2017 - edf.fr · 1 FOREWORD IGSNR REPORT 2017 FOREWORD This report, written for the Chairman of EDF, gives my assessment of nuclear safety and radiation protection within the

2017

The Inspector General’s report

on Nuclear Safety andRadiation Protection

1

FOREWORD IGSNR REPORT 2017

FOREWORD

This report, written for the Chairman of EDF, gives my assessment of nuclear safety and radiation protection within the EDF Group.

The report is also intended for all those in the company who contribute in any way to nuclear safety and radiation protection through their day-to-day actions and decisions. It will have achieved its purpose if it provides food for thought on their contributions in these areas.

It also aims to identify any early warning signs and recommend areas for improvement. It therefore focuses on difficulties and weaknesses rather than strengths and progress. This may seem unfair to those who spare no effort to ensure that complex, demanding nuclear power facilities are operated safely.

Like each year, the purpose of this report is not to cover the subjects in depth. The number and length of the chapters are intentionally kept to a strict minimum to highlight the most important points.

This report focuses on all matters within the EDF Group that contribute in any way to the safety of its nuclear activities. This is particularly true for engineering and operations in both France and the United Kingdom. Yet it is important to avoid making any hasty comparisons between these two fleets as the regulatory contexts, the reactor technologies, the fleet sizes and the similarities within each fleet are different.

My assessment is based on information gathered and observations made during the year, both in France and the UK, whether from workers in the field, or during visits to plants and meetings with the main stakeholders: contractors, managers, staff representatives, members of the medical profession, and chairmen of local information commissions in France and of Site stakeholder groups in the UK. It also makes use of visits and comparisons with other international players on the nuclear scene and of dialogue with WANO1 and the nuclear safety regulators.

I would like to thank all those I met for their unstinting help and honesty, not to mention the breadth of our discussions. Their openness, which determines the relevance of this report, is fully in keeping with the spirit of a nuclear safety culture. I would also like to thank my assistants, Jean-Jacques Létalon, Jean-Michel Fourment, John Morrison and Bernard Le Guen, who have been relentless in their efforts, particularly in drafting this report.

Finally, although this document has not been written for public relations purposes, it is available to the general public in both French and English, as in previous years, on the EDF website (www.edf.fr).

EDF Group Inspector General for Nuclear Safety and Radiation Protection

François de Lastic 24 January 2018

1 World Association of Nuclear Operators

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IGSNR REPORT 2017 SOMMAIRE

CONTENTS

1 My view of 2017 3

2 Nuclear safety results 9

3 Nuclear safety priority affirmed 13

4 Risk prevention: important to remain vigilant 17

5 Adapting people skills 23

6 Operating experience: contrasting approaches 27

7 Operations fundamentals to be reaffirmed 31

8 Importance of working closely with contract partners 35

9 Engineering support for the French fleet and new-build projects 41

10 Spares: an area for greater engagement by owners on-site 47

Appendices 53

Foreword

CHAPTER 1 IGSNR REPORT 2017

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MY VIEW OF 2017

Nogent-sur-Seine nuclear power plant

A GLOBAL NUCLEAR INDUSTRY ADAPTING TO THE DEVELOPMENT OF RENEWABLES In 2017, there were no notable events associated with reactor operation anywhere in the world. I did, however, note significant discharges of a radioactive element (ruthenium-106) which were detected in Europe. The Institute for radiation protection & nuclear safety (IRSN) has ruled out the possibility of this element having been released from a nuclear reactor and states that in France they are "of no consequence for either human health or the environment". In addition to the significance of this event, I would like to point out the lack of transparency in failing to declare it.

The overview of how nuclear power is developing is somewhat mixed:

• Much higher global investment in renewable energy than in new nuclear build, as indicated in the 2017 World nuclear industry status report

• In the US, continuing tax measures in favour of nuclear energy, but also problems experienced

by Toshiba Westinghouse and the probable cancellation of one of the AP1000 projects

• In China, the start-up of several reactors and progress on the Taishan EPRs, with successful functional tests, but no new projects for two years

• In India, the announcement to build ten or so Indian-designed reactors and several projects in conjunction with other countries, including France

• In Bangladesh, the first concrete poured for a pair of reactors

• In Japan, the low-key restarting of reactors, five of which are now in service and eight of which have completed their compliance reviews

• In South Korea, the desire to stop building any new reactors, to not extend reactor lifetime beyond 40 years, but to complete the five reactors under construction

• In Switzerland, the two votes in 2016 and 2017 leading to the freezing of new builds, but no early shutdown of reactors, with the result that Switzerland will continue to have a nuclear industry beyond 2040.

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IGSNR REPORT 2017 CHAPTER 1

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All these announcements indicate, almost everywhere, a search for a new balance based on a synergy between nuclear energy and other low-carbon energies in the fight against global warming.

In this context, WANO is continuing to promote nuclear safety - through peer reviews1 - by applying design-based reviews and Crew performance observations (CPOs, see Chapter 7). I also note the support provided for new entrants to the nuclear industry and new sites, as well as the planned establishment of a centre in Shanghai.

WHAT KIND OF ENERGY TRANSITION?

In this search for the right mix between nuclear energy and renewables, France is to update its multi-year energy plan in 2018 to cover the period 2019-2028. The ensuing debate will be of major importance to EDF. The many discussions and reports often seem to be characterised by dogmatic standpoints. Arguments in favour of an energy mix that remains broadly nuclear are still getting little media coverage. As a result, it is hardly ever mentioned that low-carbon nuclear electricity has both a high level of safety and the ability to compensate for daily - and above all seasonal - variations in electricity demand (and it must be remembered that electricity is difficult to store).

The absence of these arguments in the discussions is a source of concern at EDF. Clarifying the national strategy is a challenge to team motivation and to maintaining the attractiveness of the Group. In France and the UK, staff expect plans based on realistic time frames that allow planning and organising of the maintenance of key design, construction and operating skills in terms of quality and quantity. EDF’s Parlons énergie (Let’s talk energy) initiative in France, commencing in early 2018, meets a concern expressed by staff and should help to increase confidence in the Group’s strategy (CAP 2030).

In the UK, I have also seen sporadic questioning, especially by the media, of the merits of the government’s commitment to nuclear energy in general and to Hinkley Point C (HPC) in particular. Nonetheless, this commitment remains firm, with the desire to move towards an energy mix comprising a significant proportion of nuclear.

EDF IS WEATHERING THE STORM

In 2017, as in 2016, EDF SA experienced considerable technical problems, in particular the series of carbon segregation issues, the examination of the unmarked files (see insets) and some new hazards (see Chapter 2). Correcting defects and improving nuclear safety has led to a heavy workload for the operator and the engineering division. This has resulted in considerable disruption and operating restrictions so that the checks can be carried out, leading to longer outages. The teams at the sites 1 Assessment by operators from nuclear facilities around the

world

and at corporate level have responded to this quickly and efficiently by organising a number of task forces involving the operator and the engineering division.

I commend this commitment, but remain concerned by the excessive workload which has gone on for at least two years now and is affecting the morale of some staff. I have also observed that teams and managers are taking less account of the bigger picture in their thinking when preparing for the future. This is necessary to simplify organisations and embed results, particularly in nuclear safety. The disruption caused by the events of 2016 and 2017 will continue over the next few years, which will remain very busy.

It is a challenging context and I have observed various responses to adapt to and anticipate the problems.

Firstly, it is clear that the Nuclear generation division (DPN) is following its fundamental processes. In particular, the preparation of maintenance work based on a multi-year approach is key to high performance in nuclear safety. At the same time, preparation for the fourth ten-yearly inspection outages is intensifying so that plants can continue operating beyond 40 years, with a level of nuclear safety close to that of the new generation of reactors (EPR).

Likewise, I feel that the effectiveness of the Fleet upgrade programme, in particular the quality of its control, bodes well for the fourth ten-yearly inspection outages of the 900 MW reactors, which represent a major challenge (see Chapter 9).

In the context of the marked and unmarked files (see insert), EDF has increased its monitoring of manufacturing activities (see Chapter 8) to improve the detection of defects.

HPC: Reinforcement for an underground gallery

Good progress has been made on the new-build worksites, including Flamanville 3. The engineering division is also continuing its reorganisation for the successful construction of Hinkley Point C and future reactors, including the creation of EDVANCE, an engineering subsidiary jointly owned by EDF SA and AREVA NP2 (see Chapter 9).2 The main activities of AREVA NP have been carried out under

the name of Framatome (75.5% owned by the EDF Group) since January 2018

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The Hinkley Point C construction site is well under way with strong logistical and organisational support, and industrial safety is one of the main priorities. The current reorganisation of the project’s governance will improve relations with the Office for nuclear regulation (ONR) and should improve the interface with engineering.

I also note that EDF is looking to re-establish margins, for the benefit of nuclear safety in particular, through its R&D work in such fields as digitisation and big data for the Group’s nuclear divisions. I am impressed by its Nuclear plant of the future research programme undertaken with the operator, engineering and contract partners. Its technological building blocks make it both promising and scalable. Such innovations should boost the confidence of those involved in the nuclear industry.

The Flamanville 3 reactor vessel and carbon segregation

A higher than expected carbon content was declared in 2015 in limited areas of the Flamanville 3 reactor vessel. This phenomenon, known as positive segregation, may affect the mechanical strength of the vessel. A very comprehensive test programme was put in place to check its strength under normal and accident operating conditions.

On 10 October 2017, in view of the test results and the documents received from EDF and AREVA NP, the French nuclear safety regulator (ASN) considered that this anomaly was unlikely to jeopardise the commissioning of the reactor vessel, subject to specific checks being carried out during plant operation. Since the feasibility of these checks has not yet been established for the reactor vessel head, the ASN has requested that EDF change it by the end of 2024.Through to the start of 2017, EDF and AREVA NP also continued to check all the forged components in the primary systems of plants (in service or being built) which could be affected by such segregation. The checks did not jeopardise the fitness for service of the components in question.

RESULTS

IN FRANCEThe nuclear safety results are atypical. Although there were four INES1 Level 2 significant nuclear safety events in 2017, when there had been none since 2012, substantial progress has been made in several areas.

These four events (see Chapter 2), which did not have any real consequences on nuclear safety, were associated with either the original design or with maintenance. EDF detected them during compliance checks against the initial design carried out as part of the ten-yearly inspection outages, or during maintenance. The EDF teams responded 1 International Nuclear Event Scale

quickly to these events and initiated work across the whole fleet to check compliance with the design and re-examine the maintenance programmes. This long-term work involves methodical reviews and reconsideration of practices, including those connected with the design.

Marked and unmarked files

This issue is often confused with carbon segregation, but it is very different. It concerns irregularities, some dating back many years, discovered in some documents - referred to as marked files - from the Creusot Forge plant, which manufactured most of the major components for nuclear steam supply systems.These documents were examined one by one in 2016 by AREVA NP under the supervision of EDF. The irregularities, which varied very widely in their nature and importance, were dealt with accordingly.An examination of all Creusot Forge manufacturing documentation (unmarked files) has also been launched. This will continue until late 2018. These checks have involved more than one hundred people from AREVA NP and several dozen from EDF. So far, they have revealed numerous anomalies, but no major problems.

Despite these four events, the results for 2017 are good for nuclear safety, industrial safety and radiation protection. The number of automatic reactor trips has never been so low (22 in 2017, as against 28 in 2016). The overall accident rate for the nuclear fleet, for EDF and its contract partners clearly improved (2.2 in 2017, as against 2.8 in 2016). The radiation protection performance level is continuing to improve, both in terms of the collective and individual doses. The number of outbreaks of fire decreased and housekeeping remained good, despite a few isolated shortfalls.

These results have been achieved in a transparent manner with the number of events reported remaining at the 2016 level.

This encouraging improvement is a fitting reward for the considerable efforts made over the last two years. There are, however, some points which need attention.

I am saddened by a fatal electrocution in 2017 (see Chapter 4). This, together with the near-misses in 2017, is a reminder of the importance of following instructions. Efforts must be redoubled for the most dangerous activities: working at height, lifting and electrical hazards.

As in 2016, there was too much sub-standard work in terms of nuclear safety: in operations, with an increase in the amount of non-compliant circuit configuration, and in maintenance, with sub-standard work leading to reactor outages being extended.

With regard to fire safety, I note an increase in the number of events, indicating weaknesses in fire prevention measures.

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IN THE UKThe UK fleet achieved its best ever nuclear safety, industrial safety and radiation protection results in 2017. EDF Energy is reaping the benefits of its hard work on leadership and procedures. The number of events concerning plant alignments fell considerably and the overall accident rate is now 0.2. However, it is important to remain attentive as the number of outage extensions is still too high, the number of reactor trips has increased, and there were two potentially fatal falls from height.

I note the higher frequency of inspections of the graphite in those AGRs most affected by cracks. These inspections are becoming increasingly important as the reactors approach the end of their service life.

Sizewell B nuclear power plant

I have been impressed by the work carried out by EDF Energy based on the French model to improve housekeeping. The gap between the two fleets is narrowing, although there is still some way to go.

As the UK fleet continues to enjoy good stable results, it is the right time to prepare for the transition from AGRs to the Hinkley Point C EPRs.

RELATIONS WITH THE NUCLEAR SAFETY REGULATORS Both France and the UK have rigorous nuclear safety regulators. This is an advantage for nuclear operations and engineering.

IN FRANCE I sometimes hear staff at EDF SA say that they are tired of having a nuclear safety regulator that they consider to be nit-picking, overly concerned with the media or legal impact of its decisions and whose actions lead to unnecessarily complex operations.

In fact, I note continuing difficulties in the relations between EDF SA and the ASN with its technical support, IRSN. Good intentions too often falter over the ability to develop simple solutions together.

The amendment to the Procedures decree (June 2016) must allow greater authority to be delegated to operators

to modify their plants. This empowering of operators, which is a very positive step, should certainly be put into practice. Nevertheless, I sincerely hope that the legislation being drawn up (the details of which were unavailable at the time of writing), will not be onerous and complicated such that the autonomy given is not offset by resulting restrictions.

I believe this example is indicative of a French habit of building technical and regulatory structures that are intellectually satisfying, but very complex to put into practice. More generally, drawing up new regulations or provisions should be seen as an opportunity to clarify and simplify. The more complex they are, the more difficult they are to apply, the more they will lead to discrepancies, and the less beneficial they will be for nuclear safety. For example, the new regulations are likely to make the field of radiation protection needlessly more complex.

The application of such complex regulations also often gives rise to differing interpretations that can lead to misunderstanding the purpose of the requirements. This downward spiral leads to a risk of disaffection by the operator who, having lost the ability to assess the situation, may feel less accountable and end up simply implementing requirements without understanding them.

In my opinion, the ASN and IRSN are also essential motivators for encouraging operators to progress further on many topics. Thus, when certain INES Level 2 events mentioned earlier (anchoring of diesel generator auxiliaries and corrosion of fire systems) occurred, technical dialogue and constructive face-to-face meetings between EDF and the ASN led to equitable decisions and actions, to the benefit of nuclear safety. I hope that dealing with these events is helping to rebuild the mutual trust which is still lacking.

IN THE UKOver the last decade, EDF Energy’s nuclear generation fleet and the ONR have successfully rebuilt relationships based on trust. It is a virtuous circle; though the ONR has a strong presence, it gives the operator full responsibility to make nuclear safety decisions and will enforce its control if the operator is slow to act. Thus each staying in their own role.

The situation seems less favourable for new build, to which the ONR is devoting substantial resources. The increased dialogue, made necessary by the progress of the Hinkley Point C project, should be put to good use to improve the still unsatisfactory level of trust. I believe that the recent reorganisation of the project’s governance (see Chapter 9) is a good starting point.

ROBUST INTERNAL OVERSIGHT ORGANISATIONSI believe that the independent nuclear safety oversight teams are competent and listened to both in France and the UK.

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In France, the greater diversity of nuclear safety engineer profiles at the nuclear sites will enable them to better cover different fields.

At the Engineering & new-build projects directorate (DIPNN), the Engineering audit unit (MAE) is continuing to fulfil its nuclear safety oversight brief. It is important that they continue to be listened to and maintain their independence during the engineering reorganisation.

I note the creation of a unit responsible for the independent oversight of quality and nuclear safety at EDVANCE, the engineering subsidiary of EDF SA and AREVA NP (see Chapter 9). EDVANCE should coordinate this unit with the DIPNN’s independent nuclear safety oversight.

In the UK, the Independent nuclear assurance (INA) teams include experienced staff, often from companies outside EDF Energy. This brings additional open-mindedness, but can cause occasional recruitment challenges.

The Design authorities ensure that site operations comply with the design, including when modifications are made. This arrangement, which is more mature in the UK, works well. It was introduced into the French fleet eighteen months ago and is continuing to be scaled up. Given the workload, it is important to make sure the teams are the right size and to prioritise the areas in which they work.

THREE POINTS WHICH REQUIRE ATTENTION IN FRANCEFUNDAMENTAL PROCESSES TO BE MORE FIRMLY ROOTED IN PRACTICESIn 2017 I noted that, at the DPN and in engineering, nuclear safety remained a major component, at the heart of every process.

Numerous action plans associated with nuclear safety have been launched and are now bearing fruit. An example of this is the ‘key focus areas’ approach to automatic reactor trips, introduced at the end of 2015, which helped the fleet achieve the lowest number of trips ever in 2016, and even fewer in 2017. These good results have been achieved as a result of increased control.

I also observe an ability to respond effectively using a task force approach, to mobilise skills and to make use of substantial technical expertise when handling complex issues. The four INES Level 2 significant nuclear safety events declared in 2017 were addressed through this means.

These points highlight the strengths of the fleet and of engineering.

Although the detection of these significant nuclear safety events associated with design or maintenance faults dating back many years is down to the questioning

attitude of EDF’s staff, I do believe that the time taken to detect them is indicative of some weaknesses.

Alongside improvements in the indicators, there are still some issues and recurring weak signals. Examples of these are sub-standard work (maintenance, operations and design) and fire prevention. Fundamental steps have been introduced but they do not seem to be delivering all the expected results.

Working on an electrical panel

There are several reasons for this lack of effectiveness, the first of which is the high workload. It drives the response to events by creating numerous task forces, which are effective but are heavy consumers of both resources and time, including that of managers at all levels. This response can initiate a vicious circle: it can hamper the fundamental work needed to improve nuclear safety in order to reduce the need to deploy task forces.

Another cause is the complexity of the changes to be made to alter behaviours. Examples of this are error-prevention tools, sharing good practices between business units or applying operating experience (OPEX), which are not employed enough as tools for continuous improvement (see Chapter 6).

