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on Nuclear Safety and Radiation Protection - Energie EDF

The Inspector General’s report

on Nuclear Safety and

Radiation Protection

2012


FOREWORD

This report is destined for the Chairman of EDF with

the purpose of informing him of my judgement of

nuclear safety and radiation protection within the

EDF Group. The continuous improvement of nuclear safety

results is a fundamental commitment of the EDF Group.

In 2012, this notably took the form of the adoption of a

group-wide nuclear safety policy.

This report is also intended for all who, in any way,

contribute to improving nuclear safety. It may also prove

useful to those outside the company who work in the

nuclear field and any other branches of industry where

there are risks to be managed and who wish to contribute

to the debate. It highlights the need for sharing experience

feedback between all the nuclear operators in the EDF

Group and as well as more broadly via WANO.1

It offers a view from outside the organisational structure

and is based on facts and findings gathered in our contacts

with field staff and during discussions with the decision

makers, managers, medical personnel and trade unions

as well as outside stakeholders, especially contractor

companies. The resulting view of the situation in the field

is particularly instructive.

Emphasis is therefore placed more on difficulties and

weaknesses than strengths and progress, which may

appear unfair to those working hard at running our

complex and demanding nuclear power generating

facilities on a daily basis. When it comes to nuclear

safety, only mentioning what is going well is the first step

towards complacency. It is therefore essential to share any

difficulties and corresponding warning signals.

1 WANO: World Association of Nuclear Operators

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

I would like to thank all those I met, both inside and

outside the EDF Group in France and elsewhere, for the

probity of their welcome, for discussing matters so frankly

and creating the conditions for fruitful interchange. Their

openness, vital to the relevance of this report, continues

to reflect the spirit of nuclear safety culture. Their

contributions may not always be found in this report as

the range of subjects has had to be restricted. The year

saw the departure of André-Claude Lacoste, who has

been replaced by Pierre-Franck Chevet at the head of the

French nuclear safety authority (ASN). Mr Lacoste was the

face of nuclear safety at the service of the general public

for two decades.

I would also like to thank my advisers Jean-

Paul Combémorel, Bruno Coraça and Peter Wakefield

who, once again this year, were unstinting in their efforts.

Thanks also to Bernard Maillard who has just joined us

and Christian Thézée who left the team after twelve years

of contribution.

Finally, although this document has not been written for

the purpose of public relations, as in previous years, it will

be available to the general public on the EDF website in

both French and English (www.edf.fr). Two years after the

Fukushima accident and in the midst of intense debate

about the future of energy supply, I hope it will bring a

contribution to all readers interested in nuclear safety.

The Inspector General for Nuclear Safety and

Radiation Protection of the EDF Group

Jean Tandonnet

Paris, 18 January 2013

1


CONTENTS

CONTENTS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

01/ My view of 2012 5

02/ Nuclear operating safety: contrasting results 11

03/ Nuclear safety management: remaining vigilant 15

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

05/ Radiation protection: need for ambitious goals 27

06/ Training updated and better led by line managment 31

07/ Maintenance, a strategic domain 39

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

09/ Attention to chemistry needed in operations 49

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

11/ Plant life extension is conditioned by nuclear safety 59

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

13/ Noteworthy operating events 73

14/ Appendices 79

Result indicators :

14.1 EDF SA nuclear power plants __________________________________________________ 80

14.2 EDF Energy nuclear power plants ______________________________________________ 81

14.3 Constellation Energy Nuclear Group nuclear power plants _______________________ 82

Maps:

14.4 EDF SA nuclear power plants __________________________________________________ 83

14.5 EDF Energy nuclear power plants ______________________________________________ 84

14.6 Constellation Nuclear Energy Group nuclear power plants _______________________ 85

Technical key dates:

14.7 EDF SA nuclear units __________________________________________________________ 86

14.8 EDF Energy nuclear units_______________________________________________________ 87

14.9 Constellation Nuclear Energy Group nuclear units _______________________________ 87

14.10 Table of abbreviations ________________________________________________________ 89

3


MY VIEW OF 2012

01/ MY VIEW OF 2012

AN EVOLVING CONTEXT

2012 was marked by the aftermath of the Fukushima

accident. Beyond some changes in nuclear policy in some

European countries, 2012 was a year of transformation

and development in the nuclear industry worldwide. Most

countries have confirmed that they will be continuing

with their nuclear programmes, with the exceptions of

Germany and Italy, as well as possibly Switzerland and

Belgium where reactors have been and will be taken

out of service early on political grounds. No less than

sixty reactors are currently under construction, some by

countries which are entering the industry for the first

time. The United Kingdom, where the EDF Group is firmly

established, is continuing its nuclear revival.

The year 2012 was also a year rich in international exchanges

to disseminate the lessons learned from the Fukushima

accident and to consolidate operator commitments. The

effects of the accident have been perceptible everywhere

and even if no immediate emergency measures needed to

be taken, the response (underway or pending) has varied

substantially from one country to another, depending

on the views of the different nuclear safety authorities,

governments and operators. The stance of each country

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Chinon nuclear power plant

reflects the history of its energy needs, its public opinion

and policy considerations. Despite the commendable

harmonisation work that has taken place in Europe via

WENRA (West European Nuclear Regulators Association)

and ENSREG (European Nuclear Safety Regulators Group),

acting as forums for the nuclear safety authorities of the

European Union member states, the response has mainly

been a national matter.

In France, the recently announced early closure of

Fessenheim Nuclear Power Plant in 2016 has been a

source of incomprehension and even apprehension,

considering the first reactor had just been authorised by

the ASN to operate for up to forty years. This has been a

serious concern first and foremost for the plant staff. I will

be focusing on this issue. This needs to be considered in

the light of debate on the energy transition and energy

policy reviews of France’s neighbouring countries. I am

also interested in the ability of the company to provide

funding to preserve its assets and improve safety levels in

the future.

In Europe, the United Kingdom has made a firm

commitment to nuclear power in its energy policy. In

December 2012, the Office for Nuclear Regulation (ONR)

granted EDF Energy a site license allowing the NNB

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

6

MY VIEW OF 2012

Generation Company (NNB GenCo) to build and operate

two EPR units at the Hinkley Point site. This is the first

license of this type granted for 25 years. Furthermore,

the EPR-type received a positive outcome to the Generic

Design Assessment (GDA) at the end of the year.

I observe that, in Japan, fundamental changes are in hand

to reinforce the authority of the regulator, to consolidate

the nuclear safety commitments of the operating

organisations in a way similar to INPO (Institute of Nuclear

Power Operators) in the USA and to reinforce nuclear

safety within TEPCO (Tokyo Electric Power Company).

Looking at the situation around the world, I am concerned

about the shortcomings in safety culture in South Korea,

despite the Fukushima alert. The lack of transparency on

the incident that occurred in February 2012 at Kori Nuclear

Power Plant and the malpractice concerning spare parts

are particularly striking. I would like to emphasise that,

despite differences in national culture, operators need

to make sure that safety culture is always of paramount

importance.

This 2012 report is thus appearing at a time of change; in

France, it is also a time of massive renewal of skills and

preparation for the General Refurbishment. In the

United Kingdom, this has been a period characterised by

plant life extension for the AGRs (Advanced Gas-cooled

Reactors) and by the decision-making leading up to the

construction of four EPRs.

In this context, what overall picture can be had of the

year as concerns nuclear safety and radiation protection

within the EDF Group? My assessment reflects my analysis

of the results and events, as well observations in the field

in France, in the UK and in the USA. The findings confirm

that there are firm commitments and solid skills among

the players in the nuclear industry at this challenging

and complex juncture. What is encouraging is that the

incoming generation of new recruits is a real asset for the

Group. They are open to change and readily adapt to the

new requirements of the different professions. I would

like to, once again, reiterate my support for the plant

managers, who are faced with a complicated situation

and are showing a remarkable level of application.

CONTRASTING PERFORMANCE IN THE

FIELD OF NUCLEAR SAFETY

First and foremost, I note that no major event occurred

in any of the Group’s nuclear power plants. The continuous

improvement of nuclear safety levels remains the goal of

the company, with a number of issues having caught my

attention. Some of these issues need to be resolved while

others need to be kept under surveillance.

Within the EDF Group, there was one event that was

graded Level 2 on the INES (International Nuclear Event

Scale), relating to a case of an equipment discrepancy in

France with no direct nuclear safety implications. I would

also like to mention that there has been an increase in

the number of noteworthy events, which need to be

seen as warning signals and treated with due regard.

I am concerned that, in France, there has been an

increased amount of sub-standard maintenance work

and insufficient proficiency in the management of unit

outages. These are covered in further detail in the report.

As concerns nuclear safety, I note that the commitment

is flagging to the action plans begun some years ago,

resulting in a substantial increase in the number of events

that are significant in terms of nuclear safety.

In the UK, the indicators are encouraging as a whole. I did

however observe that improvements are needed in the

fields of reactors trips and fire control, which are not up

to French standards.

In the USA, CENG (Constellation Energy Nuclear Group)

has indicators that reveal considerable disparity between

their three sites. I note that the operability of the standby

diesel generators is well below the international levels

achieved in France and the UK, and I welcome the action

recently begun by INPO to make progress in this area.

In France, the independent internal nuclear safety

organisations remain solid and professional, although

the somewhat limited professional experience of some of

the staff shows that vigilance must be maintained. In the

UK, work on introducing a new organisational structure

is continuing. I am glad to see the deployment of the EDF

Group’s nuclear safety policy and the now regular review

of the safety indicators at the highest level. This appears

to reflect the positive effect of emulation.

As concerns radiation protection exposure has been stable

in the EDF Group, yet international comparisons show

that there is still room for improvement. I wish to draw

attention to the increasing number of significant incidents

in France. In the lead-up to the General Refurbishment,

I would like to again emphasise the need to give new

life to drives to ensure ALARA (As Low As Reasonably

Achievable) approaches are being followed.

Finally, despite a slight improvement, industrial safety

levels in France are neither up to international standards,

nor as good as the results achieved by EDF Energy.


The General Refurbishment at EDF SA

The Generation 2020 Project is designed to increase

the reliability of organisation and equipment

(maintenance and replacement of key components)

by 2015 and subsequently to make sure that the

installations are renovated with due regard for what

has been learned from the Fukushima accident to

further increase nuclear safety at the time of the third

ten-yearly inspections of the 1,300 MWe nuclear units

and the fourth ten-yearly inspections of the 900 MWe

SEVEN ISSUES NEEDING ATTENTION

My visits and encounters in the field have provided me with

first-hand information helping me to identify any nuclear

safety concerns. The differences between the different

nuclear plant types in the EDF Group and the disparity

between the sites render comparison a complicated

matter. At the end of 2012, I find that seven key issues

need the attention of the corporate management. Some

of these issues are covered in more detail in subsequent

chapters of this report. These essentially relate to the

French plants, but I have made a point of putting them

into perspective by comparison within the EDF Group as a

whole and with other plants throughout the world.

Teams heavily loaded

Last year, I highlighted in France the need for better task

prioritisation, particularly among front-line managers,

planners and outage staff, who have been finding it

difficult to focus their efforts when faced with an ever

increasing workload. This is also true for the engineering

centres, which need to simultaneously deal with plant

support, planning of ten-yearly outages (French acronym

VD), studies for plant life extension and post-Fukushima

measures. As target dates are being brought forward, the

task is made more complex and much harder at a time

when the renewal of skills is in full swing.

I am worried that we are attempting to do too much

and too quickly, and that the required quality levels or

everyday nuclear safety in the plants may suffer. To rise

to the challenge, it is necessary to work with the ASN to

target priority actions where there is significant effect on

nuclear safety. I am also concerned about the number of

requirements issued during the past year. The timetable

established, particularly in the heat of the action during

the Fukushima crisis, cannot realistically be adhered to

by either EDF SA and its suppliers on the one hand, or

MY VIEW OF 2012

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

nuclear units. Dubbed the General Refurbishment,

the investment programme forms part of the overall

plant for operations of the plants for up to sixty

years and will multiply the number of maintenance

operations by a factor of four in the coming decade.

the ASN and its specialist adviser, the institute for nuclear

safety and radiation protection (IRSN) on the other.

I consider that the volume of technical and documentary

modifications in the existing plants is excessive. In view

of what I have observed at other nuclear operators, I

wonder whether there is not an unfortunate French

tendency to seek to permanently modify the installations.

Also, too often, the supporting documentation is not up

to standard.

This year, once again, I wish to highlight the urgent

need to deal with the increased bureaucratisation and

complexification of the life of work teams. I was glad to

note and strongly approved of the warning about this

issue given by the President and CEO of INPO during a

recent conference bringing together the heads of the

nuclear operating organisations affiliated to INPO.

An unprecedented effort, but skills still in

short demand

As mentioned in my past reports, in the prevailing

industrial context, the French nuclear power plants are

facing the unprecedented challenge of renewing more

than half of their manpower by 2017. This year,

recruitment has accordingly continued with some 2000

new arrivals at the EDF Nuclear Operations Division and

Nuclear Engineering Division. I would, however, like to

draw the attention of the maintenance professions to

this situation as their needs are ever increasing and I have

observed cases where supernumerary arrangements to

cope with the demand appear to be insufficient. Provision

of planning staff has always been problematic. It is to be

remembered that, in the coming years, the lessons of the

Fukushima accident will need to be addressed (Nuclear

Rapid Response Force, reinforced operations staff etc.).

I appreciate the roll-out of the skills programme and

the excellent synergy between the EDF Group’s teams

in France and the UK. In the plants visited in France, I

noted the increased autonomy of the managers and the

7


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

8

MY VIEW OF 2012

commitment of the staff who are indeed the best placed

to determine their requirements.

As regards training, I am happy to see the increase in the

physical resources and the hiring of instructors, although

I would like to point out that the number of experienced

instructors is still too low.

Reinforcing relations with the ASN and

building a common vision

In France, in the aftermath of the Fukushima event, the

promulgation of the Nuclear Safety and Transparency Act

and associated ministerial orders, particularly the order

on licenced nuclear facilities issued in February 2012,

and the large number of cases to be processed, I have

noticed that, in general, the relations between the

operator and the safety authority are becoming

more strained. The staff on both sides are under

considerable pressure and close scrutiny, not least from

the media. The post-Fukushima case files, the case files

for the forthcoming ten-yearly outages, and future ones

relating to plant life extension cannot be considered

separately. The investment of considerable human and

financial resources is therefore required, with major

industrial constraints.

I believe that such a situation calls for dialogue at the

highest level between the operating organisation

responsible for the nuclear safety of the facilities and

the nuclear safety authority. This dialogue, which needs

to include the IRSN, while respecting the roles of all the

parties, needs to foster agreement on a method and

timetable that is as full and detailed as possible covering

all the work planned. I would like to draw attention to the

importance of the plan being truly realistic, in a context

where resources are strictly limited, including for expert

appraisal by the ASN’s specialist adviser.

In the field, I have observed good practices in certain

plants to help build up very positive relationships with the

ASN at plant level and with the IRSN: the independent

nuclear safety channels are given recognition, the

engineers liaising with the safety authority are especially

experienced and the plant manager has been able to

establish close relations with the head of the local ASN

branch. Dealings with the safety authority are therefore of

better quality and more effective. I would like to see such

practices developing in all the plants.

Now part of the laws relating to the environment, the

Nuclear Safety and Transparency Act puts the ASN in

charge of monitoring discharges into the environment,

even if not radioactive. The rules are now so extensive

and complex that I am not certain the plant managers

have realised the growing significance of this difficult

issue. As a result, legal challenges are being faced more

often by plant managers together with considerable

media pressure, even though they may sometimes appear

disproportionate.

I would also like to highlight the increasing difficulty

of finding common ground with the government

labour inspectors, in their role of industrial safety

advisers. This may lead to the staff losing confidence in

the inspectors and their credibility being diminished. The

legitimacy of the questions is not an issue, but the risk

of drifting towards a situation where checking is simply

based on documentation without due prioritisation.

I am not persuaded that this situation leads to greater

transparency.

Industrial safety in EDF Energy Nuclear

Generation: setting a good example

Industrial safety must not become the poor relative of

nuclear safety and radiation protection, as it is fundamental

to nuclear plant operating performance. I consider that

industrial safety should be given higher priority by the

front-line managers in the French power plants, as is the

case in the UK. EDF Energy Nuclear Generation, which

has focused on the issue for many years, produces results

that are ten times better than those of the French plants.

Despite progress made in 2011, I had already warned

about the industrial safety situation in France. Although I

noted clear signs of progress in response to my concerns on

the EPR worksite at Flamanville, the slight improvements

elsewhere do not meet my expectations. The results reveal

considerable differences between plants. I therefore urge

that intentions be clearly announced in France to rectify

the situation, as the improvements in certain plants show

that this is perfectly possible. When it comes to industrial

safety, the desired behaviours are the same as for good

nuclear safety culture.

In the USA, I noticed that the Constellation Nuclear

Energy Group’s industrial safety results did not match

its ambitions. The management has taken note of the

difficulties encountered and has set an action plan in

place.

EPR projects: key milestones that remain to

be passed

Twenty years after the last new nuclear plant was

built in France, the difficulties in 2011 have provided


experience feedback on a project of this scale, for both

EDF and its suppliers. The way the EPR project has

been conducted and the associated organisational

structure have been completely changed and I am

pleased at what I now see, in particular as regards the

Nuclear Design & Construction Centre (French acronym

CNEN). Nonetheless, the detailed planning - the scale

of which was under-resourced for all too long - has not

yet gained the confidence of all staff. This needs to be

emphasised. Progress is also being made in the UK. As

regards the Hinkley Point EPR project, the year was marked

by the newly clarified division of responsibilities between

Nuclear New Build (the owner-operator) and EDF Nuclear

Engineering Division (French acronym DIN) the designer.

A joint steering committee was also appointed and the

Project Execution Plan was approved, resulting in the

granting of the site license.

At the Flamanville 3 construction site, 2012 was marked by

the episode involving the reactor building crane bracket,

but work is continuing. I note with satisfaction that, at

the end of the year, 93% of the civil engineering work

and 37% of the electrical and mechanical equipment

erection work was completed. I also appreciated the

orderliness of the worksite and the industrial safety

results which will need to be kept up. I still regret the lack

of close cooperation between the Nuclear Engineering

Division staff and the staff of the Nuclear Operations

Division, the future operating organisation.

At a time when the four EPRs under construction in

China, Finland and France are progressing at a rate which

should see them commissioned around the same time,

I have observed a stronger EPR community, particularly

via the EPR Family which has been joined by the Finnish

electricity company TVO (Teollisuuden Voima Oy).

Finally, I would like to draw attention to the considerable

amount of work that remains to be done, in a limited time

span, to qualify the equipment for accident conditions

and supply the nuclear safety studies.

The challenges of an ambitious business

policy

The General Refurbishment programme commencing

with the first third Ten-Yearly outage (VD3) outage of the

1,300 MWe series plants at the Paluel site in 2015 will

be a major challenge. With twice the number of tasks

and increased levels of complexity, it will be necessary to

accordingly adapt the business policy and the purchasing

strategy with the suppliers and workers. Announcing

the contractual arrangements at an early stage of

the programme to enable contractors to properly plan

MY VIEW OF 2012

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

ahead with their investments and to form their teams

appears to be indispensable.

Over the past decade, a number of provisions have

specified the working conditions for contractor staff in

the nuclear industry. In 2012, the strategic committee

for nuclear engineering (French acronym CSFN) drew

up a social charter which forms part of every tender

package sent by the nuclear operators to the contractor

companies. This document was hailed by the High

Committee for Nuclear Safety and Transparency (HCTISN)

as “a clear advance in relations between operator clients

and contractors”. During my future inspections, I will

make a point of checking its application.

I continue to believe that contractors all need to be

more aware of the requirements of nuclear safety and

to improve their safety culture. I would also like to

draw attention to the EDF internal pre-requisites relating

to work management and increased hands-on fieldwork

time.

Throughout the year, I have also noted the importance

of logistics, a field all too often seen as secondary and

disregarded, resulting in lack of equipment, as well as

slowness to respond and reduced availability of certain

players. Proper selection of the companies in charge of

logistics is vital for the effectiveness and the safety of an

entire site. I call for great care in the selection process,

with due regard for the quality of the management to

be provided and allowance for the opinion of the plant

management.

Leadership for nuclear safety: a collective

commitment

The largest nuclear operator in the world, EDF is faced

with very different contexts in France, the UK, the USA

and China. Operation of nuclear plants calls for recognised

leadership in the field of nuclear safety. “Leadership is

not about management. On the contrary, it is a rampart

against a type of management that ‘distracts’ from

operations”. I fully endorse this definition of leadership by

Robert F. Willard, President and CEO of INPO.

Leadership requires all those in control, at corporate and

plant level, to determine the nuclear safety goals for

operations and to establish and apply the corresponding

priorities. I have frequently observed good examples

of leadership, buttressed by on-going, transparent

communication, both inside the company and with

external players. Yet, I have also sometimes noticed

major projects with no clear goals and over-complicated

annual plans. Leadership also requires the regular onjob

presence of the front-line managers for their

9


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

10

MY VIEW OF 2012

intentions to be enforced. I would like to comment on EDF

Energy’s commitment in this area, which was favourably

highlighted in a recent WANO Corporate Peer Review.

In France, I hope that the Nuclear Operations Division

will succeed with its “operational re-focusing”,

particularly in the form of increased subsidiarity and

delegation of powers to the plants. In accordance with

the nuclear safety policy of the EDF Group, I would like

to draw attention to the fact that leadership must also

find its expression at the highest levels, particularly in

corporate governance situations and in public fora.

The EDF Group also has responsibility as a leader in

international bodies such as WANO and the European

Nuclear Installations Safety Standards initiative. I am glad

to see it participating in actions such as those adopted

by WANO in Shenzhen in 2011. The EDF Group will

be reinforcing its team of engineers on secondment to

WANO in Paris from 25 members at the end of 2012 to

60 in 2015. I also hail the nomination of Jacques Regaldo

who succeeds Laurent Stricker as Chairman of WANO.


NUCLEAR OPERATING SAFETY: CONTRASTING RESULTS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

02/ NUCLEAR OPERATING SAFETY:

CONTRASTING RESULTS

An operator in the control room

The year 2012 was marked by contrasting nuclear safety results in the French plants while

those of the EDF Energy plants were mostly unchanged. The results for Constellation Energy

Nuclear Group in the USA also varied.

OPERATIONAL RESULTS

In the French plants

I would first like to mention the declaration of a nuclear

safety significant event ranked 2 on the International

Nuclear Event Scale (INES) after discovering a discrepancy

in early 2012 that had been present since construction

in the anti-siphon systems of some of the fuel storage

pools. This event, which had no immediate nuclear safety

repercussions reflected shortcomings in our management

of discrepancies and in the speed at which they are

rectified.

Secondly, I note the substantial increase (+16%) in the

incidence of nuclear safety significant events (11.9 per

reactor) compared with 2011, as well as the number of

events ranked 1 on the INES (1.55 per reactor). Although

I still consider EDF SA’s level of transparency to be

good, this deterioration calls for in-depth analysis and

corrective action. This trend - contrary to the progress

in 2011 - is mainly due to an increase in the number

of events occurring during maintenance activities

(+40%), the increase in discrepancies in operation of the

installations being more limited (+10%).

Real grounds for satisfaction

At 0.55, the number of scrams was comparable to that in

2011 (the best result in French plant history), confirming

the progress in previous years and showing that the

highest international standards had been reached. In

2012, there was not a single scram in any of thirty six

reactors for the whole year.

In other areas with major nuclear safety implications, such

as administrative lockout and reactor control (remaining

within the authorised operating envelope), the progress

recorded in 2011 has been consolidated.

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

I also confirmed the continued good results achieved in

2012 in the field of fire hazards (fighting, organisation

and training), with few outbreaks and no major firerelated

events. An event that occurred on 5 April 2012

relating to a Penly 2 reactor coolant pump warranted my

attention. It was not considered as a major outbreak of

fire according to the definitions in force, but it did occur in

the reactor building near equipment important for nuclear

safety, which constitutes a noteworthy event. Firstly, I note

the responsiveness and efficiency of the plant response

team, which was rapidly backed up by the Civil Accident

Response Services (French acronym SDIS). Secondly,

analysis of the event revealed sub-standard maintenance

followed by sub-standard operation. I observe increasing

care in observing the fire rules with players that are

motivated and respected: plant response staff, Risk

Management Department technicians, and fire brigade

officers. Once again this year, I would like to emphasise

the care needed in replacing the first generation of fire

brigade officers, and I encourage the plant managers to

focus on fire prevention as a priority matter.

I also note the forced loss rate (during reactor

operation) which confirms the progress made in 2011.

With an average rate of 2.8%, the French plants are now

at a good international level. I see this as the combined

effect of the very substantial investments begun some

years ago to address the aging of some main components

(alternators and transformers) and the progress with

rationalisation of the activities performed with the reactor

in operation, together with far stricter management of

the technical hazards. These results, recorded over the

last two years (was above 5% in 2010) are contributing

to nuclear safety by reducing the number of unplanned

reactor transients. Nonetheless, I regret that we are not

yet seeing comparable progress with the extension of unit

outages, which is also highly prejudicial to nuclear safety.

Finally, I would like to emphasise the high availability of

the engineered safety systems such as the safety injection

system, the steam generator auxiliary feedwater system, and

emergency diesels with the very low unavailability factors of

0.13%, 0.01% and 0.04% respectively (WANO indicators).

The operating organisation must be constantly vigilant to

minimise the outage time for maintenance and testing of

this indispensable equipment to minimise accident risks

and mitigate their consequences. The results for the French

plants are also among the best in the world.

Subjects for attention

The nuclear safety significant events detected during unit

outage activities and during activities conducted with the

reactor in service are similarly numerous in both cases, but

12

NUCLEAR OPERATING SAFETY: CONTRASTING RESULTS

their impact on nuclear safety is substantially greater during

unit outages (events classified as nuclear safety significant

and violations of the technical specifications for operation).

More generally, I am still concerned about the degradation

of some of the lines of defence essential for the proper

execution of our operating activities, despite the actions

taken. In 2011, I already drew attention to this issue

affecting our core activities, at a time of staff generation

turnover. As regards maintenance work, pre-job risk

analysis, technical checking and requalification of

equipment after maintenance have not been up to

standard. As regards operations-related activities, I still

observe weakness in the configuration and alignment of

systems, as well as in conducting surveillance tests to test

the operability of our nuclear safety equipment. Control

room surveillance remains, to a lesser degree, a subject of

concern, especially during unit outages.

It is noteworthy that the results for surveillance tests and

violations of the technical specifications for operations,

our highway code, which had been improving for a

number of years, slipped back perceptibly in 2012. I

would like to emphasise that, for the latter in particular,

excursions outside the authorised operating envelope are

in themselves serious, and undermine the credibility of the

operating organisation in the eyes of the nuclear safety

authority. In particular, there has been a significant increase

in cases of failure to comply with the actions laid down in

waivers that needs to be resolved.

Again this year, I note that equipment modifications

have been the cause of an excessively large number of

nuclear safety significant events, and that the trend is a

worrying one. During my visits to the plants, I have found

the motivation of the joint Nuclear Engineering Division and

Nuclear Operations Division teams to be good. However,

all too many matters are still being sent to the plants at

a late stage, preventing proper planning, particularly

during unit outages. The quality of the case files for

certain modifications is not up to standard and can result

in severe constraints on operations, if not discrepancies,

mainly during unit outages. I believe this issue needs to be

analysed in depth by the Nuclear Engineering Division and

the Nuclear Operations Division so as to reverse the trend.

In the plants in the UK

In EDF Energy, the number of nuclear safety significant

events declared in 2012 dropped slightly (to 4.6 per

reactor from 4.7 per reactor), with different declaration

rules in France and the United Kingdom reflecting the

requirements of their respective nuclear safety authorities.

A better yardstick is the number of events ranked level 1


NUCLEAR OPERATING SAFETY: CONTRASTING RESULTS

on the International Nuclear Event Scale in 2012. This also

decreased to 0.8 per reactor and is now lower that for

the French plants. The events corresponding to violations

of the technical specifications for operation substantially

increased (1.67 per reactor), partly due to the way in which

such events are defined to facilitate comparison with the

results of the French plants. I note that, faced with this

deterioration, EDF Energy NG has mobilised an inspection

team to determine the exact causes. The first indications

point to the increasing difficulty with procedure adherence

(compliance with process rules) confirming the necessity -

also in the UK - to simplify procedures wherever possible

so the profession of nuclear operator is made easier.

