Nuclear Risk Management Report Assystem 2018 Nuclear Risk Management Report

ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT

FOREWORD

This document is the sixth edition of the Assystem Nuclear Risk Management report, and the second one to be issued on an international scale, as the first years were focused on the French nuclear activities of the company.

It is addressed to Christian Jeanneau, SVP Nuclear, and aims to give a long-term perspective to all Assystem employees in nuclear, who are involved in nuclear safety along with their customers and the nuclear operators. I want to thank them all for their commitment and positive contributions to nuclear safety.

This report points out some achievements but also some weaknesses, which I am confident we will fix in 2019. In any case, they must be looked at as opportunities to foster our common nuclear safety culture, which is one of our first collective assets. In this report, the reader will also find some prospective ideas that might help meet some major upcoming challenges: our international development and the digitalisation of our world.

Jean-François Bossu, Nuclear Risk Management Director

4 TABLE OF CONTENTS

TABLE OF CONTENTS

FOREWORD 4 TABLE OF CONTENTS 5 1. ASSYSTEM NUCLEAR ACTIVITIES 6 1/ Long expertise of lifecycle developments 6 2/ Various types of projects and activities 6 • Nuclear Power Plants 7 • Fuel cycle facilities 8 • Innovative and Experimental projects 8 • Defence activities 8 • Dismantling and waste management activities 9

2. NUCLEAR RISK MANAGEMENT IN 2018 10 1/ Nuclear Risk management Scope 10 2/ Commitment to nuclear development 10 • Internal approach 10 • Openness to the outside 10 • Long term commitment to nuclear 11 3/ Nuclear risk challenges 11 • Feedback and safety culture 11 • Training 11 • Radiation protection 12 • Occupational safety 14 • Regulatory watch 14 4/ Quality in nuclear 14 • Quality assurance issues 14 • Certifications 15

3. FUTURE DEVELOPMENTS 16 1/ Nuclear safety culture in engineering 16 • Sharing at all steps 16 • Promoting engineering principles in nuclear safety 16 • HSE on construction sites and international projects 17 • Training e-learning 17 • Innovative projects and digital transformation 17 2/ Quality assurance issues 17 • International Standards 17 • Graded approach and Nuclear Safety culture 17 • Modification of Assystem administrative tools 18

4. CONCLUSION 19 1/ Main 2018 achievements 19 2/ Directions for 2019 19

5 ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT

ASSYSTEM 1. NUCLEAR ACTIVITIES

Being involved in nuclear since 1966, Assystem considers nuclear safety 2/ VARIOUS TYPES OF PROJECTS AND as key for future developments. Historically driven by the commissioning ACTIVITIES of facilities, Assystem nuclear activities now extend to technical design, operation support, maintenance planning and decommissioning. The global approach of nuclear safety issues aims at guarantying a This lifecycle approach naturally connects with system engineering, a seamless propagation of the nuclear safety concerns of Assystem discipline that is now starting to make an impact in the nuclear industry, customers, such as nuclear operators to all the stakeholders, within along with the use of digital tools and data analysis techniques in nuclear Assystem and its partners, at all the levels of the supply chain. This industrial activities. principle applies to all types of projects and activities. Therefore, Assystem nuclear safety culture and discipline embrace all the hh With more than 2.500 nuclear experts, among which activities listed below: 170 specialised in nuclear safety, Assystem has • Owner Engineer; become the leading independent European nuclear engineering company. • Project Management Office (PMO); • Architect Engineer; Nuclear safety keeps a special place in the system engineering approach, • Technical studies (site surveys, risk evaluation…); as the requirements brought by nuclear safety analysis have an impact on all the disciplines at stake in a nuclear facility. Assystem nuclear safety • Inspection (technical checks and conformity assessment…). experts play a key transverse role in all the nuclear projects. This holistic The digital methodologies and tools, such as data analysis, are not listed approach of nuclear safety extends worldwide, in particular in countries here because they do not appear as standalone activities yet. So far, that develop new nuclear power plant programs. they correspond to internal developments and apply to more classical engineering activities. Nevertheless, they are tightly linked to nuclear 1/ LONG EXPERTISE OF LIFECYCLE safety. This point is presented in the ‘innovation’ section of this document. DEVELOPMENTS The following diagrams describe the spectrum of Assystem activities:

Assystem activities initially started with the commissioning of the nuclear Nuclear Safety issues are common to most of these activities. Some fuel cycle facilities in France. This involvement in nuclear has never of them, such as compliance, inspection or nuclear risk analysis are decreased and has always been intimately linked to nuclear safety issues. directly linked to the nuclear safety discipline. Some others, such as In the UK, experience stretches back to the 1980’s in reactor build, digital engineering or project management tend to require more and submarine propulsion and waste management, all with an emphasis on more understanding of nuclear safety prescriptions and requirements. In the nuclear safety culture. the same time, standards put nuclear safety culture development at the Assystem nuclear expertise aims at proposing support to the nuclear forefront of nuclear engineering. This tendency is parallel to Assystem operators to: efforts to develop skills, encouraging cross-sectors experience for its engineers and technicians. • bring new developments, including time, schedule and budget optimization; hh Assystem intends to take advantage of various • operate performance enhancement and existing facilities life lifecycle activities and diverse projects types to extension; foster expertise within its technical teams in nuclear. • identify lessons learnt benefits to new generations of facilities;

• raise safety, environmental and securities issues. This cross-development between project stages is part of the foundations of safety culture, as defined by the IAEA. For instance, design activities Nuclear safety culture development is the backbone of these missions. must foresee future operations and dismantling must look back at all Therefore, Assystem long-term use of French regulations has always the previous phases. By extension, the nuclear risk management referred to international standards, such as IAEA guides and safety rules. discipline encourages operational teams of various fields (reactors, fuel This enables a seamless adaptation to new international programs, with cycle facilities, experimental processes…) to share and compare their new nuclear operators and unfamiliar local regulations. approach to nuclear safety principles.

hh At Assystem, the nuclear safety culture is shared and discussed as part of a constructive exchange, with employees, partners and contractors.

