2017 edition Status of safety in nuclear facilities

Transcription

1 2017 edition Status of safety in nuclear facilities General Inspectorate Annual Report

2 Status of safety in nuclear facilities edition

3 2-3 Message from the CEO, Philippe Knoche The year 2017 marks the end of the restructuring phase for the AREVA Group. On January 23, New AREVA, which groups together the fuel cycle activities - from Mining through to Dismantling - became Orano. documentation, often considered too complicated and difficult to use by people on the ground, and as such a potential source of error. We must therefore propose further improvements. In this context of major transformation, vigilance in terms of nuclear safety and occupational health & safety remains paramount, exercised on a day to day basis on our sites and also at the central level by our teams and our managers. The year is characterized by a level of operational safety performance that is stable compared to previous years and confirms a genuine incorporation of safety issues into our day-to-day practices. This positive observation deserves to be highlighted in the context of the Group s transformation. Nevertheless, even if we have a solid foundation to build on, we must engage in a process of continuous improvement. Five areas for improvement have been identified, and they constitute our priorities. Firstly, within the general framework of Operational Excellence and the continuous improvement of our performance, we need to strengthen the deployment of operating standards such as the human performance tools and Manager in the Field. The use of such tools will thus be firmly rooted in our practices and will serve to underpin a shared safety culture. The same kind of standardization approach must be applied to operational In addition, the procedures for monitoring the compliance of facilities and monitoring their aging are essential elements in controlling our activities over the long term. These must become continuous processes. The efforts undertaken in recent years in these areas have been substantial in the framework of periodic reviews. It is by integrating these processes carried out up to now in project mode that we can guarantee our ability to anticipate and identify the critical points on our equipment. Detection and analysis of weak signals must also be even more systematic to improve the relevance and depth of operating feedback. This analysis must be conducted with robust methods to identify root causes, whether technical or organizational, and the sharing of this experience must be faster. The application of the technical regulations governing regulated nuclear facilities (INBs) remains an issue. The search for consistent appropriation of certain concepts by engineering and by the operators must guide our actions in this area. Finally, the transmission of nuclear safety requirements to our suppliers must be accompanied by systematic verification as to their proper appropriation and operational implementation: the production of all monitoring plans and their systematic exploitation must be a priority. These progress actions are going to be widely disseminated with our managers and teams. They will contribute to maintaining the impetus of our continuous improvement initiative, enabling Orano to develop an even more robust safety culture, rooted in the field and based on the everyday attention of each and every one of us. General Inspectorate Annual Report

4 Vision of the Inspector General Pascal Wilz From the review of the indicators set up, from the analysis of the reported events, the inspections carried out and the various observations, it emerges that the nuclear safety of the Orano Group s operations remains satisfactory. This annual report from the General Inspectorate deals with industrial risk prevention and with the status of nuclear safety and radiation protection, for the year 2017, within the scope of Orano s activities and facilities. It is based on findings made during implementation of the annual inspection program. It includes the results of analyses of significant events which occurred in the facilities. It draws on the observations and appraisals from the group s Safety, Security, Radiation Protection and Environmental specialists. It also draws on the regular discussions held with the nuclear safety authorities, their technical support - the IRSN* 1, as well as stakeholders and French government agencies. Principal nuclear safety results 2017 was the fifth consecutive year with no INES* level 2 event. The IPR* remained stable, close to 0.1. The level of personnel exposure remained low. The radiological impact on the environment was well below regulatory values. 1Operating experience is a real driver for continuous improvement in matters of nuclear safety. Of the 117 significant events reported in 2017, 12 of them were INES* level 1 and 105 level 0. The Incident Prevention Rate (IPR*) remained stable, close to the group s objective of 0.1. This is in line with the overall average for all events reported to the ASN* by nuclear operators (source ASN* 2016 report) Figure 1: Trend in Incident Prevention Rate As in previous years, the containment function was the main contributor to level 1 events. 1 Terms and acronyms marked with an asterisk are explained in the glossary. Status of safety in nuclear facilities edition

5 4-5 In addition, the breakdown of causes of events shows that over 75% of events had a human or organizational component. Beyond the figures per se, the events that occur in installations, whatever their level, are warning signals that must be taken into account. In this respect, regardless of their classification on the INES* scale and even in the absence of any impact on employees or the environment, events such as the double fire start in drums containing uranium chips, the significant presence of nuclear material in a waste drum or the fall of a test load are early warning events that demand close attention. Each of the events is subject to a detailed analysis taking into account the technical aspects and the human and organizational factors. These analyses highlight any shortcomings in the operational documentation and reflect heightened sensitivity with regard to setting up and using computer databases to support activities. At the organizational level, in some cases findings point to insufficient preparation of exceptional activities, issues with change management and monitoring of providers. Nuclear safety engineers, used fuel processing plant, LA HAGUE 2Dosimetry levels remained stable and low both for the Group s employees and those of our subcontractors. They are in line with the results of previous years. Annual average doses were 0.8 and 0.5 msv respectively, with maximum doses of 16.1 and 14.6 msv. 18 Orano employees and 1 external worker received a dose of more than 14 msv, which is the Group s internal alert threshold. No exposure in excess of 18 msv has been recorded since 2008 (for an annual regulatory limit of 20 msv in France). These results are satisfactory and reflect the efforts made by all of the management, the employees and the radiation protection teams to control this risk. With the transposition into French law of Directive 2013/59 Euratom of December 5, 2013, a major task for 2018 will be the drafting of texts to translate these requirements into operational provisions. With respect to Orano s activities, the integration of radon into the risk assessment and the lowering of the dose limit to the cristalline lens are important issues in terms of radiation protection. 3The radiological impacts on the environment from the group s nuclear sites remain at very low levels, of a few microsieverts per year (for an annual regulatory limit of 1,000 microsieverts for members of the public). The efforts devoted to the upkeep of laboratories, both in terms of accreditations and infrastructure, as illustrated by the commissioning of the ATLAS laboratory at the TRICASTIN site, underline the Group s commitment to making sure that its industrial operations have no environmental impacts. Environmental checks at McClean Lake (Canada) On the other hand, certain categories of event presented a diminishing frequency of occurrence, indicating that the action plans implemented by the sites are achieving results. This is true of the number of pricks to the fingers or hands suffered by operators working in glove boxes, which has reduced significantly. For 2018, in addition to the treatment of the deficiencies mentioned above, two progress areas have been identified in relation to the operating experience process. Firstly, the rate of reclassification of events must be carefully monitored. Operators must endeavor to better take account of the additional factors mechanism in the ranking of their events. Secondly, one outcome of increased presence in the field is a large number of findings (as with the Gemba deployed at the LA HAGUE site), which constitute a quite remarkable reservoir of data and information. We now need to be able to process this data to identify weak signals. 4Following the reorganization of the AREVA group, 2017 was a year of transition for the operation of the General Inspectorate. Inspection units were set up specific to each entity within the group (New AREVA and AREVA NP), which continued to share resources. These measures laid the groundwork for organizing inspectorates for Orano and Framatone after their creation. General Inspectorate Annual Report

6 Vision of the Inspector General Within Orano s scope, 26 thematic inspections and 13 follow-up inspections further to recommendations were conducted, in addition to 2 reactive inspections. Furthermore, 1 cross-cutting evaluation was conducted at more than 10 sites on the integration of operating feedback from the most severe occupational accidents. These inspections generated 92 recommendations and as many action plans by the inspected entities. 114 recommendations from previous years were also closed out under monitoring. The lessons learned from these inspections fall into three broad areas: operational discipline, regulatory compliance and the handling of deviations. More than half of the General Inspectorate s recommendations concern issues related to operational discipline. Operational discipline includes the capacity of production, maintenance, and support organizations to strictly and completely comply with all operating baselines. This particularly concerns the management of temporary instructions in abnormal or degraded situations or the traceability or even the performance of periodic checks. This insufficient discipline is also found in the preparation of interventions and in the ability to control subcontractors. of operations in terms of nuclear and occupational safety, the General Inspectorate has undertaken several actions. To take account of lessons learned from the Le Creusot event (Framatome plant), the scope of action of the General Inspectorate has been broadened to include the robustness of the processes which guarantee the quality of operations and of the products manufactured. In this regard, an initial inspection will be conducted in 2018 on the management of the regulatory compliance system applicable to containers. Furthermore, the General Inspectorate will endeavor to step up its level of presence on the sites and in the facilities. It is indeed true that the inspection process, which aims primarily to control the various processes pertaining to nuclear and occupational safety implemented on sites, is demanding in its preparation, to the detriment of the actual presence of inspectors in the field. The lessons from the WANO peer review will be integrated into the inspection process. Compliance, representing some 40% of recommendations issued, mainly concerns regulatory aspects and to a lesser extent equipment. Handling of deviations, representing 5% of all recommendations, covers their analysis and sharing of the resulting OPEX*. This breakdown is comparable to previous years. The backlog of recommendations remaining to be processed at the end of 2017 amounted to 158, certain dating back over four years. Despite a slight decrease compared to the previous year, this backlog remains significant in view of the objectives for strengthening nuclear and occupational safety. To remedy this situation, which is one of the improvement areas for 2018, several actions are necessary. The General Inspectorate needs to focus on formulating recommendations that are more operational, the wording of which must be precise, and the response must be made available within a limited time frame, of the order of six months. In addition, recommendations for sites inspected less frequently will be monitored more regularly. As for the operators, it is incumbent on them, without delay, to conduct the analysis of the root causes of the findings formulated by the General Inspectorate in order to identify and propose the most appropriate measures to address the deviations observed. To improve performance and be able to provide General Management with the most accurate view of the control Meeting of CEA, Framatome and Orano General Inspectorates In addition, close ties with the general inspectorates of other operators will also be fostered. The recent separation of Orano and Framatome, the proximity of certain fuel cycle activities and the fact that the of the two companies are in the same tower naturally lead us to maintain strong synergy between the two inspectorates. To optimize this cooperation, an agreement was signed in 2017 and renewed in 2018, setting out its goals and conditions. Similarly, with the other nuclear operators, even though the organizations and scope of action are specific to each company, it is very beneficial to share our inspection methods and concerns. Areas of concern 1Maintaining skills and know-how As the Group completes its restructuring, maintaining nuclear safety expertise remains a key issue for the Status of safety in nuclear facilities edition

7 6-7 years to come. This issue is exacerbated by a somewhat bleak context in terms of the attractiveness of nuclear energy and its disciplines. Operating a nuclear facility demands long and complex initial training and a progressive learning curve, and places significant responsibility on all those involved in the business of operation, from the operator to the facility manager. The voluntary departure plan ended in It resulted in a quantitative and qualitative loss of expertise with a number of the most senior employees leaving the Group. We need to work towards a new equilibrium with our current employees and new recruits. The experts renewal campaign conducted in 2017 provided necessary impetus to consolidate this area. Objectively however, while we now have fewer skilled people, the number of issues to be addressed remains the same. The Group will therefore have to organize so as be equally present in the areas of concern. In the nuclear safety professions, networking will need to be strengthened so that we can pinpoint specific expertise and be able to call upon it as needed, particularly in response to the demands of the safety authorities, which remain very substantial. Here, Safety Excellence, Safety Focus and the Skills project, a progress report of which is presented in this report, are essential steps for maintaining skills. 2Application of regulatory requirements The resolutions concerning emergencies, modifications and waste conditioning, the codification of the order on procedures, and the transposition into French law of Directive 2013/59 Euratom, are all important texts that have been published recently or are about to be published. The capacity of the experts to assimilate these texts, to transpose them, where necessary, and to implement them, is a matter of great consequence for the future, and it demands strong mobilization on their part. Stabilization of the standards and requirements baseline is desirable to make sure the operational teams can appropriate the new provisions being deployed. This is a real challenge for the Group and attention needs to be paid in view of the interaction between regulatory changes and safety reassessment processes. may lead to insufficient controls or even deviations in the application of the provisions specified. Involvement of the operators in the direct elaboration of documentation is one of the means of producing effective operational documents. This was the approach adopted for the preparation of the COMURHEX 2 documentation, based on documentary practices in the old facility and the experience of its operators, and on OPEX from the Georges Besse II plant documentation. While this process is applicable for new facilities, the issue must continue to be addressed for the oldest installations and is an action priority for the coming years. Highlights Among the highlights of 2017 in the field of nuclear safety, the following three are particularly noteworthy: the enactment of the 3 Nuclear Safety-Environment, Health- Safety-Radiation Protection and Quality policies, the WANO* peer review of the Executive Management, and the 2017 ECRIN national internal crisis exercise. 1Enactment of policies 2017 saw the enactment of 3 essential and complementary policies for the control of nuclear safety and radiation protection: Based on the implementation of the policy, the Nuclear Safety and Environment Policy ( ) sets out twelve priorities for action relating to the safety of facilities, the safety of operations and management performance, The Health, Occupational Safety and Radiation Protection Policy ( ), focusing on three areas: the development of primary prevention, the control of operations and operating experience, The Quality Policy, essential in the management of nuclear safety, through which the Group undertakes to sustainably anchor a strong quality culture, improve the satisfaction of the customer and other interested parties and thus strengthen trust, and give impetus to continuous improvement on a day to day basis. 3Quality of the operational documentation The General Inspectorate s report makes repeated reference to the quality of the operational documentation, which is one of the causes of safetyrelated events. It may be considered incomplete, not upto-date, too detailed or insufficiently so, failing to take the operators needs into account, and so on. The lack of precision in these respects strongly impacts the degree of human reliability associated with operations. This Group Quality Policy document General Inspectorate Annual Report

8 Vision of the Inspector General 2WANO peer review In line with the 2014 and 2016 peer reviews of the LA HAGUE site, this review aimed to assess the performance of the organization and processes in place between executive management, general services and the site, in terms of their contribution to the nuclear safety and control of activities. The initial engagement with and preparation of this review began in early At the initiative of executive management, a self-assessment was conducted using the WANO guidelines. This preliminary review brought out strengths and also some deficiencies and enabled us to initiate work to address them. The review itself took place in November Its conclusions led to the identification of 5 areas for progress. Executive Management has launched the implementation of an action plan to respond to the observations made and improve practices deemed insufficient. 3The 2017 ECRIN exercise The large-scale 2017 ECRIN crisis management training exercise was conducted at MELOX on October 11 and 12. Some 350 crisis team members (including 100 FINA* volunteers) and 50 facilitators and observers were mobilized for 20 hours continuously to test out the mobilization over time. Its objectives were in line with the learnings derived from SECNUC 2016 and the 2014 and 2015 ECRIN exercises. A beyond design basis scenario was prepared to trial the Group s entire crisis organization and doctrines, as well as national plans (national plan for response to a nuclear or radiological accident and post-accidental doctrine (CODIRPA). In addition, governmental, social and media pressure was subject to the most representative simulation possible. At the end of the exercise, interviews were conducted to identify learnings and get an overview of the OPEX feedback from the different actors involved, whether they be participants, facilitators or observers. An action plan based on the lessons learned and submitted to Executive Management was approved at the end of Exercise at LA HAGUE s PCD-L Status of safety in nuclear facilities edition