Plant alignment errors were also the subject of the same

initiative and I will make a point of having progress

reported to me during my visits to these plants in 2013.

At EDF Energy, automatic scrams need to be considered

with manual reactor trips as the British procedures more

frequently require the operators to manually trip the

reactor before the automatic functions operate. The 2012

results show progress (1.48), but are still too far from the

best international levels.

As concerns fire, the increase in the number of outbreaks,

even though minor, confirms that fire hazards need to be

the subject of increasing vigilance and determined action.

During my visits to the plants, I found that the condition of

the fire protection systems could be improved and noted

that there was a management alert (an internal oversight

Level 2 Advice) on one of them. I already pointed out in

2011 that the WANO peer reviews had been finding the

level of fire prevention to be insufficient for a number of

years. The corporate peer review carried out by WANO

at EDF Energy in October 2012 reiterated this point. I am

happy to see that the comparison was launched in 2012

with the French plants and is focusing on the state of fire

protection systems to properly address the needs.

I would like to emphasise the good levels of availability

of the engineered safety features in the Advanced Gascooled

Reactor plants with unplanned capacity loss factors

of 0.3%, 0.1% and 0.3% respectively (WANO indicators)

and the exceptional results for the Sizewell B pressurised

water reactor for which the unplanned capacity loss factor

for these safety systems has been zero for a number of

years. This year, I also observe a reduction in the forced

loss rate (units in service) that has been reduced to 8.9%

(compared with more than 19% in 2010).

Finally, I would like to draw attention to the improved

operating results for the fuel route machines of the

advanced gas-cooled reactors, which have a close

correlation with nuclear safety. The significant progress,

confirmed in 2012, has resulted from the effective use of

a composite performance indicator and the considerable

work performed by the staff.

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

In the Constellation Energy Nuclear Group

plants

The number of significant nuclear safety events declared

by Constellation Nuclear Energy Group (CENG) remained

stable at close to 11 per reactor in 2012, the declaration

rules being different in the USA where INPO handles filing

and analysis.

None of the events graded on the INES exceeded Level 1 in

2012, the factor slightly increasing to 0.8 per reactor.

At CENG, as at EDF Energy, it is necessary to consider

scrams combined with manual reactor trips as the

American procedures more frequently require the

operators to manually trip the reactor before automatic

functions operate. The results for 2012 represented a slight

deterioration (0.87 per reactor), far from the achievements

of the period between 2006 and 2009. The results differed

considerably between the Calvert Cliffs, Ginna and Nine

Mile Island plants.

I would like to draw attention to the capacity loss factors

for the engineered safety functions consisting of the safety

injection system (0.2 to 0.45% depending on the plant), the

auxiliary feedwater system (0.1 to 0.9%) and the standby

diesel generators (0.7 to 1.5%). Although these results are

broadly comparable to those of the other reactors in the

USA, they are well below European levels (by a factor of

5 to 10). I am left wondering about the appropriateness

of operating modes for equipment so important for safety

such as the standby diesel generators, and I commend the

action recently begun by INPO to make progress in this area.

I note the good forced loss rate (units in service) for 2012

for the three pressurised water reactors at around 1.5%.

However, with an average factor of 3.1%, the CENG

reactor results are in the lower half when compared with

those of other American operators and vigilance is required.

Although the combined unplanned capacity loss factor

covering units in service and outage extension is very low

compared with the figure for the French installations with

different operating conditions, they have been worsening

slightly over the last five years. I would like to once again

emphasise the positive effect on nuclear safety, for the

entire group, of such a capacity level with as few unit outage

extensions and hence disturbances for the operators.

I would also like to point out the existence of chemistry and

fuel indicators which are given the same importance by the

plant managers as the above.

Finally, I am pleased to see the role played by INPO which

is challenging plants on their performance levels and

setting in place an effective benchmarking system. I must

highlight the significant number of indicators for the

CENG nuclear units which are in the INPO last quartile.

13


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Fuel performance

I would like to emphasise the importance of nuclear fuel

reliability, as it is the fuel cladding that constitutes the

first technical barrier of the defence in depth. In France,

the special “foreign material exclusion” policy designed

to protect the fuel cladding integrity has made progress,

but lags far behind what I have observed in the USA. I

emphasise the importance of due regard for this policy in

maintenance work.

Although I am pleased to see the stability of the fuel

management policy in recent years, which is what the

operators needed, I wonder about the impact of the fuel

cycle adopted for most French 900 MWe reactors on the

operating aspects. Adopted for technical and commercial

reasons which are mostly related to fuel recycling, this

choice results in one outage a year for these reactors,

representing a major challenge for the plants with four

and six nuclear units. This is at odds with the practices

of most other operators in the world, who have adopted

cycles of 18 to 24 months, such as Calvert Cliffs Nuclear

Power Plant operated by CENG where there is only one

outage every two years. Have we properly assessed all

the consequences, not least in terms of nuclear safety,

of our policy which determines our capacity to carry out

increasingly busy outages at such a frequency?

I commend the existence of the “fuel community” headed

by the Nuclear Fuel Division, linking up many bodies with

the EDF Group. This provides the impetus needed to inspire

this profession so vital to nuclear safety and maintaining

a high level of expertise, offering rich and varied careers

while fostering professionalism in our experts. I would

like to highlight the need for commitment by all those

involved to ensure full success of this enterprise.

14

NUCLEAR OPERATING SAFETY: CONTRASTING RESULTS

Receiving a new fuel assembly


NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

03/ NUCLEAR SAFETY

MANAGEMENT: REMAINING

VIGILANT

An operating team briefing

Nuclear operating safety depends on three aspects: equipment, organisation and skill.

Inside the EDF Group, the state of the equipment essential for nuclear safety is carefully

monitored. In France, the organisation of operations-related activities, particularly those

performed during unit outages, still lags behind the best international practices. In a context

of massive renewal of skills, this situation is highly detrimental to the quality of operations

and, as a result, compromises nuclear safety.

DEPLOYING THE GROUP’S NUCLEAR

SAFETY POLICY

I commend the fact that the first overall EDF Group

nuclear safety policy statement was approved by the EDF

President in February 2012 and circulated in the nuclear

plants. I particularly hail the initiatives taken at a very early

stage by EDF Energy to deploy the policy. In France, the

Nuclear Operations Division has also been taking action

(integration into training schemes, the Nuclear Safety

Memento, the new Licensed Nuclear Facility Order and

the Nuclear Safety and Management Guide). This is an

opportunity to be grasped by all managers in the

nuclear industry to give meaning to the actions to be

taken and for nuclear safety to be paramount in everyday

action. During my visits to the plants in 2013, I will verify

the continued application of the campaigns in progress

and announced in 2012.

THE MANAGERS: FOCUS ON PRIORITIES

AND LEADERSHIP

Overall, the outlook of the plant managerial staff is

correctly centred on the essentials; the priority of

nuclear safety is unambiguously stated by the

plant managements. This year, I once again met many

operating shift managers in France and the UK. Inside

EDF SA, the situation is relatively unchanged since last

15


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

year as regards their freedom to step back and put

things in perspective, their clearly recognised authority

in operations and the reinforcement of their managerial

authority. I would like to once again emphasise the need

for the plants to address this issue, which is of the highest

importance, affecting the last line of defence, which all

too often has to play its role in operations. I nevertheless

observe progress in the organisation and content of

the daily safety analysis confrontations between the

operations shift managers and the safety engineers, and

I am also pleased to see that these are now covered in a

corporate rule set.

The situation of the front-line managers is not

improving either. They are, however, now better

trained, due to the presence of the highly-appreciated

management academies, and their commitment is

unflagging. Yet they are still facing the same everyday

difficulties which involves fully devoting their time to

their staff, who are all too often physically distant and

distracted from their core profession by numerous tasks

of little actual added value. I have been calling attention

to this situation for a number of years.

It has now become indispensable to make many of the

work processes more meaningful, as some have become

routine administrative matters, and to use simple good

sense in operational implementation. Success in this area

will depend mainly on getting the managers behind it.

But there is a need to free them from tasks that all too

often keep them away from their core work, their staff

and their working conditions.

The recent words of Robert F. Willard, the new CEO of

INPO, reflects this when he emphasises that “there is an

urgent need to tackle the question of the operator’s job

becoming increasingly bureaucratic and over-complicated

and the quality of leadership, the determining factor in

the standard of operations”. His definition of leadership

needs to be borne in mind: “what constitutes a rampart

against the type of management that distracts from

operations”. I encourage the plant managements to take

action to reinforce leadership at all levels, using what has

been begun at EDF Energy as inspiration.

THE CORE PROFESSIONS IN FRANCE ARE

IN DIFFICULTY

Last year, I warned about preserving skills in France

with operations and maintenance confronted with

a massive turnover in professional staff: insufficient

management presence in the workplace and, in the case

of maintenance, the still inconsistent monitoring of jobs

entrusted to contractor staff. The findings in 2012 once

again confirmed the need to consolidate our technical

know-how.

16

NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

The observations in my 2011 report on the operating

profession remain true. Turning the considerable

investment in human resources initiated by the EDF Group

into a success remains vital for nuclear operating safety. It

depends on making the recently-initiated major changes

to the professional skills by substantially improving

the training provision and by increasing the availability

of operating staff to other areas. I reiterate my call to

the managers on all levels to give more thought to

operating when making decisions.

Just like the operating profession, the maintenance

professions (including control and instrumentation)

affected by the massive turnover of skilled staff are also

being destabilised by change and innovation, such as new

methods of equipment maintenance (such as the INPO

equipment reliability process, AP- 913, for the continuous

improvement of the reliability of equipment and systems),

review of all the operating modes in the interests of

standardisation for the new nuclear technical information

system SDIN, a new directive on multi-year maintenance,

the AMLIE spare parts management campaign, and the

new organisational structure for units either in service

or outages (including the continuous monitoring of

installations during unit outages). Maintenance services

are faced with the need to upgrade the requirements in

terms of monitoring tasks entrusted to contractors and to

devise new activities, such as those to be performed by

surveillance staff.

The weaknesses discovered in recent years are

indeed still present this year as regards many basic

aspects of maintenance (risk analysis, erection, spare

parts management, technical checking and requalification)

and of operating (reactivity control, surveillance of work

in the field and in the control room). I devote Chapter 7 to

this topic, which needs to be considered in detail.

I am carefully monitoring the situation as concerns

maintenance in the EDF Energy plants which, before

the French plants, set in place a reliability improvement

system based on INPO’s AP-913. During my visits to the

EDF Energy plants, I was surprised by the slowness of

progress concerning the reliability of equipment affected

by the system. At the current stage, it is hard for me

to say whether this weakness results from incomplete

deployment or insufficient data from the process for

guiding maintenance decisions.

BETTER MANAGING THE DESIGN BASE

I once again emphasise that, in France, we need to make

up for the considerable delay in eliminating as-built

discrepancies relative to the design base. With the support

of the Nuclear Engineering Division, the Operations

Engineering Unit has devised a proactive action plant


NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

which was shown to me, and I was pleased to see the

substantial progress made. I encourage them to persevere

with their efforts.

As regards the stability of the operations rule set in France,

I regret that there has been no substantial progress. I

observe that EDF is, according to the ASN, the operating

organisation that makes the greatest number of changes

to its operations rule set and technical specifications. I

note that EDF considers these changes are essential as

they reflect the ASN’s requirements. Although allowance

for experience feedback for our plants is an obligation

and fosters progress, I hope that a reasonable balance

can be found.

THE INDEPENDENT INTERNAL NUCLEAR

SAFETY ORGANISATION (FIS)

Skills to be preserved in the plants

In France, the staffing numbers of safety engineers satisfies

the requirements, barring a few exceptional cases. These

engineers nevertheless permanently work on a just-intime

basis and their actions are vulnerable to unplanned

events, as is the case for the operating shift managers.

The initiative taken by the director of a two-unit plant

(the most exposed to this type of situation) to increase the

number of safety engineers is instructive. Furthermore,

more than 80% of the safety engineers are from

the young engineers’ recruitment route and those

that were previously in operating teams (operating shift

managers and their assistants or simulator instructors) are

now becoming increasingly rare in the plants. I consider

that the alert needs to be given about this trend.

I would also like to draw attention to the situation in

the auditor centres in the nuclear safety and quality

departments, where numbers and skills vary greatly. They

are not always able to correctly check maintenance work

and do not yet play a role of guiding the maintenance

services in a way similar to that of the safety engineer with

regards to process-related services.

Nothing is acquired once and for all

The willingness of the Independent Nuclear Safety

Organisation to listen has been satisfactory in

most of the plants visited, despite the fact that their

relationship with the management was not always close

enough. The safety engineers - who have a difficult and

challenging job - need to maintain a close relationship

to establish their authority. I encourage the Station

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Directors to develop close, special relationships with

their safety engineers.

At plant level, the Nuclear Safety Authority may be

tempted to position itself as the “party to call” when

there is unwillingness to listen to the nuclear safety advice

given by the Independent Nuclear Safety at the plant. It is,

however, absolutely necessary to go through the referral

levels inside the company, at both plant and fleet levels.

This year, the Directors of Operations (DDO roughly

equivalent to a Chief Nuclear Officer in the UK or the USA)

have met FIS staff from every plant, which is an excellent

practice. The independent voice must feel that it is being

listened to by the fleet-level management.

I also observe that for most of the significant events that

occurred in 2012 and which led to setting up a plant or

corporate emergency management organisation, the

role of the safety engineer was insufficient. Their mission

in such a situation is laid down in the incident response

procedures which, it seems to me, guarantees their role.

Furthermore, they provide the emergency response

staff (particularly for the No. 1 Management Command

Post personnel and the shift operating manager) with

valuable assistance in diagnosis and putting the event in

perspective, which is indispensable for proper functioning

of the organisational defence in depth. The latter point

merits special attention.

The Independent Nuclear Safety function at

fleet level

I would like to draw attention to the lack of clarity

surrounding the Independent Nuclear Safety function

at fleet level, essentially due to the large number of

players responsible for nuclear safety (the Director

Delegate for Nuclear Safety, senior advisors, the Nuclear

Safety Performance Group members and the Nuclear

Inspectorate). I observe with satisfaction this situation

is being reviewed and recommend that the remit also

extends to the difficulties in managing skills at corporate

level in this context. Sorting out this issue, which merits

close attention, should help the players in the plant

Independent Nuclear Safety Organisation in their task.

The results of the overall assessments of excellence

are now the subject of reporting to the Directors of

Operations (DDOs), a change that duly clarifies their

roles. The associate director for nuclear safety at fleet

level takes action with more distance, in the true spirit

of an independent nuclear safety function, alongside the

DDOs who are well aware of the actual situation in the

plants and in charge of integration and monitoring of

performance.

17


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

THE OIU: AN INDEPENDENT INTERNAL

CHECKING ORGANISATION

This year I met the staff of the User Internal Organisation.

This body, which is part of the Nuclear Engineering Division,

operates in accordance with the legal provisions relating

to pressure equipment. The regulations require that all

such equipment be subject to “essential requirements”

from the manufacturing stage and imposes conformity

assessments. In France, supplementary requirements

were introduced under the nuclear pressure equipment

order in 2005. The ASN keeps a close watch over

such organisations to ensure strict compliance of the

requirement for impartiality in its technical assessments

and rulings, and the Inspector General for Nuclear Safety

constitutes the highest internal echelon for referral within

EDF SA. This year I verified the strength and depth of the

EDF User Internal Organisation and the manner in which

it organised the roles of its inspectors.

A DEVELOPMENT IN THE INDEPENDENT

ORGANISATIONS AT THE EDF ENERGY

PLANTS

At EDF Energy, one of the three safety engineers in the

Nuclear Independent Oversight plant inspection service

has progressively become dedicated to checking the

safety of the nuclear units by technical confrontation

with the operating shift manager on a daily basis.

Acceptance of this daily confrontation by the operating

shift manager warrants firm backing. I note, however,

that these developments remain somewhat different from

the practices in the Nuclear Operations Division in France.

These UK engineers do not have the same roles in the

emergency plan as their French counterparts.

Heysham 1 power plant

The local Nuclear Independent Oversight chief also reports

to the Plant Manager once a week, to the Station Director

once a week, as well as to the Technical and Safety

Director at corporate level. The Nuclear Independent

Oversight teams in the plants report organisationally to

18

NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

the corporate Safety and Regulation Department (the

internal regulator). I note that the quality of their relations

with the plant management is not equal in all the plants.

I still wonder why these internal inspection services are

not directly attached to the Station Directors. Although

the concept of resident inspectors may offer substantial

advantages, I also think that the director of a plant needs

to be able to count on a dedicated checking service that

can independently report on the state of nuclear safety in

the plants.

Finally, I have noticed in this context the existence of a

progressive alerting system, or escalation process, in which

alerts are passed upward from the Nuclear Independent

Oversight team, through the different management levels

at plant then at corporate level if the response at plant

level is tardy.

IN FRANCE, RELATIONS WITH THE ASN

NEED TO BE STRENGTHENED

A full-time activity for the nuclear plants

The engineers in charge of relations with the ASN, a key

group with vital skills, have been found to vary greatly

from plant to plant in terms of numbers and abilities: this

is in my opinion an issue that calls for vigilance.

Having proper daily relations with the ASN and its

specialist advisor (IRSN) means that the plants must

possess the solid skills needed to guarantee a toplevel

fully-transparent technical dialogue. I have seen

in some plants that this type of team has been set up,

being close to the management and recognised by the

ASN. The situation is still too variable between sites and

I encourage the plants to acquire the resources needed

in terms of engineers liaising with the ASN so they are

sufficient in numbers and quality.

I have also noticed in some plants that the practices are

very good, with regular meaningful contact between the

Plant Directors and the ASN regional branch directors,

making it possible to better prioritise the issues and avoid

misunderstandings.

Developing internal licensing at corporate

level

I would like to emphasise the need for developing this

system in accordance with Article 27 of the Nuclear Safety

and Transparency Act, which may be demanding for the

operating organisation but is empowering and can make

relations with the ASN far simpler and effective. Although

progress is still modest, I am pleased to see that the


NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

campaign on temporary modifications to the technical

specifications for operations is to bear fruit early in 2014.

FACILITIES UNDER DECOMMISIONING IN

FRANCE

There are two different situations: facilities on sites where

there are nuclear plants in service (the most frequent

case) and the others. I would like to draw attention to

the manner in which the nuclear operating organisation

exercises its responsibility where the stakes are high

as concerns industrial safety, radiological safety and

environmental protection, necessitating clear division

of responsibilities. I recognise the role played by the

Decommissioning, Waste Management & Environmental

Engineering Centre (French acronym CIDEN) and

motivation of the staff supervising the work, which may

be highly specialised. During my visits, I have also noticed

the excellent cooperation between such workers and the

nuclear power plant staff.

Decommission work on the Superphénix FBR installations

THE NUCLEAR OPERATIONS DIVISION’S

NUCLEAR INSPECTORATE AND

DEVELOPMENTS IN THE INTERNAL

CONTROL PROCESS

In 2012, the Nuclear Inspectorate (French acronym IN)

began the new Overall Assessments of Excellence and

its inspection programme is now scheduled to alternate

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

with WANO peer reviews, every four years. During the

follow-up visits two years after the main visits, the plants

are now the subject of an in-depth inspection every

two years and, each time, the Nuclear Inspectorate and

WANO visits coincide. This considerable tightening of

checking conducted in the nuclear plants results in a

substantially increased workload for them and for the

Nuclear Inspectorate. The plants will benefit fully from

this, insofar as they take the new arrangements on board,

both in the plants and the fleet-level departments.

I have been able to verify that the resources allocated to the

Nuclear Inspectorate enable it to perform its mission and

properly cover all fields needing attention, which are now

extended to operations (multi-year maintenance, units

in service and during unit outages) as well as industrial

safety. I stated in my previous report that this extended

scope needed to be the subject of special vigilance.

Considering the results of a first year of functioning, I see

no undesirable trends.

I note that the take-up factor of recommendations

resulting from an overall assessment of excellence

has slipped back to 55% this year. This calls for

vigilance and I will be monitoring the situation during

my forthcoming visits.

I am also pleased to see that the Nuclear Inspectorate

has established closer relations with its counterpart at

EDF Energy in Barnwood, the Safety and Regulation

Department.

The Nuclear Inspectorate also greatly contributes to

the international dissemination of EDF’s control and

verification practices; it also effectively provides training

support for Chinese and Russian operating organisations

with which EDF is increasingly cooperating in the field of

nuclear safety inspection. It also provides an indispensable

link with INPO.

A WANO CORPORATE PEER REVIEW

MUCH APPRECIATED AT EDF ENERGY

I hail the initiative taken by EDF Energy to host

another international peer review of its nuclear operations

activities at corporate level. This assessment by WANO in

October 2012 was taken very seriously by the managers

and was the subject of massive preparations. Although I

agree with the final assessment, firstly I notice the strong

points identified, such as the high level of expertise and

support provided by the corporate engineering services to

the advanced gas-cooled reactor plants in response to the

Fukushima accident, the training accreditation system, the

leadership training programme, the good organisational

alignment and the dynamic publicity campaign about

making nuclear safety a top priority.

19


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

From the results of the review, I also see the following

scope for progress:

• the reliability of the equipment and systems is not yet

sufficient,

• the performance goals are not sufficiently ambitious,

nor do they correspond to the best international

standards,

• not enough credit is given to the use of independent

networks, at either plant or corporate level,

• the impact of the corporate campaigns on the plant

resources are not being adequately assessed.

I made good note of the fact that the EDF SA plants will

also be the subject of a corporate peer review, which is

to be carried out by the IAEA in the autumn of 2014,

the first such review since a WANO corporate peer review

carried out ten years earlier.

THE ASSESSMENT AND SUPPORT UNIT OF

THE NUCLEAR ENGINEERING DIVISION: A

POWERFUL TOOL

The Assessment and Support Unit (French acronym MAE)

has been provided with the skilled personnel needed to

properly perform is checking mission. I am also pleased

to see the work being carried out in cooperation with

the Nuclear Inspectorate, ranging from the participation

of Assessment and Support Unit inspectors and civil

engineering experts in the engineering centres to

assessments of joint Nuclear Engineering Division and

Nuclear Operations Division teams during overall excellence

assessments. I also consider that the arrangements for the

engineering centre overall assessments every three years

are solid and well organised by the Nuclear Engineering

Division managers.

A SECOND WIND NEEDED WITH THE

OPERATING RIGOUR PLANS

Although I welcome the existence of the fleet-level

support arrangements for the plants facing problems, I

sometimes wonder about their effectiveness. During my

visits to the plants, I have noticed that they are only rarely

mentioned as powerful means of improving the situation,

which is often ascribed to the fact that they have been in

place for too long. No second wind was found. I would

also like to draw attention to the fears expressed in the

plants that have recently achieved better results that the

fleet level may consider them to have been “cured too

quickly”.

20

NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

THE NEED FOR ANALYSIS OF NUCLEAR

SAFETY VERSUS PRODUCTION

The technical events in 2012 and the usual tension

between nuclear safety and generation goals make

it all the more necessary to lend vigour and meaning

to such arrangements, at fleet and plant levels. I note

that, for instance, time is no longer taken for debriefing

and analysing the technical decision-making after

contingencies. The here-and-now often takes all

the attention, and time out is not being taken often

enough to think things over and draw conclusions on

the situations encountered. Communicating about and

explaining decisions relating to nuclear safety calls for

special care and taking the time to make sure that all

involved have the basic minimum of information needed

to understand. Indeed, when it comes to nuclear safety,

things cannot be taken for granted and I have met staff

who feel left out.

In 2011, at Ginna Nuclear Power Plant in the USA, I was

shown a presentation on this type of post-event analysis

which had highlighted inappropriate trends in the

operational decision-making process. It subsequently led

to the re-design of the technical contingency management

process. I encourage the development of similar practices

in the French plants.

I have also taken note of the EDF Energy campaign

launched in 2006-2007 after the discovery of cracking

in the boilers of Hinkley Point B and Hunterston Power

Plants. After thorough technical review, it was decided to

reduce the power of the reactors by around 25% nominal.

After a number of years of operation at this level, the

positive effects for nuclear safety have been confirmed

by checking, as the cracking has ceased. Furthermore,

this mode of operation is positive for the lifespan of the

graphite and hence of the four nuclear units. I commend

this type of decision as a good example of proper balance

between nuclear safety and power generating.

THE HUMAN FACTOR, FROM DESIGN TO

OPERATIONS

In France, I still see too little change in practices to

increase reliability and reduce human errors. This does not

appear to be a priority for the managers; the matter is

rarely mentioned and, finally, the application to activities

identified as important is neither widespread nor properly

done.

This situation differs sharply from what can be observed in

EDF Energy and the Constellation Energy Nuclear Group, in

both operations and maintenance. It is, however, a major

line of defence for reducing the incidence of sub-standard

operations and maintenance. The path successfully taken


NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT

by most of the control and instrumentation departments

and often by the fuel handling departments is there as a

good example.

I would also like to emphasise the role that can be played

by human factor consultants in the plants. They

are now well trained yet not utilised fully by the plant

managements. I would encourage the site directors to rely

more on their skills which can often helpfully complement

the “engineers’ view” alone. During my visits in 2013, I

will make a point of meeting them. I have also noticed

the limits of the socio-organisational and human factors

analyses recommended by the IAEA in INSAG 18. All too

many projects, e.g. the Nuclear Technical Information

System (French acronym SDIN) (see Chapter 8), or changes

in the operating procedures, have been deployed in the

plants without sufficient regard for the impact on the

operator. By contrast, I have found excellent work - from

the design stage - which unites operators, human factor

consultants, ergonomists and designers: at the Nuclear

Design & Construction Centre (French acronym CNEN)

for the future control room for the EPR and at the Power

MY RECOMMENDATIONS

I consider that our managers are not yet sufficiently

available to heed their staff and tackle the real problems:

let us allow them to act, provide them with

professional support and simplify their lives.

I also note persistent weaknesses in our operations and

maintenance professions, where a massive turnover

of skilled staff is now taking place and where too many

simultaneous changes in work practices are happening. I

recommend that, in France, there should be greater

investment in studies to determine the impact of

these numerous changes, with due consideration

of human, social and organisational factors. Similarly, I

would like to once again emphasise the need to deploy

human performance tools, the impetus to do so

appearing to be lost in the plants.

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Plants Operations Engineering Centre (French acronym

CIPN) for the modifications to the control rooms of the

1,300 MWe series plants to be integrated during the

third ten-yearly outages (VD3). I encourage the general

adoption of this type of approach.

HOUSEKEEPING

The state of the French plant continues to improve, with

sixteen rated as in “good condition”. I would like to draw

attention to the need to continue devoting the necessary

resources so these plants can reach the campaign

objective to achieve ratings of “exemplary” and to keep

them at this level.

At EDF Energy, I observed during my visits in 2012 that

there was some backsliding in this area. EDF Energy is

aware of this and has decided to implement a plan to

rectify the situation. I am pleased to see the cooperation

between the two sets of plants in this domain, with the

introduction of assessments and marking in accordance

with the exemplary conditions plan.

I also emphasise the need clearly felt for operating

competence in many other departments, such as

nuclear safety engineering, training, unit outages and

engineering. Such resources are generally in place at

EDF Energy and Constellation Energy Nuclear Group;

they need to be reinforced in France.

I would also encourage the managers to systematically

determine ambitious nuclear safety goals, the driving

force for progress, as was highlighted in the recent

WANO corporate peer review at EDF Energy.

Finally, in a context of increasing tension about

operational results, I consider more than ever that we

need independent nuclear safety organisations

that are respected and heeded by the plants, as well

as the corporate/fleet and Group levels.

21


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

22

NUCLEAR SAFETY MANAGEMENT: REMAINING VIGILANT


SAFETY IN THE WORKPLACE: FRANCE RISES TO THE CHALLENGE

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

04/ SAFETY IN THE WORKPLACE:

FRANCE RISES TO THE

CHALLENGE

Personal protective equipment worn in the turbine hall

Industrial safety is fundamental in performing nuclear operations. The unavoidable

continuous increase in the number of requirements concerning nuclear operations must

not be at the expense of the physical or mental health of our staff, or that of the contractor

companies working in our facilities.

Although the industrial safety results in France have improved somewhat in recent years,

they are still not nearly up to the best results worldwide. International experience feedback,

within the EDF Group itself, reveals that we need to be more ambitious in making industrial

safety an integral part of overall plant operating performance.

