2020 edition
Status of safety in nuclear facilities General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 1 16/07/2021 06:28 A glossary of abbreviations and main technical terms is provided on pages 63 to 66 of this report.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 2 16/07/2021 06:28 2-3
Message from the CEO Philippe Knoche
The year 2020 will remain a very exceptional one. The global health crisis that has plagued us for well over a year now has required us to adapt our organizations, our working methods, and even our ways of thinking in order to continue to conduct our production activities while maintaining control over nuclear safety, environmental protection, radiation protection, and occupational safety.
Orano’s results for 2020 in terms of nuclear safety, must take into account. It is also a reminder as to the industrial security and radiation protection are very specific features of the activities we carry out on a nevertheless mixed. daily basis at our fuel cycle facilities, which involve both chemical and radioactive components. They therefore require a very high order of exigency. irst of all, our organizations demonstrated excellent resilience to the effects of the COVID By analyzing the root causes of these events and F crisis, particularly during the periods of implementing counter measures, we must succeed in lockdown, allowing us to keep our plants operating avoiding their recurrence. The experience feedback loop safely and to continue executing projects with the is essential to our continuous progress approach. To be support of our subcontractors. The number of safety- effective and achieve ongoing improvement requires related events has been very limited. Several factors better sharing between the different sites belonging to contributed to these results. I would like to emphasize our Group and a clear collective memory of past lessons the constant mobilization of all our employees, which learned. This will be one of our key areas to advance in enabled us to keep our plants running smoothly under 2021, a year which also marks the beginning of our new the difficult conditions imposed by the application of environmental safety and health, safety and radiation strict health measures. Initial feedback has also shown protection policies, which are linked to protected that the shorter management loops which the situation interests. The preparatory and construction work required us to implement have worked well. underpinning these policies was carried out in close Furthermore, the reduced number of inspections and the collaboration with the sites, which were able to voice scaling back of modification projects has enabled their assessments of current policy and their proposals everyone, while remaining focused on safety and going forward. These proposals now form the backbone security, to concentrate on the core mission of operation of our action. Their circulation is an opportunity to be and production. seized to carefully consider our challenges for the next three years. In counterpoint to these good results, a level 2 event on the INES safety scale was registered with the French Nuclear safety and occupational safety belong to our Nuclear Safety Authority. The event involved internal core values, and we must individually and collectively contamination of one of our employees, in excess of the aim for the highest standards to fulfill them. regulatory threshold, during an operation in a glove box, though no impact on the employee’s health is This annual report from the General Inspectorate allows anticipated. Within Orano, we have to go back more than us to measure the progress we have made and to identify ten years to find an event of this level, also involving the areas for improvement on which we still need to internal contamination. This event, which must be taken work. I encourage you to read it, to appropriate it and to in conjunction with other less serious radiation share it with your teams. protection events, is a strong warning signal that we
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 3 16/07/2021 06:28 Vision of the Inspector General Pascal Wilz
Based on a review of key indicators, analysis of reported events, and the lessons learned from inspections and various observations, 2020 has been a year of contrasts in nuclear safety. Safety and radiation protection were managed effectively during the lockdown period. However, in the annual results, there has been a worsening in some of the indicators. Ambitious action plans are being implemented to improve performance in safety and radiation protection.
This annual report by the General Inspectorate Key results deals with industrial risk prevention, and assesses management of nuclear safety and radiation In 2020, there were 146 significant events reported protection for the year 2020 within the scope of by Orano or originating with Orano: 1 of these was at Orano’s activities and facilities. 1level 2 of the INES scale, while 7 were at level 1 and 138 at level 0.
he report is based on findings made during The level 2 event, the first in nearly 10 years within implementation of the annual inspection the scope of Orano’s activities, concerned a case of the program, and incorporates analyses of regulatory limit for exposure of an employee of the Group T being exceeded. events impacting safety, radiation protection and the environment, as well as the lessons After seeing a gradual reduction, the number of level 1 learned from those events. It takes into account events has remained stable for the past three years. the documents made available to the General Inspectorate, and is based on the observations and The significant increase in the number of level 0 events analyses of the Group’s safety, security, radiation confirms the trend observed over the last 4 years. While protection and environmental specialists. It also this reflects the Group’s strong desire that all deviations be reported, it is mainly explained by the increase in events draws on regular discussions held with the nuclear related to radiation protection without any decrease in safety authorities, the General Inspectorates and events highlighted in the previous report related to the other nuclear operators. operation of the Philippe Coste plant or to the management of periodic inspections and tests.
These changes led to the incident prevention rate1 (or IPR) being kept below 0.1, which remains comparable to the rate for previous years.
1 Ratio of the number of events of 1 or higher on the INES scale over the number of level-0 events.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 4 16/07/2021 06:28 4-5
Apart from the events already mentioned, the most The inspection program was revised in May to incorporate significant deviations were: checking of the implementation of derogatory measures • the loss of containment on a silo holding radioactive during the lockdown period. In certain cases, inspections sludge when carrying out reinforcement works were carried out remotely, following the example of what without any impact on persons or the environment had been done for the monitoring of recommendations. (see the box on page 40), While this mode of operation is a remedy which can be • a fault in the monitoring of the mass of uranium- employed in cases where access to sites is restricted, it bearing materials in a storage with the authorized does however demonstrate the constraints and limits for number of containers being exceeded, an inspection system. • a fault in the characterization of 2 drums of waste containing uranium, The processing of recommendations in a timely manner • the failure to perform periodic inspections and remains an area for improvement that has been identified tests on several sites. since 2018 report. Collective efforts have been made to address past recommendations. The results for 2020 made it possible to confirm the positive trend observed In contrast to previous years, 2020 was also marked in 2019: the number of outstanding recommendations on certain of our sites abroad by industrial events with to be processed continued to decrease, including for the 2 consequences which were limited, but sufficiently most long-standing (outstanding for more than 2 years) significant to require the deployment of additional preventive to which particular attention is being paid. Efforts must measures. In particular, these concerned a release of continue to be made to ensure compliance with the ammonia when performing an intervention on a storage period of two months for the creation of an action plan vessel and the break of a pipe on an acid storage facility. This in response to a recommendation. Furthermore, deadlines must involve the taking into account of operating experience for the implementation of these action plans must also be feedback from the major accident at the port of Beirut complied with more fully. This topic is an area upon which (Lebanon) concerning the explosion of a chemicals storage attention must remain focused over the year to come. facility, which occurred on August 4, 2020. Establishing close ties with the general inspectorates of other operators was held back in 2020 due to the ongoing Despite the events mentioned previously, average situation. dosimetry levels remained stable, at low levels 3 both for the Group’s employees and those of our subcontractors. While the French annual limit is 20 millisieverts (mSv) for category A personnel, average Maintaining skills doses were 0.9 mSv and 0.8 mSv for employees and external workers respectively. Actions to develop skills, as an important strategic lever in providing assistance and support for the development The number of Group employees and external workers of the Group and the management of nuclear safety having received a dose of more than 14 mSv, which is the and radiation protection, continued to be taken in 2020. internal alert threshold, was 72 and 41 respectively. This These actions are organized around the contact points for represents a significant increase in these figures. disciplines within the Group, the BUs and on sites.
The annual skills review process (Revue Annuelle des The radiological impacts on the environment from Compétences - RAC) is now well established. It allows for nuclear sites remain at very low levels of less than an accurate mapping of disciplines and of prospects in the 4 15 microsieverts (µSv) per year (for a regulatory medium term, and to specify the actions that need to be limit of 1,000 microsieverts for members of the public). taken to manage their criticality.