9 8-9 Contents Highlights 31 Dismantling operations 13 Lessons learned from the inspections 35 External transportation activities 17 Operating feedback from events involving safety and radiation protection 42 Safety management 24 Radiation protection 57 Management of degraded situations 28 Environmental monitoring 61 Glossary General Inspectorate Annual Report

10 NCPF construction site, LA HAGUE 2017 Highlights For the different entities of the group, 2017 was marked by the continued implementation of strategic decisions made at the highest level of the French State in 2015 and aimed at reorganization of the French nuclear industry. Status of safety in nuclear facilities edition

11 10-11 To this effect, on July 26, 2017, increases in capital led to the formal separation of New AREVA (which became Orano in early 2018) and AREVA SA. The measures in the voluntary departure plans were implemented. Along with these major changes, certain entities within the group (Projects, Logistics, and Dismantling & Services Business Units) underwent internal reorganizations. TRICASTIN site - EM3 facility In this context, the activities linked to daily facility operation and the investment programs were pursued, in line with the objectives defined for the year. TRICASTIN site In 2017, changes in the site s organization were examined with the goal of setting up the platform, mainly by creating a Technical Department in charge of the maintenance of all site facilities, by setting up a Production Department to coordinate the production operations, and by creating closer ties between the Safety and Radiation Protection Departments to create a worker protection cluster. The authorization to make these changes was obtained at the beginning of The EM3 deconversion facility, the construction of which was initiated in 2015, entered the functional testing phase in It is part of a program for renewing and modernizing the deconversion plant (W) at TRICASTIN. The EM3 facility will replace the existing emissions facility built in the 1980s which will reach its operating limit in June This facility is used for the first step of deconversion, which entails liquefying cylinders of depleted uranium then injecting the UF 6 in gaseous form into furnaces that will produce HF and U 3 O 8. The EM3 facility complies with the latest safety standards. On December 31, 2017, the historical conversion plant, COMURHEX I, definitively ceased its industrial production after 55 years of operation. In 2018, it will be replaced by a new plant, COMURHEX II, which is currently in the phase of testing and qualifying its equipment. All COMURHEX I personnel will continue this testing in 2018 and undergo an ambitious training program. The end of production, planned and prepared for several months, involved many safety and security operations conducted by the operating teams. These operations involved draining equipment containing uranium-bearing material, in compliance with commitments made to the French Nuclear Safety Authority. The shutdown operations started on December 7, with draining of the first equipment systems. They were completed on December 20, with draining of the last equipment systems and the last filling of a cylinder. The plant is currently in a state of industrial shutdown and safe configuration. The clean-up operations prior to dismantling will take place from January 2018 to September LA HAGUE site The process of periodic requalification of R2 and T2 evaporators, which was initiated in 2016, continued for some of them into All the evaporators were authorized to restart following maintenance shutdowns in autumn The requalification of NCP1 evaporators is planned for summer 2018 following submission of monitoring systems amendment files to the relevant authorities and an operating pressure modification file. The construction worksite for new facilities for fission product concentration (NCPF) is making progress. The construction authorization was granted in November 2017 and the first concrete was poured in December. On October 6, Pit 40 of the EEVLH building (LA HAGUE Glass Storage Extension of INB no. 116) was made available to the LA HAGUE Large Projects Department (DGP). The construction of this pit, initiated in 2015, made it possible to extend the storage capacity for containers of vitrified fission products. Its commissioning is planned for The fuel elements of the research reactor OSIRIS were processed on line 8 of the T1 B facility. This operation is the result of several years of research and development. OSIRIS fuel was used to supply the research reactor by the same name that the CEA* has used at its SACLAY site for around twenty years. Its main feature is a silicon content up to 10 times higher than other fuels processed at LA HAGUE. The presence of silicon disturbs the solvent extraction process used for other fuels. At the end of 2016, the HAO project reached a significant milestone with the end of the main civil engineering work on the storage compartment. The work had begun at the end of General Inspectorate Annual Report

12 2017 Highlights The storage compartment represents around 1,000 metric tons supported by 2 beams which are positioned on the concrete walls of the silo. It will include core process equipment necessary for the collection and conditioning of waste currently stored in the HAO silo. The hulls & end caps and the fines & resins will be collected by a gripper/rake mechanism and conditioned in drums for compacting in the ACC facility or for cementing before transfer to the ANDRA deep repository. In 2017, the main focus was on assembly of mechanical equipment in the storage compartment and improvements in the HAO silo hall with the aim of starting tests in Dismantling of the HAO south facility belonging to the UP2-400 plant, LA HAGUE Decisions on projects after Supplementary Safety Assessments (SSA) The improvements decided following the accident at the Fukushima Daïchi nuclear power plant are also ongoing at all sites. Remediation initiatives are in place. The National Intervention Force (FINA*), already operational, is progressively adding to its capacities to be able to carry out all the missions that have been planned. The work of the various crisis emergency command centers (PC) on the ground are ongoing. At TRICASTIN, the facilities are completed and have been commissioned. At LA HAGUE, the Storage Block, for hard core equipment, was delivered in early January 2017, not long before work started on the Command Block (BC), the new emergency command center, the delivery of which is planned for the beginning of On the MELOX site, the construction of a new building and the necessary adjustments began at the start of 2017 with the aim of commissioning in With a footprint of 19 m x 13 m and a total surface area of 456 m2, this building will be designed to house 30 people without external supplies for a period of 48h during crisis management. EQUEURDREVILLE- HAINNEVILLE site The inauguration in October of a 1100-m² platform on this site was a significant element for maintaining skills. This training center for nuclear disciplines, which includes 6 training worksites, reproduces various work environments (fuel cycle plant, nuclear power plant, and nuclear submarine). Zone to accommodate the future PCD-L at MELOX Status of safety in nuclear facilities edition

13 12-13 An inspector at the MALVÉSI site Lessons learned from the inspections In 2017, the General Inspectorate conducted 26 thematic inspections and 13 follow-up inspections in eleven different entities. In addition, 3 reactive inspections were conducted in response to a specific situation. General Inspectorate Annual Report

14 Lessons learned from the inspections 2017 inspections Following the reorganization of the AREVA group, 2017 was a year of transition for the operation of the General Inspectorate. Inspection units were set up specific to each entity within the group (New AREVA and AREVA NP), which continued to share resources. These measures laid the groundwork for organizing inspections for Orano and Framatone after their creation. Aligned with previous years, the inspection programs were structured around four main objectives: maintaining a high level of safety and security control as the organizations transformed, or ensuring that existing organizations maintain their capacity to respond to unplanned situations, maintaining the control of safety functions (fire, radiation protection, containment of nuclear materials, criticality, removal of residual power), managing daily aspects of safety and security through the rigorous application of operating processes and procedures, and complying with the requirements of safety authorities for monitoring and supervision of activities. With regard to Orano results, 26 thematic inspections and 13 follow-up inspections further to recommendations were conducted, in addition to 2 reactive inspections. Furthermore, an evaluation was conducted on the integration within the group of operating feedback from the most severe occupational accidents. Finally, an inspector contributed to a peer review within the context of WANO. These inspections generated 92 recommendations and as many action plans by the inspected entities. 114 recommendations were also closed out under monitoring. Finally, 5 requests for immediate action, concerning deviations with a possible impact on nuclear safety or work safety, were formulated and processed rapidly. Lessons learned REACTIVE INSPECTIONS Reactive inspections offer many lessons learned because they add to and enrich the analyses to identify causes, which are performed by the local teams impacted by the event. In addition, reactive inspections make it possible to the evaluate the efficiency of organizations in handling significant events. Two reactive inspections were performed in The first involved a failure to wear an operational dosimeter during a significant period. The second inspection focused on the response to an event in which there was a deviation in radioactive material management. Beyond the specific causes linked to the impacted activities, the common modes identified in the analysis of the causes of the events were: insufficient operational discipline, leading to non-compliance with the rules, lack of knowledge on the part of operators and subcontractors regarding the risks associated with their activities, and monitoring of these activities. These observations align with cross-cutting lessons learned from the thematic inspections, which will be discussed in the following paragraphs. ORGANIZATIONAL CHANGES AND MANAGEMENT OF SPECIFIC SITUATIONS In 2016, the LA HAGUE site was reorganized into operational units. The inspections conducted on this subject showed that this new organization was implemented in an appropriate way and that it complied with regulatory requirements. It also allowed the people in charge of monitoring to maintain their independence. However, the monitoring of subcontractors must be improved. The inspection of external transportation at LA HAGUE concluded that operational control was satisfactory. On the ground, the operators demonstrated behaviors in compliance with expectations. The interfaces between the different entities working in the facilities operated correctly. However, the interfaces between the site and the Logistics Business Unit must be improved. Inspections at the MALVÉSI site showed that the development of a safety culture is underway. Even though for all players, safety and security are important, it is not yet given priority in a systematic way on the ground. Actions taken must be consistent so that mentalities can change over time. The transition period, following structural changes at the site, represents an opportunity to enhance personnel training, finalize or update operational documentation, and deploy safety culture action plans. For the MARCOULE site, the organization, measures, and practices provide a satisfactory level of safety control, especially compliance with the baseline for the waste management service carried out for the CEA. Remarks were made concerning continuous improvement of operational waste management by operators and subcontractors involved in this domain. The organization of crisis management integrated the operating feedback from the Fukushima accident. For this purpose, the TRICASTIN site set up an organization for sharing resources between the four nuclear operators on the site. Reaching the goal of having a fully operational FINA* entails finalizing studies to characterize needs for defining the number of participants and accelerating the deployment capacities of support bases. Status of safety in nuclear facilities edition

15 14-15 MAJOR RISKS ASSOCIATED WITH SAFETY FUNCTIONS Radiation protection inspection on a glovebox glove, MELOX CONTAINMENT OF RADIOACTIVE MATERIALS An inspection of the containment in facilities using significant quantities of nuclear materials was conducted on the LA HAGUE site. It confirmed the quality of designstage technical orientations that have been maintained during construction, maintenance, and throughout operation. These constructive arrangements have been enhanced by the commitment of personnel and the quality of the organization. Its structuring, in terms of control and radiological monitoring, seems in proportion to the issues. However, it is necessary to continue using elements important for protection (EIP*) in the integrated management system to obtain the information necessary for controlling the defined requirements. RADIATION PROTECTION OF PERSONNEL Four inspections examining personnel radiation protection were conducted in France at MELOX, Triade, Bessines and in Niger, at Cominak. Radiation protection organizations and programs enable efficiently responding to regulatory requirements and to the need to optimize exposure levels and develop a radiation protection culture. The personnel in charge of radiation protection are experienced. Radiological objectives are being met. Particular care must nonetheless be taken with services performed by subcontractors, whether they concern construction inside the facilities or radiation protection control operations. In addition to practices and approaches for controlling dosimetry, certain improvements can still be made in the application of the ALARA* approach. At MELOX, the systematic analysis of work stations made it possible to contain the elevation of the collective dose, correlated with the planned increase of industrial production. This approach will enable new dosimetric gains. There has been an associated improvement in the efficacy of personal protective equipment due to the performance of new materials. On the Cominak mining site, discipline-specific good practices training was an integral part of the program to improve dosimetry for current underground mining work. This program brings together the efforts on all identified elements impacting ventilation and dust control. Particular attention must be paid to dose calculation with an increased radon coefficient. CRITICALITY Inspection of criticality risk control at MELOX showed that the level of control was satisfactory. The associated processes have been rigorously integrated. The expertise is solid and sustainable. The personnel is aware of the relevant safety issues. However, training rules must be more clearly identified regarding the criticality risk for subcontractors working in criticality risk areas. DAILY MANAGEMENT OF SAFETY/ SECURITY AND OPERATIONAL DISCIPLINE Operational discipline is one of the recurrent inspection themes in the assessment of the level of the safety or security culture. Operational discipline includes the capacity of production, maintenance, and support organizations to strictly and completely comply with all operating baselines. It is clearly present in the identification of inappropriate actions or decisions for analyzing the causes of events, in the observation of behaviors, and in the analysis of the quality of event recording. In 2017, operational discipline was the subject of a specific inspection at the TRICASTIN site and served as an investigation guideline for other thematic inspections. The result of these inspections shows that, while situations are satisfactory on the whole, there is room for improvement in certain activities. This deficiency is generally caused by a poor understanding or application of the initial demand, or by a slow quality drift in the implementation of operational measures in documentation involving complex recording. It must be reviewed and simplified to focus on the real issues. More discipline is necessary in the completion of forms. This deficiency is generally coupled with unsuitable analysis of the results from recording. There is also a constant lack of regular review in these situations, which become sensitive situations when the observation of drift does not lead to awareness/action on the part of the various players. Furthermore, reactive inspections show that the research and cause analysis tools are not always used with all of the necessary discipline. Another finding is that it is often difficult for the operators to address organizational aspects, which means that they are under-represented in the list of causes and as a result, in the corrective or preventive action plans. General Inspectorate Annual Report

16 Lessons learned from the inspections The inspection at LA HAGUE on handling shows that the site integrated the lessons learned from events and the conclusions of the WANO peer review, which enabled making the organization of handling and lifting operations and the management of equipment more robust. In addition to the site action plan, the General Inspectorate recommended improving the implementation of reliability practices, rigorous document management and display of the maximum utilization loads, and finally the application of requirements incumbent on the subcontractor in charge of the maintenance of handling and lifting equipment. The inspection on Niger mining sites highlighted the positive effects of training to promote a safety culture. In particular, this training focuses on unsuitable behaviors, noncompliance with standards, and a lack of vigilance. However, at COMINAK, the compliance of lifting equipment and machines and the practical management of work permits must be improved. On the SOMAÏR site, the phases of filling uranate drums, in 20-foot ISO containers, and of securing are satisfactory. The prevention measures for transportation risks and bulk sulfur unloading risks must be improved. At BESSINES, the practices are satisfactory. The main remarks concern improving the monitoring of regulatory controls and the management of co-activities. The rules at TRICASTIN for internal transportation comply with regulatory requirements. The different areas and activities on the site are divided between three transportation safety advisors. Their missions have been defined in accordance with the regulations on hazardous materials transportation, the application of which has been extended to internal transportation. The management of nuclear materials transportation is centralized within a given unit. The choice and monitoring of subcontractors for internal transportation of hazardous materials must comply with internal directives. The rules concerning the use of handling equipment must be strictly adhered to. An inspection on the premises of an external customer showed that the customer s standards and that of the nuclear operator are observed by the group s teams, which are active, trained, and well integrated within the customer s structures. The improvements identified concern the development of operational documentation and the monitoring of subcontractors. An inspection of the dismantling of the bitumen pits in the UP1 plant at MARCOULE showed that the incorporation and integration of the requirements of the regulatory baseline are satisfactory. However, description of project organization and monitoring of subcontractors must be improved. SPECIFIC SUPERVISION AND SURVEILLANCE Inspectorate. They concern: the functioning of internal authorization systems at the LA HAGUE, MELOX, and TRICASTIN sites, which made it possible to use several years of operating feedback on the implementation of this process and to propose measures for future implementation of the Modifications decision, progress on retrieval and packaging projects for legacy waste from the LA HAGUE site. The results of these inspections were audited by safety authorities. They provided proof of compliance with the commitments made by the group in these areas, with a structure independent of the operational organizations in charge of implementing the various projects. Recommendations The breakdown of the General Inspectorate s recommendations indicates that more than half of them concern operational discipline. % Compliance Figure 2: Distribution of recommendations according to major areas A more detailed breakdown is as follows: Compliance/ Regulatory standards Compliance/Directives Compliance/Equipment Handling of deviations Sharing Feedback from Experience Analysis of deviations Operating processes Internal checks Operating documentation Skills Contractors Handling of deviations Operational discipline Figure 3: Distribution of recommendations according to area To comply with the requirements in ASN* decisions, two yearly inspections are performed by the General Status of safety in nuclear facilities edition

