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Chapter 12

    1. Description of an NPP
      1. General description of a pressurised water reactor
      2. Core, fuel and fuel management
      3. Primary system and secondary systems
      4. Cooling systems
      5. Reactor containment building
      6. The main auxiliary and safeguard systems
      7. Other safety-related systems
    2. Operation of a nuclear power plant
      1. EDF organisational structures
      2. ASN review of operating documents
      3. ASN oversight of reactor outages
    1. Human and organisational factors
      1. Workers
      2. Nuclear safety as related to organisational and human factors
      3. Management of subcontracted activities
    2. Continuous nuclear safety improvements
      1. Oversight of anomaly correction
      2. Examination of events and operating experience feedback
      3. Periodic safety reviews
      4. Approving modifications to equipment and operating rules
    3. Integration of nuclear power plant (NPP) ageing
      1. The age of the French NPPs in operation
      2. Main factors in ageing
      3. How EDF manages equipment ageing
      4. Examination of extended operation
    4. EPR reactors
      1. The steps up to commissioning of the Flamanville 3 reactor
      2. Construction oversight in 2011
      3. Cooperation with foreign nuclear regulators
    5. The reactors of the future: initiating discussions on generation IV safety
    6. Reliance on nuclear safety and radiation protection research
    1. Operation and control
      1. Operation under normal conditions: ensuring compliance with baseline safety standards
        and authorising changes to documents
      2. Examination of incident or accident operating rules
    2. Maintenance and testing
      1. Regulating maintenance practices
      2. Examining the qualification of scientific applications
      3. Guaranteeing the use of efficient control methods
      4. Authorising periodic test programmes
    3. Fuel
      1. Controlling in-pile fuel management changes
      2. Monitoring fuel status in the reactor
    4. In-depth oversight of primary and secondary systems
      1. Monitoring and checking the systems
      2. Monitoring of nickel-based alloy zones
      3. Checking reactor vessel strength
      4. Monitoring steam generator maintenance and replacement
    5. Checking containment conformity
    6. Application of pressure equipment rules and regulations
    7. Ensuring hazard protection
      1. Prevention of seismic risks
      2. Drafting flood prevention rules
      3. Preventing heatwave and drought risks
      4. Taking account of the fire risk
      5. Checking that the explosion risk has been considered
    1. Oversight of occupational radiation protection
      1. Oversight of radiation protection in operating NPPs
      2. Radiation protection requirements for NPPs in the construction phase
    2. Oversight of application of labour legislation in NPPs
    3. Controlling the environmental and health impacts of NPPs
      1. Reviewing discharge requirements
      2. Oversight of waste management
      3. Increasing protection against other risks and forms of pollution
    1. The NPPs inspection campaign and complementary safety assessments
      following the Fukushima accident
    2. Monitoring the construction of the Flamanville 3 EPR reactor
    3. Examination of the Penly 3 creation authorisation decree
    4. Examination of the safety options for the ATMEA 1 reactor project
    5. Modification of the Blayais 3-4 creation authorisation decree
    6. Continued operation of the nuclear power plants
    7. Notable findings relating to oversight of pressure equipment
    8. Notable findings relating to occupational health and safety inspections
    9. Notable findings relating to radiation protection of personnel
    10. Notable findings relating to the environmental impacts of NPPs and discharges
  6. ASSESSMENTS Reactors in operation
    1. Evaluating the head offices and overall performance of NPPs
      1. Evaluating nuclear safety
      2. Evaluating human and organisational measures
      3. Evaluating and analysing radiation protection
      4. Evaluating health and safety, professional relations and the quality of employment in
        the nuclear power plants
      5. Evaluating and analysing environmental protection measures
      6. Analysing statistics on significant events
    2. Evaluation of each site
      New reactors
    3. Evaluating EPR Flamanville 3 reactor construction

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With regard to NPPs, ASN's regulatory and inspection duties in 2012 will be primarily concerned with the subjects presented below:

Regulation of the EPR and actions relating to new reactors

Regulation of the EPR reactor

Surveillance of construction of the Flamanville 3 EPR will continue until authorisation for commissioning of the installation. EDF at present anticipates initial operation at rated power in 2016. Between now and then, ASN will be continuing its monitoring of occupational accident risk prevention, EDF's surveillance of the quality of construction, both for the work done on the site and for the manufacturing work done by EDF suppliers and the manufacturing of nuclear pressure equipment. At the same time, ASN will be continuing its advance review of certain elements of the commissioning application file, together with the Advisory committee for reactors and, for the reactors in operation, will examine the hard core requested by ASN further to the complementary safety assessments. ASN will develop the regulation tools necessary for managing the preparation and inspection of the facility start-up tests and the final review of the commissioning authorisation application file. ASN will carry out these steps jointly with its counterparts also involved in the project.

Other actions relating to new reactors

Subsequent to the statement by WENRA published in November 2010 on the safety objectives for new reactors, ASN will contribute to actions aiming to promote these objectives in the worldwide thinking on these subjects initiated by the IAEA or within the MDEP framework. Moreover, ASN will continue to work within WENRA on the development of common positions on subjects resulting from these safety objectives and that warrant clarification.

Labour inspection

ASN will ensure that labour inspection officers are regularly present in the field, in particular for construction and maintenance site activities.

Following the deviations observed on the sites since 2009 with regard to the maximum working hours overruns and the insufficient rest periods, but also EDF's 2011 implementation of a policy of early planning of working hours during reactor outages, ASN will be particularly attentive to tangible measures affecting working hours, in particular for the management. It will continue its inspections in this area to evaluate the undertakings, assess their actual implementation and penalise any deviations observed.

ASN will focus on implementing the measures defined in the 2012 action plan from the Ministry for Labour concerning labour inspection duties, as well as in the national occupational health and safety plan, by emphasising health and safety, quality of employment, social dialogue and combating illegal labour. In the second half of the year, it will be taking part in the European campaign to prevent stress-related risks.

Finally, with a view to developing an integrated view of safety, the ASN labour inspectors will be associated and coordinated with other ASN regulation and monitoring actions, for example in the field of subcontracted maintenance.

Radiation protection and protection of the environment

Radiation protection

ASN expects of EDF that it strengthen its radiation protection policy with, notably, better preparation of interventions and progress in controlling contamination at source.

The Authority will be attentive to compliance on these different aspects in the files it will be examining, and during on-site inspections. Following on from the wide-ranging inspection carried out in 2011 on the four Loire Valley sites (Belleville-sur- Loire, Dampierre, Saint-Laurent-des-Eaux and Chinon), ASN will carry out further in-depth inspections in order to continue with its detailed assessment of the radiation protection measures taken by EDF.

Environmental Protection

In 2012, once it has received the files from EDF, ASN will begin its review of the effluent discharge and water intake license renewal files for the Bugey and then Fessenheim sites, the provisions of these licenses being currently specified in relatively old orders. ASN will ensure that the discharge limits are set for these two sites according to the best available techniques and taking account of experience feedback from the NPPs in operation.

ASN will continue to review the effluent discharge and water intake modification files for Cruas-Meysse and Belleville and will begin those of Saint-Alban, Cattenom and Paluel.

It will continue to work with the licensee to optimise discharges, in accordance with the measures decided on following the meeting of the Advisory Committee for reactors in 2006 concerning the management of radioactive effluents and chemical effluents associated with the French NPPs in operation. ASN will continue to review the files concerning steam generator cleaning, management of cleaning effluents and the fate of the used generators.

It will also devote efforts in the field to checking that the measures envisaged by EDF to tackle legionnaire's disease, but also to reduce coolant fluid emissions and to replace chiller units, are actually implemented on the sites.

