specific or rare expertise, as well as 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 exercise its responsibility as licensee with regard to the protection of people and the environment and to be able to effectively monitor the quality of the work performed by the subcontractors. Poorly managed subcontracting is liable to lead to poor quality work and have a negative impact on the safety of the facility and the radiation protection of the workers involved. EDF takes the necessary steps to control the risks associated with the subcontracted activities and regularly updates them. EDF has thus reinforced the preparation of reactor outages, more particularly to guarantee the availability of human and material resources. 2.5.2 Assessment of maintenance and subcontracted activities Maintenance of the installations Maintenance of the NPPs is also subject to regular checks by ASN during its inspections. In 2024, ASN considers that the management of the quality of maintenance activities in the NPPs is relatively satisfactory. In this respect, ASN observes that the various sites deployed EDF’s changes to the maintenance policy and that their organisation enables them to successfully carry out the required maintenance work. ASN nonetheless finds that the significant industrial workload on some sites is an obstacle to the adoption of these changes and sometimes places them in a difficult situation. ASN views positively that the number of significant events caused by an anomaly during a maintenance operation has decreased since 2022. ASN however finds that when certain maintenance work is performed, monitoring, first level analyses and requalification tests were not sufficient, because they did not systematically detect all the equipment anomalies. EDF must continue its ongoing work on the competence of the personnel and improve preparation for maintenance activities, how experience feedback is taken into account and the quality of the risk assessments, against a backdrop of a significant industrial workload linked to continued operation of the reactors and the “Major overhaul” programme. Finally, spares management remains a source of problems in the control of maintenance work, that was already identified in 2022 and 2023. Several maintenance operations had to be cancelled in 2024 owing to a lack of spare parts, either because the spares were unavailable or because of procurement delays, or for reasons of nonconformity of the spare part received. ASN considers that it is important for EDF to continue with its efforts to remedy the difficulties encountered. The organisation for performance of maintenance ASN notes that the scheduling of maintenance work has clearly improved on most NPPs, even if there are still problems of coordination with the other disciplines and the project teams. Moreover, ASN’s examination of the maintenance programmes for the equipment of the primary and secondary systems regularly reveals errors and omissions that EDF has to correct before they can be applied. Management of subcontracted activities ASN checks the conditions surrounding the preparation (schedule, required resources, etc.) and performance of the subcontracted activities (relations with the licensee, monitoring by the licensee, etc.). It also checks that the workers involved have the means needed (tools, operating documentation, etc.) to perform their tasks, in particular when these means are made available by EDF. A number of improvements have been observed since 2023 in quality management of subcontracted activities. ASN also observes a very positive move within the NPPs to improve the skills of the contractors. EDF is implementing tangible measures, such as the increase in the provision of spaces for preparation work on a mock-up. However, there are still difficulties regarding the quality of the monitoring provided (inappropriate monitoring plans, Oversight of suppliers of equipment important for nuclear safety In 2024, ASN carried out 68 inspections of the procurement chain for safetyimportant equipment intended for NPPs. These inspections checked the manufacturing processes used by the suppliers, their organisational provisions and the monitoring carried out by EDF. Of these inspections, 45 were linked to NPE manufacture and the procurement of components intended for the first EPR 2 reactors and the EDF reactors in operation. These inspections took place in France, Spain, Italy and Japan, in the plants of the NPE manufacturers and their subcontractors (forging and casting). ASN was thus able to check the quality of manufacturing and how the manufacturers, the approved organisations for evaluation of the conformity of equipment and EDF assumed their responsibilities for oversight of procurement. The inspectors found good practices in the performance of the activities entrusted to the outside contractors as well as progress in the dissemination of the safety culture, notably thanks to the deployment of standard ISO 19443 within the companies. These inspections however also revealed gaps in knowledge and a lack of dissemination along the supply chain of certain regulatory or technical requirements, shortcomings in management of the implementation of processes, as well as the need to improve the quality of EDF’s monitoring. In some cases, the inspections also showed that the suppliers’ organisational procedures needed to be reinforced, along with their safety culture. In 2024, ASN published a practical guide in French and English, intended for the equipment suppliers and their subcontractors. The purpose of this guide is to make the regulations and their objectives more accessible. It explains the design and manufacturing requirements for safety-important equipment, as well as the industrial practices that ASN considers to be satisfactory. The principles described are illustrated by industrial examples, with a resolutely practical approach. Counterfeit, falsification and suspected fraud in the nuclear field F urther to the detection of new cases of suspected fraud in the nuclear sector, the ASN Commission held a hearing of the EDF Chief Executive Officer on 26 February 2024. At a time when new projects are being launched and given the findings of recent years, the fight against fraud at all levels of the subcontracting and procurement chain must be a point meriting particular vigilance for the entire nuclear sector. It is thus primarily up to the licensees, who are responsible for nuclear safety, to prevent fraud, detect it and take steps to put an end to it. ASN thus asked EDF to significantly strengthen its organisation, as well as the steps it planned to take to intensify the fight against fraud in its subcontracting and procurement chain, whether for its reactors in operation or those under construction or planned. ASN stressed the importance of building this action plan on an identification of the root causes leading a person or organisation to commit fraud. The action plan defined by EDF is currently being implemented operationally. In 2025, ASNR will continue to monitor this implementation and check its actual application. 312 ASN Report on the state of nuclear safety and radiation protection in France in 2024 The EDF Nuclear Power Plants
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