In 2020, 25 inspections or assessments and 33 SAFETY EXCELLENCE follow-up inspections were conducted. These 5inspections generated 88 recommendations and Despite the health crisis, the Safety Excellence training as many action plans to be implemented by the plan was able to be broadly deployed: 11 sessions, the inspected entities. These figures can be compared to 96 majority of which were delivered remotely, allowed recommendations closed out under monitoring. around one hundred employees to be trained. In addition, around one hundred employees completed training to The health situation had a significant impact on the General raise awareness of the INB Order (Arrêté INB), which was Inspectorate’s program. In particular, no inspections were newly created at the request of the Quality Department. conducted during the first lockdown period from March to April. In addition, for sites abroad, no inspections The self-assessment of facility managers extended to were carried out in the field in 2020. Monitoring of the their deputies, operating managers, project managers for implementation of recommendations for these sites was closed and independent worksites was conducted at the able to be carried out remotely. end of 2019. The results are coherent with those of the
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 5 16/07/2021 06:28 Vision of the Inspector General
campaigns in 2013 and 2016. There is improvement in • to broaden one’s horizons by moving into the results for management in the field, nuclear safety and other disciplines such as radiation protection, materials safeguards. The decision was taken to repeat occupational safety, quality or industrial inspection, the training every five years. • to explore pathways offering opportunities to transfer between disciplines, in particular by moving into project management or production A STANDARD FOR EACH DISCIPLINE (facility manager). In order to ensure employees are better informed about development plans and professional career paths, a digital A dismantling safety engineer in the field platform, called O’Carrière has been deployed. Its aim is to allow employees to play a more active role in shaping their career by: • providing visibility regarding the possible career paths within the Group, • providing information about changes in disciplines within the Group and professional development plans, • helping to put together and develop their professional career plan, and • making it possible to identify career opportunities more effectively.
The points of contact for each discipline define a standard, which will be integrated into the platform. This is in Nuclear safety management particular the case for the disciplines in nuclear safety and radiation protection, the standards for which will be integrated into the platform in the first half of 2021. These IMPLEMENTATION OF THE NUCLEAR actions should help to make disciplines in nuclear safety SAFETY AND ENVIRONMENT POLICY more attractive, and to show the prospects for professional development which are open to a nuclear safety engineer: The Nuclear Safety and Environment Policy (2017-2020) • to specialize or move into expertise, was issued in April 2017, for the period from 2017 to 2020. It identifies twelve priorities relating to safety in
Nuclear safety disciplines facilities, safety during operations and the performance of nuclear safety and environmental management.
In 2020, 137 actions were carried out, out of a total of 155 actions planned, which corresponds to a rate of completion of close to 90%.
The themes on which performance appears to be most robust for this reporting period were those of ensuring compliance with regulations and safety standards, the application of standards and operating procedures, and the reassertion and strengthening of the role of the independent nuclear safety organization (Filière Indépendante de Sûreté - FIS). In contrast, the areas in which results were weakest were the performance of the operating feedback process and the anchoring into practice of sharing of experience, and the implementation of assessment of Human and Organizational Factors and human performance tools. Further to this thematic analysis, the first results of its application reveal the need to improve how nuclear safety performance is measured in order to manage it more effectively.
The identification of these strengths and weaknesses helped in the drawing up of the Policy for 2021-2023, which
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 6 16/07/2021 06:28 6-7
was done by a process of co-construction in several steps, 2020 was put to good use to specify the organization of which: the FIS at Group level. The deployment of this organization • undertook to involve all entities and stakeholders still remains to be defined in 2021 at the level of operational concerned by its application, sites. • was based on collaborative work mobilizing both the specialist HSE division and operational line management, REGULATORY WATCH had the objectives of taking operating feedback • 2020 was put to good use to deploy a new regulatory from the implementation and application of the watch tool. This tool allows each site to have access to previous policy into account and ensuring goals of regulatory watch that is personalized, allowing it to carry industrial safety and environmental protection are out its evaluations of compliance. taken into consideration more effectively, • had to adapt to the health situation (which had an It should be underlined that this work represented a very impact in terms of the cancellation of the Safety significant workload for the teams on sites and from Convention initially planned), the Group’s HSE department. This involved not only the • was closely supervised by Senior Management modification of the internal regulatory watch process, and the Executive Committee (COMEX). which has taken the new functionalities of the tool and its interfaces into account, but also work on appropriating the This Policy, which is an integral part of the Group’s CSR tool, establishing an initial state of the repository applicable approach, covers all interests protected by French Law, to each scope of regulatory watch and preparing for the and therefore covers nuclear safety, environmental retrieval of compliance data. protection and crisis management. It takes industrial risks into consideration. Though this undoubtedly involved more work than initially planned, thanks to the efforts of everyone involved, the It sets out 21 priorities for action, 11 for nuclear safety and first results are encouraging. Attention will however have 10 for the environment. Its operational application and to be paid to ensure that the workload in the established its effectiveness will be monitored by writing its priorities mode of operation remains acceptable for all sites, into the master plans of the entities concerned, as well as including smaller sites. by means of an annual implementation plan and a set of indicators which will be presented at periodic intervals to The implementation of this process is due to be evaluated the COMEX (3 times a year to the Safety COMEX). at the end of 2021.
Special attention will be paid to internal communications to ensure that each employee concerned is able to stay SAFETY CULTURE informed and appropriate the Policy. These actions are planned to be carried out in the second half of 2021, in Attaining or maintaining a high level of safety culture is coordination with the radiation protection and safety and an important and ongoing goal of the Nuclear Safety and quality policies, which have also been renewed for the Environment Policy. same period, and which also contribute to the protection of interests. The need to develop an e-learning module common to all employees to raise awareness INDEPENDENT NUCLEAR SAFETY of safety culture was identified ORGANIZATION in 2019. This module, which has been available since the end of Strengthening of the independent nuclear safety 2019, was deployed throughout organization (FIS) was recommended in the peer review the course of year. The results conducted at the end of 2017 by WANO of Senior are very satisfactory as nearly Management and its support functions for the La Hague 7,200 employees (corresponding activities. to 60% of the workforce in France) completed the module The actions taken in 2019 continued to be pursued. and passed the assessment Deployment of the nuclear The inspection unit introduced under the responsibility questionnaire successfully. safety module, La Hague of the Deputy Director of La Hague implemented its inspection program. Regular discussions with the General Beyond this, a self-assessment tool allows the general Inspectorate are making it possible to optimize activities. level of a team or a facility to be assessed and points The systematic transmission to the General Inspectorate for improvement to be identified. The constraints found of results of first-level controls of the Melox, Tricastin with regard to implementation of the tool have led to the and La Hague sites allows for a more complete internal Group to develop a utility. This upgrade was used as an evaluation of the level of safety of the sites, whilst also opportunity to review the questionnaire, in line with the making it possible to make inspections more precise and work being done in parallel by the GIFEN, with nuclear to guide the inspection program. industry partners.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 7 16/07/2021 06:28 Vision of the Inspector General