I believe that the effectiveness of leadership programmes needs to be strengthened, such as providing greater support to new and mainly young managers. Managerial presence in the field should also be prioritised by refocusing on core skills and making teams more accountable for defining and achieving their results, particularly in nuclear safety. I note that a number of divisions have embarked on these processes, which I believe bodes well for improving the nuclear safety culture. I urge them to continue with pragmatism and to include the teams in the field more.

CONSISTENCY AND INNOVATION: MAJOR CHALLENGES FOR ENGINEERING For many decades, EDF has designed and built most of the reactors it operates. The substantial EPCC1 know-how that the Group acquired during the construction of the French fleet has suffered from the lack of new projects. In this field, as elsewhere, if skills are not used sufficiently, they are lost, which partly explains the problems encountered when building Flamanville 3. EDF and its suppliers were out of touch with the new tools and methods for managing complex projects.1 Engineering, procurement, construction and commissioning

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Learning lessons from Flamanville 3, EDF is continuing to reorganise engineering, which has included setting up EDVANCE in 2017, a joint subsidiary of EDF SA and AREVA NP (see Chapter 9).

As well as strengthening project management skills, I note significant changes in engineering practices, for example working in an open-plan environment bringing together all the skills around the same objective, in close collaboration with the contract partners. I am impressed by the use of engineering methods that are both innovative and lead to potentially significant benefits (system engineering, plant lifecycle management, etc.).

EDVANCE is already very much involved in these innovations which should increase its competitiveness, and it seems to be becoming a key user of such practices. Its structure makes it very flexible and responsive. EDVANCE draws on the engineering divisions of EDF and AREVA NP and on the skills of contract partners.

The sustainability of EDF as an EPCC is dependent on the success of EDVANCE. Its first challenges will be its contribution to the project for the two Hinkley Point C EPRs in the UK and the design studies for a new reactor, destined for the renewal of the French fleet and for export. It is important to ensure that EDVANCE’s practices are consistent with those of the Group’s other engineering directorates (DIPNN and DPNT) and that innovations are shared.

INCREASING THE INVOLVEMENT OF CONTRACT PARTNERSThe specific characteristics of nuclear fleets (seasonal nature of operation with peaks in workload during maintenance outages, 10-yearly outage modifications, occasional use of specialist techniques, etc.) and their construction led EDF to retain activities that are considered to be strategic and to subcontract the rest. Contract partners therefore play a major role in achieving results. In the field of nuclear safety, sub-standard maintenance work concerns both EDF and contract partner staff (see Chapter 8). The industrial accident rate is also highly dependent on the commitment of contract partners.

Close cooperation enables sharing of knowledge, know-how and attitudes, applying a win-win approach, with

everyone maintaining their own areas of responsibility. EDF’s inspection activities and financial control are not incompatible with such partnerships.

Pipework machining by a contract partner

The context plays a key role in building a long-term relationship of trust that benefits both sides. Operators in the UK are helped by a less restrictive legal system and by closely associated industrial and purchasing approaches focused on the expectations of the sites. In France, the roles are segmented: industrial policies, purchasing processes, contract management, supplier qualification and assessment, project management, etc. I believe that the Industrial department recently created within the DIPNN provides the ideal opportunity to improve the consistency of the different policies.

In the UK, I note extensive involvement of contract partners, who are very engaged in achieving results, in particular with regard to nuclear and industrial safety, as well as to optimising expenditure. They are highly integrated, being involved in some steering groups; they are also listened to and contribute to plans for change and to the continuous improvement process.

In France, I have seen numerous initiatives in favour of working more closely together, including knowledge-sharing seminars, simplification of logistics, operation as an extended enterprise, etc. Contract partners must be integrated more in order to achieve results, in particular with regard to nuclear and industrial safety.

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NUCLEAR SAFETY RESULTS

Gravelines nuclear power plant

In France, 2017 was defined by four INES Level 2 nuclear safety-significant events and progress in other nuclear safety indicators.

In the UK, results remain encouraging thanks to a well-coordinated continuous improvement strategy.

AN EVENTFUL YEAR FOR THE FRENCH FLEET

As in 2016, 2017 was overshadowed by some major nuclear safety issues, such as carbon segregation, the irregularities in the marked files and the Bugey 5 reactor which had been offline for over two years (see the 2016 Report). One site is also now undergoing stricter monitoring by the ASN. Significant progress has been made in other areas in spite of the four INES Level 2 events (see inset), the first such incidents since 2012.

The underlying causes of these four events were legacy issues with design or maintenance, though they had no real impact on safety. They were detected by EDF during design compliance checks conducted for the ten-yearly inspections, or during maintenance activities. Credit is due to the questioning attitude of the EDF staff who detected these issues, though I fear the time it took

for them to come to light is indicative of failings in the process.

EDF’s teams have a proven track record of responding to such events and have initiated design compliance checks across the fleet, together with a review of maintenance programmes. This is a long-term task, involving systematic reviews and a rethinking of existing practices, including those covering design.

Whereas I was concerned by the deteriorating results related to automatic reactor trips and fire safety in 2015, I am pleased to report that the progress made in 2016 continued into 2017.

The total number of events per reactor rose slightly to 11.59 in 2017, compared with around 10 in previous years, and continues to reflect a good level of transparency.

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The number of INES Level 1 events or higher increased marginally to 1.21 events per reactor in 2017, from 0.98 in 2016.

Progress was made in a number of technical areas in 2017, particularly with respect to the French nuclear pressure equipment regulations. Results to date are testament to more rigorous management. In another area, the nuclear rapid reaction force (FARN) has confirmed that it is fully operational in line with the Group’s commitments. It is important that the renewal of staff is maintained at a satisfactory rate (see Chapter 5).

The high workload last year resulted in extended maintenance outages, which had an impact on the morale of all staff involved. Those sites which have aligned their organisational structures with the fleet’s best practices are generally doing better overall.

Technician on the plant

GROUNDS FOR SATISFACTIONThe number of automatic reactor trips has continued to fall to a total of 22 in 2017 - the best ever result for the fleet - compared with 28 in 2016 and 38 in 2015. This success stems from the ‘key focus areas’ approach that has been vigorously deployed over the past few years.

The number of events associated with sub-standard maintenance has fallen slightly (189 in 2017 compared with 199 in 2016). After a steady increase over the past four years, this turnaround is testament to the improvement actions undertaken, which must be maintained to sustain this trend in the long term.

I also noted a slight improvement in the number of non-conformances against technical specifications, including reactivity control.

This year again, safety systems have demonstrated excellent unplanned unavailability rates, with the safety injection systems, auxiliary feedwater systems and standby diesel generators all recording 0.00% unavailability.

The resolution of recommendations from the DPN Nuclear inspectorate (72%), WANO peer reviews (exceeding 90%) and Significant operating experience reports (80 to 85%) remains high.

On another positive note, none of EDF’s nuclear plants experienced any negative impact from the cyber-attacks that affected the world in 2017. Such attacks nevertheless serve as a warning to remain vigilant in light of this increasingly frequent and evolving threat. Progress has also been made on a broader level to deploy the programme to reinforce site security.

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

US France

0.2

0.4

0.6

0.8

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Number of automatic and manual reactor trips per reactor in PWRs in France and the US

AREAS OF CONCERNThe number of major or significant fire safety events rose from 6 in 2016 to 9 in 2017. Some of these events were particularly significant, like the fire in an administration building. The number of minor events rose by 50% to 98 in 2017 compared with 66 in 2016. I am still finding too many weak signals in the field of fire prevention, such as oil leaks and unsuitable storage of combustibles. I will be keeping a watchful eye on these issues throughout 2018 (see Chapter 3).

Results related to the quality of operations have stagnated over the past few years and showed a slight deterioration in 2017. The number of events per reactor ranges between 1.2 and 1.6 for non-conformance with technical specifications and 0.6 and 1 for alignment errors. Despite the dedicated action plan implemented over the past three years (especially on compliance with the alignment guidelines), the number of errors is still too high. The majority of these errors reflect the ongoing challenge of transforming good intentions into good practices in the field, like the rigorous application of error prevention tools (see Chapter 7).

0

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2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

US France

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Unplanned unavailability rates of PWRs in France and the US

Although corrective actions have been undertaken diligently for the Level 2 events, I note that conformance checks still need to be conducted, including the design aspects. As for the seismic resistance of an embankment at one site (see inset), EDF had classified this event as

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Level 1 and considers the temporary shutdown of the four reactors imposed by the ASN to be unsubstantiated. It seems to me that both parties should initiate further investigations into the way this event was handled so as to learn from this episode to prevent similar situations from occurring in the future.

KEEPING THE MOMENTUM GOING IN THE UK FLEETI am pleased to note that not a single INES Level 2 event or higher occurred in the UK in the past eight years.

The number of INES Level 1 events is similar to that recorded in 2016 (0.4 events per reactor in 2017 versus 0.27 in 2016). I must point out, however, that the UK nuclear safety regulator applies different declaration requirements to those imposed by the French regulator.

A small leak was observed on a steam generator drain line at Sizewell B during a planned refuelling outage. The repair, which resulted in an extended shutdown, took into account international OPEX from similar events. It has been carried out as a precaution to all steam generators on the site.

Since the amendment to the declaration criteria in the UK, similar results for INES Level 0 events have been achieved in both the French and the British fleets, with an average of around 6 events per reactor in the UK. This is a welcome indicator of transparency.

The nuclear and industrial safety indicators show an overall improvement, with the exception of reactor trips which have seen a marginal increase.

Turbine hall

This improving trend is testament to effective practices founded on a well-coordinated continuous improvement strategy. In contrast to 2016, however, there has been no reduction in the performance gap between sites. I have nevertheless noted the support provided at a national level to rectify this issue.

As was the case in 2016, no significant or major fire events were reported. The number of minor events is still relatively high however, and I notice there was a slight increase in 2017. Efforts to prevent these events must be redoubled.

Four INES level 2 events

Four Level 2 events on the international nuclear event scale were declared in 2017.1 - Weaknesses in the seismic resistance of the anchors

and supports for some of the diesel generator auxiliaries in the 1300 MW reactors and in some 900 MW reactors. This issue was detected during ageing checks and led to a review of the practices applied during plant construction to prevent these failings from recurring. The necessary structural reinforcement has now been completed.

2 - The seismic resistance of the coolant expansion tanks for the standby diesel generators at two reactors could not be guaranteed due to corrosion. This problem was discovered during additional checks performed within the scope of the previous event. It highlighted inadequate sampling in the routine checks conducted to date. Repairs were carried out and additional checks performed on the other reactors.

3 - Flood risk in the cooling water pump rooms. Corrosion was discovered on a pipe of the fire suppression system that passes through these rooms. The consequences, considered from a fire prevention viewpoint, were deemed acceptable by the operator. The ASN requested a more in-depth analysis of the potential internal flood risk if this corroded pipe failed during an earthquake. Checks were extended to all reactors and all systems posing this kind of risk. Key repairs were carried out and the outstanding work will be completed during the next maintenance outages.

4 - Seismic resistance of a canal embankment located upstream of a plant Studies conducted within the scope of OPEX showed that a section of this embankment fell short of the required safety margins, despite being capable of withstanding the most powerful earthquake ever recorded in the region. Reinforcement work was completed swiftly to strengthen this section of the embankment.

These events all go to show that room for improvement still exists in the design, construction and maintenance of plants.

GROUNDS FOR SATISFACTIONSafety results are improving overall, particularly for operations. The number of events attributable to non-conformance with technical specifications is continuing its downward trend, falling from 0.8 nuclear safety-significant events per reactor in 2016 to 0.6 in 2017. Similarly, alignment errors have fallen significantly, from 3.07 per reactor in 2016 to 0.93 in 2017.

The resolution of recommendations from WANO peer reviews and Significant operating experience reports remains at an excellent level, with over 90% and 90-95% resolved respectively. This result demonstrates a robust process of collective learning from OPEX (see Chapter 6).

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The irradiated fuel dry store at Sizewell B has been commissioned and the first casks were delivered as planned at the beginning of 2017.

I am pleased to report the high level of reliability of safety systems:

• Sizewell B pressurised water reactor (PWR) achieved 100% availability for the tenth year running.

• Unavailability of auxiliary power supplies in the AGRs was 0.08%, versus 0.17% in 2016; unavailability of safety injection systems was 0.124 compared with 0.061% in 2016; and unavailability of standby diesel generators was 0.166% versus 0.043% in 2016.

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AREAS OF CONCERNThe management of maintenance outages remains a challenge, which can affect staff composure and weaken the level of nuclear safety due to changes that have to be made unexpectedly. I am pleased to note though that safety remains the top priority for operations teams.

There is still a significant backlog of plant defects. Even if they cannot directly cause a plant event, some faulty equipment can impact the reliability of important systems and thus lower the protection threshold margins. In 2018, I will monitor the results of the action plan underway.

The number of non-conformances with technical specifications has improved slightly, but there is still too much disparity between sites. To ensure further progress is made in this area, I encourage the promotion of OPEX initiatives between peer groups from different sites, such as the Operations Manager’s peer group and the Configuration management task team.

Characterisation of cracks in the graphite bricks of AGR cores is the key factor to determining their length of service life (the oldest reactors - Hunterston B and Hinkley Point B - came online in 1976). Regular inspections tailored to each reactor remain an essential means of ensuring there are no fast-developing cracks and of re-evaluating methods of control. In 2017, three new keyway root cracks were reported in two of the three reactors inspected. The total number of cracks remains well below the limits specified in the safety case for each reactor. I welcome the increased frequency of inspections for the lead reactors.

SATISFACTORY FUEL PERFORMANCE

Leaktight fuel is the primary nuclear safety barrier and remains a major objective for both the French and UK fleets. In 2017, the fuel assembly failure rate remained at a satisfactory level in both fleets.

For PWRs, I note that:

• In France, around one in every 1,000 fuel assemblies unloaded was found to have a leak

• At Sizewell B, the only PWR in the UK, no leaks have been found to date.

Most fuel failures result from cracking caused by stress corrosion of the friction springs on some types of fuel assembly. The corroded material can come loose and become a source of foreign material. The friction springs can also damage the surface of the fuel rods through friction and cause leaks. The solution to this problem involves heat-treating the springs. This requires further development which will take at least two years before the first fuel assemblies can be manufactured.

In 2017, fuel assembly bowing had no impact on operations. This was reduced through the use of guide tubes made of a special alloy, Q12 from AREVA (currently being deployed) and ZIRLO from Westinghouse (used since 2006 in 1300 MW reactors).

Transport of spent fuel: de-tensioned flask lid bolts

It was reported in the UK that several bolts used to secure the lid of a transport flask containing spent fuel were found to be loose on arrival at the storage facility. This INES Level 1 event had no impact on safety but could have caused a contaminated water leak outside the flask had it endured a major accident.This event highlighted not only the inadequate incorporation of OPEX gained from a similar event that occurred 15 years earlier, but more importantly, a lack of compliance with procedures.

For AGRs, 8 elements were found to have leaks out a total of about 40,000 used in the reactors. Most of these failures were discovered in the same reactor. This led to the operator taking specific measures, including reducing the reactor power, lowering the rates of power increase, and increasing the cooling of the most highly irradiated fuel assemblies. The total number of leaks in this reactor fell from 16 in 2016 to 6 in 2017. The cause of these failures seems to be associated with carbon deposition on the fuel elements. This physical-chemical phenomenon is a highly complex issue to resolve. Solutions are currently being studied and I will monitor their effectiveness.

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NUCLEAR SAFETY PRIORITY AFFIRMED

Good housekeeping

Nuclear safety remains the top priority in a challenging environment and is underpinned by robust independent oversight.

In France, some of the improvements being undertaken at a fundamental level are slow to deliver tangible results in the field.

Despite the progress made by both fleets in fire safety, there is still room for improvement in prevention.

MORE SUBSTANTIVE NUCLEAR SAFETY RESULTS SOUGHT IN THE FIELDDespite budget constraints, nuclear safety remains the top priority for the EDF Group when making any kind of decision. This also holds true regarding the challenges facing both the French and UK fleets, such as the recent skills renewal in France and the preparations for the transition from AGRs to EPRs in the UK (see Chapter 5).

In France, these trying times continued on from 2016 well into 2017 with:

• Several reactors being offline for long periods (Bugey 5, Fessenheim 2 and Paluel 2)

• Shutdown of all four reactors at Tricastin for several months at the request of the ASN

• Ongoing issue of carbon segregation and irregularities found in the marked/unmarked files (see Chapter 1)

• The inspections and work associated with plant compliance checks (see Chapter 2).

I admire all the teams for their ability to adapt quickly against this backdrop of significant change, whether for the plants involved with the Fleet upgrade programme or for the engineering functions undergoing major restructuring.

Regardless of the progress illustrated by the indicators, there are still signs of weaknesses. This is especially true

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for fundamental initiatives where progress is too slow, particularly with respect to work quality in operations, maintenance and design. As I commented in 2016, this is evidence of an insufficiently pragmatic plant-oriented approach to nuclear safety with too little finding its way to the plant touchers. It also reflects the complexity of the transformations necessary to achieve lasting changes in behaviour. This is highlighted by the fact that the human performance tools, the sharing of best practices across functions and the application of OPEX are all underused as a means of supporting continuous improvement.

Surveying earthworks at Hinkley Point C

I believe leadership programmes need to be consolidated to support managers, particularly new managers. There is a need to prioritise managerial presence in the field by refocusing on their core skills, and to ensure that teams are more accountable for defining and achieving results - nuclear safety results in particular. I noted that several leadership teams were now adopting this approach, which seems to be more conducive to a stronger nuclear safety culture. I urge leaders to adopt a more pragmatic approach to engaging with teams in the field. I will be interested to see how this plays out in 2018.

I am pleased to see evidence of closer relations between the Nuclear generation division (DPN) and EDF Energy, illustrated most clearly by:

• Greater interaction between the independent nuclear safety oversight teams, notably through the end-of-year annual nuclear safety review for each site that could be adopted in the UK

• A joint safety culture seminar involving CGN1, the DPN (EDF SA) and EDF Energy

• Exchanges between Chief nuclear officers from both fleets, including joint observation of site performance reviews.

In France, the major modifications required post-Fukushima continue to be deployed to a tight schedule. Projects include the construction of local emergency response centres, the design of ultimate emergency diesel generators capable of withstanding beyond-1 China General Nuclear Power Corporation

design-basis earthquakes, and the strengthening of the control room operations teams combined with the relevant training.

In the UK, post-Fukushima modifications consistent with AGR characteristics have been completed and operator training programmes now include beyond-design-basis accidents.

