monitoring events inspections findings safety health operating experience improvements management occupational safety

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1 inspections operating experience improvements management monitoring safety events findings occupational safety radiation protection health 2014 AREVA General Inspectorate Annual Report Status of safety in nuclear facilities

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3 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES Message from Philippe Knoche, Chief Executive Officer Safety is and remains our priority; it is a major asset for improving our operating performance. «The AREVA group is engaged in a profound transformation of its operations. At times such as these, the safety of our facilities and our operations must, more than ever, remain our top priority and receive the commitment and particularly close attention of everyone. The circumstances require that we be innovative to improve our performance. This requirement is also true for safety, where we must meet all of our obligations in a manner that is fair and proportionate to what is at stake, without giving anything up in terms of our objectives. When it comes to the safety requirements imposed on us, we must do it right the first time and within the time limits to which we agreed. This means engaging in real dialogue with safety authorities to anticipate their expectations and, early on, win their acceptance of the options we have chosen especially when they are innovative ones. Managing the dayto-day safety of our operations requires skills, a clear division of responsibilities, robust facilities and equipment that comply with standards that evolve regularly, and the constant vigilance of our teams and managers. As a nuclear operator, it is our responsibility to perpetually question ourselves and continually adjust our organizations, our resources and our skills in the face of rising regulatory, social and commercial requirements. Along those lines, the first peer review conducted by WANO at the LA HAGUE site in 2014, which brings an external view from other operators of how we work, is of enormous benefit in guiding and driving our performance improvement programs. The ten-year safety review process, which recently began applying to the nuclear fuel cycle facilities, is also a fundamental tool for performance improvement which we must integrate fully into our industrial practices. Our group is facing many challenges. Safety is part of our DNA, and it is a major asset for the development of our industry and the turnaround of our operating performance. It is because of our high safety standards that we have won the trust of our customers, regulators and stakeholders. This report by the General Inspectorate, which was presented to the Board of Directors and is available to the public, analyzes the leading actions implemented in 2014 in the sphere of safety. Drawing on a series of inspections and discussions with the sites, it identifies areas that would benefit from improvement. The report is part of our policy of transparency and of our risk management initiative. The perspective of experts who are independent of the operational chain of command but in daily contact with the activities of our sites is a vital contribution to our continuous improvement strategy as regards safety. I strongly encourage everyone to take due note of the areas for vigilance and the performance improvement actions identified in this report, each in his or her area of responsibility.» 3

4 Vision of Jean Riou, Inspector General This annual report of AREVA s General Inspectorate deals with the status of nuclear safety and radiation protection in the group s operations and facilities in This report is based on findings made during implementation of the annual inspection program. It also includes the results of analyses of significant events in the facilities, and observations and appraisals by specialists of the Safety Health Quality Environment Department. In addition, it draws on regular discussions with the nuclear safety authorities, the different agencies of the State, stakeholders and other nuclear operators. Lastly, it presents the action plans carried out and the directions taken for continuous improvement of risk prevention for activities conducted in France and abroad. The safety of the AREVA group s nuclear operations and facilities continued to be satisfactory in This conclusion is based on an analysis of selected performance indicators, inspection findings, performance improvement actions and identified areas for vigilance. KEY SAFETY RESULTS As in 2013, the year of 2014 was characterized by the absence of an INES level 2 event, the very low level of personnel exposure, and the absence of radiological impacts on the environment. However, a reduction in the number of reported INES level 0 events was observed at year-end, which is cause for continuing vigilance concerning the bottomup reporting of weak signals. 1 - Operating experience (OPEX) is of major importance for safety. It is both a valuable indicator of the proper bottom-up reporting of deviations and an important way to orient continuous improvement process. The number of level 1 events in 2014 was identical to that of 2013 (19). However, it should be noted that 11 of these events concerned criticality risk prevention and 4 concerned the containment function. Both of these points should continue to receive our fullest attention. The Incident Prevention Rate (IPR*) was 0.14 in 2014 (0.12 in 2013, 0.10 in 2012), and thus exceeds the target rate of This trend is not necessarily synonymous with a reduction in the bottom-up reporting of weak signals, since events of interest with no INES ranking also belong to this category of events. Their ultimate inclusion in a broader IPR, one that also takes into account events of interest, deserves to be examined in order to have a more accurate overview of weak signals and their trends. The breakdown of INES events by reporting criteria was generally stable in relation to 2013; safety accounted for 60% of the reported events, radiation protection for 16%, the environment for 16%, and transportation for 8%. Two topics in particular emerge from the analysis of 2014 events: The first concerns events relating to systems configurations or alignment issues (uncontrolled liquid effluent transfer, poor reconfiguration of the facility after maintenance or a schedule outage, 4

