IRRS follow-up mission to France - October 2017

45 FOLLOW UP MISSIONRECOMMENDATIONS, SUGGESTIONS AND GOOD PRACTICES SF1 Suggestion: The regulatory body should consider developing definitions of emergency classes consistent with those defined in GSR Part 7 and ensure operators classify emergency situations and communicate the emergency class to offsite response authorities. 10.3. REGULATORY REQUIREMENTS FOR INFRASTRUCTURE 2014 MISSION RECOMMENDATIONS, SUGGESTIONS S21 Suggestion: ASN should consider developing a methodology to evaluate the performance of licensees during emergency exercises based on an integrated systemic approach to performance evaluation. Changes since the initial IRRS mission Suggestion 21: In France, various levels of emergency exercises are undertaken: Major Exercises involving the Government, National Exercises with operator/prefect/IRSN/ASN and finally licensee internal exercises. All these exercises are evaluated and lessons learned are produced in a collaborative manner among all participants. In the case of Major Exercises the SGDSN (Prime Minister Services) produces an after action report, for National Exercises the ASN coordinates the after action report, and finally for licensee internal exercises, a self-evaluation is prepared by the licensee. ASN performs comprehensive licensee inspections on emergency preparedness and response (EPR), but not during national emergency exercises. ASN inspections focus on program implementation aspects such as document verification, system readiness verification, etc., and in some cases local exercises or simulations. In addition, ASN will use a scenario to have the licensee run a real-time drill of a specific subset of their onsite response plan (for example, alerting and accounting of personnel, muster of response teams, etc.). ASN will also use after action reports from licensee self-evaluations to perform reactive inspections and ASN also stages unannounced inspections with these real-time drills. The full set of EPR inspection activities by ASN is quite comprehensive. However, there is no systematic evaluation of the operators during exercises by ASN. To complement the existing arrangements ASN has started working with the Office for Nuclear Regulation in England (ONR) on an exercise assessment called Level 1 Demonstration Emergency Exercise. It is part of an ONR monitoring process, which concludes with an inspection report and a letter of feedback to the operator. ONR has a specific evaluation guide whose objectives and success criteria are relatively numerous. These evaluations require an important preparation phase and the synthesis also requires a compilation of the observations during the exercise. The team of evaluators must have the necessary skills for such an assessment. ASN is considering supplementing the existing system by adopting the ONR's Level 1 Demonstration Emergency Exercise evaluation practice and has included this in their 2018/19 EPR planning as documented in an internal document. An observation of such an exercise in UK took place in June 2017 by 2 ASN inspectors and a working group involving the agents of the territorial divisions and directorates as well as the Security Officer of the ASN will be set up.