IN FRANCE, THE RESULTS ARE MEDIOCRE

AND VARY GREATLY BETWEEN PLANTS

The frequency of workplace accidents resulting in

absence from work per million hours worked for EDF and

contractor staff has improved over the last ten years. It

stood at 3.5 at the end of 2012, which is slightly better

than the figure of 3.9 for 2011. It is still well below the

best worldwide standards in the sector, which currently

stand at less than one. I also note great disparity between

the plants, and that there is little correlation with unit

outage activities. The difference in the frequency

between the best and the worst plants has remained

unchanged for a number of years, ranging from 1 to 6. I

consider that a difference this great is unacceptable: it

is a sign of shallow industrial safety and risk management

culture unworthy of the responsible nuclear operator we

strive to be.

9

8

7

6

5

4

3

2

1

0

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

Scatter of the overall “lost time accident frequencies

per million worked hours” in the French nuclear power plants

2010

2011

2012

23


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

THE RESULTS IN THE UK AND THE USA

ARE FIVE TIMES BETTER THAN IN FRANCE

In the UK the frequency of accidents resulting in absence

is 0.5, which is nine times lower than the median

frequency in France. For the broader situation comprising

accidents that did or did not result in absence per million

hours worked for EDF Energy and its contractors, the

frequency has been below 2 for a number of years. I note

that it remains above 11 for the French plants as a whole,

with comparable openness and traceability requirements.

At Constellation Energy Nuclear Group in the USA, the

frequency is 0.78 (INPO’s Total Industrial Safety Accident

Rate figure), slightly worse than the figure for 2011 which

was 0.75, after seven years when it was below 1.5.

Management involvement at all organisational

levels, combined with strong and determined motivation

from each employee can durably improve the situation,

as shown by the results of EDF Energy over the years.

Constant promotion of the zero-accident ideals by

management as part of the “incident and injury free”

approach, is contributing to maintaining motivation

among all involved.

KEEPING SIGHT OF THE ESSENTIAL,

HEEDING WEAK SIGNALS

As in the case of nuclear safety, there needs to be general

awareness that focusing on the indicator alone does not

result in disregarding any weak signals, forerunner events

and narrowly averted accidents.

Although there may be progress in debriefing after

fieldwork and narrowly averted accidents, as well as the

The Nine Mile Point 2 event

24

On18 April 2012 during the refuelling outage at Nine Mile

Point Unit 2, the 107-ton high pressure turbine casing

fell 39 inches to the turbine floor while being supported

on stands. Three workers who were performing work

under the shell at the time received minor injuries and

were able to exit from under the casing on their own. The

four metal stands used to support the casing had been

specially designed and fabricated for this application

to allow work to be performed in connection with the

extended power project. The cause of this event was

SAFETY IN THE WORKPLACE: FRANCE RISES TO THE CHALLENGE

use of experience feedback and the dissemination of good

practices, this is not the case in all the plants that I have

visited. I consider that narrowly averted accidents,

particularly in tagging and de-tagging (permit to work)

situations are highly important forerunner events that

need to be analysed by all involved to learn from them.

I was accordingly struck be such an event that occurred

at Saint Laurent Nuclear Power Plant during diving

operations in an intake channel. In view of how important

tagging is for both nuclear safety and industrial safety, I

will be focusing on this issue in 2013, particularly during

unit outages. I also note a narrowly averted accident in

April 2012 during a temporary storage operation of a

high-pressure turbine casing at Nine Mile Point Nuclear

Power Plant. Three technicians were working under

the casing when the temporary structure on which the

100 tonne high-pressure casing slipped. The immediate

quest for experience feedback made it possible to raise

awareness among the staff at the Constellation Energy

Nuclear Group of the dangers of lifting operations and

to question the temporary storage methods for heavy

components.

I am pleased to see that EDF Energy has a system of overall

monthly reporting of narrowly-averted accidents and

forerunner events. The good practice of learning from

narrowly-averted accidents is now adopted by the French

Nuclear Engineering Division and the Nuclear Operations

Division where monthly reviews of them are systematically

made at Division level. I would like to encourage these

periodic assessments with the individuals involved,

wherever work is carried out and decisions are made.

that uneven loading between the four stands caused

by an uneven floor, along with other factors, allowed

the stands to “walk” as work was performed on the

casing. The investigation revealed that CENG did not

have standards and procedures to control the guidance

on the use of cribbing or other methods to temporarily

support heavy components. Corrective actions included

establishing standards, procedures and training in this

area.


SAFETY IN THE WORKPLACE: FRANCE RISES TO THE CHALLENGE

THE CONTRACTORS: PARTNERS IN

PREVENTION

The results achieved by the contractors working in our

facilities are the result of our clearly-stated requirements

as much as their own commitment.

During my visits, I have found that the willingness of

the contractors to listen and rise to the industrial safety

challenge facing everyone varies greatly from one plant to

the next. Agreement on avenues of improvement would

help to address the needs identified.

Stricter surveillance of contractors with high accident rates

or insufficient management of prevention and industrial

safety issues would be an appropriate approach. I regret

that it is not seen as more important and better exploited

in the field.

THE DRIVING FORCE OF PREVENTION

STAFF NEEDS SUPPORT

During my visits to plants in France, I have met keen,

motivated prevention staff in close support at the work

areas. I am not convinced that the prevention staff is given

sufficient backing. The creation of the risk prevention

services has all too often been at the expense of industrial

safety, seen as the poor relation of risk management,

compared with radiation protection which is a legitimate

focus of attention.

I am glad to see the work begun this year at a number of

plants that I visited between those involved in prevention,

logistics and coordination with a view to simplifying and

facilitating field work. I would encourage the plants to

support this approach, particularly in the lead-up to the

General Refurbishment.

In risk management training and the associated refresher

courses, the role of conventional risk management is still

too limited. I note with interest the updating in progress

of the initial and refresher training content, with special

provision for training in prevention management.

THE AUTHORISED INTERNAL INSPECTION

DEPARTMENTS (SIR), PLAYERS IN THE

FIELD OF SAFETY

In France, this year, all the authorisations for the SIRs at

all the plants have been renewed. The staffing of these

departments with highly skilled workers must continue to

be the subject of special attention and can continue to

contribute to the career trajectories of engineers focusing

on prevention and industrial safety.

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

SIGNIFICANT IMPROVEMENT

IN INDUSTRIAL SAFETY AT THE

FLAMANVILLE 3 CONSTRUCTION SITE

The improved industrial safety results at the Flamanville 3

worksite, with an industrial safety action plan strongly

backed by the management and closely associating

the contractors and the operational staff in the field

represents an encouraging situation in terms of the

ability to maintain quality and industrial safety levels at

the construction site. This illustrates the importance of

management involvement in industrial safety. Extremely

strict requirements in the worksite stage will foster,

from the outset, the highest levels of nuclear safety and

industrial safety for start-up and commercial service.

90

80

70

60

50

40

30

20

10

0

-10 -9 -8 -7 -6 -5 -4 -3 -2 -1 MSI

Chooz

Civaux

Flamanville 3

Comparing the “lost time accident frequencies per million

worked hours” of most recent construction sites in France

SPECIAL ATTENTION FOR INSTALLATIONS

UNDER DECOMMISSIONING

I would like to draw attention to the importance of risk

management, industrial safety and radiation protection

in view of the types of hazards and their persistence,

with periods of intense activity, in decommissioning

worksites. This is the case with the Chooz A PWR and the

Superphenix SFR.

Despite the initiatives to improve risk management, I note

that the “lost time accident” frequency for the contactors

has remained high (11.3 in 2012 and 8.3 in 2011). This

deterioration calls for vigorous action in close liaison with

the contractors involved.

Training workshops, such as the one at Saint Laurent A

site to prepare for the work in the reactor vessel (with a

full-scale mock-up, replication of the working conditions,

briefing and debriefing with each worker, and strong

commitment by the contractor), constitute good practices,

which needs to be emphasised.

25


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

MY RECOMMENDATIONS

The excessive disparity in our industrial safety results is

being caused by the extremely hesitant involvement

of the operations management. The pressure needs

to be kept up at all organisational levels, rejecting

fatalism by promoting good practices and laying down

high standards and strict requirements.

Our involvement must be expressed by resolutely

projecting the idea that performance in industrial

safety cannot be disassociated from the global

performance when exercising our responsibility as a

nuclear operator. It may be a duty, but it is also a big

opportunity.

As part of tightening the requirements and increasing the

number of jobs being performed in the nuclear facilities,

I consider that a meeting of minds about industrial

safety (bringing together the EDF and contractor staff,

the employers, the prevention staff and those for whom

26

SAFETY IN THE WORKPLACE: FRANCE RISES TO THE CHALLENGE

the work is performed) offers an opportunity to rally

round common goals, adopting behaviour that fosters

joint progress on a permanent basis.

I encourage setting up risk management services in

the plants to provide managers with solid support.

Concerning this point, I consider that upgrading the

status of prevention in the professional career paths (at

both technician and engineer levels), reinforcing training

on workplace safety management, and fully using

systematic peer reviews in the field of industrial safety

are the managerial levers available to us.

This will not only lead to maintaining a very high level of

vigilance with the attendant results in terms of industrial

safety and risk management, but also to fostering

confidence in operational performance.


RADIATION PROTECTION: NEED FOR AMBITIOUS GOALS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

05/ RADIATION PROTECTION: NEED

FOR AMBITIOUS GOALS

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

In France, individual dose results are improving while collective dose results have been

stagnating for several years. The increased number of significant radiation protection events

and the lead-up to the General Refurbishment call for greater vigilance and initiatives to keep

exposure as low as reasonably achievable (ALARA). In the UK, the operating organisations

are focusing on contamination control. In Constellation Energy Nuclear Group, attention is

being drawn to the source term in boiling water reactors and the management of individual

doses.

THE INDICATORS

An overall decrease in individual doses

In France, the number of workers (EDF and contractor

staff) for whom the dose over twelve months exceeded

10 mSv has continued to diminish: 263 in 2012, 424

in 2011. Meanwhile, only three workers received an

individual dose above 14 mSv and none received greater

than 16 mSv. I approve the decision to reduce the prealert

threshold to 14 mSv, which has contributed to

this progress. The reduction in individual doses should be

able to continue. I would like to emphasise the grass-roots

contacts now taking place with all of the 56 contractors

with employees who have exceeded and annual dose

of 10 mSv. I also note that the contractors performing

jobs with the highest exposure (heat lagging, valve

maintenance, cleaning etc.) continue to be the subject of

extremely close vigilance by the plants.

At EDF Energy, the efforts to reduce individual doses

are also bearing fruit: the maximum individual dose was

8.18 mSv in 2012.

At Constellation Energy Nuclear Group, after a number

of years in which the number of salaried workers with

a dose of more than 16 mSv was low or zero, 2012 saw

nine with doses between 16 and 20 mSv, essentially the

result of a special job involving divers during a Nine Mile

Point Nuclear Power Plant modification.

Collective doses stabilise

From 2000 to 2010, the French average collective dose

per reactor in service dropped from 1.08 man-sieverts to

0.62 man-sieverts, combined with an increase of 50% in

the number of hours worked in controlled areas, from

27


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

4 million to 6 million. The collective exposure for all the

French nuclear power plants has stabilised in recent years,

with an increasing disparity between the 900 MWe series

and the others. In 2012, with six ten-yearly outages,

the collective dose in France was 0.67 man-sieverts per

nuclear unit, in line with the dose objectives.

In the UK, for AGRs and PWRs combined, collective

exposure has been properly under control and the

results were better than predicted. It stands at 0.06 mansieverts

on average for the AGRs and 0.04 man-sieverts

for Sizewell B, the only British PWR. The operational

challenges for the AGRs essentially relate to radiological

cleanliness, with comparisons between plants used to

determine the priorities for any action to be taken.

At Constellation Energy Nuclear Group, the collective

exposure in the PWR units has been halved over ten

years, and remains stable at 0.68 man-sieverts. However,

the collective exposure in the boiling water reactor went

back above 2 man-sieverts per reactor in 2012 (2.27 mansieverts).

Figures have not been this high seen since 2005.

The year 2012 was marked by chemical decontamination

operations and the continued removal of materials liable

to be activated, with a view to reducing the source term.

2,5

2

1,5

1

0,5

0

28

2000 1 2 3 4 5 6 7 8 9 2010 11 12

RADIATION PROTECTION: NEED FOR AMBITIOUS GOALS

PWR France

EDF 900MWe

EDF 1300MWe N4

PWR UK

AGR UK

PWR CENG

BWR CENG

Average collective dose per reactor per year in man-sieverts

Significant events more frequent in France

In France, the year was marked by a substantial increase

in the number of radiation protection significant events

(+24%) compared with 2011, mainly as a result of

radiography work (twelve related to it). The events

associated with work in red and orange radiation

hazard zones remained very numerous (4 for red,

30 for orange). I would like to draw attention to the

increased number of violations with respect to cordoning

off and disregard for dose rate alarms by both EDF

and contractor staff. This issue requires a firm, prompt

managerial response.

It also seems important to encourage willingness to

listen and to be attentive to weak signals and forerunner

events. Reporting events and near misses remains a key

factor in prevention, enabling stricter behaviour to be

introduced and appropriate corrective action to be taken.

I would also like to mention a rare case of a radioactive

source being jammed which occurred at Blayais Nuclear

Power Plant on 19 March 2012, with no consequences

for the workers in terms of exposure. This event took

an unexpectedly long time to rectify, but was correctly

managed by the nuclear operator.

RADIATION PROTECTION STAFF KEPT

BUSY IN THE PLANTS

In France, the UK and the USA, most of the staff I met

were devoted to the cause of radiation protection and

radiological cleanliness. Process maps are properly drawn

up, staff involved are empowered and regular in-depth

reviews are carried out by the nuclear inspectorate in

France, by WANO peer reviews in France and the UK, by

INPO reviews in the USA, and by the regulatory authorities

in each country.

Everywhere, the radiation protection and radiological

cleanliness are clearly announced and managed as key

performance goals in the organisation of unit outages.

The utilisation and the dissemination of experience

feedback, operation by operation, with the players

involved and the contractor staff workers should make it

possible to better determine practices sometimes differing

widely between the plants and to put forward highperformance

innovative practices for radiation protection

and radiological cleanliness.

As the work intensifies, including last-minute jobs which

are more commonplace in France, I fear that job planning

and associated feedback will not be up to scratch and

that the plant ALARA committees will flag. I consider that

the voice of radiation protection has to be clearly

enunciated and heard at every stage of planning,

execution and experience feedback management

throughout the unit outage and in every activity where

there is a radiation hazard.

The dose forecasts for the Major Refurbishment in

France necessitate special attention plant-by-plant and

operation-by-operation, beginning now. As regards the

replacement of the steam generators in the 1,300 MWe

nuclear units, I consider that the experience feedback

from the 900 MWe units and from nuclear operators

outside France will make it possible to determine, from

the outset, goals that are both realistic and ambitious. This

approach will necessarily require the close involvement of

the Nuclear Engineering Division the Nuclear Operations

Division, the plants involved and the contractors in a

properly-devised plan to ensure doses are ALARA.

The average dose per hour of work in controlled zones

has regularly diminished, dropping from 16 microsieverts


RADIATION PROTECTION: NEED FOR AMBITIOUS GOALS

per hour in 2000 to 7 microsieverts per hour in 2012. I

am pleased to see that this indicator is being taken into

account in the planning for the General Refurbishment,

making it possible to better determine priority actions,

and to reduce the individual and collective doses for each

profession.

In the plants visited, I also observed that radiation

protection and radiological cleanliness were progressively

becoming integrated into work management for plant

operations and outages, alongside specific activities such

as fuel handling and the treatment of solid waste and

effluents. I nevertheless regret that radiation protection

is still not formerly part of the continuous management

organisation team (Outage Coordination Centre manning)

during unit outages (French acronym COPAT).

THE EVEREST CAMPAIGN: EXTENSIVE

EXPERIENCE FEEDBACK NEEDED

I have always underlined the relevance of the EVEREST

Campaign which aims to enable entry into controlled

areas in conventional work clothing. By controlling

the sources of exposure and contamination, it sets out

to free most nuclear zones of excessive radiation and

contamination. It is now necessary to supplement the

experience feedback from the first three plants where this

campaign has been in place (data mainly derived from

C2 monitors triggered at controlled area exits) and from

periods of intense activity during unit outages for each

site with the contractors working there. It is appropriate

to clearly distinguish between improvements specific

to each of the three plants versus those which cover

contamination control practices applicable to all plants.

NINE MILE POINT: THE IMPORTANCE OF

THE SOURCE TERM

In 2012, at Nine Mile Point Nuclear Power Plant which

comprises two boiling water reactor nuclear units, I was

shown the chemical decontamination operations which

have reduced the source terms and exposure dose rate

by a factor of ten. The source term reflects the materials

chosen during the design phase and the quality of the

chemistry and operations. It directly affects the exposure

of the maintenance staff. It needs to be the subject of close

attention throughout the service life of the installations,

and not only in boiling water reactors.

Targeted clean-up operations are also carried out in

France. Integrating these operations into unit outage

planning shows the operating organisation’s commitment

to radiation protection. During my forthcoming visits, I

will make a point of assessing the application of these

arrangements in the plants.

4,5

4

3,5

3

2,5

2

1,5

1

0,5

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

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

Mile Point 2

0

1990 2 4 6 8 2000 2 4 6 8 2010 12

Dose rates at Nine Mile Point 2

RISK MONITORING STATIONS:

DEPLOYMENT NEEDED WITHOUT DELAY

Risk monitoring stations, equipped with cameras and

radiation meters for radiological monitoring, are already

deployed at Gravelines and Chooz Nuclear Power

Stations, as well as in EDF Energy and Constellation Energy

Nuclear Group. They combine the unit outage supervision

team, field workers and radiation protection technicians,

illustrating the value added by new technologies and

new organisational arrangements. The time taken to

deploy these new arrangements in France will need to be

carefully watched.

EDF ENERGY: EFFECTIVE RADIOGRAPHY

PRACTICES

In two years, EDF Energy has considerably reduced the

impact of radiography by systematically using collimated

sources in its AGRs. In 2012, these were used in 82%

of the radiography work. I strongly commend this action

which reduces the risk of exposure to ionising radiation,

making use of improved radiography equipment and new

non-destructive testing methods.

MAINTAINING A STRICT WATCH

FOR ALPHA RADIATION IN

DECOMMISSIONING WORKSITES

Certain special decommissioning jobs involve major alpha

particle contamination hazards, such as at the Chooz A

and Saint-Laurent A sites.

I have seen that the staff are watching the situation closely

and I can only encourage them to maintain their vigilance

in the long term.

29


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

MY RECOMMENDATIONS

The continuing quest to build on the good results

in radiation protection and radiological cleanliness

achieved in the last decade calls for a second wind, a

development that I strongly encourage. This is needed if

we are to cope with the increasing number of activities

associated with plant life extension and the forthcoming

General Refurbishment. This will require ambitious,

targeted goals.

I feel that the level of radiological performance we

are entitled to expect from a nuclear operator must

be grounded on proper arrangements to ensure

doses are ALARA. I consider that vigilance is needed

to ensure that the radiation protection services

are assigned sufficient staff with appropriate

qualifications. Higher status needs to be given to the

30

RADIATION PROTECTION: NEED FOR AMBITIOUS GOALS

radiation protection specialists, particularly during the

key phases of job planning and experience feedback.

Prevention in the fields of radiation protection and

industrial safety needs to be regularly promoted as

being fundamental to high performance in nuclear

power generation.

Given the excessive infringement of the basic rules of

radiation protection recorded this year once again, I

encourage once again the managers to reiterate

the requirements to their staff and in the field.

The influence of the source term on exposure leads me

to recommend maintaining a careful watch over

chemistry and the cleanliness of the systems during

operation as they govern the long-term situation.


TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

06/ TRAINING UPDATED AND BETTER

LED BY LINE MANAGMENT

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

The quality of training nuclear plant operating staff is of paramount importance for nuclear

safety. The current massive turnover of skilled staff at EDF SA constitutes an opportunity to

strengthen the managers’ commitment to training and renew the methods by which skills

are handed down to future generations. The development of synergy with EDF Energy -

competent in this field - can facilitate this process.

A TURNING POINT IN FRANCE

I am glad to see the good start of the Nuclear

Operations Division’s skills programme and of the

skills project at the Nuclear Engineering Division. With

excellent synergy within the EDF Group (France and UK),

the efforts are being concentrated on two key factors:

managers’ commitment and effective training.

The deployment of this programme is consistent with the

initial timetable, with four pilot nuclear plants until 2012,

and the addition of a second set of six by mid-2013.

At fleet level, I have seen that those in charge of the

nuclear power plants and their specialist advisers are

putting their weight behind this innovative project by

setting reasonable but ambitious goals: promoting the

use of the international rule set constituted by INPOs

Systematic Approach to Training (SAT) and making

possible training management accreditation by 2015.

The company has devoted considerable resources to this

objective, matching the scale of the announced ambition

with considerable scope for innovation.

To reach its goals, this programme will need to be given

unflagging support. I observe with satisfaction the large

number of key players and decision-makers at corporate

levels that are involved (deputy director, directors of

operations, training director, human-resources director

and profession supervisors), which of course calls for

proper overall coordination.

At corporate level, active promotion of

training and the professions

Corporate promotion of the professions has been

greatly intensified since 2010. This innovative approach

at corporate level is undeniably highly favourable for

the cross-fertilisation of the different professions with a

set of plants of this size. After exchanges for a number

of years with INPO and numerous nuclear plants in the

USA, 2012 saw the emergence of a rule set for managing

skills, according to which each plant will make a selfassessment

this year. In 2013, a first assessment of the

plants will be carried out by a joint team combining the

Operations & Engineering Training Unit (French acronym

UFPI), the Nuclear Inspectorate (French acronym IN) and

EDF Energy and, from 2014, the Nuclear Inspectorate

31


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

with integrate the results of these assessments in the

Overall Assessments of Excellence.

I also note signs of change for the better. For instance, the

human resources committee of the Nuclear Operations

Division is now devoting a substantial amount of time

to training (30%); the Directors for Operations have

intensified their involvement in promoting the professions

and enshrining these requirements in the NPP annual

performance contracts. I also note the excellent relations

established between the corporate profession supervisors

and their UFPI correspondents at Lyon and Bugey. To be

effective and pertinent, the supervisors need to devote a

substantial amount of time to the plants and to the UFPI.

I wholeheartedly support the recent overall review of

the maintenance professions common core knowledge,

which clearly illustrates what such a team can provide.

I am also pleased to see new impetus in linking between

the heads of departments and the training advisers

(operating, control systems and maintenance) under

the leadership of the Nuclear Operations Division’s Skills

Advisory Centre (PCC) with the active participation of

the UFPI. The Skill Programme now systematically plays

a role in providing these managers with insights and

information.

I wonder about associating the definition and promotion

of the nuclear safety professions with a body other than

the PCC, namely the Nuclear Safety Performance Group

in the Nuclear Operations Department (French acronym

UNIE/GPSN). The promotion of other professions is

missing an opportunity to better incorporate the basic

tenets of nuclear safety.

The revival of corporate-level training of maintenance

engineers is to be commended: it is designed to increase

the potential of the nuclear power plants with regards to

“technical” engineers, for whom the greatest need is in

maintenance. Training schemes for unit outage engineers

and project managers are now in place and common core

knowledge academies for incomers are also providing

special training for the main professions, thus confirming

their pertinence as well as being highly esteemed by all

the staff I have met in the plants.

I also note with satisfaction the confirmed success, from

the front-line managers to the Station Directors, of the

management academies, which now include dedicated

training advisers. I would nonetheless like to draw

attention once again to the basic training of the operating

shift managers, which has been updated but is still

leaving the main parties involved somewhat unsatisfied,

particularly concerning nuclear safety as directly applied

in the exercise of their profession.

32

TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT

Motivated managers in the plants

During my visits I have seen the increasing commitment

of the plant managers in training. More widely, the

managers appear to have properly understood their vital

role in the success of this programme and support it. Those

in charge of human resources in the nuclear power plants

are also being brought in to play a part in this programme

by the corporate promotion team. I am, however, still

wondering whether they are sufficiently free to attend to

training which now has high priority. I have indeed noticed

the influence and effectiveness of the training directors

present in all the EDF Energy and Constellation Energy

Nuclear Group plants, many coming from more technical

backgrounds.

The training committees (site, departments, teams) are

being set in place in the first pilot plants, headed by

managers provided with dedicated support (the new

profession mentors). I am pleased that the connection

between operations information (discrepancies, good

practices and performance) and the content of the training

are thus strengthened. These committees and, more

generally all the in-plant training promotion, require the

presence of these advisers who need to be sufficient in

numbers and of different professional profiles. They are in

place in four pilot plants, all visited within the last eighteen

months. For the rest of the programme, I note that it will

be necessary to recruit 150 to 200 staff for these functions,

with strict requirements concerning the past professional

career (experience in core profession).

I am also pleased to see the increased trainer staffing (UFPI

and part-time instructors in the nuclear power plants).

I was struck by the level reached in training resources in

the foremost plants, where they represent some 10%

of the personnel. Concerning this issue, I encourage

the development of short-term training secondments,

which has been successfully used in the UK and shows

considerable potential.

The simulator training of operating staff has major

implications for nuclear safety. In France, simulator training

reached twelve days on average per operator in 2012.

Despite the efforts made, I once again find that the goal

of 15 days per year per operator is still far from being

reached. Despite a very high usage factor for the simulators

(more than half the plants now have evening sessions),

the manner in which the operating departments

are organised is still not very compatible with the

training demands. This situation is not satisfactory and

far from the best international standards. Furthermore,

training for accident situations with complete teams

handling situations on a simulator specially designed to

test communication within a group under tension, appears


TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT

to take place too rarely, at a frequency of only one week

every two years.

I have duly noted the commissioning of five additional

simulators, beginning in 2014, to cope with the heavy

increase in training requirements, mainly stemming from

the current levels of new recruits. It is now a question of

abiding by the timetable.

The corporate training programme leaves too little space

for plant-level initiative and I still regret the insufficient

time devoted to normal operations and the problems

specific to each plant. This situation does not tend to

empower the operating shift managers and the heads of

the operating departments. The construction by 2016 of

local training centres (the first at Golfech Nuclear Power

Plant in 2012) containing new training and simulation

mock-ups is also a promising development. I insist on the

need to bring these core profession investments to term;

they are not just tertiary arrangements as I sometimes

hear stated. They are just bringing us up to international

nuclear industry standards.

I commend the increasing opening-up of our training

facilities to contractor staff (practical training schools

and Bugey Nuclear Power Plant maintenance training

centre) and the continued training of their management

staff (team leaders). Concerning this, I would like to once

again emphasise the possibilities opened up by e-learning

for our contractors, as is being practiced in the USA

with INPO’s NANTel system. I am surprised to see so little

initiative being taken in this domain.

Instructors on a simulator

The Operations & Engineering Training Unit,

technical support for the plants

I observe with satisfaction that the Operations &

Engineering Training Unit (French acronym UFPI) it now

proving its worth with the services it is providing to its

two main clients: the Nuclear Operations Division and

the Nuclear Engineering Division. Plant-level relations

between the training departments and UFPI and the

nuclear power plants are good. Accordingly, all the heads

of the training departments are now full members of the

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

extended plant management teams. At corporate level,

I am pleased to see that relations of confidence and

cooperation have been established. The creation of a

Nuclear Safety Advisory Section (MSQ) within the UFPI,

closely connected to the nuclear power plant MSQs, needs

to be emphasised. The avenues of progress that have

been identified closely correspond to the expectations

regularly expressed to me in the plants: faster response

to new training requirements and greater willingness to

listen to the trainees.

Although the training centres are now properly staffed

in terms of numbers, the profiles of the simulator

instructors remain worrisome as a result of the increasing

imbalance between instructors originating from the

operating professions and newly-qualified engineers.

In 2012, eight training departments out of twenty had

more than 50% of their trainers who were of the latter

type. They will be eleven in 2013 despite considerable

reinforcements of the Nuclear Operations Division staff

transferred to the training centres (65 in 2012 and 44 in

2010).

The significant increase in training relating to post-

Fukushima action (more than 300 people in the Nuclear

Rapid Reaction Force teams plus reinforcement of

the operating teams in the plants) will put pressure

on instructors and simulator time. The decision to

commission five additional operations simulators from

2104, benefitting from the latest technical innovations

(full-scale digital/tactile type) was widely expected and

corresponds to a need that I have mentioned a number of

times. This will, of course, need to be supported by a new

recruitment drive.