At Hinkley Point C, the ten traits of a healthy nuclear safety culture developed by WANO have been adopted from the outset (see Chapter 9). Many concrete actions have been taken to promote a controlled working environment and to achieve a balance between productivity and quality of life under a wider Welfare and working environment plan.

DESIGN AUTHORITIES - PUTTING GOOD PRACTICE INTO PERSPECTIVEThese organisations are responsible for ensuring that plant design integrity is maintained throughout the operating life, including for any modifications.

I have seen the progress being made by the French Design Authority (DesA) for the fleet, including, for example, the recently introduced unit design identity cards (see inset). The DesA provides the necessary support for all operating units and provides an independent verification. Links have also been established with the Design Authority (DA) in EDF Energy’s Nuclear Generation, which was set up 10 years ago. The French DesA should be able to rapidly improve its operating methods by drawing on experience from the UK DA. It also needs to make sure it has sufficient capacity to deliver its role efficiently in light of the extensive scope of work.

In the UK, EDF Energy will soon have to make some key decisions regarding the life extension and subsequent final shutdown of the AGRs in its fleet. The DA will be playing a key role in checking compliance with the reference design and in adapting this design to meet the requirements of the safety case. I also note that a review of the loss-of-grid risks associated with the UK energy transition in an isolated network has already been undertaken (see inset). Simplification of the current DA for Hinkley Point C will be based on the role of and support from EDF Energy Nuclear Generation’s DA.

Unit design identity cards

These cards - deployed by the DesA for the French fleet - provide proof that each reactor complies with the reference design. They summarise all the information deemed useful to the operator and the independent nuclear safety oversight team so the units can be restarted safely after maintenance outages. The ID cards for all 58 reactors are planned to be completed by the end of 2018.

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NATIONAL - LOCAL RELATIONS: FORGING CLOSER LINKS IN FRANCEManagers on sites have told me of their difficulty in building relations between the central services and individual plants:

• Central services are still working too much in silos, with responsibilities sometimes unclear and deploying information systems unfit for purpose

• There is a lack of engagement from plants in meeting targets and project deadlines.

These issues do, of course, need to be put into perspective as I also see many staff working hard at both plant and national level to change these attitudes and there are successes, e.g. task forces, the reduction in automatic reactor trips, and the coordination of plant-focused projects such as COLIMO for plant isolations.

I urge both central and plant leadership teams to redouble their efforts in this important area. I will continue to monitor progress throughout 2018.

ROBUST INDEPENDENT NUCLEAR SAFETY OVERSIGHTIN FRANCEThe DPN Nuclear Safety Director and his teams provide invaluable support and input to the site management and local independent nuclear safety oversight teams, especially due to their strong presence in the field.

It is important to maintain this organisation’s high profile and ensure that its advice is implemented at all levels. I was surprised to learn, for instance, that the Nuclear Safety, Radiation Protection and Environment panels1 are no longer practised, despite being prescribed in the 2016 edition of the Nuclear Safety Handbook, and that all too often the national independent nuclear safety oversight team has to intervene to re-categorise events.

The DPN’s Nuclear Inspectorate (NI) offers effective independent site monitoring. I recognise the NI’s willingness to adapt its nuclear safety inspection standards in the interests of simplification for an improved uptake by the sites. Compliance with NI recommendations is at a reasonable level (72%). I am not aware of any recruitment difficulties in this area.

I note that there are two positive developments taking place in 2018 which will add to the remit of the NI, i.e. oversight of site security and of the DIPDE with assistance of the DIPNN audit unit.

The safety engineers at the plants have a good level of skills and are participating in ongoing training programmes to develop them further. Their profiles are more experienced and varied than in previous years. This positive trend needs to continue to ensure that all knowledge areas 1 These panels are formed at the request of any staff member who

wishes to challenge, on the grounds of safety, any decision made

are covered, particularly maintenance. They are supported by the site Safety & quality managers and are well-respected by site management teams. However, I would like to draw attention to some of their tasks which appear too administrative, like updating indicators and preparing for Peer Reviews. It is imperative that these tasks do not detract from their primary role.

The independent nuclear safety oversight team at Flamanville 3 is gearing up for the plant’s operational phase. Support from the corporate oversight team and OPEX from Taishan will prove useful.

The Engineering audit unit at the DIPNN continues to fulfil its oversight role. I will be monitoring the uptake of its advice and its continued independence during the current restructuring process, as well as the team’s recruitment profiles.

I met with senior management from the Independent oversight directorate (DACI) for the newly established EDVANCE engineering division (see Chapter 9). DACI’s main challenge is to ensure independent supervision of the safety issues faced by each project area. EDVANCE will need to make sure strong links are formed between the DACI and the DIPNN’s independent nuclear safety oversight team.

Control room operator

The Internal inspection organisation (OIU), attached to the Expertise & inspection department for manufacturing & operation (CEIDRE), assesses the conformity of pressure equipment destined mainly for Flamanville 3. This year again I was struck by just how independently and diligently teams at the OIU have been working. Their focus on preserving its high profile within the group of approved bodies (APAVE, Bureau Veritas, etc.) was confirmed by EDF SA’s Industrial policy committee in June 2017. As a result, a number of activities, in addition to those undertaken for Flamanville 3 and Hinkley Point C, should be taken over by OIU from the DPNT and the DIPNN. This includes spares compliance assessments for the fleet and equipment compliance assessments for new projects. An expansion of the OIU’s remit to include other equipment could also be explored.

IN THE UKThere is a robust independent nuclear safety oversight function in the UK led by the Safety, security and assurance director who is well placed to interact both with the sites and the wider Group.

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Loss-of-grid events in the UK

The energy transition in the UK has led to the closure of coal-fired power stations in favour of renewables, which has reduced the national grid’s capability to come back online quickly following a blackout. A review of the safety studies for all nuclear plants was undertaken to demonstrate their ability to operate without the grid for longer periods of time. This necessitates larger on-site stocks of fuel oil so standby diesel generators can be used for longer periods. Blackout operating procedures have been reviewed and corresponding training actions have been instigated. The problem is limited in France because of the high levels of inter-grid connection across Europe and the different reactor technology to the UK.

The head of Independent nuclear assurance (INA) has a high profile within the various steering committees and challenges the operational teams.

The INA teams based at each site comprise experienced personnel, often from outside EDF Energy. This offers a breadth of expertise and a degree of openness which is invaluable yet which can also present recruitment difficulties for some sites. Their independence is clear to see and they have no hesitation in questioning the Chief nuclear officer (CNO) during plant performance reviews. I am also impressed by the strong trust-based relationship established with the ONR.

At Hinkley Point C, independent safety monitoring is provided by the Internal Assurance (IA) function reporting to the Safety and assurance director. The IA team also monitors suppliers to check that all safety requirements have been properly incorporated ahead of major construction milestones. I have also seen a real desire to build greater confidence into their relationship with the ONR. I will be paying particular attention to these points in 2018.

A COMMON APPROACH TO HOUSEKEEPING IN BOTH FLEETSHousekeeping in France remains good in spite of a few issues which require specific action at certain plants.

In 2017, the directors of the DPN set a minimum housekeeping performance level for a site to qualify to win any award at the annual DPN challenge event.

I also met with teams from the UK who have been making significant progress over the past two years in benchmarks and joint assessments with their French counterparts leading to agreed site scores. They still have a gap to close to reach the level of the French fleets.

The most sensitive issues in both fleets are corrosion, leaks and storage. I acknowledge the value of involving contract partners with the housekeeping initiative.

FIRE SAFETY: WEAKNESSES IN PREVENTION

Despite satisfactory results in the fire indicators for both fleets, they are undermined by some weaknesses, as confirmed in France by the DPN’s Nuclear Inspectorate.

I have observed the following at sites:

• A lack of momentum as regards a fire prevention culture

• Insufficiently demanding standards at some plants• Relationships with some external fire services that

could be improved in France• Inadequate improvement coordination of French

plants by central DPN staff.I do, however, commend the work undertaken by EDF R&D, tasked by the DPN to model fire dynamics more accurately and to assess fire loadings using a full-scale test loop.

R&D fire test loop project

MY RECOMMENDATIONS

To ensure that fundamental changes become more effective and firmly embedded in current practices, I recommend that the Directors of the DPNT and DIPNN review their leadership initiatives by focusing on the added value provided by having managers in the field and by offering greater support for newly promoted managers.

In the context of restructuring the new-build engineering function, I recommend that the Director of the DIPNN strengthen the role of its in-house nuclear safety oversight and assure not only their independence but also the widespread uptake of their advice.

In light of the risks and a number of weaknesses associated with fire safety (prevention, behaviours and coordination), I recommend that the Director of the DPNT and the Chief executive officer of EDF Energy both redouble the efforts in this area.

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RISK PREVENTION: IMPORTANT TO REMAIN VIGILANT

ICI À BUGEYJE SUIS VIGILANTPOUR MA SÉCURITÉET CELLE DES AUTRES

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Safety is a collective responsibility

The safety results are improving in both fleets. The electrocution of one worker and several serious accidents are a reminder of the vigilance required during critical tasks and the absolute need to follow instructions.

The radiation protection results are continuing to improve due to the work on fundamentals, which has been underway for a number of years.

NEED TO PAY GREATER ATTENTION TO CRITICAL TASKSIN FRANCE: IMPROVEMENT BUT ONE TRAGIC EVENTI am saddened by the fatal electrocution of a young contract partner. Nothing can justify the death of an employee and this tragedy reminds us of the importance of the day-to-day effort necessary to prevent such situations arising during critical tasks.

In the DPN, the number of industrial accidents has fallen substantially, with an overall accident rate1 of 2.2 (2.8 in 2016). However, I note that there is too great a disparity with overall accident rates up to 4 times greater in plants 1 Number of industrial accidents per million hours worked by

EDF and contract partner staff

that are the furthest behind. Slip, trip and fall hazards continue to be the main cause of lost-time accidents. The number of people injured as a result of activities involving a significant risk (lifting, work at height, electrical hazards) has fallen: 13 in 2017 (26 in 2016 and 32 in 2015).

In engineering, the results are unsatisfactory, with an overall accident rate of 3.7 for the DIPNN (2.6 in 2016) and 2.7 for the DIPDE, which is an improvement over last year (4.5 in 2016) but they are still too high. These results are linked to the accident rates of contract partners, so engineering must focus its efforts on this issue (see Chapter 8). For example, several lifting incidents and falls from height could have had tragic consequences on the ultimate emergency diesel generator construction sites.

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At Flamanville 3, the results are faltering, with an overall accident rate of 5.1 (4.4 in 2016 and 5.8 in 2015). The start-up of the plant means that systems being installed and those already in service are next to one another, which gives rise to new risks. This is why initiatives in the field must continue so that the benefit of years of work is not lost.

On decommissioning sites, the overall accident rate was 2.0 in 2017, which is an improvement as it reached 5.8 in 2016 and was 4.2 in 2015. As at the DPN, special attention should be paid to significant risks: the dropping of a container weighing several tonnes as it was being loaded onto a trailer confirms this point.

Safety takes priority on a construction site

IN THE UK: CONTINUING EXCELLENT PERFORMANCEThe accident rate remains at a very low level, with an overall accident rate of 0.2 in 2017, compared with 0.3 in 2016. This result, which is the best ever, is mainly due to the Zero harm initiative that was introduced several years ago. In particular, I note the remarkable reduction in the number of slips, trips and fall accidents, achieved as a result of valuable collaboration with contract partners.

However, the teams were hit by two potentially fatal falls from height, which demonstrated a failure to comply with procedures and inadequate levels of control. These incidents remind us that care is still vital, even when the results are excellent. I am pleased with discussions between the DPN and EDF Energy Nuclear Generation on working at height, with a joint campaign to raise awareness scheduled for 2018.

REINFORCING RIGOURThere have been a number of serious accidents or near-misses associated with situations involving significant risks. One example of this is the electrical risks in the DPN, where there was one fatal accident and 6 injuries in 2017.

I consider this situation to be unsatisfactory and that a timely response is essential. It is the result of laxity with regard to wearing the correct personal protective equipment and a failure to comply with rules. All parts of the Group must be watchful, in particular during electrical work, working at height and lifting. Attention must also be paid to dealing with weak signals and the correct use of human performance tools (pre-job briefing, time-out for personal safety, etc.).

CONSTRUCTIVE FRANCO-BRITISH DISCUSSIONS ON INDUSTRIAL SAFETYIn both fleets, I note real determination and a great deal of effort being put into industrial safety. The results are showing progress too.

BETTER SHARING OF METHODS AND TOOLS…A great deal of information is shared between the two fleets. This includes visits to provide assistance, comparative analyses, pooling experience and joint initiatives. I would like to see such dialogue continue and lead to concrete actions.

The tools and methods about which there are regular discussions include:

• Collective responsibility initiatives in safety (vigilance partagée)

• The Zero harm approach and its rules• Industrial safety messages• Industrial safety training courses for all staff prior to

unit outages• Control and support for the implementation of

human performance tools• Centres for information and meetings on industrial

safety• A risk management tool (see inset)• Teams dedicated to industrial safety, which

bring together staff from contract partners and EDF Energy.

Key risk tool

Every three months, each EDF Energy site assesses 40 industrial safety risks based on incidents, weak signals, results of inspections and audits, etc. Using this approach, areas for improvement can be defined and prioritised according to the gravity of each risk. The fleet’s corporate teams, to whom the results of these examinations are sent, can also provide the sites with targeted support and identify weaknesses common to all sites.

…WHICH MUST BE PROMOTED MORE BY MANAGERS IN THE FIELDTo be effective, these tools must be strongly supported by managers.

For example in the UK, industrial safety messages are updated each day and shared at every meeting. I am impressed by the spontaneous involvement of everyone in these short discussions. It demonstrates excellent adoption of this simple and useful lever, providing learning that is beneficial to everyone. This practice has been in place in the UK for ten years, and is still being rolled out in France.

I again stress the importance of managerial presence close to activities at plant level to support their teams and to confirm that work is being carried out safely. Many

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managers are convinced of the need for this but fail to devote enough time to it. Being present on the plant is essential, but it is above all their behaviour which counts. If a manager observes a safety performance gap and does nothing about it, this is equivalent to condoning it.

I note a difference in the maturity of the managerial style in France and the UK, both in terms of the ability to "spot at a glance" (learning to see) and the capacity to challenge (learning to speak out).

To reach their current level of maturity, UK managers have gradually implemented actions over time to increase industrial safety both collectively and individually. Ten years ago, aware of the poor performance, EDF Energy’s leadership decided to promote an approach limited to just a few simple behaviours to be adopted by everyone, everywhere. This approach was based on setting a good example and requiring management to deal with performance gaps until everyone behaved in the desired manner automatically. Other requirements were gradually added to these initial behaviours.

For the ability to "spot at a glance", the approach is the same in both countries. It involves being accompanied by a specialist or coach. In the UK, this coaching is more limited to key points, accessible to a non-specialist. This helps managers and leaders gradually assimilate more and more requirements.

PROMISING START FOR CONSTRUCTION WORK AT HINKLEY POINT CLike every large-scale construction site, there are significant industrial safety risks. At Hinkley Point C, 4 accidents were recorded in 2017, including one fall which could have been fatal. The process introduced by EDF Energy Nuclear Generation and the DPN with regard to working at height could be of use here.

Hinkley Point C has introduced a core process to manage industrial safety risks. It is based on:

• Reporting of safety performance gaps, even minor ones (currently more than 100 received per month) which could have an impact on health or safety

• Raising staff awareness by the construction site executive team based on the above information and implemented according to the activities affected

• Designation of industrial safety coordinators to clearly defined areas of the site.

This culture of reporting safety performance gaps and making staff accountable, supported by targeted communication on the risks, is promising and flexible enough to adapt to the reality of a construction site where the risks are changing daily.

DETECTING ADDICTIONS

While alcohol consumption and drug-taking are widespread in society, the risks specific to the nuclear

industry make zero tolerance imperative. Alcohol consumption and drug-taking is obviously prohibited at nuclear sites and I note that all UK sites and two French sites carry out random testing. I would like to see EDF SA’s nuclear divisions bring this initiative into general use with the support of the Group’s human resources division. It would be useful for the two fleets to share their lessons learned on this issue.

I repeat my 2015 message calling for collective responsibility in teams, for better and earlier detection of any addictions.

Inspection using smart eyewear

RADIATION PROTECTION: IMPROVING RESULTSIN FRANCE, SIGNIFICANT IMPROVEMENTSThe average yearly individual dose per employee has fallen from 1 mSv (milliSievert) in 2011 to 0.83 mSv in 2017 (see graph). Likewise, the number of employees (EDF and contract partners) having received a dose of more than 10 mSv has fallen from 274 in 2016 to 89 in 2017. No employee received a dose of more than 13 mSv in 2017. The regulatory limit is 20 mSv.

The collective dose remains at a satisfactory level (0.61 man-Sv/unit, as against 0.76 man-Sv/unit in 2016), and the average hourly dose level within the fleet, which has fallen by 25% in ten years, has remained at a low level since 2010. It was 5.39 μSv/h in 2017 (see graph). These good results have been helped by a lower volume of maintenance work than in 2016.

The radiological cleanliness indicators remained good in 2017:

• The trip rate of the radiation monitors at controlled area exits improved in 2017, reaching 0.27% compared with 0.46% in 2016

• The trip rate of the radiation monitors at site exits fell to less than one trip per 50,000 people

• 2 significant radiation protection events involving contamination of an on-site road (2 events in 2016)

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• 3 significant radiation protection events associated with skin contamination (2 in 2016)

• 3 significant events involving transport with a radiological impact (out of a total of 12).

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The results for hazardous situations improved markedly, but attention must be maintained:

• 29 events in orange hazard areas (45 in 2016)• 1 event for activities in red hazard areas (4 in 2016)• 6 events associated with radiography (9 in 2016).

The DPN Nuclear inspectorate gave a favourable assessment of the plant organisations with regard to work in red and orange hazard areas, but noted too many disparities between sites for radiography.

On the whole, the good overall radiation protection results are due to the detailed work that has been ongoing for a number of years. This work must be continued, stressing the culture of radiological cleanliness and rigour in carrying out radiography.

IN THE UK: CONTINUED PROGRESSCollective exposure on AGRs is limited due to their design, and the collective doses measured are among the lowest in the world (0.02 man-Sv/unit). The annual collective dose for the Sizewell B PWR remained low (0.3 man-Sv), which places it in the top quartile worldwide.

The maximum individual exposure for all reactors was 5.54 mSv.

I also note good results for radiation monitors at controlled area exits, with a trip rate of 0.07%, which is stable in relation to 2016 (0.09%).

