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inappropriate, incomplete, overly complex or unsuitable.

ASN has repeatedly observed this situation for several

years now, thus calling into question the efficiency of the

documentary drafting and revision process in use at EDF,

in particular given that these inadequacies can make for

difficult working conditions for the personnel and thus

degrade performance, possibly leading to the occurrence of

significant events. The difficulties linked todocumentation

are increasingly spotlighted in the assessments carriedout

by EDF following significant events.

In addition, accessibility and the physical working

environment (light, heat, noise) is continuing to create

difficult working conditions. On several sites, ASN thus

observed inefficient public address and lighting systems

in the reactor building. ASNdid however note that certain

sites were making efforts in this field.

Staffmembers are also facedwith constraints relating to the

organisation of work, in particular during reactor outages,

such as inadequate preparation for certain activities,

scheduling changes and problems of joint contractor

work and coordination between those involved. These

constraints can lead to degraded working conditions.

Provisions concerning staff and organisations

in operational reactor modification activities

At the national level, EDF has developed the “Social,

Organisational and Human – SOH” approach, the aim

of which is to transform engineering practices at EDF,

to take greater account of people and organisations in

the changes made to the systems and in modifications

to hardware and organisations, as of the design stage.

ASN considers the philosophy of the SOH approach to

be pertinent and important in guaranteeing the security

of the facilities and the safety of the workers. However,

the efforts made by EDF to deploy the SOH approach

- in particular in all the engineering centres - must be

continued in order to achieve the intended effects.

Hardware and documentationmodifications are mainly

managed at the national level, so the sites do not always

have the ability to implement changes necessary to improve

the working environment when a difficulty is identified

locally. The improvements made by the sites therefore

generally consist in implementing mitigation measures

rather than actually solving the problem itself.

Skills management, training and qualifications

The skills management, qualification and training

organisation in place on the sites is on the whole

satisfactory and the management processes well

documented and coherent. Most of the sites have set

up local training committees involving the executive

level, the management and the workers. One of these

committees rapidly detects staff training requirements

and, with the help of the production engineering training

unit, creates short and specifically targeted training

programmes according to the identified needs.

Generally speaking, the training programmes are

implemented satisfactorily and the establishment of

«academies» for the different professional disciplines is

highlighted as a strong point for the training of newcomers

to the sites. However, the training proposed by some

sites is not always adapted rapidly enough. Moreover,

the staff do not always receive the scheduled training.

Inadequacies on certain sites are however still being found

by ASN during the inspections, concerning succession

planning (GPEC). In several NPPs, certain departments

had still not produced a skills map in 2015, even though

this is the GPEC tool that enables the site to obtain a

dynamic, forward-looking picture of the professional

skills available over a five-year period. However, EDF is

on the whole making major investments in hiring and

training, in order to anticipate the renewal of the skills

threatened by staff retirements. Failure to anticipate

large-scale retirements in certain disciplines is still being

observed on a number of sites, leading to insufficient

headcounts and potentially leading to difficulties in having

more experienced personnel available for mentoring

the young recruits.

Given the level of retirements expected in the coming

years and the considerable work to be accomplished by

EDF subsequent to the stress tests or for the periodic

safety reviews, ASN considers that EDF’s recruiting and

training efforts must be maintained.

4.1.3 Health and safety assessment, professional

relations and quality of employment in the NPPs

On the whole, there is satisfactory compliance with

daily and weekly rest periods, although EDF could

further improve its compliance with ASN’s requests

concerning working hours, in particular owing to the

absence of a system for counting the time worked by

the management.

Greater consideration is being given to certain

occupational risks, such as those linked to welding

fumes. In addition, EDF’s announced expansion of

the duties of the «zone managers” to all aspects of

conventional occupational safety is a positive point.

However, constant attention to health and safety risks is

required at all times. Moreover, the presence of asbestos

in equipment if often identified belatedly, meaning that

the organisation of the work then needs to be adapted

accordingly.

Progress is still required in the management of multiple

contractors working simultaneously (quality of prevention

plans in particular) and the use of subcontracting

(combatting the illegal loaning of labour). ASN also

asked EDF to improve the distribution of operating

experience and best practices between the sites.

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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