I note with satisfaction that the UFPI has introduced a

system for assessing the work methods of each of the

nineteen training centres; this assessment will eventually

be conducted every two years. This internal checking will

notably make it possible to confirm compliance with the

rule set for assessment of skills on simulators and the

results could well be subjected to independent checking

by the Nuclear Inspectorate during the overall assessments

of excellence.

The UFPI also possesses a substantial maintenance

training capability that compares well with the best

worldwide. I have visited the installations of the Bugey

Nuclear Power Plant training centre, dedicated to the

professions of maintenance, I&C and chemistry. I observe

with satisfaction the scope of innovation in the teaching

methods, with e-learning, serious games and learning

software. I also regret that these tools, which include

the valve software FOROB, are still not being sufficiently

promoted in the plants. The motivation of the trainers

and the quality of the mock-ups and equipment make

the centre outstanding, its slogan being “where the

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

professionals train the professionals”. I hail the solid

links that have been built up with a number of technical

colleges, such as André Malraux Lycée in Montereau and

Blaise Pascal Lycée in Saint Dizier. I would also like to draw

attention to the perceived mismatch, which is resented

by those in the field, between these innovations and

the state of our computer systems, with the capacity of

our installations and local networks to cope with these

applications not being guaranteed.

The utilisation factor of this training centre is very high.

The projected extension therefore appears absolutely

necessary to meet the requirements. The introduction

of mobile training installations for fuel handling in the

1,300 MWe nuclear units is also noteworthy, usefully

complementing the PWR Nuclear Steam Supply System

Fieldwork Technical Validation Experimental Centre

(French acronym CETIC).

The opening of numerous mock-ups and equipment to

contractor staff is noteworthy. Although this has been

done in an increasing number of domains (valves, waste,

reactor coolant pumps etc.), I regret that it is only marginal

in terms of overall training time. I have taken good note

of the centralised management of training in industrial

safety and radiological protection at Bugey Nuclear Power

Plant training centre. I see this as an opportunity to link up

this training to special requirements in the maintenance

profession and to reinforce the industrial safety aspects of

training, which is currently insufficient.

I have also seen the need for greater willingness to listen

to the needs of the Flamanville 3 maintenance staff, in

the same way as this has been possible in the case of

operating training.

The Operations & Engineering

Training Unit (UFPI)

34

The UFPI has 22 training centres. It is coping with

an exceptional increase in activity with 3 million

hours of training provided in 2012. The number of

instructors has increased from 350 in 2007 to some

700 in 2012 (1,150 in 2014). The Nuclear Operations

Division represents about 80% of its work, and the

Nuclear Engineering Division about 10%.

TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT

Training an operating team on a simulator

The Safety and Protection Training Institute

and its fire training centres

I visited the Avenières centre of the Safety and Protection

Training Institute (French acronym IFOPSE), a company

belonging to EDF. Together with the Roche-Bernard centre,

there are some 60 staff who are indispensable to EDF SA

for training its personnel in fire prevention and fire fighting

in the nuclear power plants. The value of this training,

which is mainly intended for the second-line response

staff of the plant operating and security departments,

is now widely recognised. It has enabled considerable

progress to be made in the plants. I am pleased to see the

increasing opening up of these centres for training of risk

management departments, fire supervisors and engineers

from the Nuclear Engineering Division; by focusing on

prevention, these centres can cater for other branches of

industry, with which the Safety and Protection Training

Institute also works.

New developments at the Nuclear

Engineering Division

The Nuclear Engineering Division also began a Skills

Project in 2012 as it is confronted with large numbers

of staff taking retirement and the need to take on more

than 400 young new arrivals a year, most of whom are

engineers. The nuclear engineering professional academy

is in place and I am happy to see that the Nuclear

Engineering Division and the UFPI have established an

initial partnership to prioritise training initiatives to be set

in place and developed. The Nuclear Engineering Division

training, much of which is at engineer level, necessitates

the secondment of skilled personnel and even experts

from the Nuclear Engineering Division. I have observed

that such transfers are still too infrequent.

I hail the RACINES programme (French acronym meaning

to succeed with activities by inter-generational skill in

engineering and the employability of all the employees)

rolled out this year. It is intended to transfer key skills by


TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT

creating solidarity between the incomers and outgoers

and by upgrading the work methods. In the Nuclear

Engineering Division’s engineering centres, I have also

met young engineers that were highly motivated

as they had been entrusted with important tasks.

This practice needs to be encouraged and I will be

watching how it develops. Nevertheless, I regret that

the young engineers of the Nuclear Engineering Division

are not far more exposed to the plants or seconded to

them, in departments other than the joint plant and

Nuclear Engineering Division teams. This situation is very

regrettable and does not prepare for the future properly;

I feel that there is a lack of ambition concerning this

point. Are we not about to miss a historic opportunity for

bringing engineering and operations together? I see this as

a chance to foster better understanding of the operator’s

needs while disseminating the designers’ intentions. The

engineering centres, which are severely challenged by the

short-term workload, need to give greater thought to the

long term.

I am left wondering about the absence of training

departments in the engineering centres. Perhaps

corporate departments this size e.g. 1,400 engineers at

the Power Plants Operations Engineering Centre (CIPN)

alone, merit having special arrangements, in liaison with

the UFPI.

Training logistics: the weak link in the chain

I deplore the absence of the significant progress in

this domain which is indispensable for proper overall

functioning (management of the courses available,

scheduling, enrolment, attendance invitations etc.). Far

from simplifying the work of the managers, the current

system has saddled them with an increasing bureaucratic

workload. Here again, comparisons with international

practices do not show us in a good light. This has become

a sensitive issue in the nuclear power plants, problems

with the Shared Services Division (French acronym DSP)

remain plain to see and apparently very hard to solve.

The approach adopted would appear to concentrate too

much on seeking to rationalise and reduce costs, and

not enough on the quality of the service rendered to

the clients (UFPI and the managers of the nuclear power

plants). I encourage all involved to resolve this without

delay.

EDF ENERGY, A ROBUST TRAINING

SYSTEM

The system in place, which is based on a Systematic

Approach to Training (SAT), is a solid one. It is supervised

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

by an accreditation board comprising a number of

personalities from outside the company. I have nevertheless

found that some plants are faced with difficult problems

when organising training in their operating departments

because of ill-adapted work schedules, a situation broadly

comparable to that in EDF SA. Simulator training is also

insufficient, with an average of 11 days per operator per

year, much the same as in France.

I am pleased to be able to report excellent synergy

between the EDF Energy and EDF SA staff in this

field. This cooperation takes the form of cross-checking

on numerous occasions, the sharing of experiences and

the secondment of personnel. In particular, I note the

participation of EDF SA representatives in the Sizewell

Nuclear Power Plant training accreditation review, as well

as the contribution of EDF Energy mentors in assessing

the progress of the Skills Programme in the French nuclear

power plants in 2013.

AT CONSTELLATION ENERGY NUCLEAR

GROUP

As mentioned in my previous report, the Constellation

Energy Nuclear Group plant training programmes are

properly provided for and are accredited by INPO. The

system in each plant is based on self-assessments and

regular external assessments, scheduled after INPO

overall plant assessments to make sure that the training

programmes correspond to the needs of the plant. In the

USA, I noticed that training is frequently and spontaneously

mentioned as a means of improving operational

performance. One of the strategic orientations of the

Constellation Energy Nuclear Group, relating to the quest

for excellence, clearly identifies training goals and the

INPO accreditation system. I also note that the average onsimulator

training time is a little over 12 days per operator

per year. During my visit to Nine Mile Point Nuclear Power

Plant, I was shown the situation concerning the renewal

of skills. I found that special attention was being given

to supernumerary staffing, with priority focusing on

the professions of operating, maintenance and control

systems, radiation protection and chemistry. The need for

highly-specialised engineering skills had been identified

and taken into account.

RENEWAL OF SKILLS IN THE EDF GROUP

At EDF SA, succeed with generation turnover

The recruitment is substantial and normally guaranteed for

the next three years at the Nuclear Operations Division and

the Nuclear Engineering Division on the basis of diagnosis

35


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

and the path laid down by the Nuclear Technology Division

in 2010. I would like to draw attention to the vital need

to maintain the effort. I am struck during my plant visits

by the concern still expressed on this point, the fear of

seeing the “tap re-closed”, despite the unprecedented

recruitment that has taken place over the last five years.

The memory of recent historical staff reductions has still

not faded.

Not all the professions at the plants are in the same

situation. I would like to draw attention to the need

for sufficient supernumerary staff, clearly identified

as such, in the maintenance departments, which is not

always the case. In the operating departments, recruitment

is in full swing and should make it possible to achieve

proper staffing levels in the medium term. However, the

demand for skills derived from operating is currently high:

safety engineers, simulator instructors, engineers for

work management for both units in operation and during

outages, and corporate engineering centres and post-

Fukushima work. I consider that a special effort needs to

be made for a few years to satisfy the needs as they are

vital for good operational performance.

I am pleased to observe the increasing success with

inter-organisational training, highlighted in my 2011

36

6

5

4

3

2

1

0

Operating

2007 2012 2017

Experienced sta Inexperienced sta

EDF Energy, a situation under control

The management of skills in EDF Energy is in no way

comparable to the situation in France (the annual departure

rates are lower), and recruitment has been regular over

the last ten years. Nevertheless, some 470 incomers are

now in supernumerary positions, corresponding closely

to the need for skills renewal. The basic common-sense

principle appeared to be respected in the plants visited:

on departure of an incumbent from a position, the

replacement is present at the plant and already trained.

The system for planning and monitoring the renewal of

skills at the Barnwood centre is straightforward, featuring

realistic allowance for basic training time and looking

forward to the long term (five to ten years). I was also

TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT

Trends in the proportion of experienced to new staff

in the operating and maintenance professions

report. I note that, in the nuclear power plants, this is

starting to work well in many departments, including

engineer training. I have, for instance, been introduced

to trainee engineers from the Ecole des Mines de Douai

engineering school on work-study contracts in the official

inspection departments.

I would also like to emphasise the situation in the newest

nuclear plants which are not yet experiencing massive

departures of staff on retirement. With little recruitment

currently authorised, they could well find themselves in the

same predicament as the first 900 MWe plants were five

years ago, with insufficient overlap between generations.

Careful planning is needed here to avoid replicating the

same difficulties as in the older plants.

I regret the absence of a clear overall policy for meeting

future staffing needs and engineering skills, and more

generally for coordination between the two main

players, the Nuclear Engineering Division and the Nuclear

Operations Division. The difficulty in satisfying the

demand for resources probably explains this situation to

a certain extent but I consider the two divisions would

gain greatly from promoting career paths including time

in both divisions.

6

5

4

3

2

1

0

Maintenance

2007 2012 2017

Experienced sta Inexperienced sta

pleased to see the good relations established with the

Nuclear Decommissioning Authority which manages the

Magnox-type reactors while they are being closed down,

enabling the judicious redeployment of the staff involved.

I would however like to draw attention to the particular

situation regarding the operating resources which I

consider will be stretched at some AGR plants which have

to perform multiple unit outages per year. These plants,

due to the changes in the technical characteristics of their

reactors which cannot be refuelled and defueled when

on power, need up to five unit outages per year. The

operating staff are under considerable pressure during

the outage planning and execution phases alike (they are

also responsible for handling the reactor fuel).


TRAINING UPDATED AND BETTER LED BY LINE MANAGMENT

I would like to once again emphasise the importance of

technical expertise for the AGR plants, where high-level

resources will be needed to meet the demands of the

MY RECOMMENDATIONS

Training inside the EDF Group is now benefitting fully

from the synergy and comparisons with EDF Energy and

American operators, who are setting the standard when

it comes to implementing the Systematic Approach to

Training (SAT). At EDF SA, I am pleased to see something

of an epiphany with recognition of the role and the

responsibility of managers in the development

of skills. I encourage continuing along this path by

making the most of the opportunity for opening

up and making comparisons within the EDF Group,

especially with regard to EDF Energy.

I consider that the company resources invested in

training are very substantial. I would, however, also

like to draw attention to the need to maintain the

investment over time as it prepares for the future, not

only for human resources but also for modern training

equipment with associated computer systems and

networks.

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

plant engineering services, the Design Authority and the

Safety and Regulation Department until the end of their

operational lives.

In France, I encourage the development of career

trajectories spanning both the Nuclear Operations

Division and the Nuclear Engineering Division, for

both experienced and young engineers. I emphasise that

it is important to seize the opportunity constituted by the

massive arrival of young engineers in our engineering

centres to give them a proper understanding of the

realities of operations at the earliest opportunity.

They could thus become powerful exponents of

mutual openness and discovery between these two

organisations.

Finally, to better address the generation turnover

challenge, I would like to draw attention to the need

to further develop maintenance supernumerary

positions in France, and better integrate the basic

training time, as is now the case in the operating

profession. It is also necessary to accept the need

for temporary additional investment in operations

skills to be able to eventually satisfy the needs expressed

concerning a number of key areas (simulator instructors,

safety engineers, outage managers, engineering etc.).

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

07/ MAINTENANCE, A STRATEGIC

DOMAIN

Maintenance work in the turbine hall

The next ten years will be decisive for the future of the French plants. There are many

challenges to be faced, such as the post-Fukushima activities, plant life extension,

maintaining competitiveness and nuclear safety re-assessments. With the plants at midlifespan,

maintenance is acquiring strategic importance for guaranteeing the level of

nuclear safety and preserving the company’s assets. As regards this vast and complex issue

which involves a large number of different players, EDF SA is still well below the highest

international standards and must continue with the changes it is making.

As I have previously mentioned, I have noted a perceptible

increase of more than 40% in the number of nuclear safety

significant events originating in maintenance activities,

with the units in service and during outages. During

outages, these events frequently cause disorganisation

and delay, and generally have more serious consequence

for the installations which, although not in service, need

to be the subject of permanent reactor monitoring. I am

concerned by these results, redolent of slowly declining

quality in maintenance work, and I find myself wondering

about the organisation, resource availability, rigour and

means.

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THE INSPECTOR GENERAL’S REPORT

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ORGANISATION

40

MAINTENANCE, A STRATEGIC DOMAIN

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

For many years, the plants have had a policy of

rationalising the maintenance work by focusing on the

key equipment in terms of nuclear safety and operability.

This has led to specifying maintenance programmes and

the means for carrying them out. At present, there are

three types of means: 1) establishment of a multi-year

maintenance programme, 2) planning and execution of

unit outages, and 3) management of the nuclear units

when in service. I am surprised to observe that although

the rules concerning these means have been in place for

a number of years, they are not producing the desired

effects and that the standard of maintenance is regularly

dropping in the meantime.

The forced outage rate for the units in service have

been improving for a number of years, and are now at a

satisfactory level of around 2.8%. I see this as the result of

renewed investment in the main components. At present,

it is during unit outages that most of the sub-standard

maintenance work is occurring, and causing the most

serious events in terms of nuclear safety.

For a number of years, outages have been regularly

extended by more than twenty days, and by more than

twenty five days in 2012. Regardless of the cause,

outage extensions are periods of vulnerability

as they upset the planning and scheduling. They thus

foster sub-standard work and events with nuclear safety

implications. As can be seen from international experience,

they must not be seen as unavoidable, an attitude I have

on occasions observed in the plants.

Yet, the best practices I have observed outside France

concern maintenance, logically based on multi-year

forward planning right through to everyday unit

operation, and covering unit outages. The multi-year

organisation establishes a framework and a basis for a

medium-term plan, the unit outage organisation manages

heavy maintenance, and the unit in service organisation

manages everyday maintenance.

The multi-year organisation

This was originally part of the unit outage organisation

and is accordingly often overshadowed by the “mighty

war machine” that the latter constitutes, and I observe

that it has at last found its due place in the plants. I am

pleased to see this because a clear multi-year plan with

proper foresight is the key to successfully conducting

outages and ensuring that the nuclear units function

safely. This year, I note that the organisation’s workload is

building up, and that the resources in some of the plants

are being stretched.

Accordingly, I would like to mention the many rules

laid down at corporate level that have to be taken

into consideration in the plants. Faced with so many

rules and constraints, I feel sure that the staff in the field

are in danger of losing their sense of proportion. In the

oversight that they exercise, the corporate departments

need to take care to optimise rule-making, especially by

better forward planning, and thus make fewer rules.

I have also noticed that the multi-year programmes in

the plants make little or no allowance for scheduling

the work of the Nuclear Engineering Division and its

constraints. The Nuclear Engineering Division will be

responsible for a substantial amount of the General

Refurbishment work over the next ten years. It seems

to be necessary for its activities to rapidly appear in the

plant multi-year programmes. Accordingly, I am happy

to see that the Nuclear Engineering Division and Nuclear

Operations Division joint project is continuing, having

been temporarily delayed by the post-Fukushima activity,

which overlaps this work.

The “unit outage” organisation

The corporate directive that specifies the organisational

structure to be set in place in the plants for successfully

carrying out unit outages is broadly inspired by best

international practices, and is now in its third edition.


Despite this, the plants are continuing to report significant

outage extensions. It is to be remembered that proper,

successful, timely execution of a unit outage means

good-quality work and fosters nuclear safety.

For outages, the required tools appear to be at hand,

the required teams are in place and adequately staffed,

the inter-professional committees are functioning, and

the necessary resources are available. It seems that the

weakness stems from the fact that outage planning

is not held in sufficient regard and that the planning

resources and detail are lacking. In the two-unit plants,

I have often heard it said that the next outage will be

prepared when the current one is finished, sometimes

with a holiday period separating them. Even if efforts are

made, particularly with the visibility provided by the multiyear

plan for industrialising planning and scheduling, the

outage schedules must be considered sacrosanct and the

milestones met. I am surprised to learn that, sometimes,

as many as 60% more jobs may be added less than four

months before the outage start, and sometimes jobs are

added while the outage is in progress. The alert not only

needs to be sounded about simple refuelling outages

where the planning is upset as is the execution of the

outage itself, but also the multi-year programme for the

plant.

Outages without adequate planning means more pressure

for EDF and contractor staff as a result of frequent rescheduling,

time lost waiting and work being carried

out in haste. These situations foster sub-standard work,

omission of re-qualification and events with implications

for nuclear safety. I would like to emphasise the importance

of the Unit Outage Nuclear Safety Committees (French

acronym COMSAT) as a line of defence against such risks.

The rigour with which their agendas are planned by the

professions is, in this respect, vital.

Not enough resources and foresight are devoted to

planning outages, especially as these are numerous, since

core management policy favours short cycles. There is a

need to analyse the impact of the refuelling cycle length

on workload and resources, as well as the effect on the

composure of the staff and the standards of work and

nuclear safety.

The “unit in service” organisation

Although this organisation was designed a number of

years ago, its degree of implementation in the plants

varies. Its goal of seeing beyond the immediate and

setting in place a proper organisational structure featuring

foresight and adherence to a schedule has yet to be

achieved. Three- and six-week schedules are still difficult

MAINTENANCE, A STRATEGIC DOMAIN

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

to apply. Re-scheduling is still only too frequent due to

problems with methods, planning and the availability of

spare parts and resources.

I appreciated seeing rapid response teams in all

the plants visited this year. They are acclaimed by both

operations and maintenance. They enable time to

be saved in dealing with small defects and facilitated

diagnosis of others. They foster mutual understanding

between the maintenance and operations professions,

especially among the new arrivals.

Nevertheless, it remains true that the backlogs of job

requests may have got lower but are still high. To make

progress with eliminating them, the maintenance

departments still need a considerable amount of technical

assistance.

In the plants, staff are calling for smooth interfacing

between the three organisations (multi-year, unit outage

and unit in service). I would like to draw attention to the

fact that operation at fleet level is not as smooth as it

could be between the three organisations; although all

are attached to the Production Committee, they are not

monitored by the same fleet-level departments. I regret,

for instance, that the computerised scheduling tools do

not intercommunicate, making re-typing necessary which

is a waste of time and an opportunity for errors.

Here I was struck by the low quality of the computerised

tools used by the unit in service organisation, which

are often replaced with Microsoft Excel in the plants.

Standardisation of the computerised tools is planned as

part of the switchover to the Nuclear Technical Information

System (French acronym SDIN). The last plants are to

make the change in 2018 and interim solutions need to

be provided.

The unit in service organisation has not inspired the

newcomers, who prefer the unit outage organisation.

The former is not in the limelight and is often seen as

a bit-player. This impression must be overcome and the

management needs to increase the attractiveness of this

organisation in the plants.

Success will depend on the strong involvement of the

operating staff who need a clear medium-term picture

and foresight. As I sometimes observed, the lack of

consistency in the decisions made by different shift

teams is another obstacle in the organisation’s quest for

effectiveness. The need for an operating shift manager

who can step back from the immediate work to check

the scheduling and practicability is a pressing one. Like

the conductor of the orchestra, the operating department

must take the baton and set the rhythm.

I have seen such involvement in the plants at EDF Energy

visited this year. The Work Execution Centres, which

are the equivalents of our unit in operations systems in

France are characterised primarily by the strong presence

41


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

of operating skills, the establishment of the schedule at

planning level and the issuing of work permits. These

resources, which are seconded from the operating teams

for long periods, provide an effective connection with the

maintenance departments. The scheduling is considered

consensual and legitimate.

SKILLS

In this field, the maintenance departments appear to be

in increasing difficulty. The staff are young, the training

long and the departures on retirement are many. These

factors combined mean human resources will be in

short supply for some time to come. In addition, the

maintenance departments are constantly being called to

play parts in the numerous corporate projects in progress,

which frequently results in re-organisation and changing

of responsibilities. Wherever I go, maintenance staff are

under pressure and becoming disorientated.

The deployment of the AP 913 programme intended to

increase the reliability of equipment has resulted in the arrival

of a significant number of recently-qualified engineers in

the plants. Meanwhile, I deplore the insufficient number

of technical engineers in the maintenance departments

where the technical mentors are still primarily the work

package planners, who are ever few in numbers and have

many calls on their time. The introduction of reliability

departments has in some cases contributed to further

distancing the maintenance methods staff from the

field and weakening the fieldwork departments. I am

not certain that the allocation of significant amounts

of resources to the AP 913 programme, in view of the

small amount of unplanned capacity loss, is the best way

of addressing the current needs for unit outages and

planning of the General Refurbishment.

If I am sounding the alert about the need for technical

engineers and not managers in the maintenance

departments, it is because the planners have become

a rare resource that is under pressure and subject to

demands from all quarters. The position is not considered

an enviable one by our workshop technicians, who would

prefer quieter jobs for much the same money. As in the

operating departments where young engineers have been

introduced to the profession, the same needs to be done

in the maintenance departments. I hail the re-launch of

the maintenance engineer training that had been scaled

back for a number of years and which now meets a real

requirement.

In the maintenance professions, training time is also long,

with on-job exposure and the need for mentoring. The

lack of supernumerary staff at all levels is still keenly felt,

at a time when increasing numbers of staff are taking

retirement. I am pleased to note the development of

42

MAINTENANCE, A STRATEGIC DOMAIN

inter-organisational exchange programmes in the plants

for both field workers and engineers. This can go some

of the way to addressing the lack of professionals in the

maintenance departments by combining apprenticeship

in the field with mentoring and theoretical training.

RIGOUR IN EVERYDAY WORK AND

SURVEILLANCE

Rigour and quality are hard to obtain when the

workers are faced with numerous contingencies

on an everyday basis, when they have to handle case

files that are increasingly bulky and sometime lack the

drawings, and when they need to handle issues outside

their range of skills or original profession. The issue of

“hands-on time”, which was covered at length in my

previous report, remains unsolved and I regret not being

able to see progress in the field.

Increasingly faced with cases of sub-standard quality in

the field, I note that surveillance is not properly playing

its role as a line of defence. I have observed that the

context is unfavourable: the rule sets are numerous

and complicated, risk analysis is often late and too

standardised, and the surveillance manager’s position

is not held in high regard. Despite this, some plants are

on the right track and making progress. I accordingly

hail arrangements to promote the surveillance manager

position by either an associate director or by the head of

industrial relations. I strongly encourage such initiatives.

Surveillance managers are still all too often appointed

only a few weeks before unit outages, leaving them

insufficient time to study the files and draw up their

surveillance programmes. Their training remains too

orientated towards an apprenticeship consisting of book

learning rather than “by learning to see on the job”.

Regarding this subject, I would like to recognise the

creation of a department at Sizewell B dedicated to

surveillance and ensuring both the surveillance of work

and the accreditation of in-house checking by contractors.

SPARE PARTS AND THE AMELIE SPARE

PARTS MANAGEMENT CAMPAIGN

This year, once again, during my encounters with

maintenance staff, the subject of spare parts remains

a complex one monopolising much time and energy,

with one out of two parts not being procured by the

standard process. It is proving lengthy for confidence to

be restored between the multi-year organisations in the

plants and the spare parts teams of the Central Technical

Support Department (French acronym UTO). I think,

however, that we are going in the right direction.


I met the staff of the AMELIE spare parts management

campaign at the Central Technical Support Department

facilities and at the Velaines spares storage platform.

Launched in 2008, the AMELIE spare parts management

campaign is now reaching its final stages and the

permanent organisation in charge of spare parts in being

turned over to the Central Technical Support Department.

I consider it most important for the handover to take

place in a proper manner without undue haste, with as

much plant involvement as possible. The Central Technical

Support Department and the plants need to make a point

of working in close collaboration for the process to be

permanent.

With this project, EDF SA has devoted considerable

financial efforts to rationalize the management of spare

parts for the French nuclear power plants and I insist

that theses must be maintained until the project is

completed. The new stock management policy has been

accompanied by a substantial increase in the stocks, the

creation of the Velaines platform and the development

of new management tools. The Velaines platform, which

was commissioned in 2011, is the strategic centre of the

system where all movements are centralised: acceptance,

packing, storage and shipping for the 58 French nuclear

units. After a commissioning period in 2012, it should

be operating at full capacity to back up the outages in

2013. The numerous advantages of having all the spare

parts for the plants in one place (except the heavy parts,

which remain at Creil) must not lead to underestimating

the associated risks. Failure of a conveyor belt, which I

witnessed during my visit halfway through the year, is an

illustration of this issue.

Rationalisation of the corporate stocks also means

managing the work on repair and re-conditioning parts.

This management, which is just beginning, needs to

rapidly come up to speed to close the loop.

I note that stock management in the plants has become

more complex, requiring far greater competence with the

computerised tools for the storekeepers. The latter should

have greater support during the changeover.

While on the subject of spare parts, it is necessary to once

again mention the issue of obsolescence. The component

obsolescence project, begun a number of years ago, does

not seem to have been allocated sufficient resources to

cover all the issues, with the attendant risks.

MAINTENANCE, A STRATEGIC DOMAIN

The Velaines platform

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Set up as part of the AMELIE spare parts management

campaign, it will house all the spare parts for the

French plants except heavy components and standby

stocks in the plants. It is on a 15-hectare site in the

County of Meuse. The Nuclear Operations Division

has asked the Industrial Support for Production

Division (French acronym DAIP) to run this platform,

via the corporate logistics office. Some seventy

people are employed there.

Key figures for the Velaines platform:

• Warehouse surface area: 45,000 m2

• Number of spare parts: 4 million

• Number of items listed: 200,000

• Length of shelving: 7 km

• Number of storage/retrieval machine cells:

120,000

THE CONTRACTORS

The Velaines corporate stores

When it comes to work in the field, contractor staff are

confronted with the same difficulties as our maintenance

workers: long waits, tools not always available, frequent

re-scheduling and numerous constraints in the work

environment. Hands-on time is not increasing. All

recognise that it is too short, and this needs to be taken in

account when planning the General Refurbishment.

For the employers, the problems with the renewal of skills

and estimating the work load are the most intractable.

The contractors working on the French plants have the

same swings in activity as their client EDF. Better working

conditions resulting from better planning, more flexible

organisation and properly-proportioned resources will

help to compensate for shortcomings on the part of the

EDF and subcontractor staff, and thus improve nuclear

safety in the plants.