In addition to its ease of use, in regulatory reference materials subsequent to the this tool will allow users to have abrogation of French Decree 2007-1557 and the a complete overview of the changes to other internal documents, level of safety culture and make • the guide for analyzing cumulative events it possible to take transverse called for by the INB order and the ASN decision actions for improvement at concerning the safety analysis report for INBs, Group level. • the guide concerning the approach for demonstration of nuclear safety, which specifies the approach In addition to this work, it is also to be applied in response to chapter IV of ASN worth underlining the more specific actions deployed at decision 2015-DC-0532 concerning the safety BU level and adapted to the needs and disciplines of each analysis report, entity. • the guide concerning the regulations for nuclear pressure equipment, which presents, in a manner MANAGING THE REPOSITORY OF which is structured and easily consultable, the regulations applicable to nuclear pressure REGULATORY DOCUMENTS equipment installed and used on the Group’s sites, and more particularly those which are installed By way of continuation of within the perimeter of French regulated nuclear the actions underlined in facilities or in environmentally regulated facilities. the reports for previous years, the work to update The process of re-appropriation by the teams responsible the Group’s internal safety for implementing these complex documents also poses a standards, embarked upon in application of the regulations challenge. In this respect, an e-learning course put online remains an important issue, requiring the committed on July 1, 2020 on the basics of the regulations applicable mobilization of a large number of experts centrally or on sites. to INBs, which is a prerequisite for internal training in nuclear safety, should be suited to meet this challenge. The Nuclear Safety Methodological Committee (or COMET) is now in its second year of operation. It has In addition to that which has just been described in been operating in a way which fully meets the objective detail above, it is worth underlining the important work of having internal safety methodologies which are shared done internally to comment on international draft texts and developed with support from the sites and engineering (from the IAEA in particular) for fuel cycle facilities and teams. The deliverables consist mainly of methodological transportation, which will have an impact on national information sheets and guides. Details of most important regulations at a later date. publications of the year are provided below. This structure also serves as a special body for exchanging information Regarding texts destined to enter into regulatory force, ASN on these technical and methodological topics. Guide No. 30, relating to the policy for the management of risks and drawbacks of INBs and to the integrated The main internal texts made available during the course management system for operators was published. This of the past year represent a considerable body of work: text, which plays a key role in nuclear safety management, • the procedure relating to improvement of the requires internal application, something which has been management of fire risk in facilities in operation or included in the schedule of work to be carried out in 2021. undergoing dismantling. This version is an update of a document that was already becoming dated. It formalizes the justification of the choice of electrical PERIODIC REVIEWS equipment to be tested by infrared thermography and the intervals at which these tests must be In its report on the state of nuclear safety and radiation carried out, protection in France for 2019, the ASN confirmed the • the re-issue of the guide on the testing by infrared adequacy of the organizational measures put in place by thermography of electrical facilities, and the all the entities concerned by periodic reviews. Notably, updating of the guide on the implementation of “The Orano group has put in place a central organization, fire permits, which takes regulatory changes and which has improved the quality of its periodic safety operating experience feedback into account, reviews, particularly through its ability to report on the • the revised guide on the management of the safety conformity of its facilities. The Tricastin and La Hague standards for a French Regulated Nuclear Facility, sites, which feature numerous Basic Nuclear Installations or Basic Nuclear Installation (BNI) (Installation (BNIs [INBs]), have set up dedicated organizations that Nucléaire de Base- INB), which takes account of enable the periodic safety reviews of the various BNIs to the change in regulatory requirements written into be conducted continuously, which improves the rigor of the French Environmental Code since 2019 and the reviews.” the publication of ASN decision 2017-DC-0616 concerning noteworthy modifications to BNIs, Supported by this opinion and in the context of the health • the revision of the guide on the preparation and crisis, the activities of the “Review Advisor Cluster” have the content of safety reports, due to the change continued with the following objectives:
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 8 16/07/2021 06:28 8-9
• provide operational assistance to operators and For the Melox site: engineers in the application of the guides updated • support for operating and engineering teams once again in October 2020, during preparation of the elements for the file for • coordinate the creation or improvement of sub- this facility. processes associated with the overall review development process, The files submitted in 2020 were prepared with the • share the methodological development needs support of the methodological guides which have been arising from operating feedback, notably through updated once again to take into account operating cluster participation in COMET, feedback from files processed in the past and the latest • capitalize on operating feedback from the reviews, changes in regulations. Content has been standardized facilitating the exchange of information between and approaches remain coherent for all Group facilities. the various sites. Methodological assistance, in line with the action taken by COMET, has focused on continuing to improve data Data entry collection processes, and the compliance and aging review process at the sites.
Training courses for a broad target audience have been created and deployed, in the form of modules devoted to raising awareness to the processes and goals of the review, as well as the preparation of files. Nearly 50 employees intervening on projects in an operational capacity have been trained this year, and to disseminate these training courses to an even wider audience, digital versions are currently being prepared.
The lessons learned from periodic reviews have continued to be to capitalized on, in particular with the enrichment of recent databases together with monitoring of commitments made to the ASN and capitalization on financial operating experience. Beyond the primary objective of identifying requirements and anticipating future methodological issues, the collection and systematic analysis of financial operating experience are now in effect.
Benchmarking between the various Group entities according to technical and organizational themes has simplified the decision-making surrounding operating experience feedback.
At the time of its creation, the Advisor Cluster mainly provided a response to the need to apply consistent This operational assistance has enabled: methods and optimize file costs. With the objective of overall consistency in the preparation of periodic review For the La Hague site: files now having been achieved, the next actions tobe • monitoring of the processing of the periodic review file for INB no. 118 (STE3), The periodic review cycle • support for the operating and engineering teams during preparation of the elements for the file for INB no. 116 (UP3-A), and for the orientation report for INB no. 80 (high oxide activity - HAO), with the files for these last two sent to the ASN on June 26 and December 16.
For the Tricastin site: • support for the operating and engineering teams during preparation of the elements for the files for INBs no. 138 (SOCATRI), and no. 168 (GB II), with the review file for INB no. 138 (SOCATRI) sent to the ASN on June 10, • monitoring of the processing of the periodic review file for INBs no. 178 and no. 179 (Parcs).
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 9 16/07/2021 06:28 Vision of the Inspector General
taken are to be guided by improvement of the processes, MANAGEMENT OF FIRE RISKS and as a result of costs. In this regard, it is worth emphasizing the importance of the decision to maintain The fire at a laundry management platform on a site the structure of the Advisor Cluster for a period of 3 years, provides a reminder, were one to be necessary, of the need called for in the 2019 report. to manage this risk as a matter of priority.
Thus, following on from what was presented in the 2019 report, the main findings of the independent nuclear safety The main issues in nuclear safety organization (FIS), resulting from the reports by the General Inspectorate and the La Hague inspection unit and the first- and industrial safety level controls at site level, are worth underscoring.
While, in general, the organizations do seem to be PERIODIC INSPECTIONS AND TESTS satisfactory, efforts have to be made mainly in the rigorous approach to be adopted on a daily basis in performing actions In 2019, the General Inspectorate’s annual report noted which contribute to the prevention of fire risk, even if some malfunctions in the carrying out of periodic inspections improvements have been observed. This mainly concerns: and tests, including failure to meet scheduled due dates for • the management of fire loads by regular tidying of completion. This recurrent finding has been underscored workshops, by a number of significant events reported to the Safety • the availability of automatic fire detection systems Authorities which still remains too high. including knowing how to impair them during phases where it is necessary to do so, In this context, the General Inspectorate carried out four • the completion of fire permits, inspections on this process in 2020, the findings of which • the storage of flammable products, and are detailed in the section entitled “Lessons learned from • the management of water for fire extinction. the inspections”. In addition to the actions already taken by sites, these inspections allow the following main areas for transverse improvement to be identified: Fire protection team exercise • the definition of the system of periodic inspections and tests (“système CEP”) as a process common to each of the departments of a site concerned, • the rolling out of a Computer-Assisted Maintenance Management System (CMMS) in order to ensure the necessary rigor is applied in the scheduling of inspections for all equipment, • the implementation of procedures showing the control steps for entering data into databases, • the implementation of technical and monitoring checks when the periodic inspection and tests (CEP) concern equipment important for the protection of interests (EIP), and • reinforcement of the inspections by the independent nuclear safety organization in order to take more systematic action to check the execution of the process. OPERATIONAL DOCUMENTATION
Equipment with an inspection discrepancy Having been underlined as important in the General Inspectorate’s reports for several years now, the work embarked upon on the different platforms in 2019 continued in 2020 though without offering any prospects of progress over the long term. This issue is made particularly complex because of the large number of unique facilities, differences in operating modes and differences between generations.