5 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES valve or transfer pump selection error, etc.). This topic highlights the sensitive nature of preparations for effluent transfers or equipment configuration activities: consultation between teams, alignment check, etc. The robustness of the process for preparing transfers is crucial. Controlling operational risks depends on working collectively, where the keys to performance are a clear definition of roles and responsibilities, effective coordination, proper communication between workers, and disciplined execution. The second topic concerns events relating to work in regulated areas, which drew attention to deviations from rigorous compliance with basic radiation protection measures (activation and wearing of dosimeters, wearing of appropriate protective clothing, operation of mobile airlocks, etc.). This corroborates observations made during internal inspections and during the WANO peer review conducted at the LA HAGUE site. Although it is true that these events are few in comparison with the number of work tasks carried out in regulated areas, they constitute weak signals which must cause us to rethink how to maintain a good radiation protection culture. In addition to the reporting and analyzing of events which we do, it is essential that the experience of the few benefit the community as a whole. Three grouplevel meetings were held in 2014 with the OPEX coordinators of the main entities. These meetings focused on three sensitive, crosscutting themes: Handling: The discussions on this subject helped identify very tangible performance improvement actions, such as preparing a memo on the visual examination of slings or identifying hoisting and handling skills among specialists in HSE s pools of expertise. Facility compliance: This is one of the keys to maintaining the highest level of safety in our facilities. This subject was addressed from various angles: compliance in design, construction and operation, facility configuration compliance, and organizational compliance. Concrete examples drawn from recent events in the group were presented: non-conformity of the height of earth mound barriers at EURODIF, geometric nonconformity of a component of the process ventilation system at ROMANS, and nonconforming paint which released volatile organic compounds inside UF6 autoclaves in the REC II facility at TRICASTIN, making UF6 detection inoperable. Accidental spill prevention: The status of actions launched on this subject in 2013 were reviewed and OPEX from welds in the manhole of a high-density polyethylene stacker were shared, as were calculation methods for the volume of a secondary containment. The meeting also offered an occasion to address issues concerning the control of fluid transfers between enclosures and facilities. * IPR: an AREVA calculated indicator based on the ratio of INES level 1 events to INES level 0 events Internal meeting of the OPEX coordinators network in

6 Vision of Jean Riou, Inspector General dosimetry levels were low and stable, both for AREVA employees and for subcontracted workers. Annual average doses were 0.90 and 0.49 msv respectively, with maximum doses of and msv respectively. Thirteen AREVA employees and three subcontracted workers received of dose of more than 14 msv. No exposure in excess of 18 msv has been recorded since 2010 (for an annual limit of 20 msv as defined in AREVA policy). In 2014, 53.9% of AREVA s employees and 36.6% of subcontracted workers received a dose below the regulatory recording threshold of 0.1 msv, while 85.4% of AREVA s employees and 92.3% of subcontracted workers received a dose of 0 to 2 msv. Of the persons effectively exposed (those whose annual dose exceeded the recording threshold), 98.9% of AREVA s employees and 88.7% of subcontracted workers received a dose of less than 6 msv. 3 - The radiological impacts on the environment from the group s nuclear sites are negligible, at a few microsieverts per year (for an annual regulatory limit of 1 msv for members of the public in France). One of AREVA s priorities is to ensure that its industrial operations have no environmental impacts. This is the subject of diligent monitoring and follow-up. Each of AREVA s nuclear sites has at least one environmental laboratory approved by the French nuclear safety authority ASN which performs analyses on environmental samples. For AREVA, this monitoring represents about 100,000 measurements per year and concerns 1,000 sampling locations in France. The approved laboratories are part of the National Environmental Radioactivity Measurement Network (RNM). All of the data collected is periodically sent to the French safety authorities in a regulatory record. The results of environmental radioactivity monitoring are available to the public on the internet: SUMMARY OF INSPECTIONS In 2014, the General Inspectorate conducted 34 inspections in 17 of the group s entities. Three of them concerned sites outside France and 3 were conducted pursuant to events or special situations. These inspections gave rise to 146 recommendations which have been translated into action plans by the inspected entities. Verification of these action plans according to announced schedules and standard procedures gave rise to 20 follow-up inspections. The major lessons from these inspections may be divided into 3 general categories: operational discipline, regulatory compliance and the handling of deviations. 1 - Operational discipline accounted for 56% of the General Inspectorate s recommendations in This point constitutes a major area for improvement, especially since it concerns several areas related to the operational implementation of certain processes, the filling in and follow-up of recording documentation, and the implementation of internal controls. The traceability of proof of the proper operation and continuing compliance of the facilities to their configuration programs is all too often impacted by the insufficient quality of documentation. This finding applies to practically all of the entities inspected. This is particularly the case during nonroutine inspections conducted in the aftermath of a significant event, where the absence, inconsistency, incompleteness or inadequacy of recording documentation almost always appear among the direct or indirect causes of the event. Moreover, the various supervisors lack of knowledge of the exact inventory of documents to be filled in makes supervision of these documents insufficient. Departures sometimes result, weakening the management of nuclear and occupational safety. The keeping of parameter-recording documentation and/or documentation demonstrating compliance with requirements is a strong challenge for performance improvement which should receive the utmost attention from management. 2 - The regulatory compliance of facilities is the direct responsibility of the operator and the employer. The densification of regulatory requirements in France and the generalization of ten-year safety reviews to nuclear fuel cycle facilities make this challenging objective deserving of suitable resources and genuine standardization of the process. Maintaining facility compliance means bringing regulatory change under control. This requires strong involvement by the operators in the early stages of new regulation development in order to call attention 6