6 ASSYSTEM NUCLEAR ACTIVITIES

Figure 1 - Assystem activity spectrum

>> NUCLEAR POWER PLANTS (NPP) In Turkey

New build and Operation support In Akkuyu (Mersin province), Assystem was involved in the initial environmental studies for the 4 VVER 12001 reactors. In a first phase, Assystem contributes to design studies and to installation and Assystem performed some construction supervision activities. commissioning activities of new reactors, such as EPRs. For example, for the commissioning of Flamanville 3 EPR, Assystem currently mobilizes Independently, a second phase consists in leading on-site inspection for over 150 engineers and technicians. the construction and installation activities that are important for nuclear safety. The objective of this mission is to guarantee that the general In any country, nuclear safety related activities must comply with the local contractor and its subcontractors build ‘as per approved design’. This regulations and the nuclear operator internal prescriptions. NCIO2 phase is to last for a period of six years, under the framework of the Turkish law 30024 published in March 2017. It requires a specific hh Assystem company global processes promote the qualification by the Turkish nuclear safety regulator (TAEK). local analysis of regulations and best practices, in order to comply with operator and regulator In Saudi Arabia prescriptions, without deviating from internationally Under the authority of the King Abdullah City for Atomic and Renewable adopted nuclear safety principles Energy (K.A.CARE), Assystem has started siting operations in the perspective of the construction of a nuclear power plant. In that context, In the UAE Assystem completes a comprehensive and detailed site characterization and evaluation of two selected sites. Consequently, Assystem supports In Barakah, UAE, Assystem provides on-site engineering support of the 4 the Nuclear Site Licensing process by providing the preliminary APR reactors, owned by ENEC and operated by NAWAH. Site Evaluation Report (SER), the preliminary Environmental Impact This support started in 2013 with on-site CPO (chief program office), set Assessment (EIA) and the Preliminary Safety Analysis Report (PSAR) – ‘Site to ensure that the project meets technical and regulatory requirements characteristics and site parameters’ chapter. during the construction phase. The licensing process mission covers the In parallel, K.A.CARE has started the process of selecting the plant following disciplines: Mechanical Construction Management, Data technology, the supplier and the construction site for the first NPP. The Analysis, Quality Surveillance (Mechanical, Electrical, I&C, Civil, Piping), program will include nuclear waste management facilities and storages. support to Licensing process, material management and industrial safety management. Nuclear safety requirements are a common factor for all In Egypt these disciplines. In El Dabaa, the Egyptian branch of Atomproject (ASE is the engineering Assystem is also involved in the project and program management roles firm of Rosatom) builds the first of 4 VVER 1200 reactors, which will be across ENEC. Therefore, Assystem helped to establish the Program commissioned by 2026. Management Office (PMO), providing reporting, risk management, The El Dabba project is currently in a licensing phase in Egypt. Assystem change management controls, management culture and procedures. is involved in the project and provides engineering and project services Assystem also provides some other engineering and project services to the main contractor in various fields. During that phase, Assystem (operational readiness schedule, cost model). brings services for the coordination, management and performance

(1) VVER 1200 are generation 3+ PWR reactors generating 1.2 GW (2) Nuclear Construction Inspection Organisation 7 ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT

of the Independent Technical Review of Documents required to obtain Extending the lifetime of existing generation facilities is another challenge construction licenses and permits. This extends to the independent review in which Assystem is also deeply involved, for instance though I&C of technical solutions and documentation developed by subcontractors maintenance, PLM and nuclear safety case revisions. and the justification of the deviations induced by soil conditions. >> FUEL CYCLE FACILITIES In addition, Assystem brings support in adaptation of Construction Assystem is involved in all the fuel cycle activities, from front-end to back- Management Plan (CMP), Method Statement (MS) and Work Execution end, with the exception of uranium mining. This includes fuel processing Plan (WEP). and manufacturing, fuel reprocessing and temporary or final storage. In Finland Most of these activities are conducted by the main European nuclear Since 2015, Fennovoima leads the safety and engineering assessment fuel cycle operators: Orano and Framatome principally. On the front- work, necessary to obtain the construction license for a VVER 1200 end side of the fuel cycle, Assystem works with Orano in the Marcoule reactor in Hanhikivi. Since then, Assystem provides technical support to MELOX plant and with Framatome in its fuel manufacturing facilities. On assess the compliance of the VVER design with local regulatory norms the back-end, Assystem is involved in the long-term maintenance activities and standards. The reactor is expected to be operational in 2028. and the enhancement of la Hague fuel recycling plant.

As the future license holder at Hanhikivi Nuclear Power Plant, Fennovoima >> INNOVATIVE AND EXPERIMENTAL PROJECTS must demonstrate to the authorities how safety is taken into account at all Nuclear fusion stages of the plant lifecycle. Rosatom has selected Assystem for technical support to delivering the Preliminary Safety Analysis Report (PSAR), that As an active supporter of the ITER fusion reactor, Assystem contributes to shall meet the regulations established by the Finnish Nuclear Safety the design and construction of this first of a kind facility. Design office teams Authority, STUK. Fennovoima will issue this document of several thousand currently work on Tokamak equipment, while Engage and Momentum pages as part of the application to obtain the construction license. projects manage the construction and the installation of the buildings. In the UK Engage’s mission consists in providing architect engineer assistance and project management for all trades in the construction of the site facilities. At the Hinkley Point C site, EDF NNB is constructing two EPR reactors. Momentum is in charge of process equipment installation, which includes The project is in the civil construction phase. Assystem supports EDF by quality control and nuclear safety requirements conformity. Some other providing a quality control managed service, a key part of a Quality Assystem teams bring project management support. Directorate. A team of experienced QC engineers works on-site to Small and Modular Reactors ensure that quality requirements are communicated to suppliers and team- members, that everyone follows them and that a traceable database of In the UK, Rolls-Royce is developing a market-focused small modular compliance is created. This service includes importing LFE3 from other EPR reactor (SMR). The project is at the early concept and requirements projects, training and mentoring suppliers and team members. Assystem definition stage. It is based on a PWR reactor and is focused on is ready to extend its support to management of site engineering and achieving class-leading safety, build-cost and construction time targets, configuration management. In addition, Assystem currently works on the in order to provide operators with a safe, investable form of nuclear skills specification and the training model for future commissioning teams. power. Assystem’s involvement is targeted at Balance of Plant, Turbine Island, digitalisation, design optimisation and information management. hh At Hinkley Point, Assystem very much takes the In France, Assystem also proposes innovative design, to be applied to approach that ‘safety is synonymous with quality’ future SMR designs.

