort to upgrade the facilities and a strong emphasis on further improving

equipment reliability and operational focus. The rate of occurrence of events related to the

INES level events and Nuclear Reportable Event indicators is less than one event per reactor-

year of operation - and represent minor failures in very reliable plant and management

systems to protect safety and maintain legal compliance. Fluctuations from year to year in the

number of such events are expected and efforts to improve arrangements and reduce the

incidence of these events further are continuing.

During 2009 EDF Energy had one nuclear safety event rated INES Level 2 which is classed as

an incident with minor consequences to people or facilities, but where the measures put in

place to prevent or cope with accidents did not operate as intended.

The INES Level 2 incident occurred at Dungeness B power station during the construction of a

new fuel assembly. Whilst a fuel assembly is the completed series of fuel components used in

the core of an Advanced Gas Cooled Reactor Power Station, the incident did not concern the

reactor in any way. In the process of connecting a new fuel assembly to the supporting fuel

plug unit a piece of rubber was, on a procedural check, found trapped in the coupling

preventing the two sections from joining correctly. As part of the recovery process

polyurethane foam was injected below the suspended fuel assembly to minimize the potential

drop height in the event of a de-latch. Subsequent analysis of the foam showed that its use

was not permitted under the power station's operating arrangements. The foam did not come

into contact with the fuel assembly and the coupling did not fail.

There was no impact on the safety of the workforce at the station or the public at large. There

was no release of radioactivity or any damage to the plant. This incident was reported to the

safety Regulator, with which the operator has co-operated, and has been thoroughly

investigated. Companywide improvements have since been made.

In the US, operating transients, incidents, and events are trended and analyzed to assess the

effectiveness of the licensee in safely operating the plant. This assessment is performed

continuously by CENG for its reactors, as well as by the US NRC and INPO. Examples of

trends monitored are significant and noteworthy events, human performance events,

equipment failure rates, operational transients and power changes, personnel safety events,

environmental releases, etc. Much of this information is publically available on the NRC

reactor oversight process (ROP) website. INPO maintains detailed current and historical

trends for a multitude of parameters on their website, available to members.


Two events, assessed as level 1 by INPO, occurred at CENG in 2010. The first event occurred

in February at our Calvert Cliffs plant which resulted in a dual unit trip. The second event

occurred at Nine Mile Point Unit-2. This event occurred during refuelling while draining the

refuelling pool.

These events, and others in the industry, led CENG to become a leader in the development of

SOER 10-02. Actions that the team developed in response to the events include:

Conducting case studies with managers and supervisors, at least semi-annually,

to discuss engaged, thinking organizations and station standards, using significant

events and other examples to focus the discussions.

Reviewed and revised management systems – including work management,

corrective action, system health, and observation programs – to ensure that the

importance of impact of subtle problems are recognized, prioritized, and

addressed appropriately.

Established roles for the leadership team in addressing significant operating

experience.

Verified through frequent evaluation that on-duty shift managers are providing

requisite oversight of plant operations and control room crew performance.

Provided supervisors with sufficient understanding of the importance of using

significant operating experience and job-related operating experience to prevent

events. Initial and continuing supervisor training now includes the must know

significant operating experience as identified by INPO.

We are providing supervisors with the knowledge and skills to conduct behavioural

observations, measure observed behaviours against station standards to detect

worker knowledge shortfalls and verifying that supervisors are performing these

observations appropriately.

Using the systematic approach to training, we are ensuring individual workers fully

understand and are able to demonstrate what it means to be an engaged, thinking

worker.

Developing and implementing a Learning Activity to ensure individual workers fully

understand and are able to demonstrate what it means to be an engaged, thinking

worker which includes the Chili Cook-off.

Developed a handbook like the Safety Culture pocket book to communicate the

principles of an Engaged Thinking Organization

Collective dose rate and individual maximum exposure (to the whole body) (workers

only)

The levels of collective dose and of maximum individual exposure to the whole body are highly

dependent on technologies (large difference for example between AGR and PWR), and on

maintenance programs. Action plans which have been implemented in all companies of the

Group have lead to a spectacular and continuous decrease in dose rates since the eighties or

nineties.