17 16-17 Radiation protection department, inspection operation, TRICASTIN Operating feedback from events involving safety and radiation protection Twelve level-1 events and 105 level-0 events were subject to a declaration and classification based on the INES scale. This led to an incident prevention rate of 0.1, comparable to the rate for the last two years. General Inspectorate Annual Report

18 Operating feedback from events involving safety and radiation protection Results No event of level 2 or higher on the INES* scale involving the entities of the group, regardless of responsibilities (operators, industrial operators, or service providers), took place in significant events were declared on the INES* scale. None of these events had significant consequences for the personnel, the public, or the environment. These events break down as follows: 12 level-1 events on the INES* scale. These were anomalies with no impact on safety, occurring in situations non-compliant with requirements. The most significant of them concern limited dispersions of material due to 2 fires in drums containing chips of material, perforation of a water box in a calciner (see box), leaktightness defects in storage drums, and failure of a scrubber. The number of these events varies little from one year to another (15 in 2015 and 14 in 2016). 105 events of level-0 on this same scale. These entailed deviations not impacting safety that are referred to as weak signals. They must be taken into account in the continuous progress approach in terms of risk prevention. The changes in the number of events in the last six years has remained more or less constant, as shown in the following figure. 50% (versus 44% in 2016 and 33% in 2015). This analysis, which should be taken relative to the low number of events, shows that the majority of these reclassifications is based on an additional factor involving a shortcoming in safety culture. The rate of prevention of these events, or IPR*, was 0.11 at the end of the year. This result is close to the objective of 0.1. It is consistent with the overall result for nuclear operators for 2016.² Their breakdown by domain is as follows: 66% Figure 5: Breakdown by domain of significant events impacting nuclear safety Of the total 117 events declared in 2017, 78 were for nuclear safety (66%), 16 for radiation protection (14%), 14 for transportation (13%), and 8 for the environment (7%). Safety of facilities 7% 14% 13% Nuclear safety Radiation protection Transportation Environment A close-up of events declared for safety reasons according to safety functions results in the following breakdown: % 23% 4% Containment Criticality Cooling Support functions % INES Level 1 INES Level 0 Figure 4: Changes in the number of significant events impacting nuclear safety The proportion of events subject to a reclassification or a declaration at the request of ASN* has tended to increase, with a rate greater than 9%, versus a rate of 6% in 2016 and a rate of 7% in This increase mainly concerns reclassification of level-1 events of which the rate is around Figure 6: Breakdown of significant events according to safety function CONTAINMENT FUNCTION Among the 30 events related to containment control for radioactive and hazardous materials, 17 concerned a loss of leaktightness in a containment barrier for radiological or hazardous materials without impacting the environment. In the majority of these cases, the containment losses involved human action (operation, intervention, maintenance), for which better risk analysis 2 Source: ASN* report on safety and radiation protection status in France for Status of safety in nuclear facilities edition

19 18-19 integrating the entire human and organizational factor (HOF*) dimension would have made it possible to prevent the event. CRITICALITY FUNCTION Five of the 9 events involving control of reactivity of fissile materials concerned management of the risk of criticality based on mass in waste, mainly contained in drums. These events are in part related to inadequate management of legacy waste due to a failure in the control of their history. They illustrate the necessity to guarantee the traceability of recordings for operating actions, to control waste solutions and materials inventories in the long term. The other events involved radiological cleanliness, noncompliance with dosimeter rules, and non-compliance with radiation protection rules. These are also events involving human action. Transportation safety The transportation events were mainly related to equipment deviations following maintenance, to shipment operations, or to a lack of radiological cleanliness detected at low levels on one of the group s sites upon arrival of contaminated rail cars having transported used fuel. Event analysis All of these events were addressed in a detailed report prepared by the operator to find all causes and to set up appropriate and sustainable improvement actions to efficiently prevent recurrence. The analysis of these detailed reports reveals that the human factor played significant role in the causes. The breakdown of causes shows that nearly 80% of them have a human or organizational component: Used fuel interim storage pool, LA HAGUE SUPPORT FUNCTIONS Six events involved power supply equipment. Two of them led to a total loss of power supply in all or part of the facility. These situations show the importance of planning and conducting exercises with loss of normal electric power supply in the facilities, after placing in safe configuration, in order to test in real conditions the efficiency of the emergency electrical supply. The unavailability of certain emergency equipment systems should be highlighted. This concerns the case of electric generators for which the return-to-service times following unavailability are greater than those required by the facility baselines, and the case of unavailability of startup circuit batteries. A technological common mode was not detected between these different systems. Radiation protection Among the 16 events impacting radiation protection, 2 involved injuries in contaminating areas, but no contamination was found for either. Their analysis demonstrates the need to conduct a risk analysis prior to maintenance operations, in order to detect possible errors by operators. Figure 7: Breakdown of significant events according to the technical, human, and organizational causes FOCUS ON THE HUMAN AND ORGANIZATIONAL COMPONENT Technical Human Organizational Technical Human and organizational The analysis of events with a human and organizational component allows identifying several types of human errors (see figure 8): decision-making errors, found in 62% of events, are in most cases related to problems in the representation of the facility s status, failure to take the right action. The most frequent errors in human activities (normally nearly 80% of errors) were only present in 23% of events. This shows that the technical and organizational systems can tolerate this kind of error (prevention, detection, limiting consequences, etc.), finally, intentional human errors remain exceptional (5% of events for the year). General Inspectorate Annual Report

20 Operating feedback from events involving safety and radiation protection % of events concerned 80% Dismantling operation, LA HAGUE 70% 60% 50% 40% 30% 20% 10% 0% Execution errors Decision errors Deliberate deficiencies Figure 8: Breakdown of human errors In-depth analyses make it possible to identify causal factors for work situations, processes, and general organization. WORK SITUATIONS In terms of work situations, the preponderant factor remains the inadequacies of the operational documentation, with a lack of documentation at the work station, incomplete documentation (step not described, missing requirement), or documentation not up to date (see figure 9). An emerging factor concerns settings and the use electronic databases to support activities (such as CMMS), especially for planning periodic checks and tests (CEP). In addition, several events show that the interfaces between these electronic tools and operators can be a source of error (for example, information not visible, lack of alert feedback, or unclear acronyms). 40% 35% 30% organizational modifications are not always appropriately expressed in the documentation or in the requirements addressed to service providers. This last point explains the significant occurrence of definition of roles and responsibilities and coordination between departments/ subcontractors factors. Concerning the management of service providers, two areas should be taken into consideration: organizational measures that support service providers and monitoring measures (organizational and monitoring tools). 50% 40% 30% 25% 20% 20% 10% 15% 0% 10% Definition of roles and responsibilities 5% Coordination between departments Preparation of operations 0% Tools/equipment Applications Documentation Layout Design of/changes to process Management of contractors Figure 9: Breakdown of causal factors for work situations Figure 10: Breakdown of causal factors for general organization PROCESSES AND ORGANIZATION In terms of organization, the preponderant factor is the preparation of activities with incomplete risk analyses, especially in unusual or degraded situations (see figure10). To a lesser extent, the management of changes is involved in more than 35% of events. Technical changes or Second-level analysis At the central level of the group, the declarations and detailed reports undergo a second-level analysis. This mainly involves gathering lessons learned to share among the sites. Status of safety in nuclear facilities edition

21 20-21 This analysis takes place within a committee for analysis and sharing of lessons learned (CAP-Rex), which studies each declaration and detailed report and decides what to do with the lessons learned. This may involve: the Executive Committee providing information on the event and the action plan to avoid recurrence, information provided to the General Inspectorate to help it conduct its inspection, information provided to the sites in the form of a monthly summary that lists all declarations made during the month and indicates cross-cutting lessons learned, an Are you safe? lessons learned card to be shared with the on-site operational teams during a visual management meeting, sharing lessons learned with the operating feedback correspondents for the various sites. CAP-Rex is responsible for identifying and sharing operational feedback to improve the efficacy and sustainability of the lessons learned. In this context, exchange with other nuclear operators, industry players, or the Radiation Protection and Nuclear Safety Institute (IRSN*) is organized outlook These observations have led to identifying the following approaches: continue with the improvement of operational documentation. For operators, this entails developing comprehensible operational documentation. This approach will be applied in two pilot facilities in 2018, improve the support and monitoring of service providers. Several drivers will be considered: making requirements, content, and comprehensive documentation available to them, offering training materials for the use of tools, and monitoring tools together with robust exchange of information, improve the preparation of activities, particularly in unusual or degraded situations. Risk analyses must be completed and updated if the standard conditions for the activity have not been established, improve modification management. Whether for technical or organization changes, it is important to integrate them in the requirements addressed to the various players and in the operational documentation. General Inspectorate Annual Report

22 Operating feedback from events involving safety and radiation protection Increase in irradiation following cooling water flow in a calciner* THE FACTS During shutdown of the vitrification line in the R7 facility (UP2-800 plant at LA HAGUE), an alarm made it possible for the shift supervisor to diagnose an abnormal water flow inside a calciner*. He took steps to place the facility in a safe configuration. This incident caused contamination in a room situated below the calciner. This event did not impact the personnel or the environment, since the radioactive materials remained confined inside the first containment barrier of the facility. It was classified as level 1 on the INES* scale. The consequences for the facility were unavailability of the vitrification line and contamination of the inside of the containment. TECHNICAL CAUSE The premature wear on one of the wheels for calciner rotation was the cause of this event. ANALYSIS OF HUMAN AND ORGANIZATIONAL FACTORS The operation assistance system for the facility indicated that in case of blockage in the rotation wheel of the calciner tube, the shutdown procedure should be implemented, but it did not indicate a time frame. The analysis of a previous event in another facility concluded that a limit time estimated at 5 days should be defined in the operating baseline. Because of recent information actions on this subject, the operator was aware of this limit, which was being integrated in the operating instructions for this facility. This operating limit should have enabled finishing the production campaign and carrying out shutdown tasks for the line. However, three factors contributed to this event: because of the problems encountered, glass production lasted 7 days rather than around 10 hours, the time necessary in the absence of contingencies. the desire to limit the quantity of residual radioactive material in the melting pot polarized the operator, preventing examination of the endof-life management conditions for the melting pot that had been established initially. The operator thus did not define a hold point to allow for an alternative scenario to end the campaign or for measures to compensate for the impact of wheel blockage, finally, the operator assumed that the limitation from the statistical calculation had a significant margin that would allow for enough time to end the operating campaign, then to shut down the line before maintenance. LESSONS LEARNED The following actions were taken to avoid recurrence of this sort of event: modification of the general operating instructions to indicate the shutdown conditions for the calciner, expert assessment of the wheel to determine the cause of the blockage, addition of upper and lower wheels and associated rotation detection systems to the list of required availability equipment and definition of actions to be taken in case of unavailability. Status of safety in nuclear facilities edition

23 22-23 Significant presence of fissile material in a technological waste drum THE FACTS During a maintenance shutdown at the MELOX plant, the bottom of a glove box* containing powder residues of fissile material underwent cleaning operations. At the end of the operation, the operator told the shift supervisor that he had filled the sleeve with metal objects and with material. This information was recorded in the handover log ( risk of the presence of powder in this sleeve ). Two shifts later, the sleeve was removed to a technological waste drum (authorized to contain only a small quantity of material) because the dose rate measurement was deemed to be acceptable. The drum was then taken to a pre-counting station where the measurement indicated a quantity of fissile material above the authorized limit. After verification, this drum was found to contain a significant quantity of fissile materials that was incompatible with the storage rules for criticality control of technological waste drums. This event, which did not impact personnel or the environment, was classified as 1 on the INES* scale. TECHNICAL ANALYSIS The dose rate measurement did not allow detection of an excessive mass of fissile materials in the sleeve because it is only representative for a low quantity and becomes subject to self-absorption phenomena in the material when the quantity increases. ANALYSIS OF HUMAN AND ORGANIZATIONAL FACTORS Several factors contributed to this event: Use of a technological waste sleeve inappropriate for moving fissile material and the absence of specific instructions requiring formal controls. The information concerning the presence of powder in the sleeve and communicated by the operator to the first shift operator was lost during the various movements between work stations: the shift supervisor handover log documented the information passed from one station to another but did not ensure the transfer of this information to the following stations. Non-compliance with an operating instruction requiring the shift supervisor to validate the absence of powder retention in packages (here the sleeve) before they become waste. However, the operational documentation, which the shift supervisor relies on, does not contain this requirement. LESSONS LEARNED This event led MELOX to: set up neutron monitoring for evaluating the retention of fissile material present in the packages, and create an operating procedure detailing the risks involved in cleaning glove boxes. General Inspectorate Annual Report

24 Personnel protection for dismantling work Radiation protection The results of individual and collective dosimetric evaluations have remained stable and indicate that the risk at the collective level is properly controlled. Status of safety in nuclear facilities edition

