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for the protection of the interests mentioned in the
same Article L. 593-1 when they are performed by
outside contractors and must ensure that these outside
contractors have appropriate technical expertise for the
performance of said activities. It may not delegate this
monitoring action to a service provider.
The Order of 7th February 2012 setting the general rules
for BNIs requires that the licensee monitor the activities
performed by outside contractors, in order to ensure that
the operations they perform comply with the defined
requirements and, more generally, that they apply the
nuclear safety, radiation protection and environmental
protection policy defined by the licensee. The licensee
must also ensure the availability of a sufficient number
of contractors with the expertise needed to perform the
maintenance operations required to ensure the safety
of the reactors.
ASN carries out inspections on the conditions in which
subcontracting takes place at EDF. ASN in particular
checks EDF’s implementation of and compliance
with a process to ensure the quality of the activities
subcontracted: the choice of contractors, monitoring
of the work done, integration of experience feedback
and adequacy of the resources for the volume of work
to be done. For its labour inspectorate duties, ASN
also pays close attention to worker protection, notably
compliance with health and safety rules and working
and rest times, and checks the legality of the service
contracts, in particular assessing the independence of
the subcontractors carrying out the service from the
ordering customer.
2.8.2 Correction of deviations
The checks carried out at the initiative of EDF and the
additional verifications requested by ASN can lead to the
detection of deviations from the defined requirements
1
,
whichmust thenbe processed. These deviations canhave
a variety of origins: designproblems, constructiondefects,
insufficient control of maintenance work, degradation as
a result of ageing, etc.
The measures for detecting and correcting deviations,
as prescribed by the Order of 7th February 2012 setting
out the general rules for BNIs, play an important role in
maintaining the level of safety of the facilities.
1. The Order of 7th February defines the notion of deviation
as
“non-compliance with a defined requirement,
or non-compliance with a requirement set by the licensee’s
integrated management system liable to affect the provisions
mentioned in the second paragraph of Article L. 593-7
of the Environment Code”.
“Real time” verification
The performance of periodic tests and preventive
maintenance programmes on the equipment and systems
helps identifydeviations. Routine field inspections are also
an effective means of discovering faults.
Verifications during reactor outages
EDF takes advantage of nuclear reactor outages to
carry out maintenance work and inspections that
cannot be performed when the reactor is in service.
These operations are mainly used to remedy anomalies
already identified, but also lead to the detection of new
anomalies. Before each reactor restart, ASN asks EDF
to identify any anomalies not yet remedied, to take
appropriate compensatory measures and to demonstrate
the acceptability of these anomalies with respect to
the protection of persons and the environment for the
coming operating cycle.
The defined requirements
The Order of 7th February 2012, amended, states that
a defined requirement is a
“requirement assigned to an
Element Important for Protection (EIP), so that, with the
expected characteristics, it performs the function stipulated in
the safety case mentioned in the second paragraph of Article
L. 593-7 of the Environment Code, or to an Activity Important
for Protection (AIP) so that it meets is objectives with respect
to this safety case”.
For the EIP, these requirements can in particular concern:
• the characteristics of the materials used;
• the manufacturing, assembly, erection and repair
processes;
• the physical parameters and criteria characteristic
of the performance of the EIP.
For the AIP, these requirements can in particular concern:
• the skills needed to perform the activity;
• any qualifications necessary;
• checks and hold points;
• the equipment and hardware needed to enable the activity
to be carried out in accordance with the regulatory or even
contractual requirements, such as to guarantee compliance
with the safety case.
UNDERSTAND
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CHAPTER 12:
EDF NUCLEAR POWER PLANTS (NPPs)
ASN report on the state of nuclear safety and radiation protection in France in 2015