In France >> DEFENCE ACTIVITIES

In Flamanville, Assystem has brought support for the construction of the Most of the research and defence activities are conducted for CEA, first French EPR, from the construction phase, to testing and commissioning Technicatome and NavalGroup in France and Devonport, Babcock, activities. The Flamanville 3 project is indeed very cherished by AWE, Rolls-Royce and BAES in the UK. Of course, these activities Assystem’s teams, who have been involved in it since the early design are strictly separated and remain independent for security reasons. and safety studies. Nevertheless, on both sides of the Channel, Assystem teams follow a ‘safety through quality’ philosophy, including a graded approach With EDF, Assystem also brings services to the owner for operating assessment, early identification of safety and legislative standards, close NPP maintenance operations, including coordination of works and management of the ‘suitably qualified & experienced personnel’ (SQEP) configuration management. assessments and a learning from experience approach.

In France, Assystem provides engineering studies for the infrastructure hh Either from a design office perspective or as an on- updates of the nuclear naval bases and other nuclear deterrence facilities. site activity, nuclear safety and radiation protection experience is imperative for owner support In the UK, Assystem provides specialist engineering services to the Royal Navy’s fleet of nuclear submarines and the development and maintenance operations. of the UK’s independent nuclear deterrent. This support spans the whole lifecycle of those systems, including design and substantiation work, aimed at vessel, at-sea and dockside support.

(3) Learning From Experience

8 ASSYSTEM NUCLEAR ACTIVITIES

Figure 2 - Transfer hood for Cigéo waste packages

>> DISMANTLING AND WASTE MANAGEMENT ACTIVITIES In support of the decommissioning of the Chapelcross power station, Assystem conducted risk assessment and design substantiation of In France specialist lifting and transportation equipment and methodologies to Waste management for the French nuclear industry is the responsibility of enable road-shipment of outsize components for recycling and disposal. ANDRA4, who currently leads the Cigéo project of a deep repository for Assystem also provides support in the operation of legacy plants on highly active and long-lifetime nuclear waste, in Bure, France East region. the various sites including Sellafield, Dounreay, Harwell, Devonport, In this context, Assystem, in a consortium with CEGELEC CEM and Aldermaston. SPRETEC, designs the nuclear systems for transferring and handling the waste packages. Lifetime nuclear safety management is a key challenge in this project.

Assystem is also involved in dismantling and radioactive sanitation, mainly in CEA and Orano centres, throughout France. Therefore, Orano and CEA have qualified Assystem after an auditing process by experts of the two companies, under the control of their CAEAR5 commissions.

In the UK

At Sellafield nuclear site, within AXIOM, Assystem ensures value-added design solutions focused on hazard reduction, taking full account of the complete plant lifecycle. These solutions provide the Client with the benefits of accelerated decommissioning, improved performance of production operations and reductions in lifetime costs. Key activities in 2018 included detail design of the SIXEP contingency plant, concept design of upgraded hot cells and analytical facilities, and development of digital asset management tools and techniques.

Assystem is working with EDF Generation to provide advanced inspection capability to enable EDF to map the condition of the graphite structures at the heart of the AGR reactors. EDF has asked Assystem to use its expertise in optical metrology and image analysis to provide high quality inspection data that EDF will use to underpin the argument for continuing to operate the plant.

(4) Agence Nationale pour la gestion des Déchets RadioActifs (5) Commission d’Acceptation des Entreprises en Assainissement Radioactif - commission for the acceptance of radioactive sanitation companies 9 ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT

NUCLEAR RISK 2. MANAGEMENT IN 2018

1/ NUCLEAR RISK MANAGEMENT SCOPE backbone for nuclear safety in internal audits, resource management and training. They are completed by general procedures and more refined Since 2013, Assystem has grouped within the scope of its nuclear risk application instructions at the project level. management direction all the actions that contribute to the protection of the interests defined by French environmental laws. French and British For instance, the nuclear safety charter develops the following principles regulations and many other international standards link these interests to which Assystem is committed: (security, public health, wholesomeness and protection of nature and • Rigorous application of the laws, rules and safety baselines of its the environment) to objectives monitored by the quality systems of the customers, backed up by an internal control adapted to safety stakeholders. This logically extends to radiation protection and protection issues, of the workers, which originally refers to the Labour code in France. From this point of view, actions to develop safety culture and prevention are • Continuous improvement of processes and safety culture, through a complementary. constant effort in training and knowledge sharing, • Inclusion of social, organizational and human factors in the nuclear h h Continuous Training, Nuclear Risk Management, risk management approach, Quality and Occupational Safety departments work together towards a sound Assystem prevention • Confidence in technical exchanges and vigilance, which are necessary to ensure transparency of feedback of lessons learned. culture.

h In order to prevent the risk of a conflict between nuclear security and h The objectives attached to the nuclear safety operational requirements, the Nuclear Risk Management (NRM) director charter are an integral part of Assystem’s reports directly to the company General Manager. On a day-to-day commitment to responsible management, technical basis, the NRM is in direct contact with operational projects and relies on excellence and the development of the company’s an internal network of nuclear safety and radiation protection technical safety, security and environmental culture. referents. Oriented towards operations support, these groups constitute the main hotbed of the development of nuclear safety culture at Assystem. >> OPENNESS TO THE OUTSIDE The commitment of the operational departments in the same dynamics is the key to this development. In order to keep improving and to bring appropriate responses to more and more demanding nuclear safety expectancies, Assystem opens its 2/ COMMITMENT TO NUCLEAR expertise and participates in various groups in the field of nuclear safety. DEVELOPMENT This involvement can take various forms.