Please note that “Group indicator” is a consolidate one: EDF SA at 100%, EDF Energy at

100% (since 2009), CENG at 49.99% (since 2010) 44

.

44

The indicator for Tihange 1 is not presented in the currently available reports but are under the fixed limits

and strictly monitored by Belgian authorities (1.3 manSv in 2008, 1.1 in 2009 and 1.15 in 2010 globally for the

three units)

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

2000 2008 2009 2010

Collective radiation exposure(man x Sv/unit)

EDF SA EDF Energy NG-PWR EDF Energy NG-AGR

CENG-BWR CENG-PWR EDF Group

0.69

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5 H.S.

FRANCE US JAPAN GERMANY

IMPORTANT PWR NUCLEAR FLEET IN THE WORLD

H.Sv


At EDF SA, actions undertaken with contractors on the most exposed categories of workers

and on critical works have obtained good results and have to be continued. Specific actions

have been started to reduce the risk of high exposal to the hands, after two events occurred in

Chinon in 2010 (complement to the training program, specific tools to catch irradiant

objects,..).

For EDF Energy, see “Our journey to zero harm” on EDF Energy web site. For more than

three years, no worker has been exposed to more than 15 mSv/yr (legal limit 20).

CENG has had success with reducing source term, improving radiation worker behaviours and

improving its ability to direct work remotely. The programme was launched to reduce the level

of collective exposure and has resulted in individual exposure being much below the

mandatory limits, in accordance with its internal policy: no worker is exposed now to more than

20 mSv/yr. The main actions are the following:

In the area of source term;

CENG uses flushing systems and hydrolazing piping to reduce dose rates in high travel paths.

An example of very effective flushing is employed at Calvert Cliffs where larger amounts of

water are flushed through the pressurizer spray lines for an extensive period prior to an outage

which has significantly reduced exposure during a refuelling outage.

System decontamination is a periodic practice primarily used at BWRs when the Co-60 source

term increases. It has been done on entire systems and on small portions of systems. The

NMP Unit 1 has relatively low source term due to decontamination in the recent past and unit

2 has an extensive decontamination scheduled in the 2012 outage.

Nine Mile Point has also used state of the art resin to clean reactor coolant during outages and

employed slow system drains and flood-up processes effectively to reduce the dose rates

workers are exposed to.

Removal of components that contain “Stellite” is a strategy that prevents the rebuilding of Co-

60 following decontamination and at BWRs the main focus is on the removal of Original

Equipment Manufacturer (OEM) Control Rod Blades as they contain “Stellite Rollers” that

0 0 0

18

10

7

0

5

10

15

20

2000 2008 2009 2010

Individual exposure at EDF Group(number of employees exposed to...)

> 20 mSv

> 16 mSv


release contaminates that become activated in the reactor core. Unit 1 at Nine Mile Point has

reduced the OEM blades to the industry recommended amount and Unit 2 will reach that

threshold over the next two refuelling outages. At both BWRs and PWRs there has been an

effort to remove “Stellite” components from valves that are direct paths to the reactor core as

they contribute to activation of corrosion products.

Although it does not remove the source term, the use of shielding creates a barrier between

the worker and the source. This approach is used when it is not practical to eliminate the

source. The industry has a variety of shielding material available that can be custom designed

for an application to provide the maximum shielding while using the minimum space.

Tungsten shielding is the newest product available.

CENG is also progressively reducing the pore size in filters used on radioactive systems to

reduce system source term. Calvert Cliffs has experienced remarkable results through the

use of this process.

Zinc injection is a practice that has reduced dose rates over several operating cycles in

PWRs. The effect is delayed and the benefit begins to be recognized following the third

operating cycle of injection. Calvert Unit 2 displayed dose rate reductions in the refuelling

outage last year and CENG is anticipating the same benefit in the Unit 1 outage in 2012.