7 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES to the full array of consequences and ensure that the regulations are proportionate to the stakes at hand. It also means undertaking the necessary analyses to identify, facility by facility, the non-conformities induced by the new regulations and the measures to be taken (upgrades, offsetting measures). These analyses need to be able to rely on an organization and well-formulated practices so that they can be carried out within a timeframe that is compatible with the effective dates of the new regulations. Usually, the results of the analyses are expressed in the form of a table referred to as a interface document which establishes a connection between the regulatory obligations and how they are addressed. In all cases, the INB safety reviews and the promulgation of a number of new regulations (ASN decisions, Seveso 3 regulations, etc.) continue to be opportunities for verifying that the interface documents are up to date, or to finalize the construction of interface documents still under development. HOW WANO SEES LA HAGUE SITE AREVA joined WANO in This association of the world s nuclear power plant operators also welcomes nuclear fuel cycle facility operators, such as the Sellafield plant in Great Britain. The AREVA LA HAGUE plant has now joined their ranks. In 2014, WANO conducted a peer review at the LA HAGUE site which mobilized 28 inspectors from 9 different countries for 3 weeks. Representing more than 450 man-years of cumulative experience in the operation of nuclear facilities, this brought a depth of vision to the review of the site. 3 - The handling of deviations and more generally the analysis and sharing of experience are essential drivers for continuous improvement in each of the risk prevention fields associated with our operations. It was found, particularly during non-routine inspections conducted after a significant event, that causal analyses are not always carried out with the necessary level of detail. This concerns both the collection of facts, which is often too late, and the absence from the analysis of persons directly involved in the event. The result is a fault-tree analysis which often stops at the first apparent causes and does not look further for root causes. Yet the latter are indispensable to the proper identification and implementation of corrective and preventive actions that are robust and effective over time in order to avoid the recurrence of similar events. In addition to defining and implementing corrective actions following events, the management of deviations also encompasses follow-up of nonconformities, the handling of recommendations stemming from internal controls, the response to commitments made pursuant to ASN inspections, and the response to commitments arising from safety reviews or reviews of safety documentation produced in connection with facility modification projects. Once again, although progress has been made, improvements are still necessary. This external view was able to go to the essence of the site s operational practices and the prevailing safety culture on a variety of topics ranging from organization to operations, including maintenance, engineering support, radiation protection, chemistry, training, fire protection and emergency management. The effectiveness of the method used by WANO derives above all from the number of facts collected and from some 1,000 observations, which were formatted and validated one by one and then aggregated and shared in order to build a comprehensive view in relation to each of the defined Performance Objectives and Criteria. It is not WANO s mission to perform compliance audits; it mission is to measure operational performance. The result of the review was the identification of 10 areas for performance improvement, to which the site responded with an action plan which will give rise to a follow-up review in one year. The areas in question are highly varied, but concern above all people and organizations. They range from 2 2- WANO team at LA HAGUE 7