>> INTERNAL APPROACH Firstly, it can be technical. For instance, in 2018, Assystem participated in technical meetings about fire risk calculations with IRSN. Assystem The development of nuclear safety culture and, more broadly, of nuclear also takes every opportunity to join technical training or feedback risk control, is an enduring one. This effort is motivated by the shared sessions such as the ones organized in the field of radiation protection. concerns of nuclear operators for whom the risks generated by a service This technical implication in nuclear safety can also link to competitions, provider with a failing safety culture must be eliminated. Assystem such as the Spark6 contest. places this concern at the forefront of its actions. The presentation and understanding of the nuclear safety policies established by the nuclear operators is a prerequisite for all Assystem operations.

hh The increase in expectations by nuclear operators towards their providers corresponds to Assystem’s Secondly, Assystem brings experience to scientific societies or ambition to firm up nuclear risk management communities, such as RES, a society of authorities and companies involved in industrial risk, ASN with the CoFSOH7 group or the SFEN8 This commitment is declined through a nuclear safety policy and Nuclear society in France. In 2018, Assystem contributed to A3P9 a nuclear safety charter. These Assystem documents underline the international congress - a major pharmaceutical industry event - and continuous improvement approach already strongly developed in the presented a state of the art of nuclear safety and human performance fields of quality, safety and environmental protection. They constitute a in nuclear.

(6) Spark is a contest inviting current and former students of higher education in the UK and France to present innovative and novel thinking to contemporary energy challenges. (7) Comité sur les Facteurs Sociaux, Organisationnels et Humains, human performance committee headed by the French regulator, ASN. (8) Société Française d’Energie Nucléaire (9) https://en.a3p.org/ Association pour les Produits Propres et Parentéraux 10 NUCLEAR RISK MANAGEMENT IN 2018

Figure 4 - Timeline of quality for safety at Assystem

Figure 3 - A3P congress in Biarritz in 2018 3/ NUCLEAR RISK CHALLENGES

>> FEEDBACK AND SAFETY CULTURE This kind of event is an excellent opportunity to gather innovative ideas and best practices from sectors that share similar constraints, such as Assystem takes advantage from its lifecycle positioning in nuclear confinement or quality-driven issues. to enhance its system vision and wide angle nuclear safety culture Thirdly, Assystem has initiated a strong investment in integrating perspective. For instance, the feedback from services to operating NPPs young graduates in its teams. This brings new ways of exchange with is useful for design engineering or dismantling preparation studies. New engineering schools and universities, and a connection with the latest projects can also benefit from these crossed experiences. Once again, fundamental researches in the nuclear safety discipline. it is not a matter of data or detailed knowledge, but rather a question of understanding the logics that underline long-term safe nuclear operation. This extends to the UK too, where Assystem is an active member of the Nuclear Institute and chairs the NAFEMS10 technical committee. In late To realize this, Assystem organises frequent cross-visits between projects 2018, Assystem reviewed its Corporate Social Responsibility activities in order to help its engineers developing experience through feedback. in the UK. Assystem UK plans to increase its emphasis on this in 2019. More broadly, through its values, Assystem promotes a culture of nuclear >> LONG TERM COMMITMENT TO NUCLEAR prevention and safety that encourages personal thinking and helps to prevent ‘groupthink’ risk11. The nuclear safety charters set out the need for Of course, the nuclear culture that Assystem intends to develop through a positive, questioning culture and a context where issues can be raised internal and external exchange needs long term actions to be organized confidently. This approach includes independent third party reviews in topics, with a long term perspective. In 2018, Assystem drew this long of projects. In addition, efforts are been made for a better information term axis of development. So, Assystem is committed on strengthening sharing, seeking for various points of view, for the appraisal of group the following topics in the coming months: success and for a proper evaluation of risks, considering all their aspects.

• Crisis management and local feedback analysis; >> TRAINING

• Internal evaluation and e-learning; ‘Classic’ courses

• Identification of the risks and graded approach; The Assystem Nuclear Institute (ANI), an internal teaching structure • Nuclear safety culture principles sharing. created nearly ten years ago, is still developing, renewing and adapting its wide catalogue of training modules that are delivered in the field of To reach the associated goals, all the nuclear safety discipline expertise nuclear safety. This set of training modules has been labelized by the is welcome. The internal nuclear safety discipline network gathers senior French national nuclear institute INSTN12. specialists from all the types of activities and helps setting methodologies. This network is deeply involved in feedback analysis, training program definition and expert knowledge sharing. All network members are in direct connexion with the local teams. They intensively use digital tools A NEW HALLMARK / As a recognised expert in France and such as Microsoft Teams and Yammer. internationally, INSTN has been offering a Relevance and Effectiveness Quality Hallmark for our partners’ and clients’ The long term development of nuclear safety at Assystem can be put in training since 2017. The aim is to guarantee training relevance and perspective as in the next chart: effectiveness in terms of results, and demonstrate that it corresponds to operational needs. Built on our Institute’s educational and scientific This illustrates the last 5 years evolution, from an internal system focused expertise, this service is based on European standards for academic and professional training. As such, it enables our partners, such on the immediate French customers’ needs to a global integrated quality as Assystem Nuclear Institute, to benefit from our reputation for system dedicated to nuclear safety assurance at international level. excellence for promoting their own training. (INSTN annual report 2017) http://www-instn.cea.fr/media/instn-ra-2017-uk-v3.pdf

