2011

E.D.F.Présidence IGSN21, avenue de Messine75008 Paris

www.edf.fr

The Inspector General’s report

on Nuclear Safety and Radiation Protection

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FOREWORD

This report is destined for the President of EDF with the purpose of informing him of my judgement of nuclear safety and radiation protection within the EDF Group. It is also intended for all who, in any way, play a role in improving nuclear safety. It may also prove useful to those outside the company who work in the nuclear field or indeed any branch of industry where there are risks to be managed and who wish to participate in the debate. It also contributes to the pool of information shared with the other nuclear operators under the auspices of WANO.

The continuous improvement of nuclear safety results is a fundamental commitment of the EDF Group. This is notably reflected in a policy of transparency, whether in France, Britain, America or China. This document constitutes an example of this, offering an independent view of the operational situation. It is based on facts and findings derived in our contacts with field staff and meetings with the decision makers, managers, medical personnel and players on both sides of this industry as well as outside stakeholders, especially contractor companies. The resulting snapshot of the situation in the field is particularly instructive.

This report therefore concentrates more on problems and weaknesses rather than strengths and progress, except as concerns happenings outside France, where the focus is more on good practices than difficulties This may seem unfair to all those who have totally committed themselves to the delicate task of operating the facilities on a daily basis. Here, in particular, I have in mind the staff from our engineering centres and power plants who were the first to be affected by the Fukushima accident and have significantly contributed to the subsequent assessments.

I would like to thank all those I met, inside and outside the EDF Group, in France and elsewhere, for welcoming us so kindly, for discussing matters so frankly and creating the conditions for fruitful discussions. Their openness, vital to the relevance of this report, continues to reflect a spirit of nuclear safety culture.

I would also like to thank my advisers Christian Thézée, Bruno Coraça and Peter Wakefield who, once again this year, were unstinting in their efforts, without forgetting Jean-Paul Combémorel who joined us at the start of the year. I address my special thanks to Jacques Dusserre, who has left the team after six years of remarkable service. This year’s report still shows his style.

To optimise this report, the layout has been changed somewhat relative to previous years. All the issues linked to nuclear safety have been covered although the number of chapters has been reduced. Finally, although this document has not been written for the purpose of public relations, as in previous years, it will be available to the general public on the EDF website in both French and English (www.edf.fr). This year, more perhaps than previous years, I hope it will provide answers to the questions that many are posing concerning nuclear safety.

The EDF Group Inspector General for Nuclear Safety and Radiation Protection

Jean Tandonnet

Paris, 20 January 20�2

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Contents

1 My view of nuclear safety in the EDF group 5

2 A panorama of 2011 92.1 Themanagement 102.2 Thestateoftheinstallations 102.3 MaintenanceoftheFrenchnuclearpowerplants 102.4 RelationswiththeFrenchnuclearsafetyauthority(ASN) 122.5 TheEPRprojects 142.6 Theplayersinthefieldsofhealthandsafety 152.7 Radiationprotection 172.8 Firepreventionandfirefighting 182.9 Increasingnuclearpowerplantsecurity 192.10 Decommissioning 20

3 Nuclear safety management 21

4 The Fukushima Daiichi accident 27

5 Training to develop skills in the professions 39

6 The operations profession 45

7 The engineering services and operations support 49

8 Managing projects 53

9 Together with contractors towards better overall performance 57

10 EDF nuclear activities outside France 61

11 Visits outside France 69

12 Events in the EDF group 7312.1 EDFSA:prematurewearofdieselgeneratorbearings 7312.2 EDFSA:acontrolincidentandanautomaticreactortrip 7412.3 EDFEnergyfailureofcast-ironpipes 7612.4 SOCODEI:anindustrialaccidentatCentraco(Marcoule) 77

13 A technical event outside the EDF group: The Deepwater Horizon drilling platform accident 79

14 Appendices 8314.1 ResultindicatorsforEDFSA’splants 8414.2 ResultindicatorsforEDFEnergy’splants 8514.3 MapoftheEDFSAnuclearpowerplants 8614.4 MapoftheEDFEnergynuclearpowerplants 8714.5 TechnicalkeydatesforeachoftheEDFSAnuclearunits 8814.6 TechnicalkeydatesfortheEDFEnergynuclearunits 8914.7 Tableofabbreviations 91

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MY VIEW OF NUCLEAR SAFETY IN THE EDF GROUP

First, I would like to state that no major nuclear safety events occurred in the EDF Group’s nuclear plants this year. There was, however, an event ranked Level 2 on the International Nuclear Event Scale (INES) in France related to equipment failure which had no direct effect on nuclear safety (see Chapter �2), as well as some noteworthy events in France and Britain which also had no direct implications but need to be heeded as warnings and dealt with in a formal way by those in charge.I would also like to highlight, in France and Britain, the overall good performance as shown by the main nuclear safety indicators, including fire, for instance the small number of scrams in France, better performance levels in the plants and more effective international benchmarking.These results, together with our improved generating results, will make all involved feel more calm and confident, with a positive effect on nuclear safety.

I also consider that EDF SA (France) has an independent nuclear safety organisation that is both strong and professional, fostering confidence in the level of openness expected of it. The intention of the EDF Energy (UK) management to set in place the same type of organisational structure and capability is also extremely positive.

Finally, the responsiveness exhibited by the Group’s different bodies and management teams affected by the Fukushima catastrophe, both in France and beyond, also needs to be commended, which is a good sign of an operator aware of its responsibilities.

As regards radiation protection, the 20�� results in the Group are satisfactory overall. I would like to draw attention to the consequences of the forthcoming major maintenance and modernisation jobs in France, which will necessitate an even more proactive approach.

As concerns safety in the workplace, it must be emphasised that our French results are still lagging considerably behind the best results internationally as determined by WANO and vigorous action is required. Here, I consider that manager action in the field, focusing on rigour in operations, is the key to durably improving the nuclear safety situation.

Although I appreciate the levels of performance, I have to sound the warning bugle as I have an issue to raise concerning the French plants.The warning is once more about the renewal of skills in the company's staff and contractor staff that work alongside them: we need to ensure the successful handover to the incoming generation while the �8 reactors continue to operate, we need to meet the massive demand for engineers required to extend the service lives of the reactors to sixty years, and we need to take appropriate action in the Fukushima aftermath. These challenges are obliging the company to prolong its current sustained and strenuous efforts. In such a context, it is important to draw attention to the overriding need to give priority to this action without compromising nuclear operating safety.

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While I am glad that concrete action is now being taken to give more responsibility to the plant staff and managers, while providing them with stronger backup at corporate level, I believe that much still remains to be done in this promising area which is so important to ensuring calm in the field: vigilance is required.

For the sake of the nuclear industry’s future, I would like to emphasise the importance of the EPR technology, which represents an unparalleled advance in nuclear safety, irrespective of any worksite and project-related difficulties.

Beyond these essential issues which I wished to give particular prominence, I treat in the next section “a panorama of 20��”, a wider range of issues concerning operations and engineering. In the chapters that follow, in greater depth, I tackle important technical themes which engage my attention.

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2A PANORAMA OF 2011

The year 20�� was marked by the aftermath of the earthquake and tsunamis that hit Japan on �� March, more particularly their effect on Fukushima Daiichi Nuclear Power Plant. The resulting damage caused loss of the heat sink and station blackout in all six nuclear units on the site. The accident showed that it is the operator which holds prime responsibility for the safety of a nuclear power plant. It also showed, once again, that the nuclear industry demands humility and above all rigour. I would like to mention the interdependence of the nuclear industry, where a local accident affects the entire world. In view of the scale of the accident, the consequences are indicated below and covered in depth is a later chapter devoted to the case. Here, I would like to express my compassion for the families of the tsunami victims and those displaced after the Fukushima accident, whose living conditions are still strongly affected.

In the wake of the accident, stress tests were demanded as early as the 2� March by the French Prime Minister and later by the European Commission. I note that the EDF Group submitted action plans and, in the following months, made a number of assessments as requested by the French and British authorities.The accident has left its mark on nuclear power plant staff everywhere. I would like to remind the upcoming generations who did not live through the Three Mile Island and Chernobyl accidents that the nuclear industry is special and that proper safety culture is vital in both design and operations.

In France

I note that, for EDF, the first challenge was to learn everything possible from the Fukushima case, but this was not the only one. EDF has set itself the goal of continuously increasing the levels of nuclear safety in its plants and to take the necessary action to extend their service lives to �0 years. Accordingly, the year featured twice as many ten-yearly inspections as in 20�0 as well as major maintenance operations such as steam generator replacement. I observe with satisfaction that these massive investments will be maintained over the next few years to support the French plants reaching mid-lifespan and to accommodate new nuclear and industrial safety requirements.In 20��, the French Nuclear Safety Authority ruled in favour of continued operation of Unit � of Fessenheim Nuclear Power Plant, which is �0 years old, for a further �0 years in accordance with the Nuclear Safety and Transparency Act on the condition that additional works were carried out. After Unit � of Tricastin Nuclear Power Plant in 20�0, it is the second nuclear unit to pass this milestone.

The nuclear power plant refurbishment will intensify from 20�� with the major works associated with the third ten-yearly inspections of the nuclear units belonging to the ��00 MWe series. In 20�2, I will be carefully monitoring this work, referred to as the General Refurbishment, with particular attention to the skills-related aspects. The work, which is to begin in 20��, will consist of two parts: replacement of certain key components during the ten-yearly inspections to prepare for plant life extension to sixty years and, as part of the periodic nuclear safety re-assessments, integration of improvements to strengthen prevention and the ability to survive severe accidents and external events, such as earthquakes and flooding. During my visits to the plants, I observed mobilisation to rise to this challenge, yet noticed some very worrying signs in the field reflecting recent discussion of the early withdrawal from service of some of the nuclear units. This is a source of anxiety, and I am worried about a possible impact on nuclear safety.

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2In the United Kingdom

I note a revival of the nuclear industry in the United Kingdom. In July, the British Parliament approved the National Policy Statement for Nuclear Power Generation. This confirmed the planned construction of nuclear power plants, including Hinkley Point C and Sizewell C, which would make EDF Energy the first nuclear operator to participate in the revival of nuclear power in Britain. The Nuclear Site Licence application was lodged with the British nuclear safety authority and is expected to be approved by the middle of 20�2.With regard to the Fukushima accident, I note a calm and phlegmatic response at odds with the reaction in some other European countries.

In the United States of America

I headed an inspection of Ginna Nuclear Power Plant, which has been in service for 4� years. It is operated by the Constellation Nuclear Energy Group (CENG), a company in which EDF has a stake. It is to be remembered that the EDF plants in France have an average age of around �0 years and are relatively young. I would like to point out that reactors of the same PWR design have already received licenses to operate for up to �0 years.I observe that CENG has appointed EDF to preside over the Operations Nuclear Safety Committee of its board of directors. The committee has notably cross-referenced and enriched the French and American experience feedback on Fukushima.I note that, this year, the company EXELON as made an offer to purchase Constellation, itself the majority shareholder of CENG (of which it has �0.�% and EDF has 49.9%). I will be watching with interest how this new situation develops.

In China

I re-visited the worksite for two reactors at Taishan, and met people involved in the project. Setting the metal dome in place on the first reactor containment was a symbolic step, and I observed the efficiency of the joint AREVA and CGNPC (China Guangdong Nuclear Power Company) design office in catching up the delay in producing the erection drawings. In the wake of the Fukushima accident, I approve of the changes in the reactor which reflect the French proposals determined for the Flamanville � EPR, with a few site-related adaptations.

The importance of natural events

After what happened at Fukushima, where a natural phenomenon has had such disastrous consequences, I remain particularly vigilant about the consequences of natural events on the nuclear safety of nuclear power plant fleets.Within the EDF Group, in 20��, the cooling water intake of Torness Nuclear Power Plant in the UK was almost blocked due to an excessive number of jelly fish. In Maryland in the USA, Calvert Cliffs Nuclear Power Plant experienced a substantial earthquake, followed by a four-day hurricane that momentarily halted one of the nuclear units. There were no consequences in terms of nuclear safety at either of the plants, as the installations were robustly designed. In France, after a long and severe drought in the first half of the year, EDF had to make special arrangements to avoid any impact on the generation of its plants. Experience feedback from the 200� drought and heat wave, and the fact that the weather conditions were not as bad as forecast, ensured that no particular difficulties were encountered in the course of the summer.

Outside the EDF Group, North Anna Nuclear Power Plant in the USA experienced an earthquake of an intensity that exceeded its design basis. After inspection and requalification of its two reactors, the Nuclear Regulatory Commission (NRC) licensed their restarting in November. Similarly, the floods that affected Fort Calhoun Nuclear Power Station and Cooper Nuclear Power Station in June for a number of months did not cause any damage as precautionary measures were taken well in advance.

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2Grounds for satisfaction

At the start of 20��, the �8 French reactors and the �� British reactors were all generating power. This is only the second time this has happened in the history of the French plants. Meanwhile, I note a drop in the number of unplanned inoperability cases in 20�� which, to a certain extent, is good in terms of nuclear safety and demonstrated the pertinence of the major investment in refurbishment since 200�.

2.1 The management

I continue this review with four initiatives that have caught my attention.

The 2020 Generation Campaign

This embodies the thinking of the management of EDF SA’s Nuclear Operations Division (DPN) and is an intrinsic part of the action to motivate the upcoming generation of staff. This new campaign is already having beneficial effects. The attention paid to the problems faced in the field has increased the ability of the plant management teams to function in a climate of calm. I also await the results of a campaign, which is being conducted by the same plant management teams in cooperation with EDF SA's Nuclear Engineering Division (DIN) and is designed to increase the synergy between the two divisions, particularly the availability of an engineering force for the plants in service that corresponds more precisely to the needs of the operator. However, I remain attentive to the risk of overloading the engineering force, which has an increasing number of technical projects to handle.

The Associate Directors for Operations

More than ever, prioritising activities as a function of the resources available is a fact of life for the management, in both operations and engineering. The risk now being faced is the likelihood of actions being left undone in the field without reflecting managerial choices. It is in times of need that corporate-level management is seen to be a necessity, although the excessive centralisation as I have mentioned in my previous reports needs to be avoided. For the DPN, the Associate Directors for Operations play an essential role of arbitration so the necessary adaptations can take place. I also call on the management teams to re-affirm the two basic principles of nuclear safety that become all the more important in periods of intense activity and change: a questioning attitude and the duty to remain on the alert.

Establishing priorities and increasing efficiency

I note that integrated management is becoming universal in the plants, without it having been specifically asked for at corporate level. This year again, I note that this management system fosters synergy between separate campaigns and clarifies the roles of the players, which makes it possible to identify and correct any shortcomings in the organisational structure. However, I would again draw attention to the need to preserve this performance-enhancing tool in the complex environment of the nuclear industry.The prioritisation system still seems to be insufficiently clear to the front-line managers. In the plants, the managers and planners appear to be those confronted with the most constraints.

A nuclear safety policy for the EDF Group

I am glad that a start has finally been made with writing the nuclear safety policy of the EDF Group. I would like to draw attention to the importance of deploying it with all the personnel concerned.

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22.2 The state of the installations

In France, the state of the installations is improving as a result of substantial investment. It is vital to sustain this effort as the plants are now in the middle of their service lives and we are lagging behind international standards.

The state of the nuclear generating facilities should soon reach the anticipated level at most of the sites. Rather than the change in appearance, it is the change in culture that I find most noteworthy. The experience feedback from the Better

Housekeeping Project managers needs to be assessed if the achievements are to be maintained in all the plants. I hope that the management teams maintain the levels of commitment that have made this project a success. Special attention is required in the case of costal sites where salt corrosion makes it more difficult to keep up to standard. I strongly recommend that the orderliness of the EPR construction site at Flamanville be the subject of constant attention by the DIN and that housekeeping be of the highest standard when the plant enters service. At the present time, it cannot be taken for granted that this priority is clearly imparted and shared.

Alongside the Better Housekeeping Project which relates to the generating facilities, I commend the efforts to adapt and refurbish the administration buildings as part of the nuclear site administration building green renovation project – known as the PARTNER Project - which is to run over the next ten years. This project has been eagerly awaited by both EDF and contractor staff. The improved living conditions at work that are expected to result from the project represent another step forward for nuclear safety.

2.3 Maintenance of the French nuclear power plants

In France, the next ten years will be decisive for the future of the French plants. A number of challenges need to be overcome to protect investments, to plan for plant life extension and to increase availability levels while continuing to make progress with nuclear safety. To succeed in this, the DPN has launched the previously mentioned 2020 Generation Campaign. I personally share the ambitions of this campaign which are to foster responsible attitudes in the staff regarding the state and maintenance of the facilities, as well as their work methods.

I emphasise the importance of the maintenance force alongside the nuclear unit operating staff in this campaign. With the plants half way through their service lives, maintenance has acquired strategic importance in keeping the safety levels of the nuclear units up to standard and protecting the company’s assets. In the recent past, equipment failures were affecting the performance of the nuclear units, which led to questions being posed about the maintenance strategies and the organisational structure. I observe that things have evolved, and that maintenance is now being given due consideration in the current changes.

During my visits, I noted a real willingness of the local staff, particularly the maintenance personnel, to get personally involved in the operation and maintenance of their equipment. However, in the current context of skill renewal and the launching of numerous campaigns that strongly affect the maintenance staff, particularly the planners, this change is difficult to implement. Everywhere I found the planning staff were heavily overloaded. The organisational structures are under pressure due to the amount of work to be carried out, the lack of prioritisation and the lack of resources. Allowance will need to be made for this in the General Refurbishment

planning. I will make a point of monitoring its progress in my forthcoming visits.

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2This year again, it needs to be said that the way work is organised is proving a hindrance and is ill-adapted to the expected increase in the company’s workload. However, I note that certain plants have begun to change things but this is far from being the general case.The planning of the unit outages, which will represent the main workload of future major refurbishments, is still not up to the desired standard. It is not yet being organised sufficiently in advance and manpower is not being assigned to it long enough before the outage is due to begin. I note that repetitive outage activities are still not sufficiently standardised.

Certain issues, which I believed were surmountable and already resolved, appear to be chronic and are complicating the work of the maintenance staff. Wherever I go, I hear about obsolete equipment and difficulties with obtaining spares.For the field workers I met, having spares available in due time is still a major obstacle. Even if the AMELIE spare parts management project may be beginning to bear fruit by streamlining the entire supply chain, much still needs to be sorted out. In addition to the difficulty in building up stocks and arranging distribution, there are problems associated with obsolescence of components and equipment. I am still struck by the number of recorders in the control rooms that still use rolls of paper in this digital age. It seems that there has not been proper forward planning in quality or quantity, therefore a paradigm shift is required. As the industrial environment constantly evolves, and as the plants are standardised, halting production of a component can cause critical problems and lead to events of the type that occurred this year with the diesel generators (see Chapter �2).

Many newcomers have joined the plant teams on a one-for-one basis in the maintenance departments since 20�2. This being the case, the managers must remain on the alert to ensure that these newcomers get a proper grounding in the basics of their profession and nuclear safety. In such situations, human performance practices constitute strong lines of defence. These need to be applied systematically.

Once again this year, I visited an EDF Joint Maintenance Agency. In our nuclear and conventional power stations, the Joint Maintenance Agencies carry out specialised maintenance operations where the financial stakes are high. They have always demonstrated their competence to the construction companies. Given their role, subcontracting is closed to them, which means that their managers must take an active part in maintaining skill levels in all areas. I cover this issue in detail in Chapter � which is devoted to training. As these bodies can step in to replace a failing supplier, they provide the EDF Nuclear Operation Divisions with a backup. At the present time, the Joint Maintenance Agencies are small teams totally focused on technical matters, consisting of highly motivated staff. It appears to me that their motivation mainly stems from the attractiveness of the posts. These are characterised by technology, quality, autonomy and variety.

Finally, as regards results, I note this year that a number of shortcomings in maintenance have come to light. Faced with the forthcoming increase in workload, the maintenance departments need to re-achieve the levels of quality that are to be expected of them in the nuclear plants and to be ready to meet the load. In 20�2, I will be particularly attentive to this during my visits to the plants.

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22.4 Relations with the French nuclear safety authority (ASN)

There can be no long-term acceptability of nuclear power without a strong nuclear safety authority. An appropriate balance of roles is essential between the operator and the safety authority, and in France, with their technical support, the Institute for Nuclear Safety and Radiation Protection (IRSN). I am aware of the importance of the high-level technical discussions with IRSN providing its in-depth knowledge of the EDF plants, yet the actual requirements need to be stated by the ASN. Confronted by

the numerous requirements of the ASN, I would like to draw attention to the importance of prioritisation, so as to avoid overloading the engineering forces.

The Fukushima accident

This year, relations with the nuclear safety authorities were marked by the Fukushima accident.

In all countries, it is the operator that bears the responsibility for nuclear safety, as the Fukushima accident reminds us. I appreciated the responsiveness of the EDF Group as a whole in first making a rapid review of its own facilities and then answering the questions put to it. In France, the supplementary nuclear safety assessments (stress tests) requested by the ASN required a lot of time and effort. They were submitted in due time. Confidence has prevailed and, in my opinion, EDF has demonstrated exemplary openness. The openness, expected by the French public, was cited by the High Committee for Nuclear Safety and Transparency (HCTISN). In particular, I note the opening of the nuclear plants to the members of the HCTISN and the Local Information Commissions during inspections conducted in the context of supplementary nuclear safety assessments. I note the similar work carried out in the United Kingdom by EDF Energy in consultation with the Office of Nuclear Regulation. I appreciate the consistency of the action taken by the French and British safety authorities in devising stress tests in Europe. The International Atomic Energy Agency's expert appraisal mission in Japan headed by Mike Weightman, the chief inspector of the Office of Nuclear Regulation, resulted in the publication of a detailed report on the events for the nuclear operators after an initial report from the Japanese government presented to the International Atomic Energy Agency.In the USA, I observed the power of the utility company lobby, expressed through the Nuclear Energy Institute (NEI) and the Institute of Nuclear Power Operations (INPO), and especially the strong commitment of the managers at the Constellation Energy Nuclear Group.

Relations in the field

During my inspections of the nuclear generating sites and the engineering centres, I noticed, more than previous years, difficulty in relations and the settling of cases by the ASN representatives working with the EDF teams. The business constraints faced by the operator and heavy workload of both parties during this busy period have greatly strained the relations between them. I remain convinced that substance must prevail over form.

Internal licenses

I note that no real progress has been made with the processing of generic modifications, as provided for in Article 2� of the Nuclear Safety and Transparency Act, although this would offer simplicity and effectiveness. I also regret that the scope of internal licensing, as provided for in Article 2� of the Act, has still not yet been broadened within EDF SA. It seems to me that progress is needed in this area, for although the requirements are stringent, it has the virtue of clarifying and simplifying relations between the operator and the ASN. I note that it is EDF’s desire to act accordingly.

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2 In the field of fuel, the plans are being assessed in terms of the scope and the manner of execution, especially with regard to allowing greater flexibility in operation. No conclusions have yet been reached, and I fear that this is no longer a priority after the Fukushima accident. In the field of decommissioning, effective internal authorisations have long been implemented in a responsible manner.

Other issues requiring attention

I concur with the French nuclear safety authority, which has identified two sensitive issues for the nuclear plants: industrial safety and environmental protection. Concerning the first, which is covered in Section 2.�, I have been alerted to the difficulties of the plants in their relations with health and safety inspectors. Despite considerable progress, environmental protection remains a delicate issue. I share the ASN’s view that progress remains possible with the discharge of chemical effluents, as has been possible with the releases of liquid radioactive effluents over the last few years. Interfacing between chemistry, operations and maintenance needs to be improved.It is important to also be aware of the difference between the scale of the risks associated with nuclear safety on one hand, and with industrial safety and protection of the environment on the other. The consequences for the general public are of another order of magnitude. It nevertheless remains true that excellence in nuclear safety means excellence in industrial safety and protection of the environment, for all the professions involved.