8 Vision of Jean Riou, Inspector General maintenance to the supervision of modifications, from manager presence on the floor to external benchmarking, from performance indicators to established objectives, from emergency management drills to training, and from personnel commitment to their inter-personal skills. The strength and effectiveness of this process also comes from the work performed on this occasion by the site as part of an organization that brought a number of teams together to work on a genuine project. WANO s contributions extend beyond LA HAGUE; they are relayed within AREVA by the attendance of the group s managers and experts in training programs and in review missions to other sites that are members of the organization. In addition, the General Inspectorate is relaying areas for improvement identified by WANO at LA HAGUE to the group s other entities. AREAS FOR VIGILANCE Among the points to be watched, I identify the continuous attention which must be given to training and the level of safety culture of workers and their management, the particularly sharp growth in recent months of regulatory requirements, and the necessary standardization of safety reviews. In addition, the oldest waste retrieval and packaging projects at LA HAGUE require rigorous supervision, as does the operational implementation of the priority given to safety by Executive Management. 1 - The use of complex systems infers training and safety culture which should be carefully supervised and adapted. In this sense, it is essential to increase the status of the safety disciplines and to provide suitable qualifying training by offering crosscutting training within the group and by improving discussions and exchanges with the internal engineering organization. Programs to assess skills, awareness and training have been implemented with the goal of building those assets. In particular, these measures have been implemented in connection with the Safety Excellence program, which currently concerns some 500 employees among the site directors, oncall directors, facility managers, HSE managers, project managers and jobsite managers. In addition, to meet the requirements of the INB Order on the supervision of contractors, an action plan has been deployed to identify and support supervisors in their new duties. Increasing the level of safety culture is one of the commitments of the group s nuclear safety policy for Among other things, the group developed a safety culture self-assessment tool made available in June Some 1,500 people involved in the operation of nuclear facilities participated in these self-assessment campaigns at their local management s request. In addition, better integration of the underlying principles of safety culture (e.g. questioning attitude, rigorous and prudent approach) is sought by building the reliability of work practices. Eight Human Performance Tools observed at major nuclear industry players and recommended by international nuclear safety bodies were adopted and are gradually being rolled out in the group s operating entities. Added to these different actions, which must continue, is the Safety Focus program, which consists of developing a detailed map of every specialist in the safety fields in order to support their qualifying training, be in a better position to manage these valuable skills, and prepare the managers of the future. The operational implementation of this program should strengthen the ability to provide the right skills to the right place at the right time. Strong management presence on the floor supports these initiatives. 2 - The number of regulatory requirements has seen unparalleled growth since the beginning of 2012 in France. This situation is accompanied by real challenges associated with their proper operational implementation and their appropriation by the operators. In these times of new long-term regulatory requirements, the quality of the relationship with the French nuclear safety authority ASN is more than ever a crucial factor. In the forest of complex requirements, which could demotivate those who do the work and cause them to lose their way, it is important to keep our sights trained on the primary objective of improving safety. The difficulties encountered in the operational implementation of the 2005 order on pressurized nuclear equipment (ESPN) alert us to the real challenges of regulatory 8

9 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES change. All of the lessons must therefore be drawn from the misunderstandings that arose from implementation of this order so that 1) proper operational measures are ultimately defined in this regard and 2) procedures for implementing any new requirements remain the first concern of their authors. It is on the floor that safety is won first. To be met, a requirement must first be well understood and correspond to a clearly identified and accepted issue. 3 - The generalization of the ten-year safety review process to nuclear fuel cycle facilities is a strong challenge for the operator in France. The continued operation of its facility depends on it, and it calls for specialists from every area involved in demonstrating safety. 4 - Concerning the oldest waste retrieval and packaging at LA HAGUE, a number of actions continued in 2014 and frequent exchanges were held with ASN. These are long-term operations which have been clearly identified for many years, but which require research and development, the construction of new facilities, waste package acceptance, waste disposal systems, and the review of multiple regulatory documents connected with the necessary authorizations to be obtained. Seventeen projects are involved in these operations, which must be completed by In December 2014, ASN decided to frame these projects with a regulatory decision outlining milestones for each stage. This complex subject presents safety, schedule and resource challenges, and its overall management requires rigorous supervision. 5 - AREVA is going through a difficult period, but the message from Executive Management is unambiguous: safety must continue to have priority. The reviews help keep the safety of the facilities at the highest level by ensuring configuration compliance and by periodically reassessing their safety based on operating experience and best available techniques. In 2014, AREVA submitted five safety review reports and two guidance reports. ASN announced that it had concluded two reviews and continued its review of the report from one of the major INBs at LA HAGUE. In addition, ASN published requirements for the continued operation of three INBs. In 2015, three other INBs were included in this process. As this recap shows, the process is becoming a continuous one today and encompasses all of the 19 INBs operated by AREVA, including those undergoing dismantling, according to a defined schedule. The operating experience from these first reviews should be largely exploited to draw key lessons from them in terms of general organization and specific resources required, with the goal of streamlining the process and especially doing a better job of planning for these meetings. 3 Against a backdrop of strong restrictions, realigned organizations and reassigned resources, continued vigilance is needed so that the priority given to safety by Executive Management is clearly heard and operationally implemented at every level of the organization. The General Inspectorate will be particularly attentive to its achievement. LANDMARKS In 2014, ROMANS was placed under heightened surveillance, Supplementary Safety Assessments (SSA) continued, the large-scale ECRIN emergency management drill was carried out, and a safety convention was convened LA HAGUE 4- ROMANS facility 9

