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ASN observes the working of the organisations put into
place by the licensees mainly through inspections, more
specifically those devoted to safety management.
During the various periodic safety reviews of the Areva
plants, ASN examines themanagement processes which
it was not possible to deal with during the overall safety
management review, the conclusions of which were
sent to Areva on 21st September 2012. A final opinion
will be issued on all the national and local management
processes following all of these reviews, which will be
completed in 2018.
For 2016, ASNwill be particularly vigilant in ensuring that
the wide-ranging reorganisation announced by the Areva
group does not compromise the progress made in safety
management across the group. The group announces that
on the one hand its nuclear fuel conversion, enrichment
and reprocessing activities should be brought together
within a new unit and that, on the other, the nuclear
fuel fabrication and nuclear equipment manufacturing
activities should be brought together within an entity
jointly-owned by several industrial groups. In accordance
with the law, the entities which, as a result of this split-up,
will become licensees of existing BNIs within the Areva
group, will need to prove to ASN that they do in fact
have the technical and financial capacity to assume their
nuclear safety responsibilities.
Examining the measures taken by the Areva group
head office departments in terms of safety
ASN’s regulatory actions also cover the Areva head
office departments, which are responsible for the
group’s safety, radiation protection and environmental
protection policy. ASN looks at how they draft and
ensure the implementation of this policy in the various
establishments within the group. In 2015, ASN continued
with the actions taken in 2013 concerning on the one
hand the identification of the systems, structures and
components of the “hardened safety core” as part of the
post-Fukushima process and, on the other, integration
into the BNI baseline safety requirements of the new
provisions of the Order of 7th February 2012, more
specifically with regard to the identification of the
elements important for protection and their associated
safety requirements, on-site transport operations and
controlling the impact of nuisances generated by
the facilities. The 2015 inspection of the head office
departments found that the group had made significant
progress in formally defining its safety policy and how it
is implemented. Areva is however significantly behind
schedule in integrating EIP regulations (these regulations
aim to ensure that each element of a BNI on which the
licensee has built this BNI’s safety case does actually
meet the requirements stipulated in this safety case).
3.3.1 Taking account of social, organizational
and human factors
Formalisation of the way Social, Organisational and
Human Factors (SOHF) are taken into account really
began in 2005-2006 for the fuel cycle installations, with
the drafting of internal policies specific to each licensee.
This approach began to be centralised within the Areva
Group as of 2008, which is when the Group’s head
office departments started employing SOHF specialists.
Since then, a national policy has been developed and is
being gradually deployed among the group’s licensees.
The GPUmeeting held in 2011 on safety management
at Areva also enabled development and follow-up of
the SOHF measures adopted. ASN considers that this
approach must be continued for it to fully bear fruit.
Most of the various licensees within the Areva Group
are now staffed with persons competent in SOHF.
During the course of 2015, Areva developed its action
plan for implementation of the objectives defined in
its nuclear safety policy.
At the same time, ASN began to examine the deployment
in the BNIs of the safety management tools created by
Areva in response to the group’s undertakings to the
Advisory Committee in 2011. This approach aims in
particular to assess the effectiveness of implementation
in the field of the directives and guides produced by
the group’s head office departments.
With regard to the emergency organisation in an extreme
situation, the Areva head office departments satisfactorily
assisted the sites with the initial deployment of the SOHF
methodology definedwithin the context of the stress tests.
However, in 2014 and 2015, the head office departments
delegated deployment of these methodologies to the
sites, but did not retain sufficient coordination and
oversight capability for these deployments. In 2016,
ASNwill therefore pay particular attention to consistency
between emergency organisations in the event of extreme
situations, on Areva’s different nuclear sites.
3.4 Fuel cycle consistency
ASNmonitors the overall consistency of the industrial
choices made with regard to fuel management, fromboth
the safety and the regulatory viewpoints. To do this, on
the basis of the “Cycle impact” file transmitted by EDF and
drafted every ten years with the fuel cycle stakeholders,
Areva and Andra, ASN reviews the consequences for
the various steps of the fuel cycle of EDF’s strategy
to use new fuel products in its reactors and new fuel
management processes.
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CHAPTER 13:
NUCLEAR FUEL CYCLE INSTALLATIONS
ASN report on the state of nuclear safety and radiation protection in France in 2015