(10) NAFEMS is the International Association for the Engineering Modelling, Analysis and Simulation Community. (11) Groupthink is a psychological phenomenon that occurs within a group of people in which the desire for harmony or conformity in the group results in an irrational or dysfunctional decision-making outcome. 11 (12) Institut National des Sciences et Techniques Nucléaires - http://www-instn.cea.fr/en/ ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT

In late 2018, it was agreed that the ANI resource should be extended to The following illustrations are taken from the online courses that have the UK. Thanks to efforts in both countries, this has now been successful been prepared for teams working in France in the context of the INB and a pilot course is scheduled in Bristol in early 2019. order and for EDF:

hh Specific training courses on nuclear safety are delivered by senior members of the engineering team to small groups of staff, in order to encourage dialogue, questioning and mutual understanding.

The following chart illustrates the training efforts in 2018:

Figure 5 - Classic training by discipline in France in 2018

Courses with physical presence remain the privileged teaching way at Assystem, in particular when interaction with the teacher is essential for the transmission of knowledge. They systematically contain some practical implementation and an assessment of the understanding of the main points.

E-learnings Figure 7 – Images from e-learning courses The growth of the needs of trainings linked to the extension of Assystem activities and to the increase of the requirements by the customers has led E-learnings for INB order and EDF quality approach of safety constitute to developing new e-learning courses. the basis of the training, but various other customers worldwide require specific trainings, focused on local issues or regulations. In the UK, hh E-learning sessions are more flexible and allow the e-learning is more particularly used for delivering short training courses local managers to choose the most appropriate on compliance and HSE matters. moment for the training of their teams. hh Associated with online knowledge evaluation, The following chart illustrates the strong demand for these trainings e-learning has become a usual tool within and the effectiveness of the implementation of digital training in an Assystem. Meanwhile, classroom sessions remain engineering company as Assystem: the basis for the most technical training.

All these Assystem initiatives come in addition to external trainings, some of which are customer requirements and are organised in certified training centres.

>> RADIATION PROTECTION

Radiation protection of the workers is not only a legal responsibility for the companies working in nuclear, but also an objective indicator of the risk management by the local teams. At the local level, radiation protection reflects the quality of the job preparation, the understanding of the risks in the facility.

hh Radiation protection local organizations are an Figure 6 - E-learning progression indicator of the efforts made by operational teams to improve nuclear safety.

12 NUCLEAR RISK MANAGEMENT IN 2018

Therefore, Assystem monitors the dosimetry parameters of every In 2018, the increase in maximum doses was stressed by a calculation registered employee and compares these results with the preliminary artefact. As required by the regulation, doses are calculated over a radiation evaluations that are made before every activity inducting a 12-month rolling period. The maximum doses have been reached by ionizing exposure. In order to get the most significant values, average newly hired employees, who ‘brought’ with them doses integrated in doses are now systematically calculated on the basis of the workers who previous positions. Nevertheless, the issue of maximum doses will be actually integrate non-null doses. watched closely in 2019.

Operational results hh The Assystem internal objective of 5 MsV, as a The dosimetry operational results presented in the following chart show a maximum individual annual dose will help raise global reduction of the doses, both individually and collectively: alerts and initiate managing actions.

Dosimeter return delays

The measurement of the periodic dosimeters return delays is another indicator of the rigour of the radiation protection management. It shows the efficiency of the local managing teams in the collection of the dosimeters. The curve below shows that the efforts made by the local managers who handle the dosimeters must be sustained:

Figure 8 - Exposure of Assystem workers to radiation in France

This chart firstly reflects the collective reduction of the doses, which has two main origins: the efforts made to keep exposure at the lowest achievable level and a diminution of highly ionizing activities, due to the evolution of the contracts in operation services. Figure 10 - Dosimeter process anomalies follow-up Secondly, the convergence of the two dotted lines shows the efforts made This parameter illustrates the need of rigour in everyday tasks, even when to focus the categorization on the persons who are actually exposed the risk – the doses in that matter – remains as low as possible. In 2019, to ionizing radiation. This long term effort was undertaken in 2013 in the NRMD will undertake actions to mobilise the local managers on that response to a requirement from the French regulator (ASN). topic, which also have an impact on the employer responsibility.

hh As required by the regulation, the Assystem Radiation protection issues radiation protection monitoring focuses on the Even if the indicators and the reporting of non-conformities do not reveal activities in accordance with their risk for health. any major malfunction in the field of radiation protection, there is still concern among operational managers. Several causes contribute to this The collective radiation exposure at Assystem shows a long-term reduction impression, such as the high turnover of the radiation protection officers13 trend. However, when considering the maximum dose to which Assystem in France. These specialists have a regulatory mission, defined by the employees are exposed, the results look slightly different. As shown French Labour Code (R4451-110). Years ago, Assystem decided to rely below, the maximum doses rise: on them not only for radiation protection but also for on-site nuclear safety risk reduction and reporting. From the local managers point of view, they are key advisors on these topics.

hh Improving the organization of the radiation protection department is a priority as part of the development of the safety culture throughout the company.

This point will logically be one of the areas of progress for 2019.

