ASN Report on the state of nuclear safety and radiation protection in France in 2018
The Nuclear Safety Authority presents its report on the state of nuclear safety and radiation protection in France in 2018.
This report is required by Article L. 592-31 of the Environment Code.
It was submitted to the President of the Republic, the Prime Minister and the Presidents of the Senate and the National Assembly and transmitted to the Parliamentary Ofﬁce for the Evaluation of Scientiﬁc and Technological Choices, pursuant to the above-mentioned Article.
Maintaining safety margins,
Mobilisation of the competencies in the nuclear sector:
Three challenges for nuclear safety and radiation protection in France
Nuclear safety and radiation protection were on the whole maintained at a satisfactory level in 2018. Technical dialogue with the licensees and the activity managers enabled the subjects to be dealt with in sufficient depth, with regard to the nuclear safety and radiation protection issues.
- In the nuclear industry, time-frames are long. If something is not initiated or demonstrated in the short term, it will not be operational in 10 years’ time. It is ASN’s role to encourage the stakeholders to anticipate whenever nuclear safety or radiation protection are at stake.
It does this with respect to the consistency of the nuclear fuel cycle and the management of radioactive materials and waste. In the future, it will do so for the implementation of the future multi-year energy plan, but also in the medical sector, when technological or radiopharmaceutical innovations require that specific radiation protection issues be taken into consideration beforehand.
- Faced with potential hazards, faced with the ageing of facilities or the possible discovery of a hitherto unidentified fault, the licensees must make sure that they keep sufficient margins for safety and do not seek to reduce them with a view to optimization or to justify retaining the status-quo. ASN must remain vigilant on this point.
- The nuclear sector must devote efforts to maintaining and developing the key industrial competencies vital to the quality of the work done and the safety of the facilities. Difficulties in the performance of conventional industrial operations (welding, electromechanical work, civil engineering and non-destructive testing), were encountered during the construction of new facilities and during work on facilities in operation. These difficulties have raised doubts regarding the ability of the sector to carry out the large-scale work involved in the continued operation of the existing facilities, decommissioning or the construction of new reactors, with the required level of quality.
This situation requires a collective and strategic re-engagement by the industry on professional training and on industrial competencies, in order to achieve the level of quality and safety expected of the nuclear sector. This process, initiated notably with the creation of the French Nuclear Energy Industry Group (GIFEN), must now be intensified.
In the nuclear field
The fuel cycle consistency analysis entailed extensive mobilisation on the part of the licensees and led to a comprehensive, up-to-date and forward-looking view of the safety issues and of the spent fuel storage capacity needs.
The EDF and Framatome review of all the dossiers concerning the forged parts produced at Le Creusot was carried out within the time-frame.
The licensees are aware that management of facilities ageing and of maintenance operations, along with compliance of the facilities with their safety requirements, still need to be improved.
For all the licensees, the recovery and packaging of legacy waste, along with decommissioning operations, are still experiencing difficulties which lead either to delays, or to changes in strategy following several years of study. In these areas, particular vigilance is required concerning the key factors that are project management and the resources allocated to execution of these operations.
Finally, an excessive number of deviations is still being found in the large-scale works carried out during reactor outages and in the manufacturing of new equipment.
In the medical field
ASN considers that the state of radiation protection remained stable in 2018 with the professionals on the whole giving satisfactory consideration to radiation protection, with the exception of fluoroscopy-guided interventional practices.
The number of Significant Radiation Protection Events (ESR) reported to ASN in 2018 rose on the whole, but the vast majority of them were level 0 or 1 on the asn‑sfro scale and thus with no expected clinical consequences.
The persistence of radiotherapy events of a recurring nature, rated level 2 in 2018 (dose error or laterality error for example), requires an in-depth analysis of their causes and reinforcement of prevention measures.
The nuclear fuel cycle: significant progress in 2018
ASN periodically examines the overall consistency of the industrial choices made by EDF, Orano Cycle, Framatome and Andra to ensure that the fuel cycle is well-managed in terms of nuclear safety and radiation protection issues.
In this context, the need for new spent fuel storage capacity was identified. EDF sent the safety options dossier for a centralised storage pool project. Following an assessment in 2018, ASN will issue an opinion in 2019.