Official Inspection Departments (SIR)

This year, for the first time, I met the EDF managers and inspectors of the SIRs in the plants. Charged with issues relating to staff safety, they check, on behalf of the plant director, all pressurised equipment using the powers delegated to them by the government. They report directly to the plant directors to assure their independence, and their recommendations may necessitate arbitration at the highest level in the plant.I recommend the greatest vigilance concerning the management of skills in the SIRs and maintaining their independence. Indeed, ensuring the SIRs have sufficient manpower remains difficult, lengthy training is required and potential replacements need to be identified at an early stage to ensure that the posts are filled. Corporate-level promotion of this profession needs to focus more on collecting data in the field and the management and resolution of technical difficulties.

Relations with the nuclear safety authorities

For an international group like EDF, relations between the different nuclear safety authorities are a vital issue, and will become all the more so in the future with the approval of the nuclear safety submissions for EPR-type reactors in China and the United Kingdom. I am surprised that the national authorities responsible for setting the goals for nuclear safety and checking that they are met do not cooperate more actively. It should be possible to overcome this difficulty now that the Fukushima accident has led the safety authorities to cooperate more closely. I note that the ASN is working towards this by seeking harmonisation that could build on the foundations laid in the context of the Western European Nuclear Regulator's Association (WENRA) and the International Nuclear Regulator’s Association (INRA).

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22.5 The EPR projects

The third-generation EPR technology is specially designed to offer a significant advance in nuclear safety. Four such reactors are under construction in the world, and two have reached design stage in the United Kingdom: all these projects are being attentively watched in France and beyond. These projects are complex and require special skills. During the worksite period, like this year, or later during operation, regular progress and success with Flamanville � are vital for favourable outcomes with the other projects, for they all greatly depend on each other.

The scale of the Flamanville � project and the project management constraints have resulted in many difficulties in carrying out the site work and in the procurement of equipment. EDF recently announced that the commercial operation of Flamanville � has been put back to 20��. Major changes in the way the project was organised were made as early as 20�0, which clearly re-established, as I have previously pointed out, the division of responsibilities between the different players, particularly regarding the design issues. New resources for establishing a detailed schedule of the activities have been set in place. Concerning this point, I am glad to see that the ten main suppliers of the project, associated in a coordination group designated F�0, were involved in drawing up the project schedule. I would like to encourage them to continue and intensify their collaboration. This major task of scheduling and coordination is throwing light on the way the project is managed in terms of the risks, the schedule’s critical path and what is at stake.

In light of these EPRs under construction and how important it is to successfully complete Flamanville � in line with its new schedule, I question the need to maintain certain operating objectives that are specific to the French plants, such as load following and nuclear unit controllability, as these demand numerous ad-hoc nuclear safety studies being carried out specifically for Flamanville �.

Conversely, I hail two important innovations of the EPR project with regard to nuclear safety. Firstly, the objective set by EDF and its Chinese partner to qualify the EPR-type reactor's equipment for the consequences of severe accidents before unit start-up, despite that fact that this considerably augments the workload and the constraints on project management. Secondly, in the field of human factors, performing simulator-based qualification under real conditions before commissioning the man-machine interface of the computerised control room. From the point of view of nuclear safety, these two initiatives appear to be exemplary.

This year, I visited the EPR-type reactor worksite in Taishan in China. The dependence of this worksite on the Flamanville � one is striking, even though some of the building work, particularly the civil engineering, is different. From the presentations I was given, I gathered that the very recent feedback from our Chinese partner on the commissioning of the Ling Ao Nuclear Power Plant units led to the formation of testing teams at a very early stage so as to plan the procedures and tests for commissioning Taishan �. Contacts between the Flamanville � test teams and their Chinese counterparts concerning this issue could be worthwhile and in all probability profitable.

This year the Flamanville � worksite was the scene of some serious events, including two fatal accidents. Work safety, like the quality of the work, is the subject of special attention by the management and its desire to get things back on an even keel is all the greater as the erection of the mechanical and electrical equipment is about to begin, although the civil engineering phase is not entirely complete. Be this as it may, during my visit to the worksite, the state of the installations was not yet up to the announced standards. I wonder what means are available to the local managements with regard to the design services of the project team and subcontractors to get things changed and to guarantee quality and industrial safety during the erection work. I would also like to draw attention to the risk of

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2corrosion at this coastal site, as the preservation of equipment and the protection of the plant areas do not yet appear to be given sufficient priority.

The operator is already on site, with almost full staff numbers for nearly two years now. They are getting everything prepared, but the new schedule has caused them disquiet and even anxiety. Some of the simulator training programmes need to be changed, and staff turnover will begin before the plant has even started up, which I find worrying. Moreover, the schedule still does not yet make it possible to see far enough ahead to establish the content of the planning for commercial operation.I am also surprised that, in France, the management of such a project is entrusted to two different divisions. Throughout the project, the construction teams of the Nuclear Engineering Division and the operations teams of the Nuclear Operations Division report to different managements. This results in the sub-optimal use of manpower at a time when it is scarce. I note that, in the projects involving EPR-type reactors in England and China, the teams are combined from the start: multidisciplinary teams are considered positive in terms of quality, effectiveness and nuclear safety. Given the current arrangements at the worksite, I would encourage the Flamanville � teams to cooperate more during the erection and pre-operations phases.

The Flamanville � EPR showcases the EDF Group and I have been concerned to learn that it may not reach the latest standards existing in the other French plants as regards fire safety and the state of the installations (Better Housekeeping Project, O2EI).

Success with Flamanville � is a daily challenge with a direct bearing on success with the other EPR projects. The experience feedback from France, China and Finland is a key asset for the EDF Group that needs to be fully exploited.

2.6 The players in the fields of health and safety

This year, I continued to meet medical staff, essentially doctors and health and safety inspectors, in both France and the United Kingdom. They are the key players in the field of health, but also as concerns management of psychosocial risks, quality of life and industrial safety.The health of company and contractor staff is one of the main concerns of the EDF Group. I emphasise that industrial safety cannot be separated from nuclear safety and has to be given the same priority. The international approach, and that of EDF Energy, is leading EDF SA to increasingly consider industrial safety as a meaningful indicator of rigour in everyday operation, and hence of nuclear safety culture.

The medical staff and their working conditions

Relations between the medical services and the plant management staff have generally improved in recent years, which is highly important. In almost all the plants I visited, I encountered medical practitioners who were willing to work openly with the management staff. These crossroads of cultures, where health, industrial safety and radiation protection meet give greater depth to risk analysis and the resulting decisions. It offers leverage in achieving progress for the managers and the occupational health staff. I encourage the management teams to develop closer links with the medical practitioners.

In the field of radiation protection, these relations help:

the medical staff to actively contribute to prevention and exercise their medical surveillance in a pertinent manner, adapted to the actual risk levels,the radiation protection staff to gain a clearer understanding of human, organisational and technical matters.

I am keeping a watch on the workloads of the medical staff charged with monitoring the plant staff, as well as Radiation Worker Accreditation (DATR) for the increasingly numerous contactor staff. This monitoring, which the contractor joint medical services are not all empowered to provide, involves

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2some �,�00 contractor workers who are concentrated at certain sites. It is to be remembered that the medical staff will need to be able to perform this task in the next few years when there will be an increase in the amount of maintenance work and the contractor joint medical services will be faced with recruitment problems. I note however that the arrival of the new Type C2 controlled area exit detection portals should reduce the demand for whole-body counting.

Quality of life and psychosocial risks

Subsequent to the agreement which involves preventing psychosocial risks and improving the working lives of EDF SA staff signed on �0 November 20�0 by three trades unions, I observe that the initiatives to protect and improve the life and health in the workplace, some of which were already in hand under a prior agreement within the Nuclear Operations Division, are continuing. Wellbeing in the workplace fosters nuclear safety and it is indispensable to go further with this action, and for the managers to be more directly involved in it.

Alcohol and drugs

I have previously stressed the importance of the measures to bar anyone under the influence of alcohol or drugs from the workplace. In France, the awareness of the problem has increased, but the requirements of the Nuclear Operations Division management, including random alcohol testing, are not being applied with equal rigour everywhere. As concerns drugs, detection is at the discretion of the occupational physician alone, which is insufficient in my opinion.Meanwhile, in the United Kingdom, EDF Energy has set itself the goal of checking 20% of the personnel for alcohol and drugs every year, including contractor staff. The plant managers are informed of the results, which can entail medical surveillance and even loss of accreditation for violators. The statistics show a year-on-year increase in the number of violations. This trend, which is also observed in comparable countries, should lead us to call the current French policy into question. In the USA, the policy is similar to that in the UK.

Industrial safety in France

The constant efforts to mitigate risks have helped to progressively reduce the frequency of occupational accidents. Although the incidence of such accidents has been reduced by a factor or two over the last ten years, the figure in France stands at �.8 per million hours worked for EDF and contractor staff, which is well above that for the nuclear industry as a whole. In 20��, the figures did not improve, and there were three fatal accidents: two on the Flamanville worksite and on Gravelines Nuclear Power Plant. It is however to be noted that the Production and Engineering Directorate (DPI) conducted an industrial safety

assessment.The results call into question the adequacy of the risk management and mitigation. The involvement of the management teams at the highest level remains insufficient. I call on them to clearly announce this as a priority in the field. The contractors need to be involved in this initiative.I feel sure that extending the scope of the overall assessments of excellence by the Nuclear Inspectorate to the field of industrial safety will help to ensure that better results are obtained. On a plant level, I consider that the profession of health and safety adviser in the risk mitigation services needs to be given more prominence.

British Energy (now EDF Energy) setting an example since 2005

Although starting from a frequency factor of �.8 occupational accidents per million hours worked, when this figure doubled at the beginning of 200�, the company took some decisive action. Rules

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2of behaviour were laid down at the highest levels of British Energy and the main contractors. These reiterated the rules on alcohol and drugs, as well as the need to maintain a questioning attitude, to use one's own professional experience to plan activities, to use personal protective equipment, to organise experience feedback, to refuse a non-secured work area, and to compare one's self with and accept the challenges of others. In 20��, the frequency factor dropped to 0.�.

2.7 Radiation protection

For the EDF SA's nuclear plants, there was a heavy maintenance operation workload with 9 ten-yearly outages, more than twice as many as the previous year.

Collective dose

The plants have entered a period of cyclic oscillation of the collective dose synchronised with the maintenance outage profile. This oscillation lies within the band corresponding to the international results for reactors of equivalent technology. The increase in worker exposure time when all other factors are unchanged therefore automatically increases the collective dose per reactor, which increased from 0.�2 man-sieverts in 20�0 to 0.�� man-sieverts in 20��.In some of the plants, I note with satisfaction that the operations designed to reduce the mean values of the dose equivalent (source term) as part of the ALARA approach. These operations are, in some instances, occasionally affected by the presence of particles emitting radioactivity or systematically affected by certain maintenance operations.

Individual doses

Individual doses continued to drop among the professions with the highest exposure (scaffolding erectors, heat lagging workers, welders etc.). This improvement can be ascribed to the revival of the ALARA approach, which accompanies work area dose optimisation. The number of radiation workers whose dose over twelve months exceeded �� mSv continued to decrease, with two cases reported in 20��.

Events in 2011

Two radiation protection events were classified as Level � on the International Nuclear Event Scale, one of which occurred during a maintenance operation when a worker’s hand was irradiated, corresponding to a skin dose of 4�0 mSv, close to the regulatory limit of �00 mSv. I note stability in the number of significant radiation protection events. I recommend, once again, greater rigour with certain issues, such as: access to red and orange radiation hazard areas, the wearing of personal protective equipment in radiation hazard areas, radiography work, the planning of jobs in controlled areas and work in the reactor and fuel building pools. I note that the field work processes have been reinforced in the plants but behavioural patterns still indicate difficulty in adaptation.As the ten-yearly outages involve a considerable amount of maintenance work and scheduled testing, they are accompanied by a great increase in the amount of radiography. Similarly, at the Flamanville � EPR worksite, the start of mechanical equipment erection has resulted in a strong increase in the amount of radiography, with the operations complicated by the great number of different professions being present and some individuals having little awareness of the high risks associated with the work. Although the overall level of management of these activities improved substantially in 20�� in all the plants, a number of narrowly averted incidents indicate the need for greater vigilance. I thus regret that the Radiation Protection Surveillance Station that is planned to be installed in every plant has been re-scheduled whereas many plants outside France have long had them.I also note recurrent violations of the restrictions on access to radiation hazard areas for service personnel with temporary employment contracts (temporary workers and fixed-term contract workers). The situation did not improve in 20��. It should be possible to solve EDF’s administrative difficulties under a framework agreement on “socially responsible subcontracting in EDF” proposed to the

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2contractor companies in France. I consider that the situation absolutely must be brought under control as soon as possible.The need to control the source term has led some plants to envisage joining the campaign to enable entry into controlled areas without a special protective suit (EVEREST Project), long since adopted by a few pilot plants (Golfech, Civaux and Cattenom Nuclear Power Plants). This project, which I strongly support, consists in ridding the radiation hazard areas of contamination and any significant sources of radiation, hence accessible in normal working clothes. In the three pilot plants, this initiative has made it possible to stay longer in the radiation hazard areas and thus increase the time spent on the job (see Chapter 9) and supervisor presence in the work areas. It is supported by all those working in the plants, despite the difficulty in achieving the situation, which necessitates setting in place a new organisational structure for logistics and field work.

Finally, I suggest that particular care be paid to upgrading the health and safety professions in general and that of radiation protection in particular, as well as to preserving, or even strengthening, the necessary skills so as to avoid the stop-and-go in the recruitment process seen in the past.

EDF Energy’s plants are mainly advanced gas reactors (AGRs) which generate lower collective and individual doses than pressurised water reactors (PWRs). The 20�� results are satisfactory. The collective dose stands at 0.�� man-sieverts per reactor. The greatest challenges in 20�� were the refuelling and maintenance outage of Sizewell B and work on the reactors of Hunterston B, Hinkley Point B and Heysham B.As in France, the individual doses are the subject of considerable attention. The highest annual individual dose was �.�2 mSv.The plants have been equipped with new detection portals at the exits of controlled areas that can detect very small traces of contamination, in accordance with international standards.The number of significant radiation protection events was the same as in 20�0. None involved a significant internal or external individual dose level or reached a level which required special reporting to the authorities.

2.8 Fire prevention and fire fighting

I am glad to be able to report that the 20�� nuclear safety results were positively affected by a significant drop in the number of fires.In the EDF-SA plants there was a fire in a transformer that confirmed the relevance of the organisational system combining the nuclear plants and the county accident response services (French acronym SDIS).

In the French plants, the fire brigade officers seconded to each plant are becoming a regular feature and the renewal of the first generation is proceeding smoothly. After background work on organisation and response, this new generation will need to focus on prevention and the quality of the exercises and drills, in which I have observed a certain lack of motivation among the participants. More varied exercises and drills carried out in radiation hazard areas are needed to improve the performance levels.

Although the fire fighting organisation has remained at the level that is extremely satisfactory, in the plants I observe slower progress in the uptake of prevention culture among the field workers, particularly contractor staff. The result has been that the number of fires of human origin was still too high. In the great majority of the plants the Better Housekeeping Project and the campaign to control fire hazards launched by the Nuclear Operations Division improved fire hazard mitigation, especially as a result of the strict rules about forming packages during unit outages. These arrangements facilitate the progress of the response forces and improve the way products and equipment are placed in interim storage in the facilities. I observed that the number of false fire alarms had decreased, increasing the

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2credibility of the detection system as a whole. I regret to say that I also noticed that the second-line response team is not always at full strength when alarms have gone off.Checking the fire compartmentation system - the cornerstone of French practice - is again encountering difficulties due to obscure problems with databases in certain plants. This situation has been going on too long and needs to be rectified as soon as possible.

When I met the management team of the AMELIE spare parts management campaign, I was pleased to see that the organization of the fire-fighting arrangements for the general warehouse at Velaines had been set in place conjointly with the county accident response services as per nuclear plant practice and that EDF had contributed additional equipment to the nearby fire station.

2.9 Increasing nuclear power plant security

As was decided in 200�, the security of the French nuclear plants is being stepped up by the military police. The process is to be complete during 20�2, and 2 of the 20 plants are still awaiting secondment of personnel. For the remaining �8 plants, locally organised squads of specialised military police guards are now operational, their quarters have not yet all been built but work is advancing.Both the military police and EDF have expressed their satisfaction. During my visits, I observed the presence of military police on duty inside the plants. This calls for two observations: the EDF and contractor staff accept this new situation that had long been apprehended, and the EDF plants are now much more like what I see to be reasonable in other countries. The new arrangements also facilitate the administrative procedures involved when issuing authorisations to enter the plants. The procedures of EDF, the military police and the local authorities are optimised in a satisfactory way.The security installations have been reinforced and many of the old ones have been replaced. The working conditions in the surveillance stations of the security facilities have been significantly improved.Intrusions by an international association on � December 20�� were widely reported in the media, which was the intruder’s goal. I consider that such irresponsible and unacceptable acts in no way reflect any vulnerability of the system set in place by EDF and the military police. The intruders were unable to gain access to any sensitive areas and the guards handled the matter with discretion.However, more generally, it is once again my impression this year that the coordination between the Group’s security management, the Nuclear Operations Division security committee, the Nuclear Engineering Division’s engineering support (in the Electromechanical Department) and the local site protection services deserve an organisational system more close to that adopted for nuclear safety and the associated oversight.

The year was marked by a number of security-related inspections of the plants by the High Commissioner for Defence and Security (HFDS) attached to the Ministry for Ecology, Sustainable Development, Transport and Housing (MEDDTL)

I also note that, at the end of 20��, at the request of the French government and in agreement with EDF SA, the IAEA conducted an International Physical Protection Advisory Service (IPPAS) inspection, created by the IAEA to assist states in strengthening their nuclear safety rule set with particular reference to site security at Gravelines Nuclear Power Plant. On this occasion, it stated its findings and recommendations in terms of coherence with the international rule sets (INFCIRC/22�/Rev.� Guidelines) and the best international practices. As is the case with visits of this type, it will be followed up with visits to check that the recommendations are being integrated and to provide assistance as appropriate.I am glad to see that, as in the case of nuclear safety, this field is being opened up to outside appraisal.

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22.10 Decommissioning

The only nuclear generating facilities under decommissioning in the EDF Group are located in France.

This year, I visited the decommissioning site of the first French pressurized water reactor, located in Chooz in the Ardennes. The dismantling of this somewhat special facility, the nuclear part of which is located in a cavern, has been going on for a number of years. The work, begun in 20�0, now mainly relates to the reactor coolant system. The steam generators were being decontaminated to reduce their status on the nuclear waste scale. With the Nuclear Engineering Division acting as client (the Nuclear Environment and Decommissioning Engineering Centre, CIDEN), the work is being carried out by contractors, who have

to acquire the skills and experience necessary for such work that is highly specific to the four types of reactors under decommissioning: heavy water reactor (Brennilis), pressurized water reactor (Chooz), gas-cooled natural uranium fuelled reactor (Bugey, Chinon and Saint-Laurent) and sodium-cooled fast reactor (Creys-Malville). The work represents an interesting challenge, demanding new industrial solutions to specific technical problems. Finding solutions for permanent disposal of the different types of waste is complicated by the social and political climate in France, and can result in delays in the decommissioning work or the creation of costly interim storage facilities. This was recently the case at Brennilis where work was resumed in November 20��.I observe that EDF’s policy of decommissioning as soon as possible is now confronted with administrative, legal and technical obstacles that are being exacerbated by non-governmental associations and by the government authorities in the case of the treatment of radioactive waste.

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NUCLEAR SAFETY MANAGEMENT

The commitment of the managers, at every level of responsibility in the company, is now clearly perceptible in the EDF Group's plants. The need, however, for proper prioritisation of projects is not yet sufficiently visible by staff in the field. Giving more responsibility to local managements would increase the effectiveness of action and reassure the staff.

Nuclear safety management must be designed to ensure good results both in the present and the future.Although the results again this year are basically satisfactory with real success in some areas, I have made a point of identifying areas where progress needs to be consolidated and where improvement is needed to plan ahead for the results of the future.

A nuclear safety policy for the EDF Group

I am glad to see that a start has been made on drafting the first EDF Group nuclear safety policy, covering all entities responsible for nuclear safety in EDF SA in France, EDF Energy in the United Kingdom, the Constellation Energy Nuclear Group in the United States and the Taishan Nuclear Power Company Joint Venture Company in China (in which EDF has a �0% stake).Its official release in early 20�2 will make it possible to re-assert, at the highest level, the absolute priority being given to nuclear safety under all circumstances and in all places, as well as EDF's commitment to strengthening the role of WANO after the Fukushima accident. It will also make it possible to re-state, if not clarify, the different levels of responsibility for nuclear safety in the organisational structure of the EDF Group. I encourage all managers of operations departments, power plants and engineering centres to take the opportunity of its publication to re-affirm that nuclear safety is paramount in every action of all the employees of the EDF Group and of its contractors.

Responsibilities of nuclear power plant directors

I note that the head of departments, especially in the power plants, need to feel that they are being listened to, understood and properly supported in their delicate task.The principle of subsidiarity, clearly announced at corporate level, is now adopted, with a better balance between the respective duties at corporate level and at plant level, where the operations responsibilities are the most direct.The introduction of the Associate Directors for Operations attached to the directors of the Nuclear Operations Division is a good example of this. Their prerogatives make them the official representatives of the nuclear power plant managements, with real power to arbitrate in the prioritisation of activities and the disposal of resources. Their main focus is the plants, of which they have an intimate understanding, which is of vital importance when managing a set of nineteen. Their job, which extends to all areas of integration, has the basic purpose of facilitating the work of the plant directors without absolving them of their responsibilities.

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Further increasing subsidiarity

This innovation is comparable to the arrangements in place for a number of years in EDF Energy, with three Chief Nuclear Officers for 8 plants. The latters’ role is however more focused on everyday performance management and, as there are few plants, they take a very active role in the field.

I consider these changes to be very positive. It needs to be made sure that they become permanent and, more generally, that this new subsidiarity remains within a well-defined context.

An independent organisation well-respected in the plants

One of the characteristics of the nuclear industry in France is the existence of an independent checking network with special skills alongside the managerial hierarchy: the Independent Nuclear Safety Network. This network is active at three levels: generating plant or engineering centre, operations division and the top of the EDF Group.I find that this Independent Nuclear Safety Network is robust and staffed with qualified personnel, in almost all the plants that I visited. It is heeded by the plant directors who regularly organise meetings with the heads of the Nuclear Safety Advisory Units and the Safety Engineers.I also observe with interest the EDF Energy initiatives to upgrade the “real time” nuclear safety checking systems in the plants, which need to be reinforced.In 20��, benchmarking with two French nuclear plants, followed with an experiment involving three British plants bore witness to the way fruitful exchanges are developing between the operators of the two different sets of plants.

A need for process skills

I would, however, like to point out the need for vigilance about the renewal of safety engineering skills and the frailty of the local audit teams. With the necessary operations skills in short supply, young engineers are filling Safety Engineer positions to an excessive degree.

The inspection programmes are carefully designed and scheduled for the year in accordance with a framework laid down at corporate level. I note that the framework leaves little margin for initiative in local checking, which should be examined, and I especially wish to again stress the improvement in the quality of the annual diagnostics carried out by the plants. For example, the plants establish their Annual Nuclear Safety Analyses by combining the different perspectives of the management and those of the Independent Nuclear Safety Networks.

I consider that the Local Safety Committees offer powerful leverage for progress, offering forums where views can be openly expressed by plant managers and assist in the decision-making process.

In other countries, I also meet operators that seek to reinforce their independent checking capability, at both plant and corporate levels. The staff working for the Chinese operator CGNPC, the South African operator ESKOM and the Russian operator Rosenergoatom, all have cooperation agreements that link them to EDF, principally with the Nuclear Inspectorate of the Nuclear Operations Division, and show a growing awareness of its importance.