Figure 9 - Maximum radioactive doses to Assystem workers in France

(13) Personne Compétente en Radioprotection : PCR and Technicien Qualifié en Radio Protection : TQRP 13 ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT

>> OCCUPATIONAL SAFETY For instance, international regulation is a major topic for data scientists or for Assystem training teams. The new GIFEN15 structure will also help Accident reduction is a paramount objective at the company level. addressing international regulatory issues. Assystem was ISO 4500114 certified in 2018 and the system is now fully efficient. Despite of this important evolution, the reduction of accident 4/ QUALITY IN NUCLEAR rates is still slow, as shown in the chart below. As every year, Assystem organised in 2018 a seminar, designed as For nuclear activities, occupational safety is watched very closely, an observatory for nuclear safety and quality. It was an opportunity because occupational safety often reflects organization issues and to gather operational and company support teams, and to share prevention attitude. important feedback from recent projects where nuclear safety was a key performance. This year, the conference floor was also given to EDF hh Assystem considers that an accident on a nuclear DPN, who presented the nuclear operator vision of digital nuclear safety. site is never a ‘classical’ accident. Through Human In the digitalization process, the seamless transition between quality Performance, it is always linked to nuclear risk. assurance and nuclear safety methodologies is essential. Nuclear safety targets such a high confidence level that only a strong and well Hence, despite the fact that no particular accident occurred in a nuclear understood quality system can fulfil the nuclear operators and regulators facility in 2018, occupational safety, as part of the global prevention expectancies. culture, remains a priority from the nuclear risk perspective. The chart below shows the global company figures in France: hh The strong and efficient relationship that links Quality and Nuclear Safety at Assystem remains a key asset in the company continuous improvement policies.

>> QUALITY ASSURANCE ISSUES

In 2018, in France, quality and nuclear safety teams conducted 42 internal audits and radiation protection specialists 7 specific audits. The conclusions of these audits are analysed in close relationship with the operational management. Each audit detects an average of 4 to 5 non-conformities, which initiate action plans. Other parties, such as the

Figure 11 - Accident frequency and gravity indexes in France nuclear operators or external assessment entities, can also detect the non-conformities. In the UK, the incidence of lost time accidents is of the order of one per million operating hours. This figure is regarded as typical for the sector. hh At Assystem, all the non-conformities are processed through a unique and shared process, which As for any other issue, Assystem conducts some kind of internal benchmark, in order to identify and take advantage of local best practices. In the guarantees the best treatment, regardless of their UK, Assystem takes a risk-based approach to occupational health and origin. safety. As local staff are predominantly office-based, the major risks that they face stem from display screen equipment, emotional and mental In this process, the quality system collected 11 non-conformities with an well-being and travel, especially driving. Monthly safety shares and impact on nuclear safety. Among these non-conformities, 6 were raised compulsory e-learning packages make sure these topics are given by third parties and only 2 have been closed. These two figures illustrate good coverage. As a new development in 2018, a number of UK staff the efforts that still need to be made to develop the company nuclear was trained to be mental health first aiders, able to support colleagues safety culture: with stress or emotional issues. All these actions contribute to human • More non-conformities should be raised internally, without external performance and hence to nuclear safety. intervention;

>> REGULATORY WATCH • The reactivity in the execution of the action plans must be increased.

For a few years now, Assystem has been using Amadeo, an external These two points may look very critical, and they will be if they are not service for nuclear risk regulatory watch, provided by Bureau Veritas. corrected in 2019. Nevertheless, it is important to keep in mind that This service focuses on French regulation. As Assystem nuclear activities these weak points are pointed out precisely because the quality and extend to new countries, regulatory watch is becoming essential for the management system itself has become more rigorous and demanding. common understanding of responsibilities and the proper adaptation To illustrate that high demand level, for instance, out of 147 evaluations of company processes to local issues. On that purpose, Assystem now (FEP16) published by EDF, only 1 reports a lack in nuclear safety culture. extends its watch to international institutions such as IAEA and puts the It has been corrected since. regulatory issues at a high priority level in its development actions.

(14) Assystem is the first engineer to obtain certification under this new standard, governance of which is more participatory and collaborative than that of OHSAS 18001. (15) Groupement des Industriels Français de l’Energie Nucléaire – professional association promoting business in nuclear. (16) Fiche d’Évaluation Prestataire – contractor evaluation report 14 NUCLEAR RISK MANAGEMENT IN 2018

In addition, support and operational teams need to correct the following points in 2019:

• The preliminary risk assessments must be initiated on due time and must be oriented towards graded approach elements;

• The inductions for new comers in the operational teams contain nuclear safety culture issues and must be given without delay;

• The competency matrixes on the projects must be regularly updated, in coherence with the progression of the employees and the needs of the projects. This concerns in particular internal checks and the production of documents intended to the regulators.

>> CERTIFICATIONS

Assystem has a long term experience of quality assurance assessment. The main quality system certification is driven by ISO 9001:2015 norm, assessed by LRQA17 (confirmation in 2018). In addition, the ISO 45001 applies for the HSE management system. Assystem also holds a NCIO18 authorization certificate issued by TAEK19 - the Turkish regulator - to perform inspection activities for SSC20 important for safety.

In 2018, the second year of Qualianor21 certification on the radiation protection scope in France, Assystem passed an operation audit, confirming the first certification audit. In addition, in a continuous improvement process of its radiation protection management system, Assystem conducts internal audits that ensure the conformity to the French regulations: Article R. 4451-122 of the French Labour code and 27 November 2013 Order on external companies carrying out nuclear activities and temporary employment agencies concerned by these activities.

In 2018 also, Bureau Veritas led a review of policies in force across Assystem and recommended that the UK system be used as a basis for the creation of a standardised nuclear quality assurance manual which could lead to accreditation to NQA-1 standards. This work has now evolved and is being incorporated in the Project Hive activities to implement common business, data, processes and tools across Assystem.

In addition, Assystem holds some agreements issued by the licensees (EDF/UTO, Orano, CEA,… ), assessing either the global management system or some specific abilities, such as dismantling engineering.

The general objective pursued by Assystem is to develop its global quality management system in nuclear in conformity with ISO 19443:2018 Quality management systems - Specific requirements for the application of ISO 9001:2015 by organizations in the supply chain of the nuclear energy sector supplying products and services important to nuclear safety (ITNS). As far as necessary, based on this foundation, this system can be supplemented by specific certifications, established according to the needs of international customers.