There were 10 significant radiation protection events in 2017 (20 in 2016), none of which were classified as very serious contamination incidents.

RADIATION PROTECTION MANAGEMENT

IN FRANCE: ROBUST LEADERSHIP THOUGH STILL DOMINATED BY SPECIALISTSThe results are good and improving; the management of radiation protection remains active yet it usually seems to be in the hands of specialists, with little ownership by management. WANO indicates that there is some room for improvement in comparison with the best operators. I note that new tools continue to be deployed to assist with this ongoing improvement.

Risk prevention monitoring units (see inset) have been set up on most sites in France. They will be on all sites by the end of 2018.

CADOR (a decision support tool for optimising the installation of biological shielding) will only be more widely used if it is simplified soon and made more user-friendly. This is all the more important as it is useful for reducing occupational doses during the Fleet upgrade programme.

Risk prevention monitoring unit

Campaigns to clean up primary cooling systems are the most effective lever for reducing the radiation source term and thus the collective dose. However, they are often postponed or cancelled because of scheduling constraints. I would ask the DPN to be more proactive on this matter. Nonetheless, I note the continuing efforts to eradicate hot spots.

In my 2016 report, I highlighted the introduction of new radiation protection regulations, their complexity and the likelihood of operators feeling less accountable. Their entry into force in January 2018 will have a significant impact on the organisation:

• Creation of a radiation protection skills centre at each site

• Writing of guidelines

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• Implementation of a new dosimetry information system

• Monitoring of certain requirements such as the eye lens dose or radon

• Etc.

I note that the DPN has set up a task force and I will monitor its work to assess the benefits achieved and the complexity created for the sites.

Close-proximity radiography (CPR)

This radiography system, which is a great deal more compact than conventional systems, is placed in contact with the component to be checked. The radioactive source always remains inside its protective container. It also has a beam concentrator (collimator) which limits radiation scatter. This improves the protection of workers and reduces the size of the prohibited access area during radiography. CPR systems can also use selenium sources. The implementation of CPR in France requires a change in regulations.

IN THE UK: PROACTIVE MANAGEMENTAt EDF Energy, I note continuing progress in the management of radiation protection:

• Use of a new indicator to monitor and manage small-scale contamination

• At Sizewell B, significant efforts by the team to reduce the dose during irradiated fuel dry storage operations (6.5 man-mSv for the first fuel cask and 2.34 by the seventh cask)

• Widespread implementation of close proximity radiography (see inset) which limits the risks during radiography.

Risk prevention monitoring unit

This computerised unit provides real-time centralised collection of radiation protection measurements from mobile sensors installed around the worksites. It has video and audio equipment for communicating with workers if it is necessary to alert them.This good practice optimises the dose while limiting the number of people in the area concerned. It helps workers focus on the job in hand and makes it easier for similar worksites to share experience using videos.

POSITIVE SYNERGYIn the context of their 5-year radiation protection synergy plan, the DPN and EDF Energy Nuclear Generation are in regular contact, and hold an annual plenary meeting. In 2017, discussions and achievements mainly concerned transport containers for radioactive products, gamma radiography cameras, close-proximity radiography (see inset) and risk prevention monitoring units (see inset). I encourage such dialogue, which is driving improvements in both fleets.

MY RECOMMENDATION

Throughout the Group there have been accidents and weak signals during activities involving significant risks (electrical work, working at height, lifting, etc.). I recommend that the Directors of the DIPNN, the DPNT and EDF Energy further reinforce the prevention of these risks for EDF staff and contract partners.

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ADAPTING PEOPLE SKILLS

Paris-Saclay training centre

It takes some time to become suitably qualified and experienced in the nuclear sector, which means the manpower and skills requirements must be planned for well in advance to ensure that nuclear safety is maintained.

Against a background of change and a quest for competitiveness, the role that managers play in supporting their teams is more crucial than ever.

STAFF REDUCTIONS UNDERWAY AT EDF SA

MANAGED REDUCTIONS NOT AFFECTING NUCLEAR SAFETY…The staff reductions instigated in 2016 continued in 2017, at differing levels for the various sites and jobs. I am pleased to report that an influx of new recruits has been maintained at both the DPN and the DIPNN. This will make it possible to develop the skills of the staff concerned, providing the necessary time for them to become suitably qualified and experienced.

Almost all business units carry out good advanced planning of jobs and skills (GPEC), which helps them

control staff movements far enough in advance. In particular, this enables the plants to prepare for the job targets defined for each profession by 2020.

The sites in question are anticipating changes in their organisation or type of activity, for example preparing for Flamanville 3 to come into service or setting up EDVANCE (see Chapter 9). The same applies to teams whose workload is increasing, or is about to increase, and whose manpower has been increased. This is the case for the Nuclear rapid action force (FARN), the Joint outage teams or the Site joint project teams (mixed engineering and operations teams responsible for implementing modifications in the plants).

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1200

1000

2017 2005

800

600

400

200

018 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 52 54 56 58 60 62 64 66

DPN age pyramid

Overall, I am impressed with how the ongoing manpower reductions have been controlled and managed, maintaining nuclear safety as the priority.

…BUT SOME POINTS TO MONITORI again emphasise that the pressure to reduce workforce numbers is likely to reduce inter-site mobility. This could prevent staff gaining wider experience, which is essential not just for the Company, which must have the necessary skills available at the right time, but also for staff fulfilment and motivation. Some good practices have been developed locally, e.g. in one plant, intensive training sessions have been organised for people in the commercial division or conventional power field prior to a job transfer. Teleworking at the Operations engineering unit (UNIE) has also been introduced to address the lack of appeal of a site in the Paris area. Overall, however, there is still little in place to increase mobility through career paths being specially developed for the people involved, as I have been recommending for some years. Good intentions and willingness are not enough and I have to question whether the system should be forced a little by introducing target indicators, or even quotas.

It is important that a minimum influx of new recruits is maintained. The diversity they bring is vital for open-mindedness, innovation, motivation, etc. Although it is not currently at the stage of an alert, signs of a decline in the attractiveness of jobs in the nuclear industry may need some attention.

I have also observed recurrent problems in planning sufficiently early for the replacement of some high-level experts in the Group.

I have stressed the importance of advance planning in skills management. To achieve this goal, any critical jobs identified must of course be closely monitored.

This is particularly the case for the operations teams at the DPN (see Chapter 7) or for the renewal of the first FARN teams. I must stress the challenges faced with this process: in order to maintain the attractiveness of the FARN, sites must supply it with high-calibre staff and must also make sure that they capitalise on the experience they have gained when they return.

In addition, the increase in the number of staff in the Site joint project teams, as planned for in recent years, should

continue so that sites which are due to incorporate the Fleet upgrade programme modifications have adequate resources for their next ten-yearly inspection outages.

It is also important to prepare in advance for the renewal of the nuclear fleet. The career paths of those involved in current EPR projects in France, China and the UK should be organised so that the skills they have gained can be utilised in upcoming projects.

THE CHALLENGE OF TRANSITIONING FROM AGRS TO EPRSIn the UK, the end of the service life of the AGRs, the first of which were commissioned in 1976, will lead to a reduction in the number of staff operating the sites concerned between 2023 and 2030. At the same time, the need for skills to implement new projects and operate future nuclear units will increase. New skills will also be needed for decommissioning activities.

Hunterston B nuclear power plant

The need to meet these challenges, while keeping staff well informed so that they remain motivated, is well understood.

Managing this transition from AGRs to EPRs is a key issue for the future of EDF Energy, which has initiated reviews to create and analyse various scenarios. These reviews are led jointly by EDF Energy Nuclear Generation and the new-build business unit, with the aim of improving nuclear safety, reducing risks and lowering costs for the whole fleet. Since decisions on the involvement of EDF Energy in some of the scenarios are not entirely within their control, it is important that these key options can be discussed well in advance with the relevant stakeholders.

These discussions made significant progress in 2017, applying a broad-based approach covering extension of service life, withdrawal from service and decommissioning of the AGRs, as well as the construction and operation of the new reactors. I am impressed with the way in which they have been organised well in advance, both in-house and with the external bodies that may be involved in some scenarios. I will keep an interest in developments.

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CONTINUING ROBUST SKILLS DEVELOPMENTThe significant renewal of skills, which began some years ago at EDF SA, has been a success. The various approaches, such as the Skills programmes at the DPN and the Systematic approach to training (SAT) at EDF Energy, have professionalised new recruits and developed the skills of the more seasoned staff.

ADAPTABLE TRAININGIn the UK, qualification programmes for workers and managers are continuing to work well. For key positions, the programmes are regularly assessed by the Training standards and accreditation board (TSAB).

In France, the DPN spends a significant proportion (around 10%) of its total salary bill on training workers. To make it easier to better assess the contribution of training and therefore target expectations, a number of criteria are defined when the training requirements are drawn up. These criteria need to be broad-based. It is also likely that the reduced training burden in the future will make it easier to set priorities. For example, the length of the initial training for new recruits (induction training) will be adjusted to ensure there is no overlap with other courses.

At the DPN, there are training committees now in all the business units and thus the Skills programme was accordingly ended in 2017. The ongoing activities which it initiated have been incorporated into the ‘Developing highly-professional employees’ sub-process, in order to achieve strong business performance, while maintaining the current arrangements. In 2018, I shall be monitoring how this is rolled out on all sites.

Central control room training

Training for DPN professions is coordinated by the Skills advisory centre for organisational effectiveness (PCC-EO) (see inset), except for certain groups, such as nuclear safety, spares and site protection which are organised by the relevant business units.

This coordination is carried out efficiently by a small group of experienced staff, and is widely appreciated. To increase its impact still further in the plants and DPN corporate business units, I encourage the PCC-EO to provide more concrete operational support to sites that are struggling.

Skills advisory centre for organisational effectiveness (PCC-EO)

This small team, reporting directly to the DPN’s deputy director in charge of resources, is responsible for:

• Coordinating the networks: heads of departments, first-line managers, specific professions such as operators, field supervisors, etc.

• Establishing and keeping up to date the role booklets which describe the fundamentals of the profession, core competencies and the organisation of the teams in the plants

• National ownership of training content and associated training resources

• Evaluation of certain corporate projects requiring a high level of technical expertise

• Supporting sites in managing change (drawing up job requirements, advance planning of skills and jobs, rolling out corporate standards, supporting heads of departments when they take up their jobs or in carrying out their work, etc.).

The Operations & engineering training department (UFPI), which has branches across France (see map), continues to play a key role in qualifying staff. Like the other business units, it has adapted to the manpower reductions. The balance between experienced trainers and new recruits is satisfactory, but still fragile. Shared training services, established in all the plants, improve the link between identified needs and the courses available, as well as pooling training courses.

Training centresUFPI HQ

Map of UFPI locations

In France and the UK, initial training and refresher courses for operators meet international standards. However, there are still some problems, e.g. at EDF SA, filling some positions in the operations core staff and organising their training (see Chapter 7).

On-demand or Just-in-time (JIT) training is utilised, but it could be stepped up and provide more focus on certain sensitive areas such as valves or rotating machines.

SOME POINTS REQUIRING ATTENTIONIn France, I sometimes hear criticism of training which is considered to be too broad-based, when most needs are

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specific and relate to targeted practices. The Systematic approach to training was designed to move from mass training to à la carte training that is more targeted and effective for both managers and staff. I can therefore see that progress still needs to be made before it can be fully rolled out and subjected to full oversight. I would suggest discussions with EDF Energy about the role of the Training standards and accreditation board.

The involvement of managers in supervising the training needs of their teams is still inconsistent. This is also true of the assessment of training courses and the use of human performance tools. I again stress the need for managers to play an active role at every stage in the ongoing qualification of their teams, from identifying needs through to providing support in the field.

In a number of plants, I was shown mock-ups and well-equipped craft training centres. Although everyone recognises the contribution they make, they are still underutilised by EDF SA and their contract partners.

MANAGERS ALWAYS IN DEMAND

EDF Group managers and leaders are always telling me about the problems they have in dealing with their day-to-day work:

• Being under internal and external pressure (managing schedules, costs, numerous changes or initiatives to be addressed, regulator requirements, media pressure, etc.)

• Having too many administrative tasks and unsuitable tools for managing human resources

• In France, an integrated management system that is often poorly implemented, with too many meetings that achieve little.

These problems can be amplified by managers not having enough technical experience to be able to support their teams effectively.

The volume of work caused by these challenges is probably one of the reasons for both qualitative and quantitative weaknesses in manager presence in the field. Too often focused on what is happening in the short term, they find it difficult to motivate their staff.

I frequently see workloads that are unevenly distributed and teams working at different rates, even though they are carrying out the same types of activity. I would like to see these disparities evened out, as they are detrimental to both efficiency and the peace of mind of all involved.

Despite these problems, I am delighted to note that managers at all levels remain strongly committed and motivated throughout the EDF Group. They work unstintingly, sometimes making up for weaknesses in the organisation or in colleagues, and do their utmost to develop their teams.

Team briefing

The manager networks help them to share problems and good practices, simplify some methods, share innovations, combat silo mentalities, and develop solidarity. These networks are a great help and I would like to see them introduced more widely.

Despite the difficult environment, managers are taking up major challenges, both in terms of achieving objectives and managing short-term risks, and preparing for the future. They have the support of their line managers and should be better protected against demands which take them away from their teams and their core roles.

MY RECOMMENDATIONS

Against a background of manpower reductions at EDF SA, I repeat my recommendation to the Directors of the DPNT and DIPNN to boost the mobility of management staff, bearing in mind numerical objectives for inter-site mobility and inter-departmental mobility, and maximising cross-career pathways.

At EDF SA, applying the human resource management tools is very time-consuming and they do not meet user requirements. To avoid managers from being diverted from their core activities, I recommend that the Human Resources Director update these tools, ensuring they are simpler and more consistent.

To secure the success of future projects, skills requirements must be planned sufficiently well in advance. I recommend that:

- The Chief Executive Officer of EDF Energy continue the analysis of scenarios for the transition from AGRs to EPRs

- The Director of the DIPNN build the career paths of those involved in the EPR projects, to capitalise on the experience they have acquired in the various project phases for the benefit of future projects.

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OPERATING EXPERIENCE: CONTRASTING APPROACHES

An organisational learning team in the UK

Operating experience (OPEX) plays an important role in nuclear safety by helping to prevent error repetition.

Based on the simple principle of giving the right information to the right person at the right time, OPEX needs to be implemented with rigour and consistency.

To benefit from OPEX and make the most of the advances provided by digital tools, it is vital to ensure that the significant amounts of data involved are well structured.

OPEX contributes to one of WANO’s 10 principles for a healthy nuclear safety culture: continuous learning. Everyone in the EDF Group is asked to actively participate in collecting operating or design experience, both within the company and externally. The information gathered should be analysed so lessons can be learned, and available OPEX taken into account before carrying out work.

I am aware of how difficult it is to apply this principle, which is simple in theory, but is complex to implement.

SOME SIMPLE PRINCIPLES…

The concept of OPEX dates back many years. When nuclear generation first began in France, the SAPHIR event reporting database was created to keep track of events, analyse them and suggest corrective actions. The practice of sharing experience is also long-established.

Numerous documents, reports, reviews, regular analyses, etc. also contain information that complements OPEX. The main difficulty is supplying this information to

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whoever needs it, when they need it and in a user-friendly format.

Operators worldwide and INPO took up this challenge. In the early 2000s, they defined processes dedicated to OPEX called Corrective action programmes (CAP) which were quickly adopted in the UK and France.

The CAP approach is systematic and based on the following principles:

• Everyone involved - EDF and contract partners - can simply report their observations (equipment failure, human error, document errors, organisational weaknesses, high-risk situations, etc.)

• Managers encourage and facilitate this reporting• Every day, dedicated experts categorise the findings

and keep track of them • External OPEX is taken into account• Simple or in-depth analyses propose actions which

are regularly checked by managers• Analyses are conducted in order to detect trends• This work is carried out at both plant and corporate

level.

These arrangements operate in both France and the UK, with dedicated resources (between 4 and 5 staff in each plant and between 5 and 12 at corporate level) and regular meetings are held in support of the OPEX process.

OPEX being used at a pre-job briefing

…WITH DIFFERING INTERPRETATIONS

In all the business units I visited this year, I saw how important OPEX is to everyone. When asked about it, irrespective of their level in the organisation, they expressed their desire to use it to minimise the repetition of events and capture observations in order to help others. Everything has the potential to become OPEX: a report, an experience-sharing meeting, an email, etc. This approach, though commendable at first sight, differs considerably from the international principles and undermines the desire to have traceable, non-repetitive and accessible OPEX.

In France I feel that the process has prevailed over common sense and is not sufficiently geared towards performance improvement, nor sufficiently worker-oriented.

At the DPN, there is certainly a desire to abide by the principles, but this is hindered by problems with their practical application: reporting findings, presentation of OPEX and the ability to find it. It is clear that the fleet OPEX database (BIP) - which seeks to make OPEX available to all - is currently unsatisfactory. The main vehicle for communicating OPEX is at corporate level, with the provision of a weekly OPEX report. It is full of detail, but not particularly instructive. Work to improve it is underway.

Engineering is struggling to deal with all its findings using a single process and restricts itself to key issues relating to design. This approach has the benefit of being simple, but misses out on the potential of the wealth of information available in the field.

EPR construction site teams favour sharing of experience through direct discussions, which are simpler, more interactive and more detailed, rather than using a more instructive format with OPEX traceability that withstands the test of time for future projects.

EDF Energy came up against the same problems when it set up its own OPEX system in around 2005. It managed to overcome them without compromising on the principles by simplifying:

• How findings are reported• How OPEX is presented and categorised, ensuring

it is instructive and documents are organised in a structured manner

• The search system.

OPEX has thus become part of EDF Energy’s culture. It is encouraged by managers and appreciated by the people I met, who understand its importance and use it regularly: “I can’t do without it”.

IN FRANCE, LABORIOUS REPORTING OF FINDINGS…Today, in the DPN, reporting observations is still a complicated, time-consuming process. It is a source of much discontent and demotivation. The CAMELEON environment is being introduced (see inset) to improve this situation by the end of 2018. Data entry should be simplified and eventually be possible from smartphones.

To keep the volume of OPEX manageable, the DIPNN concentrates on major design defects which, once prioritised by a dedicated team, form the subject of OPEX action sheets. Around forty sheets are issued each year and stored in a database where they are linked to relevant documents (reviews, reports, etc.). This approach has the benefit of setting priorities, but OPEX becomes the domain of specialists.