10 Vision of Jean Riou, Inspector General 5- L. Oursel among the Strategic Management Team during the ECRIN drill, September 30 and October 1, P. Knoche during the AREVA Safety First 2014 Convention 1 - ASN placed the ROMANS site under heightened surveillance in February 2014 following repeated operational deviations and a series of postponed commitments. In response, the site set up a Multiyear Safety Improvement Program (PPAS). This program covers configuration compliance projects for facilities subject to commitments following safety reviews of two INBs; Criticality Risk Prevention Improvement; and a strengthening of the contracting authority s organization and of the site safety organization, in particular with the institution of Operating Safety Engineers. In November 2014, during its review inspection, ASN noted good progress on the actions undertaken. The General Inspectorate oversaw the site s preparation of the review inspection and carries out a follow-up inspection of the PPAS every two months pursuant to the ASN requirement. 2 - In response to ASN s initial decision following the Supplementary Safety Assessments (SSA), AREVA engaged in several actions in 2014 involving the strengthening of ultimate defense in depth levels, particularly for equipment in the hardened safety core. These studies and initial work concerned both the level of unforeseen event to take into consideration (probabilistic studies of seismic events), facility robustness, definition of supplementary mitigation means to be implemented, and emergency management resources (new management centers, living quarters and equipment storage facilities). At the same time, the organization of FINA, AREVA s national response force, was defined and its first members were identified and trained. 3 - The large-scale 2014 ECRIN emergency management drill was conducted at the TRICASTIN site on September 30 and October 1. It mobilized the group s entire emergency management organization, representing more than 300 people at the site and 90 at headquarters, including all of the members of Executive Management. With a 70- person coordination team and preparations conducted in project mode over several months, the drill sought to apply strong pressure to everyone involved in a crisis through activities simulating most of internal and external stakeholders. Several events were simulated impacting a number of the site s facilities and requiring the use of hardened safety core resources defined in the Supplementary Safety Assessments (SSA), including FINA and the INTRA economic interest grouping, to ensure the operator s ability to manage such extreme situations over the long term. The drill is an essential tool for preparing an operator to meet its responsibilities under all circumstances. It should be repeated regularly The Safety First 2014 Convention assembled close to 200 managers involved in safety management from throughout the group. The convention provided a venue for discussing the challenges associated with the new safety requirements in France. It was an opportunity for Executive Management to clearly express the priority that should be given to safety, for ASN to state its expectations of AREVA, and for the Director of WANO Paris to share key lessons learned from the first WANO peer review at LA HAGUE. It was also an occasion for discussion of the operational implementation of the new regulatory obligations, the safety review process, the mobilization of skills and resources, and contractor involvement.

11 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES Content BACKGROUND AND FINDINGS p Highlights of Lessons learned from the inspections and WANO s review 24 Operating experience from events 28 Radiological monitoring of personnel 34 Environemental monitoring HUMAN AND ORGANIZATIONAL FACTORS p Simplification of the group s organization 45 Definition of responsabilities 46 Safety and radiation protection skills 48 Human performance tools 50 Safety culture self-assessment STANDARDS AND SAFETY DOCUMENTATION p Changes in regulatory standards in France 55 Safety reviews 57 Safety management 61 Management and supervision of subcontracted activities 64 Emergency Management MANAGING TECHNICAL RISKS p Criticality 75 Fire 78 Monitoring of external transportation operations 82 Radioactive waste management 85 Dismantling and clean-up AREAS FOR IMPROVEMENT AND OUTLOOK p Areas for improvement and outlook GLOSSARY p Glossary 11

12 BACKGROUND AND FINDINGS Background and Findings P. Knoche at the TRICASTIN site in

13 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES 2014 was a difficult year for the nuclear industry. Nonetheless, the group has still set a priority on the fundamental objective of continuous nuclear safety improvement. BACKGROUND AND FINDINGS The evidence can be found in some of the highlights that punctuated 2014, such as the new production tools that the group completed or brought into operation designed to make significant material improvements, or the actions to strengthen the operational practices and safety culture of all players: welcoming the first peer review by WANO at the LA HAGUE site, strengthening of safety training programs, conduct of the large-scale 2014 ECRIN drill at the TRICASTIN site, the Safety First 2014 Convention These positive aspects must nevertheless be weighed against events that are less so, such as ASN s strengthened surveillance of the ROMANS site or the difficulty of the oldest waste retrieval program at LA HAGUE to produce visible results. Major action programs launched in previous years also continued: simplification of the group s legal structure, work related to the overhaul of French nuclear regulations, material investments following the Supplementary Safety Assessments, implementation of ten-year safety reviews, dismantling of old plants... Aside from the daily and ongoing work carried out by all parties, the challenges presented by the safety of the group s operations are still a driver for actions and improvements and a fundamental trait of AREVA s identity. 13

