on Nuclear Safety and Radiation Protection - Energie EDF

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