In the area of worker behaviours;

CENG uses Dynamic Learning Activities to improve worker behaviours in Industrial Safety,

Human Performance and In Radiation Safety. The static display is used to present both good

and faulted behaviours to help the worker recognize how they should perform in the actual

work area.

Just In Time Training is also used to familiarize a worker with an area, component or

procedure that they may not have used in an extensive period to identify potential error traps.

Full Scale Mock-ups of equipment are used to familiarize workers with new equipment or

equipment where the risk of error is high or the consequences of error are high. There are

mock-ups available for a variety of major equipment (e.g. Steam Generators, Reactor Coolant

Pumps. Pressurizers, valves). Nine Mile Point Unit 2 is implementing Power Up-Rate

modifications in the Spring and there are mock-ups of some of the high dose rate components

that are going to be modified so workers can practice and perfect their equipment.

In the area of improving CENG ability to direct work remotely;

Every CENG site employs extensive remote camera systems along with radio equipment to

enable prompt communication to correct behaviours or provide detailed instructions. This

equipment is employed by Radiation Protection Personnel as well as Crew Leaders so that

they can direct activities and not receive unnecessary radiation exposure.

There are also Electronic Dosimeters employed that will alarm if a worker is in a higher dose

rate area than planned or if they have received more exposure than they were authorized to

receive. The Electronic Dosimeters can also be equipped with transmitting devices so that a

central location can monitor their exposure and if outfitted with communication equipment they

can be informed of their exposure and exposure rate without manually viewing their dosimeter.


These Electronic Dosimeters and similar portable area and air radiation monitors can be

installed in any location to enable the tracking of changes without the need to expose a

Radiation Protection Technician to obtain the information.

The personnel monitoring equipment is also capable of being connected to the site computer

system to inform personnel of alarms or malfunctions as much of the equipment contain self

diagnostic software to prevent use when they are not operating properly.

Dose to the most exposed person of the public

We are required (45

) to assess the radiation dose to the most exposed members of the public

in the vicinity of our sites using the results of our environmental monitoring (46

). The result is

specific to each site and differences are not a sign of good or bad performance, because of

the numerous parameters on groups’ behaviour and the geographical characteristics used for

the calculation (47

).

Applied to the surrounding populations, the dosimetric or health impact of radioactive liquid

and gaseous releases leads to a dosimetric value around 1/1,000th (a few µSv) of the

exposure due to natural background radioactivity (that itself can vary greatly from one region

to another according to the type of soil.

The consistent level of very low public dose from 2008 to 2010 is evidence of the companies’

successful efforts to employ best practicable means to minimize the impact of their releases

on the public.

45

Since 2008 in France ; before that date, the requirement was to verify that any element of the monitoring

was below the limits; in fact they were well below.

46 The method is specific to each country; it uses the principle of « reference groups » and calculation models

agreed by NSA and taking into account the proximity, the food habits, meteorological conditions, etc ; the

general method is the same as the one used for the initial Impact Assessment but some improvements can

have been introduced at one moment in the past.

47 The effect of Tihange’s global releases is around 0.03 mSv/yr and slightly decreasing, in parallel with

decreasing of radioactive releases


Analysis and monitoring of radioactivity levels in the environment are essential to assess the impact of radioactive substances on human health, on the environment and on the resources of economic interest (especially water and agriculture).

In order to centralize information on environmental radioactivity in France and to provide access to measurement results for both professionals and non-professionals while strengthening harmonization and the quality of measurements performed by certified laboratories, the French stakeholders in environmental monitoring have launched the website www.mesure-radioactivite.fr, the French National Network for the Measurement of Environmental Radioactivity.

Under the Public Health Code, this network is developed under the auspices of ASN in collaboration with IRSN and in partnership with the Ministry of Health, Ministry of Ecology and Energy, major nuclear licensees (EDF, ANDRA, AREVA, CEA), health agencies (AFSSA, InVS) and environmental protection associations (including the independent laboratory ACRO).

A unique initiative in Europe, the site www.mesure-radioactivite.fr centralises all the results of radioactivity measurements carried out on the environment by various organisations and makes them available to experts and the public with frequent updates: on average, 15,000 measurements are added each month.