Our business policy in the field of maintenance, as I have

seen during my visits to the plants and encounters with

43


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

the contractors, oscillates between approaches, resulting

in confusion and misunderstanding. We do not make

a clear choice between on-going relations based on

partnership and seeking our advantage in a competitive

MY RECOMMENDATIONS

The recurrent difficulty for the plants in completing their

unit outages on schedule are a source of sub-standard

work and discouragement. In the field of maintenance,

a clear, multi-year outlook faithfully corresponding to

the activities to be scheduled in the medium term is

indispensable for success with the unit outages and for

reducing the amount of unplanned capacity loss. Yet

this not sufficient. We also need to rationalise the

unit outages and make meeting our obligations

sacrosanct. The company must also accept the

consequences of it technical and economic choices

in the field of fuel, particularly for the 900 MWe

nuclear reactors with short fuel cycles.

Unlike the operating department, who are constantly

challenged by the independent nuclear safety

organisation, maintenance does not have the

benefit of an equivalent external look at its everyday

activities. Today, the staff of the independent nuclear

safety organisations are young and their training has

focused on process considerations with little or no

44

MAINTENANCE, A STRATEGIC DOMAIN

market. Both approaches have their advantages and

disadvantages. Difficulties arise when we swing from one

to the other, as circumstance or markets dictate.

focus on maintenance. I call for the introduction

of maintenance engineers in the maintenance

departments and the incorporation of maintenance

skills of adequate level into the independent

nuclear safety departments.

The desire to reduce outage durations and centralise the

maintenance of spare parts needs to be moderated by

giving thought to our maintenance policy. Should

we still be carrying out repairs in the nuclear units?

Would it not be better to perform standard exchanges

of entire plant items as many other operators do? The

question needs to be posed, especially as it would foster

more frequent involvement of the original equipment

manufacturers.

Finally, I can state that the staff hands on in the plants

are working very hard to improve the overall results.

The difficulties in managing the outages and the quality

of the field work must not eclipse the motivation and

commitment of the EDF and contractor staff.


NUCLEAR TECHNICAL INFORMATION SYSTEM: STILL A LONG ROAD AHEAD

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

08/ NUCLEAR TECHNICAL

INFORMATION SYSTEM: STILL A

LONG ROAD AHEAD

Blayais Nuclear Power Plant

The renovation of the Nuclear Technical Information System (French acronym SDIN) directly

involves four professional divisions of EDF SA: first and foremost the Nuclear Operations

Division and also the Nuclear Engineering Division, the Nuclear Fuel Division and the

Industrial Support for Production Division. This is part of the initiatives to make progress in

the professions, improve operating standards, increase equipment reliability and enhance

the performance of the installations. In view of its strong impact on the work organisation

and methods, and the attendant risks, I have focused on the manner in which the change

is being organised, with particular reference to nuclear safety.

THE DEPLOYMENT CONTEXT

The nuclear plant data system in France is more than twenty

years old and due for renovation. EDF decided to choose

a tried and tested management model with the goal of

backing up and consolidating the initiatives concerning the

nuclear professions. Harmonisation of practices between

plants and standardisation of the work methods, increasing

synergy between engineering and operations, increasing

equipment reliability, improving operating performance

and developing the use of experience feedback are among

the intended objectives of the initiatives to make progress

associated with the design and deployment of the Nuclear

Technical Information System.

I am pleased to see the roll-out of the Operations and

Maintenance Methods Programme (French acronym

MME) in the Nuclear Operations Division, now in charge

of coordination, which will synchronise the different

projects associated with the Nuclear Technical

Information System. This has also made it possible to

establish milestones and deliverables for overall success,

while providing assistance for the plants.

The Operations and Maintenance

Methods Programme for 2015

The Generation 2020 project organised by the

Nuclear Operations Division has set in place an

Operations and Maintenance Methods Programme

for 2015 combining:

• deployment of AP 913 methodology intended to

increase equipment reliability and enhance system

performance,

• creation of a standardised activity model library

for both operations and maintenance on a plant

and corporate level,

• creation, for each group of similar reactors, units

for updating the standardised activity model

libraries using experience feedback from the

plants and updating the rule sets,

• completion of the AMELIE spare parts

management project,

• deployment of the Nuclear Technical Information

System.

45


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

BLAYAIS NUCLEAR POWER PLANT: THE

LEADER

I visited Blayais Nuclear Power Plant where the staff

showed how the project was progressing. I found that

the managers and staff of the teams to all be very keen.

Blayais was chosen as the first to deploy the SDIN in a

plant once the documentation part (the only part available

to date) went live in the first corporate departments,

namely the Central Technical Support Department (French

acronym UTO) and the Operations Engineering Unit (UNIE).

The plant had the reputation of having well-ordered

processes, a properly integrated multi-year maintenance

policy and the rules for unit in service and unit outage

situations. The deployment was initially planned for 2010,

but actually began in the middle of 2011 and was extended

to unit outages in 2012, including a ten-yearly outage.

I appreciated the particularly strong involvement of

the plant management, beginning with the director

and extending through the line management, at a time

when the plant was extremely busy.

Proper allowance for nuclear safety by the

plant

I also noted the unflagging involvement of the independent

nuclear safety organisation at the plant to promote the

INSAG 18 initiative and to avoid compromising nuclear

safety during deployment in the plant, which was not

complete at the time of writing this report. Special

attention has been paid at the plant to real-time nuclear

safety and the control of state changes during unit

outages and start-up.

The professions find common ground on the

basics

The plant management took care to engage with both the

service-users and service-providers. They were involved in

training, planning and analysing the impact of the basic

work elements, with managers putting themselves in the

positions of the players.

The plant management seized the opportunity to get all the

professions to work together (operations, maintenance,

chemistry, logistics, risk management etc.) on establishing

the basics of the activities liable to be affected by the SDIN.

This work has made it possible re-examine and update

the basic work protocols: functional diagnosis to drawup

a job or fieldwork request, planning of preventive

and contingent activities, programming, scheduling and

coordination of activities, making allowance for logistical

46

NUCLEAR TECHNICAL INFORMATION SYSTEM: STILL A LONG ROAD AHEAD

constraints, drawing-up job permit requests, risk analysis,

requalification, rectification of discrepancies, first-line and

second-line analyses and experience feedback. In this

context, the deployment has strengthened the position

of the multi-year initiative in a manner consistent with the

unit in service and unit outage initiatives.

A major effort to cope with an

underestimated workload

I have discovered that an excessive number of adjustments

had to be made which required much time and effort at

the plant (still the case), indicating that the system was

not properly finalised before deployment, and also that

the workload was underestimated from the start,

even though the plant had the reputation of being wellorganised

with good work methods.

There was clearly failure to foresee the amount of work

required, at programme level and in the plant, for the

professions and for the owners of the information system.

Although the plant was busy with its routine work to

generate power and cope with a ten-yearly outage at the

same time as the system was deployed, it nonetheless

rose to the challenge and set contingency plans in place

without compromising everyday nuclear safety. This,

however, required a major effort for the plant staff,

particularly as the professionals needed were already busy

with many other things, and here it is especially planning

that I have in mind.

Insufficient prior consideration of the nuclear

safety implications by fleet level

I have also noticed that it was necessary to make major

corrections at a late stage, which could well compromise

nuclear safety, for instance, operations requests to allow

good planning of the agendas for the unit outage safety

commission meetings before changing reactor modes

during start-ups.

I am surprised to see that the new tool allows more

laxity and less clear traceability of the lines of defence

at this stage than the existing SYGMA system. It has

necessitated organisational arrangements that are more

complex and stricter in order to prevent degrading nuclear

safety in execution, as well as to maintain independence

of technical checking, first and second line analysis, and

verification work.

The nuclear safety analysis was carried out as part of

the Nuclear Technical Information System programme

at the start using the INSAG 18 approach as a basis and

inputs from a socio-organisational and human factors


NUCLEAR TECHNICAL INFORMATION SYSTEM: STILL A LONG ROAD AHEAD

analysis but it was not initially sufficiently challenged

by fleet level on these considerations. I am therefore

raising the question as to the depth of the nuclear safety

analysis of the programme as a whole, and suggest that it

needs to be more adaptable and responsive as experience

feedback on the programme accumulates.

A tool that is not yet mature

I also note that many more software rectifications are still

awaited by the users in the new version which was due

by the end of 2012 and which will need to be qualified

at plant level. I regret that, pending the availability

of the new version, the plant is obliged to work with

an unfinished tool and draw attention to the risk of

premature withdrawal of the SDIN Programme support

to the pilot plant, a possibility that was mentioned during

my visit.

In the case at hand, that plant was able to rise to a high

standard of work involving all the stake holders and

closely involving both sides of the industry. On the face

of it, the new information system appears to have been

better accepted by the new generation of staff.

It is to be hoped that, now the staff at Blayais Nuclear

Power Plant have borne the brunt of the debugging, no

more will be needed before further deployment. However

I am left still wondering whether the conditions in the

other plants are sufficiently robust for its successful

deployment.

KEY FACTORS FOR SUCCESS WITH

FURTHER DEPLOYMENT

Given the scale of the impact at Blayais Nuclear Power

Plant, where a strong and stable situation prevailed, it

appears to be vital that the backup of the programme by

fleet level is sufficient for Blayais site (where final closeout

of all the issues will be complex) and for the other

plants. Blayais Nuclear Power Plant will soon be faced

with steam generator replacement work, which is why

the backup needs to continue until deployment is

complete. This should be done with close involvement

of the new set of plants concerned. Special attention will

be needed for the plants with two nuclear units.

Particular care will also be required for the professions

most affected. Here I have in mind the planners in

particular, who benefitted from relative stability during

the deployment of the SDIN at Blayais Nuclear Power

Plant. I am raising the alert as to the capacity of the

plants to simultaneously cope with the renewal of skills,

the passing-on of knowledge and skills to the incoming

generation, the start of the General Refurbishment and

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

the roll-out of the SDIN. The attention paid to the manner

in which the change is managed must be particularly

careful.

The harmonious co-existence of the AP-913 project,

the new activity model library, AMELIE spare parts

management campaign and the SDIN must be durably

guaranteed up to 2018. In this context the MME 2015

programme is playing a vital role that needs to be

recognised in its action to orchestrate and set the

timeframe for the key stages. I would like to draw

attention to the resources required and the need to make

sure that this programme is kept going.

To manage the change, I consider that tracking nuclear

safety and business performance indicators, to make

sure there is no deterioration during the deployment

phase, and the properly targeted return to steady-state

conditions will help to ensure success. To avoid the players

becoming discouraged with this lengthy deployment,

it will be necessary to regularly set in perspective the

performance results and the trends.

I have also observed that questions are being raised

about the deployment of the SDIN in the engineering

centres. Allowance needs to be made in the SDIN for the

particularities of the design rule sets and the modifications

made by the Nuclear Engineering Department to find new

synergy between engineering and operations.

The staffing of the organisations for each of the

standard nuclear reactor series, their responsiveness,

and their connection to the engineering bodies in

charge of establishing the rule set and with the plants

for the integration of experience feedback will need to

be the subject of special attention by the MME staff.

Furthermore, I am left wondering about the depth of the

standardisation or the work methods that the company

will finally be able to achieve for each reactor series and

for the plants as whole, as deployment at the pilot plant

necessitated integrating many local particularities.

47


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

MY RECOMMENDATIONS

The plants must always be able to fully exercise their

responsibility as a nuclear operator making sure that

nuclear safety has top priority throughout the

deployment of the SDIN. It is vital that they mobilise

their independent nuclear safety organisations, by

reinforcing skills if necessary. Similarly, the plants

must always be able to take full possession of the SDIN.

Faced with a set of projects of this scale, of which the

SDIN is only one, I conclude that there is a need for a

high-level supervisory body. The MME programme,

whose role is currently coordination, could well be

made a permanent function with the role of crossorganisational

supervision. Similarly, I would like to

draw attention to the skills and authority that the future

plant-level project managers need to have. Meanwhile, I

approve the decision taken at corporate level to proceed

with the deployment of this project by stages, allowing

for the actual situations in the field.

48

NUCLEAR TECHNICAL INFORMATION SYSTEM: STILL A LONG ROAD AHEAD

If carried out properly and in sufficient depth, bringing

in all the stakeholders, the work on the fundamentals

of the professions and work methods, alongside the

deployment of the SDIN, will eventually bring dividends

in terms of nuclear safety. I emphasise the need to

properly assess the impact of the scale of the change

and the necessary support at each individual plant.

This means taking into full account the workload and

the situations of the professions at each plant, as well as

the need for overlap between the plants to facilitate the

sharing of experience feedback.

I also note that the plant managers need to get involved

in deploying such a project, listening to any difficulties

expressed, and be willing to engage in the field to

understand the situation and arrange for effective

compensatory and corrective measures.

Finally, I emphasise the strong commitment of

the Blayais Nuclear Power Plant staff and of the

corporate-level teams in the SDIN. Such commitment is

indispensable to successfully deploy the system in the

other plants.


ATTENTION TO CHEMISTRY NEEDED IN OPERATIONS

09/ ATTENTION TO CHEMISTRY

NEEDED IN OPERATIONS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Chemists in a nuclear power plant, key competences

Maintaining proper water chemistry in a PWR reactor is one of the nuclear operator’s basic

tasks. Maintaining high chemistry standards make the equipment last longer and greatly

contributes to nuclear safety and radiation protection. The changes introduced in EDF SA in

recent years merit being extended. The Group also need high levels of expertise to manage

the particularities of its AGR and BWR facilities.

This year, I met the chemistry service in each EDF SA plant I

visited to assess the skills of the staff and the willingness to

heed their advice during the different stages of operations.

I also met the staff in charge of chemistry in the Corporate

Chemical & Metallurgical Centre of Expertise (French

acronym CEIDRE), a corporate department ensuring an

innovative technical and promotion function essential

for the 58 plants. In the UK, I concentrated on issues

associated with carbon deposition in the carbon dioxide

systems, while at Nine Mile Point and Hartlepool Nuclear

Power Plants I focused on chemical cleaning.

THE FRENCH PLANTS

Skills

I found that chemistry skills are dependable and kept

up to standard. Apart from the very understandable

apprehension about future departures on retirement,

I have found the supernumerary posts well-staffed

and experiencing little difficulty with recruitment into

this highly-technical profession, where apprenticeships

are becoming increasingly common. The recruiting of

chemists by the plants, normally with skilled-technician

level qualifications, takes place in a straightforward

manner; three quarters of the plants also hire chemical

engineers, which is a very positive trend and should be

universal.

Corporate promotion of the profession is often

complicated by the fact that the skills needed are scarce.

Training is mainly left to the plants with the Operations &

Engineering Training Unit (UFPI) taking little action in this

field, although it is an important one.

What the chemists in the plants are saying

I have noticed the situations vary greatly in the field.

All too often, little attention is paid to the technical

recommendations issued by the chemistry services with

little action taken, whether the plant is in service or during

an outage.

49


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

The legitimacy and authority of the chemists is still

insufficiently established in the plants. Accordingly, fifty

percent of the question/answer forms sent by the plants

to the CEIDRE for review before a technical decision is

made, reflect lack of confidence in the chemist’s opinions

on the part of the plants. This situation is very different

from the practices of nuclear operators in other countries,

where the plant chemists speak with authority. At EDF SA,

it is usually the corporate-level engineering echelon that

has the last say in operations-related technical matters,

very likely in view of the preponderant role of the CEIDRE

(formerly the Laboratories Group, French acronym GDL)

at the time of commissioning the nuclear units in the

eighties.

When the unit is in service, they have great difficulty

in receiving support, for instance to initiate or expedite

searches for the cause of air ingress into the condenser. This

important parameter nevertheless governs the durability

of the tubes and the lifespan of the steam generators.

The chemists encountered generally feel that they receive

little support from the operating departments, particularly

the shift teams and the operating managers. Identifying

the chemical issues and taking related action, often with

effects in the medium and long term, is not given the

same attention by the operating shift teams as action to

deal with real-time nuclear safety requirements. I have

also sometimes observed insufficient commitment by the

safety engineers in this context.

I am surprised to see that, during unit outages, effective

practices such as drying and protection of the feedwater

train are still as difficult to do (I have only seen this done once

during my visits this year). The chemists cannot get the unit

outage staff to listen to them. Nevertheless, I observed

good cooperation between the unit outage staff

and the chemists during the shutting down phase:

oxygenation, purification and radiochemical cleaning of

the reactor coolant system. Success with these complex

operations has a strong effect on our radiation exposure

results. Time pressure appears to be properly managed

at the plants visited, and some excellent practices were

observed such as adding a chemist to the operating shift

team in the control room.

I met some very keen and motivated chemists strongly

aware of their role as custodians for the medium and long

term who were well supported by their Plant Managers.

I regret that this favourable situation is not the case

everywhere.

The equipment

I would like to draw attention to the differences in the

demineralisation plants and the ways they are run.

50

ATTENTION TO CHEMISTRY NEEDED IN OPERATIONS

In some cases, the operations department and the

chemistry department handle its operation jointly, and

in some cases one or the other. I observed an innovative

practice that consisted of entrusting operations to an

outside company which, although it may not be the only

solution to the difficulties encountered, has the merit of

clarifying the responsibilities of each department. I also

noticed, at one plant, the support given by the Authorised

Internal Inspection Department (French acronym SIR) to

the chemists’ arguments concerning protection against

corrosion in certain vulnerable systems, particularly the

feedwater train. I am glad to see such a joint action, and

this type of approach could well be adopted in other

plants to ensure that those in charge are aware of the

long-term implications for preserving the assets.

Promotion of chemistry for the operational

fleet

The role of the CEIDRE is to handle technical promotion

and be the prime technical adviser on chemistry for

the plants. The meetings to pool information on specific

issues and the “chemistry roundtable” organised every

year help to establish solid links between the corporate

engineers and the chemistry staff in the plants. I encourage

the existence of such occasions, and recommend that the

managers make a greater commitment to them. They are

unique opportunities to put the basic messages across

and show the importance of appropriate chemistry during

operations.

The existence of an effective system for finding solutions

to the problems faced by the plant operators (doctrine,

interpretation of the technical specifications for operation

or the results of measurements etc.) is also to be

commended. The pertinence and promptness with which

the question/response forms are dealt with is universally

praised by the plant staff, whether chemists or managers.

The corporate-level promotion of the chemistry profession,

which is handled by Skills Advisory Centre (PCC) of the

Nuclear Operations Division, resumed in 2012 after a year

of inactivity. Staffing of this type of function needs to be

managed very carefully. The definition of the common

core of knowledge for chemistry, which is currently being

established, seems to correspond to a real need, as the

chemists are now finding it hard to establish their position

in the current maintenance professions arrangements. I

hail the reinforcing of training with the support of CEIDRE

for the team leaders and front-line managers, and the

heads of departments. I am wondering about the need

for similar reinforcement of the training intended for the

safety engineers and operating shift managers, whose

chemistry training seems to be barely sufficient.


ATTENTION TO CHEMISTRY NEEDED IN OPERATIONS

I consider that the link between the CEIDRE (Nuclear

Engineering Division) and the Operations Engineering Unit

(Nuclear Operations Division) is not sufficiently strong,

partly due to the absence of a chemistry specialist in the

top management team of the Operations Engineering Unit

(UNIE). More generally, the responsibility for approving

changes in the rule set does not appear to be sufficiently

defined. As the chemistry and environmental discharge

committees do not deal with these issues, it would be

good if the Operations Technical Committee (CTE) could

handle them on an ad-hoc basis. It would appear that too

little attention is still being devoted to chemistry in the

Production Committee.

As regards documentation, the chemistry speciality was

not included in the initial scope of the project to re-write

and standardise the procedures as part of the Methods

and Practices Harmonisation Campaign, partly due to the

small number of documents to be produced compared

with the other specialities. I am nevertheless sorry to the

see the opportunity to staff the new nuclear-unit series

documentation bodies being lost for chemistry skills.

The situation would be greatly helped by making use of

the skills and the views of the chemists in drafting the

standardised procedures for the field of chemistry and

others, such as the normal operating procedures.

The Jean-Jacques Letalon

working group

This corporate working group, which between 2009

and 2012, brought together some twenty EDF SA

plant managers and experts made a number of

recommendations.

• Include chemistry and, more generally the

production assets as a whole, in the operational

focus, even in the short term

• properly include chemistry in our real-time

operations

• include chemistry indicators in our performance

reviews

• make sure it has the place it merits in our

organisational structure

• clarify and tighten the checking carried out by the

Nuclear Inspectorate in this field

• Strengthen the chemistry culture of leaders (at

plant and fleet levels)

• Give the head of the chemistry department high

status

• Fully review the chemistry training intended for

managers

• Reinforce the plant chemistry engineering capability

International benchmarking

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

The use of dashboards and indicators for monitoring

performance is becoming standard practice in the plants. I

also note that the WANO indicator intended for profitable

international benchmarking is not considered sufficiently

pertinent by many EDF experts. Experiments conducted

at one plant to test a new indicator dubbed “CEI” by

INPO in the USA were shown to me. I encourage the

rapid adoption of performance monitoring indicators at

EDF SA enabling comparisons with the results of other

nuclear operating organisations elsewhere in the world.

Indeed, I am struck by the persistent differences in the

assessments of our results by our experts and by those of

WANO. As I see it, the plants greatly need to have access

to benchmarking if progress is to be made.

Similarly, WANO assessments of the Peer Review type

conducted in France have given rise to highly perceptible

differences in conclusions and requirements in this

context. The different operating conditions of the French

plants, which operate in the load-following mode, do not

fully explain the disparity. Although I am pleased that the

Nuclear Operations Division’s Nuclear Inspectorate has

been including this since 2011, in the periodic overall

assessments of excellence, it needs to more closely align

its requirements with those of WANO. I would also like

to emphasise the importance of preserving chemical

engineer skills in its assessment teams.

AT EDF ENERGY

I note the scale of work carried out to better control the

carbon deposition phenomenon, which has far-reaching

implications for operations and for the lifespan of an AGR.

View of carbon deposition on AGR fuel

AT CONSTELLATION ENERGY NUCLEAR

GROUP

I note that in the PWRs belonging to the Constellation

Energy Nuclear Group, performance has long been good

in this field. In the USA, the nuclear operators have

51


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

developed a set of chemical performance indicators

that has proved its worth and is in routine use by the

managers. Comparison with other PWRs in the USA

shows Constellation Energy Nuclear Group’s performance

to lie within the first and second quartiles. The results

are substantially worse for boiling water reactors, where

chemical cleaning operations have in the past been

postponed for short-term financial reasons. I would also

like to draw attention to the highly-negative effect of this

MY RECOMMENDATIONS

In France, more than two years after release of the

Letalon Report containing analysis and proposals, I

observe the road to achieving the goals set and best

international standards is still a long one. The scant

regard by the managers of the plants for the conclusions

of the report and the relatively weak corporate-level

support, although it was soon as revolutionary when it

was published, explain this situation.

The commitment of the nuclear power plant managers

remains too uneven and in some instances insufficient:

chemistry is all too often at the back of the queue. The

counterbalance to the pressure to keep the durations of

outages as short as possible is often indecisive, frequently

because the culture or awareness of the importance

of chemistry among plant decision-makers (directors,

operating shift managers, safety engineers and outage

supervisors) is still insufficient. Yet, many aspects of

nuclear safety and radiation protection depend on it.

I encourage the continuation and the broadening

of training intended for these key players.

52

ATTENTION TO CHEMISTRY NEEDED IN OPERATIONS

postponement on radiation protection (see Chapter 5).

I would like to hail the commitment of the current

Constellation Energy Nuclear Group management team

which, when the plant was bought out, were confronted

with this situation and invested heavily in major cleaning

operations which are now giving encouraging results. I can

see how greatly this commitment has been appreciated

and has encouraged the staff.

I also consider that CEIDRE expert appraisal and

promotion campaigns of operational experience

feedback warrant more recognition. CEIDRE is

a fleet-level department that has close links with

operations but which, because it reports to the Nuclear

Engineering Division, often has difficulty in making itself

heard. Relations with UNIE accordingly need to be

strengthened.

At a time when we are making a massive investment

in the replacement of major components, such as the

steam generators in France and AGR-type reactor life

extension in the UK, higher priority needs to be given,

on a permanent basis, to maintaining desirable

chemistry in the equipment. Also, as I mention in

Chapter 11, I would like to emphasise the need for

continuing to invest in research and development

work focused on the behaviour of the equipment.

I encourage the development in France of exchanges

of international practices and the use of common

indicators for chemistry-related performance to keep us

in the front running in this high-technology field. This

will enable those in charge to make the right decisions,

for the long and short term.


A NEW IMPETUS FOR THE EPR-TYPE REACTORS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

10/ A NEW IMPETUS FOR THE EPR-

TYPE REACTORS

The Flamanville site pump station

After a difficult 2011 for the EPR construction site at Flamanville, a new start-up schedule

was issued and the project reorganised. In 2012, weld defects were discovered in the main

crane support plates, putting the schedule back by at least six months. The countdown to

start-up has begun, the worksite has found its enthusiasm again, and the Nuclear Design &

Construction Centre (French acronym CNEN) design work is running at full pace. Progress is

continuing with the EPRs under construction in other countries.

RE-ORGANISATION OF THE CNEN

Using experience feedback on the difficulties experienced

in 2011, the Flamanville 3 project management and

organisation were changed. The project is now clearly

assigned to the CNEN. The head of the CNEN is

responsible for allocating resources, finding common

ground on the main issues, relations with the French

nuclear safety authority (French acronym ASN) and with

the main suppliers, with the head of the Production and

Engineering Directorate or his representative acting as

the sponsor of the project. I am pleased to see the new

clear and simplified organisational structure which has

been set up and in which the respective roles are plain to

see, and the missions and responsibilities can be readily

understood.

To rise to the challenge of starting up Flamanville 3 in 2016

and managing the other EPR projects, in particularly the

Hinkley Point project, the CNEN has totally re-arranged its

internal organisation and functioning. In particular, I note:

• the creation of a nuclear safety, radiation protection

and environmental issues department guaranteeing the

implementation of rule sets in projects and supervising

the drafting of the regulatory case files and managing

the associated issues, This department is in charge of

independently checking answers submitted to the

nuclear safety authority. I consider that it now also

needs to set itself up as an independent organisation

for other departments of the division,

• the re-organisation of the design departments and the

creation of technical supervisory units in the project

teams, in close liaison with the planning and contracting

staff in each project.

• working as a project platform bringing together the

different players (worksite management, technical

supervision and planning, thus avoiding the inefficiencies

that dilute responsibility.

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Under the new organisational arrangements, the CNEN’s

EPR project team is responsible for the quality, cost and

deadline goals, as well as handling the Level 1 and 2

scheduling for all the activities. During my visit, the

priorities of the project team were focused on drawing up

a new schedule after the crane bracket welding incident

and the organisational structure to set in place, between

with the different players including SOFINEL, a joint EDF

and AREVA design office, to integrate without delay the

numerous modifications required before hot testing and

fuel loading. I observe that working in platform mode

now makes it possible to fully devote efforts to the real

issues. Accordingly, consideration is now being given to

producing the testing documents, organising the onsite

testing commissions and drafting the regulatory

documents required under the Nuclear Safety and

Transparency Act for preparing for start-up. I emphasise

the need for the future operator to be involved

in the forethought and planning at the earliest

possible stage.

I approve training the teams in project management and

using current industry-standard scheduling tools. The size,

however, of the project planning teams does not yet seem

to be sufficient to make up for time lost since the start of

the EPR project.

QUALIFICATION AND FABRICATION

The architecture of the instrumentation and control

system of the EPR is now licensed. For more than a year,

the Nuclear Engineering Division teams have been actively

working on answering the ASN’s questions to reach this

goal. Even though there may be changes needed in the

software versions to be used, they are confident that

this can be done. Justifications about the performance

of some of the control units (response times, number of

data inputs handled etc.) will probably necessitate further

alterations during the start-up tests.

I continue to be worried about the process for qualifying

the equipment for accident conditions for which the

responsibility was transferred to the suppliers in 2005.

This transfer, all too often made with little support for

the suppliers, has sometimes resulted in their failing to

understand what justifications are required and what

tests need to be carried out. At the present time, many

things are late and the overall process visibility is low. It is

to be borne in mind that equipment qualification must be

obtained before starting the reactor.

On-site erection is often the last line of defence in

ensuring the conformity and quality of the equipment

provided. The support bracket incident is a very

revealing example of this. I hail the responsiveness

and responsibility exhibited by EDF concerning this case in

54

A NEW IMPETUS FOR THE EPR-TYPE REACTORS

deciding, as soon as the first defects where discovered, to

test all the brackets liable to be involved, which led to their

being scrapped. The project team has begun checking

some fifteen other items of equipment with welds of

similar types. This case of sub-standard quality is now

behind us and the defects resolved. Qualification and the

monitoring of fabrication, however, remain areas where

the Flamanville 3 project team is running substantial risks.