To give fresh impetus to this issue of key importance for the nuclear safety in normal operation, Senior Management has decided to conduct a methodological study based on Operational Excellence tools. Work on this study has already commenced. The conclusions are expected in 2021.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 10 16/07/2021 06:28 10-11
Lubrizol accident: lessons which still have to be deployed
The fire affecting the Lubrizol plant and INTEGRATION OF NEW REGULATORY the warehouses of Normandie Logistique REQUIREMENTS which occurred in Rouen in September 2019 Orano has set up a first working group to assess the has resulted in a thorough re-examination impact on its facilities of the “Inventory of stored of industrial risks, focusing on: materials” part of the ministerial action plan, in order • fire prevention, to meet the new regulatory requirements as fully as • preparation for emergency situations, possible. The objective of this working group is to • alerting and keeping the public harmonize practices across the Group’s different sites. It has in particular made it possible to identifier the need informed in the event of an industrial for an internal guide on the management of inventories accident. of small volumes of chemicals. This group also includes operators of INBs, in anticipation of the publication of equivalent regulatory texts for this type of facility. A GOVERNMENT ACTION PLAN A benchmarking on the practices of companies from different industries has also been carried out, via France Subsequent to an action plan presented by the French Chimie. ministry for Ecological and Inclusive Transition presented in February 2020, several regulatory texts The other regulatory texts, for which the schedule for applicable to Environmentally Regulated Facilities the implementation of measures runs from 2022 from (ICPEs) were published at the end of 2020. Their purpose 2026, have undergone an initial analysis, which will be is to reinforce: consolidated during the course of 2021. • measures to plan ahead for and facilitate the technical management of an accident, Future changes to regulations to be taken into account • the prevention of fires in storage areas for for Environmentally Regulated Facilities (ICPEs) include: flammable liquids, • the indication in the hazards study of the types • the prevention of fires in warehouses for combustible of decomposition products likely to be emitted in materials, the event of a major fire, • monitoring of the consequences of an accident • the integration into the internal operations plan for the environment and health, (POI) of measures allowing the operator to carry • means of prevention and investigation. out environmental sampling inside and outside the site when conditions allow, as well as the means and methods envisaged for rehabilitation and cleanup of the environment after a major accident.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 11 16/07/2021 06:28 Vision of the Inspector General
MANAGEMENT OF SUB-CONTRACTORS • the integration of protected interests (AIP/EIP/ED) into technical specifications, Due to the large proportion of activities which are sub- • management of preparation of the monitoring contracted, in particular for the maintenance of facilities strategy and its application through to the and given the large number of significant events involving follow-up of action plans resulting from monitoring them, their management remains a key issue. procedures, • the need to strengthen safety culture and to take Following on from the work carried out in previous years, the risk of fraud into account on sub-contractor several transverse actions were carried out in 2020. teams, • the taking into account of human performance Based on joint work between representative monitoring tools by sub-contractors and their incorporation managers, a guide specifying the skills reference into contractual clauses. framework for monitoring managers, who play a key role in the system, has been published. This guide distinguishes between 3 areas (risks, technical discipline INDUSTRIAL RISKS and territory), as well as 10 skill areas, such as safety culture, and 4 levels of maturity. The analysis of the events identified in paragraph 2 of this section led the Group to implement a concerted plan of action to strengthen management of industrial risks. McClean plant, Canada There are several aspects to these measures: • the strengthening of the process of reporting and monitoring of events related to industrial risks, identical to that used for events related to nuclear safety and radiation protection. Implemented for all sites in France and abroad, it uses a measurement scale internal to the Group, which is based on the ARIA2 scale, used for estimating the severity of events, • in the short term, for sites which need it, a review of the main risks and the means of managing them, as well as the review of certain storage facilities for hazardous materials, • over the longer term, for sites which require it, the deployment of a safety management system similar to that implemented for Seveso-type environmentally regulated facilities, • the strengthening of expertise of sites and of the industrial safety culture of managers.
To check the adequacy of the standards, 25 representative monitoring managers took part in a pilot campaign for self-assessment of their skills. This campaign allowed positive points and points on which there are shortcomings to be identified and to validate the plan to conduct a skills self-assessment campaign for all monitoring managers in 2021.
Work has begun on the design and production of an e-learning training module for monitoring managers with an objective for deployment during the course of 2021.
Beyond these works being conducted on a large scale, specifying the applicable framework at Group level, in a similar way to that already described for the management of fire risk, it is also important to underlinemain points for improvement:
2 ARIA scale: European scale of industrial accidents.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 12 16/07/2021 06:28 12-13 Contents
52 14 Dismantling 2020 Highlights operations 20 55 Lessons learned from External transportation the inspections activities 28 Operating feedback 60 from events involving safety and radiation Management of protection degraded situations
44 63 Radiation protection Glossary 50 Management of impacts on the environment
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 13 16/07/2021 06:28 La Hague Site
2020 Highlights
Despite the health situation, Orano continued to modernize its industrial facilities at all its sites. A structural reorganization of the Group has also been completed and has been in place since January 1, 2021.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 14 16/07/2021 06:28 14-15
Change to the Orano group’s Tricastin Site
organization PHILIPPE COSTE PLANT
On January 1, 2021, a new Group organization was The beginning of 2020 was marked by the replacement of implemented to align the legal structure with the the crystallizers. This major project, initiated in 2019, was organizational structure of the Business Units. This change completed during a scheduled shutdown in mid-February is presented schematically in Figure 1. 2020. A total of 9 crystallizers were gradually installed in the plant after removal of the old equipment, connected In terms of nuclear safety, this organizational change and insulated before testing. The plant was then able to is accompanied by nuclear operator reassignments. restart at the end of May, despite the constraints of the Accordingly, on the basis of a change of nuclear operator first lockdown period. file submitted in February 2020, ASN issued a favorable 3 opinion on December 1, 2020, paving the way for the At the end of August, the first kilos of UF6 were produced publication of two decrees4, which formalize the transfer from the fluorine of the first electrolysis cell of the new of nuclear operator from Orano Cycle to Orano Recyclage building 62 at the facility. This building 62 houses the new for the La Hague and Melox nuclear facilities, and from additional pool of electrolyzers, equipment designed to
Orano Cycle to Orano Chimie-Enrichissement for the produce the fluorine needed to convert UF4 into UF6. Tricastin and Malvési nuclear facilities.
These decrees provided that in order for these operator Introduction of the last crystallizer in the Philippe Coste plant change authorizations to take effect, two orders stating that the new operators have demonstrated compliance with the obligations set forth in Article R. 593-42 of the French Environmental Code must be published by March 31, 2021 at the latest.
Following the favorable opinions of the energy minister on December 21, 2020 and of the French Nuclear Safety Authority (ASN) on December 22, 2020 (opinion No. 2020-AV-0371), two orders dated December 24, 2020 specifed that the changes of operator provided for in the aforementioned decrees should take effect on December 31, 2020.