Part of an effort to make data on radioactivity in the environment more transparent for citizens, www.mesure-radioactivite.fr provides quick and easy access to a wide range of data related to the national network (regulation, operation and laboratory accreditation). It includes a section explaining radioactivity, how it is measured and its biological effects. The website gives the user keys to understanding the environmental radiological measurement results. The site will be improved over time taking into account the feedback of the users.

Results available on the website are provided by laboratories that have been certified by ASN.

They comply with the norm NF EN ISO 17025 and have succeeded inter-comparisons

exercises organised by IRSN.

2.2

1

0.0

06

0.0

06

0.0

07

2.4

1

0.0

02

0.0

02

0.0

03

1

0.0

72

0.1

17

0.1

04

0

0.5

1

1.5

2

2.5

3

Natural Public limit 2008 2009 2010

Dose to the most exposed members of the public (mSv/yr)

In UK

In F

In USA

http://www.mesure-radioactivite.fr/

http://www.mesure-radioactivite.fr/


Waste generation or storage

The indicators cannot be compared and a consolidated indicator is not possible due to the

great differences between legal requirements and the categories of waste (the boundary

between levels) (see §3.3). For the moment each company has its own indicators and EDF

Group, as has WANO itself, has tried to find basis for benchmark.

The trends can be shown on these charts (data before EDF acquisition not available); they are

mostly influenced by the volume of maintenance and by the dates of shipments 48

.

Spent fuel

Regarding spent fuel, the situation is not the same in EDF (where spent fuel is totally sent off

site for re-processing), EDF Energy (where spent fuel is partially stored on site: totally for

PWR’s fuel, partially for AGR’s fuel), and CENG (where it is totally stored on site). Taking into

account theses differences within national strategies and the fact that spent fuel sent off site

will vary from year to year due to numerous factors which include cooling times, optimising

transport arrangements and operation capabilities within national industries, that figure doesn’t

show any significant trend. Nonetheless it confirms that a large majority of spent fuel produced

48

For Tihange, waste indicators are presented globally for the site in the following report, page 40; they can’t

be isolated for unit1; no indicator for spent fuel is publicly disclosed for the moment ;

http://www.electrabel.com/assets/content/whoarewe/Declarationenvironnementale211_8938400CB3F44A0C

9DE32C1D5BEA4F99.pdf

0

5

10

15

2008 2009 2010

EDF SA operational waste (in m3/TWh)

Low or medium level, short life

High or medium level, long life

0

200

400

600

800

2008 2009 2010

EDF Energy operational waste (in m3)

Low level

Intermediate level

0

200

400

600

800

2008 2009 2010

CENG operational waste (in m3)

Low or medium level




by the Group is re-processed. The provisions made in EDF Energy and CENG regarding on-

site storage are presented in the §3.4.2.

Please note that the “Group indicator” is a consolidated one: EDF SA at 100%, EDF Energy at

100% (since 2009), CENG at 49.99% (since 2010)

Radioactive waste generated by decommissioning:

The available numbers are provided by EDF SA, the only company of the Group which

presently implements decommissioning programs (see § 3.4).

The chart shows the cumulated quantity of radioactive waste of each category:

o very low level and short life which are sent to the “CSTFA”, the adequate disposal

located in Morvilliers (Aube)

o low or medium level, short life, which are sent to the “CFMA”, the adequate disposal

located in Soulaines (Aube)

o metallic waste which are sent to Centraco, to be molten and re-use in nuclear industry

The total is currently lower than expected for this year, which indicates that there is no cause

for concern except delays advocated in §3.5.2.

0

200

400

600

800

1,000

1,200

1,400

1,600

2008 2009 2010

Spent fuel (tons of U)

Discharged by EDF Group Sent off site by EDF Group


As we decommission other nuclear sites operated by other companies of EDF Group we will

publish relevant information, including decommissioning waste figures, in an open and

transparent way.

Being aware of their respective responsibilities, and accordingly with their regulations, EDF

Energy and CENG, as explained in §2.5.2, already regularly reassess forecasted quantities or

costs of future waste generated by decommissioning. For example, EDF Energy currently

forecast total generation of 190,000 m3 of packaged waste (LLW and ILW)

49.