The authority of the operations shift managers needs to be reinforced

In the nuclear power plants, the operations shift managers are responsible for conducting nuclear safety checks 24/�, under power delegated directly to them by the plant director. I note that this delicate task is respected in the plants, and that it is performed with competence and proper awareness of the responsibility. These key players also have the job of ensuring that operations are proceeding correctly, by supervising the activities performed in the nuclear units and handling the associated arbitration and prioritisation.

In France, I wonder about the ability of the operations shift managers to take stock of the situation as they are sometimes completely taken up with the current issues or activities that should be entrusted to

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others. Their counterparts in nuclear power plants in other countries, particularly the USA and the UK, appear to be calmer in performing their everyday tasks, having broad and effective support; they are able to step back from the situation to the benefit of this “line of defence”.

During my visits to the nuclear power plants, I also noticed how a special direct relationship has been reinstated between the plant director and the operations shift managers. This makes it possible to effectively mobilise the shift teams about the nuclear safety goals, and operations in general. This type of link between these two management levels is vital for proper control over nuclear safety in operations and thus merits special attention.

Deciding in perfect safety

I also consider that special attention needs to be paid to the proper functioning of the decision-making processes related to operations in each plant. In these processes, the operations shift manager must always be the final decision-maker, and benefit from the indispensable support of expert advisers, if not the plant

management. The proper positioning of plant management level decision-makers (designated PCD� in the on-call rota system) merits the same attention.

I note the desire of the Nuclear Operations Division in France to give new life and effectiveness to the flagging Nuclear Safety, Radiation Protection, Availability and Environment Watch (OSRDE) initiative by recreating it in a simpler form so it can be used more often. Originally introduced by one of my predecessors, this initiative draws on concrete examples and encourages the nuclear operator to regularly assess the relevance of trade-offs made in the past that have implications for nuclear safety. I consider that, with the wave of new plant managers arriving, the need to revive this initiative is pressing. The same applies in EDF Energy and the Constellation Energy Nuclear Group, where operational decision-making reflects this (see Chapters �0 and �2).

Motivated managers in the plants

Once again this year, I observe the high level of commitment and motivation of the managers in all the plants visited. On all fronts, performing what can be a thankless task, they deserve special attention on the part of the plant managements.

I am glad to observe that proper training programmes for managerial positions are now becoming available and are universally appreciated. In this context, the EDF Energy programme for the development of leadership is truly remarkable. The stated intention of focusing the manager on their profession and on operations accurately reflects their aspirations and the needs of their teams. Yet, when I meet the front-line managers, they readily mention the difficulties they have with everyday logistics and the increasing deadweight that they call bureaucratisation. I again wish to draw attention to this real problem, which needs to be solved by resolute action. In accordance with international practice, the good practices that I observe in some plants consist in setting up dedicated advisory support in the departments; they merit further development.

Performance indicators

I would like to first emphasise the joint work carried out this year in the French and British plants to better establish coherent performance indicators and thus make benchmarking more meaningful (see Appendix �4).In the French plants, the number of nuclear safety significant events declared in 20�� remained high (at �0.� per reactor), although there was a perceptible drop in the number of events ranked Level � on the International Nuclear Event Scale (0.9� per reactor). This positive point is to be borne in mind, despite the declaration of one nuclear safety significant event at INES level 2 (at the beginning of 20��) after equipment failures in some of the 900 MWe series reactor standby generators (see Chapter �2).

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In EDF Energy, the number of nuclear safety significant events declared in 20�� dropped (4.� per reactor), with different declaration rules in France and the United Kingdom reflecting the requirements of their respective nuclear safety authorities. The number of events ranked on the International Nuclear Event Scale (all Level �), which is more directly comparable, was higher than in 20�0 and higher than in the French plants (�.� per reactor).

I consider that the degree of transparency in EDF SA and EDF Energy is satisfactory. It is based on more rigorous detection of minor discrepancies in the field, by the technicians themselves, and on unambiguous managerial practices reflecting solid nuclear safety culture.

Three results are particularly noteworthy, as they illustrate the return on investment in the action taken some years ago at both corporate and plant levels, relating to key issues: reactor scrams, compliance with the technical specifications for operation, and fire.

Reduced number of scrams

A record to beat

This year, the number of scrams in France was particularly low (0.�0 per reactor per year), the lowest level ever recorded in the French plants. This result places the EDF’s French reactors on an equal footing with the best in the world, with 38 reactors where not a single scram occurred during the entire year. It

is the result of long-term action taken over a number of years to improve both the reliability of equipment and human action. However, this year I note a higher proportion of scrams of human origin, suggesting that the Human Performance Campaign might be running out of steam, in terms of the practices designed to increase reliability.

At EDF Energy, as in the United States, there is a risk of lumping automatic scrams and manual shutdowns together, as the operating practices are different. British procedures more frequently require the operators to trip the reactor manually, before automatic action is triggered. The 20�� results are stable compared with the previous year (�.9� per reactor) and still not as good as the best results worldwide.

Managing the operations rule set

In the French plants, compliance with the technical specifications for operation (the nuclear operator's ‘highway code’) achieved its best levels since 2004. The support and training work undertaken in the plants meets the requirements very well, which explains these results. I recommend that these good practices be made permanent. The reduced number of excursions outside the authorised operation envelope, a point that I emphasised in my report last year, has also contributed to greater compliance with the technical specifications for operation and reflects the progress made with directing operations from the control room.

At EDF Energy, the results are stable in this area, without re-achieving the high performance levels of 200� to 2009. This represents one of the main avenues of progress that the British plants are taking.

Managing the fire risk

I would like to again emphasise the good results of the EDF plants in the area of fire (see Chapter 2), as this hazard represents a major issue and calls for determined action.The reduced number of fires in 20�� is spectacular (nearly 20%) and shows the relevant action taken in recent years. The plants all have excellent organisational systems in place to address the fire hazard, relying on a network of professional fire brigade staff (one per plant), and close cooperation with the county accident response services.

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Fire prevention, especially in work areas, has not yet attained the level intended but fire action plans are in place everywhere and are being monitored.I note that arrangements have been made to ensure that the campaign to control fire hazards is made permanent which gives me confidence that this ambitious programme will be taken to completion. This is a clear illustration of the level that any responsible operator can achieve when pressed by the nuclear safety authority.

In the United Kingdom, the results were also good, with a significant reduction in the number of fires. The peer reviews, however, carried out by WANO in the last two years in the plants have frequently revealed weaknesses in the maintenance of the fire systems and management of the fire loads.

My main concerns

Sub-standard maintenance in work areas and sub-standard control of operations - most related to alignment and system configuration - are still too frequently coming to light in the directing of operations from the control room, demonstrating that the core skills are still insufficient, if not deteriorating. In a context of particularly high staff turnover, the acquisition of proper professional skills must be a priority.

Relevance and professionalism

I am most concerned about the common causes of these discrepancies which, all too often, reveal problems with the supervision of contractor work, failure to properly understand certain risk analyses, and technical checking by EDF staff that is not up to standards. In coming years, major efforts will be required to

reverse this trend.

Going the whole way with the actions in

progress

The use of error prevention tools, despite an unprecedented training drive in recent years, is still not sufficiently widespread. Certain professions are doing well, such as automation and fuel handling, but there is still a long way to go to close the gap between the practices observed in the control rooms in France compared with EDF Energy.

I am aware of the scale of the action taken, but consider that attention must also be drawn to the risk of burnout with the Human Performance Campaign if the managers do not more clearly express their requirements concerning these new practices. I consider that priority must be given to the changes in the operating department.Finally, while I am glad to report the reversal in the trend as concerns excursions outside the authorised operating envelope, I also have to report the recurrence of significant events involving reactivity control, particularly during reactor coolant dilution, as mentioned in my previous report. Determined action is required here to ensure proper training in carrying out such operations, which must in no case be standardised. The event described in Chapter �2 illustrates this type of issue.

An evolving corporate-level checking system

The Nuclear Operations Division relies on a solid nuclear safety process. Annual reviews make it possible to clearly establish the major issues by analysing the events in the plants in service and accurately determining the policy needed to improve matters, which are stated in the Annual Performance Contracts of the plants. The strengths and weaknesses of the plants identified in this work are good to know. The timing of the process has been revised and is now situated before the plant nuclear safety reviews, which are increasingly being linked to the standard timetables for the reviews of the Integrated Management System. This change has been made to accommodate a pressing need of the plants, who are adopting the Integrated Management System in increasing numbers. This enables priorities to be established further in advance, hence scheduling the action plans earlier in the year.

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I note with satisfaction that, this year, the nuclear inspectorate was able to complete its checking programme, unlike in previous years, as I have previously had cause to regret in my reports. The significant increase in the number of inspectors is the main reason. It now remains to ensure that this positive development remains a permanent one.I take note of the decision to simplify the arrangements for checking the plants, by converting the overall safety reviews into overall excellence reviews. These overall excellence reviews - more broadly covering operations, for instance safety in the workplace and generating capacity - will be carried out every four years in each plant, alternating with the WANO peer reviews, the frequency of which is now changed to every four years (previously every six). Each plant will thus be evaluated by the nuclear inspectorate or by WANO teams every two years. This is very gratifying, and comparable to what is carried out by the Institute of Nuclear Power Operations (INPO) in the United States, for instance. I would also like to draw attention to the priority that must always be given to nuclear safety in these assessments and the need to provide the additional resources of adequate quality.

The reinforcement of resources made available to WANO, which was decided in 20��, to enable it to better conduct its nuclear plant assessment activities throughout the world will also require the secondment of experienced staff from the plants. I believe this issue will need to be monitored closely in order to satisfy these demands.

The Nuclear Engineering Division’s nuclear safety checking system, provided by its Assessment and Support Unit, is modelled on the nuclear inspectorate and still appears to be pertinent. It is also necessary to have sufficient inspectors to properly perform its duties.

At EDF Energy there is no internal inspection service that can make large-scale audits or assessments comparable to the overall safety reviews. The choice was made to rely on the WANO peer reviews for checking the plants, these being carried out every three years and featuring an external viewpoint. At corporate level, the Safety and Regulation Department possesses substantial engineering resources providing a clear picture and analysis of the results and the nuclear safety trends in the plants collectively and individually (comparable to the task performed by the Nuclear Safety Performance Group in the Nuclear Operations Department). Its linkage, with resident inspectors in the plants, remains perfectible and I note with satisfaction that, as mentioned, its strength is being reassessed, including reinforcement of the plant inspection teams.

The major projects are better prioritised yet the conditions in the field remain difficult

Supporting change

Having raised the alarm in the past about the risk of an excessive workload associated with a large number of campaigns being conducted in parallel in the nuclear plants (see Chapter 8), I welcome the decisions that were taken this year to stagger them over time. During my visits, I have observed that decisions

have enabled stronger multi-year campaigns to be organised that better reflect the ability of each plant to handle things. The results of this major change are, however, not yet being felt in the field.The still very great number of changes in professional practices and in organisation will require, on a long-term basis, greater backing in the form of support and help in alleviating the difficulties encountered by staff.

In conclusion, nuclear safety management is maintained by motivated players in the field but their action is all too frequently impeded by there being too many priorities and by insufficient logistical support. Nuclear safety levels are satisfactory, with undeniable successes and also weaknesses clearly identified by the managers. Improvement of the results requires priority being given to professional apprenticeships for the numerous incomers to the world of nuclear power generation, with more independence being granted at plant level.

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THE FUKUSHIMA DAIICHI ACCIDENT

This natural catastrophe caused an event that shapes the future of the nuclear industry, transforms its worldwide governance and forces it to give thought to plant design beyond the original design basis. The EDF Group has shown a high degree of responsiveness in meeting the demand to re-assess nuclear safety and look at the future. This challenge facing the engineering forces must not have an impact on the support they provide to the operating plants in the field of nuclear safety.

Note: this chapter is based on international analysis available on 31 December 2011 and does not cover all aspects of the catastrophe.

On 11 March 2011, an extremely powerful earthquake occurred out at sea some �80 kilometres from Fukushima Daiichi Nuclear Plant operated by the Japanese corporation TEPCO, consisting of six boiling water reactors (BWRs). This caused reactors that were operating to automatically trip by activating the earthquake protection systems. Some circuit breakers and the electrical power system were damaged. The standby diesel generators automatically started to power the safety systems. Forty one minutes after the earthquake, the first of a series of seven tsunamis hit the site. The maximum wave height was �4 to �� metres whereas the site protection was designed to withstand �.� metres, which flooded the plant platform, including the standby diesel generators and the electrical power distribution equipment. Only a few batteries remained operable in Reactor �, and one diesel generator

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for Reactors � and �. Response was greatly complicated by the loss of lighting in the four facilities affected.Without cooling, core melt began that same day in Reactor �. In Reactors 2 and �, core melt was delayed as a result of cooling by the action of turbine-driven pumps that remained operable.The hydrogen produced by the deterioration of the fuel resulted in explosions in Reactors � and �, which greatly complicated response. The pressure rose in the containment vessels, making it necessary to vent them. During the venting, dose equivalent rates of �2 mSv/h were measured at the site boundary. A total of �00 people received a dose above �00 mSv but the contamination released into the atmosphere was 3,000 times less than at Chernobyl according to the IAEA.

An immediate reaction to the event

Throughout the world, the nuclear industry quickly responded to the event to understand and learn from it without delay:

11 March 2011: the accident occurs in Fukushima Nuclear Power Plant,18 March 2011: WANO issues a Significant Operating Experience Report entitled “Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami” (SOER 20��-02), giving all members � month to assess the degree of accident preparedness in their facilities and to submit reports,March 2011: governments begin requesting their nuclear safety regulators to conduct investigations,May-June 2011: A team of international experts from the IAEA representing �2 different countries conducts an investigation in Japan.June 2011: a ministerial conference on nuclear safety is held by the IAEA,October 2011: the WANO members unanimously decide to modify the way in which the association operates so as to reinforce its resources and authority,First half of 2012: peer reviews will be carried out by the nuclear safety authorities of the European Union countries,June 2012: the conclusions will be submitted to the European Commission.

First inferences reported by the Japanese authorities

A prompt and uncompromising

report

During the ministerial conference with the IAEA in Vienna in June, the Japanese government presented a comprehensive report on the accident. The section devoted to “the lessons learnt from the accident to date” was very relevant to EDF and all the other nuclear operators. It must be borne in mind that the emergency response was conducted in a situation where the earthquake and

tsunami had destroyed the public services, particularly the electrical power, communication and transport networks, as well as much of the area surrounding the plant, leaving more than 20,000 dead or missing. In addition, numerous aftershocks hindered the work. The lessons of the accident can be divided into five categories: the adequacy of the preventive measures, the adequacy of the technical response to this severe accident, the adequacy of the relief effort, the strength of the safety infrastructure, and the nuclear safety culture. The Japanese government's report merits a detailed study to find out all that can be learnt from it. To serve as examples, I have selected some aspects that can be learnt from each category.

Adequacy of the preventive measures

The arrangements for protecting the site against the effects of tsunamis were insufficient.The arrangements for managing severe accident situations were not defined in sufficient detail, being generally considered to be voluntary action by the operator rather than a legal requirement. Furthermore, the severe accident management guidelines had not been reviewed since their promulgation in �992, having been neither made more stringent nor improved.

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The measures taken to guarantee stand-alone operability of the individual nuclear units in an accident were insufficient.

Adequacy of the technical response to this severe accident

The accident response arrangements need to be supplemented with measures such as reinforcing radiological protection in the control rooms and emergency centres, upgrading the ventilation and air conditioning systems and upgrading the auxiliary systems, in particular by providing self-contained lighting and communication equipment.A suitable quantity of personal dosimeters, protective suits and emergency equipment must be available on-site. Most of the personal dosimeters and dose-measuring devices at Fukushima were un-usable as they had been damaged by the seawater.

Adequacy of the nuclear emergency response

The division of roles and responsibilities between TEPCO and government organisations at corporate and plant level need to be clarified.The response to offers of assistance from other countries and communication with the international community need to be improved. For instance, there should be a list of the supplies and equipment necessary to react effectively to any type of accident, the points of contact in the event of an accident should be established well in advance in each country and the arrangements for sharing information should be improved.

Strength of the safety infrastructure

Measures to take into account new knowledge and expertise, particularly as regards system design, need to be reassessed. A new legal framework will clarify the status of renovation work.Increasing the levels of skill in the human resources, operators and regulators should involve, in terms of training, focus on nuclear safety, nuclear emergency planning and response, emergency management and nuclear medicine.

Nuclear safety culture

The organisations and individuals involved in national nuclear regulations who are responsible to the public for nuclear safety, need to give consideration to whether they have made proper allowance for new knowledge with the responsiveness and the promptness needed.

The first lessons I have learnt

Unparalleled experience feedback

For my part, my first impressions before further study are:

• The importance of the initial design basis and the systematic reassessment of protection systems during ten-yearly nuclear safety reviews, as is required by French law,

The importance of having resources that can be rapidly deployed and can be quickly located on site so they can be easily mobilised. This is paramount when we consider the speed at which core meltdown can begin in pressurized and boiling water reactors in the total absence of coolant and electrical power.

The need for hydrogen recombiners or more powerful ventilation systems, in view of the devastating effects of the hydrogen explosions on relief operations.

The importance of providing connection points for emergency equipment, to provide assistance in plants that are isolated and partially destroyed,

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The need to improve emergency management by including scenarios where an accident affects more than one nuclear unit in the same plant,

The need for skills of high levels that can be rapidly integrated into the decision-making systems of the government and political authorities,

The extremely harsh conditions in which the TEPCO and contractor staff bravely took action to re-establish a minimum of functionality, with little assistance due to the site being isolated.

Internal actions within the EDF Group in France

Within a few days, EDF mobilised their resources to offer and arrange immediate support measures. The French vendor AREVA, the French atomic energy commission CEA, and EDF investigated what means were available for response in hostile environments from the INTRA robotics group. The EDF Group also sought to assess the long-term impact on its nuclear plants. This was facilitated by EDF's integrated structure, with a strong engineering force to assist with design and operations issues.

“Kit inspections”

Compliance is a priority

I note EDF’s responsiveness in rapidly drawing conclusions which, together with those of INPO, were used to draft the specification in WANO's SOER 20��-02. By March, the goal was set of assessing each plant’s proper compliance of the installations and organisational structure with the design basis rule set, with

particular regard to the risks of flooding, earthquake, loss of the heat sink and station blackout. This work was positively received by the French nuclear safety authority (ASN).

I stress the importance of priority being given to rectifying the persisting discrepancies, particularly for accidents consisting of loss of cooling and of power supplies.I note that these analyses did not reveal any significant risks for the nuclear safety of the installations.

Supplementary nuclear safety assessments process

Supplementary nuclear safety assessments (or stress tests), carried out at the request of the French government or the ASN have made it possible to make assessments extending beyond the design basis of each of the plants. The results were submitted to the ASN in mid-September 20��, and were made public.The process consists in studying extreme situations on a purely deterministic basis, independently of the plausibility or probability of occurrence. It focuses on determining at what point substantial discharges into the atmosphere would occur and demonstrating the presence of any cliff edge effects associated with the loss of means used to protect the installations or control accident situations.For conditions beyond the current design basis, studies investigated earthquakes �.� times higher than the design basis ones, floods �.� times greater than the once in a thousand �,000-year flood levels increased by a margin and rainfalls two times greater that the design basis ones. Finally, allowance was made for total loss of the water and power supplies for eight days, while the current design basis corresponds to 24 hours with no off-site power supply or �00 hours with no heat sink for the entire site. EDF’s priority has been to finalise the studies in the assessment reports, to substantiate the proposed countermeasures and to implement them, as well as to hasten the implementation of certain modifications and actions to restore compliance with the requirements.

The high quality work carried out during the supplementary nuclear safety assessments demonstrated EDF’s ability to manage the design basis of its facilities. I also note that this work enabled the plants to re-appropriate their design rule sets. This is encouraging at a time when generation turnover risks losing some of the organisational memory.

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Finally, at the request of the High Committee for Transparency and Information Concerning Nuclear Matters, the supplementary nuclear safety assessment includes a third part (specific to France) relating to the conditions for using contractors in the nuclear plants in service. I mention this issue again in Chapter 9.

Continuous improvement

From their commissioning, the EDF nuclear power plants have been the subject of numerous upgrades and modifications intended to increase their safety levels, particularly during the ten-yearly inspections. These changes are made in accordance with the policy on continuous improvement of nuclear safety that has prevailed in France since the construction of the very first nuclear plants, and codified in the Nuclear Safety and Transparency Act since 200�.

Stress tests : confirmation of nuclear safety

The stress tests have enabled EDF to substantiate the existing design basis of the facilities, a position largely borne out by the successive reviews already carried out during the ten-yearly re-assessments of plant nuclear safety, and by rules set out from the design stage for the EPR-type reactor. For my part, I agree with this.

I also note that, for extremely severe accidents, these analyses confirm the accuracy, for the protection of populations against radioactive discharges, of the findings concerning the resources implemented in the wake of the Three Mile Island and Chernobyl power plant accidents.

Countermeasures proposed

Robustness and resilience

Up to March 20��, situations as extreme as those studied had not been followed by the definition of specific countermeasures in view of their low probability. The study of additional countermeasures is therefore being proposed to increase the robustness and the resilience of the installations.

As regards robustness, additional arrangements have been selected such as reinforcing the electrical power supplies and the water make-up systems. These arrangements constitute part of a ‘hard core’ of measures capable of withstanding beyond-design-basis events. Planning these measures is a major step forward but I would like to draw attention to the need for restricting their perimeter so as not to excessively complicate the installations.As concerns resilience, the goal is to have both human and material means available at corporate and plant levels that are able to respond flexibly to a wide range of unplanned situations. The creation of the Nuclear Rapid Response Force (FARN), operational on-site in less than 24 hours, answers this concern. The FARN should eventually have a staff of around �00 divided between the plants and who will continue to perform their original professions on a part time basis.

I fully agree with the steps planned in these two areas and I approve of the priority that EDF is giving to implement these countermeasures in concordance with the ten-yearly re-appraisals. Their application, however, must allow for the actual situations in the field. The problem of skills that is currently so acute, especially for operations staff, and the need to prepare for an increased engineering workload leads me to advise everyone to keep a careful watch over how these measures are implemented. My worry is that, as a result of an increasingly heavy workload, the plants and the engineering centres will find it difficult to handle their tasks, priorities will be managed in a way that cuts out issues relating to everyday nuclear safety. Obviously, allowance must be made in budgeting for these new measures. The availability of a pool of quality industrial suppliers will be vital in implementing these plans.

Emergency management

Severe accident management features three clearly-defined centres of responsibility: the operator, the nuclear safety authority and the government, all acting at two levels: local and national.

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At EDF, the national-level emergency management resources have always been the subject of special attention and the associated organisational structure has proved its ability to support the plants in actual and simulated incidents. There is, however, a need to examine the consequences of an event affecting multiple reactors in the same plant, at both local and central level, for all the parties involved. Thought has also been given to the conditions under which response personnel would be working in an emergency, and it will be necessary to take into account experience feedback from Fukushima on their radiological monitoring and protection, as well as on their living conditions in the affected facilities.

I would like to draw the attention of the government authorities to what the accident in Japan has revealed, the number of evacuees involved, and the implications for training their nuclear emergency decision-makers, which could be carried out on an emergency simulator for instance.

Level of nuclear safety, the ASN’s ruling

In the ruling it issued on � January 20�2 after the supplementary nuclear safety assessments, the ASN re-affirmed the fact that the operator bears prime responsibility for the nuclear safety of the facilities. The ASN is to perform checking in the name of the government.