In the UK, EDF Energy has opted for a single database, utilising the Asset management system (AMS). Its use is now embedded and staff no have difficulty in reporting

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their findings. As soon as the Hinkley Point C EPR construction site started, an initiative was put in place to get everyone (EDF and contract partners) involved in continuous improvement. Developed in just five months, the tool offers many ways to report findings: via computer, smartphone or paper forms left in boxes in each work area.

… BUT AN IMPROVING STRUCTURE FOR OPEXThe volume of OPEX increases rapidly over time. A data structure is essential so that users can find events easily and make use of them for many years after they occurred.

In France, I was struck by the large number of databases (Terrain, SAPHIR, CID, CQFD, FAREX, BIP, etc.). Each of them uses a different structure, making it hard for users to easily find information in a convenient format. This situation is clearly understood across the fleet and a redesign of the user environment has been initiated through the CAMELEON project. The eBriD module (see inset) is currently being deployed and will be accessed in the future via CAMELEON; it is designed to simplify briefing/debriefing and to make OPEX available to plant workers. I will be observing its effects and the response of the plant teams.

Organisational learning portal (OLP)

This is the user interface, developed by EDF Energy, based on the software tool Sharepoint. Scrolling banners provide quick access to the most recent and important OPEX. For a given event, a user can track the various documents produced in a structured order (initial description, first lessons learned, causal analysis, technical discussions and detailed reports) and stop at the required level of detail. Users can subscribe to receive daily, weekly or monthly email alerts concerning events on their selected topics (e.g. valves, electrical items, industrial safety, etc.). They can also search and create automatic search filters (frequently used when preparing for plant outages).

In the UK, the Organisational learning portal (see inset) is appreciated by users and recognised by WANO as an excellent product. I have seen it being used regularly by teams. Its strength lies in its modern interface and the strict application of a structured process:

• Initial brief - within two days of an event that justifies sharing quickly, a single illustrated explanatory page is issued which gives a simple description of the facts and sets out immediate actions to be taken. No brief is issued until it is of sufficient quality, which is assessed using an evaluation framework

• Learning brief - within a week, this brief, which has also been assessed for quality, details the initial lessons and recommends any further action required

• Event analysis - within 30 days an analysis is completed (65 days for a root cause analysis), and further actions are added, if necessary

• At the same time, sites can report follow-ups, actions taken, and discussions between experts, in the form of chats, photos or documents via the OLP.

OLP home page

The OLP thus provides straightforward access to the information in a progressive manner, from a single interface. I am impressed with the professionalism of the teams responsible for OPEX in the plants and at corporate level. Together they ensure that deadlines are met and they produce highly instructive material. They are, in fact, applying the principles of OPEX and continuous improvement to their own activities.

I can see that all OPEX is being fed back via this single OLP/AMS channel. Every year, approximately 300 initial briefs, 500 learning briefs, 1,600 simplified and 50 root-cause analyses are produced from 45,000 reported findings.

While promoting the capture of as many findings as possible, EDF Energy continues to prioritise the analyses produced so that the quality and relevance of OPEX is maintained.

CAMELEON project logo

CAMELEON

A future OPEX environment for the DPN, which began in 2014 and led by UNIE, is currently being rolled out on four pilot sites (Tricastin, Blayais, Nogent and Flamanville). It aims to simplify how findings are reported and it will also be available as a smartphone application. This tool will gradually replace all the existing databases, and could also be used by the DIPDE.

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eBriD, for briefing and debriefing

Integrated into CAMELEON, this software is used by work teams to collect and capitalise on OPEX. Using this tool, OPEX can be retrieved at the time work is to be carried out and linked to similar activities managed by the maintenance information system. Users become active participants, adding OPEX to eBriD that they would like to find next time they carry out a task. Searching is simplified by the direct link to maintenance activities. The tool makes pre-job briefing and debriefing easier.

SEARCHING FOR A SEARCH ENGINE

Even when it has been simplified and structured, there is still a substantial volume of OPEX data, and retrieving it is not straightforward. Everyone dreams of having the equivalent of Google for OPEX that would allow users to extract significant information for a given situation using just a few key words.

An OPEX search engine has been developed in France. Its aim is to allow users to find all the documents associated with key words across different databases. I have observed a mixed reaction from end-users. The relevance and sorting of information fed back requires improvement (too many objects, poorly prioritised). Database access rights are also restricting access to some of the suggested documents.

In the UK, the OLP has an integrated search engine. Despite an ongoing push to simplify, multiple sorting is sometimes complex. If necessary, it is easy to call the local OPEX team who will perform the search for you and set up a customised filter which can be reused later. Consideration is underway on how the search engine can be enhanced to be more akin to the tools used on the internet.

EDF R&D may also be able to provide a solution based on its work on big data. In fact, new digital processing, with its capacity to cross-reference physical values, report texts, video images, etc. over long periods of time, is opening up many possibilities. Some solutions, already being tested with users, can be applied to sort large amounts of data very quickly and format it to suit end-user needs.

eBRiD project logo

MY RECOMMENDATION

Although implementing OPEX, which is essential to nuclear safety, is simple in principle, the volume of data involved makes it complex. Work is needed to simplify OPEX documentation and to make it more informative. I recommend that the Directors of the DPNT and the DIPNN jointly re-orientate the development of an OPEX information system, drawing on EDF Energy’s experience.

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OPERATIONS FUNDAMENTALS TO BE REAFFIRMED

Control room: the centre of operations

A nuclear power plant is highly automated. The quality of monitoring carried out by the operations teams, both in the control room and in the plant, is therefore fundamental for nuclear safety.

Renewal of the workforce must be accompanied by the re-incorporation of the operations fundamentals: nuclear safety requirements, organisation and leadership appropriate to the role. This should be done from plant level right through to senior management.

Digitalisation provides an opportunity to improve the quality and efficiency of operations, but care must be taken to avoid drifting from the fundamentals.

The operations teams play a key role in compliance with the plant operating rules, essential for the nuclear safety of reactors. They are especially responsible as they are in the front line in the event of an accident. They also play an important role in the success of both in-service and outage unit projects during the preparation and work phases. That is why, during my visits, I systematically try to assess the robustness of the operations profession, to monitor how it is adapting to organisational changes or digital tools, and to check that it is maintaining its position at the centre of plant production.

FUNDAMENTAL REQUIREMENTS CLEARLY DEFINEDOver a number of years, I have seen a desire to clarify and simplify operating standards. In France, in the early 2000s, the DPN issued the Operations core skills handbook, which is regularly updated. The 2014 edition clearly explains both the basic principles of the profession and the organisation and leadership associated with it. In the UK, the core skills are covered in a booklet and procedures; in particular, the central position of operations is clear from

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the requirements of key meetings where there is always a focus on operations. The reference in both countries is the Significant operating experience report (SOER 2013-1) from WANO, which describes the best international operating practices.

I have seen some interesting approaches which could be shared. In France, the merit of the Operations core skills handbook is that it brings together the fundamentals in a single, straightforward document. I also appreciate the value of the ‘head-up’ monitoring associated with the control room supervisor role. Some sites use an armband to easily identify the person responsible in the control room, as well as a timer to ensure this panel and display monitoring is carried out at the required frequency. In the UK, I am impressed by the flexibility of the organisation. The operations teams do not hesitate to adopt a 5-team rather than a 6-team shift pattern during the night, at weekends or during unit outages, to limit replacements and the associated fatigue. In addition, one person can carry out various jobs within a shift team, as long as they have the required authorisations. A control room supervisor may therefore stand in for a shift manager or an operator.

1 Carefully monitor the parameters and state of

the plant

2 Manage plant configuration changes

3 Adopt a conservative

approach to unit operation

4 Work efficiently together 5Clearly

understand how the units are designed

and how the systems interact

Operations requirements in France

OPERATIONAL QUALITY TO BE EMBEDDED

In 2017 as in 2016, I noted an improvement in the main nuclear safety indicators for operations, in particular with regard to reactor trips in both France and the UK. Noticeable progress has also been made on conformance with technical specifications, especially in the UK. In my view, these improvements are down to the tight control of these areas, the implementation of international best practices, and collaboration between the two fleets.

These improvements should not overshadow the weak signals and disparities between the results on different sites:

• In France, the number of operational non-conformances has not decreased for five years (see inset)

• There are still too many alignment errors in France despite the action plan that was initiated, whereas the situation in the UK has improved

• The outage durations for maintenance or refuelling are slipping, although operations is not solely responsible for this

• There are still some weaknesses in fire prevention (interim storage of combustibles and oil leaks).

Despite the efforts made, there is still some way to go. The requirements are clear and the owners known, but action must be taken to embed results. The answers can be found in SOER 2013-1 in the section on the key to long-term sustainability. It deals with embedding the application and support of the fundamentals in the processes, procedures and indicators. This is particularly true for the use of human performance tools for nuclear safety. I believe that more time should be spent at plant level coaching staff on the fundamentals (see Chapter 5).

Some operational non-conformances

Following scheduled maintenance work on the demineralised water system at a site, the system was put back into service. A drain valve was left partly open, resulting in water spilling through to the level below. Several items of equipment, including nuclear safety components, were soaked, fortunately with no adverse consequences. The valve had not been closed correctly and was jammed by a link of isolation chain, without the operator noticing.On another site, an automatic reactor trip occurred during power raise after a scheduled outage. Both the operator and the supervisor had forgotten to confirm an authorisation allowing them to increase the reactor power, as required in the procedure. This risk had already been clearly identified and shared in advance of the operation.In both cases, strict application of the human performance tools (self-checking, time-out, peer-checking, pre-job briefing) would have prevented the error.

AN ONGOING DIFFICULT SITUATION FOR SKILLSIn France, I note disparities in filling the jobs defined by the Operations core skills handbook. An example is that of control room supervisors: not all of the positions have been filled on some sites. More specifically the situation exists with the following posts:

• Shift managers: recruitment has been completed, sometimes with people that need additional time to gain more experience

• Deputy shift managers: the concern is not so much recruitment but positioning in the new job, as some recruits are still too focused on the control room and not enough on work week and outage projects

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• Control room supervisors, for whom supervisor training should be made standard

• Operators who become control room supervisors too early due to the need to fill gaps

• Operating technicians who lack some experience because too many of them have left to become operators

• Operations plant engineers whose enhanced role requires them to take on a broader range of activities (isolation, supervising plant technicians, coordinating industrial safety) and to monitor new training in the context of multi-unit accidents.

Training should be accelerated and staff supported. I note that a work programme has been put in place at corporate level to meet the timescales for the deployment of the organisational modifications from the Fukushima OPEX.

In the UK, the AGR situation does not pose any problems. The operations organisations are stable. Post-Fukushima changes have been limited by the high degree of inertia inherent to this type of reactor, and by the fact that the sites only have two twinned reactors (a single control room). In addition, the flexibility of the organisation means that recruitment can be easily adjusted to address events. This, however is not the case at Sizewell B where a number of operators were recruited by another PWR operator - a newcomer to the nuclear industry working in English. Action was quickly taken to deal with this situation, which could happen again.

Control on the plant

A CENTRAL ROLE TO BE MAINTAINED

Operations must be placed at the centre of the organisation. To do this, the shift teams, which have an ongoing 24/7 responsibility, must have the attention and support of the whole site, in particular for in-service and outage unit projects. Operations must also be fully committed to this central role, through the example it sets in delivering operational results and ensuring that the fundamentals are implemented. I noted a generally satisfactory situation during my visits. There are, however, too many disparities between the French sites.

In France and the UK, shift managers are given a central role in the daily operations meetings, although I occasionally see some who are too reserved and would benefit from some coaching by their manager. I have been impressed by the practice in the UK where the shift

manager is in direct contact with the wider corporate management, through a dial-up audio message recorded each morning detailing the plant’s daily schedule and operating risks.

I note, in both France and the UK, that there are shortfalls in staff seconded to support work week activities. This point does not currently affect performance levels (backlogs, control room errors, etc.) due in part to the work of the teams responsible for dealing with emergent issues (response team in France, Diagnostic and repair team (DART) in the UK). I will, however, be monitoring this situation.

Conversely, outage teams are well-resourced with operations skills. The position of the shift teams is well-established here, particularly during the outage and start-up phases. Despite demanding outage schedules, management clearly demonstrates the priority given to nuclear safety, demanding that teams take the time needed to carry out high-quality work. This message is nevertheless coming up against two obstacles: the desire to get everything finished by the end of a shift and above all insufficient use of the human performance tools.

Operations training

THE BENEFITS OF AN INTEGRATED COORDINATION OF OPERATIONSIn the UK, I am pleased with the effective corporate-level governance by the Fleet manager responsible for operations. He organises monthly Peer group meetings for operations managers. Each meeting is sponsored1 by a plant director. The meetings cover performance management and implementation of operator fundamentals (governance, leadership, etc.). During the meetings, plants are challenged (actions, indicators, etc.) and they can be quickly offered assistance. The meetings report to the corporate Operations delivery team (OPDT) which consists of all the plant directors and is led by one of them. This team challenges the Peer group and makes decisions on issues proposed to it by the Peer group. In addition, the operations manager at each plant leads a local OPDT, which has strong links with the corporate OPDT. The various groups work closely together, meeting

1 The sponsor attends the meetings but does not lead them. The sponsor challenges and coaches the group, as well as being the link with the corporate Operations delivery team (OPDT) and other plant directors

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monthly to discuss operational matters, operating results and progress on the delivery of the operations transition plan.

In France, the Skills advisory centre for organisational effectiveness (PCC-EO, see Chapter 5) leads the operations profession. Three to four Operations manager meetings are held each year, which are attended by an average of 75% of all sites. Information is fed back to the Operations directors and the DPN’s Deputy Director responsible for resources. Supervision of operations (results, indicators, etc.) is the responsibility of the Production Director on the production committee. There is a weakness in the link between leadership of the function and site operations. I see this as a cause of the poor overall progress made by sites in implementing the Operations core skills.

Crew performance observation

This activity, developed by WANO, consists of in-depth individual and collective observation of operations teams on simulators. The purpose of this assessment, carried out by experienced peers, is to assess the ability of teams to deal collectively with normal and accident conditions. This process has already been successfully applied to the Taishan and Flamanville 3 EPRs. It has confirmed the ability of the teams, who are still new, to confidently take over their future work scope. WANO is to extend the use of CPOs to operating sites in the context of Peer reviews, which also help to ensure compliance with the requirements recommended by SOER 2013-1.

DIGITALISATION SUPPORTING THE FUNDAMENTALSThe operations profession is becoming increasingly complex: more requirements than ever before and more equipment to operate. There is also a much greater volume of OPEX. This is instructive and can make up for a lack of experience as long as it is made available to staff in the right way (see Chapter 6).

I have seen digitalisation work carried out to provide operations staff with tools to meet these requirements and improve operational quality. For instance, I have noted the following:

• In France, the COLIMO project simplifies and improves the safety of plant isolations. This is an example of a project managed both for and with plant staff. It links in to existing tools and is easy to access by smartphone or tablet. It also provides e-service counters to improve the issuing of work permits to contract partners

• The trial use of tablets in the field to support plant monitoring

• A similar approach for control room operators • In the UK, the Organisational learning portal (OLP),

for practical access to OPEX (see Chapter 6).

The SEPTEN in France has developed the ANTARES animation to quickly test and check instructions in the event of accidents (Chapter VI of the General operating rules) and to substantially reduce the engineering workload.

EDF R&D is also heavily involved in this field. In the context of its work programme called Nuclear plant of the future, it is providing several building blocks to assist operations:

• Control support through 3D calculation of the effects of core poisoning due to fission products

• Technical specifications compliance support for operations managers and nuclear safety engineers

• 3D simulator training for operating technicians, particularly for alignment operations.

During discussions with the operations teams, I noted a considerable desire to see the widespread introduction of such tools, and would suggest an acceleration of their implementation.

Using a tablet for plant activities

MY RECOMMENDATIONS

Based on the OPEX from Fukushima, the DPN decided to strengthen the operations roles and to implement associated qualification and experience processes. I encourage the Director of the DPN to complete this work, paying particular attention to the development of the skills of those concerned.

Both in France and in the UK, there are still weak signals concerning operational quality. I urge the directors of both fleets to embed the application of the operations fundamentals more firmly in the processes and the indicators.

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IMPORTANCE OF WORKING CLOSELY WITH CONTRACT PARTNERS

Contract partners carrying out a test in a controlled area

The quality of maintenance is in large part assured by contract partners and is essential to nuclear safety.

Strong ties between EDF and its contractor partners allow for a more effective sharing of objectives and methods favourable to quality.

Like EDF, contract partners are faced with the issue of staff renewal and must take a proactive approach to transferring skills.

INTEGRATE TO WORK BETTER TOGETHER

I often meet with contractor staff during my visits and I notice that the general feelings and attitudes in the plants tend to differ between France and the UK. In both cases, staff feel they can express their opinions freely. While it takes on a positive and constructive form in the UK, it tends to be more critical and dissenting in France. This can also be perceived in the manner in which EDF SA staff act towards contractors.

Two main factors seem to explain the British circumstances: a ‘one team’ approach that fosters integration, and clear contractual arrangements that focus on technical issues.

EMULATING THE ‘ONE TEAM’ SPIRIT…In the UK, it is difficult to distinguish between EDF and contractor staff during a meeting. Beyond wearing the same overalls, their level of involvement is also the same. Contractor staff tend to hold considerable influence

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in most processes within their remit. During my visits, I noted that British contract staff systematically referred to the site results, reflecting well on their ownership.

Management apply the same leadership principles since they train together with their EDF Energy counterparts. They play a key role in teams, which helps to develop an identical value system while encouraging dialogue and better understanding of respective viewpoints.

They are strongly engaged in the site management groups, including at a high level in some instances, e.g. daily operational meetings with the site management. In doing so, they positively assert their roles, recommend solutions and make useful contributions to the results. They are also closely involved in in-service and outage unit projects, especially during preparation.

They are equally engaged in site initiatives (industrial safety, radiation protection, etc.) in their early stages, which is useful for organising any training, communication and inter-company information-sharing that may be necessary. In way of continuous improvement, they take part in CAP meetings and analysis, and their views are taken seriously.

Without being as systematic as in the UK, many of these approaches are also implemented in France, where I observed some promising practices:

• Tri-party agreements between operations, engineering and contract partners, which embed contractor staff in deploying the solutions from an early stage

• Close working arrangements that help everyone to focus on the same objectives, to share the same tools - and even the same offices – and to simplify interfaces

• Creation of business associations run by a contract partner on challenging areas to optimise coordination.

… BY CREATING A FAVOURABLE ENVIRONMENTIn the UK, most contract partners have been operating on the same site for many years and are confident that their contract will be renewed. There are several reasons for this.