I note that the issue is finally being taken seriously by

the Nuclear Engineering Division, with arrangements to

provide suppliers with support, an in-depth reappraisal

of the doctrine concerning surveillance of fabrication and

strict instructions for their staff in charge of surveillance.

The reactor building crane bracket

incident

The reactor building polar crane beams are

supported by 45 brackets secured to mountings in

groups of three.

The combined weight of three brackets and a

mounting is around twenty tonnes.

The brackets are welded-up from plates and

machined using a semi-automatic process, before

undergoing a final heat treatment. The surface and

the depth of the welds are checked as part of the

fabrication process before painting. The testing

revealed the presence of unacceptable defects in

some of the welds. This resulted in rejecting all the

consoles and starting a new fabrication cycle.

On 23 November, low wind enabled the installation

of the first mounting, using a 600-tonne crane. The

fifteen mountings were set in place as they were

delivered to the worksite. The last mounting was

fitted on 21 December 2012.

Three reactor building crane support brackets


A NEW IMPETUS FOR THE EPR-TYPE REACTORS

THE FLAMANVILLE 3 EPR CONSTRUCTION

SITE

“We’ll meet the 2016 deadline” was what I kept hearing

this year on the worksite among the site management

organisation staff. The year was marked by the support

bracket incident, but the work continued. By the end

of 2012, 93% of the civil engineering and 37% of the

mechanical and electrical equipment work was complete,

not to mention that the pumping station intake channel,

which is shared with Flamanville 1 and 2, was also flooded.

Last year, I pointed out the difficulties that the site

management organisation was facing, having a difficult

worksite and a heavy and complex organisational

structure. This year, I visited a changed worksite and

was very pleased to see the general condition and

the way the work was being managed. The reorganisations

of the CNEN is one of the reasons, but not

the only one. I would like to emphasise the commitment

of the head of the site management organisation and all

the staff concerning nuclear safety and worksite tidiness.

After numerous accidents in 2011, two of which were

fatal, EDF SA took action involving all the contractor

companies at the worksite and their employees. The

results are clear to see in the installations and show in the

accident frequency factors which, for the first time, have

fallen below the threshold of 15. I encourage all those

working at the site, whether EDF or contractor staff, to

keep up the effort and maintain the trend. It should be

borne in mind that good behavioural patterns in terms

of industrial safety are generally also good in terms of

quality, foundations for good nuclear safety.

This year I commend the orderliness of the facilities

which I associate with a commitment to industrial safety

and ascribe to the appointment of building supervisors

and coordinators, which I have called for in the past,

and whose presence is now paying dividends. They are

unanimously acclaimed and appreciated.

In this context, I would, however, like to draw attention

to two risks that appear to be growing. The first is

fire, while the second is associated with the extensive

radiography work necessary during erection. For these

two risks, the site management organisation has planned

countermeasures, with the recruitment of a professional

fireman and the appointment of two individuals with

special skills in radiation protection. I insist that these

resources be reinforced, where necessary.

An innovative and pragmatic approach to analysis of

the protection of equipment in storage at a coastal

site for a number of years was shown to me. It is necessary

to make sure that the findings are put to good use at

future worksites. Despite the intentions announced last

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

year and the action taken, the planning and scheduling

of the project activities from the CNEN, for both site and

design work, remains a weakness in managing start-up.

Everywhere on the worksite, among Nuclear Engineering

Division and Nuclear Operations Division staff alike,

there are complaints about the lack of visibility in their

activities beyond a horizon of six to twelve months. The

main Level 1 milestones have been laid down but the

finalisation of the Level 2 (covering more than 10, 000

tasks) and of the Level 3 plans are not yet rationalised.

Faced with the workload corresponding to the delay, it

would appear that resources engaged by the project team

are still insufficient and the confidence that the planning

process effort will be sufficient is fading. I have heard

questions being raised about the confidence that can be

placed in the critical path, in the absence of a sufficiently

clear and detailed description of the sequence of events.

I am surprised to see that the same tool is not being used

by everyone, necessitating copying with the attendant

waste of time and risk of mistakes. Concerning this point

in particular, action is needed without delay.

Industrial safety, a daily challenge at Flamanville 3

The EPR construction site in figures

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

whom are locals

• 20 million hours already worked

• Every night, 30 radiographs of welds are taken

• 400 km of pipes and 1,500 km of cables

THE FUTURE OPERATOR OF THE EPR

The future operator, present at the plant from the outset,

has not been directly involved in running the worksite,

and has had to adapt to the scheduled commissioning

date being put back again, now until 2016.

Even though the operations staff have gone through a

period of discouragement after the announcement of

delays in the site work that have meant that they would

have to postpone performing their proper work, I note that

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

they have now put this behind them. The professionalism

of the staff has continued to grow, and secondments to

other plants as well as to the worksite or the engineering

force have successfully taken place.

I approve the choice given to each staff member, in

a meeting with their superiors, to determine their

own career path and to decide whether to stay at the

worksite or work elsewhere, in the power plants. In my

opinion, this has greatly contributed to overcoming the

disheartenment at the beginning of the year and has

completely cleared the air. In addition, it has made it

possible to establish a solid system of forward planning of

employment up to the time of commissioning. However,

the four-year extension of the site work does not help

with the operators taking ownership of the facilities, or

with the site management organisation, which over time

has become too bureaucratic and administrative. I deeply

regret that the operating staff are still stationed on the

cliff top away from the worksite and the installations, and

cannot easily go onto site to follow the erection work

and familiarise themselves with their future installations.

The explanations that I was given by the staff of the two

organisations do not seem to be very convincing.

Concerning this point, I consider that the probable

delay of one year in moving all the staff to the

future operations building alongside the nuclear unit

installations does not encourage the operators to feel that

the build-up to commissioning is under way. Even though

the operations teams have been re-organised to optimise

the transfers of equipment, few systems have actually

been transferred and I am left wondering about the ability

of the transfer process to cope with the future workload,

with the time available rapidly diminishing.

This year, during my visits to simulator facilities at the

CNEN, the Operations Engineering Training Unit and

the Research and Development Division, I noted the

substantial amount of work devoted to determining

the composition and organisation of the EPR control

room operations teams. In designing the man-machine

interface of the EPR control room, the concept was to run

the unit by just one active operator and one supervisor.

The first tests took place in 2009, but as a result of the

degree of progress with the design work, certain scenarios

were not yet playable by the operations staff. Meanwhile,

other EPR operators (TVO and TNPJVC) have opted for

a more conventional system with two active operators

and one supervisor. After a number of tests this year, EDF

should be in a position to choose the form of organisation

and submit it to the nuclear safety authority. In view of

the consequences of this choice for the future operator,

this matter appears to be a particularly urgent one.

56

A NEW IMPETUS FOR THE EPR-TYPE REACTORS

MY VISIT TO TVO AT THE OLKILUOTO SITE

TVO is a Finnish public limited company operating two

boiling water reactors commissioned in 1978, of which

the power ratings have been upgraded to 860 MWe.

The company has some 850 staff, with 500 handling

operations. For many years, TVO’s operating results

have been among the best worldwide. Despite its size,

it possesses wide experience. Its maintenance policy is

based on the swap-out of complete equipment items,

hence enabling outages to be kept short and has proved

its worth.

The construction, erection and commissioning of a

new EPR nuclear unit (OL 3) is taking place as a turnkey

operation by the vendor AREVA. With less than two years

to go before commissioning, the company is only now

beginning its recruitment of the future operating staff.

The approach, which is very different to our own, explains

the low-volume of exchanges between EDF and TVO staff

about EPR matters: their staff have not been available.

Today, I note with satisfaction that exchanges of views and

sharing of experience are beginning and the operators are

also cooperating. This year, TVO has joined the EPR Family

and is actively participating in the various working groups.

AREVA alone bears responsibility for the construction site.

All the project teams and the decision-making bodies are

stationed on-site, and the AREVA France teams only act

to provide support on a case-by-case basis. I am glad to

see that the exchanges between AREVA’s OL3 worksite

staff and the staff of the Flamanville 3 site management

organisation and the EDF CNEN are well-established,

frank and apparently useful. It is to be remembered that

OL3, the first EPR in the family, is specially instrumented to

supply a set of readings specified at the design stage for

the other reactors of the same type.

THE EPR PROJECT IN THE UK

The EPR construction site at Olkiluoto

The relations between the EDF Energy Nuclear New

Build (NNB) staff and that of the Nuclear Engineering

Division in France seemed to have been strained last year

but have now greatly improved. The successive stages


A NEW IMPETUS FOR THE EPR-TYPE REACTORS

of certification of the EPR in the UK and the building

licence application process are being worked out and

the responsibilities of the owner-operator (NNB) and

the designer (the Nuclear Engineering Division and the

CNEN) are now clearly established. The site licence for

Hinkley Point C was obtained from the Office of Nuclear

Regulation in December 2012.

The Hinkley Point C project team has set up a Project

Execution Plan laying down the principles of the project,

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

its general organisation and the roles and responsibilities

of all involved. The Project Execution Plant re-affirms the

responsibilities of NNB as the operating organisation and

licence holder.

I note the creation of a project technical steering

committee designated MODEM (Monitoring and DEcision

Meeting) which has made it possible to settle almost all

the technical issues identified last year.

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

Since the worksite opened in 2005, EDF has been

running a social and economic backup programme

that has won acclaim in France and beyond.

The mainspring of success for this type of back-up

project is access by local companies to contracting

work, with the benefit for the surrounding area

that results from it. Local employment is a powerful

argument and EDF has set in place appropriate

professional training in support of it. Today, as the

erection phase begins, some 360 workers have been

trained to work in the metallurgy and inspection

professions. At the end of 2012, 87% of them were

hired and 75% still had their jobs after one year.

Facilitating the accommodation of incoming workers

makes them feel comfortable and improves their

quality of life. The contractors’ association at the

worksite is taking care of this. Utilisation of purposebuilt

living quarters, furnished rooms and local

subsidised housing, plus some 1,200 private lodgings

and bed-and-breakfast type accommodation provide

CHINA AND THE EPR REACTORS AT

TAISHAN

In a context of competition between Generation III projects

under construction in China, TNPJVC the owner of the

Taishan site, is getting ready to become the operator of the

first EPRs to go on line. I would like to draw attention to

the potential difficulties in supplying the design work. The

Taishan schedule, which is now ahead of Flamanville 3,

has given rise to a risk of loss of coherence between the

reference nuclear unit and its daughter one. I wish to

signal the need to reinforce the EDF back-office support

team accordingly, as the staff are already very busy.

a wide range of solutions to meet the needs of

everyone. The Flamanville 3 contractors’ association

has been a success. What has been learnt from

this initiative needs to be put to good use for the

ten-yearly outages of the plants and the General

Refurbishment.

The old Flamanville iron mine buildings converted.

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MY RECOMMENDATIONS

I consider the proactive treatment of the reactor building

crane bracket incident to be exemplary. This incident

could have involved us in lasting difficulties with the

nuclear safety authority and the general public. EDF

has behaved responsibly and handled the matter as

an operator conscious of the requirements of nuclear

safety. Some lines of defence failed to function properly,

but others held. Although rationalisation is always

necessary, I am sounding the alert about the danger

of having only one line of defence.

The need for detailed, reliable planning and scheduling

is universally accepted. But it is difficult for teams to

establish it and determine the critical path with sufficient

accuracy. The EDF organisation certainly underestimated,

from the beginning, what planning resources and

skills would be necessary. In setting up such projects,

I consider that we pay insufficient attention to the

support aspects compared with the technical ones.

Making up for lost time consumes even more resources.

Concerning this point in particular, it seems that

action is needed without delay.

58

A NEW IMPETUS FOR THE EPR-TYPE REACTORS

The spectacular turnaround in the Flamanville industrial

safety results once again shows the importance of

encouraging the managers in the field to focus on

safety. This, however, can only be successful if it has

the support of those in charge of the main contractor

companies. Here, I hail the decisive, unifying role that

the F10 plays in this domain, as in others.

From what I observe outside France in other EPR projects,

I clearly see the complications that arise in France from

having this project managed by two separate divisions;

one in charge of design and construction, while the

other is in charge of future operations. This has made

it difficult to optimise the company’s resources during

the construction phase, which involved substantial

delays. This year, once again, I emphasise the need to

reinforce cooperation between the two divisions.


PLANT LIFE EXTENSION IS CONDITIONED BY NUCLEAR SAFETY

11/ PLANT LIFE EXTENSION IS

CONDITIONED BY NUCLEAR

SAFETY

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Replacement of steam generators

In the EDF Group, plant life extension has been authorised in the USA, is progressing

towards authorisation in the UK and is being examined in France. The aging of equipment

necessitates heavy maintenance work to guarantee nuclear safety. The integration of

experience feedback, new nuclear safety objectives, new safety margin assessments and

the handover to a new generation of engineers are all factors on which successful plant life

extension depends.

AT GROUP LEVEL

For economic reasons and in view of the durability of

the non-replaceable components, plant life extension

beyond the limits originally planned is now being

actively sought in France, the UK and the USA.

Throughout the world, many reactors have already been

licensed to operate beyond 40 years. This objective

involves inspections, refurbishment work and standard

replacement of equipment, which may be substantial,

as well as major programmes of design or research and

development. In addition, it may be necessary to replace

certain items of equipment after decades of operation.

The operational history and the successive modifications

made to plants and to procedures make it particularly

complex to keep updated the safety case for each specific

reactor. Furthermore, many procedures are interdependent

or interlocking (design safety case, design, construction,

spare parts, maintenance, operations, training and

engineering) and the modifications incorporated may

affect all of these issues.

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

I note that the concept of “safety margins” is generally

used inside the EDF Group, but with specific methods and

a field of application that differs in the UK, the USA and

France. These margins need to be reassessed with care in

plant life extension studies.

IN FRANCE

EDF has clearly announced that continuing service beyond

40 years is conditioned by a level of nuclear safety that

has been precisely defined together with the means

of attaining it for all reactors aiming for sixty years of

service. This approach is followed “with due regard for

the objectives set for the new reactors and the best

international practices”, as required by the nuclear

safety authority. Operational experience, international

experience feedback including that on Fukushima, new

data and knowledge about risks and dangers (e.g. seismic

and tectonic) are to be taken into account “insofar as

this data is actually beneficial to nuclear safety and that

their technical and industrial feasibility under acceptable

economic conditions can be established, considering

reactors in commercial service”.1

It is to be borne in mind that, in France, each VD includes

a nuclear safety reassessment and a programme of

work and modifications approved by the nuclear safety

authority. This principle is applied before dividing the work

into industrial-scale packages, with a lead plant for

each type of reactor. Operating by work packages ensures

technical, functional and documentary coherence, which

is essential for nuclear safety. The Fukushima accident

precipitated the early deployment of some of these

modifications in response to ASN technical requirements,

at the expense of the initial ten-yearly programme which

had already been divided into work packages.

I would like to draw attention to the considerable

workload resulting for the engineering centre staff,

and the increased vigilance required as a result of

rearrangements, which is becoming increasingly common

in the wake of the technical requirements arising after

ten-yearly outages.

I have observed that, in this period of unprecedented

renewal of the engineering staff, it is difficult to find

experienced personnel capable of drafting the high-quality

modification case files needed, while the high standards

and the short deadlines greatly complicate the task. It will

take a number of years to reverse the trend and I note

that all too many modification case files prepared by the

engineering centres are not complete or as well-structured

as they were in the past, when received in the plants. Also

in the plants, the staff in charge of implementing the

1 Letter dated 24 January 2011 from the EDF Chairman

to the Minister of Industry and Energy.

60

PLANT LIFE EXTENSION IS CONDITIONED BY NUCLEAR SAFETY

modifications are generally less experienced, as the older

workers retire. This “supplementary line of defence”

therefore risks becoming progressively weaker. I would

like to emphasise the important role of the EDF Research

and Development Division in plant life extension: studies

on the long-term behaviour of the reactor vessels and

containments, as well as changes made to the computer

codes.

The stages of plant life extension in

France

• In 2009, EDF informed the nuclear safety authority

of its intention to keep the option of operation

for 60 years open for all its plants in service in

France. The nuclear safety re-assessments already

performed in the French plants reflect international

experience feedback and have reduced the

probability of occurrence of core meltdown while

limiting the consequences.

• In 2012, EDF stated its goal of further increasing

the level of nuclear safety to continue operation

beyond 40 years, carrying out the process in the

light of the nuclear safety objectives for new

reactors. EDF plans to implement this nuclear

safety initiative from the fourth ten-yearly outages

(VD4) of the 900 MWe series units as of 2019 and

of the 1,300 MWe series units as of 2025. Some

modifications will be incorporated in advance

during the third ten-yearly outages (VD3) of the

1,300 MWe series units from 2015 as part of the

post-Fukushima actions in all the plants.

• The options for plant life extension were the

subject of a meeting by the Standing Committee

for Reactors on 18 and 19 January 2012.

Examination of the options for the VD4 for the

900 MWe series units will take place at another

meeting scheduled for late 2013 or early 2014.

IN THE UNITED KINGDOM

Sizewell B, a recent PWR, has had the advantage of

sharing information with the worldwide community

of PWR operators and the corresponding feedback, for

example in the field of steam generators, pressurisers, the

primary coolant system welds, and fuel performance.

In comparison, the AGRs which are only found in the UK,

have given rise to problems which often require unique

solutions. Aging of the graphite cores is studied and

monitored by a team of some 200 experts who include

EDF Energy specialists and staff working under contracts.


PLANT LIFE EXTENSION IS CONDITIONED BY NUCLEAR SAFETY

A vast graphite R&D and inspection programme is in

progress. I was shown a number of computer models and

AGR GRAPHITE

Nuclear safety requirements

The AGR graphite cores are designed to fulfil a

range of safety functions. The key requirements

are moderation of fast neutrons, maintain channel

shape for control rod and fuel movement, direct gas

flow to maintain fuel and graphite temperatures.

Aging and deterioration of graphite

There are two principal mechanisms affecting the

AGR Cores:

• graphite weight loss due to oxidation of the

graphite,

• graphite shrinkage leading to brick cracking

affecting core geometry and distortion.

Both of these factors compromise the ability of the core

to fulfil its key safety functions and therefore there is a

Weight Loss

Tolerable limit

Progressive weight loss

Time

Current position and forword strategy

The overall strategy to support the safe lifetime for

the graphite core:

• Understand the levels of graphite degradation that

can be tolerated for brick cracking and graphite

weight loss

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

saw a number of mock-ups of the cores and the control

rod channels , some of which were full scale.

limit to the allowable degradation of weight loss and

brick cracking.Since graphite components cannot be

repaired or replaced they limit the lifetime of the core.

The cracking will go through two phases – gradual

cracking in early life, and rapid cracking in late-life

to reach the tolerable limit. Weight loss is simply

progressive throughout life.

Brick cracking

Tolerable limit

Early-life bore

cracking

Graphite core under construction

Time

Late-life

keyway

root cracking

• Predict, with confidence, the rate of graphite

degradation in brick cracking and weight loss

• Carry out a suitable inspection programme to

determine with the right confidence the condition

of the cores

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Hinkley Point B Nuclear Power Station

In addition, there is a lifetime programme for each AGR

which covers operation until its withdrawal from service

with a precision of ±2 years. A programme of work and

maintenance is in place for each of the twenty main

systems to make sure they reach their target service lives.

If necessary, research and development work is carried out

to obtain the knowledge required to make any decision

with nuclear safety implications.

At EDF Energy, the Design Authority department maintains

visible safety cases to guarantee that the overall nuclear

safety case for each reactor is always clearly established

so it can be used and understood by a wider group than

a small number of highly-experienced professionals, many

of whom are due to retire.

IN THE UNITED STATES

My visit to Nine Mile Point Nuclear Power Plant,

Constellation Energy Nuclear Group and Nuclear Energy

Institute (NEI) this year was not focused on plant life

extension, since I covered this issue in 2011 when I visited

Ginna Nuclear Power Plant, the oldest Constellation

Energy Nuclear Group power plant. Calvert Cliffs, Ginna

and Nine Mile Point Nuclear Power Plants have been

successively licensed to operate for up to 60 years.

However, there are a few points that I believe require

special care.

First of all, in the USA, the spent fuel storage pools

of some plants are now full, including those of

Constellation Energy Nuclear Group. This is because the

government authorities put off the decision to create a

federal spent fuel repository. For the Nuclear Regulatory

Commission (NRC) and the operating organisations, I

understand that they see this as a business risk that does

not affect nuclear safety. Concerning this point, I note

that the regulatory nuclear safety requirements differ

in the USA and Europe. As I see it, if the operators of a

nuclear power plant cannot unload the core because the

spent fuel storage pool is full, then that is incompatible

with good nuclear safety practices or judicious planning

for emergency situations. I have taken good note of

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PLANT LIFE EXTENSION IS CONDITIONED BY NUCLEAR SAFETY

the fact that Constellation Energy Nuclear Group has

provided additional storage capacity at Calvert Cliffs and

Ginna Nuclear Power Plants, and that this is nearly ready

at Nine Mile Point Nuclear Power Plant.

Secondly, at Nine Mile Point Nuclear Power Plant, the

plant engineering team seems to be particularly busy. The

refurbishment required due to plant aging is taking place

at the same time as numerous unscheduled activities in

the wake of the Fukushima events. In addition, work is

being carried out to increase the power rating. In view of

the fact that there are limited numbers of skills available

at the headquarters, I would like to sound the alert on a

situation that may develop in time into a nuclear safety

issue.

I was also struck by the effectiveness of the methods

used by the nuclear industry in conjunction with the

NEI, which interacts with the NRC on generic issues.

High-level working groups are entrusted with questions

such as security and emergency planning. The working

groups are assisted by numerous ad hoc committees that

develop the necessary clarifications on certain issues, such

as the behaviour of buried pipes. A committee called the

Strategic Issues Committee deals with strategic questions

and includes the Chief Nuclear Officers of all the different

operators. If more than 80% of the Chief Nuclear Officers

agree on an issue, an action plan for the entire sector is

created and all agree to comply with it.

Finally, I would like to emphasise the strong links between

the American nuclear operators, including Constellation

Energy Nuclear Group and the Electric Power Research

Institute. As concerns the plant lifespan, I note the Long

Term Operation Program which focuses on seven topics,

such as reactor coolant system metallurgy, concrete

structures and advanced computer codes for accident

studies.


MY RECOMMENDATIONS

PLANT LIFE EXTENSION IS CONDITIONED BY NUCLEAR SAFETY

For the UK

The publically announced objective of extending the

service lives of the AGRs by an average of seven years

is ambitious, clear and inspiring. Although there are

corresponding associated financial incentives for most

of the staff involved, the experts specialised in these

programmes need to be given motivating criteria

relating to nuclear safety objectives so that they clearly

understand the essential nuclear safety phenomena

and parameters, and also to guarantee that any plant

lifespan proposed to the plant management includes

appropriate and properly substantiated margins.

Three departments are involved: 1) Design Authority

charged with handling the overall nuclear safety cases, 2)

the teams in charge of research into graphite and other

vital components such as boilers, and 3) the Nuclear

Safety Division which provides the internal independent

nuclear safety analyses. Each plays its own highlyspecific

role in the field of nuclear safety. I consider that

this arrangement needs protection and support to avoid

any untoward pressure to prolong the service lives of

the existing reactors beyond what is reasonable in terms

of nuclear safety, particularly in the event of delay in

building new power plants.

I fully approve the integration of young professionals

under supervision to prepare and keep up to date the

visible safety case files and ensure traceability, under the

close watch of experienced professionals to guarantee

the transmission of knowledge before the latter retire.

As indicated in 2011, successive long delays have

occurred in incorporating certain modifications with

nuclear safety implications. For each reactor to be able

to benefit fully from the safety advantages conferred by

a lifetime programme, I reiterate that it is indispensable

for there to be proper project management.

For France

Once a new modification programme is established,

it seems essential to seek functional coherence in

new groups of work packages (“lots” in French)

to guarantee their durability, in order to ensure

the availability in due time of all the associated

documentation, spare parts and training.

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

The post-Fukushima modification files, the case files

for the forthcoming ten-yearly outages and future ones

relating to plant life extension cannot be considered

separately. The investment of considerable human and

financial resources is required, with major practical

industrial constraints.

I consider that such a situation calls for dialogue at the

highest level between the company and the nuclear

safety authority to determine the priorities and to

find common ground concerning strategy, as is

practiced in the UK and the USA. This dialogue, which

needs to include the IRSN, needs to establish agreement

on a method and timetable that is as full and detailed

as possible covering all the work planned. I would

like to draw attention to the importance of such a

programme being truly realistic in a context where

resources are strictly limited, even for technical

expert appraisal by the ASN. Even if the nuclear safety

authority commits itself to plant life extension case-bycase,

a plan covering all the interactions and preparatory

stages, as well as mobilisation of the resources, the

practical methodology and a proposed timetable is

now necessary. I recommend rigorously determining the

priorities in the interests of nuclear safety.

And more generally for the Group

After decades of operation, the nuclear units, even if

identical or similar at the time of commissioning, have

different service histories. Tracking the nuclear design

and safety files; from the pre-construction phase until

after decommissioning, spans the professional lives of a

large number of players. Certain phenomena of reactor

deterioration or wear due to aging are well known but

contingencies may arise over time as a result of technical

faults.

I encourage the development of the following good

practices:

• guaranteeing that the nuclear safety case files

applicable to each reactor are kept up to date,

• planning handovers very carefully and transferring

knowledge between experts,

• conducting targeted research and development work,

• planning and managing projects rigorously.

63


POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

12/ POST-FUKUSHIMA: THE NUCLEAR

OPERATORS ARE MOBILISED

A Nuclear Rapid Response Force exercise

The EDF Group is taking action at the highest level to make good use of experience feedback

from the accident that occurred in March 2011 and is making any necessary modifications.

A number of countries are debating the impact of national culture on nuclear safety action,

highlighting the need for review by peers from a different culture.

THE SITUATION AT THE FUKUSHIMA SITE

For more than a year at the Fukushima site, all the cores

and spent fuel have been sub-critical, cooled and stable.

In the surrounding area, the local inhabitants have been

authorised to return to some of the evacuated areas.

The doses received in the vicinity of Fukushima

Here is some data on the doses received by the

residents in three conurbations where the exposure

was particularly high (14,000 inhabitants out of a

total of 160,000 evacuees):

• 0.7% of those living nearby received doses of at

least 10 mSv

• 42.3% of them received doses above 1 mSv but

below 10 mSv

Access is still limited to some areas, and will continue to

be so for some decades.

A new independent nuclear safety authority has been in

place since September 2012. Most of the nuclear reactors

in Japan are still out of service. The political context

remains complex, with the debate about energy strategy

continuing.

• 57% received doses of 1 mSv or less

• 60 hospitalised people died as a result of

complications due to evacuation

(Source: the official report of the independent inquiry

commission on the Fukushima nuclear accident)

Note: in Japan, the average radiation dose is 3.75 mSv

per year, of which 1.48 comes from natural sources

and 2.25 from medical exposure.

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

NATIONAL CULTURE AND SAFETY

CULTURE

The official report of the

independent inquiry commission set

up by the National Diet of Japan

66

In December 2011, the National Diet of Japan set

up an independent commission which published

a report six months later. Here are a few extracts

of declarations made by Kiyoshi Kurokawa, the

Chairman of the commission.

“It was a profoundly manmade disaster – that could

and should have been foreseen and prevented.”

“For all the extensive detail it provides, what this

report cannot fully convey – especially to a global

audience – is the mind-set that supported the

negligence behind this disaster”.

“What must be admitted – very painfully – is that

this was a disaster ‘Made in Japan’. Its fundamental

causes are to be found in the ingrained conventions

of Japanese culture: our reflexive obedience; our

reluctance to question authority; our devotion to

‘sticking with the program’; our groupism; and our

insularity. Had other Japanese been in the shoes of

those who bear responsibility for this accident, the

result may well have been the same”

“This conceit was reinforced by the collective mindset

of Japanese bureaucracy, by which the first duty of

any individual bureaucrat is to defend the interests

of his organization. Carried to an extreme, this led

bureaucrats to put organizational interests ahead of

their paramount duty to protect public safety. Only

by grasping this mindset can one understand how

Japan’s nuclear industry managed to avoid absorbing

the critical lessons learned from Three Mile Island and

Chernobyl; and how it became accepted practice to

resist regulatory pressure and cover up small-scale

accidents.”