It “considers that the safety level of the facilities is sufficient for it not to request immediate action in any of them. Notwithstanding, it considers that their continued operation requires increasing without delay their ability to resist external events beyond the existing nuclear safety margins.”

The ASN will therefore impose a set of requirements on the operators and make the existing ones on nuclear safety more stringent with regard to protection against natural hazards (earthquake and flooding). It notably stresses EDF’s proposals to define a ‘hard core’ of material and organisational provisions to deal with extreme situations and the progressive setting in place of the Nuclear Rapid Reaction Force from 20�2.

It notes that social, organisational and human factors have been the subject of special attention and describes the priorities regarding the renewal of personnel and the way recourse to sub-contracting is organised.

It requests improving the process for handling cases of discrepancies and violation of the rule sets as regards hazards associated with other industrial activities.

In the United Kingdom

The board of EDF Energy Nuclear Generation rapidly took action to assess its plants, after a meeting held on �4 March. This initiative was backed up by the publication of SOER 20��-02 by WANO on �8 March. Meanwhile, the government appointed the chief inspector of the Office of Nuclear Regulation to conduct a nuclear safety assessment, and he issued a preliminary report in May and a final one in September 20��.

Working method

After the Fukushima accident, EDF Energy in the United Kingdom and EDF SA in France maintained close communications on the methods of assessment and the hypotheses adopted. This initiative guaranteed that the approach would be consistent within the group.At the same time this was taking place at national level, the European Commission, via the requirements of European Nuclear Safety Regulators Group, drew up a document indicating how stress tests were to be conducted with the European Union. There are many points in common between the Office for Nuclear Regulation (ONR) and the European Nuclear Safety Regulators Group requirements,

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however the former extended its scope to include post-accident management as well as openness and transparency in the nuclear industry.The originality of the Office’s approach is to ensure that experience feedback from the accident is obtained and handled using current practices and existing regulatory processes.

Reactors of different types

High-inertia reactors

It is to be noted that, due to the way they are designed, advanced gas-cooled reactors respond differently from pressurized water reactors to severe accidents. Advanced gas-cooled reactors have a power density that is some 40 times less than pressurized-water reactors and substantial thermal

inertia. In the event of loss of cooling, the rate at which their temperature rises is far slower. In addition, the fuel cladding is made of stainless steel that does not produce hydrogen at very high temperatures in the presence of water vapour, unlike in pressurized water reactors in which the cladding is made of zirconium.Sizewell B is a pressurized water reactor of recent design and was assessed in a manner consistent with that of EDF's rectors in France.

The level of nuclear safety, the Office for Nuclear Regulation’s ruling

In the context of this overall nuclear safety assessment, EDF Energy did not identify any shortcomings in any of its plants.In the Office’s preliminary and final reports, it is stated that “in view of the direct causes of the Fukushima accident, we (the ONR) see no reason to place restrictions on the operation of nuclear power stations in the United Kingdom." and "the British nuclear industry has responded in a responsible and appropriate manner, showing leadership in the field of safety and solid nuclear safety culture in its reaction to date.". The reports conclude that the British approach to establishing design rules for nuclear facilities provides proper allowance for external events. The requirement to make periodic reassessments of the nuclear safety case and to submit them to the Office constitutes a reliable way of making sure that the nuclear facilities have been upgraded to reflect progress in technology. Otherwise, they would be closed down.

Changes being studied

Technical modifications in the facilities are being planned to increase their ability to resist natural events, including the possibility of rapidly connecting emergency equipment. The storage of emergency equipment off-site will be increased to enable response teams to take action more quickly.

Improved emergency

preparedness

The resources of the regional emergency response centres are to be reinforced and could be used in any type of emergency, nuclear or otherwise.

Training, severe accident procedures, emergency exercises and communication systems are all being upgraded in the field of emergency preparedness.

As regards openness and transparency, the creation of centres to receive the public in every plant is being envisaged.

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In the United States

In the United States, the response to the Fukushima accident by the nuclear industry was carefully organised by INPO, the Nuclear Energy Institute (NEI) and the Electric Power Research Institute (EPRI), involving the creation of a steering committee charged with coordinating the efforts of seven working groups.

Like elsewhere in the world, the operators all responded to WANO’s SOERs and the equivalent reports by INPO, by conducting the required plant reviews.All agree that the NEI, with the assistance of industry partners, collected and made available information on the accident in a highly effective manner, satisfying the demands of the general public, the media and politicians.The Nuclear Regulatory Commission (NRC) created a near-term taskforce consisting of experts with the task of re-examining the American processes and regulations, before issuing recommendations for contingent changes in policy.In my exchanges with INPO, one issue came up often: after a serious nuclear accident in any country, all the main national and international organisations would have to work together as the events unfolded. They would need to rely on well-established relationships and networks. Before any such occurrence, the heads of the different organisations need to know each other and understand what roles they would be called to play.As regards emergency response, it appears that the American plants are well organised with the local administration, but at federal level the Federal Emergency Management Authority (FEMA) does not appear to have solid arrangements in place for a nuclear crisis.

Constellation Energy Nuclear Group (CENG)

An extremely active operator

CENG is deeply committed to post-Fukushima actions in the American industry. Its Chief Nuclear Officer is supervising one of the seven above-mentioned working groups, and represents CENG in the steering committee. Furthermore, CENG is coordinating the response to INPO Event Report ��-4 on station blackout.

Internally, CENG is intiating action relating to:

assessment of earthquake resistance and study of flooding margins,

capacity of the batteries, improvement of the in-pool instrumentation, reinforcing of the boiling-water reactor vent lines, and bringing the severe accident guidelines up to standard,

purchasing of mobile equipment and studies on rapid hook-ups,

on-site assessments from November 20�� to April 20�2, as well as delivery of mobile equipment in the first half of 20�2.

Different types of reactors

CENG operates two boiling-water reactors at Nine Mile Point, on the shores of Lake Ontario. The basic design of Reactor � at Nine Mile Point is very similar to that of the first nuclear units at Fukushima (Mark I type).In their other two plants (Ginna and Calvert Cliffs), CENG operates three pressurized water reactors.

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Level of nuclear safety, the NRC’s ruling

In July 20��, after the Near Term Task Force of experts from the NRC issued a report featuring twelve themes and some thirty recommendations and requirements. They declared the American plants to be “safe and that none need be shut down”. I note that the experts expressed the need to clarify the requirements relating to "design basis events" and "beyond design basis events". Furthermore, they report lack of coordination of the voluntary initiatives of the industry, where rigorous checking by the NRC does not occur.

These recommendations, which were made public in July 20��, were divided by the NRC into three categories in October 20��, under Letter SECY��-���:

short term: earthquake and flood assessments, loss of electrical power supplies, increased dependability of boiling-water reactor vent lines, reinforcement of severe accident management procedures,medium term: fuel storage pool water make-up ability, emergency preparedness,long term: ability to vent pressurized water reactors, mastery of the hydrogen risk.

Analyses and initiatives by other international players

The international nuclear safety community (Global Nuclear Safety Regime)

The term is used by the International Nuclear Safety Advisory Group of the IAEA. It expresses the collective international enterprise that seeks to define a level of performance expected of all operators and regulators, to monitor their performance, and to build their competence and capability. It includes all the national and international efforts and networks. More detail is given in the report INSAG-2�. Post-Fukushima, a number of important steps have been taken in the international arena and in strengthening the global nuclear safety regime. I consider that it is vital for the key players of the nuclear industry, particularly EDF, to contribute more actively by their effective and sustained participation in the life of this community.

WANO

WANO commits its credibility

I note that WANO reacted promptly to the Fukushima accident in close liaison with INPO and made sure that all its members rapidly checked their plants and their accident preparedness. The process was found to be useful, revealing a number of areas where improvements could be made, such as training,

documentation, maintenance and checking of emergency equipment.Amongst other things, a fourteen-member commission was set up to recommend modifications to the programmes and the functioning of WANO. During the biannual general meeting of WANO held in Shenzhen in October 20��, the WANO members unanimously approved the recommendations. They related to:

broadening the scope of WANO’s activities,

establishing an integrated worldwide strategy for response to events,

increasing the credibility of WANO, notably by modifying the peer review procedures in depth,

increasing the visibility of the association,

improving the quality of all the products and services on offer.

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A substantial increase in its resources will be necessary. In particular, the members will need to make resources and competent staff available to the association and its programmes. This contribution will remain modest compared with the direct costs resulting from the Fukushima accident and its impact on public confidence. The EDF Group has actively supported this commission and its recommendations which should increase the credibility and power of WANO.I think that all the nuclear operators should be responsible for ensuring that this programme is properly executed as concerns timing and content.

The IAEA

At the end of May 20��, an international team of IAEA experts with representatives from 12 countries went to Japan. They visited Fukushima Daiichi, Fukushima Daini and Tokai Daini Nuclear Power Plants. Their findings bore out the inferences mentioned above. The visit brought other issues to light:

The response undertaken on the spot, under extremely difficult conditions, by specialised personnel who proved themselves both committed and determined was exemplary. It made it possible to adopt the most appropriate approach for ensuring nuclear safety in view of the exceptional nature of the situation.

Highly-professional logistical support was set up, especially by the arrangements taken in "Village J” (centre providing access to the site, located 20 km away) to provide protection for the response workers that needed to go to the sites.

The action plan set up to regain control of the accident-stricken reactors is important and well-recognised. It needs to form part of a broader plan possibly leading to decontamination of areas outside the sites affected by radioactive discharges in order to enable the evacuees to return to normal life. The entire world would thus bear witness to the measures that might be necessary to cope with this type of extreme nuclear event.

The nuclear regulations need to be designed to make allowance for extreme off-site events and be the subject of periodic re-appraisals. They also need to preserve the independence of the nuclear safety authority and clearly indicate the role of all the players under such circumstances, as required under the IAEA's standards.

A large amount of information was obtained by the team. I was impressed to learn that at the neighbouring site of Fukushima Daini, where flooding caused less damage than at Fukushima Daiichi, TEPCO and contractor staff installed nine kilometres of temporary electrical cables in sixteen hours, making it possible to re-establish nuclear safety functions.

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In conclusion, as in the case of the Three Mile Island and Chernobyl accidents, the Fukushima accident has affected the future of the nuclear industry.

I consider that the reaction of the nuclear operators of the EDF Group was prompt and proportionate, both in terms of the actions speedily put in hand and the quality of the response to the requests of their respective nuclear safety authorities.

I note that during this unprecedented assessment procedure, the nuclear safety of the EDF Group's reactors proved to be adequate in terms of the current rule set. The allowance for even more severe natural events will increase the level of their nuclear safety.

I would once again like to draw attention to the engineering resources that will need to be mobilised for these studies and works at a time when, in France in particular, the engineering staff are already busy with other nuclear safety requirements. They will also need to cope with large-scale turnover among their personnel.

Nuclear accident preparedness in the countries where the Group has interests, involving government authorities, operators and safety authorities, will need to be re-assessed to determine its ability to cope with an accident such as Fukushima, where a number of reactors on the same site are threatened and large-scale evacuation is required. The states and their services need to take decisive action in this field, and I encourage their progress.

I consider the decisions taken in October 20�� by nuclear operators from around the world under the aegis of WANO are necessary as they greatly strengthen the international oversight of the nuclear operators’ activities. I am glad to be able to report that EDF has played an active role in this process.

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TRAINING TO DEVELOP SKILLS IN THE PROFESSIONS

In France, the company has been confronted with an unprecedented generation turnover. Planning for the general refurbishment of the EDF SA plants will soon put great pressure on many skills. Managing these challenges without compromising nuclear safety will require managerial commitment to training and the professions.

The French aspect of this state of affairs is considered in this chapter. This year, massive recruitment is continuing with the hiring of nearly 2,000 engineers and technicians in the nuclear sector. First, they will be compensating for 40% of the personnel in the engineering and operations divisions that will be retiring between 20�0 and 20��, with departures peaking in 20�4. This is the back of the wave of staff that were hired to build the nuclear plants in the late seventies and early eighties, which was not properly planned for in the previous decade.

Recruited staff will also have to cope with the General Refurbishment workload and the modifications due to the experience feedback from the Fukushima accident. As the time required to train and become a true professional is long in the nuclear industry, it is necessary to make special arrangements to cope with the demand.The Nuclear Operations Division and the Nuclear Engineering Division have accordingly set in place a very ambitious programme. I observe that this programme is based on an in-depth analysis of the situation and was inspired by the best practices worldwide.

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Rare skills

I would like to stress that the replacement of experts is vital to the future of the company, although they may be few in number. It will need to be planned ahead field by field, including in the nuclear fuel and the R&D divisions. In the plants, the same applies to the rare skills that require foresight to be acquired in view of

the corresponding professional experience needed.

Skills

The landscape

The effects of the rationalisation and productivity drive in the first half of the last decade are proving difficult to overcome. As the time taken to train and become a true professional is long, the renewal of skills remains a major concern for the plant managers despite an unprecedented effort.

In the operations branch where the time taken to become a true professional is even longer, collective experience is diminishing. In 200�, there were � experienced staff for each new arrival, in 20�2 there will only be � for each new arrival, with the situation improving in the following years. This situation calls for changes in the way activities are organised and checking is conducted in the teams.

In the maintenance profession, the situation is different but remains problematic with � experienced staff member for each new arrival in 20�2. The influx of new employees raises the question of how different generations will get along together. The incomers’ approach to work is different and the company will need to take this into account.

It is in engineering where the dearth of experienced staff will be most keenly felt, whereas the EPR-type reactor work is the most intense, the engineering force for the plants in service needs to maintain the performance levels of the �8 reactors and the issues raised by the Fukushima accident are keeping nearly �00 engineers busy in the Nuclear Engineering Division and the Research and Development Division. To this must be added the resources needed for decommissioning work. In view of this large and increasing workload, it will no doubt be necessary to work differently. Why not seek and encourage reinforcement by other engineering companies?

In the Nuclear Fuel Division, a professional trajectory has been developed to compensate for the number of staff taking retirement before the end of the decade, compromising some of the expert appraisal skills. The creation of the fuel community in 20�0 is fostering cross-functional management of skills throughout the branch, divided between the different divisions of the company. Here, the annual recruitment of some ten individuals appears to be sufficient to meet the needs of the Nuclear Fuel Division.

Engineering, a priority

The engineering personnel needs of the Nuclear Engineering Division and the Nuclear Operations Division for the next ten years amount to �,000 to �,�00 engineers.

Reinforcing engineering skills

In 20��, more than 400 incomers joined the Nuclear Engineering Division, a trend that will continue for the next three years. Although most of the needs are covered by hiring young graduates, candidates with professional experience are especially coveted. I would like to draw attention to the highly-competitive fields

(civil engineering, chemistry and project managers) and the highly-specific ones (instrumentation and control, and radiochemistry). I can only encourage the recruitment of such staff. In particular, I would like to stress the efforts of the Construction and Operation Expert Appraisal and Inspection Centre to recruit chemists of the highest calibre.

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I would like to emphasise the creation, in 20�0, of special training arrangements for incomers in the Research and Development Division lasting two to three years to ready them for the operations and engineering professions. These joint Nuclear Engineering Division and Research and Development Division hiring actions may be limited in number but constitute an excellent initiative.

Mobility

I observe that the internal job market has not regained its fluidity, but I commend the work carried out on cross-division career trajectories by the Production and Engineering Directorate. Faced with the lack of experienced personnel with the skills needed, most of the plant managers prefer to keep their staff. I can only encourage that the human resources policy take into account the particularities of the incoming generation, which does not have the same expectations as the outgoing generation. I am glad to see the setting up of Professional Career Supervisor positions in every department of the Nuclear Operations Division and the Nuclear Engineering Division. I will make a point of meeting them in my forthcoming visits.

I also note the hesitation, if not the reluctance, of the supervisors to make the decisive step of accepting an executive position. The perception of the duties and constraints of an executive position and the temporary loss of certain advantages are the main reasons. Progress with functional mobility has been insufficient and social promotion stalls at the transition from technician to executive.

The many people retiring are draining the pool of experience. I am left wondering about how to solve the problems associated with these trends. Might it be possible to render jobs more attractive to keep the personnel needed, even if this means consenting to work part time? Has full use been made of imagination in finding the best solutions?

New challenges after Fukushima

Managing a multi-unit

accident

The Fukushima accident will have an impact on the plants’ human resources. The stress tests show the need for supplementary skills in carrying out the minimum amount of response work in exceptional complex situations. Up to now, the postulation of an accident in one nuclear unit of a plant offered the possibility of reinforcements arriving from the other units. The deterministic hypothesis of an

accident in all the nuclear units in the same plant would prevent mutual backup. To meet the need for reinforcement, additional experienced operations personnel will be needed in the coming years.

Consideration also needs to be given to the creation of the Nuclear Rapid Reaction Force, which will consist of Nuclear Operations Division staff: some ��0 staff, seconded to this new activity for ��% of their time. I will be watching how this new system is set in place.

Furthermore, the decisions taken by the operators that attended the WANO Biannual General Meeting in October 20�� involved providing the organisation with more manpower and some 200 experienced engineers have been seconded to it. For the EDF Group, this means that 4� experienced executives will need to be made available to the WANO centre in Paris. I stress that high-calibre personnel must be sent and the undertaking be fulfilled as they appear to be essential for nuclear safety and the future of the nuclear industry.

Cooperation with EDF Energy

Cooperation has been arranged with EDF Energy to conduct recruitment jointly in the United Kingdom. Some twenty engineers thus joined the Nuclear Engineering Division this autumn on secondment for two years before returning to EDF Energy.

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Exchanges of personnel are also developing between EDF Energy and the nuclear departments of the Nuclear Technology Division. I encourage these exchanges, which should intensify with the construction of EPR-type reactors in the UK.

Training

Training requirements more than doubled between 2008 and 20��. This increase is expected to continue. At the present time, scope for recruitment is limited by the capacity to receive new arrivals and train them into professionals. In view of the numbers, the quality of training is vital to successfully renewing the skills.

The training potential has been considerably reinforced with the creation of the ‘nuclear generating and engineering’ vocational academies. The ‘nuclear generating’ academies provide more than �00,000 trainee-hours, half of which are given by instructors and half by plant operations staff.

Training resources

The vocational academies also provide basic training for staff joining the nuclear divisions. All are equally appreciated by both the operatives and their managers. This must be continued. I hail the creation of ‘specialist knowledge’ vocational academies, following on from the ‘common core’ academies, in an increasing number of areas.I also note with interest the creation of a training scheme for the plant directors newly appointed by the Nuclear Operations Division. This rounds off the range of training intended for managers, from front-line supervisors to heads of departments and unit outage project leaders. At the Torness site in Scotland, I saw a leadership training scheme that seemed highly innovative and which I recommend.

I think that more attention needs to be paid to “just in time” training. Training before a delicate operation is always highly beneficial in terms of mastering nuclear safety. I am all for this type of training that is closely integrated with the operations process, particularly when simulators are used. The development of ad hoc mock-ups for specific types of equipment also forms part of this type of training. During my visits, I noticed some excellent initiatives which deserve to be more widely known.The practical training centres in the plants are excellent for carrying out more general training or training focused on human performance. I encourage the plants to use these practical training centres to the best advantage of their staff and that of their contractors. The full-scale simulators are vital learning tools for operations. They need to be upgraded to be more representative of the different control rooms in service. I am glad to see that the simulators are being used more and more frequently. Here, I would like to draw attention to the fact that Gravelines Nuclear Power Plant has six nuclear units and needs a second simulator.I insist that the operations departments organise themselves better and enable the operators to have training on demand. In other countries, simulator sessions are more systematic and better organised, being integrated into the teams’ timetables.

Once again, I would like to point out that there is a need for more experienced instructors. The training centres of the plants in other countries commonly have twice or three times more staff. Beyond this major effort, there is a need to make better use of the potential of this profession to attract the top professionals and make sure that their feedback to operations will be good. On one British site, I observed a short-duration secondment system, lasting between six months and a year, which appeared to be giving satisfaction.

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Greater independence

Hands-on training of managers

Apart from the resources, there is room for progress when it comes to transferring more responsibility to the managers. In my visits to the plants, I have all too often observed managers with insufficient concern for training their staff. I suggest that the departments take greater charge of training and that the managers be free to say what is lacking in the staffing and functioning of their departments so

they can have the training modified accordingly. The commitment to skills also means identifying the training requirements by appropriating the programmes and by getting managers more involved in the training.

The question of local independence in training has been raised, with the need for liaison between the nuclear plants and the Operations Engineering Training Unit, which acts a prime contractor for training. I have taken note of the experiments conducted at Golfech, Civaux, Chooz and Tricastin Nuclear Power Plants and the planned extension to include six other plants in 20�2. I had these shown to me at two of the first plants. I am convinced that a degree of independence is beneficial as it places more responsibility on the managers when it comes to training. The Operations Engineering Training Unit needs to support this important transition. This alternative approach will only be successful if all involved actually agree on granting more independence to the plants.

Systematic Approach to Training

This year, during my visits to Koeberg and Sizewell Nuclear Power Plants and to INPO, I was given presentations of the internationally-recognised Systematic Approach to Training that is used in many companies. This consists in determining the scope of training on the basis of the actual needs for skills in departments using job descriptions supplied by the plant management for which the training is performed and which has defined the management’s priorities. Koeberg Nuclear Power Plant, which is located in South Africa, has opted for it. I also appreciate the pragmatic approach preserving the spirit of the method that was used at Sizewell Nuclear Power Plant to achieve full accreditation of its training department by the end of 20�2, as is the case at the other EDF Energy plants.

I note that the Nuclear Operations Division has not yet set itself the goal of accreditation, preferring to concentrate on the approach in depth according to the INPO's rule set.

Training that is closer to the

technician’s task

For all the technical professions in the Nuclear Operations Division, a rule set is being accordingly prepared on the basis of the activities that the professions are to perform. The experts of the professions and the Operations Engineering Training Unit are considering designing more than �,�00 courses for the Nuclear Operations Division with the Operations Engineering Training Unit as prime

contractor. By means of this work which is due to continue until 20��, my wish is for the training to be less theoretical and more closely focused on the professions.

EPR training

Staff training began in 2008 well in advance of schedule. The control room simulator is already in service, which is important as �0% of the operating personnel are actually new arrivals in the company and that the control room is totally computerised. The training is, here again, planned in accordance with the Systematic Approach to Training methodology, which is a guarantee of quality at a time when it will be necessary to provide one million trainee-hours throughout the period leading up to commercial operation. In China, I note that problems associated with the lack of experience is cleverly countered by accrediting all operators on Chinese reactors with computerised control rooms, such as the CPR �000 series, before moving on to the EPR-type reactor.

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Apprenticeship and mentoring

This year, I observe a readily-understandable disquiet among the most experienced staff as to the manner of transmitting their experience and know-how before retiring. The adoption of sandwich courses and mentoring by the Nuclear Operations Division provides at least a partial response to this question. Mentoring is, in my opinion, vital to the success of sandwich courses. The number, quality and motivation of the tutors will all call for vigilance. The inflow of new arrivals is so great that I have, on occasions, encountered mentors who have only been in the company for three years, which can hardly be sufficient.

Lycée André Malraux in Montereau

The Lycée de Montereau has been a partner of EDF in the nuclear industry for many years. I commend this partnership, selected for its proximity to the nuclear plants at Nogent, Belleville, Dampierre and St. Laurent, and for the presence of the dynamic teaching team that is a stakeholder in this ambitious project. I discovered all this when I visited the establishment. The ‘valve system’ practical training centre is particularly well equipped.

The Lycée provides initial vocational training in nuclear technology up to school-leaving level, and in-service training for EDF and nuclear contractor staff. All students awarded diplomas are able to find jobs. Alongside the conventional training for valve and electronic technicians, I noted a course for contractor staff supervisors. In 20��, for the first time, a “nuclear environment” vocational diploma was developed for apprenticeship training for future work area managers and supervisors.