25 24-25 The group s diversified activities generate high variability of radiological risks and potential situations involving personnel exposure to ionizing radiation. To successfully carry out these activities in the group s facilities, in France and abroad, the employees of the group and of subcontractors who are exposed to ionizing radiation are medically monitored with dosimetric monitoring suitable for the type of exposure. Results The results are calculated over 12 consecutive months 3 for the group s 14,199 employees and for 9,460 subcontractor employees who underwent individual dosimetric monitoring in France and abroad. AVERAGE DOSES In 2017, as in 2016, the level of average doses for all personnel monitored remains comparable to 1/20 th of the French regulatory annual limit of 20 msv. More specifically, the average dose over 12 consecutive months for the group s employees was 0.8 msv and 0.5 msv for subcontractor employees. This average dose may change, especially according to discipline. The highest values are related to mining activities, work in glove boxes, activities of nuclear departments to support maintenance operations in facilities in service, and activities related to clean-up and dismantling. In this period, 56% of the Group s employees and 31% of subcontractor employees subject to dosimetric monitoring were exposed to a dose under the measurement threshold (or zero dose). Checking for contamination, LA HAGUE The breakdown of annual doses received by the personnel was, for the most part, between 0 msv and 2 msv: 87% for the group s employees and 92% for subcontractor employees (see figures 11 and 12). 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% < 2 msv 2 and < 6 msv 6 and < 18 msv and < 20 msv Figure 11: Breakdown of annual doses received by the group s employees (including zero doses) 0% < 2 msv 2 and < 6 msv 6 and < 18 msv and < 20 msv Figure 12: Breakdown of annual doses received by subcontractor employees (including zero doses) In 2017, personnel who underwent dosimetric monitoring and for whom an annual dose above the threshold was recorded represent (see figures 13 and 14): 71% of the group s employees and 89% of subcontractor employees with a dose below 2 msv; 91% of the group s employees and 97% of subcontractor employees with a dose below 6 msv. 15% 5% 3% 3% 1% 1% 0.3% < 2 msv 2 msv and < 4 msv 4 msv and < 6 msv 6 msv and < 8 msv 8 msv and < 10 msv 10 msv and < 12 msv 12 msv and < 14 msv 14 msv 71% Figure 13: Breakdown of doses received by the group s employees over 12 consecutive months (including zero doses) 3 From July 1, 2016, to June 30, General Inspectorate Annual Report

26 Radiation protection 89% 2% 2% 6% 1% 0,3% 0.2% < 2 msv 2 msv and < 4 msv 4 msv and < 6 msv 6 msv and < 8 msv 8 msv and < 10 msv 10 msv and < 12 msv 12 msv and < 14 msv Figure 14: Breakdown of doses received by service providers over 12 consecutive months (including zero doses) This results from the group s implementation of measures to make personnel categorization more consistent with the provisional individual dose objective. For personnel with dosimetry significantly below 6 msv, classification in category B provides for more accurate monitoring. The longer use of the same dosimeter by category B personnel (3 months) makes it possible to account for doses that would be below the recording threshold with monthly use (category A). This is part of the general objective of limiting doses and applying the equity principle aimed at reducing the highest individual doses, by discipline and work environment. MAXIMUM DOSES According to recordings for 2017, the regulatory annual dose limit of 20 msv was not exceeded. The annual maximum dose recorded for both the group s employees and subcontractor employees is of the same order of magnitude as for It is respectively 16.1 msv and 14.6 msv. Since 2008, no employee has received an annual dose higher than 18 msv. For 2017, 18 group employees and 1 subcontractor employee received a dose higher than 14 msv, a value for which an action plan must be implemented. These numbers, down from 2016, result from monitoring and control that was compatible with activities in the facilities. This indicates good application of ALARA* approaches on a daily basis in operating and dismantling activities. COLLECTIVE DOSE The collective and individual dosimetric evaluations for a maintenance operation are indispensable in preparing for this operation. The collective dosimetric evaluation is an indicator that varies according to the operation, which reflect the group s diversified activities. In 2017, the collective dose of the group s employees, for all types of exposure, was 11,276 H.mSv, including 71% due to external exposure, and 5,103 H.mSv for subcontractor employees, including 35% due to internal exposure, resulting from the mining activities of Cominak. Analysis of results The satisfactory results for 2017 are an extension of the results obtained in previous years. They are based on a shared culture within the teams that work on the ground and also on the permanent action of radiation protection specialists. However, minor events were recorded during the year. They show the importance of primary radiation protection prevention, which is based on evaluating risk control before taking action, to limit employee exposure by reducing possible causal factors. They also show the importance of maintaining high standards and a progression in the operational control of risk situations, starting when personnel enter regulated access areas, with: rigorous application of rules defined for the wearing and activation of individual dosimeters, the wearing of personal protective equipment, and access conditions in special regulated areas. rigorous application of rules for control of personnel and equipment when these areas are exited, to guarantee the radiological cleanliness of the facilities, and shared vigilance without banalization of risks. Training to dress for operations PERSONNEL CATEGORIZATION When the provisional exposure for an employee is evaluated between 1 msv and 6 msv over 12 consecutive months, the employee is classified as category B. If the evaluation is greater, while remaining below the annual regulatory limit of 20 msv, the employee is classified as category A. Of the group s employees, 73% who underwent individual dosimetric monitoring were classified as category B. This proportion is slightly higher than for previous years. Status of safety in nuclear facilities edition

27 26-27 Example of operating feedback: Ventilated protective suit The preventive rules with regard to radiological contamination, either chemical or involving asbestos, determine the choice and number of suits to be worn. The prevention objectives are aimed at the absence of internal and external contamination of the employee during his or her activity and upon leaving the work area. These objectives are also aimed at obtaining an acceptable stress level during work phases, taking into consideration the characteristics of the environment around the work station, the operation time, and the physical effort required. Capitalization of operating feedback and analysis of trends in dosimetric evaluations as well as circumstances and causes of radiation protection and safety events are essential data for improving and controlling radiation protection performance. For example, following a dysfunction of a ventilated protective suit (rupture of an air supply hose) during a clean-up operation, an in-depth analysis of the use of this protective equipment was conducted. Based on the dysfunction, requests for changes in the suit were addressed to the supplier to improve control of operations on the ground. In addition, the entities using this suit were reminded to check the risk analysis for consistency with the worksite environment, to comply with the domain and rules of use, and to ensure that personnel are aware of proper use of the suit in normal and degraded conditions. including radon in risk evaluation, lowering the crystalline dose limit, changes to the organization of radiation protection departments to take account of relations with conventional risk prevention organizations and organizations set up to comply with the French health and environmental codes, reorganization of technical inspection organizations, simplifying zoning, level of monthly reference, and radiological monitoring of non-classified workers who access the areas. In addition, the increase in the number of worksites at nuclear facilities that involve both radiological and asbestos risks has led nuclear operators to provide a technical response for the optimized protection of personnel. These measures take regulations into consideration and use better techniques to prevent the double contamination risk (asbestos and radiological), while avoiding the addition of risk for personnel as well as major or minor discomfort, according to conditions defined by the suppliers of personal protection equipment, prevention specialists, and occupational health physicians. The measures are an adjustment to general regulations regarding asbestos in the context of worksites where there is the combined risk of asbestos and radioactive contamination. These proposals are being examined by the authorities to arrive at integration in the regulations with a time objective set for outlook Similar to nuclear safety, radiation protection involves significant regulatory work, which should be applied within the group. The publication in 2018 of the decree on worker protection against the risks of ionizing radiation, which transposes the 2013/59/Euratom directive and modifies the French labor code, will bring about significant changes in our practices. This text calls for the deployment of a new integrated approach involving all professional risks, while leaving the protection of workers unchanged. It also creates dialogue between the occupational health physician and the radiation protection officer. A group-level coordination will make it possible to prepare an operational implementation of the main regulatory changes, which concern: General Inspectorate Annual Report

28 Taking samples near LA HAGUE site Environmental monitoring To check that our activities do not impact populations, ecosystems, or biodiversity, we rely on our recognized human and technical expertise. The results are shared with the relevant players through public reports, joint expert assessments, and publications. Status of safety in nuclear facilities edition

29 28-29 Results in terms of radiological Environmental monitoring laboratory, LA HAGUE impact The annual radiological impacts (or dosimetric impacts) of the group s large nuclear sites remain at very low levels: 0.24 microsievert (µsv) for the TRICASTIN site, 13.1 µsv for the LA HAGUE site, and less than µsv for the MELOX 4 site. These values should be compared with exposure associated with other sources of natural or artificial radiation and the regulatory limit value for the public of 1000 µsv per year of dose added by nuclear activities. This very low impact is the result of constant progress over time in terms of treatment and control of releases in the environment. The vigilance of our teams remains a priority in the context of organizational changes underway within the group. Results in terms of chemical impact With regard to the release of chemical substances, the health impacts around sites are below reference values, as assessed with the methods recommended by the French ministry of ecological and interdependent transition, the national institute for industrial environment and risks (INERIS), and the institute for public heath surveillance (INVS). The risk indicators for threshold effects are less than 1 and the excessive individual risks for non-threshold effects are below 1/10,000, whatever the exposure scenarios of local residents and the age categories considered. Reliability continuously monitored To guarantee the reliability of the different checks performed 5, implementation of periodic cross-checking between the various measurement laboratories is required by regulations. These checks concern part of the measurements conducted by the operator and are performed by the LA HAGUE and TRICASTIN sites with the IRSN* in Le Vésinet. The summary reports on these cross-checks are submitted annually to the ASN*. They confirm the consistency between the various results obtained. Conducting these checks properly is one of the key points in order that internal laboratories, which ensure release monitoring, obtain ISO certification, in compliance with the requirements of the ASN decision no DC of July 16, 2013, modified by the decision no DC-0569 of September 29, ATLAS laboratory 4 Evaluated based on real releases authorized for For example, the TRICASTIN site performed 24,000 samples and 30,100 analyses (2016 figures) General Inspectorate Annual Report

30 Environmental monitoring Regrouping of approvals for laboratories on the TRICASTIN site for transfer to Atlas (INB no. 176) Atlas will be used to conduct environmental and industrial analyses for all of the facilities on the TRICASTIN site. Historically, TRICASTIN has had four analysis laboratories. In the context of improving expertise in this domain and modernizing equipment, the site submitted a request in 2013 to the Minister in charge of nuclear safety for authorization to create a single laboratory. After a public inquiry organized in spring 2014, and after a decree authorizing creation of INB no. 176 was obtained in September 2015, on March 7, 2017, ASN authorized commissioning of this new laboratory at the beginning of May. This project, involving an investment of more than 20 million euros, brings together all players in charge of analysis activities on the TRICASTIN site, or about 100 people. An important project in anticipation of the transfer of environmental monitoring approvals and Cofrac accreditation was set up to ensure control of the environmental monitoring activity at each step of equipment and team transfer. This project, which included various components (sequencing of transfer operations, definition of prerequisites, operator training, equipment requalification measures, and document management), was monitored by ASN* which regularly reported on progress to its approval committee. The transfer of the environmental laboratories took place at the end of March To check the efficiency of all control measures for the project, an internal audit was conducted by TRICASTIN in May The laboratory teams were able to demonstrate service continuity and control of risks associated with the transfer. This led Cofrac to write a letter dated August 8, 2017 on its decision not to conduct a closer evaluation (additional audit outside the cycle) following transfer of the two environmental laboratories to the Atlas Environmental Monitoring Laboratory (LSE). ASN also made use of this project management and this internal audit report to authorize, by a decision dated July 1, the transfer of around twenty ministerial approvals of exenvironmental laboratories to the Atlas LSE. The transfer of the ex-environmental laboratories to a single, spacious, and agreeable location at Atlas was a real opportunity for the Environmental Monitoring Unit. Simplified team management and sampling management together with optimized analysis and sharing of equipment and technical skills contributed to the improvement and sustainability of our results. This work had a strong impact on our activity, but the commitment of the entire team, valued by our regulators, made it possible to reach our goal. After a few months of operation, feedback from the teams is very positive. Jean-Marc Chevalier, Manager of the Environmental Monitoring Unit - TRICASTIN site. Environmental team in the ATLAS laboratory Status of safety in nuclear facilities edition

31 30-31 Waste storage, LA HAGUE Dismantling operations Dismantling activities during 2017 continued their ramp-up, underway for several years, especially at LA HAGUE. This large-scale and complex program mobilizes numerous skills to ensure the best possible compliance with the milestones set by ASN. General Inspectorate Annual Report

32 Dismantling operations Dismantling of the HAO south facility at the UP2-400 plant, LA HAGUE The Annecy SICN site, where ICPE-classified nuclear activities were conducted and eventually led to a return to initial state and rehabilitation, is still rented in its entirety to three companies, which are implementing industrial activities or energy production benefiting local populations. CADARACHE SITE The operations for dismantling the Plutonium Technology Facilities (INB no. 32) and the Chemical Purification Laboratory (INB no. 54), initiated in 2009 after 40 years of industrial operation, were completed at the end of At peak activity, these operations mobilized up to 300 employees of the group and its partners. In total, more than 460 glove boxes, 30 tanks, and 4 km of pipework were disassembled, cut, then conditioned and removed in safe conditions. For the administrative component, 2017 was a significant year with the examination by nuclear safety authorities and the IRSN* of the dismantling strategy of the group s facilities, and its application at the LA HAGUE and TRICASTIN sites to allow joint examination in April 2018 by the Standing Group of Experts and by the Commission of Safety in Laboratories, Plants, and Waste. These operations to clean-up and dismantle the equipment and to condition it as waste made it possible to free up around 60 emptied manufacturing process facilities, making it possible to return them to the CEA, the site s nuclear operator. Finally, the administrative processes for requesting a dismantling authorization continued on both the LA HAGUE and TRICASTIN sites, with examination by the Standing Group for Plants (GPU) of the complete dismantling files of INB no. 33 and 38, and the periodic reviews of INB no. 33, 38, and 47, with public inquiries prior to decrees for dismantling INB 93 and 105. Facilities nearing the end of dismantling or in reindustrialization VEUREY AND ANNECY SICN SITES For the Veurey site, the administrative process initiated in 2014 for the decommissioning of the two INB no. 65 and 90 was continued with additional documents submitted to the Prefecture of Isère to request public easements, in view of a public inquiry to take place in 2018, prior to the decommissioning by ASN.* In addition to the administrative process, reindustrialization actions are still underway with more than half of the surface area of the site rented to industrial groups. The project to reindustrialize the west part of the site is also underway with the management of an economic interest group and the support of local authorities. Storage of waste drums in the Chemical purification laboratory, CADARACHE MIRAMAS SITE Following clean-up operations finished at the end of 2015, the demobilization and monitoring operations were completed in The redevelopment of this site is aimed at selling all parcels so that the land can be reused for industrial purposes. Two operations are to be completed in 2018: sale of the west area for a solar power farm as part of a call for bids by the energy regulation commission, transfer of the central and east areas to an operator for a large-scale 10-year industrialization project. Status of safety in nuclear facilities edition