In 2018, ASN issued its opinion on the fuel cycle consistency dossier for the period 2016‑2030. It considers that this file satisfactorily presents the consequences of different fuel cycle evolution scenarios on the facilities, on transport operations and on waste. However, the consequences of unforeseen events which could affect the operation of the cycle need to be studied in greater depth. ASN underlines the risk of saturation of the spent fuel storage capacity if no new facilities are built, as well as the need to anticipate any strategic evolution in the operation of the fuel cycle at least ten years in advance.
In this respect, ASN asked the industry to examine, with regard to nuclear safety and radiation protection, the consequences of the multi-year energy plan on the nuclear fuel cycle, each time it is revised.
Prevention, detection and handling of fraud: progress made in 2018
The EDF and Framatome review of the manufacturing files for all the forged equipment from the Le Creusot plant was completed in 2018. The ASN analysis of this review on each reactor revealed no new deviation prejudicial to their safety, which would have required corrective measures prior to their restart authorisation. Some additional controls or tests however still need to be carried out. The EDF and Framatome examination of the manufacturing files of cast parts is continuing.
In 2018, ASN defined and deployed an action plan designed to optimise the prevention, detection and handling of suspected cases of fraud. At its request, the industry reinforced its measures in this area. ASN has enhanced its own oversight process with specific provision for fraud detection during the course of inspections. It also provided whistle-blowers with a new service on its website, enabling fraud or falsification alerts to be collected and processed.
Continued operation of the 900 MWe reactors: the high level of mobilisation must be maintained
In 2018, with the support of IRSN, ASN continued to examine the fourth periodic safety review of the 900 MWe reactors, in order to define the conditions in which they can continue to operate. ASN will issue a resolution on the generic part of the reactor periodic safety review at the end of 2020. The review will then be carried out reactor by reactor: it will start with Tricastin 1 and run until 2030.
The inspections performed and the deviations detected show that the compliance of the facilities with their safety requirements needs to be reinforced: Management of this compliance will thus be a key aspect of ASN oversight in 2019, more particularly during the reactor conformity checks.
Periodic safety reviews for facilities other than power reactors: an approach proportionate to the issues
Since 2017, the licensees have been carrying out periodic safety reviews of several tens of facilities (research, fuel cycle, decommissioning, waste, radiopharmaceuticals, irradiators). ASN has implemented an examination method commensurate with the issues. Some facilities warranting particular attention, owing to the risks inherent in the activity and the nature of the radioactive substances they contain, or because they were designed on the basis of old safety standards, will be subject to an in-depth examination.
Flamanville EPR: significant work still to be done by EDF
The Flamanville EPR reactor is designed to provide a higher level of safety than the reactors currently in operation.
ASN stresses the fact that EDF still has a significant amount of work to do before fuel can be loaded into the reactor, in order to demonstrate compliance of the facility with its safety requirements.
Construction work and equipment manufacturing have experienced numerous difficulties, mainly due to a loss of experience in the performance of major construction sites. These difficulties also indicate shortcomings in the licensee’s monitoring of certain activities on the construction site. The approach proposed by the latter for dealing with the anomalies detected in the main steam system pipe welds is currently being examined. ASN will issue its opinion on the acceptability of this approach in 2019.
ASN will be particularly vigilant with regard to the satisfactory performance of tests prior to start-up and to the handling of any deviations. Furthermore, the results of tests performed on the EPR reactors abroad and exchanges between safety regulators will enable ASN to identify particular topics that require reinforced attention and oversight.
Waste: an issue involving numerous stakeholders
The Cigéo project for the deep geological disposal of high and intermediate level long-lived waste reached a major milestone in 2018, with the ASN opinion on the safety options dossier. The project as a whole has reached a satisfactory level of technical maturity. Certain subjects however still require additional work before the creation authorisation application can be submitted. ASN more particularly issued additional requests concerning bituminised waste packages and a multi-disciplinary expert review is in progress on these aspects. Andra intends to submit the creation authorisation application for this disposal centre in 2020. It will take account of the ASN opinion issued regarding the safety options dossier.
In conjunction with the Ministry responsible for Energy, ASN was closely involved in drafting the project management report and in preparations for the public debate concerning the next National Radioactive Material and Waste Management Plan, organised by the National Public Debates Commission (CNDP). This report aims to shed light on the main questions submitted to the debate, more particularly the management of materials, spent fuel storage needs, the management of very low level waste and of higher level wastes, as well as on the practical arrangements of the industrial phase of the Cigéo project.