14 BACKGROUND AND FINDINGS Highlights of New REC II facility, TRICASTIN Changes in the regulatory standards Work to expand the French regulatory standards continued in 2014 at a rapid pace, as illustrated by the orders approving ASN general technical decisions on pollution control, control of health effects and environmental impacts, material modifications, fire hazards control and criticality risk management. Numerous other regulations will be issued, particularly to standardize the content of documentation used for the operator s own requirements or sent as back-up for regulatory reports. Ten-year safety reviews The program to deploy the safety review process for AREVA s INBs continued. Initial feedback pointed to the need for true standardization of the process throughout AREVA. This means better planning, their inclusion in a continuous process in terms of resources and skills, scheduling of compliance verifications, and required upgrades. Commissioning of new facilities The commissioning of the new enriched UF6 receiving, sampling and measurement facility (REC II) at INB 198 (Georges Besse II plant at TRICASTIN) is one of the final stages in AREVA s major plant replacement program in the front end of the nuclear fuel cycle. Its operation enables the corresponding operations in INB 93 (EURODIF) to be terminated and performed in a facility presenting greater robustness in the face of extreme events. It is also an important milestone in safety improvement and is evidence of the group s commitment to carrying this type of program out over the long term (10 years). The new aqueous hydrofluoric acid storage facilities were transferred in 2014 to the operating 14

15 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES teams of the W defluorination facility at the TRICASTIN site, demonstrating the commitment to a comprehensive strategy of safety improvement by reducing the non-nuclear risks associated with the operations involved. The first phase of the glass storage capacity extension program was completed at the LA HAGUE site. This allows the safe storage of final waste from the reprocessing of irradiated fuel to continue for several decades until the CIGEO final disposal facility is brought into operation by ANDRA. The design principles of the preexisting storage facilities were reexamined in detail on this occasion and validated. construction. Illustrations are large-scale operations such as the preventive replacement of equipment associated with the fuel element shearing function at the LA HAGUE site or the start of operations to replace an evaporator used to concentrate fission products at that same site. The success of these projects shows that activities which were not considered achievable during the initial design of the facilities have become so today, thanks to the technical expertise acquired over time. BACKGROUND AND FINDINGS 3 2 Post-Fukushima actions For AREVA s facilities, one of the major conclusions of the post-fukushima Supplementary Safety Assessments is that a priority should be placed on improving the tools for managing extreme emergencies. With this in mind, and in addition to the immediate measures deployed in 2012 and 2013, the first contracts were signed for the construction of reinforced buildings at the TRICASTIN site to house the corresponding functions. At that same site, water curtains were installed as ultimate protection for the oldest facilities at W Plant in the event of an accident, pending W replacement by the EM3 facility. Construction of the latter is scheduled to begin in Exceptional maintenance activities Ongoing work to maintain facility compliance continued in parallel with important new facility The establishment of FINA, AREVA s National Response Force, is in progress and has mobilized a large number of employee volunteers at the group s different sites. This mobilization is seen in all targeted operational skills, including protection, measurements, response, repairs and clean-up. 2- New SHF3 storage facility, W Plant, TRICASTIN 3- UP3 shearing machine magazine, LA HAGUE 15

16 BACKGROUND AND FINDINGS Highlights of 2014 Quality demonstration issues for pressurized nuclear equipment Issues related to the interpretation and practical implementation of regulations currently applicable to pressurized nuclear equipment (ESPN) in France continued to be a subject of concern in Among other things, this led to a delay in upgrades and safety improvements to nuclear power plants engaged in a steam generator replacement program. FOCUS Safety First 2014 Convention On November 27, the Safety First 2014 Convention assembled close to 200 managers in charge of safety in the facilities. They were able to discuss the challenges of shared safety within the group aimed at integrating the new French regulatory obligations as efficiently as possible while maintaining an approach proportionate to the issues and to the continuous improvement of risk prevention. The convention offered an opportunity for insights and discussion of key topics of current interest. The talks centered on operational implementation of the new regulatory obligations, the safety review process, mobilization of skills and resources, and contractor involvement. Four key messages emerged from the convention: sharing a single perception of the safety issues, improving the sharing of experience, defining responsibilities unambiguously, and referring to the robust culture and expertise existing within the group. The convention also heard assessments of AREVA s safety management from the French nuclear safety authority ASN and from WANO. I. Araluce (WANO) during the Convention P.F. Chevet (ASN) during the Convention 16