33 32-33 Facilities undergoing dismantling work INB no. 33, 38, 47, AND 80 - LA HAGUE SITE Studies and construction for waste recovery and conditioning (RCD) and for dismantling (DEM) underway for several years continued during 2017 at 4 INB in the dismantling phase. Significant aspects were as follows: in the high activity dissolution extraction (HADE) building, the end of recovery and removal of waste of one of the graphite-gas dissolvers and the continuation of dismantling operations on the solvent treatment and extraction units, end of mechanical treatment of drums and continuation of the characterization of waste from building 119, for the plutonium average activity (MAPu) building, the end of removal of material from room 107 and continuation of dismantling operations, continued construction of the civil structures of the waste recovery facility of silo HAO as well as erection of the first mechanical equipment systems, and end of work on civil structures for the waste recovery facility of silo 130, the set up of all mechanical process equipment, and the beginning of tests for commissioning the facility in April Parallel to these projects, studies were conducted to prepare for future operations. The detail studies of the sludge recovery and conditioning (RCB) project brought to light significant complexity in terms of operability and maintainability that is incompatible with the combined requirements of safety and recovery time. This finding, submitted in detail to ASN, led to the study of alternative scenarios in which recovery is carried out as quickly as possible and in compliance with requirements. All of the teams have been mobilized to respect scheduling and, in particular, the milestones set by ASN. However, the extent and complexity of certain waste recovery and conditioning (RCD) projects required submitting requests to safety authorities for the extension of deadlines. The beginning of recovery of GCR waste in silo 130 planned in July 2016 was thus extended by the ASN decision no DC-0612 from October 26, 2017, to April 30, Waste sorting at LA HAGUE At the administrative level, following the joint processing of the periodic reviews of INB No. 33, 38, and 47, with the request files for a dismantling authorization decree for INB no. 33 and 38, the Standing Group which met April 19, 2017, issued a satisfactory opinion concerning the re-examination files. These files are to be completed to integrate facilities that will continue to operate. EURODIF GEORGE BESSE PLANT (INB No. 93) - TRICASTIN SITE Following the public inquiry held at the beginning of 2017, the last step of the examination process for the dismantling authorization request file for INB no. 93, filed in 2015, was given a favorable opinion by the Inquiry Commission. On the basis of this opinion, completed by that of the municipalities, departmental councils, and the Local Information Commission, the Prefect of the Drôme, in his capacity as the coordinating prefect, addressed on March 31, 2017, a favorable opinion to the Mission of Nuclear Safety and Radiation Protection (MSNR), in charge of developing the project of the dismantling authorization decree for the INB. EURODIF cooling tower under construction, TRICASTIN A request will soon be submitted to ASN concerning the modification of the date to start recovery of waste from silo HAO and the hull storage facility (SOC). The technical operations to build the infrastructure necessary for waste recovery and conditioning are progressing correctly but have nonetheless been slowed by the significant constraints caused by coactivity in a limited space. General Inspectorate Annual Report

34 Dismantling operations This decree project will be submitted to ASN and the nuclear operator for an opinion before its publication in the Official Journal of the French Republic in Parallel to this process, the re-examination of the safety of INB no.93 was carried out in CONVERSION FACILITY (INB No. 105) - TRICASTIN SITE Similarly to INB no. 93, a public inquiry took place at the start of 2017 for the file to request dismantling authorization for INB no The Inquiry Commission issued a favorable opinion with one reservation concerning public involvement in the decision-making process for management of this facility s soils. On the basis of this opinion and of the following: 1) the removal of the reservation by a letter of commitment in March on the part of the operator; and 2) the opinions of municipalities, the departmental councils, and the Local Information Commission, the Prefect of the Drôme addressed on March 24, 2017, a favorable opinion to the Mission of Nuclear Safety and Radiation Protection, in charge of developing the project of a dismantling authorization decree for the INB. UF 4 to UF 6 conversion plant, TRICASTIN This decree project will be submitted to ASN* and the nuclear operator for an opinion before its publication in the Official Journal of the French Republic in Parallel to this process, the periodic review of this INB* was carried out in Finally, operations to return to initial conditions the former Comurhex laboratory, which is an ICPE* located on the site of INB no. 105, are underway. PIERRELATTE INBS - TRICASTIN SITE On the Pierrelatte INBS (defense nuclear facility) located on the TRICASTIN site, the dismantling process and operations continued in 2017 with: the definitive decommissioning of the Diffuser Building by the DSND* following dismantling and clean-up operations, which were conducted by the teams of Dismantling and Services Business Unit (BU D&S), the start of operations to dismantle the Transfer and Sampling facility at the beginning 2017, examination by the DSND* of the files for a dismantling authorization request for the Laboratory and Waste Treatment Station facilities, and continuation of the administrative process of return to initial conditions (shutdown, dismantling, and clean-up) of facilities in the north area of the site, in the framework of the protocol for transfer of ownership with the CEA.* Status of safety in nuclear facilities edition

35 34-35 Arrival of used nuclear fuel at the VALOGNES railway terminal External transportation activities Industrial performance requires perfect control of transportation flows for radioactive materials, whether their destination is our customers or our sites, and regardless of who produces them. The logistical operations are thus carried out with safety objectives that are identical to those set for the facilities. General Inspectorate Annual Report

36 External transportation activities Railway transport containers Supervision of transportation Controlling the safety of transportation of radioactive materials requires a defense-in-depth approach based on the principle of three barriers: safety of design, manufacture and maintenance of the casks, reliability of the transportation operations themselves, and the preparation of response in case of an incident or accident. For all of its activities, the group has established a supervisory process for transportation in order to ensure its control. It is run and implemented by the Logistical Business Unit (BU*), with support from the General Inspectorate. This process complements the application of national and international regulations on the safety of radioactive materials transportation and is thus based on the general principle of risk control. In the framework of sensitive operations, it allows for supervising the transportation of radioactive materials. The logic of precaution is extended beyond the domain of safety strictly speaking and radiation protection: safe transportation must identify and control all risks related to the operation, whether or not they are safety risks. Common documentary baseline Upstream of transportation, the definition and implementation of a common baseline gives a framework and homogeneity to the group s practices. It mostly comprises texts applicable to the transportation of radioactive and nuclear materials, and two major directives that cover the safety of transportation of radioactive materials and the compliance of packages. In early 2017, the baseline of texts applicable to radioactive and nuclear materials was put into circulation. The directive on the safety of radioactive materials transportation was updated to examine the exhaustivity of the general requirements of regulations concerning radioactive materials transportation (2012 version - SSR-6 - IAEA*) and to ensure consistency with the procedure to control compliance of packages of radioactive materials. Before the issuance of this directive, all transportation advisors and site safety advisors worked on it collaboratively. Delivery of Uranium containers by rail The essential condition of risk control associated with transportation is to adopt a global vision in order to avoid focusing exclusively on the operations. The process of supervision thus extends over several domains: upstream of transportation, by definition, the implementation of a common baseline and permanent deployment of risk analysis, in an operational framework, by the monitoring of transportation activities on our sites, but also anywhere that activities are carried that impact safety, or in the event of an incident or accident, by crisis management. Status of safety in nuclear facilities edition

37 36-37 Risk analysis For the permanent deployment of risk analysis, the approach first involves identifying and analyzing all of the transportation flows. For 2017, around 800 transportation flows, involving around 4,000 transportation operations, were active. They concerned 20 of the group s industrial sites. All transportation flows conducted or supervised by the group s Logistics Business Unit undergo exhaustive data collection to then evaluate the risk level. lacking handling equipment. A road survey was also conducted for the itinerary between the Daya Baya port and the Taishan power plant. Internal inspections During the transportation, a qualified team of inspectors on the ground (shipping and destination sites and in the areas of transshipment, especially ports and airports) was deployed. The goal was to ensure the preparation of packages and shipment at the group s sites. The activities performed there and the activities of service providers were also supervised, in all countries where our transportation took place. The change in the number of inspections declared unsatisfactory is used to evaluate the level of transportation control. This rate remained at a suitably controlled level: 5% in 2017 for 207 inspections carried out. This outcome was achieved through constant alertness for weak signals measured by the rate of not totally satisfactory inspections, which has remained at 20% since Unloading FCCs from flatcars at Daya Bay Harbor These results reflect the proactivity of operators in the area of safety, with the group s well-known high standards. The inspections conducted are the occasion to underline these standards. 60% When a flow or a specific transportation subject requires in-depth risk analysis, the Logistics BU* carries out a technical study that sometimes leads to evaluations on the ground, or road surveys. The studies may meet the needs of group entities to open a new flow or optimize the risk level of an existing flow. They must guide operators in the implementation of measures guaranteeing the strict application of technical and regulatory specifications for transportation. The studies cover a vast thematic domain and require diverse types of expertise: organization of transportation, regulatory watch, safety, security, loading and stowage, or informing the public. These studies also concern the validation of ships that the group s entities may need to load with radioactive waste. This has led to the elimination of eleven ships of the 180 evaluated up to the present. In 2017, the Logistics BU delivered the first fuel assembly core of the Taishan power plant in China. Upstream of this transportation operation, an in-depth risk analysis was conducted and regularly updated. This analysis led to evaluation of 2 possible commercial ports. Since the customer s final choice was the private port of the Daya Bay power plant, a detailed technical evaluation of the port was conducted. It was aimed at ensuring that a ship could maneuver and unload with its onboard cranes in a shallow private port, designed for unloading barges and 50% 40% 30% 20% 10% 0% Non-satisfactory Figure 15: Changes in the level of non-satisfactory inspections 60% 50% 40% 30% 20% 10% 0% Not totally satisfactory Figure 16: Changes in the level of not totally satisfactory inspections General Inspectorate Annual Report

38 External transportation activities In addition to inspections, audits of the group s sites and those of suppliers are conducted to evaluate the performance of existing organizations and processes. In 2017, 40 audits were carried out (4 for the sites and 36 for suppliers). The group currently employs 180 transportation suppliers (rail, road, sea, air, other services), with a worldwide scope. They are selected and validated in a panel called TC7, following qualification based on audits and inspections. plan enables managing: 1) a command and local decision center (PCD-L) of the Logistics BU* that interfaces with the command and national decision center (PCD-N) of the group, and the PCD-L of the site, as shipper or receiver; 2) a technical unit; and 3) a communication unit. This plan also enables sending out a mobile unit and specialists to the site of the accident, to the customer, and, if the event occurs in France, to the concerned prefecture. The entire system is tested during internal crisis exercises, some of which simulate accidents taking place outside France. In 2017, the Logistics BU* conducted or participated in 5 exercises on a greater or lesser scale, internally within the group or externally. A national exercise, entitled TMR62, took place on May 23, 2017 in the Pas-de-Calais department. TMR 62 NATIONAL EXERCISE The Pas-de-Calais department does not have any nuclear facilities, but its geographic position and its road and rail infrastructure makes it a place of passage for the transportation of radioactive materials. Inspecting a TN17/2 load on wagon at COVRA facility Management of deviations The changes in the level of transportation control are also measured by the number of significant events declared and their level of classification using the international nuclear event scale (INES). In 2017, 17 significant events classified on the INES scale were recorded in the transportation domain, including 15 on public roadways. These results can be compared with 28 events for 2016, including 14 within the external transportation scope alone. In 2016, 11 events were linked to concentrated uranium packages transported from mines in Niger and Namibia. In 2017, only 1 event from these mines was declared. Of the 14 significant events in 2017, 7 concerned the preparation of packages or shipments, 3 concerned contamination of wagons from power plants, and 2 involved road accidents abroad. Management of degraded situations In case of a degraded situation requiring it, the Logistics BU* sets up and coordinates the activation of the transportation emergency and response plan (PUI-T). This This exercise corresponded to the approach, initiated by public authorities, to develop the nuclear risk culture in non-nuclear departments. Following 3 exercises in 2016 involving several prefectures with a 4-hour exercise, one of the objectives of the 2017 exercise was to implement an open-ended scenario to intensify the level of complexity and propose actions to recover the damaged package. The exercise involved several players, especially the LA HAGUE site (shipper), the Logistics BU (transportation organizer) as well as the group s central services, the Prefecture and the departmental services, the departmental fire and emergency service (SDIS 62), the ambulance service, national police forces, the Nuclear Safety Authority (ASN), the Radiation Protection and Nuclear Safety Institute (IRSN), and the National Support Mission for Nuclear Risks (MARN). The exercise did not involve deployment on the ground (instead it was on the table ), but used a realistic scenario bringing together all of the concerned players. The exercise scenario simulated a collision between a train transporting hydrocarbons and a train transporting a waste package, and its extended effects over time. Beyond these objectives associated with control of the crisis management organization for all of the players (communication and interface between the players, alert system, etc.), the technical teams of the Logistics BU* were able to verify their capacity to propose a scenario to recover the cask and the wagon in order to meet the requests of the Prefect. Status of safety in nuclear facilities edition

39 38-39 Managing communication with the population and the media was another important objective of this exercise. The simulated media pressure, developed by a specialized company, represented 200 calls by journalists, 85 articles, several thousands of tweets as well as TV reports filmed live at the departmental operational center (COD) situated at the prefecture. This significant pressure was handled efficiently by the various players. Each of them gained operating feedback from this exercise, which was considered a success overall. The group also participated for the first time in a training session at the National Firefighters Academy (ENSOSP) for technical advisors in the fire and emergency response services of departmental management (DDSIS) and of prefects. This participation enables a better understanding of the constraints of responders but especially, a better understanding of the role of operators in the civil security response organization (ORSEC) and the ways in which they can support responders. This collaboration is to be repeated in Training in the transportation domain Given its expertise, the group continued, for the fifth year, its contribution to the program offered by the National Institute of Advanced Safety and Justice Studies (INHESJ) to train the responders of territorial public authorities who man the departmental operational centers (COD) of prefectures. In addition, an on-call manager of the group participated in each of these exercises, to better understand the expectations of public authorities relative to operators involved in transportation. TMR62 crisis exercise: Image of simulated accident condition - Source IRSN General Inspectorate Annual Report

40 External transportation activities TN G3 CASK - A new design for the transportation of used fuel assemblies In the coming years, the TN G3 cask is intended to replace the entire fleet of TN 12/2 and TN 13/2 casks ( Mark II generation) for the transportation of uranium oxide used fuel assemblies. It also has a double leaktightness barrier, high performance materials including a shell ensuring the absence of fast fracture risk at -40 C, and shock-absorbing materials with low sensitivity to temperature effects in ranges of high variability. Innovative technical solutions were constantly applied, notably for the qualification of behavior under crushing of the new shock-absorbing material of the caps (carbon foam blocks), for procedures for controlling defects in the steel shell, and for specific tests of a failure criterion of the screw systems for the caps, which undergo significant plastic stress during regulatory drops. The safety options of the package model were submitted to ASN* in Since then, several regulatory drop campaigns on the 1/3 scale were conducted and showed in every case the proper mechanical behavior of the packaging. Leaktightness was also maintained following the drops. Virtual reality, with VR headset. TN G3 With two versions (short and long), this cask is part of the development of a new generation of the type B(M) cask model, which meets the IAEA regulatory changes in the 2012 documentation. By 2022, it will be used for the first removals from EDF nuclear power plants, eventually including those of the first French EPR in Flamanville. The cask s design, which started in 2006, had to comply with very demanding specifications due to the operating conditions and in line with specifications for the TN 12/2 and TN 13/2 casks. Changes in regulatory requirements also had to be integrated. The approval request was submitted to ASN in November After a phase of expert assessment by ASN and its technical support organization, the IRSN, as well as numerous meetings and technical exchange with the Logistics BU, the conclusions of the assessment were submitted to the Transportation Standing Group, composed of French and foreign experts. In July 2007, this committee issued its recommendations and a globally satisfactory opinion. The expert assessment of the Competent Authority then entered a final phase of technical exchange before approval of the TN G3 cask, obtained in May In addition, the performance of the cask is superior to that of the Mark II generation. This cask is thus capable of transporting twelve fuel assemblies with maximum enrichment of 5% and an average burnup fraction of 70 GWj/tU. Status of safety in nuclear facilities edition