Sites with different levels of responsibility - A supply chain team responsible for purchasing, industrial policy, and spares can be found on each site. It maintains dialogue with both the operational departments and the contract partners to provide clarification on the technical aspects of contracts. These open discussions cover a diverse range of topics, whether volumes, risk taking or margins. Such technical cooperation is crucial. EDF Energy’s central supply chain function federates, coordinates and supports the local supply chain teams. They work in close collaboration and the sites take more responsibility than those of EDF SA.

Owing to the size of EDF SA, its purchasing policy is centralised. Its client-supplier relations tend to be

conventional and based on flat-rate service agreements. The financial advantage is obvious since it promotes bulk procurement which is conducive to cost reductions, but this approach is somewhat removed from the reality in the field. I wonder if it would not be more appropriate to reach a balance that reflects each activity. Is it wise to consider a facility cleaning contract in the same way as the purchasing of heavy components to be dispatched to many sites?

Knowledge of margins - Suppliers in the UK have no issue with sharing information on their margins (value, variations in relation to the workload or the risk involved, manpower, etc.) They often figure in the contract. By dissociating the financial and technical aspects, suppliers are given the assurance needed to focus on their services and their contribution to performance. This does not prevent the client from conducting serious negotiations and strict expenditure control on a regular basis. During discussions in France, suppliers refuse to discuss the financial aspects openly, especially if this requires divulging their margins. To explain their refusal, they often cite feelings of distrust with respect to how this information will be used.

Working together

Contract partners involved in site results - By evolving their methods and sometimes those of the client, suppliers in the UK no longer think twice about suggesting solutions to improve the site’s performance in terms of quality, industrial safety and cost benefit. In France, an increasing proportion of contracts now include bonus-penalty clauses tied to the results. More recently, the progressive implementation of ‘productivity partnerships’ is paving the way to open discussions on shared financial gains.

Greater visibility for contract partners in the longer term - In the UK and France alike, contracts are reissued approximately every five years, but suppliers in the UK are more than often renewed when their services are good quality and reasonably priced. This decision-making process is simplified when the margins are clearly stated. This is conducive to building long-term relations reflecting the ‘one team’ spirit. In France, suppliers frequently change sites when contracts are being renewed, most of which are based on bulk procurement. The quality of services (best bidder) does not carry enough weight with

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respect to the criteria used to select tenders, and deserves more attention in the purchasing process. To give contract partners sufficient visibility to adapt their skills to the expected workloads, the DPNT holds a meeting every year to explain their global needs and schedule of activities, especially for the Fleet upgrade programme. This approach does not however provide the same degree of visibility on a local level as in the UK.

In short, it is not straightforward to compare the cost pros and cons of the British model against those of the French. This is due to different laws, coupled with the contrasting sizes and characteristics of the two fleets. I note, however, the positive impact of practices in the UK that simplify contractor involvement in a way that is favourable to results, especially in nuclear safety. I believe a balance could be found in France to better manage costs along with building up contractor confidence in the long term. Within this context, I have seen promising changes in the purchasing policy: review of the general terms and conditions of purchase, innovative contracting procedures, updating of tender selection criteria, etc.

I noted that the DIPNN is in the process of setting up the Industrial department which will be responsible for industrial policy. This is an opportunity to align the different industrial policies and to clarify the interfaces between the functions involved in contractor qualification, assessment and inspection. I recommend taking advantage of the new Industrial department to extend the limits of contractor partnerships within industrial policy and purchasing.

Craft training centre

MAINTAINING SKILLS: A JOINT COMMITMENTIn France, contract partners and EDF alike are seeing large numbers of staff leave on retirement while their workforce gets younger. Recruitment, training and knowledge transfers are therefore important processes in light of the increasing level of activity, particularly with the Fleet upgrade programme.

I commend the proactive approach at EDF to challenge and support contract partners by giving them greater visibility of the workload ahead and by carrying out joint actions in education to simplify recruitment. I was, however, told that resources were stretched in certain areas, e.g. valves

and pipework in plants, and more recently, electricians on the Flamanville 3 construction site.

Mobile training for greater coverage

SPIE Nucléaire has deployed a mobile training unit that focuses on three key risks: working at height, electrical hazards and road accidents. Offering theoretical and simulator-based training courses, this set-up is able to reach a wide audience because it can travel to the sites where the training demand is expressed. Regularly called in by the plants, this mobile training unit also helps to create and spread a common safety culture.

Some large companies are making an effort to invest in training through the creation of craft training centres. I was able to visit the centre run by SPIE Nucléaire in 2017 where it trains staff in the fields of safety (see inset), welding, valves, pipework, electricity, instrumentation, operations support, etc. Based on a pragmatic approach, it offers some tools targeted at workers that share good practices, especially in the area of human performance tools.

Contractor associations, which also include smaller companies, have reorganised their craft training centres and streamlined their courses with the help of EDF SA to better adapt the training content to the needs.

I also commend the use of digital educational tools that quickly capture and hold the attention of the younger generation:

• Online community platform called EUREKA run by EDF SA, which provides a network for information-sharing between contract partners and now boasts more than 3,500 members

• Tablets used for pre-job briefing, which include photos and can be taken with staff wherever they go

• Smart eyewear to record video footage during complex operations that can be used in training courses

• E-learning courses, particularly on human performance tools.

Encouraging progress has been made in developing synergies between the sites and contract partners through the creation of mock-ups and craft training centres. A little more effort is required to reach an optimal utilisation.

SIMPLIFYING AND CLARIFYING REQUIREMENTS AT EDF SADuring my discussions with contract partners, their frustrations with the requirements were clear as they find them too complicated, often disparate between divisions, and diverging from current industrial practices. They

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often discern considerable differences between EDF SA and their other clients. These problems exist on several levels.

First, despite considerable efforts to harmonise requirements, differences still emerge between sites when it comes to applying them. Second, the training requirements are not always well-suited. A valve technician mentioned a qualifying training course on bolted flange joint assemblies where an excessive number of points needed checking.

Third, the contract partner qualification process is also considered complicated, which can dampen the ambitions of those wishing to work in the nuclear sector. I note the work undertaken by the Central technical support unit (UTO) to simplify this and to encourage new entrants into the field.

Finally, the harshest criticism is reserved for technical and administrative clauses in contracts. Excessive in number and sometimes contradictory, they need to be simplified for contractors, EDF contract managers and inspectors alike, who are all required to comply with them.

Using smart eyewear

This is a recurrent need: in the early 2000s, the ECOREP approach was deployed to simplify EDF’s technical specifications. This work was resumed a couple of years ago by the Technical standards committee (CRT), this time including industry partners in an attempt to harmonise with common industrial practices. I note that the Thermal plant engineering department has already adopted a similar simplification process that will be beneficial to the nuclear fleet. This extensive task is of great importance to the quality of work and should be seen through to completion.

IMPROVING EDF SA SURVEILLANCE

Relations between EDF and its contractors that are built on trust are conducive to quality, yet it is important to make sure the responsibilities of each are clear. This is particularly true for the operator for whom surveillance is fundamental: trust can only be strengthened through a suitable system of surveillance.

ADAPTING SURVEILLANCE TO MANUFACTURINGBased on the lessons learned from the reactor building crane bracket defects at Flamanville 3 in 2012, EDF completely overhauled its surveillance of manufacturing.

The responsibilities and remit of the Expertise & inspection department for manufacturing & operation (CEIDRE) were clarified, with their skills and coordination duties consolidated.

Following the marked/ unmarked files (see Chapter 1), the CEIDRE has extended its arrangements to include random visits to manufacturing sites, sample taking and counter-testing. These measures also set out to prevent and detect any counterfeits. It is important that the scope of such checks be progressively extended to include second-tier suppliers.

These changes are a step in the right direction. Aware of the possible resistance to such checks, whether from the suppliers or the project functions, I will be observing if they are supported by all stakeholders.

FRESH IMPETUS FOR SURVEILLANCE ON THE PLANTSSurveillance is carried out by about 500 qualified officers. They are generally satisfied with their training, even if some would prefer a few more practical exercises. They are coordinated by local managers, who are themselves supervised by a national manager from the Skills advisory centre for organisational effectiveness (PCC-EO).

I note, however, the following actions for improvement:

• Facilitating their presence in the field by relieving them of their administrative duties and by making sure their surveillance better reflects the progress of activities underway

• Consolidating their technical experience by offering stronger managerial support (see inset).

I encourage management to become more involved so surveillance officers can gain more confidence in their rapport with contractors.

Sub-standard quality during a sub-contracted activity

One of the reactor safety injection pumps was programmed for replacement during a planned maintenance outage. During the pump rebuild, a rubber seal several tens of centimetres in diameter fell into the system, which went unnoticed by the work team. A drop in the flow rate was then observed during testing prior to recommissioning. The system was reopened and the problem was discovered. The event did not impact nuclear safety since the reactor was shut down but it disrupted the site’s organisation, introducing a schedule delay of 18 days. The task had been allocated to an experienced contract partner and clearly identified as an operation with safety implications. This sub-standard quality revealed a failure to use human performance tools (self-checking, peer-checking and time-out). This error was also not detected by EDF during surveillance.

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UPDATING THE CONTRACTOR ASSESSMENT PROCEDUREUTO evaluates contractors on the basis of contractor assessment sheets filled in by the plants and other functions. It organises an audit if any issues arise and it can decide to step up its surveillance of any contractor if necessary. This affects about forty contractor companies every year.

Surveillance in the field

Contractors can be critical of this evaluation process which is criteria-based and thus deemed ill-suited because it fails to take into consideration any difficulties and efforts made. They believe it to be overly bureaucratic and centred on applying penalties rather than focusing on achieving a successful outcome together.

The sheets are often late in being issued and their quality is variable. I note that the electronic version should improve response times and simplify formalisation of these assessment sheets.

The contractor assessment approach appears relevant, but its implementation needs to be optimised because UTO and the sites are still striving to converge on a common vision. I encourage UTO to continue its efforts in convincing the sites of the added-value of this process, and the sites to commit to improving the quality and responsiveness of the evaluation sheets.

MY RECOMMENDATIONS

Relations between EDF and its contract partners must focus on the quality of work and be based on mutual trust. I recommend that the Directors of the DIPNN and the DPNT take advantage of the new Industrial department to extend the limits of contractor partnerships to include industrial policy and purchasing.

A trusting partnership does not exclude surveillance. I recommend that the Director of the DIPNN continue improving the effectiveness of its surveillance system for manufacturing, and that the Director of the DPNT enhance the surveillance of work on the plants.

Over time, specifications have drifted from current industrial practices. I recommend that the Director of the DIPNN, supported by the DPNT, follow through with the simplification of documentation under the leadership of the Technical standards committee.

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ENGINEERING SUPPORT FOR THE FRENCH FLEET AND NEW-BUILD PROJECTS

Hinkley Point C construction site

Nuclear safety in the fleet or for new-build is particularly reliant on a strong engineering capability.

Aware of the challenges ahead, the engineering divisions are pursuing their restructuring to improve effectiveness and quality, notably through the creation of EDVANCE.

These changes will contribute to the success of the Fleet upgrade programme and the EPR which are major projects for the Group.

GOOD PRACTICES IN SUPPORT OF NUCLEAR SAFETYFor several years now I have been pleased to observe the development of engineering tools and methods to improve team effectiveness and design quality. Most of these practices have emerged from the Group’s project management policy. This has been incorporated into the transformation of the divisions affected.

CONSOLIDATING PROJECT MANAGEMENTMost projects now benefit from more robust planning, empowering those involved and bringing them closer

together. Identified risks are better managed by the teams who can now focus on meeting objectives with confidence.

A technical and economic analysis led to reviewing options and to targeting the engineering resources to produce a solution tailored to the exact requirements. I saw the benefits of this initiative when the SEPTEN updated the EDF standards on tornado impact, when the CNEPE re-engineered the local emergency response centres, and when the DIPDE recommended the withdrawal of certain modifications under the fourth 10-yearly inspection outages for the 900 MW reactors.

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In preparation for 10-yearly inspection outages and new-build projects, the needs of end-customers should be well defined, with close communication between the designer and the operator, to avoid costly, time-consuming repeat work.

BROADER CROSS-FUNCTIONAL WORKINGBy working in an integrated team or extended enterprise including contractors, interface management is simplified and work practices are consistent. In this context, I was shown the work execution centres for the design of post-Fukushima ultimate emergency diesel generators at the DIPDE and for the local emergency response centres. I was also introduced to the integrated teams set up for Hinkley Point C. These offices centralise staff from EDF SA, EDF Energy, AREVA NP, design offices and construction contractors. The effectiveness of such an approach is clearly visible. It is, however, important to make sure interfaces between teams on the same project are managed effectively and that the core skills of seconded staff are regularly updated.

Integrated team

The DIPDE explained its arrangements to me on the design of modifications to the nuclear island, where an engineer is appointed to manage design integration in conjunction with designers from different fields. This approach seems promising as it sets out to achieve a greater level of design consistency.

Once fully deployed, methods such as system engineering1 coupled with high-performance tools (digital mock-ups, 3D/4D software for Hinkley Point C, plant lifecycle management, etc.) will enable gains in efficiency and quality. I will follow up on their implementation.

ONGOING EXPERIENCE-SHARING Comparing of practices can encourage progress, for example when the Thermal plant engineering department supports the nuclear divisions. It is the same when an engineering division working for several clients (operational fleet and new build) uses its different experience to improve effectiveness and quality. This is also true for Franco-British collaborations which can be beneficial to both parties. For instance, meetings 1 A multi-disciplinary approach based on a breakdown into

sub-products and covering the whole lifecycle for improved traceability of requirements

organised in 2017 between the Design authorities (see Chapter 3) enabled collective progress. I believe such collaboration should be intensified.

ENGINEERING IN SUPPORT OF PLANTS IN SERVICETHE FLEET UPGRADE PROGRAMME PLAYS A PIVOTAL ROLEThe programme brings together a total of 22 projects devoted to extending the service life of the fleet and implementing post-Fukushima changes. Led by a tight-knit team, the programme is recognised by all stakeholders for its core project management role.

Its interfaces with project management via the DPN (owner), as well as those with the engineering divisions and the Design authority for the fleet, are at the right level. Relations between project leaders and the Fleet upgrade programme management are now running smoothly, though room for improvement remains with their fellow engineering functions.

Relations with the ASN have improved. A set of standardised indicators are now used to manage sensitive issues, and regular meetings are organised at various levels covered by an escalation process.

The Fleet upgrade programme relies on a set of management methods that demand a high level of standardisation across the plants: work plans, risk identity cards, multi-year modification programme, greater collaboration with contractors, etc. For example, the allocation of modifications between different outages has been optimised to meet the planned outage durations, and cost-benefit analyses have challenged design changes that may have already been implemented in some reactors.

Ultimate emergency diesel generator at Civaux

This results in differences being introduced into plants in the same reactor series. I would like to stress the importance of controlling configuration changes and maintaining consistency in modification packages.

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BETTER INTEGRATION OF SITE JOINT PROJECT TEAMSThese teams composed of staff from engineering and operations are responsible for implementing modifications in the French plants. It is clear that their clients (the plants) are increasingly pleased with their work. I nonetheless encourage site management to push for better integration of these teams, because still too often, they are physically isolated or insufficiently included in projects and daily life at the plant to which they have been assigned.

The staff in site joint project teams are generally young and enthusiastic, with most going through some form of qualification and experience process. The team numbers and inter-site support staff have been increased to prepare for the first outages of the Fleet upgrade programme. This increase will continue to cover the peak workload expected in 2018-2020 (see Chapter 5).

A proportion of the teams work for the DIPDE while the rest work for the CNEPE, with cross-functional coordination: the Construction engineering committee chaired by the DIPDE Director is responsible for joint management; the Quality manual - updated and simplified in June 2017 - is applied by all the site joint project teams; the peer groups are productive. I will look closely at this arrangement to confirm that it compensates for any tendency in the teams to work differently, being in two different divisions.

Taishan nuclear power plant

PROACTIVE SUPPORT FOR THE FLEETIn France, the engineering units at the DPNT and the DIPNN strongly support the plants on high risk projects or task forces for event recovery. This is illustrated by: UTO’s contribution to resolving complex issues (e.g. sleeving of steam generator tubes at Gravelines 5), and the task force with staff from the SEPTEN, CEIDRE, UNIE and the DIPDE assigned to the carbon segregation issue.

Yet due to the number of issues to be handled simultaneously, the DPN’s corporate departments are struggling to provide sufficient support alongside the plants, to complete significant actions, and to support cultural changes.

In the UK, I noticed that the corporate teams are closely involved in providing support to the sites in need. The sites are considered as clients and the corporate teams are expected to provide their services until the anticipated results are achieved.

EPR PROJECTS

EPR milestones reached in 2017

• Taishan: the hot functional tests were started in April 2017 and the first fuel element was introduced into the fuel building’s storage pond in October.

• Flamanville 3: the cold functional tests ended in December 2017, followed by the successful completion of the hydrostatic test on the primary system in January 2018.

• Hinkley Point C: the first nuclear safety concrete for the galleries was poured in March 2017.

• EPR 2: the configuration for the next design phase was selected in October 2017.

TAISHAN: FIRST-IN-SERIESThe satisfactory outcome of the hot functional tests has instilled greater confidence in the design of the plant and the preservation of equipment. Almost 160 operations staff have been integrated into the test teams, thus giving them the time to become familiar with the plant.

During my visit in October, the fuel storage building for reactor 1 was ready to receive the first fuel assemblies. In other areas, the last modifications remain to be completed, along with finishing and cleaning in some rooms. I noted that the project management had placed great emphasis on avoiding foreign material risks and fire hazards.

The actions underway to prepare for operations are generating confidence, as confirmed by external assessments: pre-OSART review by the IAEA in January 2017 and the CPO follow-up by WANO (see Chapter 7) in September 2017. Assessments will continue through 2018 with a joint visit by the nuclear inspectorates from CGN and the DPN following start-up of the first reactor.

As in 2016, I am impressed with the pragmatic approach of the teams and their ability to incorporate OPEX from other CGN sites. The support provided by EDF seconded staff (about 50 people) continues to be useful and appreciated. I encourage further discussions on the form of this collaboration after the start-up.

Collaboration between the professions is also ongoing with other projects, i.e. Flamanville 3, Olkiluoto 3 and Hinkley Point C. Beyond these fruitful exchanges, I would like to stress the importance of having well-organised OPEX from other EPRs available for new nuclear build, such as Hinkley Point C (see Chapter 6).

A TIGHT SCHEDULE FOR FLAMANVILLE 3Some major milestones were also achieved at Flamanville 3 in 2017 (see inset).