17 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES Lessons learned from the inspections and WANO s review The General Inspectorate conducted 34 inspections in 17 of the group s entities in 2014, including 3 which concerned sites outside of France. Of these, 3 were conducted following events or particular situations. These inspections gave rise to 146 recommendations which have been translated into action plans by the inspected entities. Twenty follow-up inspections were conducted to check the effective implementation of the actions and compliance with the schedules announced in the action plans. A specific report was devoted to each of these inspections. The General Inspectorate also took part in the peer review organized by WANO at the LA HAGUE site. BACKGROUND AND FINDINGS Lessons learned from the inspections The 2014 program of inspections by the General Inspectorate dealt primarily with themes aimed at the prevention of major risks associated with safety functions at the nuclear sites (fire, radiation protection, radioactive materials containment, and criticality). These themes accounted for one third of the inspections carried out. The second priority of the 2014 program concerned how safety is addressed in recurring activities. The themes analyzed are based on observations made during inspections carried out in 2013, current events at some sites, and observations of degraded situations. For example, the supervision of contractors was assessed at the LA HAGUE, TRICASTIN (EURODIF) and MARCOULE sites. The process for handling deviations was analyzed at the Installed Base France entity (services to utilities) and at the LINGEN site in Germany. The management of nuclear and occupational safety during maintenance and repairs was examined at the SAINT-MARCEL heavy component manufacturing site. The quality of training and chemicals management processes was verified at the RICHLAND site in the United States. construction of the living quarters and logistics building of the new Emergency Management Center. Another important area of investigation for the General Inspectorate involved the assessment of industrial safety and occupational safety measures. It conducted inspections of fire hazard management, machine tool compliance, lock-andtag procedures, and implementation of the action plan set up after inadequacies were found in 2013 in the Mabounié workshop at the BESSINES site. As part of the independent inspections requested by the French nuclear safety authority to check compliance with its decisions, the General Inspectorate assessed the existing internal authorization process at the LA HAGUE site and carried out bimonthly monitoring of implementation of the safety improvement plan at the ROMANS site. The General Inspectorate also conducted regular checks of transportation operations. Specifically, it looked into the supervision of shipments at the national and international levels, and at onsite transfers. A recurring area of attention for the General Inspectorate concerns a review of safety management measures implemented during an important stage in the lifecycle of a facility. It conducted two inspections on this subject at the TRICASTIN site concerning the REC II facility and project management measures implemented during 1 1- Inspection in 2014 at the RICHLAND site, United-States 17

18 BACKGROUND AND FINDINGS Lessons learned from the inspections and WANO s review Three non-routine inspections were carried out to help operators analyze deviations occurring during operations and define measures to be implemented so that they do not occur again. Implemented together, these inspections gave rise to 146 recommendations in 2014, all of which have been translated into action plans by the inspected entities. The 2014 inspections also prompted 6 requests for immediate action to deal with 23 situations deemed to present risk. Lessons learned by topic MAJOR RISKS RELATED TO SAFETY FUNCTIONS Radiation protection of personnel Three inspections were conducted at SOMANU, MALVESI and TRICASTIN to check the adequacy of radiation protection management processes. These inspections reinforced observations made in They pointed to proper oversight of regulatory compliance, both at the corporate level in the Safety Health Quality Environment Department and at the entity and site levels. A well-developed set of reference documents thus underpins structured organizations. However, operating procedures are not always followed with the necessary rigor on the floor, and the supervision exercised by supervisors and radiation protection personnel does not always detect inadequate behaviors, particularly when it comes to the wearing of dosimeters and monitoring at the exit from a regulated area. Radioactive materials containment Two inspections were conducted on this topic at MELOX and TRICASTIN to check the ability of material measures to contain radioactive products inside a given perimeter. Measures to control the dispersion of radioactive materials usually combine static and dynamic containment in response to defense-in-depth concepts, and a series of barriers or containment systems. The exceptional nature of the presence of radioactive materials outside the regulated area and the very low levels of contamination detected in those situations demonstrate good control of containment. The first findings confirm this observation, and inspections to be conducted in 2015 on this topic are expected to bolster it further. One area for improvement was nonetheless identified in the design (air flow diagrams, ergonomics), installation, compliance check and operation of mobile or permanent containment airlocks used for entry to and exit from areas with a risk of contamination. Nuclear safety criticality Two inspections on criticality risk management were conducted at LA HAGUE and TRICASTIN. The various lines of defense set up to prevent the risk of a criticality were significantly impacted by a certain number of events, prompting the affected sites to reassess their organization, operating processes and checks on the control of this risk. The conformity analyses and safety reassessments conducted during the 10-year safety reviews of the INBs also provided an opportunity to check the adequacy of measures contributing to criticality risk management as well as, to the extent necessary, to revise related practices and procedures. Here and there, these checks may increase the number of detected anomalies, but they are integral to the continuous improvement process and the constant search for the highest level of safety. 18