Figure 1: Changes to Orano group’s organization
3 Referenced 2020-AV-0368. 4 Respectively, decrees No. 2020-1593 and No. 2020-1594 of December 15, 2020, supplemented by decisions No. CODEP-LYO-2020-060146 and No. CODEP-LYO-2020-060173 for the environmentally classified (ICPE) facilities for conversion (Philippe Coste plant) and W. General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 15 16/07/2021 06:28 2020 Highlights
INB NO. 138 - TRIDENT THE FLEUR PROJECT
The purpose of the TRIDENT5 workshop is to store and The request for authorization to create the nuclear storage treat nuclear waste produced by the Tricastin facilities facility “FLEUR, Parc d’entreposage P36”, concerning an (sorting, characterization, compacting, concrete injection, extension of the existing uranium oxide storage yards, and conditioning) before evacuation to Andra. After was submitted for public inquiry at the end of 2020. obtaining the administrative authorizations required for the creation of the workshop in 2019, the workshop’s equipment was progressively commissioned during 2020. Malvési Site Active testing of the workshop began in September, leading to the storage of the first waste packages shortly thereafter. The other equipment will be commissioned in THE NVH PROJECT stages. This mainly concerns: In May 2020, the UO (NVH) workshop project reached • the skirted compacting press, which will make it 2 another important milestone in its construction phase possible to compact, in a confined enclosure, more with the topping out of the main building, marking the end than 60 metric tons per year of wet low- and very of the building’s structural work and allowing finishing low-level waste; the compacted waste packages operations to begin (floor coverings and interior painting) will then be directed to the concreting unit for the as well as work on the ventilation and electrical work creation of the final package, in accordance with packages, followed by the introduction of equipment such Andra approvals, as the maintenance and process gantries. • the package press will complete a process for sorting and cutting up mainly metallic VLLW, The transfer to the operator of the workshop is planned treating a total of more than 300 metric tons of for 2022. waste per year. • the baler-compactor, commissioned on October 5
in response to the shutdown of the press at the View of the UO2 workshop under construction, Malvési site waste treatment station (STD), will treat more than 600 metric tons per year of nonmetallic VLL waste.
View of the skirted compacting press in its containment, TRIDENT
TRANSFER OF THE FIRST MATERIALS INTO THE PERLE CELL
The PERLE6 and CERS7 project, carried out in the lagoon area, aims to consolidate and densify the legacy solid View of the package press and the boxing station, TRIDENT residues produced by the site into impermeable storage cells.
An important milestone was reached at the end of August 2020. The PERLE cell received the first cubic meters of residues from the B5/B6 ponds. A total of 72,000 cubic meters of material will be transferred to INB no. 175 ECRIN and the CERS.
The commissioning of these facilities, after 20 months of work, marks the start of a key phase. Indeed, the emptying of the operating ponds and the consolidation of Malvési’s legacy solid residues in the INB ECRIN facility will help secure the site’s storage capacity for the next forty years.
5 Integrated processing of nuclear waste 6 PERLE: reversible surface storage project. (Traitement Intégré des DÉchets Nucléaires du Tricastin). 7 CERS: reversible surface storage compartment. Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 16 16/07/2021 06:28 16-17
View of PERLE cell, Malvési site
La Hague Site Operators in the control room, Melox site
CONVERGENCE PROJECT
2020 marks the start of the CONVERGENCE project. This major project for the site, which will be implemented over the next few years, will mainly include the following: • the construction of a building to house the support functions, • the creation of a centralized control room that will bring together in one place the control of the UP 2-800 and UP 3 facilities with innovative control systems, and • a revised maintenance organization that will be tasked with meeting the challenges of maintenance management. us to optimize the switchover procedures and to make final adjustments. This process will serve as experience MODERNIZATION OF THE CONTROL feedback in future deployments. ROOMS IN THE UP3 PLANT
For the first time since the commissioning of the UP3 plant, FISSION PRODUCT CONCENTRATION the control rooms of several workshops have gradually EVAPORATORS changed over their control and supervision systems, thereby upgrading to new generation control stations. The evaporator replacement project is progressing, reaching the final phase of assembly. Following the Thanks to the strong involvement and support of the lockdown decisions for the period from March 16 to May operator who worked with the control room modernization 11, the new fission product concentration unit project project teams, each changeover was successfully (NCPF) took the measure of the health constraints and the completed. As with any new technology, it was first tested necessary organizational measures. The provisional dates and validated on the development platform before being for active commissioning are June 2022 for NCPF T2 and gradually deployed on site. This first deployment allowed June 2023 for NCPF R2.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 17 16/07/2021 06:28 2020 Highlights
Measurements of the thicknesses of the accessible zones In addition, they verified the way in which experience of the six evaporators of the R2 and T2 workshops feedback was exploited, the policy of continuous are continuing annually. They confirm the decrease of improvement, operation, maintenance, expertise, the corrosion rate since 2015 and the implementation equipment reliability, training and qualification of of corrosion minimization measures. Taking these personnel, fire protection, occupational safety, radiation improvements into account in the estimate of the operating protection and management of emergency situations. time of the evaporators was the subject of a request for a Moreover, this exercise enabled the peers to identify significant modification authorized by ASN in May 2020. actions for improvement as well as best practices that The measures have led to the specifying of the date by could be used by other nuclear operators. which the minimum admissible thickness will be reached, which is beyond 2024, except for the 4120-23 evaporator Following the assessment, the operator will submit to in T2. For the latter, the controls are carried out at each WANO an action plan to implement its commitment to Maintenance Shutdown, the number of authorized opening improve the safety of its facilities, the first effectiveness of days is deducted and the next control must be carried out which will be verified two years later. before the half of the planned operating time to confirm the analysis. The next inspection is scheduled for May 2021. This was the third peer review, two earlier ones having been held in 2014 and 2016 for limited parts of the plant.
R 7 FACILITY - END OF THE URANIUM- MOLYBDENUM (UMO) FUEL TREATMENT EXTENSION OF THE HULLS STORAGE CAMPAIGN BUILDING Earthworks for the extension of the Compacted Hulls Following UMo fuel treatment campaign in the 1970s and Storage building (ECC) began on September 14, 2020. The 1980s, adaptations to the cold crucible vitrification line objective of this extension is to create additional storage at the R 7 facility were made beginning in the 2000s in capacity for CSD-C9 containers in order to optimize existing order to be able to vitrify this type of fission product for storage capacities. the first time despite their highly corrosive nature. Since 2013, this technical challenge has been a strong focus for The new building is scheduled to be in operation by early the operating, maintenance and project teams as well as 2026. various experts, including from the CEA. The recovery of these Umo fission products was completed in 2020 and led to the production of more than 700 vitrified containers. Preparation of a drop test of a cask The objective is then to switch to cold crucible vitrification of fission products from UOX fuels. A first campaign was carried out for which the production rate was reduced in order to make a comparison between the treatment of simulated solutions and the solutions resulting from the process. Feedback will be collated by the CEA, which is the licensor of the process and is present on the site to provide start-up support.
WANO PEER REVIEW
From October 5 to 23, 2020, a team of 25 experts from WANO8 conducted a peer review. Over a period of three weeks, the team members visited several of the plant’s workshops to carry out a safety assessment, benchmarking against the best international standards.
Through field observations and interviews with operators and managers, the team was able to assess the safety practices of these plant’s facilities as well as their operational control, in order to appraise operating discipline and the level of safety culture.
8 World Association of Nuclear Operators. 9 Standard compacted waste container. Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 18 16/07/2021 06:28 18-19
Earthworks for the extension of the ECC building, La Hague site This operation, which began in June 2020, should allow part of the rooms to be modified in 2021 and the balance in 2022.