“The goal must be to learn from this disaster, and

reflect deeply on its fundamental causes, in order to

ensure that it is never repeated.”

The independent commission’s report highlights the

considerable impact of the accident on the general

population, particularly the extreme stress resulting from

the uprooting of families and the overturning of their

lives.

It also expresses through its Chairman the role of the

Japanese culture and he calls for his compatriots to think

carefully about its impact. This uncommon suggestion

deserves to be highlighted and is also applicable in other

countries.

POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

Indeed, in other regions of the world, incidents in nuclear

power plants frequently reveal gaps between the actual

situation and excellence, both in the fields of design

and operations. International peer review teams often

pinpoint such areas for improvement (AFI) and propose

solutions which have proved their worth elsewhere, such

as stricter application of the training requirements and

procedures, or openness in reporting incidents to WANO.

It is often, however, claimed by the hosts that national or

local culture cannot assimilate such good practices, which

are seen as problematic or even impossible to implement.

I am inclined to think that arguments predicating “local

culture” or “special local circumstances” are just

excuses for not making continuous progress with nuclear

safety, and that nuclear safety professionals must carefully

guard against them. This is clearly seen in the case of

Onagawa Nuclear Power Plant near Tokyo, where the

nuclear operator has adopted the highest level of quality

for the nuclear safety design options. The tsunami risk

was identified in 1968 and the site elevation was set

more than 14 metres above sea level: good nuclear safety

culture ensured that the design safety margins were

adequate.

IN FRANCE

Action by EDF SA

The company decided to upgrade nuclear safety to limit

the risk of major radioactive discharges with regard

to substantially worse contingency cases, situations

combining station blackout with loss of the heat sink for

a long period of time.

This substantial upgrade of nuclear safety is based on

physical arrangements and extra resources for emergency

planning and response. The experience feedback from

Fukushima indicates the need for:

• reinforcing the protection against external hazards to

avoid possible cliff-edge effects,

• having sufficiently robust and diversified electricity and

water supplies,

• having a suitable organisational structure covering means

of transport, logistics, protection and communication,

• having identified last-resort resources for the case

where a situation deteriorates,

• having an emergency management centre that is

sufficiently well protected.

To meet these goals, EDF has committed itself to four

major action plans.

Firstly, an analysis of whether the operating teams

are sufficient in numbers to apply the post-accident


POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

operating procedures in the event of a severe accident,

particularly one involving more than one reactor. The

recent conclusions suggest reinforcement of these

teams, to provide for the additional equipment proposed

in the wake of the stress tests and to be able to cope

with accidents affecting more than one nuclear unit. This

reinforcement is to be completed by 2020 at the latest.

Secondly, the incorporation of major modifications,

in a progressive roll-out forming part of the continuous

improvement of nuclear safety and foreshadowing the

plant life extension project requirements. In addition,

stress tests have revealed shortfalls in conformity that also

need to be resolved.

Thirdly, the creation of a hard core of robust physical

and organisational arrangements. This is to guarantee

nuclear safety beyond the original design base, as a

final line of defence against certain highly-improbable

situations. The physical and organisational arrangements,

which are limited in number, should prevent any sustained,

massive radioactive discharges into the environment. The

hard core also includes arrangements for emergency

management, notably emergency management centres,

means of communication, dosimetry and measurements

in the environment.

Fourthly, the Nuclear Rapid Response Force, a

corporate-level EDF unit integrated into the EDF

emergency management system. It will rapidly provide a

plant in difficulty with backup consisting of equipment

and personnel, taking over from the plant staff and

fielding additional emergency response resources within

24 hours, with operations on-site beginning within

12 hours of being summoned. Since 1 January 2013,

the Nuclear Rapid Response Force is ready to deploy a

reconnaissance team and a flying column to any plant to

take action in the case of an incident involving a single

reactor. At the end of 2014, it should be able to cope with

four reactors in difficulty at a single site, and by the end of

2015 with the six reactors at Gravelines site.

Finally, on 13 September 2012, EDF submitted its

assessment reports on the sites of lower priority than

the nuclear power plants, i.e. the six decommissioning

sites. As in the case of the plants in service, a standing

committee will handle these stress tests in mid-2013.

Key dates

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

• May 2011: ASN requirement for a stress test and

validation of the European stress test specification

• September 2011: EDF stress test reports

• November 2011: Standing Committee review of

the stress tests

• January 2012: National report on ASN nuclear

safety supplementary assessments

• March 2012: on-site review by European safety

authority peers

• April 2012: presentation of peer reviews to

ENSREG (European Nuclear Safety Regulators

Group)

• June 2012: setting up of the steering committee

on social, organisational and human factors

organised by the ASN

• June 2012: stress tests - additional ASN

requirements (more than 600 technical

requirements)

• August 2012: extraordinary IAEA Convention on

Nuclear Safety meeting

• September 2012: EDF stress test reports for the

decommissioning sites

• December 2012: Standing Committee meeting

on determining the hard core of the stress report

requirements

The stages of incorporating

modifications

• In the short term and until 2015, implementation

of provisional means for covering long-term

station blackout and loss of all heat sinks situations

using local and mobile safety resources (pumps,

generating sets etc.). Additional resources with

one generating set per nuclear unit, wells drawing

from the water table and connection points for

water, air and electricity.

• Between 2015 and 2019, installation of the

first hard-core items. Incorporation of final

modifications of the installations, last-resort

diesel generator, last-resort water make-up with

dedicated supply. Construction of a hardened

local emergency management centre.

• From 2019 to 2025, completion of the hard core

items to cover the most extreme situations.

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Actions and standpoints of the nuclear safety

authority

The French national report on the stress tests was submitted

to the European Commission in early January 2012. It was

widely distributed and there was a peer review by the

European nuclear safety authorities organised by ENSREG

before the end of March 2012. On that occasion, Tricastin

Nuclear Power Plant was inspected by an international

team. A report was produced by ENSREG in April 2012,

which was submitted to the European Commission.

On 26 June 2012, the French nuclear safety authority

published its decisions in the form of technical requirements

relating to the mitigation of natural risk, as well as risks

relating to other industrial activities. In the context of its

decisions, the ASN “considers that the safety level of the

facilities is sufficient and thus no request for immediate

action is required in any of them. Meanwhile, it considers

that their continued operation requires increasing without

delay their ability to resist external events beyond the

existing nuclear safety margins.”

It also reiterates that an accident can never be ruled out

and that the operator bears prime responsibility for the

nuclear safety of its facilities. The ASN therefore imposed

a set of measures on the operators to address:

• combinations of natural phenomena of exceptional

amplitude exceeding the levels considered at the time

when the design was established,

• severe accident situations after prolonged station

blackout or loss of cooling capability.

EDF SA’s contribution to WANO

In October 2011, at the WANO Biannual General Meeting

held in Shenzhen, China, it was unanimously voted to

increase the human and physical resources by increasing

the secondment of competent persons by the members.

Seventeen EDF SA engineers joined the staff at the Paris

centre in 2012, and the number is due to increase to 32

in 2013, 40 in 2014 and 47 by the end of 2015. This

is an opportunity for a certain number of engineers to

be exposed to international practices. I note that EDF has

done all it can to reinforce WANO at a time of massive

renewal of skills. I am glad to see this commitment as I

believe the nuclear industry needs such an organisation

that is strong, recognised and coercive when necessary to

achieve progress in the field of nuclear safety.

This year, seven peer reviews were hosted in EDF SA

plants.

68

POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

IN THE UNITED KINGDOM

The main actions of EDF Energy

The stress tests were completed on schedule. In the UK,

the beyond-design-basis risk considered most probable

is a violent storm (rather than an earthquake and/or a

tsunami). The damage by water can occur at any height

and not only at ground level. Once the electrical systems

are damaged, their repair and return to service may take

a long time (such as in Fukushima), which is why the basic

cooling system features pumps that are directly-driven by

diesel engines.

It is of fundamental importance to be able to control

emergency measures from outside the plant, keeping

most of the staff at a safe distance from the hazards

on the site. In the case of Fukushima, the emergency

measures were, and still are, hindered by the closeness of

the emergency centre.

The first eighteen months after the accident were

devoted to analysis of the existing nuclear safety margins,

assessment of the possibilities of improving the situation

and establishing an integrated solution (modifications,

new equipment, emergency procedures etc.).

Sizewell B Nuclear Power Plant

The execution phase to follow will be completed by mid-

2014. This will include many hundreds of actions relating

to:

• the resilience of the installations (protection of the

buildings including access to the plants and the

emergency centres, emergency installations, data

management systems, satellite technology, interfaces

for the reception of emergency equipment and supplies),

as well as the construction of additional emergency

centres in the plants where necessary; it will also cover

the reinforcement of the plants from outside via mobile

emergency management centres and reinforcement of

the central emergency centre at Barnwood,

• the storage of emergency equipment at four strategic

points (dewatering pumps, high-pressure pumps,

off-road vehicles some of which would be for the

transport of large special-equipment containers, mobile

generating sets and accommodation units),

• modification of the way in which the emergency


POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

response is organised (new roles and new knowledge

requirements),

• the following modifications at Sizewell B: introduction

of auto-catalytic hydrogen recombiners inside the

containment (April 2013), remote control of the filtered

containment venting system (October 2014).

For the Hinkley Point C EPR project, proposals regarding

the lessons learnt from the Fukushima event were

submitted to the Office of Nuclear Regulation (ONR).

Key dates

• April 2011: immediate reports from the operators

describing the state of the facilities with regard to

the design basis

• May 2011: provisional report by the chief

inspector of the ONR

• October 2011: final report by the Chief Inspector

of the ONR

• October 2011: submission by the licensed nuclear

operators of the final stress test reports

• April 2012: on-site review by European safety

authority peers

• August 2012: extraordinary IAEA Convention on

Nuclear Safety meeting

• October 2012: rapport by the Chief Inspector

of the ONR on the state of progress with

implementation

The actions and standpoints of the Office for

Nuclear Regulation

In October 2012, the ONR Chief Inspector published a

report on the implementation of lessons learnt by the

British nuclear industry from the earthquake and tsunami

in Japan. Here are some of his conclusions:

• “all relevant stakeholders have shown an appropriate

level of commitment to address the Chief Inspector’s

recommendations and the relevant findings of the

Stress Test reports”,

• “there is clear evidence that adequate progress is being

made, with improvements either in place or planned”,

• “However, more needs to be done and it is important

that all involved sustain their efforts to ensure that all

recommendations, considerations and findings are

closed out, and that the intended safety benefits are

realised”,

• “ONR will press for the industry to complete the more

significant improvements arising from learning from the

Fukushima event by the end of 2014.”

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

EDF Energy’s contribution to WANO

Since the decisions taken in Shenzhen, EDF Energy now

has eight staff seconded to the WANO centre in Paris

(four in 2011, thirteen in 2013). The purpose is to set

the example by meeting the goal set for the number of

seconded staff in 2015 by the end of 2013. The company

has set in place a cycle of WANO reviews in its plants every

three years, with intermediate follow-up every eighteen

months.

Every year, six to eight technical assistance missions are

carried out, with forty to fifty employees participating

in peer reviews and thirty to forty contributing to other

assistance missions. A chief nuclear officer directed the

WANO internal assessment of all the five WANO centres

worldwide.

IN THE UNITED STATES

The main actions of the Constellation Energy

Nuclear Group and the American nuclear

industry

Through the NEI and INPO, the American nuclear industry

rapidly organised itself to draw the first lessons from the

accident. The presence of a number of boiling water

reactors on its soil and the similarity of some of them to

those at Fukushima have facilitated the analysis made. I

observed that, by April 2011, a steering committee had

been set up in response to the Fukushima event which

included the industry players, EPRI, INPO and NEI, with the

spheres of action entrusted to seven working groups. NEI

remains the main coordinator of exchanges between the

nuclear industry and NRC for generic issues.

The industry and NRC have agreed on a set of actions to be

taken without delay. These notably include diverse and

flexible coping strategies (designated FLEX) designed

to maximise the safety improvements within the shortest

time possible. The electricity companies purchased

mobile FLEX equipment (pumps, diesel generators etc.)

before the end of March 2012, with on-site deployment

and training to begin shortly afterwards. An NEI policy

document describes the deployment and protection of the

equipment, its utilisation as part of operational procedures

associated with accidents and incidents, its maintenance,

its testing and the associated training requirements.

I would also like to highlight the decision to create regional

centres - one in Tennessee and the other in Arizona -

intended to store equipment vital for preserving nuclear

safety should an extreme event occur. Created in mid-

2012, they will supplement the mobile equipment at the

sites and are to be operational before the end of 2014.

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Key dates

• April 2011: immediate reports from the operators

describing the state of the facilities with regard to

the design basis

• July 2011: publication of the NRC Near-Term Task

Force’s report

• December 2011: determination by NRC of three

categories of action to be taken: Level 1 “to be

done immediately”, Level 2 “in the event of limits

imposed by critical skills or resources” and Level 3

“when studies in greater depth are necessary to

substantiate regulatory action”.

• March 2012: publication by NRC of directives

for resilience strategies for coping with station

blackout, hardening containment venting systems

and instrumenting spent fuel storage pools. It

requires additional information on the assessment

of seismic risks and flooding, on-site verifications,

and also specifies requirements concerning

staffing levels for emergency situation planning,

as well as the reinforcement of the means of

communication.

A timetable has been defined for the regulatory requirements,

which indicates the key dates of the different stages of the

work. Apart from FLEX strategies, these stages cover station

blackout, hardening containment venting systems, and

spent fuel pool instrumentation and filters. The scheduling

also covers organisational matters, including major accident

management directives, measures relating to industrial

safety in the event of accidents in numerous plants, as well

as increasing the resistance to earthquakes and floods.

In America, the industry is in the process of reassessing the

seismic risks using models and data updated for the plants

in the central and eastern areas of the USA. The goal is to

determine the need for updating the nuclear safety rule set

for the main systems, structures and components. I have

taken good note of the fact that a decision is due concerning

the necessary scope of probabilistic analysis of the seismic

risks for the Constellation Energy Nuclear Group plants.

70

POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

The modifications to be made at

Nine Mile Point 1, a Mark-1 design

reactor similar to Fukushima-

Daichi 1

• A decision concerning the filtered venting systems

for boiling water reactors is pending in February

2013.

• Installation of two wide-range measuring channels

for the water level in the storage pools (2014)

• Providing uninterruptible power supplies for the

site communication systems and those of the

emergency centre (2014)

• Reinforcement of the reliability and operability of

the containment venting system (Spring 2015)

• Provision of tappings and connection points on

mobile equipment for the supply of air, water, fuel

oil and electricity (Spring 2015)

• Construction of a storage area protected against

external events for mobile emergency equipment

(2015)

• Installation of barriers to mitigate the risk of the

diesel generators being flooded in the event of

extreme and protracted precipitation (Spring

2015)

IN CHINA

For the two EPR nuclear units under construction at Taishan,

I note that a close link is being maintained with the

Olkiluoto and Flamanville projects, which is extremely

positive. This sharing of experience, which has covered the

manner in which the project staff have responded to the

post-Fukushima regulatory requirements, has contributed

to the promotion of nuclear safety at design, construction

and operations levels. I remain attentive to the tsunami

risk in the geographical area in which the Taishan plant is

located. During my inspections in 2013, I will be focusing

on this aspect.


Key dates

POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

• March 2011: decision by the State Council to put

the approval and licencing of new reactors on

hold but continuation of power generating in the

existing nuclear facilities and the construction of

the 25 nuclear units already under way

• October 2012: announcement that the

construction of nuclear power facilities will be

resumed, with a small number of Generation

III projects over the next five years, probably at

coastal sites

In conclusion, I think that rapid adoption of the stress

test route in Western Europe has enabled operators and

regulatory authorities to begin reassessing the design

bases in terms of natural hazards and to conduct the

corresponding nuclear safety studies more promptly there

than in the USA. Nonetheless, after 9/11, the USA has

probably progressed further and faster as concerns the

availability of mobile response equipment for emergency

situations.

MY ANALYSIS AND

RECOMMENDATIONS

For France

I observe that the programme of physical and organisational

modifications is particularly ambitious. EDF is clearly one

of the operators to have taken action most promptly in

the areas of physical and organisational arrangements

to resist external hazards. I emphasise the importance of

dealing with cases of non-conformity as top priority.

The creation of the Nuclear Rapid Response Force

(French acronym FARN) has increased the sustainability

of response by being available to support the plant

emergency teams and the ability to deal with an accident

situation affecting a number of reactors at the same site.

Its staffing and specialisation began at Civaux Nuclear

Power Plant to prepare for deployment in early 2013 of

an national reconnaissance team and a flying column

ready to be sent to any nuclear power plant. I emphasise

the need for training, maintaining skills and motivating

the Nuclear Rapid Response Force staff.

The project also calls for promptly creating a number

of connection points for equipment in the plants

in a coordinated manner. This is accompanied by

modifications to the installations affecting systems that

are important to nuclear safety. I would like to draw the

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Without knowing the details of the American regulatory

arrangements, I remain convinced that the periodic

reassessment of nuclear safety is definitely positive. This

exists in France and the UK, with ten-yearly reassessment

of the risks in the light of new data and knowledge.

I note that “hard core” requirements (robust physical

and organisational arrangements intended to guarantee

nuclear safety beyond the design basis, an ultimate line of

defence against highly-improbable situations) are as yet

limited to France.

I would like to call to mind the letter sent in July 2012

by the Chairman of EDF to Li Ganjie, the president of

the extraordinary meeting on the IAEA Convention on

Nuclear Safety in August 2012. This letter forcefully

states the standpoint of the EDF Group which is that “no

severe accident will entail a consequence long-term

contamination of large territories”. It also emphasises

the importance of periodically reviewing the nuclear

safety options. It seems highly desirable for all the reactors

in the world to meet these two requirements.

Finally, I hail the active manner in which the EDF Group

managers in France, the UK and the USA have drawn

lessons from the Fukushima accident and influenced

world governance of the nuclear industry.

attention of the ASN and EDF to the very short time

available for settling all these matters. The electrical

resupply points can raise design questions that can be

difficult, particularly in the field of instrumentation and

control, as it is needed to guarantee that the existing

situation is not negatively impacted. This is an important

nuclear safety issue.

As in 2011, I insist that the Nuclear Rapid Response Force

which is part of the EDF accident response organisational

structure, is the subject of due consideration with the

government authorities: the Nuclear Risk Support Team

(MARN), the defence zone prefectures and the National

Committee of Public Safety and Defence. I note that

an experiment is planned with the public authorities of

South-East France.

In view of these major changes that come in addition

to the General Refurbishment work, I will be carefully

watching how these modifications are made without

overloading the skills in the plants and the engineering

centres. I would like to once again hail the way all the

players mobilised to deal with a task this great while

respecting the time limits and quality requirements.

I recall the need to establish a strategic plan with

the ASN as soon as possible, including the ten-yearly

nuclear safety upgrades that are now enshrined in

French law.

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For the UK

In beyond-design-basis scenarios corresponding to

extreme situations that combine the loss of all electrical

power supplies and the loss of all heat sinks, the

temperature rises more rapidly in a pressurised

water reactor than in an advanced gas-cooled

reactor, as the power density of the latter is forty times

less. The consequence of this is that the deterioration

steps during an accident and the measures to be taken

are different in both reactor types. The time available can

be measured in days for an AGR, while only in hours for

a PWR. In both cases, I am pleased that the mitigating

measures to be implemented take cognisance of the

view of the emergency managers, the operating staff

and the emergency response staff in the field.

I also note that the players, operator and Office of

Nuclear Regulation, have a process for continuously

improving safety, which will make it possible to integrate

all existing and future post-Fukushima experience

feedback.

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POST-FUKUSHIMA: THE NUCLEAR OPERATORS ARE MOBILISED

For the USA

None of the plants in the USA were shut down in

the wake of the Fukushima accident and the selfassessments

and checks required under the regulations

gave rise to corrective action.

The organisation of relations between the safety

authority and the industry is consolidated by the NEI

as concerns generic matters. This division of roles has

proved highly effective. Meetings are generally held in

public; they are frequent and clearly focused, having

made it possible to make progress in a country where

respect for the judicial system is of primary importance.

I have also observed the usefulness of a high-level

strategic plan, established with the mutual agreement

of the regulatory authorities and the industry and that is

widely known and respected. This contributes to nuclear

safety as the priorities are laid down with care, taking due

allowance for nuclear safety and business constraints.

The companies and plants can thus schedule these

changes and modifications to ensure minimum impact

on nuclear safety during the implementation phase.


NOTEWORTHY OPERATING EVENTS

13/ NOTEWORTHY OPERATING

EVENTS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Kori Nuclear Power Plant in South Korea

The events singled out this year have connections with the main operations professions.

Of very different natures, they show the need for continuously consolidating safety culture

and the human and organisational lines of defence.

A SERIES OF CASES OF SUB-STANDARD

QUALITY DURING UNIT OUTAGES

The facts

The nuclear unit was in the hot shutdown mode (155 bar

and 297°C) pending restarting after a planned inspection,

scheduled three months earlier. The operations field team

in the reactor building was re-filling with water and

venting the Loop 2 cold leg bypass line. This operation

followed on from operations carried out on the same

day on the orifice plate of the loop (opening for visual

inspection).

After venting, when closing the valve (RCP 426VP) which

connects to the nuclear island vent and drain system,

the drain flow sight glass of the latter system broke. This

resulted in a major reactor coolant leak of 7 m3 per hour.

The three operations staff present left the area without

being wounded or contaminated. The operations team,

in accordance with the procedures, initiated transition

of the nuclear unit to the safe cold shutdown state (27

bar and 90°C) and the leak was stopped after a few

hours by closing the valve on the spot. There was no

discharge into the environment. The analysis ordered by

the corporate director of the plants and the director of

the plant in question after the incident revealed that the

handling of the event (nuclear safety, industrial safety,

radiation protection and protection of the environment)

had been managed in accordance with the emergency

management instructions but that there were weaknesses

and shortcomings that needed to be corrected.

The sequence of events

This event had serious consequences due to the loss of

primary coolant inside the reactor building which lasted a

number of hours and endangered the field staff. It resulted

in a ten-day extension of the outage at considerable

expense. It resulted from a string of cases of sub-standard

quality and the crossing of lines of defence.

In the sequence of events, I note that:

• the planned replacement of 11 primary coolant

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

temperature measuring probes during the outage was

managed by the plant instrumentation and control

department,

• the job was out-sourced to a prime contractor

(this was a Case 1 Situation where the service

provider had its own quality assurance system and

working procedures). Replacement of the probes

necessitates changing the adapters. When the

adapter is seized, it needs to be drilled out to extract

it. This was the case with ten of the eleven adapters.

• the prime contractor entrusted the work to a subcontractor:

the instrumentation and control department

put the valves and metal fabrications department in

charge of technical surveillance of the drilling.

• the procedure calls for drilling a 20 mm blind hole and

vacuuming up the cuttings. If it proves impossible to

unscrew the adapter after making a first hole, a 22 mm

diameter through-hole can be made on the condition

that the cuttings are vacuumed up and an endoscopic

examination of the header is performed with a flexible

probe that is at least one metre long,

• the sub-contractor took the initiative of making a

through-hole straight away, using a 20 mm diameter

drill, without following the procedure and without

informing either the prime contractor or EDF. This was

done with the eleven adapters in succession.

• the endoscopic examinations were carried out by the

sub-contractor with an unsuitable endoscope (too

short and rigid) which failed to detect the presence of

cuttings in the header,

• the EDF inspector replicated the check by the subcontractor,

with the same result,

• two months after the job, when restarting the nuclear

unit, an insufficient flow in the Loop 4 temperature

bypass was detected. An inspection of the loop orifice

plate was decided upon and scheduled for handling

with the unit at shutdown state with the steam

generators in service,

• two days later, inspection of Loop 4 indicated the

presence of cuttings in the header. The raising of the

primary system temperature and pressure continued

without the two other loops being inspected (although

similar drilling operations had been performed),

• a week later, it was decided to inspect the two other

loops. The nuclear unit was in hot shutdown mode.

After the inspection of Loop 2, the event occurred

when the bypass line was put into service.

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NOTEWORTHY OPERATING EVENTS

My analysis

I have picked this event as it illustrates some of the

current maintenance difficulties with their actual

and potential consequences. In the case of the probe

replacement work, however, I do not see what are usually

the causes of sub-standard quality: the need to change

probes is not a new one, the maintenance instructions

date back a number of years, the unit outage spanned a

number of months and there was no urgency about the

job, the main contractor was properly qualified (Level 1)

by the Central Technical Support Department and had

previously carried out this work, as had the sub-contractor.

This being the case, I am struck by the succession of

cases of sub-standard work of all types and the

weakness in the lines of defence, which failed to perform

their roles.

I am left wondering about the deliberate and repeated

disregard for a procedure important to nuclear safety. I

consider that the sub-contractor demonstrated a real lack

of nuclear safety culture, compounded by lack of staff

training. The question must be raised as to the reliability

of Case 1 qualification of a contractor as a line of defence

when its checking and surveillance systems can let such

discrepancies through.

Nowhere in the reports about the event is there any

mention of the risks for the ALARA approach, the

importance of which I would like to underline for the

operatives and inspectors.

Neither was EDF surveillance of the work a sufficiently

strong line of defence. This was done by each profession

without considering the wider implications of the work. In

multi-speciality services such as this, it is desirable to have

a single inspector watching the contractor.

Finally, after first discovering cuttings in the Loop 4 line, I

am surprised that a week went by before inspecting the

two other loops.

In conclusion, it is to be borne in mind that this event

had no consequences on the environment or on the

operators and that incident was properly managed. What

needs to be remembered is that we need to question the

confidence we place in certain lines of defence which may

not be as strong as we imagine. It is there to remind us,

once again, that analysis of the risks and checking and

inspection in the field are necessary for obtaining

proper quality and dependable nuclear safety.


A DIAGNOSIS ERROR DURING START-UP

The facts

The annual outage for maintenance and refuelling was

coming to a close and start-up was beginning. The reactor

pressure vessel was closed, the core was still sub-critical,

the pressure in the reactor coolant system was 3 bar, the

primary coolant pumps were stopped and venting of the

reactor coolant system was in progress.

At the end of the afternoon shift at around 20:00, the

control room operators noticed a drop in the level of the

chemical and volume control tank for the reactor coolant

system, which they interpreted as being due to a primary

coolant outflow and estimated it at 5 m3/h. Actually,

the venting operations performed that afternoon had

destabilised the pressure regulation action of the chemical

and volume control valve of the reactor coolant system, a

phenomenon of which the operators were unaware.

They saw neither a change in the levels of the reactor

building sumps, nor in the charging and letdown flows.

Unable to explain the chemical and volume control tank

level change after analysis, it was considered that one

of the nuclear steam supply system parameters was not

under control, indicating the need to operate the reactor

in accordance with an incident situation procedure using

what is termed as a symptom-based approach. The

operations team applied the procedure and alerted both

the safety engineer and the duty Emergency Controller

(known as PCD1 in France).

Between 20:00 and 21:00, the control room shift changed.

In accordance with the procedures, the operators manually

started the low-pressure safety injection pumps to

compensate for the loss of primary coolant. The automatic

protection function isolated the containment, resulting

in isolation of the main reactor coolant system makeup

lines. As a result of the absence of an actual outflow

from the nuclear steam supply system and the starting

of the low-pressure safety injection, the pressure in the

reactor coolant system rose to around 10 bar as injections

at the reactor coolant pumps seals were maintained. The

incoming operations shift manager then decided to stop

injection at the reactor coolant pump seals so the decay

heat removal system safety valves would not open.

Meanwhile, the PCD1 decided to muster the plant

emergency response team capable of dealing with such

a case. In the control room, the outgoing team stayed to

support the incoming team, and the two operating shift

managers were present at the same time.

At 21:10, application of the symptom-based approach

resulted in opening the zero-flow valves of the lowpressure

safety injection pumps to the safety injection

NOTEWORTHY OPERATING EVENTS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

sumps inside the reactor building. Five minutes later, the

operators in the control room observed that the level in

the reactor coolant tank (PTR) was dropping and the levels

in the reactor building sumps were correspondingly rising.

This valve opening led to an outflow of some 120 m3 into

the sumps.

Around 21:40, the operations shift manager decided

to send a team into the reactor building to identify the

reason for the flow of coolant into the sumps, and it was

soon determined that it was the safety injection systems

sump levels that were affected.