It is my wish that the French education system recognise the importance of the industry’s requirements and the awarding of official diplomas. Relations between EDF and the Lycée are excellent and the company needs to maintain its support, notably by continuing the cooperation with Nogent Nuclear Power Plant and through the supply of equipment.

In conclusion, to make it possible to compensate for departures and cope with the workload in operations and engineering, we need to make training more closely reflect the needs in the field and to assign the necessary resources to it. The integration of the best international practices is a very promising development. Success will depend on the full involvement of the management teams in training.

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THE OPERATIONS PROFESSION

The operations departments are key players in the field of nuclear safety. Scope remains for improvement in the activities that are central to the profession. Upgraded staff training and stronger leadership on the part of the operations shift managers would help to improve the quality of operations and foster calmness.

For a nuclear plant, the results in terms of nuclear safety as in production are closely linked to the presence of a truly professional operations team that is recognised as such by the other professions and manages everyday activities with authority.The competence of the players, its standing in the eyes of the plant management and its ability to encourage process skills in other professions, are all factors that are essential to success and should be found in all the EDF Group's plants.

A major recruitment drive, weakness in human resources remains

In the French plants, the operations professions are also confronted with high levels of staff turnover which, in 20�2, will result in the supervision factor reaching two experienced staff for each new arrival.

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Invest even more in skills

In all the plants visited this year, I saw the scale of recruitment having taken place and the intensity of efforts made in the plants to train and integrate the incoming generation. It seems that despite the unprecedented efforts, the forward planning of jobs and skills is still not up to standard in most of the

plants. Filling the different positions in accordance with the scheduling — as regards technicians, operators and team leaders — has substantially improved but will require more time and sustained efforts. This is especially the case as many skills derived from the operations professions are in short supply in many other departments and still severely lacking for positions of the highest importance: simulator instructors, safety engineers, outage supervisors, sub-project leaders in both the unit outage and unit in-service teams and engineering.

Progress in compliance with the rule set and recurrent shortcomings in the execution of activities

Concerning one vital issue, I note with satisfaction that compliance with the technical specifications for operation, the ‘highway code’ for reactor operations, is an area where there has been substantial progress. This is the result of large amounts of support and training work carried out in many of the plants, including the active involvement of the operations shift managers and safety engineers.The progress achieved in most of the plants in the field of administrative lockouts also needs to be emphasised.

The profession comes first

However, I note regular control room surveillance discrepancies and perceptible deterioration as regards errors in alignment and system configuration. Concerning this last point, the causes identified cover virtually the entire range of what operations staff ought to know, clearly illustrating that there is a problem

with the key skills central to the profession. It seems that the so-called field activities, performed outside the control room throughout the plant under possibly difficult conditions, merit greater attention on the part of the plant and operations managers. Closer observation of the practices, which are often little known, and the everyday problems encountered by the technicians could reverse this trend.I can also see how certain difficulties in the application of operating rules and procedures during normal operation sometimes reflect a lack of confidence in documentation that has recently been updated. Much work on standardising the operating procedures as part of the Methods and Practices Harmonisation Campaign has indeed been carried out in recent years, providing greater allowance for experience feedback and rationalising this vital documentary activity. But every modification of the rules or instructions seems to result in people losing their bearings. This is also true of maintenance work. It is therefore essential to take care to provide the users with proper backup during this transitional phase. It is positive that the operations shift managers and the operating staff still have plenty of confidence in the incident and accident situation operating procedures, which they regularly test on simulators. This is a factor that greatly inspires calm.

I also observed, in most of the plants that I visited, that the error prevention tools are not being used systematically both in the control room and in field activities. An unprecedented investment in training has taken place in the plants, both in the practical training centres and on simulators. Still, at the present juncture, the penny still has not dropped and we are still far from what I can observe elsewhere, particularly in the control rooms of EDF Energy.There is a real risk that the human performance practice campaign is running out steam. Since this is an innovative project that is no longer consuming many resources, I call on the plant managements to take action to ensure that the penny drops, particularly with the new intake.

The operations shift managers need to assert their authority

The operations shift manager’s task is to provide nuclear safety checks 24/�, under powers delegated directly to him by the plant director. These key players also need to ensure operations are proceeding smoothly, by supervising all the activities begun by the nuclear unit staff, determining the best trade-offs and allowing for the constraints of the maintenance services. They all manage an operations team

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and thus have the task of setting the standard for rigour in operations for each of their staff and developing a work atmosphere that encourages willingness to learn and openness to the outside.

In light of my visits, I wonder if they are able to see things in perspective, as all too often they are caught up in the work in hand or activities of which they could well be relieved. The operations shift managers that I have observed in nuclear power plants in other countries and belonging to other companies, particularly the USA and the UK, appear to be calmer and freer in the execution of their everyday tasks. They have broad and effective support and are able to step back from the situation to the benefit of this line of defence.

The initiative taken in the French plants to better organise work during operations and outages, which are inspired by the best international practices, such as AP 928 and outage control centre (OCC), are a step in the right direction and increase the support from which the operations shift manager benefits. I recommend that care should be taken to ensure this position is given its proper standing in any new organisational setups.

Operations shift supervisors are real managers

I would also invite the plant managements to carefully consider the managerial dimension of their operations shift managers who, to succeed in inducing major changes in certain professional practices, need to see their authority backed up and their initiative encouraged.

Training and drilling the staff: an absolute priority

The basic training of the staff is of high quality with a substantial syllabus for the reactor operating personnel. It should also be noted that specialist knowledge academies for technicians and field staff are becoming universal. These academies, co-organised by highly-experienced technicians, fulfil the requirements and ensure that knowledge is properly passed on to the next generation.

I observe with satisfaction the widespread introduction of a more formal assessment of operator skills on simulators, using a realistic and pragmatic method. This change, inspired by international practices, is of a nature to inspire confidence in outsiders, especially the nuclear safety authority.

Training: an activity in its own right

Nevertheless, the training and drilling of operations staff still falls far short of the Nuclear Operations Division's target of �� days of drill on a simulator per year for each operator, which is only being met in a few plants. Problems are arising with work organisation and even simulator availability in the plants with four or six nuclear units.

I note excellent initiatives in fieldwork, for instance scheduling ad hoc training for the staff concerned before each unit outage, as is the case in the plants of the Constellation Energy Nuclear Group and EDF Energy. The practice is still insufficiently widespread.From what I have seen in most plants that I visited, there is a regrettably small number of training days that are carried out with entire teams outside shift work. These actually constitute excellent opportunities for developing team spirit and bringing the managers closer to their teams, which is very important for properly handling operations under normal, incident and accident conditions. The real problems encountered with work organisation, which make such practices rare, appear to need re-examination.

More generally, I consider that the presence and the involvement of managers in simulator usage remain insufficient, for both heads of operations departments and plant management staff. Such involvement, so perceptible in the EDF Energy plants for instance, provides leverage for progress and increases the effectiveness of training.I am glad to see that the skills programme, drawn up by the Nuclear Operations Division after hard work on opening up internationally, is now going ahead. It needs to be supported with time and resources, but the goal is clearly announced; fostering more responsible attitudes to training in the plant managers.

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Changes to be progressively made in the professions

The announcement of ambitious objectives for all the technical professions has been the subject of plans for the professions that were set in hand more than five years ago in the nuclear plants. This involved an operations professions steering group laying down new job descriptions for these professions, extending from increased technical knowledge for expert field staff to further skills for control room personnel, with the introduction of a third operator and the unit control operator.Reinforcement of the team leaders under the operations shift managers, with associate operations shift managers and operational safety associate managers is also a key feature of the changes in the professions.

It is plain that these changes are only partially complete in the plants that I visited, and there are still strong reservations among those concerned. Their introduction is also being slowed in many operations departments by the rate at which skilled staff can be supplied, despite the fact that the special training schemes are now heavily subscribed. This is simply going to take time and continued investment.

The control room: a working environment that needs to be sacrosanct

If there is a place in a nuclear plant where calm needs to prevail, it is indeed the control room. I note with satisfaction that considerable progress has been made in recent years and, during my visits, I see concrete initiatives being taken in the field, boosted by a corporate-level directive that makes a great deal of sense. However, we are still far from the best practices that can be observed outside France.Access is still not limited to the strict minimum, particularly during unit outages, and the operations staff do not always seem to be sufficiently firm or imposing to ensure that the rules are obeyed. Practices to increase reliability in the control rooms which, by their very nature, render the operations sacrosanct, are still very far from being fully adopted.

The modernisation of the instrumentation and devices used in the control rooms, which can also greatly contribute to calmness there, is not, in my opinion, being given high enough priority. For instance, I am still sorry to see that there is no means of viewing operational data remotely outside the control rooms where it can be accessed by the maintenance services; this is particularly a problem in the 900 MWe nuclear units.

For Flamanville �, I note with satisfaction that these issues have been taken into account in the EPR-type reactor design, going as far as reviewing the entire organisation of the control room activities. Without questioning the validity of the proposed change, I note that the ergonomics and the man-machine interface are the subject of a major human factors qualification programme.

In conclusion, the operations professions, like others, are faced with a situation of unprecedented generation turnover. The EDF Group will have to invest massively in human resources in France. Total success with this investment is vital for operating safety. This, however, depends on how successful the major changes in the content of the professions prove to be, by not only substantially improving the training system but also encouraging greater openness in the operating staff to the outside world.The plant managements will need to focus on operations in their deliberations and decisions to strive for a higher level of nuclear safety and better operating results.

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7THE ENGINEERING SERVICES AND OPERATIONS SUPPORT

The French nuclear power plants now face an unprecedented challenge. They will only be able to overcome it with the effective and responsive support of their own engineering services. These services need to be better organised and rapidly find ways of coping with a heavy workload.

For the French plants, EDF has the ambition to regain its place of leader in the nuclear industry by its levels of nuclear safety and performance. Extending plant life to �0 years and integrating the experience feedback from operations and the aftermath of the Fukushima accident will be part and parcel of its challenges for the next few years. To deal with these issues, EDF will be making good use of its integrated engineering capability, which plays a vital role, especially in its support for operations.EDF’s engineering force is vast and diverse, and it is not possible to discuss all its tasks and component parts every year. This year, I have chosen to focus on the “designer after-sales service” it provides (referred to as engineering support for the plants in service) and on the corporate level bodies that provide the operator with support.

Succeed with the Major

Refurbishment

The Nuclear Operations Division cannot implement its General Refurbishment programme without the proper backing of the Nuclear Engineering Division’s design engineering force. Also, unassisted, no nuclear plant can prevail against the challenges that await it. Operator support organisations are indispensible, whether they are the engineering centres of the Nuclear Engineering

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Division or the corporate departments of the Nuclear Operations Division. Although everyday operation is a matter for the plants, the quality of the support they receive to maintain the proper standards, is the determining factor. I wish to stress that, despite the numerous initiatives launched in recent years, it still remains difficult to obtain this support. The actions taken to clarify the responsibilities and simplify the interfaces have not yet achieved the desired results.

Engineering support for the plants in service – the process

I have observed during my visits to the plants and engineering centres that the process involved in providing engineering support for the plants in service remains complex and ponderous. The organisation and decisions of engineering support for the plants in service are still extremely centralised, with reporting at many levels. I can see the gap between the operators’ needs, faced with difficulty in improving or even maintaining its levels of performance, and what the engineering support for the plants in service can actually provide. For instance, it cannot currently respond to modification requests in less than four or five years. This seems to be the case in most engineering centres of the Nuclear Engineering Division.

Responsiveness to plant request

All too often, the corporate-level engineering force is unable to satisfy the plant requests in due time, either because its organisation and resources prevent it from doing so, or because it has other priorities. Indeed, I find that the engineering centres in charge of engineering support for the plants in service are constantly

having to make complex trade-offs to optimise their resources. The aftermath of the Fukushima accident this year is another example of this, and one that has made the situation worse.In this changing situation, the role of the joint teams, the bridgeheads of the engineering support for the plants in service, is vital. I understand how much they facilitate the uptake of modifications by the plant departments and, in return, warn the engineering centres of the constraints associated with handling certain issues. I appreciated meeting teams that were both motivated and proud of their profession, despite the size of the workload and the tardy and fluctuating scheduling. The gap between production and engineering in France is less perceptible elsewhere, as the plant engineering teams are more substantial. This being the case, the joint teams are, as I see it, in a good position to facilitate dialogue between the plants and their engineering support.

Engineering projects for the plants

The joint Nuclear Engineering Division and Nuclear Operations Division project

The above situation reduces the capacity of the nuclear plants to cope with the challenges they face. The operator needs a more responsive engineering force for its plants that is more attuned to its needs and preoccupations. Meanwhile the Nuclear Engineering Division engineering force needs to step back and see things in proper perspective. The “joint Nuclear Engineering Division and Nuclear Operations Division project for the plants in service” launched in 20�0 is intended to remedy this. I approve its goals which consist in, first, providing design skills in each plant and, second, making it clear to the Nuclear Engineering Division what corresponds to asset-related engineering for the major long-term projects and what corresponds to responsive design-related support to satisfy the operator’s immediate needs. However, I regret the delay in the project this year, even if this may have a lot to do with the mobilisation of the staff for the stress tests after the Fukushima accident.

Reinforcing the in-plant engineering capability

In my previous report, I have already warned about the weakness of the plant engineering capability and the flood of requests that this generates for the engineering centres. I commend the decision to provide design capability in each plant and encourage the managers of the Nuclear Engineering Division and the Nuclear Operations Division to provide staff as soon as possible for these engineering forces that are indispensable to the operator. It seems appropriate to

return the powers to the plants and I am glad to see that one of the project goals is to reduce the time taken to respond to their requests.

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Coping with ever-increasing workloads

Finding engineering

partners

The engineering centres in charge of engineering support for the plants in service are constantly having to make complex trade-offs to optimise their resources. I am not convinced that this is always taking place at the correct level. This mode of regulation incumbent on the engineering support for the plants in service will not be appropriate for the increased workload in the future. The amount of plant-

related activity is set to more than double. Even if the massive recruitment, which I commend, takes place, the engineering force will not be able to double its manpower in such a short lapse of time (see Chapter �). The company will no longer be able to stagger the jobs to smooth the load, as it has done in the past. Perhaps preparations need to be made for another approach to doing things and having them done that is more orientated towards partnerships and cooperation with other engineering forces? Under the circumstances, EDF’s integrated engineering capability would gain from opening up more to the outside and seeking collaboration or other tried and tested solutions.

Governance of the engineering support for the plants in service

Today, the operator needs to participate more actively in establishing the priorities for engineering work and what needs to be abandoned for the plants. As part of the joint Nuclear Engineering Division and Nuclear Operations Division project, a working group has proposed changes in the governance of the engineering support for the plants in service, particularly in the functioning of the still very numerous managements, directorates and committees. The technical steering committee jointly set up by the managements of the Nuclear Engineering Division and the Nuclear Operations Division will establish the basic policy for the plants. I will be watching with interest its work and the results which, I believe, will improve the functioning of the engineering support for the plants in service.

The 2012 engineering methods project

At the engineering centres that I visited this year, I was struck to see that there were still no ‘off-the-shelf’ type project management tools that are found in many engineering offices. The engineers are all too often still using their own locally-developed applications. This does not facilitate either interfacing or overall engineering performance. Faced with the great increase in work for the plants in service and for its new jobs, the Nuclear Engineering Division has begun an in-depth analysis of its methods of directing and monitoring projects. The result of this analysis was the 20�2 engineering methods project, which kicked off this year. The Nuclear Engineering Division’s big projects concerning new nuclear facilities, as well as the engineering support for the plants in service, should rapidly benefit from this project. The work on the tools and methods can greatly boost the productivity of the engineering force, which must take care not to forget that the future workload will be considerable and well above their current capacity.

The corporate departments of the Nuclear Operations Division

In the Nuclear Operations Division, two corporate departments - the Central Technical Support Department and the Operations Engineering Unit - centralise the support and expert appraisal capacity necessary for plant operation and maintenance. Halfway between design engineering and in-plant engineering, these two departments carry out projects for the plants that are particularly important in terms of nuclear safety and performance.This year, I visited the Operations Engineering Unit where I note the high quality of staff work and their contribution to the technical performance of the plants. The Operations Engineering Unit directs, on behalf of the Nuclear Operations Division management, a number of projects and processes for which it has acquired, and is recognised to have, special know-how. Its responsiveness in dealing with the many cases entrusted to it is renowned.

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Developing assistance to the

plants

Under the current circumstances, when both progress in nuclear safety and higher performance levels are being sought, I question the need to direct or manage from Paris projects that essentially relate to the plants. I see this as a rather unusual positioning of the corporate operating departments in France, of which the tasks are too frequently orientated towards directing (major projects) or

organising (processes) at the expense of providing assistance and support for the plants, which remains a side issue. As I see it, this merits analysis and comparison with the practices of other big operators in America and Britain.

This year, my visits included a trip to the Institute for Nuclear Power Operations in Atlanta (INPO, see Chapter ��). INPO handles four vital functions for all the American plants: assessment, experience feedback, assistance and training. The assessments focus on performance and are conducted by experienced auditors; they systematically integrate nuclear safety function reviews at plant and corporate levels. The experience feedback originates for the American plants and from all over the world. The events are analysed by the INPO engineering staff and pooled between all the companies. Assistance is systematically proposed to the plants whose results are deteriorating and imposed on any plants in difficulty. The action includes support visits, analysing difficulties and defining monitoring indicators. Training is available to all the companies and their contractors, featuring numerous sessions that are permanently available. This ensures that all staff members are properly qualified and have the necessary know-how before authorisation.

An example to follow

With nuclear units of many technologies and ages belonging to different operators, the American plants can nevertheless be seen as more homogeneous in their way of managing nuclear safety and performance than the French plants, although the latter are standardised and have a single operator. I am left

wondering about the causes of such a difference. It appears that INPO is contributing to this state of affairs by leaving it to the plants to take the initiative but providing its support when performance levels deteriorate and focusing its action on assistance. In view of the challenges that the French plants will soon be facing, I note that thought is now being given to the tasks and stance of the Operations Engineering Unit and the Nuclear Inspectorate. I will make a point of keeping abreast of the conclusions reached.

In conclusion, the French nuclear plants need to be able to count on a reliable and effective engineering force to rise to the challenge of the General Refurbishment. The Nuclear Engineering Division and the Nuclear Operations Division are jointly seeking optimal solutions for satisfying the plants’ need for assistance. The short- and medium-term engineering workload will not be cleared without opening up more to the outside and finding new work methods. As with other operators, the corporate operations departments need to provide more effective support and assistance to improve the results.

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MANAGING PROJECTS

Project-mode management fosters nuclear safety and cost-effectiveness. The success of projects requires directing them professionally and setting goals that are consistent with what the relevant organisational structure can absorb. They need to be more focused on how to instigate and support change, particularly when the stakes are high. This is the case for the EPR projects which represent major challenges for the Group.

Many campaigns important for nuclear safety are managed in the form of projects throughout the EDF Group. These campaigns are very diverse in terms of scale and success (nuclear safety, duration, quality and cost). If their development is not sufficiently effective and rational, projects can have negative effects on other modes of work simply because of their sheer number. Conversely, well-organised projects constitute a precious management tool.

Taking up complex technical challenges

In some cases, I have seen that specific technical problems with implications for nuclear safety and production are managed in the form of projects. They include, for instance, the post-Fukushima tests and studies as well as certain problems affecting only one or two nuclear units, such as the hot box domes of the advanced gas-cooled reactors. As a general rule, these activities are properly organised and targeted, and project-mode work is a useful asset.

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Scheduled unit outages

Another step to take

All the scheduled unit outages, such as those for refuelling, ten-yearly inspections, steam generator replacement and regulatory outages all constitute “projects”. I have noticed that they vary in their quality and results. The nuclear units with the best performance levels in the Group have the skills needed, divide the work

into appropriate packages, arrange to have the spares in due time, fix the content of the outage, get the main contractors involved in the planning and scheduling, and then carry out the activities in a safe, rational and effective manner. The levels of unplanned capacity loss factor (UCLF) in such nuclear units show the quality of the work. At a time when larger-scale work is being contemplated, particularly in France with the General Refurbishment, we should think about the efforts that need to be made in some plants to attain excellence.

Instigation of change at national level

Perfect is the enemy of good

Many campaigns are carried out at national level, particularly in France. This is not the place to describe them individually but some of them need to be mentioned: the O2EI Project (better housekeeping campaign), the INTEP Project (campaign to introduce new technology into the plants in service), the MOPIA Project (campaign

to set in place an attractive business policy) the AMELIE Project (spare parts management campaign), the PHH Project (human performance practices campaign), the SAT Project (systematic approach to training campaign), the SDIN Project (nuclear technical information system campaign), the BMA Project (campaign for the harmonization of practices), the REX Project (experience feedback campaign), the OCC Project (campaign for continuous monitoring of installations during unit outages) the AP 928 Project (campaign for work management), and the AP 9�� project (campaign to increase equipment reliability). With �8 reactors in �9 plants, many projects are pilot-plant based to prepare for the deployment of new methods. This is good practice, of which I approve. It involves making choices to determine how much we should standardise and how much initiative we should leave to each plant. I think that in every project, the proper balance needs to be found, with due allowance for the principle of subsidiarity under which, whenever possible, responsibilities are delegated and individuals are encouraged to show thoughtfulness and commitment in their work.

The successful projects –and there are many– maintain precise objectives and their progress is continually assessed and monitored. When they are completed or have made sufficient progress, the integration of their content into standard procedures needs to be studied with care and managed effectively to preserve what has been achieved. I have found that this is not always the case. Furthermore, the number of campaigns managed as fleet projects seems to be greater than most of the plants can handle with their current operating cycles and human resources.I note, however, in 20�� that efforts were being made to stagger the projects in time. I consider that the multi-year scheduling in each plant, reflecting the possibilities and capabilities of each plant, is a good practice. The nuclear plant governance systems (e.g. the 20�� operations and maintenance methods programme for the AP9��, AMELIE, SPP, SDIN and BMA Projects) also meet this need and should facilitate success in the plants with all these projects. These positive trends show that perseverance is called for as they are now staggered over a considerable length of time (until 20��).The creation of the position of Associate Director for Operations is a positive point: these directors help set up multi-year programmes and analyse project risks, while prioritizing and determining trade-offs.

I also note that as soon as a project management team is assigned to a major technical problem (such as one associated with steam generators or alternators) there is a risk that it will no longer be properly coordinated with other parallel projects and activities.

In the United Kingdom, I have observed work organisations for certain technical domains in which supervisors responsible for all the plants collaborate with individual plants to draw up transition maps (deployment schedules) over five years. The timing and order of deployment of the steps mentioned in

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the schedules are left to the discretion of each plant. This approach comes across as being pragmatic. Nevertheless, it is clear that with 8 plants, the British situation is simpler than in France where there are �9 plants.

The approaching peak in activity

Thinking differently

The goal of the joint Nuclear Engineering Division and Nuclear Operations Division Project is to guarantee that the two divisions schedule and field the resources necessary to effectively manage the approaching peak in activity associated with the third and fourth ten-yearly outages, plant life extension and post-Fukushima

modifications, as well as the arrangements needed for the EPR-type reactors. From the exchanges with the Nuclear Operations Division management, I gather that "to reduce the activity peak by delaying work is not the correct solution and that, on the contrary, it is necessary to confront it”. I totally agree with this.

Key decisions will need to be made about what parts of the work are to be outsourced and what are not, the specific work methods to be adopted and the way the work is organised, what replacement and spare parts will be used and the skills and manpower to be engaged by EDF and its main contractors.

New projects

Synergy to be developed

The Group’s current EPR-type reactor projects (at Flamanville, Taishan and Hinkley Point) are gigantic. They are not all equally advanced, and each has its own specific context and work organisation. As concerns project management and nuclear safety, I note the following vital points:

Leadership must be unambiguous and the organisational structure must be as simple as possible if excellence is to be achieved. The best results are obtained when the general managements of the main players in the project communicate regularly and maintain synergy where the parties involved combine their efforts to achieve the same goal. This facilitates respecting schedules, as well at the dissemination of a veritable culture of quality at the stages of design, fabrication, erection and testing, on which a proper nuclear safety culture can in its turn be based, which is indispensable for plant start-up.

