LES ACTIVITÉS NUCLÉAIRES : RAYONNEMENTS IONISANTS ET RISQUES POUR LA SANTÉ ET L’ENVIRONNEMENT coordination between the different disciplines, particularly between maintenance, operation and project teams. These shortcomings generally take the form of a failure to respect the fundamentals of communication and information transfer. They are often attributable to complex and poorly managed organisations, resulting in a lack of understanding of the roles and responsibilities of those involved and the interfaces, as well as shortcomings in activity scheduling and problems in matching material and human resources to requirements. Management of subcontracted activities ASNR checks the conditions surrounding the preparation (schedule, required resources, etc.) and performance of the subcontracted activities (relations with the licensee, supervision by the licensee, etc.). It also checks that the workers involved have the means needed (tools, operating documentation, etc.) to perform their tasks, in particular when these means are made available by EDF. ASNR noted a positive dynamic within NPPs with regard to the improvement of contractor skills. EDF is implementing tangible measures, such as the increase in the provision of spaces for preparation work on a mock-up. Some sites have also opened up their e-learning areas to contractors. EDF’s supervision of subcontracted activities is improving overall. However, the difficulties encountered by certain outside contractors mean that EDF must continue to step up its actions. In particular, the supervision carried out by EDF sometimes still focuses too much on compliance with quality assurance and safety rules, to the detriment of the technical aspects. In particular, ASNR has noted that contractors sometimes operate without the skills they need to carry out their work properly and to understand the impact of their activity on the installation’s operation. Inappropriate monitoring and surveillance plans and shortcomings in the traceability of supervision actions are also noted, as well as the absence or only partial completion of supervision actions. These various findings call into question not only the process for selecting outside contractors, but also whether the licensee has put in place sufficient measures to check and monitor the level of competence of contractors through appropriate supervision. 2.5.3 – Regulation of the conformity of facilities with the applicable requirements Maintaining the conformity of the facilities with their design, construction and operating requirements is a major issue insofar as this conformity is essential for ensuring compliance with the safety case. The processes employed by the licensee, notably during reactor outages, contribute to maintaining the conformity of the facilities.. The identification and processing of deviations The checks initiated by EDF within the framework of its operating baseline requirements and the additional verifications requested by ASNR, on the basis more particularly of Operating Experience Feedback, can lead to the detection of deviations from the baseline operating requirements, which must then be processed. These deviations may have various causes: design problems, construction errors, insufficient expertise in maintenance work, deterioration through ageing, organisational shortcomings, etc. The steps taken to detect and correct deviations, specified in the Order of 7 February 2012, play an essential role in maintaining the level of safety of the facilities. “Real-time” checks Carrying out periodic test and preventive maintenance programmes on the equipment and systems contributes to identifying deviations. Routine visits in the field and technical inspection and verification of activities considered to be important for the protection of people and the environment are also effective means of detecting deviations. Verifications during reactor outages EDF takes advantage of nuclear reactor outages to carry out maintenance work and inspections which cannot be performed when the reactor is generating electricity (see Highlight No. 8). These operations more particularly correct already known deviations, but can also lead to the detection of new ones. Before each reactor restart, ASNR asks EDF to list any deviations not yet remedied, to take appropriate compensatory measures and to demonstrate the acceptability of these deviations with respect to the protection of people and the environment for the coming production cycle. Ten-yearly verifications: conformity checks EDF carries out periodic safety reviews of its nuclear reactors every ten years, in accordance with the regulations (see point 3.2). EDF then carries out an in-depth review of the actual state of the facilities by comparison with the applicable safety requirements, more particularly on the basis of the in-service monitoring hitherto carried out, and lists any deviations. These verifications are supplemented by a complementary investigation programme, the aim of which is to check parts of the facility for degradation modes which are not covered by the inspections involved in the preventive maintenance programme. The additional verifications in response to ASNR requests In addition to the steps taken by EDF with regard to its operating baseline requirements, additional checks are carried out at the request of ASNR, whether, for example, further to OEF about events which have occurred on other facilities, after inspections, or after examination of the provisions defined by the licensee within the context of the periodic safety reviews. ASNR requirements concerning repairs ASN published its Guide No. 21 in 2015 regarding the handling of conformity deviations. This Guide specifies ASNR’s requirements concerning the correction of non-conformities and presents the approach expected of the licensee in accordance with the proportionality principle. This is based more specifically on an assessment of the potential or actual consequences of any deviation identified and on the licensee’s ability to guarantee the safety of the reactor in the event of an accident, by taking appropriate compensatory measures. The Guide also recalls the principle of the correction of conformity deviations as soon as possible and in any case defines the maximum times allowed. 2.5.4 – Assessment of oversight of facilities compliance with the applicable requirements Condition of equipment and conformity In the past, ASN has found that the organisational measures taken by EDF to deal with deviations comprised shortcomings and that the time taken to characterise, check and process the deviations did not always comply with the requirements of the Order of 7 February 2012. In 2019, EDF therefore revised its internal baseline requirements for management of deviations, in order to improve how they are processed and provide ASN with reactive information proportionate to the safety implications. Since these new internal baseline requirements have been applied, ASNR finds that in most situations, EDF corrects the deviations within the required time. These efforts will need to be continued in the coming years, notably on the occasion of the ten yearly outages. ASNR is particularly vigilant about the results of the compliance management actions implemented by EDF during the review of each reactor and the lessons learned by EDF. 298 ASNR Report on the state of nuclear safety and radiation protection in France in 2025
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