CRISIS CONTROL CENTER
Like the equivalent installations at La Hague and Tricastin, this facility has been designed and built to withstand the most extreme natural threats. Commissioning, originally planned for 2020, has had to be deferred for industrial reasons.
Digital view of a modernized control room, Mélox site
Melox Site
REFURBISHMENT OF THE CONTROL ROOMS
After 25 years of use, the control rooms for several process areas and facilities (powders, pellets, cladding and PCS) are to undergo an in-depth refurbishment. Drawing on the experience of the La Hague plant, which is carrying out a similar operation, all the equipment and infrastructure in these rooms are to be replaced in order to equip the facility Bessines-sur-Gartempe Site with state-of-the-art control rooms. Despite a five-week interruption due to the pandemic, satisfactory progress is being made on the worksite for the Center for Innovation in Extractive Metallurgy building (Centre d’Innovation en Métallurgie Extractive – CIME), the first stone of which was laid on September 10, 2019.
The building’s foundations, completed at the very beginning of January 2020, were followed by the installation of the concrete framework of the pilot hall. The final floor slab of the laboratory area was poured in early March. Structural work resumed at the end of April, allowing for a ramp up of the workforce on the site with the building structure being topped out and the arrival on site of crews from various different trades to complete technical and secondary works.
Delivery of this building is scheduled for 2021 after 20 months of work.
Packages
At the end of a process lasting under 12 months - a time frame which should be underlined-, resolution CODEP- DTS-2020-059227 issued by the ASN President on December 21, 2020 certified that the model of cask made up by the TN Eagle package complies with the requirements for a Type B(U) cask loaded with fissile material. In addition, a license has been filed with the US safety authority, the NRC. This type of cask has a dual function: transportation and storage. Modular in design, the structure is built from standard technological bricks and is weld-free.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 19 16/07/2021 06:28 Operators conducting a monitoring inspection
Lessons learned from the inspections
The General Inspectorate conducted 25 inspections and 33 follow-up inspections, reflective of the special effort previously initiated to process the recommendations according to schedule.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 20 16/07/2021 06:28 20-21
2020 inspections renewal of medical visits of category B personnel, the inspection of pressure equipment, and specific prevention plans. Compensatory measures were defined and Aligned with previous years, the inspection programs would be applied if necessary. Postponed inspections were structured around four main objectives: or training sessions were organized as soon as possible • maintaining a high level of control over nuclear without necessarily waiting for the deadlines set by the and conventional safety as the organizations exemptions. were transformed, or ensuring that existing organizations maintain their capacity to respond to unplanned situations, Visual management session at the Melox site • maintaining control of safety functions (fire, radiation protection, confinement of nuclear substances, criticality, removal of residual power), • management on a daily basis of nuclear and conventional safety through a rigorous application of operating processes and operating procedures, and • compliance with requirements of safety authorities around monitoring and supervision of activities.
Given the circumstances of 2020, the inspection program was modified twice. These inspection themes were completed by a series of inspections on the application of exemption measures during the first lockdown period at the La Hague, Tricastin, and Melox sites. These inspections were conducted remotely in June and July. In addition, except for recommendation monitoring inspections, it was not possible to visit the sites abroad.
Overall, 25 thematic inspections and 33 recommendation monitoring inspections were conducted.
In total these inspections resulted in 87 recommendations and as many action plans issued by the inspected entities, to be considered relative to the 96 recommendations At the La Hague site, the implemented crisis organization whose conclusion was checked. and preventive measures enabled the safe operation of facilities that remained in operation and those that shut down. Following contradictory changes in exemption REACTIVE INSPECTION measures for the medical visits of category A personnel, the fitness prolongation initially planned was suspended. No reactive inspections were performed in 2020. This led to delay. An action plan was set up to address this. ORGANIZATIONAL CHANGES AND MANAGEMENT OF SPECIFIC SITUATIONS At Tricastin, the organization and preventive measures enabled the operation at minimum for nuclear and IMPLEMENTATION OF EXEMPTION PROVISIONS conventional safety of facilities that remained in operation and the continuation of high-priority projects (notably The exemption provisions related to the public health Philippe Coste and TRIDENT). The dismantling worksites crisis, authorized by regulatory texts, are described in a were shut down. Except for the significant event at INB technical note issued by HSE Management. This technical no. 155 related to a lack of personnel declared in early document was revised according to regulatory changes. April, no weak signals or any other event caused by the At the Hague, Tricastin, and Melox sites, ASN (French public health situation was escalated on the day of the Nuclear Safety Authority) was regularly informed about inspection. No work difficulties arising from wearing the measures taken and the status of the facilities. surgical masks was noted. No difficulties were escalated concerning the workload associated with the processing During this crisis period, inspections by the independent of accorded exemptions for renewing the medical visits safety sector were ensured by engineers in charge of shift of Orano Cycle personnel. Checking for masks and the operating safety. The majority of regulatory actions were recycling of radiation protection training also caused no completed by the planned date. The exemption measures problems. were deployed for the inspection of respiratory protection devices, replacement of delayed reading dosimeters, the The organization set up at Melox during the shutdown, recycling of radiation protection training sessions, the based on the activity continuation plan (PCA), was aimed
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 21 16/07/2021 06:28 Lessons learned from inspections
at ensuring continuous operation with fewer personnel Tricastin - TRIDENT - Ventilation stack while maintaining the nuclear and conventional safety conditions in accordance with baselines. A “reserve” team was set up during this time to compensate for any absences. The creation of a PCA follow-up committee with supervisors organized in morning and afternoon shifts made it possible to ensure the close monitoring of activities and respond to the needs of operators. However, this organization, especially if it needs to be prolonged, requires an examination of potential consequences, especially a risk analysis, notably in terms of Human and Organizational Factors. A strength lies in the regular communication organized to provide any necessary information to all Orano personnel and its subcontractors.
IMPLEMENTATION OF TRIDENT
As part of the prolongation of the 2018 inspection on the implementation of safety requirements, an inspection was preliminarily conducted for the implementation of the nuclear waste treatment workshop, TRIDENT, at Tricastin. The result was that the requirements associated with nuclear safety, conventional safety, and the environment OPERATIONAL MANAGEMENT OF defined during the design phase have been taken into account. Thanks to the processes put in place by the owner NUCLEAR AND CONVENTIONAL SAFETY and prime contractor, they ensure the facility’s compliance. SUPPLIER MONITORING However, complete implementation requires drawing on a formalized and shared process as well as an updated Inspections on the monitoring of its suppliers took place on schedule. This schedule must include recommendations the premises of NPS BU, then in the workshops of the two issued following the processing of modifications for suppliers of parts used in the manufacturing of transport site waste management, resulting from the startup of casks TN24 and TNG3. Monitoring of the manufacturing TRIDENT. The analysis of compliance with the ASN conducted by quality inspectors, either belonging to NPS decision no. 2017-DC-0587 on waste conditioning must BU or provided by a temporary consortium, appear to be be concluded for all waste to be conditioned. robust. The skill and experience of the two inspectors contacted provides a guarantee of inspection quality. This activity, independent of the NPS BU engineering, has an Tricastin - TRIDENT - Concreting unit accreditation from the French accreditation committee (COFRAC) for the inspection of welding operations and non-destructive testing. The monitoring process is based on a program ensuring robust quality. The skill of the inspectors is based on an initial experience requirement, training sessions and mentoring leading to qualification, then on periodic follow-up of their skills. However, awareness-raising around preventing the risk of fraud must be extended to all inspectors whether they belong to Orano or the temporary consortium. Finally, monitoring activities and the checking of supplier files require that the inspectors have access to all requirement documents, provided in an updated form by the engineering department.