41 40-41 MOX 6 TRANSPORT - Transportation under strict monitoring The 6 th transportation mission involving MOX fuel left Cherbourg at the start of last July, en route for Japan and arrived at the Takahama nuclear power plant after two months at sea. Sixteen MOX fuel assemblies fabricated in the MELOX plant were delivered on time and in compliance with quality requirements, to our customer the Kansai Electric Power Company (Kepco). Organized by TN International and prepared in close collaboration with public authorities, the maritime transportation of MOX between France and Japan, started in 1999, has not led to any safety incidents. The cask used, designed by TN International, constitutes a veritable fortress (1 cask = 100 metric tons when empty for 10 metric tons of materials transported) that complies with the most stringent standards of the International Atomic Energy Agency (IAEA) and guarantees the containment of the materials in all circumstances. The maritime part of this transportation is based on the expertise of the British PNTL (subsidiary of TN International, INS, and a consortium of electric utility companies). PNTL is specialized in the maritime transportation of nuclear materials. The ships have numerous types of safety equipment (double hulls, redundant command and propulsion systems, etc.) as well as defense equipment, a unique characteristic in civil maritime transportation. In parallel, a Global Acceptance program was applied upstream and during transportation in countries close to the route, even though the ship circulated in international waters. This pedagogical and transparency approach in our transportation operations, essential for their acceptability, also addressed the general public (media invited to the ship s departure, tweets, etc.). This 6 th transportation of MOX, requiring two years of preparation, confirms our capacity to offer our customers reliable organization based on 50 years of nuclear logistics experience. Loading of a transport cask General Inspectorate Annual Report

42 Visual management session Safety management 1 Implementing nuclear safety, radiation protection and environment policies 2 Human and organizational factors 3 Maintaining skills and know-how 4 Monitoring subcontracted activities and subcontractors 5 Controlling standards and requirements 6 Industrializing safety reviews 7 Managing design and construction requirements Status of safety in nuclear facilities edition

43 Implementing nuclear safety, radiation protection and environment policies The Nuclear Safety and Environment Policy, and Health, Occupational Safety and Radiation Protection Policy set out the targets and priorities for the period 2017 to During the Safety Convention held on December 14, 2016, the CEO set out the key focus areas for the group in relation to nuclear safety and environmental protection over the short and medium term. The priority themes are the management of the investment programs, standard work and vigilance in operational discipline, the industrialization of safety reviews at group facilities, the close involvement of managers on the ground, the development of skills in the operational chain, and the strengthening of the evaluation of nuclear safety performance by the independent safety organization Nuclear Safety and Environment Policy Based on this framework, and including the operating experience feedback from the implementation of the Nuclear Safety Policy during the period , the group formalized its Nuclear Safety and Environment Policy, which was published in April together with the Health, Occupational Safety and Radiation Protection Policy. The document has been widely circulated, both internally among employees and to external companies working for the group. The aim of the policy is to ensure that all employees work together to manage safety and the environmental impact of activities according to the key priorities and actions. To this end, 12 levers for improvement have been identified: incorporating safety and environment issues into our investment programs, ensuring the continued compliance of risk control measures, preventing and limiting the environmental impact of our industrial activities, coordinating site dismantling and remediation programs, ensuring that operating standards and procedures are strictly applied, strengthening control of subcontracted activities, notably monitoring, developing OPEX*, particularly in terms of feedback to the design stage, producing safety files that comply with regulatory changes, increasing the presence of operational managers on the ground, making use of the independent safety organization at each level of the organization, completing self-assessment exercises on nuclear safety skills and culture, increasing the use of human performance tools (HPT). To support the deployment of this policy and measure its effectiveness, performance targets have been included in the site master plans and action plans. Regular reports on these targets are made to the Executive Committee. For the 2017 implementation of the policy, there are 122 actions divided between the nuclear platforms in France (TRICASTIN, LA HAGUE AND MARCOULE) and the relevant BUs (Mining, Dismantling and Services, and Projects) and corporate departments. The plan review performed in January 2018 showed that more than 80% of the planned actions had been completed in 2017 or the first quarter of Significant progress has been observed in three areas of the policy: In relation to preventing and limiting the environmental impact of our industrial activities, progress has been made on the nitrate treatment projects (TDN) at MALVÉSI, the project to reduce nitrate waste via the STU at LA HAGUE, the project to remove the Floxal open water cooling system at MELOX, and the R&D project to treat waste currently without a specific processing route (sludges, oils, etc.). In relation to producing safety and environmental assessment files that incorporate regulatory changes, files have been submitted for new facilities (the Mining Innovation Center at BESSINES and FLEUR at TRICASTIN), new activities (fuel at MELOX), works (crisis control center at MELOX following the complementary safety assessments), General Inspectorate Annual Report

44 Safety management modifications to governmental orders (the ECC extension to LA HAGUE) and periodic reviews. In relation to developing skills and increasing the presence of operational managers on the ground, vocational training for facility managers has been introduced at national nuclear platforms, with six cohorts completing the Safety Excellence program (chiefly aimed at the members of the Executive Committee, the directors of business unit operations, site directors, facility managers, and the managers of project management and engineering projects) in Measuring the effectiveness of this proactive approach over the long term remains a delicate task, as it is difficult to express nuclear and environmental safety levels using quantifiable, numerical values. During this period, the following global indicators have been fairly stable: number of significant events, incident prevention rate, number and rate of completion of internal control programs conducted by the safety organization, and the ratio of facility managers trained in Safety Excellence. In this context, an optimization exercise was carried out and the number of nuclear safety and environment indicators was reduced. This resulted in the selection of seven indicators (KPIs) to monitor the progress made regarding: compliance with deadlines for the group s major SHSE commitments, outstanding commitments undertaken by the operational entities, incidents involving liquids or gases being released into the environment, the reclassification of incidents detected by the operator or inspection authority, the quality of the files submitted for administrative authorization, awareness-raising and training in Safety Excellence for the group s executive directors, self-assessment campaigns in relation to the level of safety culture. These indicators will be monitored regularly during Executive Committee meetings in Depending on the progress made, we may launch group-wide activities or targeted actions at certain sites. WANO* peer review of corporate departments As a member of WANO, the World Association of Nuclear Operators, the group received a delegation of international peers from November 13 to 23, 2017, who came to evaluate the efficiency of the group s corporate departments supporting LA HAGUE recycling activities. The complete review process, known as a Corporate Peer Review, took more than a year, with the following key steps: a launch week (January 4, 2017), an internal self-assessment based on the WANO standards (March to June), a preparatory visit from the WANO team to headquarters and the LA HAGUE site (May 10 to 12), the submission of a file of supporting documents (October), a ten-day review by a team of 12 peers from seven countries, the drafting of a progress plan approved by the Executive Committee (December to January 2018). The progress plan is based on the results of the internal self-assessment, the conclusions and recommendations from the review proper, and the regular guidance provided by the Executive Committee. It helps improve the management of nuclear safety and environmental issues over the short term, and notably includes: the introduction of an internal communication initiative known as Safety Five, the formalization of a standard establishing the design authority and the structure of the independent safety organization, a skills assessment for all nuclear safety engineers. Participants at the WANO peer review close-out meeting Status of safety in nuclear facilities edition

45 44-45 Work-study program participant with mentor, LA HAGUE the content of awareness-raising actions: theoretical content and practical application, the format of awareness-raising actions: target population, session duration, number of personnel trained per session, profile of session leaders, refresher sessions, the involvement of management and site managers in deployment, the structure in place to support deployment: actors involved, methods for identifying relevant activities and human performance tools, methods for in-situ monitoring, tools to support deployment and monitor implementation. It was found that there was still a certain amount of variation in the objectives set by the various operational entities and in the deployment of human performance tools, in terms of the personnel trained, the activities targeted and the workshops and facilities that were prepared for deployment. 2 Human and organizational factors The human and organizational factors (HOF) approach, applied within the group for nearly 10 years now, is used during the design of new facilities or when technical or organizational modifications are being made, as well as during facility cleanup/dismantling operations and periodic reviews. It is also applied in the analysis of significant events involving nuclear safety. The aim of the approach is to make performance more reliable, optimizing activities by taking into account the way in which humans work, while guaranteeing compliance with nuclear and occupational safety requirements. Best practices and other notable actions were also identified, for example: the organization of theoretical and practical training sessions using models (see inset), an approach focusing on work activities to identify the phases sensitive to human error and determine the appropriate human performance tool/s this approach makes it possible to offer training support materials adapted to every scenario for better assimilation by operators, the incorporation of human performance tools into the existing tool for managerial inspections, the introduction of an inspection to check that human performance tools are being applied by the personnel and teams trained, with mapping to adjust and improve deployment. These best practices will make it possible to develop a deployment standard that will be implemented as part of manager training. This should standardize the content of training courses and the approaches taken by each operational entity. Deployment of human performance tools Human performance tools (HPT) are work standards that aim to encourage a questioning attitude and a rigorous and careful approach among operators working with hazardous systems and activities. An evaluation was carried out in 2017 to assess the deployment of human performance tools and identify the factors that promote their integration into operating practices. It covered the following elements: Service activity for EDF at a NPP General Inspectorate Annual Report

46 Safety management Human and organizational factors during organizational change Organizational change is a natural part of facility operation, but it can still affect how activities are performed and the capacity of individuals to act in a safe way. During organizational change, it is therefore important to analyze the impact of changes on operator activities and ensure that the planned measures will make it possible to manage the risk of human error. To this end, several studies were performed in 2017 in support of modification projects or to obtain operating experience feedback in order to evaluate the real effects of organizational change and make any adjustments needed. These included: an analysis of the impact of setting up the worker protection unit at the TRICASTIN site, an evaluation of the impact of the Dismantling and Services BU* transformation project, operating experience feedback from the reorganization of part of the LA HAGUE site. Deployment of human performance tools at LA HAGUE Following events in which human factors played a significant role (notably transfer operations), and in light of observations made by WANO during the 2016 site review, the LA HAGUE platform decided to design and produce a model and associated training course to strengthen operator assimilation and implementation of human performance tools for operations. An exercise in which two operators must communicate an instruction of type open valve XXX by telephone. In this role-play, the operators must use secure communication: Operator 1 gives instructions to operator 2. Operator 2 repeats the instruction back to operator 1. Operator 1 confirms that the message is correct. In 2018, this training will be extended to the maintenance and radiation protection teams and managers. The first training sessions began in February 2017, and 337 employees had received training on the models by the end of Training involves a theoretical component, and a practical component working on models that allows the trainees to implement four human performance tools (self-checking, cross-checking, the one-minute pause and secure communication) in three scenarios: An exercise in handling hoses and connecting them to a pre-assembled piece of equipment, which involved identifying various components and checking the connections. This exercise allows operators to implement self-checking and the one-minute pause. An exercise in pairs to identify and check valve positions (open or closed) on a facility. Using a list detailing the valve numbers and their expected position, and a layout drawing, the pair has to make sure that the valves are configured correctly. This exercise lets operators put into practice secure communication, cross-checking, the one-minute pause and self-checking. Mockup developed at LA HAGUE for practical training on HPTs Status of safety in nuclear facilities edition

47 46-47 Research into human and organizational factors Orano has renewed its commitment to the RESOH (Research in Human and Organizational Safety) training and research chair. This chair, hosted by the IMT Atlantique engineering school, is supported by three other partners (Naval Group, ANDRA and IRSN*). The scientific aim of the RESOH chair is to contribute, through research in human and social sciences, to extending knowledge in the fields of safety and human and organizational factors (HOF). This work is focused on the influence of the recourse to subcontracting. In 2018, the goal is to apply the results of the first studies completed and identify other activities that could benefit from this research work. running skills assessment and self-assessment campaigns, providing professional training, providing training and awareness-raising programs on safety culture, operational excellence, field management practices and the implementation of human performance tools during operations. Since 2016, maintaining skills has been identified as one of the risks in the group s risk portfolio. With this in mind, a cross-cutting critical skills project has been set up, which has strengthened two initiatives related to nuclear and occupational safety, and the environment: Safety Excellence for managers in the operational hierarchy and Safety Focus for the nuclear safety organization. Training on HPTs at LA HAGUE 3 Maintaining skills and know-how Acquiring and maintaining skills is a major part of the group s Nuclear Safety and Environment Policy, given the challenges associated with group development. Maintaining skills Two of the twelve priorities of the policy are to develop the technical and managerial skills of the management staff and to deploy the training programs identified following regular assessments of nuclear safety skills and safety culture. To this end, the Executive Committee places a special focus on monitoring the training of directors and facility managers, and on safety culture self-assessments. Based on their annual plan, the purpose of which is to implement the policy, the BUs* and sites have completed around 20 actions linked to maintaining or improving skills. In particular, this concerns management committee members, facility managers and their deputies, field managers, project managers, work supervisors, and safety operators and engineers (operating and facility personnel). In practice, this involves: establishing skills standards and requirements, Critical skills project A cross-cutting critical skills project, coordinated by the Human Resources Department, was set up in May The objective is to identify disciplines considered to be sensitive in terms of maintaining skills, produce a diagnosis specifying the challenges for each of those disciplines, then formalize and implement an ad hoc action plan to maintain skills over time. In 2017, the project team and associated network of discipline advisors: prepared a factual assessment, discipline by discipline, after 18 months of the project, formalized an annual skills review process, which is completed by the BUs, with the support of the Human Resources Department, in order to inform senior management about their skills management priorities. At the end of 2017, around ten disciplines were categorized as critical disciplines based on the current situation and group outlook. They notably cover project General Inspectorate Annual Report