A scheduling process that it reliable and comprehensive, covering all aspects of the contributions from the different players and all necessary linkages. For example, the links between design and procurement for the licensing safety case and the timetable for their execution must be indicated and clear to all: architect engineer, the designer that orders the equipment, the vendor, the quality control staff, those writing the procedures (operations, maintenance and training), the teams in charge of erection and commissioning, etc. Such scheduling makes it possible to follow the progress with the project and to manage any contingent issues and modifications in total safety and under proper control. It is also possible to schedule the surveillance activities in advance to ensure that suitable resources are available at the due time to guarantee a level of quality that corresponds to the designers' intentions.

Project teams having the right resources and the key players grouped in the same geographical location insofar as possible. The joint engineering office set up in 20�0 by the boilermaking contractor and its Chinese client for the Taishan Project is a good example of this.

Using tried and tested standards and methods for managing data, documentation and work organisation (for instance the design of piping and the routing of cables).

Exemplary safety in the workplace and housekeeping at all stages of construction. Everyone must be aware of the need to preserve and protect the equipment delivered to the worksite, before and after erection. This is particularly important in the case of coastal sites. I have observed that sometimes this is not done properly.

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Skills and experience in all domains, in particular the placing of contracts, scheduling, nuclear safety management and the surveillance and coordination of work.

In conclusion, work being carried out in project mode is essential to ensuring effectiveness in the nuclear industry. As I indicated in my report last year, nuclear safety and cost-effectiveness are closely linked. Effective project management is one way of optimising both at the same time.

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TOGETHER WITH CONTRACTORS TOWARDS BETTER OVERALL

PERFORMANCE

Year on year, dissatisfaction with contractual relations can be found on both sides since the requirements grow as fast as the corrections that are made after each fruitful exchange. The solutions and the commitments frequently result in superficial complexity without treating matters as comprehensively as the nuclear industry demands. It must be made sure that the charter for progress and sustainable development, as well as the recent agreements on socially responsible subcontracting at EDF, usher in change in the status quo as regards industrial relations in EDF SA.

The role of contractors in the nuclear plants is a vital one in terms of both cost-effectiveness and nuclear safety. Some 80% of all maintenance work is contracted out and this proportion may rise with the increase in the number of ten-yearly inspections, the General Refurbishment and the work required as a result of the experience feedback from the Fukushima accident.A wide range of means of improving the conditions under which contractors operate are being deployed in the plants at the initiative of EDF. Here I wish to give an up-to-date list of the current avenues of progress.

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Better sharing of strategic issues with contractor companies

The MOPIA Project (campaign to set in place an attractive business policy) offers a full set of tools but has not been as effective as expected. Many arrangements have been made to improve the business conditions for contractors, particularly clearer contract terms and the development of incentive schemes (best bidder, bonuses etc.). I am afraid that although these arrangements have, in general, been well received by the contractor companies, they do not offer sufficient progress as regards sharing the strategic issues. There does not appear to be any substantial progress in the quality of work or in the planning and duration of the field work to better control the outage lengths.The desired change will not come from the contractors alone; EDF will need to take action, a point that I will return to later. It seems that this is the main problem here and I wonder about the reasons for the current situation. Is it really so difficult for a client to regain control of the requirements that it imposes? Have past practices taken such a hold as to be unchangeable?

Training fosters progress

I think that the first step should relate to the contractor training set-up. Training should, as I see it, extend to all staff, not only field workers. All working in the nuclear industry must be conscious of the associated requirements relating to nuclear safety, industrial safety, radiation protection, the environment, quality

assurance, etc. It is true that EDF provides support for all companies when they begin working in nuclear field, but the acquisition of a nuclear safety culture must be constantly fostered and developed by the contractor company itself, with the assistance of EDF if necessary. A joint strategic vision cannot otherwise exist. EDF needs to provide itself with the means to create such a situation for all its contractors. One of the obstacles resides in the fact that the EDF budget is relatively small for certain companies.In the USA, INPO – an association of 2� nuclear operators with a total of �04 nuclear units – provides the training and assessments of workers at all levels in the contractor companies. Checking is selective and the operator and contractor management teams are directly involved. I am convinced that this arrangement is more effective than that currently used at EDF.

Planning work at the plants further ahead

Foresight and planning mean

success

Here, again, I call on EDF and its contractors to work this out between them. Despite perceptible progress, I find that EDF does not clearly define its outage programmes sufficiently early and does not award all the contracts in due time. Under the circumstances, the contractors do not have the resources available to concurrently plan their work in the different plants where

they have been chosen.Scheduling can be disturbed by the very numerous modifications incorporated into the EDF plans, which are issued either as soon as they are specified or in batches. These modifications cover technical issues, of which nuclear safety is one. No outage for maintenance resembles the previous one. This type of situation also exists in other countries, though their technical rule sets seem to evolve more slowly. The positive side of the situation for EDF is that there is on-going action to increase nuclear safety. Is the required effort, however, compatible with the resources and skills of the Nuclear Engineering Division, the Nuclear Operations Division and the contractor companies?At Sizewell B, an EDF Energy plant in the United Kingdom, I encountered a team of planners during a visit who were working with contractor representatives �8 months before an outage. Some EDF plants have pro-active partnership policies that call for contractor involvement long before unit outages when the resources make this possible.

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Improving working conditions

Rethink and simplify the rule

set

As concerns the physical conditions of work at the plants, I observe that the situation is improving year by year and this is confirmed by the contractor representatives that I meet. Yet, the many technical and administrative formalities that have to be endured before a job can actually begin and the unpredictability in the scheduling generate unacceptable waits. The

‘hands-on’ time when the professional action covered by the contract is really taking place, is only a small proportion of the total time spent. I have identified the main factors that regularly cause trouble:

Organisation of the working environment which places a heavy burden on the field worker and his supervisor. The contractor job supervisor is responsible for industrial safety, radiation protection, fire prevention, the technical case files and lockout for field work, which all amount to a sum of preparations before arriving in the work area.

Instability of the scheduling of jobs, as previously mentioned, which results in delays as adequate consideration is not given to alternative scenarios.

Missing spare parts which can interrupt jobs and result in workers being switched to other jobs scheduled at other times during the outage, with the final result of the overall schedule being upset.

Special tools which are sometimes unavailable when unit outage activity is peaking and often result in long waits before the stores can issue them.

Logistics which need to be improved to create a proper workflow (for instance, airlock equipment and assembly, scaffolding and removal of heat lagging).

These weakness need to be rectified as soon as possible in light of the big jobs ahead.In the best-organised plants outside France, I find that the number of scheduling staff is generally considerably greater. Apart from controlling the official schedule, the critical path (the red line for the outage) is monitored at very close intervals and alternative scenarios are prepared and assigned resources to be able to cope with contingencies with minimum disturbance. I also note that field workers are generally given far more support and that sometimes specialists arrive in the work area just in time, a bit like a surgeon in the operating theatre.

Sub-standard maintenance

For greater visibility

The year 20�� has been marked by more cases of sub-standard maintenance than previous years, with the responsibility shared between EDF SA and its contractors. The amount of EDF contracting work varies from year to year, depending on the reasons for the outages (e.g. a large number of ten-yearly inspections in progress),

the number of modifications and specific work programmes (e.g. the O2EI Project, the fire action plan and the General Refurbishment). Without sufficiently long contracts, contractors can hardly be expected to retain staff with the required skills. Furthermore, pressure to reduce contract prices often results in cutbacks in supervision.

More staff motivation

More responsive recognition

Bonuses and penalties are frequently totted up annually, which is readily understandable in terms of company management. Yet the final result is often zero since the penalties cancel out the bonuses, which is very discouraging for those that deserve bonuses.

I have observed in the US that motivating the players is a major concern in company management and bonuses are paid out very soon after jobs are completed.

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Bringing surveillance up to standard

In EDF, surveillance is being developed to provide quality assurance for major jobs. The staff members in charge of surveillance hone their professional skills in the field and attend special new courses on complex activities. Nevertheless, the profession differs between plants and divisions, is given little credit and has not established a career trajectory. Yet it is a full-fledged profession and the volume of work in the next few years will make it a very important one.

Better work means less supervision

The ideal system would enable contractors to get everything right the first time, with external checking by EDF sized accordingly. Prevention would then pay dividends.

In the joint teams in plants at the Nuclear Engineering Division, surveillance is affected by seasonal ebb and flow in the activities, and reinforced by sub-contracting to cope with waves. This situation merits being continuously assessed.

What I have seen, however, during my visits at plant and corporate level is many players taking energetic action, and additional organisation interfaces appearing to limit the effects of such situations. I hail them and respect their work but I still deplore the waste of time and trouble caused by weaknesses in organisation which are prejudicial to nuclear safety.

Numerous avenues of progress identified at corporate level show promise, such as the OCC Project (continuous monitoring of installations during unit outages), the arrangements for outage planning, as well as the AMELIE Project (spare parts management), provided sufficient scope is left for local initiative and pragmatism. For instance, giving more prominence to contractor assessment records throughout industrial catchment areas is a good decision. Indeed, corporate-level assessment of a contractor organisation consisting of a number of regional offices with different levels of performance is hardly meaningful.Another difficulty which I often hear mentioned in the plants is that some jobs and generic contracts are carried out by companies selected at corporate level without the plants having a voice in the matter. The plants having built up fruitful relationships with other contractors thus see their work wasted.

As part of the stress tests requested by the ASN after the Fukushima accident, the issue of "reliance on sub-contracting" was selected. This corresponds to a particularity of the French system and I see no direct link between it and the accident. In Japan, the number of sub-contracting levels for the same job can appear numerous in the eyes of Europeans. I have never heard of such practices in France.

In conclusion, the contractor companies, the joint ventures and the organisations representing the professions and EDF SA must, I believe, do more to shape their mode of operation as one of partnership. The charter for progress and sustainable development and the agreement on socially-responsible sub-contracting in EDF represent steps in the right direction, but do they provide sufficient leverage to rapidly fulfil the ambitions announced for the nuclear plants?

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EDF NUCLEAR ACTIVITIES OUTSIDE FRANCE

The operations context differs with the country but everywhere the same priority is given to nuclear safety and the constant challenge of achieving high performance. There were no serious events that affected nuclear safety in any of the 20 nuclear reactors in EDF’s scope outside France. The numerous good practices identified within the Group need to be more effectively shared in the operation, construction and commissioning of new reactors.

This year, I visited some of the nuclear facilities of the EDF Group outside France. EDF has a majority stake in EDF Energy, which operates fifteen reactors in the United Kingdom and plans to build four EPR-type reactors there. In addition, the EDF Group has a 49.9% shareholding in Constellation Energy Nuclear Group which operates five reactors in the United States and a �0% shareholding in two EPR-type reactors under construction in China.

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Points in common

I have noted some issues that undeniably contribute to nuclear safety in a measurable manner.

Training is often well organised and associated with a method of accreditation by a commission including players from outside the company. For operations staff, training is integrated into the shift cycle, guaranteeing regular training and assessment. The line management is characterised by its high degree of involvement, striving to satisfy current plant needs.

The nuclear safety supervision committees frequently benefit from the presence of highly-qualified external members.

Care is being taken to try to stop staff following the procedures unthinkingly and losing sight of the ultimate goal of their action.

Communication and synergy between the companies of the EDF Group is improving as regards technical matters and nuclear safety, for instance in the fields of chemistry, engineering, alternator technology and by participation in peer reviews.

The control rooms are characterised by an atmosphere of calm and attentiveness, and I have observed the systematic use of human performance tools there.

The unit outages are the subject of planning well in advance and hence of excellent quality. The schedule is protected against the effects of contingencies by calling in dedicated teams.

Each formal meeting begins with a message about nuclear safety or industrial safety, enabling the management to clearly state its expectations, while encouraging the staff to reflect on nuclear safety.

The plant nuclear safety assessments rely on recognised outside organisations (INPO and WANO).

EDF Energy in the United Kingdom

Managerial practices

The leaders are forging nuclear

safety

For British plant operations, three Chief Nuclear Officers (CNOs) are each in charge of two or three plants. The plants thus benefit from close and effective support. I would like to draw attention to the need to ensure that the plant directors have sufficient independence.

I am aware of a strong will to increase both nuclear safety and cost-effectiveness, for instance by substantially reducing the number of outstanding work requests or by regularly investing to keep operating equipment up to standard. This is done on the basis of a risk management system that facilitates decision making and the judicious utilisation of resources. I have, however, observed that this system can fail (see Chapter �2).Surveys of safety culture perception are regularly carried out on the employees of EDF Energy and its main contractors. The results of the surveys (with very high response rates of 90%) are compared with those of similar surveys carried out by electricity companies in the United States. The results are used by the managers to determine justified, targeted action, at plant and corporate levels.I was also impressed by the efforts made to offer innovative leadership training at all levels. The training courses relate to ‘nuclear professionalism’, human performance tools, mentoring or the development of leadership by working with groups comprising employees from different professions and hierarchical levels, which are referred to as diagonal slices. Striking images with clear messages are used to show how the way in which work is actually done can deteriorate to a point where it fails to match up to what is expected by the management and how, at the same time, dangers, risks and equipment faults can accumulate without being detected until the safety margins are lost.I note that the independent organisations for checking nuclear safety in the plants do not yet appear to have sufficient status or authority. I observe with satisfaction that a new approach, after benchmarking

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with nuclear safety and quality teams from the French plants, has been experimented with and found promising in three British nuclear power plants.For nuclear safety checking at plant and corporate level, EDF Energy has opted to rely on peer reviews conducted by WANO every three years. At EDF Energy there is no internal inspection organisation that can make large-scale audits or assessments comparable to the evaluations conducted by the Nuclear Inspectorate in France.I note that, in 20��, there was a strategic re-orientation at fleet level which set the priorities for the nuclear safety committees. Apart from examining the major organisational and technical changes affecting nuclear safety, emphasis is more clearly placed on the operations-related issues raised by the plants. This development is appreciated by the plant directors and appears to me to be positive in terms of nuclear safety.

Dynamic relationships in the field

Knowing how to create

favourable situations

In the plants, I have noticed dynamic relationships with most of the big contractor companies. The nuclear safety objectives and training courses determining workplace behaviour patterns are specified and imposed jointly. Voluntary safety representatives are in place in all EDF Energy departments, and I appreciated their enthusiasm and commitment. The contracts are generally long-term with straightforward financial motivation for workplace safety and quality.

Major efforts are made to achieve the goals of the EDF Energy’s ‘Zero Harm’ Campaign. I note a strong desire to simplify or eliminate any pointless administrative procedures associated with the key processes. These actions stem from the analysis made after a fatal accident in Heysham � in 20�0.The drive for continuous improvement of quality has been re-invigorated after the discovery of instances of sub-standard maintenance. The action of the EDF Energy and contractor field supervisors is recognised as vital for achieving progress. These supervisors, who are numerous, receive special training and accreditation for their role. This is highly commendable, in view of the authority given them and the resources assigned.I note, however, that making technical decisions is sometimes too readily delegated to contractor companies as regards both maintenance operations and local engineering matters. This point merits careful attention as it has the potential to fragment the nuclear operator’s responsibility as owner for nuclear safety.

Noteworthy points concerning operation, and interesting initiatives

In all the plants, WANO peer reviews indicate scope for progress in the maintenance of fire equipment and the management of fire loads.As regards radiation protection, British staff benefit from the low levels of exposure inherent in the design of their advanced gas-cooled reactors. I also noted with satisfaction that the Sizewell B plant is maintaining itself in the top decile results worldwide for the doses received in pressurized-water reactors. I note that contamination control has been announced as a top priority for all the plants.I observed a highly-effective practice in one plant: the one-stop process that quickly corrects any discrepancies when operating procedures are applied. This practice answers the need to keep the procedures up to date, justifying strict compliance with them. This seems to call for benchmarking by the staff of the French plants.

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Three significant events

I have chosen some of the technical events that occurred in 20�� to consider in detail. The first was classified Level 0 on the International Nuclear Event Scale and occurred in a coastal plant as a result of an invasion of jellyfish (800 tonnes), illustrating the need to be prepared for any kind of external event. In point of fact, the operators were at all times in control of the situation and the reactors where stopped in total safety. The prompt and resourceful use of trawlers also helped to cope with the event.

In another plant, an event classified Level � on the same scale affected the reactor auxiliary cooling systems after pipe failure, where sensitivity to corrosion had previously been identified. This event was highly significant in terms of controlling the decision-making processes at project management level. It is detailed in Chapter �2.A last event relating to actions central to the operations profession was classified Level � on the scale also caught my attention. After a short unit outage, the steam generator auxiliary feed valves were not re-opened as expected during re-starting and stayed that way for nearly nine hours. Subsequent analysis of this violation of the technical specifications and system alignment error revealed incomplete checking before starting, lack of rigour in the documentation and log-keeping, as well as unsatisfactory communication within and between the teams involved.Together, these three events throw into stark relief three vital issues for any nuclear operator. They have been the subject of in-depth analysis in the relevant plants and the experience feedback has been shared with the other plants and at corporate level within EDF Energy.

Technical challenges in advanced gas-cooled reactors

A unique and demanding technology

The advanced gas-cooled reactors are now facing complex technical problems that necessitate the mobilisation of highly-specialised engineering staff. Their task is also complicated by the fact that this reactor design is not found anywhere else in the world, offering little scope for joint assistance and the pooling of experience feedback with other operators. Some of the technical

problems now have to be managed without the assistance of the equipment makers and designers, who are no longer in business.As concerns the study and comprehension of phenomena with nuclear safety implications, I note that work is continuing on the graphite cores of the advanced gas-cooled reactors, the cracking of steam generator piping and the deposition of carbon on the fuel in certain reactors. These efforts show that the British nuclear industry needs to adopt a proper policy of strategic long-term research and development work. The first loading into the advanced gas-cooled reactors of the newly-designed "robust fuel”, the culmination of a long process of testing and technical study before licensing, is a positive point.Consequently, I consider that it will be necessary to maintain a high-level engineering capability until these reactors reach the end of their service lives, and possibly during their decommissioning. Maintaining the special skills will require an accredited training system. The recent accreditation of the first departments (design authority, engineering, safety and regulation departments), for the first time anywhere in the world for these disciplines, fulfils this need.

New nuclear plants: the EPR project

As part of the plans to build new nuclear generating facilities in the United Kingdom, a number of submissions were made to the Office for Nuclear Regulation and the authorities for environmental protection and regional development. News of the nearly unanimous vote in Parliament in July 20�� that confirmed that nuclear power would be included in the future energy mix was received with enthusiasm inside the company.

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The structure of the EPR Project appears to be judicious; a single body is charged with monitoring the studies, supervising the work and handling commissioning, and is preparing to become the future operating organisation.Numerous features of the Sizewell B reactor design, the only PWR in the United Kingdom, are considered as technical points of reference, such as the ultimate heat sink and the stand-alone operability time on loss of the electrical power supplies. These important points have been the subject of an in-depth study with a view to licensing the EPR type in the United Kingdom and to determining what post-Fukushima actions are required. Any differences between the reactors of the EPR type in France and the United Kingdom will need to be carefully explained in the public arena, and I recommend that the reference design of the British installation be settled as early as possible.

I regret that the proper functioning of the project is still hindered by problems relating to the computer systems and their security, making it difficult to access the drawings and documentation across borders with the architect-engineer in the United Kingdom and the design offices in France.

Constellation Energy Nuclear Group in the United States

Managerial practices

I have visited Constellation Energy Nuclear Group (CENG) for a number of years in succession. The arrangements for managing its reactor line-up of � pressurized-water reactors and 2 boiling-water reactors are now well-established. I note that the nuclear excellence dashboard performance indicators are being used effectively. The unplanned capacity loss factor is below 2% which confirms that CENG is in proper control of the reliability of its equipment and maintenance operations, which is vital for nuclear safety and a positive factor. On a more detailed level, I note that the equipment reliability index – created by the Institute for Nuclear Power Operations, the Electric Power Research Institute (EPRI) and the suppliers – used by the plants to compare their levels of performance is being used productively. Its use in other plants of the Group has begun and I encourage more widespread adoption.

As previously mentioned in my reports, the close and beneficial collaboration between CENG, the Institute for Nuclear Power Operations, EPRI and the Nuclear Energy Institute (NEI) is plain to see. These organisations clearly provide numerous American electricity companies, some of which are small, with vital support which is comparable to that from which EDF’s French plants benefit via the company’s internal support departments.

CENG operates two boiling-water reactors at Nine Mile Point on the shores of Lake Ontario. The basic design of Reactor � at Nine Mile Point is very similar to that of the first nuclear units at Fukushima (Mark � type). I therefore made a point of obtaining information on this plant and the main modifications and improvements made since �9�9. Detailed analysis of the lessons directly applicable to Nine Mile Point Plant is outside the scope of this report, but I note with satisfaction that CENG has been very proactive in the American nuclear industry actions post-Fukushima.More generally, for the use of operational experience feedback (particularly TMI, the 9/�� attack and recent advances in knowledge), I note that the continuous improvements of the nuclear safety arrangements (design, construction and training) are not achieved only by the rules laid down by the Nuclear Regulatory Commission (NRC). Many actions and modifications that are significant in terms of nuclear safety have been made on the initiative of the American operators, frequently submitted to the NRC via the Nuclear Energy Institute. This can be compared to the French and British processes of ten-yearly nuclear safety re-assessments but is not as methodical.

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My observations in the field

Ginna Nuclear Power Plant was commissioned in �9�8 and is the pressurized-water reactor that has been in service for longer than any other in the United States. Its operating license was recently extended to 2029, corresponding to sixty years. This is an example for all the pressurized-water reactors operated by EDF, as it prepares to extend the service lives of its reactors.I attended one of the quarterly meetings of the Nuclear Safety Review Board chaired by a qualified personality from outside the company. This meeting is always preceded, the day before, by a walkdown in the plant and a series of meetings with the plant personnel in each of the main fields of operation. Those I interviewed were all asked to express their feelings about their own levels of performance. The interviews helped reach an understanding as to the manner in which the personnel determine, describe and even assess their personal performance. The need to set goals suited to all levels in a consistent way was brought up in a pragmatic manner.

I also note that CENG’s three plants assist each other effectively during unit outages by staff transfers that can be very substantial (around half the maintenance department staff).

Knowing where we are going

On a number of occasions, I also observed the CENG central management and the plant managements requesting personnel to explain their actions and rank the performance levels of their plant. This way of doing things seem to be very appropriate.

The CENG nuclear safety chief has a solid diagnosis available and the priorities for improvement are clear: lock-outs, circuit alignment and safety in the workplace. As I see it, this means that nuclear safety is constantly being critically reviewed and upgraded.The managers are motivated and demanding in terms of requirements and nuclear safety. One of the managers recently mentioned in a meeting that, in view of certain shortcomings, there was a need to move on from dissatisfaction to intolerance and that things accordingly needed to change. I think that this type of attitude needs to be more general within the Group.I also note the appointment, at CENG operations meetings, of a Nuclear Safety Advocate who has the role of promoting nuclear safety during the meeting. This practice, which fosters feelings of responsibility, seems to be worthy of interest and offers parallels with the role of the safety engineer in the French plants.