MONITORING SERVICE PROVIDERS
Two inspections on service providers were conducted at Marcoule and Tricastin.
The inspection at Marcoule within the scope of activities for the CEA highlighted that the monitoring of service providers was satisfactory. The centralization of BU DS purchases in 2018 was a positive point for the uniformity
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 22 16/07/2021 06:28 22-23
of practices. The Group’s directives with regard to compliance with requirements applicable to hydrazine monitoring service providers were applied. The documents storage must be assessed. In addition, the compliance of made available to subcontractors carry forward the CEA’s various storage areas for chemical products in the central requirements, based on compliance with the French quality warehouse must be checked and the industrial operator order of August 10, 1984, and the Group’s requirements made aware of the chemical risks. The inventories of in the area of nuclear and conventional safety. During chemical products with quantities lower than 250 liters visits in the field, subcontractor preparation of operations must be better monitored by the workshops and the and their implementation were compliant with applicable concerned site entity. The concerned operators must rules. Finally, the monitoring plans meet the defined needs. be trained to develop a culture around chemical risks. However, the strict application of the Group’s procedure The action plan around sizing the leak containments, concerning the hazard table for activities must be further made in application of the ASN decision no. 2016-DC- improved and the specifications must be more of a 0360 concerning the environment, must be continued. driver for the application of best practices for managing Concerning the experience feedback for the LUBRIZOL worksites, such as the use of reliability practices and “5S” fire and in response to ASN’s request, the inventories do approaches. not enable, at the inspection date, a totally exhaustive real-time view of all hazardous substances present on the The activities assigned by Tricastin to outside subcontractors site. The response to this request is being processed at are based mainly on the processes of the Integrated the Group level. Management System. Some of these processes are classified as activities important for protecting interests On TEMIS sites in northwest France, positive changes (AIP). Their monitoring was considered by ASN in 2018 to have been observed since the 2018 inspection in the require strengthening. It is the subject of specific monitoring area of chemical product management. Several editorial by the site management committee. These out-sourced projects and projects to harmonize practices between the activities mainly concern maintenance. Their performance sites were initiated and remain to be brought to a close. is structured around advanced tools that contribute to the However, the application of the Group’s pillars concerning precision seen in the field. The deployment of monitoring handling must be reinforced. In addition to the defense plans has significantly progressed. It must be carried to improvement actions against fire risk that were requested term while taking into account the new organization of during the 2018 inspection, additional prevention the site. The involved actors are trained in the regulatory measures such as the strengthening of fire permits and requirements and local characteristics. The preventive the de-energizing of electrical equipment when rooms are provisions for making the operations safe are effective. not occupied, must be deployed. Maintaining equipment However, the classification of AIP by Purchasing must important for safety and periodic regulatory inspections be developed and a model for preparing descriptions must be improved. Furthermore, the degreasing-pickling- of requirements that includes regulatory and internal passivation room at the Valognes site must be brought into requirements must be defined. However, the monitoring regulatory compliance as soon as possible in accordance of subcontractors must be continued. with the requests of the regional department for the environment, town, and country planning and housing OPERATIONAL PRECISION (DREAL).
The inspection at Malvési shows that the state of the site’s WASTE MANAGEMENT outside areas as well as the facilities and worksites visited are satisfactory, enabling the free and safe circulation The inspection involved the INB no. 151 and the applied of vehicles and people. The inspected activities are development center of the Melox site. covered by procedures; documentation is available to the inspectors. However, the examination of the recording At the INB no. 151, waste management is particularly documents showed that improvements are necessary important because of the variety of waste generated and concerning the quality of preparation, the exhaustiveness the importance of radiological sorting that goes with it. of information, and the identification of signatories. Some This management is satisfactory. However, updating of the prevention plans examined included inaccuracies and the consistency of the applicable baseline must be and the checks to be performed by specialists were improved, due to the changes in facilities and practices. lacking. Improving the precision of fire permits is also necessary. Finally, the use of a plasma cutter requires The applied development center ensures that research careful attention. The analyses performed by specialists and development programs are carried out on MOX fuels at the site should be completed with experience feedback and that pre-industrialization operations take place. Waste from incidents that occurred in the past on other sites. management in this facility must make progress to better comply with the provisions defined in the prefectural order MANAGEMENT OF CHEMICAL PRODUCTS and the waste management plan. The organization of the INB must be extended to the applied development center The inspection of the La Hague site shows that the site so it benefits from existing methods and good practices. baseline on the management of chemical products is The interfaces between these two facilities must also be robust. Best practices were observed in the field. However, better coordinated.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 23 16/07/2021 06:28 Lessons learned from inspections
MANAGEMENT OF PERIODIC INSPECTIONS AND At Malvési, the management of periodic inspections TESTS and tests is satisfactory. It is defined by organization documents covering all concerned equipment. On Following numerous deviations on the performance of the day of the inspection, all the tests planned were controls and periodic tests, the General Inspectorate performed, with the exception of six devices, for which conducted a cross-functional review of the control of their inspection was postponed pursuant to the exemption management process. provisions of ordinance 2020-306 of March 25, 2020. Harmonization of practices must be strengthened by Melox is correctly organized for managing periodic drawing on the model used by the technical department. inspections and tests. On the day of the inspection, none of This specifically concerns quality assurance for managing the in-service equipment items appeared to have exceeded lists of measuring equipment for radiation protection. their inspection date. However, the extension of the computer In addition, the information of the safety-quality- management tool to all types of inspections and tests and environment department must be improved along with the strengthening of the collection of management- and the independent control of this department relative to the inspection-related are not likely to extend management approach to periodic inspections and tests. precision and induce continuous progress.
At the Tricastin site (INB no. 105, no. 155, and plant W), WORKPLACE SAFETY the process is defined and the tools are in place for the inspection of the process’s progression. The management The inspection conducted around controlling occupational principles are complied with, and no deviation on the safety and radiation protection during activities progression of this process was observed. Managing conducted by Orano, the industrial operator of the Aube periodic inspections and tests is mainly carried by the disposal center operated by Andra, showed that the maintenance process. The computer management tool results in terms of safety and radiation protection for and the inspection procedure for its configuration are 2019 are satisfactory and lower than the set limits. The sufficiently rigorous. The generalization of inspection personnel are committed, motivated, and skilled. There management using this tool is a desirable area for are many awareness-building actions. The Group’s improvement. The target of 98% for performing safety pillars were applied; however, their use is still inspections according to schedule has proven difficult on uneven in the field and must be taken further. Experience the chemistry part; conversion and action plans have been feedback from abnormal situations is analyzed and the defined accordingly. Finally, the reliability of summary efficiency of corrective actions is checked as part of the tables of periodic inspections and tests related to the supervisory program the following year. However, all conventions between operators and the maintenance operators must be trained in radiation protection and department must be improved, namely by implementing must regularly participate in radiological exercises. The quality assurance procedures. This will make it possible conditions of radiological operations must be improved in to avoid dysfunction in the scheduling of inspections the “inventory” room. Finally, risk prevention in the area as illustrated by the event declared on November 27, of falls from height must be strengthened when CBFK 2020, at INB no. 155, concerning the absence of periodic packages are unloaded. inspections of three effluent tanks classified as equipment The general organization for safety at the Innovation important for protection (EIP). Center in Extractive Metallurgy of Bessines-sur- Gartempe site is satisfactory. The interfaces between the Operators at the Malvési site closed and independent worksite and the other facilities are limited to what is strictly necessary by means of a specific entry and a dedicated parking lot for the vehicles of the companies working on this worksite. The handling of public health conditions is also satisfactory.