48 Safety management management, engineering, nuclear safety, industrial risks and the environment, radiation protection, quality, and inspections. In relation to nuclear safety, the main actions performed in 2017 to strengthen the organization and promote the discipline were: the diagnosis of a target workforce, entity by entity, to ensure that the 2018 budgets were consistent with the nuclear safety-related activities and needs of sites and BUs*, the development, by the safety advisor network, of skills standards for nuclear safety engineers, with a view to assessing skills and providing training (see Safety Focus ). In 2018, the annual plan for nuclear safety disciplines includes: a half-yearly review of the target workforce, with the operational entities, a skills self-assessment campaign for nuclear safety engineers working within the group (around 300 to 320 personnel), the revision of the IGSN internal training scheme for nuclear safety engineers and a pilot session to check its focus and content, the benchmarking, with other operators, of skills monitoring and training for nuclear safety engineers, the formalization of training standards for nuclear safety engineers and human and organizational factor network specialists. Safety Focus Following the initial diagnosis of the nuclear safety discipline at the end of 2016, the group decided to reactivate a cross-cutting initiative to improve skills among nuclear safety engineers. This initiative is known as Safety Focus. It aims to provide tools to evaluate individual skills and the skills within the discipline, and offer a pathway and range of training and awareness-raising sessions for employees working in the discipline. The project has the following milestones: the establishment of skills standards and requirements: this was completed with the group network of nuclear safety managers in the second half of 2017, at the start of 2018, a skills self-assessment campaign on a pilot population (around 30 nuclear safety engineers representing all relevant entities), in order to consolidate the skills standards and establish the requirements for each type of role, a skills self-assessment campaign among all nuclear safety engineers in the first half of 2018, in order to set out the training priorities for the 2019 training plan. Safety Excellence The aim of the Safety Excellence initiative is to strengthen skills in nuclear and occupational safety and the environment within the operational hierarchy. Initiated at the request of senior management in 2012, it covers nearly 400 employees in France and internationally across the whole group. The initiative involves monitoring and supporting Executive Committee members, operational BU* directors, site directors (and their deputies), on-call managers, facility managers, the managers of project management and in-house engineering projects, and BU and site SHSE/ HSE managers. In total, the initiative covers seven groups. For each group, the program has three parts, with a selfassessment and/or assessment campaign based on the Safety Excellence standards for key operational roles, the establishment of prerequisites at the start of a shift and operational requirements halfway through a shift, and the implementation of dedicated awareness-raising and training actions. Glove box training. École des Métiers. LA HAGUE The main achievements in 2017 included: an SHSE skills self-assessment campaign for site directors, three awareness-raising actions for Executive Committee members on safety culture, the risks Status of safety in nuclear facilities edition

49 48-49 and safety concerns associated with materials transportation, and human performance tools (HPT) and the advantages of applying them in the field, training for two cohorts of BU and site directors, three cohorts of facility managers and two cohorts of managers of project management and in-house engineering projects. This meant that 76 employees completed a two- or six-day training course focusing on the day-to-day management of HSE issues. By the end of 2017, more than 80% of the permanent Executive Committee members, more than 60% of directors of business unit operations and site directors, and nearly 90% of facility managers had completed Safety Excellence awareness-raising or training sessions. In 2018, priority will be given to revising the skills standards (to develop the radiation protection and general protection elements), a self-assessment campaign for facility managers and training for project managers (for three to four cohorts following the pilot carried out in March 2017). 4 Monitoring subcontracted activities and subcontractors Annual subcontracting report In response to a request from the Ministry for Industry in May 2011, the sixth annual report was published on subcontracting within the group s activities in France. This report details and provides justification of the conditions in which external companies may be used or activities subcontracted on group sites or worksites. The 2016 report, which was published in July 2017, takes particular care to demonstrate how recourse to subcontracting and the performance of subcontracted activities can take place in accordance with group responsibilities in terms of nuclear safety, radiation protection, occupational safety and the protection of nature and the environment. Work setting at Orano headquarters Conclusion The continuous development of nuclear safety skills among all employees is a clear objective at the highest level of the group, and part of every manager s role. In 2018, work will continue on the programs already in place to ensure a high level of understanding of the nuclear safety, radiation protection and environmental issues associated with our activities among the operational hierarchy and nuclear safety engineers. This notably includes the Skills project and the Safety Excellence and Safety Focus initiatives. In addition, work will begin on drawing up the standards and refining the requirements regarding skills and training for specialists in human and organizational factors, alongside efforts to improve the quality and innovative nature of internal nuclear and occupational safety training. The report gives a general overview of the group s practices in terms of the contractor-supplier relationship, industrial policy and community involvement, the purchasing process, expectations and checks regarding the skills and training of subcontractors, operation preparation and support, and risk prevention in subcontracted activities. It also provides a status report on the main observations made in relation to the group s subcontracting activities in France by key actors (staff representative bodies, the CHSCT expanded to include external companies, the General Inspectorate and the ASN*) and identifies, on this basis, recurring subjects or major issues. As part of a continuous improvement approach, the report identifies areas for improvement, notably: the use of the hazards table to identify risky contracts, the inclusion of safety culture requirements in supplier specifications, the revision of monitoring standards for subcontractors, the revision of the contract evaluation sheet to reinforce the HSE criteria. This public report was distributed internally and externally, notably among the group s employees, service providers and suppliers, as well as to the ASN*, the DSND*, the General Inspectorate Annual Report

50 Safety management IRSN*, the National Association of Local Information Commissions and Committees (ANCCLI) and Local Information Commissions (CLI) near sites. Integration of HSE requirements into the purchasing process In 2017, the group s HSE and Supply Chain corporate departments and nuclear platforms worked together to draw up and implement operational tools to improve the way in which nuclear safety and environmental requirements are integrated into the purchasing process. In particular, this concerned the application of the hazards table before drafting the expression of needs and the revision of the contract evaluation sheet. After the distribution of the internal hazards table standard in May 2016, the nuclear platforms in France set out the deployment methods before rolling it out (from January 1, 2017, for TRICASTIN and MELOX, and January 1, 2018, for LA HAGUE). Internal procedure for the supplier management system In practice, after a year of operating experience, the implementation of the table has made it possible to: The work of the Steering Committee for Social, Human and Organizational Factors Orano, as the operator of a regulated nuclear facility, is a member of the multidisciplinary, pluralistic body known as the Steering Committee for Social, Organizational and Human Factors (COFSOH). This Committee, set up and led by the ASN*, includes representatives of institutions and environmental protection associations, figures chosen for their scientific, technical, economic or social skills, managers of nuclear activities, and members of federations representing the nuclear sector and the trade union organizations of represented employees. In particular, Orano contributes to the GT-B working group on legal issues raised by the Committee or its other working groups. More specifically, the GT-B examines the legal framework governing recourse to service providers and subcontractors under the legislation covering INBs following the major change introduced by Law of August 17, 2015, on the energy transition for green growth (known as the TECV Law) and Decree of June 28, 2016 on the modification, decommissioning and dismantling of regulated nuclear facilities, as well as subcontracting. The main areas that the operators, administrative authorities and stakeholders examine together are: the monitoring of company groupings, the internal monitoring of industrial groups, the definitions and criteria for monitoring in such a way that is proportionate to the stakes, the transmission of information on weak signals from subcontractors, the transitivity of the requirements of the contract between the contractor and the service provider, or of the contracts between the service provider and subcontractors. The objective for 2018 is to issue a balanced summary document that contains useful explanations of the regulations, as well as proposals for operational measures to improve the SHSE control of subcontracted activities within the scope of regulated nuclear facilities. Status of safety in nuclear facilities edition

51 50-51 classify suppliers in a more detailed way in three categories: strategic+, strategic or standard, establish a link to the monitoring level required for the supplier and contract, systematize contract evaluation sheet requests on an objective basis. The results show that at MELOX, the number of strategic+ and strategic suppliers has increased by 20% (from 98 in 2016 to 118 in 2017), increasing monitoring volumes, while the number of contract evaluation sheets validated (67 in 2016, 151 in 2017) and the evaluation rate for these suppliers (88% in 2016, 97% in 2017) have also increased significantly. In addition, work began in 2017 to simplify the contract evaluation sheet and incorporate HSE evaluation criteria consistent with those in the hazards table. This was done via a dedicated working group with representation from the TRICASTIN, LA HAGUE and MARCOULE platforms, coordinated by the Supply Chain and HSE corporate departments. When complete, the revised contract evaluation sheet should focus on the quality of the service performed and include around thirty criteria at the most (compared to 37 in the current version), one-third of which should be HSE criteria or directly linked to HSE issues: observance of the specification and associated requirements, observance of standards and instructions, notably regarding nuclear and occupational safety, the monitoring and managing of radiological and dosimetric inspections, results of the monitoring plan or monitoring actions, nuclear and occupational safety culture and operational excellence, effective management of raw materials, natural resources and waste, no releases into water or the air, response to deviations and involvement in the analysis of relevant events, control of subcontracting and subcontractors. The revised contract evaluation sheet is due to be published as a standard in the first half of 2018 and should enter into force by the end of the year, following changes to the purchasing information system. In 2017, guiding principles were also introduced regarding the monitoring of activities subcontracted within the group, whether for design and construction projects (with in-house engineering and project management) or for joint activities at a platform entrusted to a specialist group entity (industrial operator contracts or maintenance contracts involving multiple techniques). The observations for the year gathered during the preparation of the subcontracting report, inspections by the General Inspectorate and the ASN*, and the work mentioned above have made it possible to identify areas for improvement for They notably include the formalization of our expectations as a nuclear operator towards subcontractors in terms of safety culture, the formulation of relevant requirements for the protection of interests in our expressions of needs, the assimilation of our document standards and requirements by subcontractors and the integration of five years of operating experience into the revision of the standard on monitoring subcontracted activities. In addition, in 2017 the group launched work to update and develop its management specification for suppliers. The management system specification for suppliers aims to formalize the generic requirements complementing standard ISO 9001 that must be respected by the supplier or service provider in the fulfillment of a contract awarded by the group in its role as nuclear operator. In practice, these generic requirements are supplemented by specific requirements noted in the expression of needs and/or in the contract. Suppliers convention More specifically, the work to revise the specification will include: the clarification of certain essential terms (notion of activities important for the protection of interests, technical checks and monitoring), the addition of requirements regarding counterfeit, fraudulent or suspect articles, the addition of requirements regarding skills, the incorporation of safety issues and the effective management of the subcontracting chain (link to the Procedures Decree modified by Decree of June 28, 2016), the revision of the appendix specifying the group s expectations in terms of safety culture. The updated version of the specification is due to be published in 2018 and it should enter into force by the end of the year. General Inspectorate Annual Report

52 Safety management 5 Controlling standards and requirements In the context of continuous regulatory change, the operational transfer of texts must remain a priority to make regulations as accessible as possible to operators. Editorial work session Over the past year, notable regulatory updates include the publication of two resolutions concerning emergencies and significant modifications to INBs, as well as the analysis of the draft decree on INBs and transparency in nuclear matters. In 2018, work will continue to establish how these texts will be applied within the group. General rules for facility modification ASN* resolution 2017-DC-0616 of November 30, 2017, concerning significant modifications to INBs, as per Article 27 of November 30, 2017, was approved by the Order of December 18, It specifies the list of significant modifications that must be reported. This resolution replaces the ASN* resolution on the provisions of the internal authorization system and thereby the individual resolutions permitting sites to use such a system. This general resolution sets out the rules regarding the management of significant modifications to INBs. Such management activities, which are considered to be activities important for the protection of interests (AIP), must be adapted to the issues presented by each modification with respect to the protection of interests. Based on the principles of the resolution concerning physical modifications to INBs (ASN 2014-DC-0420, in force since 2014 but due to be repealed on July 1, 2019), the aim of the resolution is to broaden the scope of the regulatory requirements for physical modifications to encompass modifications relating to organization, documents, emergency management and internal transportation. In addition to the general criteria to define the significant modifications that must be reported, which are relatively close to the existing criteria in the internal authorization system resolutions for the LA HAGUE, TRICASTIN and MELOX sites, the resolution introduces new criteria by drawing a distinction between the different types of modification (physical, organizational, documentary, and relative to emergency preparedness and management or internal transportation). It will enter into full force by July 1, 2019, at the latest, with application from January 1, 2018, limited to the significant modifications that must be reported, as defined based on solely the existing criteria in the site internal authorization systems. Minor modifications, on the other hand, will be identified based on the existing criteria in internal modification procedures, supplemented by the cases cited in the new resolution. The management of these qualifications will need to be adapted due to the repeal of the internal authorization system resolutions, and our internal procedures will also be revised, with: the introduction of internal inspection bodies, replacing the internal authorization systems and CEDAI committees; the strengthening and adaptation of our modification management processes, in line with the requirements of the new resolution will be considered the pilot phase of operation for the new internal inspection bodies, with the examination of the files subject to authorization before they are sent to the ASN*. This phase will also be used to refine our existing criteria for identifying INB modifications that must be reported, in accordance with the new criteria in the resolution. Other ASN resolutions in 2017 Two more major resolutions were published in the past year: ASN* resolution 2017-DC-0587 of March 23, 2017, relative to the packaging of radioactive waste and the conditions of acceptance of the radioactive waste packages in the disposal INBs, approved by the Order of June 13, The application of Status of safety in nuclear facilities edition

53 52-53 this resolution is currently being examined by INB operators and ANDRA, with a view to adjusting the existing standards to make them consistent with the objectives of the resolution. ASN resolution 2017-DC-0592 of June 13, 2017, concerning the obligations on INB licensees in terms of preparedness for and management of emergency situations and the content of the on-site emergency plan, approved by the Order of August 28, ASN guides In addition to these resolutions, the ASN published several guides, notably on scientific computing tools and transportation: Guide 28 on the qualification of scientific computing tools used in the nuclear safety case 1 st barrier. This guide applies to the scientific computing tools used at the initial design stage of INBs, or during periodic safety reviews, operation, shutdown or dismantling. Guide 34 on the implementation of the applicable regulatory requirements for the internal transportation of hazardous goods. Guide 31 on the procedures for notification of events concerning the transport of radioactive materials on the terrestrial public highway, by sea or by air. This guide supersedes the part of the ASN guide of October 21, 2005, concerning the transportation of radioactive materials on public roads, as modified. The nuclear operators have also written a guide covering the integrated management system and their policy on the protection of interests. This inter-operator integrated management system guide (by ANDRA, the CEA, Orano, EDF, CIS-BIO, GANIL and ILL) was issued in March 2017, with a presentation given to the ASN at the meeting with operators on November 28, The ASN confirmed that it would not issue a resolution but rather publish its own guide, scheduled for the end of Internal group texts The group has continued updating its internal prescriptive standards, with the publication of the following texts: a directive on the guiding principles for allocating internal tasks and responsibilities relating to nuclear safety during the transportation of radioactive materials on public roads, a directive on the durability of chemical products and procedures in application of the European REACH regulations, a guide to the performance indicators used to monitor the Nuclear Safety and Environment Policy. Outlook Several actions begun in 2017 will continue in These include: internal group operating experience feedback on the deployment of the EIP* initiative on sites; the analysis of new safety case requirements arising from ASN* resolution 2015-DC-0532 of November 17, 2015 (concerning the content of the safety analysis report), in relation to the current methodologies, summarized in a guide; the production of guide to the activities important for the protection of interests, notably including the identification and classification rules; the production of a procedure describing the rules applicable to INB modifications. EIP/AIP Methods Guide 6 Industrializing safety reviews The industrialization of the safety reviews is an objective set by the Executive Committee that concerns all relevant group entities. The need for industrialization Given the operating experience feedback from the first series of periodic reviews extended to fuel cycle facilities, industrialization has become necessary in order to: General Inspectorate Annual Report