Finally, ASN will continue to ensure that account is taken of the experience feedback from the SOCATRI and FBFC events, by analysing the further steps taken by EDF and by means of targeted inspections.

Hazard prevention

Preventing fires and explosions

ASN will check compliance with the requirements concerning management of the fire and explosion risks in the files it will be reviewing and in its site inspections.

With regard to checking integration of the fire risk, ASN will be particularly attentive to the steps taken by EDF with regard to management of fire sectoring and management of fire loads.

With regard to the explosion risk, ASN will for example be carrying out inspections to continue to monitor the steps taken by EDF following the ASN decision concerning management of the risk of NPP on-site explosions (decision 2008-DC-0118 of 13 November 2008), as well as compliance with the requirements of the regulations concerning occupational safety in an explosive atmosphere (ATEX).

Flood prevention

In 2012, ASN will submit the draft guidelines on protection of BNIs against external flooding to the advisory committees for reactors, laboratories and plants. These draft guidelines were produced by a working group which, between 2006 and 2009, brought together ASN, IRSN, the nuclear industry licensees and experts from the field of hydrology. Public consultation on this project was organised in 2010.

1,300 MWe and 1,450 MWe reactor containment

A GPR meeting is planned for late 2012 to look at the issues of the 1,300 MWe and 1,450 MWe reactor containment, in particular in the run-up to the third ten-yearly outage inspections for the 1,300 MWe reactors. The GPR will in particular examine the double-wall containment, the doublewall containment internal ventilation system, the containment penetrations, the containment extensions and the corresponding bypass risks, as well as the behaviour of the auxiliary buildings.

Review of safety associated with ten-yearly outages

In 2012, ASN will attentively continue its examination of the safety reviews of NPPs that are associated with the ten-yearly outages. ASN considers this step to be crucial in gaining a precise understanding of the condition of the reactors, but also for continuously improving the safety of the facilities. One year after the end of each ten-yearly inspection, ASN will issue its opinion on the ability of each reactor to continue to operate and, as necessar y, will specify the technical requirements needed to manage and monitor this continued operation. In 2012, ASN will make its position known following the third ten-yearly inspections of Bugey reactors 2, 4 and 5, Dampierre 1 and Tricastin 2.

Continuing operation beyond 40 years

As EDF has indicated its desire to extend the operating life of its reactors up to 60 years, ASN will pursue its examination of the possible conditions for extension of their operation. In 2012, following a meeting of the GPR concerning the programme of study and work proposed by EDF with a view to extending reactor operations, ASN will make its position known. For ASN, extension of reactor operations beyond forty years can only be envisaged if it is associated with a proactive and farreaching programme for improved safety that is in line with the safety objectives adopted for new reactors and with best international practice.

Complementary safety assessments following the Fukushima accident

ASN will issue technical requirements to EDF as a result of its analysis of the complementary safety assessments. The purpose of these requirements will be to cover all the technical topics resulting from the analysis of the Fukushima accident, for example with regard to the robustness of the facilities to earthquake and flooding, to loss of electrical sources or heat sink, severe accident management, consideration of human and organisational factors and subcontracting.

In addition, the action taken further to the 2011 inspections in response to this accident will be checked in 2012, either as part of the normal programme of ASN inspections, or during the course of specific inspections.

ASN will draw the conclusions of the ongoing European peerreviews, in which it is a participant and one objective of which is to compare the requirements stipulated by the safety regulators or the measures proposed by the foreign licensees.

It will take part in international experience feedback on the subject, paying particular attention to understanding of the accident, management of the operations to regain control of the facility, decommissioning and decontaminating the facility and making it safe.

ASN will make modifications to its programme to update the baseline safety requirements applicable to the design of new nuclear facilities, but also, as part of the periodic safety reviews, for the facilities currently in operation.

ASN will contribute to the expression of R&D requirements to be added in the medium term to the applicable baseline safety requirements for the prevention of this type of accident and to improvements in the understanding of severe accidents and post-accident management.

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