Despite the high number of people involved, housekeeping is satisfactory. Nevertheless, I am sorry to

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see the deterioration in industrial safety results in 2017 (see Chapter 4). At a time when assembly and testing activities are being carried out simultaneously, there is a greater need for vigilance with respect to critical tasks, particularly for plant isolations.

I noted that many activities are being run concurrently in the same areas on site. I urge everyone to learn from this OPEX for future projects, since coordinating activities is one of EDF’s key considerations for guaranteeing construction quality. I cannot stress enough how important it is to have managers from both EDF and contract partners in the field.

After the hydrostatic test at Flamanville 3

The first tests were completed satisfactorily. The cold functional tests started in December as planned and were completed successfully in January 2018 with the hydrostatic testing of the primary cooling system. Cooperation between construction site teams and operations staff is improving and I hope this positive trend will continue. However, the design freeze, eliminating outstanding defects and ensuring that systems are installed and handed over to the operator at a satisfactory pace remain challenging. The qualification records for equipment under accident conditions are not yet complete. A number of licensing documents are still being examined by the ASN and IRSN.

The plant is gearing up for the start of operations; preparations are ongoing to train the teams, secure spares (see Chapter 10) and pool certain activities with Flamanville 1 and 2.

I recognise the tight control of this project and the high degree of commitment demonstrated by EDF and contractors alike. Despite increasing pressure to deliver on time, I am pleased to see that nuclear safety remains the top priority for the teams.

AN ENCOURAGING START AT THE HINKLEY POINT C SITENew project governance has been put in place at Hinkley Point C taking into account findings from a number of reviews and audits. This should help to optimise roles,

clarify responsibilities and reinforce confidence in the relationship with the ONR.

The newly created position of Technical director is particularly significant, as it does have a cross-organisational role. It includes responsibilities in quality control and design assurance and acceptance. The Technical director coordinates the major technical decisions in conjunction with the Engineering director. Six Programme directors now also report directly to the HPC Managing director, which underlines their central role in the project.

Yet interaction remains complex between HPC project management and the engineering divisions which comprises the Responsible designer1. In addition to the promising developments underway, I have high hopes that the benefits offered by EDVANCE (see inset) will simplify these work processes, enhance design quality and boost team morale.

When I visited the construction site where some 2,500 people work, including several from CGN, I was struck by the extent to which the organisation, safety culture and quality controls were already in place and aligned with WANO’s ten traits. All of this goes a long way towards instilling confidence in the project’s future success.

3D concrete reinforcement modelling

Other areas of improvement in efficiency and quality were also demonstrated to me; the 3D modelling of concrete reinforcement which will eventually replace printed plans; the high degree of interaction between command centres2 (in France, in Bristol and at Hinkley Point) supported by the use of modern communication tools; the pre-construction planning aligned with sub-contractors; and the 4D tools which add a time dimension to the 3D model of the plant. I will be particularly interested to see how these promising methods progress in 2018.

CLEAR DESIGN OPTIONS FOR EPR 2As part of the preparations to renew the reactor fleet, teams at EDF and AREVA NP carried out studies in 2017 to optimise the EPR design. The decision was made at the end of October 2017 to continue the studies based on a technical configuration known as EPR 2.

The reactor power in the chosen solution is the same as at Taishan. The EPR 2 will ensure good implementation of initial feedback from the ASN following publication of the nuclear safety report for the EPR NM. EPR 2 can take full 1 Engineering divisions responsible for design2 Command centres for the various project contributors

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advantage of the studies already conducted to improve constructability and to facilitate standardisation of the EPR NM. This all helps to reduce the risks involved.

The engineering methods already used should help to control the project configuration. However, care needs to be taken to make sure the proposed software tool changes do not disrupt the progress or impair the quality of ongoing designs which are still subject to strong schedule pressure.

Teams working in the joint EDF-AREVA NP office are part of EDVANCE (see inset). Drawing on their combined experience from design and, for some, from the Flamanville and Olkiluoto work sites, will help to secure the success of the project.

The same can also be said of involving contractors from the outset of this phase; civil engineers have been seconded to the team and an extended enterprise has been set up between the CNEPE and the manufacturer responsible for the turbine generator design.

As in previous years, I note that there has been sound project governance and I urge the DPN to maintain its involvement in the decision-making process and daily activities of the teams.

THE CREATION OF EDVANCE

EDF SA and AREVA NP have joined forces to form a new company, EDVANCE (see inset), to tackle key issues impacting the French nuclear industry: ensuring competitiveness, delivering successful projects, sustaining critical skills, supporting international development and replacing the existing fleet. The EDVANCE leadership team is aiming to develop a common culture to underpin the success of this ambitious programme.

It was clear to me that staff were on board with these changes, but that they also had high expectations for simplification (interfaces, methods and tools) owing to the increasing pressure they feel to increase their productivity. To successfully overcome this challenge, while maintaining the enthusiasm and morale of everyone involved, I recommend a step change in simplifying work in these areas.

EDVANCE

Established in June 2017 as a joint venture between EDF and AREVA NP (with an 80% and 20% share respectively), EDVANCE provides engineering, procurement, construction and commissioning (EPCC) services for engineering of the nuclear island and the command and control system for the Group’s new builds or projects destined for export.Projects are run by EDF or an ad hoc project management company.AREVA NP will use its nuclear reactor manufacturing expertise to design and manufacture the primary cooling system and supply the nuclear safety command and control system with its associated instrumentation.EDVANCE responsibilities cover those activities previously carried out by different engineering divisions (SOFINEL, a major part of CNEN’s activities and some of those previously assigned to SEPTEN, CEIDRE and AREVA NP). New-build projects (EPR 2 plus Hinkley Point C and Flamanville 3) will be progressively transferred to EDVANCE.EDVANCE teams are composed of staff seconded from the parent companies or from partner engineering companies for each project.

Although an improvement in performance is important, this must not be to the detriment of quality which is vital to nuclear safety. I also believe it is important not to lose the know-how of SOFINEL. I urge management at EDVANCE to quickly finalise the organisation of its independent oversight function and the related interfaces with the DIPNN oversight function.

The creation of this subsidiary comes hand in hand with a new organisation for the DIPNN divisions. I believe it is important that EDVANCE and the DIPNN follow through with their restructuring processes in a coherent manner. This is useful in several fields: OPEX, engineering methods, tools, career paths, training, coordination of cross-functional working, etc.

MY RECOMMENDATIONS

The success of Hinkley Point C, which has moved into a new phase, will be secured by an effective organisation and relations based on trust with the ONR. I recommend that the Chief executive officer of EDF Energy and the Director of the DIPNN continue to simplify their decision-making processes and interfaces, particularly between the Project management and the Responsible designers.

EDVANCE carries, on behalf of the future of the nuclear sector, responsibility for overcoming some major challenges that are closely tied to the performance of the engineering functions. I recommend that the Director of the DIPNN pay close attention to:

- Consistency in the transformations being undertaken by EDVANCE and the DIPNN- Flexibility in career paths between EDVANCE and the rest of the Group.

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SPARES: AN AREA FOR GREATER ENGAGEMENT BY OWNERS ON-SITE

Primary pump diffuser

The plant spares organisation is centralised in France where several initiatives launched over the past few years have contributed to an overall satisfactory level of nuclear safety.

Yet this very complex area continues to elicit high levels of dissatisfaction, resulting in a lack of confidence from stakeholders.

In contrast, spares management in the UK is decentralised due to the heterogeneous nature of the fleet.

Plant spares have a specific role to play in system availability. Although nuclear safety has not been seriously impacted by the failure of spares, I have noted a certain degree of difficulty or dissatisfaction in France that merits a better appreciation.

My main focus areas are the organisation, the quality of stores, the technical controls, obsolescence, and the specific issues relating to Flamanville 3.

CENTRALISED MANAGEMENT IN FRANCE

The DPN has a centralised organisation to handle spares because of the size of the French fleet and above all its use of standardised plant technology. The national Central technical support department (UTO) is responsible for general coordination of this organisation, which also includes deployment of the support tools. Hence, most plant spares are stored in national centres (see inset).

10

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The classification used for spares takes into account nuclear safety (see inset) by aiming to achieve optimal availability of all nuclear safety-classified parts (20,000 catalogue items out of a total of 360,000).

Several groups contribute to the supply chain:

• The national logistics agency (ALN) receives, stores and transports parts from the national stores

• Plants are responsible for requesting spares (identifying and reserving them), local storage and returning any items left unused or requiring repair

• The engineering divisions (DIPDE, CNEPE and UNIE) specify the parts to be ordered following modifications; the DIPNN assumes the same role for new projects

• The purchasing division and its local teams are responsible for setting up supply and repair contracts.

The high number of stakeholders involved in this process undoubtedly contributes to the overall sense of complexity perceived on the plants.

Sizewell B stores

DECENTRALISED ORGANISATION IN THE UK

The British fleet comprises a single PWR (Sizewell B) and 14 AGRs which have significant differences. Each site is therefore responsible for managing their own spares, from ordering through to storage. The number of spares is defined jointly by the local engineering and supply chain teams in line with the service life of each reactor. As in France, this analysis is performed on the basis of the 5-year forecast of requirements, procurement lead times and history of use.

Some parts are managed at a national level as they are considered to be strategic due to their cost, the procurement times involved or the impact of a failure on production. The Engineering governance delivery team monitors the risk level and purchasing decisions related to these spares. The team’s decision-making is aided by various ad hoc groups, some of which include suppliers. Most strategic spares for AGRs are stored at Heysham, the remainder being stored on supplier premises.

Classification of plant spares in France

Spares are classified in categories according to their safety level and other applicable requirements. They are itemised in a national spares catalogue which lists all relevant information.The 360,000 catalogue items, corresponding to several million spares, are split between different inventories according to the frequency of consumption and sensitivity in terms of safety or plant availability.National safety inventory has around 10,000 items classified as sensitive for safety or availability. Their use is subject to national approval and they are stored at national stores.Local safety inventory has around 10,000 items classified as sensitive for safety or availability. They are stored on site at individual plants to ensure availability in less than 24 hours.National operational inventory has around 70,000 items that are used frequently and/or needed for the Operations engineering unit maintenance programmes. They are stored at national centres.Local operational inventory has around 10,000 items for frequently used, low-cost spares. They are stored on site at individual plants to reduce transportation requirements and simplify logistics.Made-to-order parts cover around 150,000 items for rarely used spares which have no guaranteed stock levels. They are ordered directly by plants from the UTO. Accurate forecasting is critical for these parts, since procurement lead times can be up to several years.In addition to the categories listed above, there are more than 100,000 inactive items, where local or national stocks are no longer required for various reasons.

QUALITY STORAGE FACILITIES

ON-SITE STORES On-site stores in France and the UK are in good condition and provide satisfactory storage for spares.

Particular attention has been paid in France to electronic components and polymers which are stored in special temperature and humidity-controlled facilities. This is not the case at all EDF Energy sites.

Storage practices and controls are carried out on parts as required - such as regularly turning motors a 1/4 turn.

I am surprised by the rate at which on-site stores in France are filling up, contrary to the objectives laid down for transferring spares to central stores. It appears that some of the national operational inventory is still stored locally instead of nationally. In addition, areas allocated to spares requiring repair are becoming crowded to the extent that one plant had to build a dedicated store.

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THE CENTRAL STORE IN FRANCE The Velaines site is one of the stores for spares in France (see inset). During my visit in 2017 I noticed the significant improvements made since my last visit in 2014; cleanliness and tidiness of the premises and the engagement of the people I met. I was, however, surprised to learn that a new extension to this facility was being built so soon after the initial store opened.

There are other sites, such as Saint-Leu d’Esserent which is used to store heavy components because they can be easily transported by river, and Dieppedalle which is used to store large components with a very low turnover. Several other warehouses are also being leased as temporary stores until the extension to the Velaines facility is complete.

Velaines logistics centre

This centre opened in 2011 and was the culmination of a project set up to improve the management of spares by centralising storage and optimising flows. Around 120 people (EDF staff and contractors) manage a total of 6 million spares, corresponding to 100,000 catalogue items, in a 39,000 m2 facility. They all weigh less than 10 tonnes and do not require any special means of transport. Deliveries are made via:

• A daily shuttle service to each plant • Taxis providing a fast delivery service in exceptional

circumstances• Trucks which deliver the parts required for

maintenance outages.The current extension, due for completion in 2018, will add a further 30,000 m2 of storage for parts despatched from plants and other stores, including Saint-Leu and leased warehouses.

TIGHTER TECHNICAL CONTROLS REQUIRED IN FRANCEHow can teams be sure they are fitting the right parts? This issue arises at the time work is carried out, but the risk of something going wrong starts as soon as an order is placed, which is why diverse arrangements have to be in place to guard against this.

In France and the UK, an initial sample check is conducted in the factory where the parts are manufactured. It continues to be difficult to monitor multi-level sub-contracting activities. Furthermore, I do not believe that these checks are sufficient to prevent the risk of fraud. I will monitor the consolidated arrangements made by the Expertise and inspection department for manufacturing and operations in France.

Each spare in France is checked on arrival at the central store by a warehouse operator with no specific technical skills. This check is limited to its appearance and documentation.

Delivery activities in the Velaines centre

Whether in France or the UK, any spares delivered to individual plants undergo the same checks (visual and documentation) carried out by a warehouse operator. In the UK, however, parts are subsequently quarantined until a full compliance check is carried out by a qualified engineer or technician. I visited a facility that was very well equipped for such compliance checks, complete with earthing mats, electronic inspection equipment, etc. I have only come across this practice at one plant in France.

Once a spare has been handed over to the relevant owner, it has to be checked.

Once work is complete, some spares are returned to the stores. Some of them may not have been used, others only partially, and some may require repairs. The spares are checked again at this stage of the process, prior to their reintegration into local or national stores. In the UK, parts are quarantined and checked systematically by the owner. This is not the case in France. This means faulty parts can clog up the supply chain, only to be detected further down the line. I was made aware of a case of an electronic card which was incorrectly re-integrated into the stores, which was subsequently the cause of an automatic reactor trip. Most defects are detected when they are installed or during tests conducted prior to commissioning, without impacting safety.

ROOM FOR IMPROVEMENT IN OBSOLESCENCE MANAGEMENTObsolescence is a major concern in both fleets.

Increasingly shorter product life cycles mean that the risk of obsolescence is rising steadily. This phenomenon affects all equipment - including valves - when they comprise programmable electronic components. At Flamanville 3, some components (such as electronic cards, organic cables and neutron detectors) are in urgent need of effective obsolescence management strategies.

Several targeted measures have been taken in France to combat this issue, like the operational maintenance contracts negotiated for the instrumentation and control systems for the N4 plants. These measures require a major commitment from EDF’s engineering departments (UTO, UNIE, DIPDE, CNEN, CNEPE) and from R&D. However, the number of different stakeholders involved leads to

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the duplication of efforts and poor clarity in terms of responsibilities, which in turn raises questions about how thoroughly measures are implemented. In my view, the strategy initiated by the DPN to merge and centralise obsolescence management through the UTO is critical to improving this problem.

Obsolescence is a key issue in the UK too, particularly for the AGRs at the end of their service life. EDF Energy has signed contracts with various suppliers to carry on their production lines and maintain skills into the longer term.

There is a need to build a strategic stock of certain spares in both countries.

Visual inspection of a spare

Increasingly tighter regulations in France, especially those imposed by the nuclear pressure equipment regulations, are resulting in longer manufacturing lead times. For instance, the fabrication and qualification lead time for control rod mechanisms may be as long as eight years. These constraints can push some manufacturers into ceasing production of certain parts. Lastly, it can also sometimes delay replacement equipment or force the use of repaired legacy parts instead of new ones.

RESTORING OWNER CONFIDENCE ON FRENCH SITES DISSATISFACTION AT PLANT LEVEL DESPITE REASONABLE RESULTSTeams across the sites are expressing some disappointment with the level of availability and quality of spares. I hear a lot about non-conformances or standard spares being unavailable, which results in lost time and wasted effort. This is driving some plants to reserve more parts than they need from the stores - or even to place orders directly with suppliers - fearing that they will not have the required spares available when they need them. Conversely, the indicators are good and have been improving for several years now, demonstrating no impact on safety and little impact on other performance indicators. The sites also recognise the responsiveness of the teams at Velaines.

In this context there is not a straightforward conclusion as to the best course of action. It appears to me that the way of working and dialogue between parties needs

to evolve to instil greater confidence through a better understanding of the expectations of each party.

IMPROVING UTO COMMUNICATIONS TO THE FLEETTo me, there appears to be a lack of communication between the UTO and the plants, mainly with the technical functions, which creates a knowledge gap relating specifically to:

• Central stores • Organisation of spares management • Basic concepts such as those concerning made-to-

order parts (see inset).

The UTO has launched initiatives to rectify this, including the organisation of visits to the Velaines stores for some site staff. This is a very positive step which should be expanded and supported by relevant training materials.

Another stumbling block is a lack of knowledge of indicators and how to interpret them. The UTO has set up a new, more transparent monitoring system (see inset) to overcome this issue, but it is currently only used by spares engineers. It would be worth sharing it with other affected staff on site.

MAKING TECHNICAL OWNERS MORE ACCOUNTABLEI noticed a lack of accountability at plant level related to spares; requests are often made for more than double the actual requirement, and spares checks in the stores can be infrequent and not always planned ahead. Staff need to be more proactive when updating and checking the spares databases, which, if utilised properly, would help avoid delays in handling urgent requests.

The role of spares logistics managers also tends to vary across sites: plant managers, financial controllers, technical managers, etc. This complicates coordination on a national level and hinders transparency. This may partly explain why the staff directly involved take more of a back seat.

UPDATING THE SPARES DATABASEThe UTO and the plants all agree that the national spares database is of sub-standard quality. There needs to be joint ownership of this legacy issue inherited by the UTO. Currently, the programme to update all 360,000 catalogue items initiated by the UTO is likely to take almost a decade to complete.

Spares management system

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A new monitoring system in France

This information and monitoring system, developed in 2017, is based on a tool common to the plants and the UTO. Performance indicators, such as orders not delivered, demand forecasts and the requirement-to-use ratio, used to be calculated by various divisions. They are now calculated automatically thanks to this tool, which provides access to all the data and clearly describes the methods used to calculate the indicators. It is evolving and will enable improved monitoring of spares procurement contracts in the future.

FLAMANVILLE 3 SPARES: INTEGRATION INTO THE FLEETThere will be very little pooling of spares for this single reactor within the French fleet (currently less than 5% of the 30,000 catalogue items are managed by the UTO).