54 Safety management ensure that approaches and methods are consistent, in order to reach a single, reproducible position on cross-cutting issues across all facilities; develop methodologies applicable to the periodic reviews. In 2017, there were specific objectives aiming to: better anticipate the deadlines for reviews, establish the main issues and objectives for each INB*, establish standards and requirements common to all operators that went beyond existing directives and guides to ensure that reviews were better organized and improve the content of the review files. First page of the internal tool devoted to periodic reviews In this context, two cross-departmental functions were introduced: the site coordinator, charged with coordinating the various INB review projects at a single site, planning these reviews over the medium and long term, identifying or issuing specific site procedures and facilitating the collection of the data required for the reviews, the advisor cluster, which coordinates review activities at group level, suggests methodological approaches, ensures that regulatory changes are taken into account and manages operating experience feedback. finalizing and sending the review file for INB 118 (STE-3); preparing and implementing the orientation report (DOR) for the review of INB 116 (UP3-A). For the TRICASTIN site: deploying commitments regarding INB 155 (TU5), finalizing and sending the review files for INB 93 (Georges Besse 1) and INB 105 (COMURHEX 1), which are also the subject of dismantling files, preparing and launching the orientation reports for the review of INB 138 (SOCATRI) and INB 178 (Parcs). For the MELOX site: preparing and implementing the orientation report for the review of INB 151 (MELOX). Work began on establishing specific review standards common to all operators, with the creation of an orientation report preparation guide. This guide was drawn up in order to provide a tool for prioritizing the actions to carry out during a review, according to the issues specific to each facility, previous OPEX analyses and changes to regulations or the state of the art. Orientation reports are now drawn up using this guide. This initiative will come to an end in 2018 with the finalization of the full periodic review standards, which will optimize the drafting process for each element of the review file and be supported by specific tools. In addition, organizational principles will be drawn up to supplement those set out in existing directives. The site coordinators reporting to the site safety directors now work in close collaboration with the advisor cluster, which is positioned within the projects BU. This made it possible to coordinate review-related actions throughout Main periodic review activities for 2017 For the LA HAGUE site: finalizing the examination and implementation of commitments regarding facilities being dismantled: INB 33 (UP2-400), INB 38 (STE-2 and AT1) and INB 47 (ELAN IIB), and the INB 117 (UP2-800) workshops; Engineering at Orano Projets Status of safety in nuclear facilities edition

55 Managing design and construction requirements According to the defense in depth approach, quality design is the first line of defense. Throughout 2017, in order to follow the industrial transformation objectives of the group, projects have systematically incorporated the principle of using measures proportionate to the safety stakes, which involves ensuring that technical, financial or organizational decisions are made in a way that is consistent with the scale of the risks and challenges of the facility concerned. using criteria levels. Each level ultimately contributes to preventing damage (excessive deformation, plastic instability, elastic instability or fatigue damage). In the same way, it is important to remember that if equipment is identified as being important for protection as per the regulations, there are specific measures relating to its design, manufacture, maintenance, assembly, testing and operation. These measures are based on requirements formalized in the safety analysis (known as safety requirements). They are graded given what is usually called a construction class and applied in practical terms in such a way that is proportionate to the safety stakes, which is essential to properly rank priorities in technical, economic or even organizational terms. On this basis, in the context of several periodic reviews at the LA HAGUE site, it was possible to make excellent progress on earthquake and climate hazards. Design work, Orano Projets This means that nuclear safety is incorporated during the design phase according to three essential pillars. The safety analysis, at the heart of the process, is performed by the prime contractor, supervised by the project owner with the support of the corporate departments. This analysis must be performed before the main technical decisions are made, with the integration of the general safety objectives selected for the project. It involves assessing the various lines of defense in place for the processes, which have different safety requirements depending on the operating phase of the facility. These safety requirements are used to draw up and monitor the safety case. The identification, from the feasibility phase, of the different operating situations in line with the safety objectives selected for the project begins well in advance of the detailed design process. This vital stage chiefly concerns the definition of the hazards identified (natural and industrial), their level (normal or accident) and the rules for incorporating them into the design of the facility and the safety case. The detailed breakdown of the safety requirements applied to the systems, structures and components is then carried out, activity by activity 6. This principally includes the operational application of the safety requirements in terms of behavioral requirements, then analysis criteria, in accordance with the selected design regulations. One illustration of this in the context of new projects (see inset on the FLEUR project) is the way in which the TRICASTIN site collaborated with the corporate departments and project suppliers design departments on a joint nuclear safety/design initiative to guide designers in optimizing the incorporation of external industrial hazards into facility design, maintaining a high level of safety formalized in a consistent safety case. This optimized approach would not have been possible without the contribution of the College of Experts (see inset). For the mechanical equipment, for example, the analysis regulations describe the design and construction rules, defining, on the basis of linear or non-linear calculation models, methods for justifying its mechanical behavior 6 Activity here is used in the sense of the INB Order and corresponds to the different life cycle phases design, construction, commissioning, operation, maintenance of the system under consideration. General Inspectorate Annual Report

56 Safety management 2017 expert recruitment campaign Given the group s development objectives, strengthening expertise goes hand-in-hand with our business plan, excellence and the distinctive added value we seek to be able to provide to our customers. We are strengthening our expertise in the following key areas, as much to maintain our core business activities as to master new fields: new materials, mechanics, chemistry, modeling, including the foundations of applied mathematics, new technologies, particularly digital technologies. The 2017 campaign began in April. It aimed to encourage individual applications in the area of technical expertise, while remaining selective as part of a medium- to longterm vision. Through this process, the company sought to identify and recognize a distinctive level of skill and personal engagement, sufficient to justify the title of expert. There are three levels of expertise: Expert (level 1), Senior Expert (level 2) and Expert Fellow (level 3). The expert role includes providing technical support in the areas of operations and business development, innovation, knowledge expansion and communication, and developing the company s technical influence. To guarantee their capacity to hold this role, experts are appointed based on the following criteria, in addition to their technical skills: recognition by peers, their capacity to use their knowledge to help the business progress, and specifically to establish, affirm and defend a technical position by considering all relevant issues, their long-term personal involvement, their capacity to communicate and work as part of a network, their scientific and technical curiosity. In total, 465 experts were appointed during the 2017 campaign, which closed with an awards ceremony at the end of January The FLEUR project each building could be reduced from 819 tonnes at the preliminary design stage to 308 tonnes at the end of the detailed design phase. One of the activities of the TRICASTIN platform is storing the U 3 O 8 produced by the TU5 facility following the processing of uranyl nitrate from LA HAGUE. The FLEUR project aims to create new storage capacity in optimal safety, environmental and physical protection conditions. The future storage facility will comprise: four storage buildings (P36A, P36B, P36C and P36D) built from metal frames and cladding, an earth dike providing biological protection, a stormwater basin, a perimeter fence and gate, contributing to protection. Overall view of the FLEUR project From the earliest preliminary design stages to the finalization of the detailed design, joint work between the operator, project owner, plant safety section and engineering office made it possible to agree on the optimized design solution of a metal-framed building. Through this approach, the mass of the metal frame of FLEUR project - 3D simulation of the frame Status of safety in nuclear facilities edition

57 56-57 FINA team during an exercise Management of degraded situations Preparation for managing degraded situations is an integral part of the group s safety and security culture. General Inspectorate Annual Report

58 Management of degraded situations At every level of the organization, systems are implemented in terms of training, exercises, and operating feedback to maintain the highest levels of safety and security in degraded situations. The crisis exercises make it possible to individually and collectively acquire the skills necessary to respond optimally to any emergency situation and to validate the use and operational relevance of any system. These exercises, according to their level and intensity, may involve various configurations of local and national teams, or international teams for sites outside France. Exercises can also be conducted upon request of the authorities and public powers. responses acquired, especially in the use of tools; strong commitment and mobilization; efficient teamwork and exchange, etc. The action plan based on the lessons from this exercise will form the backbone of preparatory work for managing emergency situations in The application of emergency decision-making and the digital transformation of crisis management tools are two other major areas for structuring actions in The PCD-N during an ECRIN exercise These national and international exercises are part of a scheduling cycle over three years and reflect the group s continuous progress strategy. For 2017, 8 exercises were carried out. The efficacy of these exercises is to a large extent based on the quality of upstream preparation and the relevance of the scenario, compared to those considered in the emergency plan (PUI or POI) of the concerned site. The ability to adapt to new threats is also important. The progress actions implemented in 2017 were aimed at improving: implementation of resources and equipment mentioned in the Supplementary Safety Assessments (SSA), anticipation of continued activity for the entire group, consideration of the human and organizational factor (HOF) in the management of operational crises, and new technologies watch to improve the management of emergency situations. Particular attention was paid to the implementation of various steps of the switch from a standby situation to the management of an emergency situation. Progress strategies for 2018 The specific theme areas for 2018, based on the expectations of public powers and authorities, as well as the events and feedback from the exercises during the past year, especially 2017 ECRIN, will be: Consistent and reliable sharing of information, and means of acquisition and transmission, Technical, engineering, and expert support solutions, Application of actions to maintain the FINA* in operational conditions, and Improving our internal organization to handle hybrid crisis scenarios which combine safety, security, and cyber aspects ECRIN exercise The 2017 large-scale ECRIN exercise took place at the MELOX site (Gard department) on October 11 and 12, 2017, over 20 consecutive hours. One of the objectives was to train the various crisis teams to respond to a major event over time, in order to test the group s entire organization and the existing crisis doctrines as well as national plans (national plan for response to a nuclear or radiological accident and post-accidental doctrine (CODIRPA)) and to validate the operational character of FINA*. More than 200 people participated in this exercise and its operating feedback. Among the positive observations, the objectives of the exercise were reached overall: automatic Status of safety in nuclear facilities edition

59 58-59 Emergency decision-making The August 28, 2017 order on approval of the ASN decision no DC-0592 of June 13, an emergency decision - concerning the obligations of INB operators with regard to preparation and management of emergency situations and to the content of the internal emergency plan, was published in the Official Journal of the French Republic on September 3, In this domain of activities, the decision covers certain requirements in the area of alert and coordination with Authorities and outside service organizations, human resources, crisis exercises and simulations, equipment for managing emergency situations, facilities for managing emergency situations, and the protection of people on the ground. The decision calls for making requirements more stringent in terms of training and exercises for designated first responders in basic nuclear facilities and their monitoring. The text will go into effect on January 1, For facilities other than nuclear power reactors. Other articles will go into effect between 2019 and Crisis Command Center at TRICASTIN Selected in 2014 as a pilot site for the construction of a Crisis Command Center (PCC) following the Supplementary Safety Assessments (SSA), the TRICASTIN site took possession of its new crisis management center, available for all operators of the site s facilities, and made improvements with regard to extreme natural events: earthquake, tornado, extreme temperatures, flooding, etc. It includes 3 buildings: one for housing security teams (Living Quarters), one for storing firefighting equipment (Logistics Unit), and a specific building for crisis management (Command Building). Living compound and Logistics building (BV/BL), TRICASTIN The first two buildings were delivered and commissioned at the end of With authorization from ASN in September 2017, the third and last building has been commissioned. It consists of living quarters and a specific crisis management area. Commissioning of the command building took place in two phases to integrate permanent operational crisis management: a first phase of operation with temporary equipment and resources, then starting in November 15, recovery of all equipment and means from the former TRICASTIN crisis management center. A few final adjustments are underway to finalize the project. General Inspectorate Annual Report

60 Management of degraded situations Orano s National Intervention Force (FINA) The Supplementary Safety Assessments (SSA) conducted following the Fukushima accident highlighted the need to create an intervention force capable of providing human and equipment support to a site in crisis. The FINA project was launched at the end of After several years of construction, FINA now offers real intervention capacity, based on the principle of voluntary involvement. It will become fully operational in 2018 with implementation of a policy to maintain operational conditions in view of sustainable functioning. This concerns training and exercises for voluntary participants as part of predefined missions, as well as permanent availability of specifically defined and acquired equipment for handling this type of situation. To obtain a level of performance, the strategy for using FINA will have operating feedback from the exercises in which it participates. For example, the 2017 ECRIN exercises involved teams and equipment for the implementation of its 5 components: Response-Protection, Support Base, Logistics, Crisis and Intervention Engineering, and Management Staff. Orano s National Response Force (FINA) during the extended Internal Crisis Exercise (ECRIN) at the TRICASTIN site More than 100 people were mobilized on several sites during this exercise: PCD-N 7 at La Défense PCD-L 7 at MELOX, TNI at SAINT-QUENTIN-EN-YVELINES (SQY), Orano Projects at SQY and PIERRELATTE, and UPMS 7 at TRICASTIN, IN ORDER to implement missions for: environmental measures and characterization, decontamination and containment, supply of personal protective equipment and fuel, deployment of a mobile communication network on the ground and in the buildings, investigations in a building with a robot, transportation of volunteers between the living quarters, workshop, TRICASTIN, MELOX, etc., deployment of new systems such as robots. FINA team briefing 7 PCD-N: National crisis control center (Poste de Commandement et de Direction National) PCD-L: Local crisis control center (Poste de Commandement et de Direction Local) UPMS: Material and site protection unit (Unité de Protection de la Matière et du Site) Status of safety in nuclear facilities edition

61 60-61 Glossary ACRONYMS AIP: ALARA: ANDRA: ASN: BU: CEA: CEDAI: CHSCT: CLS: COFRAC: DSND: EIP: Activities Important for the Protection of interests As Low As Reasonably Achievable French National Agency for Radioactive Waste Management (Agence Nationale pour la gestion des Déchets Radioactifs) French Nuclear Safety Authority (Autorité de Sûreté Nucléaire) Business Unit (in the Orano organization) French Atomic Energy and Alternative Energies Commission (Commissariat à l Énergie atomique et aux énergies Alternatives) Internal Authorization Request Evaluation Committee (Commission d Évaluation de Demande d Autorisation Interne) Health, Safety and Working Conditions Committee (Comité d Hygiène, de Sécurité et des Conditions de Travail) Local Safety Commission (Commission Locale de Sécurité) French Accreditation Committee (Comité FRançais d ACcréditation) Delegate for Nuclear Safety and Radiological Protection for Defencerelated Activities (Délégué à la Sûreté Nucléaire et à la radioprotection pour les activités et les installations intéressant la Défense) Equipment Important for Protection EURATOM: European Atomic Energy Community FINA: Orano s National Response Force HCTISN: HOF: IAEA: ICPE: INB: INBS: IPR: IRSN: OPEX: SSA: High Committee For Transparency and Information on Nuclear Security (Haut Comité pour la Transparence et l Information sur la Sécurité Nucléaire) Human and Organizational Factors International Atomic Energy Agency Environmentally Regulated Facility (Installation Classée pour la Protection de l Environnement) French Regulated Nuclear Facility (Installation Nucléaire de Base) French Defense Nuclear Facility (Installation Nucléaire de Base Secrète) Incident Prevention Rate Institute for Radiation Protection and Nuclear Safety (Institut de Radioprotection et de Sûreté Nucléaire) Process designed to organize Operating Experience Supplementary Safety Assessments TSN Law: French law no of June 13, 2006 on transparency and security in nuclear matters WANO: World Association of Nuclear Operators General Inspectorate Annual Report