In 2018, ASN also examined CEA's strategy for decommissioning and waste and materials management. Jointly with the Defence Nuclear Safety Authority (ASND), this for the first time concerned all civil and defence-related facilities. It notably examined the prioritisation of operations according to their nuclear safety and radiation protection implications, so that CEA could more efficiently manage these large-scale projects at a time of a constrained budgetary context. ASN will issue its opinion on this strategy in 2019.
Medical: persistence of points requiring particular attention and the need for anticipation
Improving the analysis and prevention of significant radiation protection events
The overall increase in the number of ESR notified indicates greater transparency, in particular in nuclear medicine and radiology (conventional and computed tomography). However, for radiotherapy, the fall in the number of ESR notified that has been observed since 2015, continued in 2018. The causes of this drop should be identified.
In 2018, ASN observed that the number of serious ESR notifications was still high. To prevent such events, with the support of a multidisciplinary expert group and as part of a continuous improvement approach, ASN aims to achieve broader publication of recommendations and summary documents intended for those in charge of the activities. Under ASN coordination and following on from the work done on radiotherapy Operating Experience Feedback (OEF), this expert group will in 2019 exploit national OEF about the most serious or frequent ESR in the imaging and nuclear medicine fields, reactively and operationally.
At the same time, in conjunction with the learned societies, a review will be carried out on the scales currently used for the ESR classification and the changes that would appear to be needed.
Continuing the graded approach to oversight
In 2019, ASN will continue to deploy tools for a graded approach to radiation protection oversight. The actions undertaken as of the end of 2017 will be supplemented by decisions concerning the new registration system, which could more particularly concern fluoroscopy-guided interventional practices and scanners.
Anticipating technological change
A committee to analyse new medical practices or technologies using ionising radiation will be operational in 2019 in order to ensure that they are deployed under the best radiation protection conditions for patients, personnel and the environment. This committee could notably recommend prospective data collection and support measures for professionals.
Source security: continued implementation of oversight
In 2018, ASN contributed to the preparation of the “Source Security” Order, which is coordinated by the Ministry responsible for Energy, and it made changes to its internal organisation for the management of sensitive information. Measures to implement source security oversight will continue in 2019.
Nuclear accident management: improvement actions to be continued
The nuclear crisis management system in France is robust. However, the emergency exercises need to be carried out in mobilisation conditions that are more representative of the organisations and they should more closely involve the populations living in the vicinity of the nuclear facilities.
ASN is working with all stakeholders to revise post-accident doctrine, so that it is simpler and more operational. The increased radius for the distribution of stable iodine tablets around the NPPs from 10 to 20 km and the performance of a major exercise will also help improve the nuclear accident management system.
International: new steps in the sharing of good practices
The first Topical Peer Review planned by the European Directive on Nuclear Safety concerned the management of nuclear reactor ageing. This review, held under the aegis of ENSREG (European Nuclear Safety Regulators Group), enables practices to be compared and led to recommendations regarding ageing management. It showed that the approach adopted by the European countries was satisfactory with regard to power reactors and that it should be extended to research reactors. In 2019, each country will draw up a national action plan to incorporate the conclusions of this review.
France hosted an Artémis peer review mission as required by the European Directive on Radioactive Waste Management, carried out under the aegis of the International Atomic Energy Agency (IAEA) to examine the organisation in place for managing radioactive materials and wastes. The review pointed out that the French system covered all the issues and presented many strong points, more particularly in terms of skills and the continuous progress approach. Areas for improvement were identified, for instance effective performance of dismantling as short as possible and optimisation of very low level waste management. These conclusions were made public in a report.
ASN continued its involvement in the sharing of good practices in the field of radiation protection. For example, in accordance with the justification principle, it proposed replacing the use of high-level sealed sources with an alternative technology.
ASN financial resources: the system must be more robust
The resources dedicated to the regulation and oversight of nuclear safety and radiation protection remain a sensitive subject. In its final observations issued at the end of 2018 following its inspection of ASN, the Court of Audit notably pointed out that the contribution from several budgetary programmes meant that the total cost of external oversight of civil nuclear safety in France was difficult to identify clearly. Moreover, in the light of the major issues involved in the oversight of nuclear safety, the Court of Audit recommended that financing arrangements more appropriate to ASN’s duties and working methods be implemented, in order to consolidate its independence and free it from budgetary regulation mechanisms. ASN will continue to address this subject in the future.