Pooling with other EPRs, including Hinkley Point C, will also be very limited in light of the differences in design, the use of different suppliers and requirements specific to each country.

The first spares for Flamanville 3 (large components and ongoing consumables) have been identified by the DPN and ordered by the DIPNN. Some of them have already been or will be used for testing. It is essential that the site makes sure that stock levels guarantee sustainable operation.

This stock will be reintegrated into inventories managed by the UTO after start-up. I have been informed of two specific issues:

• Consistency of Flamanville 3 spares identification with that of the national spares database

• The financial impact of this integration on stock management within a restricted budgetary context, without penalising the rest of the fleet.

MY RECOMMENDATIONS

Responsibility for spares is inconsistently distributed across leadership teams in the French fleet. I recommend that the Director of the DPN make sure that those responsible for spares in the site management teams are clearly designated at an appropriate level and they have the same position on all plants.

To limit the risk of spares non-conformance in France, I recommend that the Director of the DPN reinforce the technical controls for all spares reintegrated into plant stores by the site technical owners.

In an environment where equipment obsolescence is increasingly an issue, I recommend that the Director of the DPNT work in liaison with the DIPNN to improve the organisation such that it is more responsive and proactive.

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APPENDICES

RESULTS FOR THE NUCLEAR FLEETS

EDF SAEDF ENERGY

THE NUCLEAR SITES

EDF SAEDF ENERGY

KEY DATES FOR THE NUCLEAR UNITS

EDF SAEDF ENERGY

ABBREVIATIONS

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RAPPORT IGSNR 2017 APPENDICES

RESULTS FOR THE EDF SA FLEET

Nº Indicator 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

1 Number of significant nuclear safety events graded 1 or greater on INES per reactor1 1.15 1.17 1.17 0.91 1.55 1.19 1.14 1.16 0.98 1.21

2 Number of significant nuclear safety events (0 or greater on INES). per reactor1 10.34 10.93 10.45 10.57 11.90 11.60 10.8 10.03 9.78 11.59

3 Number of cases of non-compliance with technical specifications. per reactor

1.70 1.39 1.55 1.36 1.52 1.34 1.55 1.24 1.48 1.41

4 Number of alignment errors2 per reactor 0.62 0.53 0.77 0.71 0.70 0.66 0.60 1.03 1.04 1.84

5

Number of trips per reactor (for 7.000 hours of criticality3) • Automatic 0.51 0.71 0.69 0.50 0.55 0.59 0.53 0.66 0.48 0.41

• Manual 0 0 0.01 0.05 0.03 0.03 0.07 0 0 0.04

6 Average operational collective dose. per nuclear unit in service (in man-Sv)

0.66 0.69 0.62 0.71 0.67 0.79 0.72 0.71 0.76 0.61

7

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

between 16 and 20 mSv 14 10 3 2 2 0 0 0 0 0

• Number of individuals with doses between 14 and 16 mSv - - 60 43 22 18 5 2 1 0

8 Number of significant radiation protection events

107 102 91 92 114 116 113 109 117 131

9 Availability (%) 79.2 78.0 78.5 80.7 79.7 78.0 80.9 80.76 79.6 77.1

10 Unplanned unavailability (%) 4.4 4.6 5.2 2.2 2.8 2.6 2.4 2.48 2.02 3.26

11 Occupational accident rate with sick leave (per million hours worked)4 4.4 4.3 4.1 3.9 3.5 3.3 3.2 2.7 2.8 2.2

1 Excluding ‘generic’ events (ones due to shortfalls in design)

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

3 Average value for all reactors. unlike the WANO parameter which is based on the median value

4 Accident rate for EDF SA and its contractors

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APPENDICES RAPPORT IGSNR 2017

RESULTS FOR THE EDF ENERGY FLEET

Nº Indicator 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

1 Number of events ranked 1 or higher on INES. per reactor

1.13 0.80 0.93 1.33 0.80 0.80 0.33 0.47 0.27 0.40

2 Number of nuclear safety events ranked 0 or higher on INES. per reactor

4.53 5.47 5.60 4.7 4.6 5.1 4.5 7.40 9.6 6.07

3 Number of cases of non-compliance with technical specifications. per reactor

0.27 0.13 0.60 0.33 1.67 0.67 1.53 1.00 0.80 0.60

4 Number of alignment errors. per reactor 0.27 0.13 0.60 0.33 3.07 3.33 2.80 2.87 3.07 0.93

5

Number of unscheduled trips. per reactor (for 7.000 hours of criticality) • Automatic 1.13 0.82 0.58 0.74 0.64 0.45 1.17 0.57 0.3 0.49

• Manual 1.04 1.44 1.68 1.22 0.84 1.03 0.62 0.19 0.42 0.37

6

Average collective dose. per unit in service (in man-Sv) • PWR 0.264 0.337 0.271 0.537 0.037 0.386 0.365 0.048 0.544 0.296

• AGR 0.167 0.100 0.018 0.084 0.063 0.034 0.074 0.067 0.021 0.020

7

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

8 Number of significant radiation protection events

38 31 43 43 50 27 27 18 20 10

9

Availability (%): • EDF Energy fleet • PWR • AGR

51.2 89.2 48.5

71.0 87.4 69.8

65.7 45.6 67.1

72.0 82.5 71.3

78.0 89.2 76.3

78.9 83.0 78.2

72.1 84.1 70.2

77.30 100 73.7

83.0 82.0 83.1

81.6 83.8 81.2

10

Unplanned inoperability (%) • EDF Energy fleet • PWR • AGR

20.4 2.1 21.8

13.2 0.9 14.0

19.6 54.3 17.1

13.0 3.4 13.7

8.9 9.9 8.7

6.9 0.2 7.9

10.7 0.7 12.3

2.3 0

2.7

5.1 0.1 5.8

5.0 0.0 5.7

11 Occupational accident rate with sick leave (per million hours worked)1 1.8 0.6 0.4 0.6 0.5 0.2 0.2 0.4 0.3 0.2

1 Accident rate for EDF Energy and its contractors

Factors to be taken into account in comparing the results of EDF SA with those of EDF Energy:

• Line 2: the procedure for declaring events to the UK safety authority changed in 2015. which means more events are now declared than in the past

• Lines 3. 4 and 8: the event declaration procedures are not the same in the United Kingdom and France as a result of the respective nuclear safety authority requirements. EDF Energy and EDF SA harmonised their event classification practices in 2012

• Line 6: the reactors of the two fleets do not share the same technology (mostly AGRs in the UK and PWRs in France). The AGR design means that radiation exposure is some 10 times lower (source: WANO)

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EDF SA NUCLEAR SITES

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

Number per typePressurised Water Reactors

GCR HW FBR Engineering 300 MWe 900 MWe 1 300 MWe 1 450 MWe

1 600 MWe (EPR)

Construction

Operation

Decommissioning

Engineering Centre 7

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EDF ENERGY NUCLEAR SITES

Hunterston B

Hinkley Point B

Hinkley Point C

Barnwood

East Kilbride

Dungeness B

Sizewell B

Sizewell C

Hartlepool

Torness

Heysham 1

Heysham 2

LondonCardiff

Edinburgh

AGR: Advanced Gas cooled ReactorPWR: Pressurised Water ReactorEPR: European Pressurised Reactor

Number of reactor per type AGR PWR EPR Engineering

Construction or Project 4

Operation 14 1

Engineering Centre 2

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KEY DATES FOR EACH OF THE EDF SA NUCLEAR UNITS

Year commissioned

service

Nuclear Unit

Power in MWe*

VD1 VD2 VD3Year

commissioned service

Nuclear Unit

Power in MWe*

VD1 VD2 VD3

1977 Fessenheim 1 880 1989 1999 2009 1984 Cruas 4 915 1996 2006 2016

1977 Fessenheim 2 880 1990 2000 2011 1984 Gravelines 5 910 1996 2006 2016

1978 Bugey 2 910 1989 2000 2010 1984 Paluel 1 1330 1996 2006 2016

1978 Bugey 3 910 1991 2002 2013 1984 Paluel 2 1330 1995 2005 2015

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 2017

1980 Dampierre 2 890 1991 2002 2012 1985 St-Alban 1 1335 1997 2007 2017

1980 Gravelines 1 910 1990 2001 2011 1986 Cattenom 1 1300 1997 2006 2016

1980 Gravelines 2 910 1991 2002 2013 1986 Chinon B3 905 1999 2009 -

1980 Gravelines 3 910 1992 2001 2012 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 1335 1998 2008 -

1980 Tricastin 3 915 1992 2001 2012 1987 Belleville 1 1310 1999 2010 -

1981 Blayais 1 910 1992 2002 2012 1987 Cattenom 2 1300 1998 2008 -

1981 Dampierre 3 890 1992 2003 2013 1987 Chinon B4 905 2000 2010 -

1981 Dampierre 4 890 1993 2004 2014 1987 Nogent 1 1310 1998 2009 -

1981 Gravelines 4 910 1992 2003 2014 1988 Belleville 2 1310 1999 2009 -

1981 St-Laurent B1 915 1995 2005 2015 1988 Nogent 2 1310 1999 2010 -

1981 St-Laurent B2 915 1993 2003 2013 1990 Cattenom 3 1300 2001 2011 -

1981 Tricastin 4 915 1992 2004 2014 1990 Golfech 1 1310 2001 2012 -

1982 Blayais 2 910 1993 2003 2013 1990 Penly 1 1330 2002 2011 -

1982 Chinon B1 905 1994 2003 2013 1991 Cattenom 4 1300 2003 2013 -

1983 Blayais 3 910 1994 2004 2015 1992 Penly 2 1330 2004 2014 -

1983 Blayais 4 910 1995 2005 2015 1993 Golfech 2 1310 2004 2014 -

1983 Chinon B2 905 1996 2006 2016 1996 Chooz B1 1500 2010 - -

1983 Cruas 1 915 1995 2005 2015 1997 Chooz B2 1500 2009 - -

1984 Cruas 2 915 1997 2007 2017 1997 Civaux 1 1495 2011 - -

1984 Cruas 3 915 1994 2004 2014 1999 Civaux 2 1495 2012 - -

VD1: First ten-yearly inspection outageVD2: Second ten-yearly inspection outageVD3: Third ten-yearly inspection outage

*Net continuous power

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KEY DATES FOR THE EDF ENERGY NUCLEAR UNITS

Year commissioned

serviceNuclear Unit

Reactor Number

PowerMWe RUP

(1)

Planned date of withdrawal from service

(2)

1976 Hinkley Point B R3 480 2023

1976 Hinkley Point B R4 475 2023

1976 Hunterston B R3 480 2023

1976 Hunterston B R4 485 2023

1983 Dungeness B R21 525 2028

1983 Dungeness B R22 525 2028

1983 Heysham 1 R1 580 2024

1983 Heysham 1 R2 575 2024

1983 Hartlepool R1 595 2024

1983 Hartlepool R2 585 2024

1988 Heysham 2 R7 615 2030

1988 Heysham 2 R8 615 2030

1988 Torness R1 590 2030

1988 Torness R2 595 2030

1995 Sizewell B 1198 2035

(1) Reference Unit Power (RUP): the rated electrical power of the generating unit as declared by EDF Energy in its daily transactions.

(2) Dates of withdrawal from service. including all life extension decisions. Updated in 2016 for the reactors at Heysham. Hartlepool and Torness.

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ABBREVIATIONS

AAGR Advanced Gas-cooled ReactorALARA As Low As Reasonably AchievableALN National logistics agencyAMELIE DPN project to transform the logistics of spare parts AMS Asset management systemAMT EDF fleet maintenance agencyANTARES Animation to test and check instructions in the event

of accidentsASN French Nuclear Safety Authority

BBIP Plant OPEX databaseBWR Boiling water reactor

CCADOR Decision support tool for optimising installation of

biological shieldingCAMELEON Operating experience user environmentCAP Corrective action programme (UK)CEFRI French committee for the certification of companies

in training and monitoring radiation workersCEIDRE Expertise and inspection department for

manufacturing and operationCGN China General Nuclear Power CompanyCIR Construction engineering committeeCIT Thermal plant engineering centreCLI Local information commissionCNEN Nuclear engineering departmentCNEPE Electromechanical & plant engineering support

departmentCOLIMO A DPN project to modernise isolation and alignment

practices and methodsCPO Crew performance observationCRT Technical Standards committeeCSN Council for Nuclear SafetyCNO Chief Nuclear Officer (UK)CSNE DPN nuclear safety review meeting

DDA Design authority for EDF Energy Nuclear GenerationDACI Independent oversight directorate for EDVANCEDAIP Industrial support for production divisionDART Diagnostic and repair teamDCN Nuclear fuel divisionDesA Design authority for the French fleetDIPDE Nuclear fleet engineering. decommissioning &

environment divisionDIPNN Engineering & new-build projects directorateDP2D Decommissioning & waste directorateDPN Nuclear generation divisionDPNT Nuclear & conventional fleet directorateDRS Nuclear safety standards directorateDTG General technical department

EEGE Overall nuclear safety assessmentEDT Dedicated field teamEDVANCE Joint venture between EDF and AREVA NP

(80% and 20% respectively)EMAT Shared teams providing support during unit outagesENISS European Nuclear Installations Safety StandardsESPN Nuclear pressure equipmentEPCC Engineering, procurement, construction and

commissioningEPR European Pressurised ReactorEPR NM European Pressurised Reactor new modelESR Significant radiation protection eventESS Significant nuclear safety eventEUREKA Online network for information sharing between

contract partnersEVEREST EDF project to allow workers to enter controlled

areas wearing ordinary work clothesENSREG European Nuclear Safety Regulators Group

FFARN Nuclear rapid reaction forceFIS Independent nuclear safety oversightFME Foreign Material Exclusion

GGPEC Advanced planning of jobs and skillsGPSN Nuclear safety performance group (UNIE)

HHCTISN High committee for transparency and information on

nuclear mattersHPC Hinkley Point C

IIAEA International Atomic Energy AgencyIA-HPC Independent assessment HPCICRP International Commission on Radiological ProtectionIN Nuclear inspectorate (DPN)INA Independent Nuclear Assurance (EDF Energy)INB Licensed nuclear facilityINES International Nuclear Event ScaleINPO Institute of Nuclear Power Operators (US)INSAG International Safety Advisory Group (IAEA)IOP Operations engineeringIRAS Plant engineer assigned to relations with the ASN (NPPs)IRSN Institute for radiation protection & nuclear safety

JJIT Just in time

LLLS Turbo-alternator last-resort power supplyLWRS Light Water Reactor Sustainability programme

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MMAE Engineering audit unit at the DIPNNMAAP DPNT performance assessment and support teamMEEI Campaign for maintaining exemplary housekeeping

(DPN initiative)MME Operations and maintenance methodsMMR OPEX search engineMOMR Operational supervision and risk management

(DIPNN)MQME Campaign to raise the standards in maintenance and

operation (DPN)

NNCC Operations core skills handbookNCME In-service maintenance professions common coreNDA Nuclear Decommissioning Authority (UK)NEA OECD Nuclear Energy AgencyNEI Nuclear Energy Institute (US)NNB Nuclear New Build (EDF Energy)NNSA National Nuclear Safety Administration (China)NPP Nuclear Power PlantNSSC Nuclear Safety and Security Commission (South

Korea)

OOIU Internal inspection organisationOLP Organisational learning portalONR Office for Nuclear Regulation (UK)OPDT Operations performance delivery teamOPEX Operating experienceOPPT Control room supervisorOSART Operational Safety Review Team (IAEA)

PPCC-EO Skills advisory centre for organisational effectivenessPDC Nuclear engineering key skills development planPUI Onsite emergency planPWR Pressurised Water ReactorPSPG Police site protection unit

RRCP Main primary cooling system of the reactorRCV Chemical and volume control system of the reactor’s

main primary systemR&D Research & Development directorateRIS Emergency water injection system for reactor coolingRGV Steam generator replacementRTE Power grid companyRTGV Steam generator tube rupture

SSAT Systematic Approach to TrainingSAPHIR Event reporting databaseSDIN Nuclear technical information systemSDIS Local fire and rescue servicesSEPTEN Nuclear and conventional design departmentSIR Authorised internal inspection departmentSMI Integrated management systemSODT Safety Oversight Delivery TeamSOER Significant Operating Experience Report issued by

WANOSOFINEL Joint EDF and AREVA design officeSPR Risk management departmentSTE Technical specificationsSYGMA Computerised maintenance management system

TTEM Unit in serviceTNPJVC Joint venture between the Chinese company CGNPC

(51%). Guangdong Yuedean Group Company (19%) and EDF (30%)

TSAB Training standards accreditation boardTSM Technical Support Mission by peers organised by

WANOTSN French nuclear safety & transparency actTVO Teollisuuden Voima Oy (Finland)

UUFPI Operations & engineering training departmentUNIE Operations engineering unit (DPN)UNGG Gas-cooled graphite-moderated reactorUTO Central technical support department (DPN)

VVD Ten-yearly inspection outageVP Partial inspection outage

WWENRA West European Nuclear Regulators AssociationWNA World Nuclear AssociationWANO World Association of Nuclear Operators

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Jean-Jacques LÉTALON. John MORRISON. François de LASTIC. Jean-Michel FOURMENT. Bernard LE GUEN

PHOTO CREDITS

ANTONY HUYGUEBAER – THIERRY MOURET – THOMAS DERON – GRAVELINES NPP – PHILIPPE ERANIAN – SIZEWELL B NPP – BERNARD LE GUEN – ÉRIC LAMPERTI – CENTRAL TECHNICAL SUPPORT DEPARTMENT – HINKLEY POINT C SITE – HUNTERSTON NPP – JEAN-PIERRE MAUGER – YVES HUET – SOPHIE BRANDSTROM – DAVID MORGANTI – MARC DIDIER – STÉPHANE LAVOUE – JEAN-LOUIS BURNOD – ANTONY RAKUSEN – GUILLAUME MURAT – R&D EDF – BUGEY NPP – FLAMANVILLE NPP – ST ALBAN NPP – CHRISTOPHE MEIREIS – CIVAUX NPP – EDVANCE – GRÉGORY BRANDEL – TAISHAN NPP – ALEXIS MORIN.

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E.D.F.Présidence IGSNROffice: 33 avenue de WagramMail: 22-30 avenue de Wagram75008 Paris✆ : +33 (0)1 40 42 25 20

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7The new offi ces of the Engineering technical department in Lyon

Documents

2017 - edf.fr · 1 FOREWORD IGSNR REPORT 2017 FOREWORD This report, written for the Chairman of EDF, gives my assessment of nuclear safety and radiation protection within the