(17) Lloyd’s Register Quality Assurance. (18) Nuclear Construction Inspection Organization. (19) Turkish Atomic Energy Authority. (20) Structures, Systems and Components. (21) QUALIANOR is a third party certification body that certifies the radiation protection system for Assystem in France - https://qualianor.com/radio-protection/ 15 ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT

FUTURE 3. DEVELOPMENTS hh Assystem intends to combine digital engineering 1/ NUCLEAR SAFETY CULTURE IN and the increasing nuclear safety regulatory ENGINEERING expectations, to build a dynamic and reliable new approach of nuclear safety through quality and >> SHARING AT ALL STEPS shared culture. As pointed out by international standards and organisations, nuclear safety is a paramount priority for the management, which must promote The combination of digital engineering techniques and of risk-based exchange at all steps and at all levels within Assystem and in close approach of standards leads to the widening of risk analysis through relationship with all the stakeholders. One of the first expressions of these processes, as shown in the following figure: sharing activities is the Nuclear Safety talks.

To promote the safety culture, UK employees share a long-standing industry tradition. They start every significant meeting with a safety share- a short discussion about an experience or an event related to safety. This ensures that everyone starts the meeting having literally put safety first, rapidly sharing safety messages round the business effectively.

hh Whenever they are organized, nuclear safety talks foster the in depth development of Assystem nuclear safety culture.

As this good practice expands to teams in France and, more generally, throughout the company, the nuclear risk management takes this opportunity to promote nuclear safety talks, and not only occupational safety, as it is usually the case.

Externally, the Assystem vision of nuclear safety, which is understood as a positive performance of projects and facilities, will be shared in industrial or international structures to which Assystem contributes. Among these organisations, the creation of the GIFEN22 Nuclear safety and quality commission will be an opportunity for Assystem to express its positive vision of nuclear safety. Figure 12 - Development of risk analysis through engineering processes >> PROMOTING ENGINEERING PRINCIPLES IN NUCLEAR SAFETY The implementation of this new approach at all levels, down to small and middle-sized projects is a real rupture for an organisation that As an engineering company oriented towards innovation, Assystem previously relied on feedback driven continuous improvement. It will is working on a digital approach of nuclear infrastructures, based on allow anticipating the nuclear risk, as expected in the post-Fukushima systems, models and data. This approach of system engineering requires context. a functional approach of the processes, where continuous improvement and nuclear safety requirements follow-up are key. hh The future quality organisation at Assystem will In particular, nuclear risks must be identified in the processes and their lead simultaneously to a global and to a tailored interactions. Opportunities for improvement, correction and mitigation approach of the nuclear safety prescriptions. of the risks are pointed out and followed through a quality oriented practice. To be able to answer prescriptions of authorities worldwide, the Assystem has decided to orient its quality system towards the ISO 19443 backbone of nuclear safety at Assystem will be global, in accordance standard, based on the IAEA GS-R prescriptions. The future quality with international standards. Meanwhile, the risk analysis approach system will also take advantage of the feedback of the main operators through engineering processes will create a tailored – thus graded and nuclear safety stakeholders in the world, expressed in various global – approach of the risks already under the surveillance of the nuclear or local standards, such as the ASME NQA-1. operators and their regulators.

(22) Groupement des Industriels Français de l’Énergie Nucléaire – French industry structure committed to nuclear energy development 16 FUTURE DEVELOPMENTS

>> HSE ON CONSTRUCTION SITES AND INTERNATIONAL mixes safety and production needs, and the data analysis works PROJECTS indifferently on textual data or time series.

As in 2018, the health & safety of Assystem employees will be a major Most of these projects take their roots in digital technologies and already issue for the company. This topic is directly linked to nuclear safety, record quick wins. The main reason for this success lies in the fact that mainly through the rigour of Assystem employee exposure to radiation they all improve the quality of information sharing between project management. phases and between disciplines. As a key interface between these matters, nuclear safety will take a great advantage of digital innovation. This subject is strictly defined by the French regulations, which regularly evolve in order to improve the protection of the workers. The related For these reasons, at Assystem, the nuclear safety discipline network requirements mainly concern the administrative procedures and the keeps a close look on digital innovations. On the other hand, it is now trainings provided to individuals in the nuclear facilities in France. necessary to mobilise expert resource to help innovative projects taking advantage of this nuclear safety interest in digital. For example, since Assystem takes these prescriptions as an opportunity to improve the nuclear safety is under a strict regulatory control, digital engineering must quality of its risk analysis, for instance in the radiation prospective anticipate the required verifications. evaluation processes and the identification of risk reduction measures. As such, it contributes to nuclear safety culture and system engineering In all these fields, Assystem will go on investing in postgraduate programs, of the processes. through a proactive international recruiting policy.

Every country has its own regulations and its own health and safety indicators, as these points usually take their roots in the industrial 2/ QUALITY ASSURANCE ISSUES traditions and culture. More than just complying with these regulations The evolution of the nuclear safety discipline in the present digital and prescriptions, Assystem uses its international presence to benchmark transformation context also applies to the quality assurance methodology. various practices. The aim of this policy is to take advantage of international visions as complementary rather than just competing. >> INTERNATIONAL STANDARDS

>> TRAINING E-LEARNING The ISO 19443 standard, which complements ISO 9001:2015 for nuclear, was issued in May 2018. This norm will be taken into account At Assystem, the first e-learning courses to be put online were nuclear in all the new documents of the Assystem Quality system. Therefore, the safety courses. The main reason for this achievement is efficiency, as system will change gradually to integrate this standard within a few nuclear safety prescriptions must be delivered to a great number of years. The modifications will take advantage of the conclusions of the employees, in a quite repetitive manner. In that perspective, some new ISO 9001:2015 certification audit. Notably, these improvements will e-learning courses will be proposed to the managers and the employees concern risk graded approach and nuclear safety culture. in nuclear. In parallel, Assystem will go on working on international regulations, in hh E-learnings do not replace face to face training order to: sessions, but they help increasing the global • collect feedback in implementation of nuclear projects worldwide; efficiency of nuclear safety culture development. • provide the best possible answer to local nuclear operator needs.