Decision makingIn one of CENG’s plants, the operations team encountered difficulties in determining the cause of irregular test performance by an item of equipment important for nuclear safety (a standby turbine-driven pump). The technical support provided for the operations teams by the local engineering force focused on a single technical cause assumption which proved to be wrong. The dialogue between the engineering and operations staff was deficient to the point where the nuclear safety authority questioned the ability of the plant to deal with this type of problem.The CENG management then agreed to an in-depth analysis of the organisational structure and decision-making chain in the event of a contingency. This analysis led to setting up a new process: integrated problem identification and resolution process, specifying the responsibilities of the different people and organisations linked to operations. This initiative appears to have been effective and well appreciated. It is now used in all CENG plants.This event clearly illustrates the difficulty in effectively connecting operations-related decision making – normally handled by the operators – to the numerous other processes. These include adverse condition monitoring, operability criteria, the corrective actions programme, failure mechanism identification, risk management, human performance, equipment reliability (AP9��) and post-incident analysis. The method, just as much as the solution adopted, needs to be given careful consideration by nuclear operators as the issues cut clear across all the organisational structures. At some time or another, every organisation needs to be re-appraised by those who put it into place. This can be a complex process, but it is always a sign of a good nuclear safety culture.

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Noteworthy events

An earthquake occurred in the east of the United States during the summer of 20��. The effects were perceptible in one of CENG’s nuclear plants, but the intensity was well below the design basis and had no effect on reactor operation or any implications for nuclear safety. Classified Level 0 on the International Nuclear Event Scale, it nevertheless revealed that the operators had difficulty in determining, within the time limits, the intensity of the earthquake from the control room as required in the procedures for emergency plan initiation. It is to be noted that special knowledge, rarely used by operators, is needed to correctly interpret the readings available. This finding needs to be made known to all the EDF Group plants to ensure proper application of this type of procedure which is rarely used but extremely important.Another event of natural origin, Hurricane Irene, affected a CENG plant in September 20��. A sheet of metal that came loose from the turbine hall cladding gave rise to an electrical fault in a transformer, causing one of the two reactors to scram. This event, which was classified Level 0 on the International Nuclear Event Scale, was correctly managed by the staff. Investigations showed that the cladding had not been properly installed and that the design drawings were not sufficiently explicit. Previous wind-damage feedback about similar cladding was not taken into account.

Taishan Nuclear Power Company Joint Venture Company in ChinaThis year, I visited the construction site for two reactors of the EPR type at Taishan. I saw how the work had progressed, with the schedule for Reactor � now very close to that for the Flamanville � EPR. The metal dome on the reactor building, which was installed during my visit, was a symbolic moment for this immense site where more than �0,000 people are now working.I also met the teams managing the project, who explained the development of the joint AREVA and China Guangdong Nuclear Power Company’s design office (the client’s engineering

and boilermaker forces). This new office has been found very effective and has been able to produce erection drawings on time, a situation that I noticed during my previous visit.The Chinese staff of the Taishan Nuclear Power Company Joint Venture Company and China Guangdong Nuclear Power Company rely on the extensive experience accumulated by their testing and operations teams through the commissioning of CPR 1000 reactors.As is the case for Flamanville �, I also noted that it has been decided to qualify the equipment for the consequences of severe accidents before start-up by making maximum use of the EDF SA approach.At the headquarters of China Guangdong Nuclear Power Company, I was shown the plan to create an independent safety organization at plant and corporate level, corresponding to EDF SA practice. This will increase nuclear safety as the number of reactors in service is rapidly increasing. I am glad to see the active cooperation and exchanges with the Nuclear Operations Division’s Nuclear Inspectorate, which extends to the training of Chinese inspectors.More generally, Chinese companies are quickly becoming major players in the nuclear field throughout the world, with �4 reactors in service and 28 under construction at the end of 20��. Holding the two-yearly general assembly of WANO in Shenzhen in October 20�� was a symbol of their new status. I consider that it is essential for the EDF Group to continue to do its utmost to share its construction, commissioning and operating experience with the Chinese companies so at to promote a high level of nuclear safety. I note the opening of an EDF office in Shenzhen in 20��, closer to the industrial concerns and operators, which will facilitate experience feedback and the exchange of information.

In conclusion, I am glad to see increasingly active cooperation between the different nuclear bodies of the Group. This diversity is an asset that can be a driving force for substantial progress in the field of nuclear safety. I encourage the development of such exchanges on the existing nuclear facilities and the projects for new reactors. All have much to gain from opening up to the practices of others, regardless of their background.

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VISITS OUTSIDE FRANCE

Sharing experiences and methods with nuclear operators in other countries enables us to question our own practices and put our entire field of activity in proper perspective. Exchanges with INPO, the leading player worldwide in performance assessment, are also indispensable for challenging the Group's methods and understanding the checking carried out in CENG’s plants.

The INPO headquarters in Atlanta, Georgia

I had the privilege of spending quality time with a number of the top managers, which proved extremely useful as INPO plays a major role in the nuclear power industry in the USA. Its authority results from the full and unreserved support of the presidents of its member companies. It is adequately funded and most of the staff (80%) are full-time employees. It plays an essential role in its relations with the many American nuclear operators who do not have any substantial internal corporate-level functions. With more than �00 reactors in the United States, as well as others belonging to members in other countries, INPO makes assessments of and provides support for a wide and diverse number of plants and organisations. It appears that its value essentially resides its considerable professional knowledge, its commitment and its impartiality since it belongs to none of the companies it assesses. INPO has an external viewpoint and is not exposed to management constraints or internal pressure by the operators evaluated. It is thus easier for it to call into question the pertinence and the credibility of company policy.

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Its main functions consist of making assessments (�4 per year), accrediting training programmes, managing experience feedback and offering support for American power plants.

The assessments

The assessments focus on companies and plants. After the assessment of a plant, an overall performance ranking is confidentially communicated to it. This ranking is discussed between the Chief Executive Officers of INPO and the company involved.

INPO organises an annual conference for managers during which warning signs are examined in a closed session. Last year, the pressing issues were the increase in the number of significant operating events (Publication SOER �0-2) and of automatic and manual reactor trips, underperformance by the operations teams and failure of backup diesel generators. The best plants are identified and the managers of the low-performance ones are asked to explain to their peers what measures are being taken to reduce the risk that their company represents for the nuclear industry as a whole.

At INPO, I was shown an excellent summary of the types of plant reactions in cases of deteriorating performance and hence deteriorating INPO rankings:

There are plants that immediately seek to re-achieve excellence, exhibiting a will to turn things around from the first signs of deterioration by taking aggressive action and accepting critical feedback from the hierarchy whatever its source. They make it plain that they are not satisfied with the situation, without seeking excuses and show their commitment at all levels.There are plants in which the situation continues to deteriorate, where the managers are slow to recognise and accept that there is a problem, tending to explain away rather than rectify the issues and hesitate to make decisive changes. They react defensively, quoting their good performance levels in the past rather than the best levels currently achieved by others.

I think that there is much to be learned from this.

Furthermore, INPO offers a system of progressive support with targeted missions after each assessment for each avenue of progress identified. For a plant in difficulty, it creates an ad hoc oversight commission that meets its chief executive officer every six months.I particularly remember an interesting observation in some American feedback: "the worst plants generally have staffing pipeline problems in operations, with the result that the other departments lack process skills. The have also often had budget cuts.”I also discussed the post-Fukushima action with members of the assessment team that I met (see Chapter 4). Like WANO, INPO must also include beyond-design-basis situations in its performance assessment criteria and objectives. At present, the Severe Accident Management Guidelines do not cover fuel interim storage pools and therefore need to be supplemented.

Performance indicators

Most of the indicators show that performance levels in the industry in America have reached maxima or are stagnating and “the strong propensity for significant events detected in early 2010 is continuing”.The operability factors for standby diesel generators have never been as low in the United States. On the basis of their probabilistic studies, I see that the American operators are increasing the amount of elective maintenance work on diesel generators during plant operation. In most other countries, this is not authorised or is tightly controlled by the safety authorities. I consider that this question needs to be the subject of international debate, particularly in light of the Fukushima accident.Fuel reliability is an issue on which INPO is working in close liaison with the suppliers, through the Supplier Participant Advisory Committee. In 200�-200�, only ��% of the plants could boast no cladding leaks over a period of three years. The proportion has now reached �0% (��.�% for pressurized-water

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reactors). In 20�0, 92% of the plants had no leaks. This is a good example of collaboration between the operators and suppliers with a view to increasing nuclear safety.

Avenues of progress identified by INPO

INPO’s intention is to discuss with the sites potential areas for improvement before the facts have been fully researched and established so as to forestall any incidents as far as possible. They also intend to increase the observation of the operations teams.INPO also intends to concentrate on the operator’s fundamental skills and knowledge. In the recent Significant Operating Experience Report ��-�, it seeks to foster a situation where substance prevails over form, focusing on what is done in the actual process.INPO issues useful recommendations on topics such as operational decision-making, nuclear safety culture and dynamic leadership.Together with the Massachusetts Institute of Technology, it runs a training syllabus for chief executive officers and top executives who have recently started working in the nuclear sector.I was also shown a particularly interesting feature of another syllabus: the e-learning tool NANTel. This system, which is also available to service providers, covers issues such as human performance tools and foreign material exclusion. INPO is beginning to work directly with contactors and not only with operators. More than 9�,000 connections to the NANTel site have been logged.Action is also in progress to encourage service-providers to participate more in building up experience feedback records, including during the construction phase.

INPO makes videos of the main events in the nuclear industry. This is an excellent initiative, particularly for the new generation of staff. I recommend their use throughout the EDF Group.

The nuclear industry in South Africa

In South Africa, the electricity company ESKOM is in charge of generating electricity throughout the country, mainly from coal. It also operates the only nuclear power plant in Africa. From the outset, it has cooperated in peer reviews and benefited from the assistance of WANO, INPO and the IAEA. It has also signed a technical support contract with EDF SA as the reference plants for its two 900 MWe pressurized-water reactors are French. They have been in service since �984.During my visit, I observed that it is actively engaged in benchmarking and encourages international scrutiny. The EDF engineers at the plants are well integrated with the local staff and the ESKOM hierarchy. EDF practices constitute a reference point for defining modifications and for operations. In recent years, a number of major modifications have brought the South African facilities up to conformity with the IAEA standards (Publication INSAG �2 relating to basic safety principles for nuclear power plants) for new nuclear plants. ESKOM has used probabilistic studies of nuclear safety in operations as part of the process for determining priorities and making decisions.

The operations department is well staffed and has solid experience. The training programme is directly accredited by INPO. The line staff act as if they own the training. The simulator updates and the different procedures associated with them are carefully coordinated with the changes incorporated in the plant’s reactors. The operations personnel carry out simulator training for one week out of six, with the shift rota arranged accordingly.

I was impressed by the staffing and the resources of the training department, with nearly �0 instructors working in modern facilities, open to the outside (especially schools) and fully integrating the contractor companies.Many additional staff have been recruited and are under training or occupy supplementary positions set up as part of plans to build a new plant.Substantial investments have been made to keep the plant up to standard. Replacement of the steam generators and increasing the thermal rating of the steam supply system are being planned. It is worth pointing out the good condition of the Koeberg steam generators, which are the last of

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their generation still in service. This attests to the scrupulous monitoring and control of the chemistry parameters throughout their 2� years of operation.I noted that one of the reactors has excellent reliability results for recent years, with a coefficient of unplanned capacity loss factor of less than 2%, while the other reactor was affected by a turbine design problem, recently rectified, which significantly reduced the reliability results. Furthermore, airborne contamination in the reactor building during a unit outage resulted in the slight internal contamination of 24� people. The similarity with an event that occurred earlier in Tricastin Nuclear Power Plant in France which was not given consideration in Koeberg shows the importance of experience feedback.I observed that one of the challenges with which ESKOM is faced is being able to plan and schedule the unit outages sufficiently far in advance to be able to have the necessary job packages and spare parts available in due time.I also observed that the managers of the ESKOM nuclear activities invited WANO to organise peer reviews in their plant and also give an outside view of the different types of organisational structures envisaged to supervise the nuclear branch of ESKOM which mostly operates fossil-fired plants. Rightly, this organisational aspect is considered vital to guaranteeing nuclear safety in this type of situation.I also noticed that those I spoke to were very concerned about the checking and surveillance of vendors and service providers, as well as the methods to be adopted for fostering suitable behaviour and guaranteeing regular quality of work.

As regards nuclear safety management, I observed that ESKOM was seeking to perfect its independent nuclear safety organisation on the basis of French principles and practices. A French nuclear safety engineer has been seconded to Koeberg for this purpose. The nuclear safety committees seem to be well organised, with performance benchmarking and practices being regularly compared with those in France and the United States.

Finally, I met with some South African nuclear safety authority staff, both in the plant and in Pretoria. Faced with the difficulty common to all authorities with few nuclear facilities to check, I note the bilateral relations with other nuclear safety authorities, including the French ASN and the US NRC.

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EVENTS IN THE EDF GROUP

The events covered in this chapter relate to the main operations professions: maintenance, operating, engineering and projects. They show the need to continuously consolidate the human and organisational lines of defence.

12.1 EDF SA: premature wear of diesel generator bearings

Each nuclear reactor is equipped with two redundant diesel-driven generating sets capable of providing backup power for stand-alone operation of the main safety-related equipment in the event of station blackout (high-voltage lines). Furthermore, in the event the two backup diesel generators fail, each plant has a last-resort standby generating set that can rapidly be hooked up to a nuclear unit in time of need (diesel-driven in most of the 900 MWe series plants and gas-turbine-driven in the others).After the original maker ceased production of the connecting rod big-end bearing shells for the standby diesel generating sets of the 900 MWe series units, another company – the current leader the field – began producing them in 2002.The diesel engine company responsible for engine supply and maintenance then asked this supplier to manufacture bearing shells identical to the previous ones. It should be pointed out that the diesel engine company is also not the same company that originally designed and manufactured the equipment.After faults in 4 of the generating sets between 2008 and 2009 and in light of international experience feedback, the diesel engine company began to doubt the durability of the components and proposed a design change.Without waiting for the end of the in-shop qualification tests (�8 months from September 2009 to March 20�0), the new generation of bearing shells (the only ones available) were fitted at the end of 2009 to �� sets previously equipped with the former bearing shells. The ASN was kept informed. After the tests, as they were found to have very long service lives, the diesel engine company and EDF announced that the new-type bearing shells were qualified.On 22 October 20�0, three of the new generation of bearing shells failed during requalification tests after maintenance on a nuclear plant’s last-resort generator diesel engine. In-depth expert appraisal revealed abnormal wear of 8 other bearing shells of the same type.During a surveillance test on 28 November 20�0, serious internal damage was detected in the diesel engine of the standby generator at another nuclear plant.A technical team at the Nuclear Operations Division was assembled in early 20�� and examinations were begun at other plants possibly affected. These examinations confirmed the presence of premature wear in other bearing shells.The corporate engineering force's conclusion was the existence of a potentially generic discrepancy in all the 900 MWe facilities with engines equipped with these bearing shells. The ASN was immediately informed of the expert appraisal results and a generic significant event in terms of nuclear safety was declared as Level � on the International Nuclear Event Scale.However, in one of the 8 plants affected, two of the nuclear units had both standby diesel generators implicated, as well as the plant's last-resort diesel generator. This resulted in the declaration of a Level 2 significant event on the International Nuclear Event Scale.

Precise characterisation of the physical defect causing the failures led to the corrective action rapidly being determined, involving improved honing of the bearing shells in the factory, increasing the pressure in the lubrication system and changing the oil type. Meanwhile, the defective parts were replaced over a three-month period in all the engines affected (around thirty).

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In the short term, arrangements were implemented to intensify the monitoring of the behaviour of this equipment in service (more frequent oil analysis) as was an additional maintenance programme. A test engine equipped with the new better-honed bearing shells was subjected to ad hoc endurance tests.

Finally, finding a permanent solution was the subject of intense, regular technical discussions with the ASN.

In conclusion, the first thing I noticed about this serious event, which did not directly impact the nuclear safety of the reactors affected, is the promptness with which action was taken as soon as the fault had been properly identified. When faced with a potentially generic fault affecting a large number of plants simultaneously, the corporate-level forces (the Operations Engineering Unit and the Central Technical Support Department) appear to have been effective, even though the technical diagnosis was hard to establish. The proper handling of such cases with the ASN and its technical advisers from the institute for nuclear safety and radiation protection (IRSN) requires response at a level that the plants cannot provide. Maintaining, and even developing, the key skills in these organisations is thus of the highest importance.When I talked to the specialists in charge of dealing with this contingency, I also noticed the difficulty in getting a diesel engine company to respond quickly enough and make the skills available. These skills had been dissipating over time and as a result of restructuring in the sector.In the case of equipment so important for nuclear safety, this seems to show the need for greater care and vigilance, as such trends can eventually degrade even the best designs.

12.2 EDF SA: a control incident and an automatic reactor trip

An event occurred in 20�� in one of the 900 MWe units that caught my attention, even though there were no direct consequences for the nuclear safety of the installation. It was ranked Level � on the International Nuclear Event Scale. It revealed inadequate planning for a normal operating transient (a power drop), the absence of a questioning attitude when faced with something unexpected, and poor hands-on reactor control.

The facts

The power level of the nuclear unit was due to be dropped to ��% rated power to repair one of the turbine-driven feedwater pumps on the secondary side of the installation. This operation was scheduled to take place during the night, and repair work was to take approximately �4 hours.A temporary control order written by the operations department support team to prepare for the power drop (transient) was available to the control room operators. The order was not the subject of joint planning with the core and fuel engineering forces at either plant or corporate level. It specified maintaining the control rod clusters inserted by a certain amount (�80 steps). During operation at ��% rated power, the operators scrupulously observed this operating order, following flux tilt parameter Delta I.

Once the turbine-driven pump was repaired, the operating staff commenced power escalation according to the normal procedure. At �8% rated power, the rod lifting operation was interrupted due to a fault signalled by the instrumentation and control equipment. The automation department duty service was called to deal with this.

At the handover between the morning and the afternoon shifts, the operator in charge of the primary side of the installation considered that the Delta I reading was too high and requested explanations. He was told that he had to respect the temporary control order. During the handover to the afternoon shift, the computer department duty service was called in to repair the control assistance system that was inoperable due to a random computer fault. This system supplied the operator with the level and trend of the xenon-effect, an important control parameter. This display-orientated tool is not strictly required for resuming power escalation, as the operator has other sources of information. The inoperability of

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the control assistance system was mentioned during the pre-shift briefing by the associate operations shift manager. This was not considered to be a reason to stop by either the associate operations shift manager or the main operations shift manager, who authorised resumption of the power escalation with reduced monitoring capability, as the operators were experienced, having between � and 20 years of service. This instance of inoperability was not the subject of sufficient risk analysis between the operators, the associate operations shift manager and main operations shift manager.

Power escalation was therefore begun under these conditions at ��:�0 hours. The reactor operator then calculated the volume of water to be injected into the reactor coolant system to bring the power from �8% to �00% rated power using the normal procedures. He proceeded to make successive and progressive injections of water without having data on the xenon-effect in the reactor (which was then decreasing). He concentrated on monitoring the key parameters, i.e. the power, average reactor coolant system temperature and Delta I.At �4:�0 hours, the power was brought to 99% rated, the operators leaving a �% margin to allow for the inoperability of the control assistance system. Continuing to apply the chosen approach, the reactor operator continued to inject water to control the average reactor temperature and return the control rods to a less-extracted position.The rapid xenon decay continued to add reactivity which, combined with the effect of the water injection, resulted in the automatic and deep insertion of the control rods. As the action of the rods is highly effective, Delta I then rapidly decreased. This set off the alarm signalling an excursion outside the authorised envelope, resulting in the operations shift manager being called to the control room.At �4:�� hours, the operators applied an operating procedure covering this type of situation and dropped the reactor power by �.�% nominal, while injecting boron into the reactor coolant system and extracting the control rods.At �4:�� hours, the automatic DeltaT-SP protection functionality provided for the purpose reduced the power then shut down the reactor by dropping the control rods, resulting in virtually instantaneous shutdown. The operating instructions planned in this type of situation were then applied without difficulty. After analysis of the causes behind this automatic reactor trip and repairing the control assistance system, the reactor was put back into service the next day at 0�:�8 hours (criticality) and reached full power the following night.

Insufficient preparation for an unusual transient

This reactor is continuously run at �00% rated power. Extended power drop transients of this type are very rare in this type of nuclear unit, which should have meant more careful preparations, combining all the skills involved, including the plant's expert core/fuel engineer. Replicating the transient on a simulator, which is an easy matter with the resources now available to engineers, would have made it possible to devise an appropriate control strategy.

An insufficiently questioning attitude when faced with the unexpected

The perfectly justified questions of the operator beginning his shift about the unusual Delta I reading were disregarded and the team continued applying the temporary instructions. Analysis of the risk represented by the inoperability of the control assistance system was not taken far enough with, for instance, the main and associate operations shift managers failing to grasp all the implications of the situation. A proper pre-job briefing would probably have made it possible to identify all the issues.

Deficient control action

The water injected into the reactor coolant system to bring the power level from �8% to �00% nominal increased the core reactivity – which was indeed its purpose – at a time when the xenon-effect decay was also increasing reactivity. This inappropriate action illustrated that the operating staff and the main and associate operations shift managers had not fully understood the way the xenon-effect was developing. Use of the standby computer application Xenon 0D, which can be accessed on the control

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room intranet, would have partially compensated for the inoperability of this system and provided the essentials needed for comprehension.

I note that at all three moments in time, there was insufficient understanding of the physical phenomena involved.

In conclusion, this event clearly shows the need to increase operating staff knowledge of the complex physical phenomena involved in reactor control by means of more suitable training. The presence in each plant of expert core/fuel engineers now offers a way of increasing skill levels in this area and making better use of the simulation facilities.

Practices to increase reliability (here pre-job briefing), an interrogative attitude and, when necessary, the ability to say "stop", are all expressions of nuclear safety culture and represent strong lines of defence against the unexpected.

12.3 EDF Energy failure of cast-iron pipes

The facts

The two reactors of an advanced gas-cooled reactor plant were in commercial operation when pressure loss was detected in the seawater systems used for cooling the auxiliaries of one of them. A visual examination made it possible to rapidly find a large leak in a buried pipe. In accordance with the procedures, the operators reduced power and switched over to the system of the other reactor to provide cooling. The reactor involved was then shut down for repair. The operating staff had no great difficulty in ensuring compliance with the technical specifications. The leak was clearly caused by internal corrosion which had eaten through the wall of a cast-iron pipe.

The context

Cast-iron pipes were commonly used for the seawater systems of the British advance gas-cooled reactors. The way seawater causes corrosion is well known and documented. The owners of the EDF Energy facilities had not carried out replacement and refurbishment of these systems early enough. A number of failures in service have already occurred in advanced gas-cooled reactors, notably in 2004 and 200�. The recent incident was thus a recurrent event. Since 200�, a vast inspection and replacement programme has been pursued in all �4 advanced gas-cooled reactors. The pipe sections buried in the ground were the last to be replaced.

The causes

Analyses carried out after the event revealed the following salient points:

The numerous groups charged with supervising the replacement of the defective pipes tolerated slowness of the work,The pipe replacement project did not have the planned results: there were shortcomings in the design specifications and the work organisation. There was delay in project implementation and frequent changes in project manager (seven in five years, including four in the last �2 months),The risk analysis and management process failed to neutralise the risks in due time.In the present case, the pipe inspection programme gave no pre-alert of the type of failure that occurred and thus precluded an action plan being made.

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My comments

After incidents in the plants, the control room staff and field workers are often under the spotlight. In the present case, however, I think we need to go back and consider how the management and the engineering support perceive the risks, establish the priorities and, above all, take measures to minimise the risks. Here, a known phenomenon of aging was affecting cooling systems important for reactor safety. Both internal and international operating experience feedback was well known. The pipe replacement policy had been laid down and the necessary budgeting provided. The cast-iron pipe replacement project began in the plant in 200�. There were at least six committees (e.g. project investment, liaison and others) charged with evaluating the progress with the project and setting the priorities. All these bodies were worried by the slowness of the replacement work but none had the clout to speed up the work. The pipe replacement project was but one of a series of major projects with calendar slippage. I observe that another project relating to the refurbishment of the emergency core cooling systems of the reactors and hence important for nuclear safety is also experiencing delays and problems.This event shows that, in the field of nuclear safety, every link in the chain must be strong if defence in depth is to be assured. It is necessary but not sufficient to identify the risks and rank them. Risk mitigation measures need to be determined and budgeted. Projects must then be managed in a professional manner until completion (quality, deadlines and costs).The driving force that management provides to deal with situations, the resourcefulness and responsiveness of the engineering forces, and the professional management of projects, are all vital aspects of nuclear safety.

