on Nuclear Safety and Radiation Protection - Energie EDF

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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
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