49

See http://www.nda.gov.uk/ukinventory/the_inventory/2010-inventory.cfm

17,841 19,345 20,585

2,2972,524

2,869920

1,1571,418

0

5,000

10,000

15,000

20,000

25,000

30,000

2000 2008 2009 2010

Decommissioning waste in F(cumulated rough tons)

Very Low Level Low or medium level, short life Send to Centraco


Appendix: Acronyms

AFCEN Association Française pour les règles de conception, de construction et de surveillance en exploitation des Chaudières Electro-Nucléaires

AGR Advanced Gas-cooled Reactor

ALARA As Low As Reasonably Achievable

ALARP As Low As Reasonable Practicable

ANDRA Agence Nationale pour la Gestion des Déchets Radioactifs (France)

BEG British Energy Group (UK)

BWR Boiling Water Reactor

CEG Constellation Energy Group

CENG Constellation Energy Nuclear Group

CEO Chief Executive Officer

CGNPC China Guangdong Nuclear Power Group

DOE Department of Energy (USA)

DG Diesel Generators

EDF Electricité de France

EDG Emergency Diesel Generator

EPR European Pressurised Reactor

EPRI Electrical Power Research Institute (USA)

EMS Environmental Management System

EURATOM European Atomic Energy Community

FBR Fast Breeder Reactor

FTSE Financial Times/Stock Exchange

GDF Geological Disposal Facility (UK)

GINSR General Inspector for Nuclear Safety and Radiation protection

GRS (or GSR) General Requirement for Safety (IAEA)

GWd/t Giga Watt-Day per ton

HR Human Resources

HSE Health and Safety Executive (UK)

HLW High Level Waste

IAEA International Atomic Energy Agency

ICRP International Commission on Radiological Protection

ILW Intermediate Level Waste

INES International Nuclear Events Scale

INPO Institute of Nuclear Power Operators (USA)

INSAG International Nuclear Safety Advisory Group (IAEA)

IRSN Institut de Radioprotection et de Sûreté Nucléaire (France)

ISFSI Independent Spent Fuel Storage Installation (USA)

ISO International Organization for Standardization

LLW Low Level Waste

LLWR Low Level Waste Repository

mSv MilliSievert (= 0.001 Sievert) (= 0.1 Rem)

MOX Mixed oxide

NEI Nuclear Energy Institute (USA)

NEPA National Environmental Protection Agency (China)

NLF Nuclear Liabilities Fund (UK)

NMP Nine Mile Point (USA)

NNSA National Nuclear Safety Administration (China)

NPP Nuclear Power Plant

NRC Nuclear Regulatory Commission (USA)


NSA Nuclear Safety Authority

NSC Nuclear Safety Council

NWPA Nuclear Waste Policy Act (USA)

ONR Office for Nuclear Regulation (UK)

OEA Operational Excellence Assessment (EDF Nuclear Inspectorate)

OSART Operational Safety Assessment Review Team

OTS Operational Technical Specification

PPI Plan Particulier d’Intervention (Special Intervention Plan, France)

PUI Plan d’Urgence Interne (Internal Emergency Plan, France)

PWR Pressurised Water Reactor

RMD Risk Management Division (France)

SOER Significant Operating Experience Event Report (INPO USA)

TMI Three Mile Island (USA)

TNPJVC Taïshan Nuclear Power Joint Venture Company (China)

TSM Technical Support Mission

TSN Transparence et sécurité nucléaire (French law)

TSO Technical Specifications during Operation

TSAB Training Standards Accreditation Board

TWh Tera Watt hour

UATR Unplanned Automatic Trip Rate

UNE Unistar Nuclear Energy

UNGG Uranium Naturel Graphite Gaz (France) (eq NUGG)

USNRC United States Nuclear Regulatory Commission

VLLW Very Low Level Waste

WANO World Association of Nuclear Operators

WNA World Nuclear Association

nuclear safety our overriding priority

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