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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
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E.D.F. Présidence IGSN 21, avenue
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