19 AREVA GENERAL INSPECTORATE ANNUAL REPORT 2014 STATUS OF SAFETY IN NUCLEAR FACILITIES The General Inspectorate s inspections on the criticality topic are part of these checks; they are conducted to ensure that the new provisions are effectively implemented and comply in particular with the requirements of ASN s criticality decision of 2014, made in implementation of the Order of February 7, These two inspections pointed out that operators pay particular attention to the subject of criticality risk prevention and that safety reviews have significantly challenged the robustness of the demonstrations and existing operating provisions. The keeping of operational documentation is a remaining area for improvement. 3 BACKGROUND AND FINDINGS Fire Four inspections were conducted at MELOX, TRICASTIN, MALVESI and JARRIE on consideration of the fire hazard. permits) and local managers (identification of the types and locations of hazards, strengthening of interfaces with external fire-fighting services). The areas for improvement mainly concern the completeness of the risk analysis done prior to hot work (e.g. consideration of the total volume surrounding the work area, including above and below) and the rigor with which preventive measures arising from the risk analysis are deployed. The management of the inhibition of fire detection systems during hot work could still be improved, in particular for a return to service as soon as possible after the end of the work. 2- Inspection at the MALVESI site, in Inspection at the JARRIE site, in 2014 Fire hazard studies, safety reviews and implementation of the resulting improvement measures were largely responsible for the continuous improvement in consideration of the fire hazard. This includes strengthened prevention measures in operations, such as control of heat loads or the management of hot work. In fact, the General Inspectorate found that constructional features and equipment performance are clearly improving. The fire prevention and firefighting organizations are also improving and are getting closer to the standards developed by AREVA under the impetus of corporate services (harmonization of conditions for using hot works 2 SAFETY MANAGEMENT Follow-up of commitments made to ASN in 2011 during the meeting of the Standing Committee on Safety Management and Radiation Protection In 2014, the General Inspectorate finalized inspections to assess the sites implementation of commitments related to safety management that had come to an end in 2013 and Its finding pointed to the involvement of AREVA s different entities in availability and use of an internal set of safety references This involvement will continue to be the subject of close attention for the General Inspectorate. Supervision of contractors The supervision of contractors was assessed at the LA HAGUE, TRICASTIN (EURODIF) and MARCOULE sites. 19

20 BACKGROUND AND FINDINGS Lessons learned from the inspections and WANO s review 4- REC II facility, TRICASTIN The finding is that the new regulatory requirements on the supervision of contactors have generally been adopted. This involved the training of 500 supervisors and improvement of the traceability of supervision activities aimed at ensuring that contractors comply with the safety requirements. The perfectible areas identified concern strict compliance with due dates for conducting supervision activities and the sufficiency of organizations set up to harvest operating experience from such supervision plans, which do not yet appear to be perfectly suited to the stakes at hand. The General Inspectorate also examined measures implemented by the contracting authority to provide supervision of project design and construction activities for the living quarters and logistics unit of the TRICASTIN Emergency Management Center carried out by external contractors. Start-up of the repackaging, sampling and control facility (REC II) The General Inspectorate reviewed the conditions for transition from the construction phase to commissioning, followed by start-up of the REC II facility. Based on the positive experience with restart of the North and South centrifugation plants at the Georges Besse II INB, this transition was managed by creating an integrated organization (contracting authority, project management and future operator) and through Internal Authorization Committees for Startup under the responsibility of 4 the future operating teams. The main observation concerns the strengthening of the transition from project management processes to operator processes. Transportation Shipments were the subject of two inspections. The first concerned the efficiency of AREVA TN International s supervision of shipments, while the second concerned the quality of internal shipments managed at the TRICASTIN site. The Transportation Supervision Department of the Nuclear Logistics Operations entity supervises all of AREVA s nuclear materials shipments. This organization has turned in satisfactory performance in shipment follow-up coordination and in transportation-related emergency management. Internal transfers at the TRICASTIN site are governed by an Internal Radioactive Transfers regulation that is incorporated in the general operating procedures of the different INBs at the site. Broader pooling of logistics operations has just been instituted as part of the site reorganization. The objective is greater harmonization and optimization of processes used at the site. OCCUPATIONAL SAFETY IN THE WORKPLACE Lock and tag procedures The lock and tag process of AREVA TA CADARACHE was assessed in The General Inspectorate had issued a generic recommendation on this subject in 2013 concerning minimum information to be displayed on items subject to lock and tag procedures as well as conditions for lock-off and the use of key interlocks. To follow up on its recommendations, a situational analysis was performed during inspections conducted in AREVA s sites have begun to revise their lock and tag procedures and to adapt them to practices on the floor. The inspectors noted that actions launched in the past three years are taking shape. The lock and tag process for hazardous electrical, mechanical and fluid circuits nonetheless remains a point for particular attention and will continue to be closely followed by the General Inspectorate. 20