The PCD1, in the control room around 22:00, assessed the

situation with the two operating shift managers present.

He confirmed that the incoming operating shift manager

was the one in charge of operations. The latter suggested

closing the zero-flow lines valves of the low-pressure

safety injection pumps. The strategy was adopted and the

level in the reactor coolant system tank rapidly stabilised.

At 22:30, the parameters had stabilised and the integrity

of the reactor coolant system was confirmed. The lowpressure

safety injection pumps were stopped.

The operating team exited the incident. procedure

in the middle of the night shift as the primary coolant

balance had returned to conformity with the technical

specifications for operation.

My analysis

• An error of diagnosis

The decision to operate the reactor using incident

and accident situation procedures resulted in an

error of diagnosis by the operations teams, who

mistakenly believed that there was a primary coolant

leak. I would like to point out that the team, in

difficult circumstances, re-established functioning

in accordance with the technical specifications for

operation, adapting the incident situation procedures

to the events as they occurred.

• Lack of mastery of physical phenomena

I observe that the physical phenomena involved

in this event are rarely encountered in operations

and the operating staff and their technical advisers

found it hard to handle them although they were

all experienced. It would also appear that too much

confidence is being placed in leak balance calculations

carried out under abnormal thermal-hydraulic

conditions and there is insufficient awareness of the

uncertainty of the calculations for such situations.

Also, the procedure contained no warnings about the

risk of making too much of a somewhat unreliable

result.

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THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

• An operating shift manager taking initiative

I am pleased with the initiative taken by the operating

shift manager, who was able to ask the right questions

and to promptly suggest pertinent courses of action

to the PCD1, even if this involved departing from

procedures which were being followed.

• Weakened organisational lines of defence

I would like to draw attention to the need for

proper functioning, under all circumstances, of the

organisational lines of defence which are vital for

defence in depth. The simultaneous presence of two

shift teams with their managers in the control room,

the presence of the executive management echelon

in the control room, and not in the emergency centre

provided for such contingencies and giving the

players space for thought, as well as the role of the

safety engineer, are all issues than need to be carefully

considered in the context of unsettled situations.

As I see it, mustering the emergency management

staff in events of this type where they are not formally

required nonetheless constitutes an excellent practice,

with its effectiveness having been demonstrated on

a number of occasions. Furthermore, even though

the decisions made by those involved, in real time

and under difficult conditions, finally proved to be

the right ones, there is no reason not to perform an

in-depth analysis of the human and organisational

factors aspect of the event. I accordingly encourage

the plants to establish, in advance, the respective roles

of the key players in such circumstances: operating

shift manager, PCD1 and safety engineer, using the

analysis of actual events as a basis.

• Confidence of the operating staff in the

incident and accident procedures

Finally, I have noticed that there are inaccuracies, and

even omissions, in the symptom-based incident and

accident situation procedures when the nuclear unit

is in this plant state. Without questioning the benefits

in terms of nuclear safety that these instructions

afford, which have long been established and are

recognised throughout the world, I would like to

draw attention to the necessity to quickly correct

procedures. Promptness is the price that must be

paid to ensure that confidence in these important

documents is preserved.

In conclusion, this event highlights the need to

continuously improve our accident situation

procedures, as regards the underlying physical

phenomena and the proper functioning of our

accident management organisational arrangements.

Clear understanding of the roles of all the key players,

decision-makers and advisers, using pooled experience

76

NOTEWORTHY OPERATING EVENTS

as a basis, merits close consideration at all levels of

responsibility.

Finally, I consider that although the symptom-based

incident and accident situation procedures, which

are by their very nature overarching, may suggest action

that may appear to be radical or even disproportionate

and costly (in terms of equipment and availability), they

are nevertheless undoubtedly extremely beneficial

in terms of nuclear safety, and those engaged in the

field need to place their confidence in them. The nuclear

operator must always be ready to pay the price.

TWO EVENTS IN SOUTH KOREA

Falsified spare part quality certificates

In 2012, the government of South Korea condemned the

use of spare parts with falsified certificates of authenticity.

This related to some 230 types of components (including

relays, fuses and fans) and around a dozen suppliers in

South Korea and internationally. Five of the twenty three

South Korean nuclear power plants were affected and the

national Nuclear Safety and Security Commission (NSSC)

ordered the shutdown of two reactors (Yonggwang 5

and 6) to bring them up to standard. Although the NSSC

considers the impact on nuclear safety to be under control,

the shutdown is liable to have major consequences for

the electrical power supply in the country in the months

to come. Legal action has also been instigated by the

government authorities.

Major shortcomings in nuclear safety culture

at Kori 1

• The facts

Kori Nuclear Power Plant is one of the four nuclear

power stations in South Korea, all of which are

operated by the publicly-owned company KHNP and

its subsidiary KEPCO. Twenty three nuclear units are

in service and five others are under construction at

two other sites. Most of them are pressurised water

reactors.

Kori 1 is a PWR with two loops and a power rating

of 610 MWe. It entered commercial service in 1978

and was the first of a number of such nuclear power

generating facilities in South Korea.

On 9 February 2012, a scheduled outage was taking

place for maintenance and refuelling. One of the two

diesel generator sets (Group A) was out of service for

scheduled maintenance.

The fuel building pool was full of water and


preparations were being made for fuel unloading.

Cooling was provided by one of the two shutdown

cooling system pumps designated Pump B. Pump A

was undergoing maintenance.

The electrical power supplies then available were the

off-site 345 kV mains supply, the Train B step-down

transformer and the site standby diesel generator,

in accordance with the technical specifications for

operation at this stage of fuel handling. The site

standby diesel generator was available, but connected

to Nuclear Unit 4.

The Train B site auxiliary transformer (154 kV) and

the Train A standby diesel generator set were out

of service for scheduled maintenance too, while

maintenance work was just finishing on the Train A

site auxiliary transformer.

Human error during execution of tests on the main

turbine generator resulted in loss of the off-site power

supplies. The Train B diesel generator could not be

started, which resulted in loss of all the electrical

power supplies to Nuclear Unit 1.

The operators managed to re-establish an electrical

power supply 12 minutes later from Train A, and 19

minutes later for the Train B pump cooling the shutdown

reactor.

Cooling during shutdown was accordingly lost

for nineteen minutes and the maximum water

temperature reading in the hot leg of the reactor

coolant system went up from 36.9 to 58.3°C, while

that of the storage pond went up from 21 to 21.5°C.

There was no observed damage to the fuel as a

result of the transient. The incident thus has no

actual consequences in terms of nuclear safety,

the environment or the plant staff. The potential

consequences could have been very serious.

• Lack of transparency

Ignoring the applicable requirements, the management

of Kori 1 (Nuclear Units 1 and 2) did not report the

event to the NSSC, the South Korean nuclear safety

authority, and also failed to call the alert for the event

as provided in the plant’s emergency plan. The Kori 1

management did not report the event to the NSSC

until 12 March 2012, more than a month later.

The NSSC immediately ordered the reactor to

be shut down, announced the event to the general

public and sent in a special technical inspection team

to make a full inquiry.

Together with the government authorities, the

company KHNP organised an expert appraisal

mission by the IAEA, which was carried out in

June 2012 using operational safety review team

methodology, with the assistance of experts, most of

whom were European.

NOTEWORTHY OPERATING EVENTS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

• The main conclusions of the IAEA

The IAEA team announced that the NSSC had

completed it provisional inquiry and was continuing

its technical assessments and investigations. On the

basis of this provisional inquiry, the NSSC demanded

corrective action in the following areas:

• reinforcement of safety culture,

• greater reliability of the standby diesel generator

sets,

• checking of configurations and risk management

during the refuelling outage sequence,

• testing and maintenance procedures,

• declaration of alerts and emergency actions.

The IAEA team confirmed that some of the corrective

action had already taken place and some was in

progress. The management and staff of Kori 1 were

found to be keen and working hard to integrate all

the improvements. Analysis of the root causes of the

event is continuing and is to lead to further corrective

action intended to improve safety culture, processes

and design.

The IAEA team made its own technical analysis

of the event and also focused on the failure to

report the event to the safety authority and

on the violations of technical specification for

operation, which were constituted by the absence

of immediate measures to make the standby diesel

generating set operable, as well as beginning the fuel

unloading process the day after the incident though

neither of the two standby diesel generating sets

were yet serviceable.

This analysis enabled the team to identify other

causes that contributed to the event and determine

supplementary corrective measures for Kori 1.

Some examples of important contributing causes:

• “The safety culture at Kori 1 NPP was unable to

counter neither the errors committed in the station

blackout event, nor the subsequent leadership

failures in communication and reporting. The Kori

1 NPP safety culture needs to support leadership

in decision making and develop stronger defenses

when facing unexpected or difficult situations,

• Human factor: the disregard of instruction associated

with overconfidence of contractor’s worker during

generator protection test,

• Kori 1 plant manager and other staff in the control

room decided not to report SBO. The plant manager

opted to hide this event due to heavy feelings of

a burden to preempt public critics and a fear of

worsening the plant’s credibility. In light of the

prevailing high respect for authority of supervisor

the staff involved were unwilling to disagree with

plant manager, although several elements of safety

77


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

policy and administrative procedures of the plant

were violated,

• Rescheduling outage work (generator protection

system test was started earlier than the original

schedule, maintenance of station auxiliary

transformer A was started although station auxiliary

transformer B was not returned to operation). The

approval and risk assessment for this unusual lineup

was inadequate in that the potential consequences

were not considered,

• Kori 1 NPP internal oversight failed to reveal the

station blackout event.”

The expert mission gave their recommendations to

address these contributory factors.

Proactive policy decisions

In the light of these serious shortcomings, I note that

the South Korean authorities have announced

that they have initiated far-reaching reforms and

taken vigorous action to reinforce the powers

and independence of the NSSC, the nuclear safety

authority. I have also noted numerous changes in

the operator’s management team, which need to be

accompanied by changes in their practices, as the IAEA

highlighted.

In conclusion, barely one year after the Fukushima

accident, I see from these events that the need for proper

safety culture and transparency is not yet universally

acknowledged. Nuclear safety in operations, which

alone can win confidence in the nuclear industry, will

always depend on two things: a responsible nuclear

operator and a strong nuclear safety authority.

78

NOTEWORTHY OPERATING EVENTS

I consider that a nuclear safety event of this nature

challenges the nuclear community, as concerns both the

collective responsibility of each operating organisation

with regard to its peers and the effectiveness of the

international watchdogs.

Incident sequence (1)


7:30pm on Feb 9 : Tesng of generator protecon relay started

8:34pm : During the relay test, due to the failure of reseng the test-nished relay,

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

resu in LOOP

8:34pm : EDG “B” failed to start on demand due to starng solenoid valve failure resu

in SBO, and subsequent loss of shutdown cooling and SFP cooling (RHR)

Incident sequence (2)


Kori 1: electrical power supply system diagram 1

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

circuit breaker exiting SBO condition in 12 minutes 4

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

to Bus “B” because RHR “A” was under maintenance in 19 minutes 5

Kori 1: electrical power supply system diagram 2


14/ APPENDICES

APPENDICES

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

79


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

80

APPENDICES

14.1 - RESULT INDICATORS FOR THE EDF SA NUCLEAR POWER PLANTS

Indicator 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Number of events classified on INES as

1 or greater, per reactor 1 1,20 0,88 0,76 1,22 0,80 1,15 1,17 1,17 0,91 1,55

Number of significant nuclear safety

events, per reactor 1 8,14 7,62 9,54 10,21 10,80 10,34 10,93 10,45 10,57 11,90

Number of cases of non-compliance

with the technical specifications for

operation, per reactor

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

Number of alignment errors, per

reactor 2 0,93 0,50 0,66 0,69 0,57 0,62 0,53 0,77 0,71 0,70

Number of scrams, per reactor and per

7,000 hours of criticality 3

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

• Manual 0 0 0 0 0 0 0 0,01 0,05 0,03

Average collective dose in operations,

per nuclear unit in service

(in man-sieverts)

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

Exposure of individuals:

• Number of individuals with doses

above 20 mSv 1 0 0 0 0 0 2 0 0 0

• Number of individuals with doses

between 16 and 20 mSv

74 73 28 17 20 14 10 3 2 0

Number of significant radiation

protection events

160 177 173 112 99 107 102 91 92 114

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

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

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

1 Excluding generic events, i.e. events due to design defects.

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

event.

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

reactor.

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


APPENDICES

14.2 - RESULT INDICATORS FOR THE EDF ENERGY NUCLEAR POWER PLANTS

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

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

1

Number of events ranked 1 or

more on INES, per reactor

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

2

3

4

5

6

7

8

9

10

11

12

Number of events ranked 0 or

more on INES, per reactor

Number of events of highest level

declared to the ONR, per reactor

Number or cases of noncompliance

with the technical

specifications for operation, per

reactor

Number of alignment errors, per

reactor

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

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

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

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

Number of unscheduled reactor

shutdowns, per reactor and for

7,000 hours of criticality

• Automatic 1,51 1,30 0,74 0,73 0,44 1,13 0,82 0,58 0,74 0,64

• Manual 1,39 2,18 1,28 2,54 1,48 1,04 1,44 1,68 1,22 0,84

Average collective dose in

operations, per nuclear unit in

service (in man-sieverts)

• PWR 0,351 0,032 0,352 0,524 0,045 0,264 0,337 0,271 0,537 0,037

• AGR 0,073 0,026 0,055 0,152 0,071 0,167 0,100 0,018 0,084 0,063

Exposure of individuals:

• Number of individuals with

doses above 20 mSv 0 0 0 0 0 0 0 0 0 0

• Number of individuals with

doses above 16 mSv 0 0 0 0 0 0 0 0 0 0

Number of significant radiation

protection events

Availability (%) :

EDF Energy plants

• PWR

• AGR

Forced Loss Rate (%)

EDF Energy plants

• PWR

• AGR

Accident Frequency Rate

(for 200,000 hours worked)

192 184 368 249 58 38 31 43 43 50

78,2

86,1

77,6

11,7

2,4

12,4

69,9

89,4

68,5

15,5

9,7

15,9

71,9

83,7

71,0

12,3

0,0

13,1

66,1

85,3

64,7

17,0

0,3

18,2

62,8

98,4

60,2

20,3

0,4

21,7

51,2

89,2

48,5

20,4

2,1

21,8

71,0

87,4

69,8

13,2

0,9

14,0

65,7

45,6

67,1

19,6

54,3

17,1

72,0

82,5

71,3

13,0

3,4

13,7

78,0

89,2

76,3

8,9

10,0

8,7

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

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

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

Factors to be taken into account in comparing the results of EDF SA with those of EDF Energy:

• Lines 3. 4, 5 and 9: the event declaration procedures are not the same in the United Kingdom

and France as a result of the respective nuclear safety authority requirements. EDF Energy

and EDF SA harmonised their event classification practices in 2012.

• Line 7: the reactors of the two sets of plants do not share the same technology (mostly AGRs

in the UK and PWRs in France). The AGR design means that radiation exposure is some ten

times lower (source: WANO).

81


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

82

APPENDICES

14.3 - RESULT INDICATORS FOR THE CONSTELLATION ENERGY NUCLEAR GROUP

NUCLEAR POWER PLANTS

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

1

2

3

4

5

6

7

8

9

Number of events ranked 1 or

more on INES, per reactor

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

Number of significant nuclear

safety events, per reactor 1 15 8 12 9 12 13 9 11 11 10,8

Number of NRC Notices of

Violation

1 1 3 1 1 1 4 2 1 1

Number of alignment errors,

per reactor 2 2,3 1,3 1,7 1 2 1 0,67 0,33 0,33 0,67

Number of unscheduled reactor

shutdowns, per reactor and for

7,000 hours of criticality

• Automatic 0,70 0,51 0,51 0,34 0,34 0 0,17 1,02 0,70 0,70

• Manual 0,17 0,17 0,17 0,17 0,17 0,17 0,17 0 0 0,17

Average collective dose in

operations, per nuclear unit in

service (in man-sieverts)

• PWR 1,14 0,49 0,81 0,80 0,46 0,61 0,46 0,44 0,68 0,68

• BWR 1,85 2,24 2,01 1,15 1,65 1,51 1,19 1,88 1,22 2,27

Exposure of individuals:

• Number of individuals with

doses above 20 mSv

• Number of individuals with

doses above 16 mSv

Number of significant radiation

protection events

0

8

5

12

0

6

0

2

1

3

- - - - - 8 12 8 4 4

Availability (%) :

• CENG 89,5 93,9 94,2 93,1 93,9 95,4 95,2 94,2 91,4 87,3

10 Forced Loss Rate (%)

• CENG 2,96 1,11 0,81 1,79 1,70 0,52 1,10 2,31 3,07 3,10

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

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

2 INPO Component Miss-positionning events (Consequential).

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

Factors to be taken into account in comparing the results of EDF SA with those of

Constellation Nuclear Energy Group:

• Lines 2, 3, 4 and 8: the event declaration procedures are not the same in the USA and France as a result of

the respective nuclear safety authority requirements.

• Line 6: the reactors of the two sets of plants do not share the same technology (three PWRs and two BWRs

for Constellation Nuclear Energy Group and all PWRs in France). The design of the BWR results in higher

exposure than in the PWR (source: WANO).

• Line 9: the four reactors at Calvert Cliffs and Nine Mile Point are refuelled every 24 months while that of

Ginna Nuclear Power plant is refuelled every 18 months.

0

4

0

0

0

4

0

1

0

9


APPENDICES

14.4 - MAP OF THE EDF SA NUCLEAR POWER PLANTS

Brennilis

Construction/Project

Operation

Cherbourg

Decommissioning

Flamanville

Chinon

St-Laurent

Civaux

Blayais

Tours

Bordeaux

Penly

Paluel

Golfech

Gravelines

Dampierre

Bourges

Amiens

Paris

Nogent

s/Seine

Belleville

Cruas

300 MWe 900 MWe 1300 MWe 1450 MWe 1600 MWe

Chooz

Lyon

Clermont-Ferrand

Nîmes

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Bugey

Cattenom

Fessenheim

St-Alban

Grenoble

Tricastin

Strasbourg

Creys-

Malville

Marseille

83


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

84

APPENDICES

14.5 - MAP OF THE EDF ENERGY NUCLEAR POWER PLANTS

Number of reactor per type AGR PWR EPR Engineering

Operational

Construction or Project

Engineering Centre

Edimbourg

Hunterston B

East Kilbride

Heysham 1

Heysham 2

Cardiff

Torness

14 1

Barnwood

Hinkley Point B

Hinkley Point C

Hartlepool

London

4

Sizewell B

Sizewell C

Dungeness B

AGR : Advanced Gas cooled Reactor

EPR : European Pressurized Reactor

2


APPENDICES

14.6 - MAP OF THE CONSTELLATION NUCLEAR ENERGY GROUP

NUCLEAR POWER PLANTS

Nomber of reactor

per type

Engineering

PWR

600 MWe

PWR

900 MWe

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

BWR

620 MWe

BWR

1 300 MWe

Operational 1 2 1 1

Head Office (CENG)

1

Nine Mile Point 1

Ginna

Washington DC

Atlanta

Nine Mile Point 2

Baltimore

Calvert Cliffs

New-York

BWR : Boiling Water Reactor

85


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

86

APPENDICES

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

Year commissioned

Nuclear

Unit

Power

in

MWe(*)

VD1 VD2 VD3

Year

commissioned

Nuclear

Unit

Power

in

MWe(*)

VD1 VD2 VD3

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

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

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

1978 Bugey 3 910 1991 2002 1984 Paluel 2 1330 1995 2005

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

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

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

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

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

1980 Gravelines 2 910 1991 2002 1986 Chinon B3 905 1999 2009

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

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

1980 Tricastin 2 915 1991 2000 2011 1986 St-Alban 2 135 1998 2008

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

1981 Blayais 1 910 1992 2002 2012 1987 Cattenom 2 1300 1998 2008

1981 Dampierre 3 890 1992 2003 1987 Chinon B4 905 2000 2010

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

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

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

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

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

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

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

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

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

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

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

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

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

VD1 : First ten-yearly outage

VD2 : Second ten-yearly outage

VD3 : Third ten-yearly outage

(*) Net continuous power


APPENDICES

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

Year

Commissioned

Nuclear Unit

Reactor

Number

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

Reference Unit

Power (MW)

(1)

Planned date of

withdrawal from

service

(2)

1976 Hinkley Point B R3 435 2023

1976 Hinkley Point B R4 435 2023

1976 Hunterston B R3 460 2023

1976 Hunterston B R4 430 2023

1983 Dungeness B R21 520 2018

1983 Dungeness B R22 520 2018

1983 Heysham 1 R1 585 2019

1983 Heysham 1 R2 575 2019

1983 Hartlepool R1 595 2019

1983 Hartlepool R2 585 2019

1988 Heysham 2 R7 610 2023

1988 Heysham 2 R8 610 2023

1988 Torness R1 595 2023

1988 Torness R2 595 2023

1995 Sizewell 1191 2035

(1) Reference Unit Power means the rated electrical power of the generating unit

as declared by EDF Energy in its daily transactions on December 2012.

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

15 January 2013.

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

GROUP NUCLEAR UNITS

Year

Commissioned

Nuclear Unit

Reference

Unit Power (1)

Planned date of withdrawal

from service (2)

1969 Nine Mile Point 1 621 2029

1970 R.E. Ginna 581 2029

1975 Calvert Cliffs 1 875 2034

1977 Calvert Cliffs 2 875 2036

1988 Nine Mile Point 2 1304 2046

(1) Net continuous power

(2) Date of withdrawal from service approved by NRC on January 2013

87


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

88

APPENDICES


14.10 - TABLE OF ABBREVIATIONS

A

AAR Automatic reactor shutdown

AGR Advanced Gas-cooled Reactor

ALARA As Low As Reasonably Achievable

AMELIE Project to transform spare part logistics

AMT Thermal Maintenance Agency

ANDRA French National Radioactive Waste

Management Agency

ASN French Nuclear Safety Authority

B

BMA Standardised activity model library

BWR Boiling water reactor

C

CAP Annual Performance Contract

CEFRI French committee for the certification

of companies in training and monitoring

radiation workers

CEIDRE Corporate Chemical & Metallurgical Centre

of Expertise

CENG Constellation Energy Nuclear Group (USA)

CGNPC China Guangdong Nuclear Power Company

(China)

CIDEN The Decommissioning, Waste Management

& Environmental Engineering Centre

CIEST Inter-Contractor Work Conditions and Safety

Committee

CIPN The Power Plants Operations Engineering

Centre

CLI Local Stakeholder Committee

CNEN Nuclear Design & Construction Centre

CNEPE Electromechanical & Plant Engineering

Support Centre

COMSAT Unit outage safety meeting for operational

state changes

COPAT Unit Outage Operational Control Centre

CSN Nuclear Safety Council

CSNC Design Nuclear Safety Committee (Nuclear

Engineering Division)

CSNE Operations Nuclear Safety Committee

(Nuclear Operations Division)

D

DAIP Industrial Support for Production Division

DCN Nuclear Fuel Division

DIN Nuclear Engineering Division

DNMC Daya-Bay Nuclear operation and

Management Company (China)

DPI Production and Engineering Directorate

DPN Nuclear Operations Division

APPENDICES

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

E

EGE Overall Excellence Evaluation

EGS Overall Nuclear Safety Assessment

ENISS European Nuclear Installations Safety

Standard

ENSREG European Nuclear Safety Regulators Group

EPR European Pressurised Reactor

EPRI Electric Power Research Institute (USA)

ESR Significant radiation protection event

ESS Significant nuclear safety event

EVEREST EDF campaign to allow entry into controlled

areas in street clothes

F

FARN Nuclear Rapid Reaction Force

FME Foreign Material Exclusion

G

GDA Generic Design Assessment (UK)

GPEC Advanced planning of manpower and skills

GPSN Nuclear Safety Performance Group

H

HCTISN High Committee for Transparency and the

Supply of Information Concerning Nuclear

Matters

IAEA International Atomic Energy Agency

ICRP International Commission for Radiological

Protection

I

IFOPSE Industrial Safety and Prevention Training

Institute

IN Nuclear Inspectorate (part of EDF Nuclear

Operations Division)

INB Licensed Nuclear Facility

INES International Nuclear Event Scale

INPO Institute of Nuclear Power Operators (USA)

INSAG International Safety Advisory Group (IAEA)

INTEP EDF Research and Development Division

initiative to introduce new technologies in

the plants in service

IOP Operations Engineering

ISOE Information System for Occupational

Exposure of OECD NEA

K

KEPCO Korea Electric Power Corporation (South

Korea)

KHNP Korea Hydro & Nuclear Power (South Korea)

89


THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

90

APPENDICES

M

MAE Assessment and Support Unit of the Nuclear

Engineering Division

MARN Nuclear Hazard Management Support Team

MME Operations and Maintenance Methods

MOPIA Project to set in place an attractive business

policy

MPL Front Line Manager

N

NDA Nuclear Decommissioning Authority (UK)

NEA OECD Nuclear Energy Agency

NEI Nuclear Energy Institute (USA)

NIO Nuclear Independent Oversight (SRD / EDF

Energy)

NNB Nuclear New Build (EDF Energy)

NNSA National Nuclear Safety Administration

(China)

NPP Nuclear Power Plant

NRC Nuclear Regulatory Commission (USA)

NSSC Nuclear Safety and Security Commission

(South Korea)

O

O2EI Better Housekeeping Campaign (a Nuclear

Operations Division initiative)

OIU User Internal Organisation

ONR Office of Nuclear Regulation (UK)

OSART Operational Safety Analysis Review Team

(IAEA)

P

PARTNER Ecologically-sensitive nuclear plant

administrative facility refurbishment

PBMP Basic Preventive Maintenance Programme

PGAC Worksite General Assistance Services

PHPM Methods and Practices Harmonisation

Project

PUI EDF Emergency Plan

PWR Pressurised water reactor

R

R&D Research and Development Division

RET Exceptional Work Permit

REX Experience feedback

RTE Power grid

RTGE General Technical Rules intended to avoid or

mitigate the off-site nuisances and hazards

associated with the operation of licensed

nuclear facilities

S

SDIN Nuclear Technical Information System

SDIS County Fire and Emergency Services

SEPTEN Basic Design Centre

SGDSN National Committee of Public Safety and

Defence

SIR Official Inspection Departments

SOFINEL Joint EDF and AREVA design office

SPR Risk Management Department

SRD Safety and Regulation Department (EDF

Energy)

STE Technical Specifications for Operation

SYGMA Computerised maintenance management

system

T

TEM Unit in service

TEPCO Tokyo Electric Power Company (Japan)

TNPCJVC Joint venture between the Chinese company

CGNPC (70%) and EDF (30%)

TSM Technical Support Mission by peers

organised by WANO

TSN French Nuclear Safety &Transparency Act

TVO Teollisuuden Voima Oy (Finland)

U

UFPI Operations & Engineering Training Unit

UNGG Gas-cooled graphite-moderated reactor

UNIE Operations Engineering Unit

UTO Central Technical Support Department

V

VD3 Third Ten-Yearly Outage

VP Mid-length outage

W

WANO World Association of Nuclear Operators

WENRA West European Nuclear Regulators

Association


APPENDICES

THE INSPECTOR GENERAL’S REPORT

ON NUCLEAR SAFETY AND RADIATION PROTECTION

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

PHOTO CREDITS

Cover : © EDF Médiathèque - Laurent VAUTRIN

Chapiter 01 : © EDF Médiathèque - Marc MORCEAU

Chapiter 02 : © EDF Médiathèque - Alexandre SARGOS

Chapiter 03 : © EDF Médiathèque - Philippe ERANIAN

Chapiter 04 : © EDF Médiathèque - Stéphane LAVOUE

Chapiter 05 : © EDF Médiathèque - Jean-Luc PETIT

Chapiter 06 : © EDF Médiathèque

Chapiter 07 : © EDF Médiathèque

Chapiter 08 : © EDF Médiathèque - Marc DIDIER

Chapiter 09 : © EDF Médiathèque - Philippe ERANIAN

Chapiter10 : © EDF Médiathèque - Alexis MORIN

Chapiter 11: © EDF Médiathèque - Olivier BLAISE

Chapiter 12 : © EDF Médiathèque

Chapiter 13 : © Ho New / Reuters

91


E.D.F.

Présidence IGSN

21, avenue de Messine

75008 Paris

: +33 (0)1 40 42 25 20

www.edf.fr

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