The numbers of sessions is very encouraging and the local managers From that point of view, some Assystem postgraduates have started a still must push their collaborators to register to these online sessions. research on the best system approach to international regulation. They However, once the novelty effect has passed, it will be necessary to are driven by company senior experts. evaluate in detail the strengths and weaknesses of this new learning >> GRADED APPROACH AND NUCLEAR SAFETY CULTURE method. For instance, it is necessary to collect the feedback previously brought by the teachers, who often corrected their live session contents Implementation of graded approach is one of the main changes between according to the reaction of their audience. today’s system and the future ISO 19443 standard. Actually, the present quality system, mostly based on the French regulations already To put it in other words, these e-learning trainings do not replace integrates some graded approach characteristics. For instance, radiation instructor-led trainings, but they help concentrating on specific issues protection or vessel and piping standards organize checks and controls while ensuring a common shared nuclear safety knowledge for all in the in accordance with pre-established categories. The main change in company. The next Quality and Nuclear safety internal observatory will the new system will concern the categorization process, which will be make a focus on this issue. based on a functional analysis. The risk analysis will directly result of this >> INNOVATIVE PROJECTS AND DIGITAL functional analysis. TRANSFORMATION hh In the future nuclear quality system, functional Assystem has undertaken a wide spectrum of innovative projects, such analysis of the activities will become a key step as SMR23, new smart hot cell design, requirements tracking engineering towards risk identification and graded approach. and data analysis integration. The SMR is looked at through MBSE24 methods, the hot cells are designed with a lifecycle approach which

(23) Small and Modular Reactors (24) Model Based System Engineering 17 ASSYSTEM 2018 NUCLEAR RISK MANAGEMENT REPORT

This will contribute to the need to adjust nuclear safety to the real needs, and to find an optimal response to the risk.

The second main axis of the new ISO standard is about the enhancement of nuclear safety culture. Assystem actions will go on developing this culture, as shown above. Nevertheless, some additional effort needs to be deployed on the evaluation of the nuclear safety culture and of the general knowledge. The message to address the nuclear safety employees can be expressed in the following words: ‘Your knowledge is precious for company and nuclear. So, we assess it and we will give you all necessary help to improve on weaknesses’. The Assystem Nuclear Institute (ANI) will have this role.

>> MODIFICATION OF ASSYSTEM ADMINISTRATIVE TOOLS

New ERP25 software, to be deployed in 2020, shall integrate nuclear safety processes, so that the related requirements are flawlessly associated to the company practices. The nuclear risk management direction is associated to this important project, called Hive.

Hive will fully integrate with the graded approach, based on a risk analysis of the production processes. For example, the following figure shows how the deliverable production process will adjust to the risk, providing an adjustable number of revisions:

hh As for all the administrative tools and processes, the quality assurance and nuclear safety processes must be simple and efficient. Nuclear safety is a matter of rigour, not of complexity.

Figure 13 - Hive future deliverable production process

(25) Enterprise Resource Planning software helping manage the highest level company processes

18 CONCLUSION

4. CONCLUSION

At the very beginning of 2019, Assystem Nuclear Safety related 2/ DIRECTIONS FOR 2019 activities have reached a very good level in general. In France, the INB order and the main nuclear operators policies are well known and In 2019, Assystem will aim at delivering to its customer projects at the understood. The trainings and quality tools are in place. The remaining highest level of nuclear safety, while keeping the associated requirements issues are followed through the auditing system, which seamlessly adjusts sustainable. This objective will be managed through the evolution of the to customer needs and findings. In the UK, the quality system is also at a quality assurance standards, such as ISO 19443. This will imply the very good level and training is efficient. development of: • Systematic risk analysis leading to a rigorous graded approach; Nevertheless, because nuclear safety is a very demanding discipline, • Robust nuclear safety culture, shared at all company levels. efforts and progress are always necessary to avoid a painful regression. In the coming years, Assystem will face two major challenges that will This implies that methods and principles that have been developed within help, as they will demand efforts and progress: international development AEOS and AIL structures are extended to all the group entities, on a and digital transformation. worldwide basis. Some specific efforts will also be made to: hh As France and UK projects have led the • Foster internal radiation protection field expertise and administration; development of Assystem nuclear activities for more • Develop new trainings, both online and with experts; than 50 years, they now have to adjust to a wider • Implement systematic an evaluation of nuclear safety culture and scope of regulations and standards. techniques, starting with the employees exposed to nuclear risks; • Improve the collection of internal non-conformities; International development in nuclear brings useful benchmark and gives • Provide more robust evidence of the qualification of project staff. the opportunity to review company processes with new criteria and In addition, these efforts will be extended to all the external entities that prescriptions. Digital transformation provides a new set of questions, and might join the group in the future months. obliges the experts to focus on the ‘why’ rather than on the ‘what’. In To achieve these objectives, Assystem will keep the most coherent both cases, it is necessary to answer fundamental questions and not only approach of nuclear safety along with quality. This seamless transition formal ones. between quality and safety is differentiating for Assystem, as it lies between prescriptions and internal processes. hh Even if these challenges are very demanding for its nuclear resource, Assystem takes all these changes more as a chance than as a constraint.

1/ MAIN 2018 ACHIEVEMENTS

In 2018, for Assystem, the key completions for nuclear safety were: • Training engineering development, with new e-learning modules; • Qualianor confirmation of certification for radiation protection monitoring system; • Reverse evaluation of internal procedures; • Internal nuclear safety discipline structure development and commitment to nuclear safety culture spreading; • Constant reduction of exposure to radiation and better follow-up of workers and activities. Of course, Assystem teams will carry on these continuous improvement actions in 2019 and the coming years.