ASN Report 2017

359 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 12  - EDF Nuclear Power Plants Management of subcontracted activities Maintenance and modification activities on French reactors are to a large extent subcontracted by EDF to outside contractors. EDF justifies the use of subcontracting by the need to call on specific or rare expertise, the highly seasonal nature of reactor outages and thus the need to absorb workload peaks. EDF’s decision to resort to subcontracting must not compromise the technical skills it must retain in-house, in order to carry out its responsibility for the protection of interests and be able to effectively monitor the quality of the work performed by the subcontractors. Poorly managed subcontracting is liable to lead to poor quality of work and have a negative impact on the safety of the facility and the radiation protection of the workers involved. EDF has taken steps to control the risks associated with subcontracted activities and has reinforced the preparation of outages, more particularly to guarantee the availability of human and material resources. ASN monitors the conditions in which the work is performed (accessibility of premises, noise, heat and light environment, etc.). It also checks that the workers involved have the means necessary (tools, documentation, etc.) for the performance of the tasks, in particular when these means are made available by EDF. 2.6.2 Evaluation of the working of the organisations and control of activities Organisation of work and working conditions In 2017, ASN is still noting numerous shortcomings with regard to the planning and individual and collective preparation of activities, which are key phases in error reduction in terms of safety, whether or not the work is subcontracted. These shortcomings, notably during reactor outages, lead to scheduling changes which are the cause of degraded working conditions owing to the increased number of contractors working in the same place and difficulties with coordinating them. The checks run on the implementation of work error- reduction practices in the NPPs show that there is still room for improvement. In 2017, ASN on several occasions observed on the one hand that the equipment to be made available to the workers was inappropriate or even missing and, on the other, that certain activities were performed in cramped spaces with difficult access and in unfavourable working environments (light, heat, noise), with signage errors and logistical problems. Problems with communication between departments or between trades during the performance of a task further aggravate the risk of shortcomings in the control of the activities. ASN still observes that the documents made available to outside contractors are inappropriate, which regularly leads to the occurrence of significant events. The checks initiated by ASN in 2016 resulted in EDF identifying new situations and new events of the same type in 2017. These checks will be maintained in 2018. Provisions concerning staff and organisations in operational reactor modification activities ASN considers that EDF’s SOH 1 approach is pertinent and necessary for managing the facilities, their modifications and the conditions in which these are carried out. The effects of this approach, the deployment of which must be continued, are as yet insufficient. ASN still observes modifications that cannot be carried out in the conditions initially envisaged. In 2017, ASN carried out several inspections at the EDF head office departments to check that the processes implemented by the licensee in fact comply with the user-centred design principles. Skills management, training and qualifications The organisation in place on the sites for managing skills, qualifications and training is on the whole satisfactory. In 2017, on several sites, ASN however observed shortcomings in personnel training, which can be partly ascribed to large- scale retirements. Some advanced or critical skills now lie with just a single individual. In 2017, ASN still considers that the processes used by EDF to manage and maintain the skills necessary for management of the activities, including reactor control activities, must be given particularly close attention by EDF. Given the retirements to come and the scale of the work needed to allow the continued operation of the reactors, ASN will check that the action plans implemented by EDF to correct the shortcomings observed actually produce the expected effects. The operating experience feedback process Operating experience feedback, as an organised and systematic process of collecting and analysing the signals emanating from a system, is one of the key tools in managing safety and radiation protection. Even if the significant event analyses carried out by certain sites are able to go further than the apparent causes and highlight organisational problems, this is not the case for all the sites, which reflects differing levels of involvement by the personnel with competence for organisational and human factors. ASN also observes that the corrective measures taken by EDF are not always able to address the organisational malfunctions highlighted by these analyses. Generally speaking, there is inadequate sharing and effective utilisation of the lessons learned, whether between sites, between departments on a given site, or between the sites and the EDF head office departments. In 2018, ASN will check that the action plans initiated by EDF to improve how operating experience feedback is shared, including with outside contractors, and the corresponding lessons to be learned, produce the desired effects. 1 . At the national level, EDF has developed the “Social, Organisational and Human – SOH” approach, the aim of which is to transform engineering practices at EDF to take greater account of people and organisations in the changes made to the systems and in modifications to hardware and organisations, as of the design stage.