12.4 SOCODEI: an industrial accident at Centraco (Marcoule)

On �2 September 20�� at around �2:�� hours, an accident occurred in the Centraco site, on the working deck of an induction furnace for melting down metal waste. The Centraco furnace receives short-lived low and very-low level waste produced during the routine operation of the nuclear facilities, maintenance work, process changes and nuclear facility decommissioning.The plant is a licensed nuclear facility that is regularly inspected by the nuclear safety authority.A furnace worker who was near the furnace was killed. Four other people were injured, one seriously.The fire caused by the explosion in the area was brought under control by ��:0� hours by the plant response staff.The Centraco facility is wholly-owned subsidiary of EDF and, as part of the IGSN's mission, I have some remarks to make about the way the accident developed:

It did not cause any radioactive or chemical discharges,The Centraco facility is located in the district of Codolet, alongside the centre belonging to the French Atomic Energy Commission (CEA) in Marcoule. It maintains close operations-related and technical relations with this centre, and the emergency was managed from there. The EDF corporate emergency management system was mobilised as soon as the accident became known,A calculation error resulted in the radioactivity inside the furnace being underestimated. The causes of the error were subsequently determined.

As analysis of the accident is not yet fully complete, I will return to this event is my next report.

Although the radiological potential of the event was limited, it was a serious industrial accident as there was a fatality. Application of the International Nuclear Event Scale criteria resulted in classifying the event as Level � due to the small amount of radioactivity contained in the furnace.

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A TECHNICAL EVENT OUTSIDE THE EDF GROUP

The Deepwater Horizon drilling platform accident

The context

On �9 March 2008, Mineral Management Service (MMS) in the United States granted British Petroleum (BP) an exploration permit in Mississippi Canyon Block 2�2 in the central part of the Gulf of Mexico. The permit was to last �0 years, with BP holding ��%, Andarko Petroleum holding 2�% and MOEX Offshore holding �0%.On 22 May 2009, MMS granted a drilling permit for the Macondo well located �,�00 metres underwater.After early drilling attempts proved difficult with the first method and further complicated by Hurricane Ida, BP called in the Deepwater Horizon platform which is owned and operated by Transocean, under contract. Within the scope of this contract, the platform made some thirty boreholes, two thirds of which were exploratory. The Deepwater Horizon arrived on location on �� January 20�0 and drilling commenced on � February 20�0.The accident occurred on 20 April 20�0 when a deep production well was being completed. There were eleven fatalities.Technical problems, non-conservative decision-making and insufficient responsiveness led to excessive delay in detecting leakage and deciding to close the valves on the production casing. The gas escaping up the well caught fire at platform level and the platform sunk.The tragic loss of human life was accompanied by an ecological disaster caused by the discharge of oil over a period of three months to produce the greatest ever oil spill near the coast of the United States.

With the press calling the accident the ‘American Chernobyl’ and the ‘Ecological 9/��’, President Obama announced a moratorium on offshore drilling on 2� May 20�0.A report on the event was drawn up by a commission of government-appointed experts, in which fault tree analysis identified eight successive factors that led to loss of the platform. These lines of defence can be classified under four groups of critical factors:

The well containment was faulty, but this was not actually detected (problem relating to the cement and mechanical barriers),Well monitoring failed to detect the leak and control over the well was lost (interpretation of pressure tests, control room surveillance and response time),The oil spill on platform level was not contained (nor was the gas, which caught fire),The blow-out preventer emergency system failed to close off the well (the well isolation system did not work and the fire was fed with gas).

Although the resulting oil spill was not the worst the world has seen, it proved to have the greatest impact on the oil industry in the end by forcing the players to review the design, utilisation, monitoring and safety of their procedures and installations.

The lessons

I have no comments to make about the technical aspects of the case, which have nothing in common with the nuclear industry, but wish to examine the factors that resulted in the platform loss in the light of nuclear safety culture. Here, this accident and the Fukushima accident together constitute the two most recent industrial accidents with effects on the environment associated with the production

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of energy. It is relevant to the nuclear industry because the American government asked INPO at an early stage to make available its experience in the national nuclear industry. Furthermore, the world of energy is an interdependent one, where every local event has a global resonance.

I contacted the French oil consortium TOTAL and discovered that the factors of experience feedback derived from the accident are much the same as those identified by the nuclear industry: work with contractor companies, reinforcement of an independent safety organisation with the drilling supervisor, increasing the staff skills (particularly for dealing with exceptional situations on simulators), development of special means to cope with improbable events, inspections of current deep-drilling operations and the associated safety equipment, strengthening the ability to combat widespread pollution, checking the effectiveness of the emergency plans in different situations, etc.

Lessons for nuclear safety culture

In the EDF Group, I observed considerable diversity in the reactions to this accident. First, I would like to commend the exemplary approach adopted by EDF Energy soon after the accident. This was of the bottom-up type, with each nuclear generating site forming working groups to discuss, analyse the facts and propose ways of further reinforcing nuclear safety in the nuclear plants. The inputs from the plants were then amalgamated in a single report that was submitted to the management of EDF Energy. This process involved all the hierarchical strata at plant and corporate levels, embodying the intent to make progress in safety culture at all levels. EDF Energy finally identified three topics for further examination to challenge its own organisational structure with regard to nuclear safety:

management of the service providers (business strategy, awarding contracts, purchasing, supervision, surveillance, checking, etc.).nuclear safety checking loops, both internal and with the authorities,management of the nuclear safety barriers and making provision for their contingent deterioration.

The staff involved in the plants were extremely interested in the process. It is the first time such an operation has taken place for an industrial event that occurred outside the nuclear industry. This job also broke down many of the barriers between the different professions since it will lead to a joint submission by all the nuclear plants. Finally, EDF Energy has called on the nuclear safety authority (the ONR) to work jointly on pooling the analyses.

EDF SA, for its part, organised consultation at corporate level using the strong analytical capabilities of the industrial hazard management department at the Research and Development Division, the risk checking directorate of the Group, and representatives of the Production and Engineering Directorate. A meeting to share analysis was organised with EDF Energy. The Fukushima accident occurred in March 20��, with the result that the focus immediately switched to this major event with multiple consequences for the EDF Group. The result was that the top-down approach chosen by EDF SA did not filter through. It was a missed opportunity for creating an impetus to reinforce nuclear safety culture at all levels of responsibility down to the field, within a reasonable timescale.

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In conclusion, the BP accident has the following features in common with other major industrial accidents:

it was a call to the international players in the sector to make in-depth reviews of the safety of their operations,it created more solidarity between the industry players; safety has become a pressing issue and due regard needs to paid by all the players as the failure of any one of them can have grave repercussions for all the others.

In the nuclear field, the principle of appraising the technical and organisational systems by an outside third party – preferably a peer – has enabled objective assessment by competent players, while limiting the risk of conflict of interest as peers have no automatic tendency to be conciliating. The practice has long been universal.Finally, international harmonisation of safety standards is a path on which every industrial sector exposed to risks needs to resolutely set foot so that a level playing field is created. The aeronautical industry has set an excellent example of this. This is an area where progress is still needed in the nuclear industry throughout the world.

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APPENDICES

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14.1 - Result indicators for EDF SA’s plants

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Number of events classified on INES as 1 or greater, per reactor * 1.00 1.20 0.88 0.76 1.22 0.80 1.15 1.17 1.17 0.91

Number of significant nuclear safety events, per reactor * 7.70 8.14 7.62 9.54 10.21 10.80 10.34 10.93 10.45 10.57

Number of cases of non-compliance with the technical specifications for operation, per reactor

1.30 1.57 1.16 1.48 1.55 1.70 1.70 1.39 1.55 1.36

Number of alignment errors, per reactor ** 0.74 0.93 0.50 0.66 0.69 0.57 0.62 0.53 0.77 0.71

Number of scrams, per reactor and per 7,000 hours of criticality (the average value for all reactors) • Automatic 1.19 1.13 1.01 0.93 0.89 0.87 0.51 0.71 0.69 0.50

• Manual 0 0 0 0 0 0 0 0 0.01 0.05

Average collective dose in operations, per nuclear unit in service (in man-sieverts

0.97 0.89 0.79 0.78 0.69 0.63 0.66 0.69 0.62 0.71

Exposure of individuals:

• Number of individuals with doses above 20 mSv 0 1 0 0 0 0 0 2 0 0

• Number of individuals with doses between 16 and 20 mSv 154 74 73 28 17 20 14 10 3 2

Number of significant radiation protection events - 160 177 173 112 99 107 102 91 92

Availability (%) 82.2 82.7 82.8 83.4 83.6 80.2 79.2 78.0 78.5 80.7

Unplanned capacity loss factor (%) 2.5 3.0 3.5 3.2 3.3 3.7 4.4 4.6 5.2 2.2

Occupational accident frequency factor (Tf) *** 8.5 7.5 5.5 5.5 5.6 4.6 4.4 4.3 4.1 3.9

* Excluding generic events, i.e. events due to design defects

** Any configuration of a system or its services that deviates from the expected situation and is the cause of a significant event

*** Tf: frequency of occupational accidents with sick leave for 1 million hours of work

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14.2 - Result indicators for EDF Energy’s plants

Consideration needs to be given to the following factors when comparing the results of EDF SA with the British ones:

Lines 3, 4 and 5: the event declaration procedures are not the same in the United Kingdom and France as a result of the respective nuclear safety authority requirementsLine 7: : the reactors of the two sets of plants do not share the same technology (mostly AGRs in the UK and PWRs in France). The AGR design means that radiation exposure is some ten times lower (WANO).Line 9: To facilitate benchmarking, the values of previous years have been modified to allow for the fact that the declaration criteria of EDF Energy and EDF SA are different.

N° Indicator 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

1Number of events ranked 1 or more on INES, per reactor 5.67 5.27 5.60 5.67 3.13 1.20 1.13 0.80 0.93 1.33

2Number of events ranked 0 or more on INES, per reactor 10.53 10.80 9.60 9.13 7.53 4.93 4.53 5.47 5.60 4.7

3

Number of events of highest level declared to the Nuclear Installations Inspectorate, per reactor

- 5.47 3.60 2.67 1.53 0.40 0.67 0.33 0.67 0.46

4

Number or cases of non-compliance with the technical specifications for operation, per reactor

- - - 1.00 0.73 0.13 0.27 0.13 0.60 0.33

5Number of alignment errors, per reactor - - 0.40 1.09 0.69 0.13 0.27 0.13 0.60 0.33

6

Number of unscheduled reactor shutdowns, per reactor and for 7,000 hours of criticality • Automatic 1.70 1.51 1.30 0.74 0.73 0.44 1.13 0.82 0.58 0.74• Manual 1.96 1.39 2.18 1.28 2.54 1.48 1.04 1.44 1.68 1.22

7

Average collective dose in operations, per nuclear unit in service (in man-sieverts)• PWR 0.296 0.351 0.032 0.352 0.524 0.045 0.264 0.337 0.271 0.537• AGR 0.103 0.073 0.026 0.055 0.152 0.071 0.167 0.100 0.018 0.084

8

Exposure of individuals:• Number of individuals with

doses above 20 mSv 0 0 0 0 0 0 0 0 0 0• Number of individuals with

doses above 15 mSv 0 0 0 0 0 0 0 0 0 0

9Number of significant radiation protection events 98 192 184 368 249 58 38 31 43 43

10

Availability (%):• EDF Energy plants 74.6 78.2 69.9 71.9 66.1 62.8 51.2 71.0 65.7 72.0• PWR 88.9 86.1 89.4 83.7 85.3 98.4 89.2 87.4 45.6 82.5• AGR 73.6 77.6 68.5 71 64.7 60.2 48.5 69.8 67.1 71.3

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Unplanned capacity loss factor (%)• EDF Energy plants 15.0 11.7 15.5 12.3 17.0 20.3 20.4 13.2 19.6 13.0• PWR 2.4 2.4 9.7 0.0 0.3 0.4 2.1 0.9 54.3 3.4• AGR 15.9 12.4 15.9 13.1 18.2 21.7 21.8 14.0 17.1 13.7

12Occupational accident frequency factor (for 200,000 hours worked) - - 0.51 0.37 0.22 0.27 0.35 0.11 0.007 0.12

13Occupational accident frequency factor (Tf) *

- - 2.6 1.9 1.1 1.4 1.8 0.6 0.4 0.6

* Tf: frequency of occupational accidents with sick leave for 1 million hours of work.

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14.3 - Map of the EDF SA nuclear power plants

Construction/Project

Operation

Decommissioning

300 MWe 900 MWe 1300 MWe 1450 MWe 1600 MWe

FlamanvillePaluel

Penly

Gravelines

Chooz

Cattenom

Nogents/SeineDampierre

Belleville

Fessenheim

Chinon

Civaux

Blayais

Golfech

Bugey

St-Alban

Creys-Malville

Cruas

Tricastin

St-Laurent

Brennilis

Clermont-Ferrand

Nîmes

Grenoble

Lyon

Bordeaux

Bourges

Paris

AmiensCherbourg

Tours

Strasbourg

Marseille

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14.4 - Map of the EDF Energy nuclear power plants

Construction or Project

Nomber of reactor per type AGR REP EPR Engineering

Operational

Engineering existingnuclear sites

4

14 1

2

Hunterston B

Hinkley Point B

Hinkley Point C

Barnwood

East Kilbride

Dungeness B

Sizewell B

Sizewell C

Hartlepool

Torness

Heysham 1

Heysham 2

London

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14.5 - Technical key dates for each of the EDF SA nuclear units

Year com-missioned

Nuclear Unit

Powerin

MWe(*)VD1 VD2 VD3

Year commis-sioned

Nuclear Unit

Powerin

MWe(*)VD1 VD2 VD3

1977 Fessenheim 1 880 1989 1999 2009 1984 Cruas 4 915 1996 2006

1977 Fessenheim 2 880 1990 2000 2011 1984 Gravelines 5 910 1996 2006

1978 Bugey 2 910 1989 2000 2010 1984 Paluel 1 1330 1996 2006

1978 Bugey 3 910 1991 2002 1984 Paluel 2 1330 1995 2005

1979 Bugey 4 880 1990 2001 2011 1985 Flamanville 1 1330 1997 2008

1979 Bugey 5 880 1991 2001 2011 1985 Gravelines 6 910 1997 2007

1980 Dampierre 1 890 1990 2000 2011 1985 Paluel 3 1330 1997 2007

1980 Dampierre 2 890 1991 2002 1985 St-Alban 1 1335 1997 2007

1980 Gravelines 1 910 1990 2001 2011 1986 Cattenom 1 1300 1997 2006

1980 Gravelines 2 910 1991 2002 1986 Chinon B3 905 1999 2009

1980 Gravelines 3 910 1992 2001 1986 Flamanville 2 1330 1998 2008

1980 Tricastin 1 915 1990 1998 2009 1986 Paluel 4 1330 1998 2008

1980 Tricastin 2 915 1991 2000 2011 1986 St-Alban 2 135 1998 2008

1980 Tricastin 3 915 1992 2001 1987 Belleville 1 1310 1999 2010

1981 Blayais 1 910 1992 2002 1987 Cattenom 2 1300 1998 2008

1981 Dampierre 3 890 1992 2003 1987 Chinon B4 905 2000 2010

1981 Dampierre 4 890 1993 2004 1987 Nogent 1 1310 1998 2009

1981 Gravelines 4 910 1992 2003 1988 Belleville 2 1310 1999 2009

1981 St-Laurent B1 915 1995 2005 1988 Nogent 2 1310 1999 2010

1981 St-Laurent B2 915 1993 2003 1990 Cattenom 3 1300 2001 2011

1981 Tricastin 4 915 1992 2004 1990 Golfech 1 1310 2001

1982 Blayais 2 910 1993 2003 1990 Penly 1 1330 2002 2011

1982 Chinon B1 905 1994 2003 1991 Cattenom 4 1300 2003

1983 Blayais 3 910 1994 2004 1992 Penly 2 1330 2004

1983 Blayais 4 910 1995 2005 1993 Golfech 2 1310 2004

1983 Chinon B2 905 1996 2006 1996 Chooz B1 1500 2010

1983 Cruas 1 915 1995 2005 1997 Chooz B2 1500 2009

1984 Cruas 2 915 1997 2007 1997 Civaux 1 1495 2011

1984 Cruas 3 915 1994 2004 1999 Civaux 2 1495

VD1 : First ten-yearly inspectionVD2 : Second ten-yearly inspectionVD3 : Third ten-yearly inspection (*) Net continuous power

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14.6 - Technical key dates for the EDF Energy nuclear units

YearCommissioned

Nuclear UnitReactor Number

Reference Unit Power (MW)

(1)

Planned date of withdrawal from

service(2)

1976 Hinkley Point B R3 435 2016

1976 Hinkley Point B R4 435 2016

1976 Hunterston B R3 460 2016

1976 Hunterston B R4 430 2016

1983 Dungeness B R21 520 2018

1983 Dungeness B R22 520 2018

1983 Heysham 1 R1 585 2019

1983 Heysham 1 R2 575 2019

1983 Hartlepool R1 595 2019

1983 Hartlepool R2 595 2019

1988 Heysham 2 R7 605 2023

1988 Heysham 2 R8 605 2023

1988 Torness R1 600 2023

1988 Torness R2 605 2023

1995 Sizewell 1191 2035

(1) Reference Unit Power means the rated electrical power of the generating unit as declared by EDF Energy in its daily transactions on 17 January 2012.

(2) Dates of withdrawal from service, including all life extension decisions made on 17 January 2012.

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14.7 - Table of abbreviations

AAAR Automatic reactor shutdown

AEN OECD Nuclear Energy Agency

AGR Advanced Gas-cooled Reactor

AIEA International Atomic Energy Agency (IAEA)

ALARA As Low As Reasonably Achievable

AMELIE Project to transform spare part logistics

AMT Joint Maintenance Agency

ANDRA French National Radioactive Waste Management Agency

ASN French Nuclear Safety Authority

BBR Reactor Building

BK Fuel Building

CCAP Annual Performance Contract

CSB Chemical Safety and hazard investigation Board

CEFRI French committee for the certification of companies in training and monitoring radiation workers

CEIDRE Construction and Operation Expert Appraisal and Inspection Centre

CENG Constellation Energy Nuclear Group

CGNPC China Guangdong Nuclear Power Company

CIDEN Nuclear Environment and Decommissioning Engineering Centre

CIEST Inter-Contractor Work Conditions and Safety Committee

CIPN Nuclear Equipment Engineering Department

CIPR International Commission for Radiological Protection

CLI Local Information Commission

CNEN Nuclear Engineering Department for New Build

CNPE Nuclear Power Plant

COPAT Outage Control Centre (OCC)

CSN Nuclear Safety Council

CSNE Plant Safety Review Committee

DDCN Nuclear Fuel Division

DIN Nuclear Engineering Division

DNMC Daya-Bay Nuclear operation and Management Company

DPI Production and Engineering Directorate

DPN Nuclear Operations Division

EEDEC Skills and Employment Development Pledge

EGE Overall Excellence Evaluation

EGS Overall Nuclear Safety Assessment

ENISS European Nuclear Installations Safety Standard

EPR European Pressurised Reactor

EPRI Electric Power Research Institute

ESR Significant radiation protection event

ESS Significant nuclear safety event

EVEREST EDF campaign to allow entry into controlled areas in street clothes

ENSREG European Nuclear Safety Regulators Group

FFAI Fire Action Sheet

FAVL Long-lived low-level radioactive waste

GGPEC Advanced planning of jobs and skills

GV Steam generator

HHCTISN High Committee for Transparency and

Information on Nuclear Safety

HSE Health and Safety Executive

IFOPSE Industrial Safety and Prevention Training Institute

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IIN Nuclear Inspectorate (part of EDF Nuclear

Operations Division)

INB Licensed Nuclear Facility

INES International Nuclear Events Scale

INPO Institute of Nuclear Power Operations (USA)

INRA International Nuclear Regulator Association

INSAG International Safety Advisory Group

INTEP EDF Research and Development Division initiative to introduce new technologies in the plants in service

INTRA Post-accident robotic response group

IOP Operations Engineering

IRPA International Radiation Protection Association

ISOE Information System for Occupational Exposure of OECD AEN

MMAE Nuclear Engineering Division Support and

Expertise Unit

MOPIA Project to set in place an attractive business policy

MPL Front Line Manager

NNDA Nuclear Decommissioning Authority (UK)

NEI Nuclear Energy Institute

NNB Nuclear New Build

NNSA National Nuclear Safety Administration (China)

NRC Nuclear Regulatory Commission (USA)

OO2EI Better Housekeeping Campaign (a Nuclear

Operations Division initiative)

ONR Office of Nuclear Regulation (UK)

OSART Operational Safety Analysis Review Team (IAEA)

PPAI Fire Action Plan

PARTNER Ecologically-sensitive nuclear plant administrative facility refurbishment

PBMP Basic Preventive Maintenance Programme

PGAC Worksite General Assistance Services

PHPM Methods and Practices Harmonization Project

PUI On-Site Emergency Plan

RRDA Project to reduce the durations of outages

R&D Research and Development Division

REP Pressurised water reactor

RET Exceptional Work Permit

REX Experience feedback

RTE Power grid

RTGE General Technical Rules intended to avoid or mitigate the off-site nuisances and hazards associated with the operation of licensed nuclear facilities

SSDIN Nuclear Technical Information System

SDIS County Fire and Emergency Services

SEPTEN Basic Design Department (Nuclear Engineering Division)

SIR Official Inspection Departments

SOH Socio-organizational and human approach

SPR Risk Management Department

SRD Safety and Regulation Department (EDF Energy)

SRO Senior Reactor Operator

STE Technical Specifications for Operation

TTEM Unit in service

TNPJVC Joint venture between the Chinese company CGNPC (�0%) and EDF (�0%)

TSM Technical Support Mission by peers organised by WANO

TSN Nuclear Safety & Transparency Act

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UUFPI Operations Engineering Training Unit

UNE Unistar Nuclear Energy

UNIE Operations Engineering Unit

UNGG Gas-cooled graphite-moderated reactor

UTO Central Technical Support Department

VVD Ten-yearly inspection

VP Partial inspection

WWENRA West European Nuclear Regulators

Association

WANO World Association of Nuclear Operators

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Jacques DUSSERRE, Jean-Paul COMBEMOREL, JeanTANDONNET, Peter WAKEFIELD, Christian THEZEE, Bruno CORACA

Photo CREDITS

Cover : © EDF Médiathèque - H. M. DUCLOS Chapter 2-� : © EDF Médiathèque - Alexis MORIN Chapter 2-� : © EDF Médiathèque - H. M. DUCLOS Chapter 2-�0 : © Sylvain CONSEIL Chapter � : © EDF Médiathèque Chapter 4 : © TEPCO Chapter � : © EDF Médiathèque - H. M. DUCLOS Chapter � : © EDF Médiathèque Chapter � : © EDF Médiathèque - H. M. DUCLOS Chapter 8 : © EDF Médiathèque - Alexis MORIN Chapter 9 : © EDF Médiathèque Chapter �0 : © EDF Energy Chapter �0 : © TNPJVC Chapter �� : © ESKOM Chapter �2 : © EDF Médiathèque

2011

E.D.F.

Présidence IGSN

21, avenue de Messine

75008 Paris

www.edf.fr

The Inspector General’s report

on Nuclear Safety and Radiation Protection

ED

F IG

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T’S

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