The exchanges around the safety action plans between the owner and the general contractor in charge of construction are flexible and responsive. The safety pillars are correctly included in the instructions. However, their application in the field can be perfected and their prevention rules must be clarified and made uniform between the companies performing the same types of work, especially the provisions concerning personal protective equipment. The rules of physical separation between trucks, machinery, and pedestrians must be better defined and implemented. The rules for preventing fire risks must be strengthened. Finally, the conditions of use for elevating platforms and scaffolding must be checked.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 24 16/07/2021 06:28 24-25
Operator of Orano DS at the Aube disposal center (CSA) on behalf of Andra so that only approved criticality engineers can issue opinions and make recommendations during operation or emergency situations. In addition, the various obligatory training courses must be defined and taken account of as AIP.
SPECIFIC SUPERVISION AND SURVEILLANCE
REGULATORY COMPLIANCE
The TRIADE inspection showed that this site is part of a voluntary approach to improving regulatory compliance of its facilities and in an intensified dialog with the supervisory administrative authorities. However, the prefectural orders must be included in the new regulatory watch system deployed in 2020 and a bridge document justifying the application must be developed. A process of managing modifications of facilities and their impacts on regulations must be deployed. Finally, REACH and CLP regulations must be better taken into account in operational processes.
In 2020, the annual report on progress made in old waste recycling and conditioning projects involving La Hague showed that the risk management for these activities complies with safety requirements. The processes of CONTROLLING MAJOR RISKS prime contracting are periodically assessed and are part ASSOCIATED WITH SAFETY FUNCTIONS of a continuous improvement approach. The interfaces are organized and the organization is defined in an internal RADIATION PROTECTION baseline. The safety baseline applicable to recovery and conditioning of waste (RCD) projects is complete. It Given the activities at the Melox plant and the toxicity of was revised to meet regulatory requirements. The RCD the material used, radiation protection is a major issue. activities classified as AIP are conducted according to The level 2 significant event, according to the INES scale site procedures and the requirements of the French INB of February 11, 2020, concerning an exposure above the order. Inspections and monitoring have been set up. annual threshold is confirmation of this. The inspection The characterization of maturity is being developed and highlighted that the action plan taken following this event was verified on four projects. Visits to silos 115 and 130 was correctly conducted and that the operations were revealed that these facilities are in good condition, that carried out according to a clearly defined organization. standards on reliability-building practices of operations The external exposures remain high with a collective and the Group’s pillars are applied, and the monitoring dose on the rise in 2019, due to exceptional work. The of the worksite carried out by the prime contractor and practices are based on methods and awareness of the with regard to safety requirements is of satisfactory radiological risks. However, the contribution of actors quality. However, compliance with the internal baseline must be strengthened so that radiation protection is an or provisions of the French INB order require consistency integral part of operations, notably for subcontractors between the responsibilities of the facility managers, in charge of maintenance. The inclusion of experience involving management of major projects with the feedback in the operational documents for preparing provisions of the internal system of responsibilities. It operations must be improved to reduce worker exposure. also entails taking account of RCD project milestones, The characterization of AIPs associated with radiation the definition of waste packages in the AIPs already protection, particularly for training the personnel and implemented on site, and finally, the inclusion of the implementing checks must be improved. characterization as the best available technique for waste packages in the project’s management plans. CRITICALITY The inspection cycle for checking the application of The Tricastin inspection showed that the level of control the ASN decision no. 2017-DC-0592, relative to the of criticality is satisfactory overall. Criticality engineers preparation and management of emergency situations, are experienced and specifically assigned. The operating which supplements the INB order for the requirements personnel are aware of the issues around criticality and associated with crisis management, was taken further rigorously apply the related instructions. Nevertheless, with the Melox site in 2020 and will be completed with the organization around criticality must be better defined La Hague in early 2021.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 25 16/07/2021 06:28 Lessons learned from inspections
Aerial view of TRIADE
The Melox site took account of this decision by initiating were reviewed. The sites used 2018 and 2019 to update the necessary actions to comply with the provisions of their change management processes. To do so, they were this decision. Nonetheless, since certain obligations had to helped by specialists from the Group HSE management; be finalized in 2018, notably the sizing study, monitoring, the objective was one of facilitation, of limiting the risks and updating conventions, the implementation of the related to the interpretation of complex regulations, and operation documentation in emergency rooms was not of harmonizing new methods. This work resulted in the brought to term. In addition, equipment from additional publication of a Group internal directive. The inspections safety assessments are not stored with the expected conducted examined the use of the regulations, the compliance in cabinets and suitable rooms. The inspection effectiveness of the provisions implemented, and the was completed by checking the reliability of emergency experience feedback between the sites. electrical power supply systems which highlighted that these systems are operational and that the people in The processes are mainly based on modification request charge of their control have received training. However, files called “FEM-DAM”. They make it possible to analyze the risks of common-mode failure have not been analyzed the impact of the change, define the required level of and the monitoring of the generators used in emergency authorization, list the requirements to meet, manage situations, entirely subcontracted, must be strengthened taking account of requirements, and formalize the to improve failure risk identification or early aging. authorization of implementing the change. Updating the processes for managing changes made it possible to The general inspection took place, between 2019 and include new ASN requirements at Melox and La Hague. 2020, on the La Hague, Tricastin, and Melox sites. The Further details are to be added for the Tricastin process. inspections covered the implementation of the provisions An assessment of compliance with the ASN decision in the ASN decision no. 2017 DC-0616 relative to INB remains to be formalized for the La Hague and Tricastin modifications. Operation of an INB requires the capacity to sites. The criteria for classifying the change were revised change the technical and organizational means described in compliance with the criteria of the ASN decision. in its safety documents. These modifications result from Particular attention must be paid to temporary changes to internal factors for production and maintenance, customer show that they remain within the scope of the authorized requests, or external causes. The frequency of these baseline. They must be covered by an agreement of the modifications is high. Changes in regulations, with the nuclear safety department and must be included in the change in the classification of substantial modifications, change management process. The organization deployed significant or insignificant, made it necessary to adapt the for verification and assessment as well as the associated organization of the site. Thus, the internal auditing bodies semantics must continue to be brought into agreement replaced the internal authorization commissions. The with the requirements of the INB order. The organization methods and the criteria for classifying the level of changes of internal audits was defined. These entities have been
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 26 16/07/2021 06:28 26-27
tested and are operational. The formal elements and 2020 recommendations the expectations must be better defined at Tricastin. The interactions with the local committees for nuclear safety The inspections conducted in 2020 led to the issuance and the internal authorization committees for startup of 87 recommendations, a figure comparable to that must be detailed at La Hague and Tricastin. The internal for 2019. Their breakdown, detailed in the following two audit body has been called upon for all significant changes figures, is coherent with the inspection themes that were subject to authorization since July 2019, in accordance with verified during the year that was just completed. applicable regulations. For significant changes subject to a declaration, the opinion of the entity must be in survey form. This is systematic at the Tricastin site because it lacks the experience feedback necessary to define the survey criteria. The entity was not asked by the La Hague site in 2019 for the significant changes subject to a declaration because the experience feedback was deemed sufficient.
The implementation of the internal authorization systems is satisfactory. The transition period was used to include new requirements and adapt the processes with sufficient lead time. Melox led the operation with a specific project. La Hague also updated its entire baseline. The management of recommendation monitoring sheets must be improved with a more rigorous application of the process. The verification and assessment action programs must take Figure 2: Breakdown of recommendations of the GI according to area (in %) account of the modification activities more broadly, notably the management of these monitoring sheets. The use of workflows for the management of FEM-DAM is in practice at La Hague and planned for at Tricastin. This tool has the capacity to improve the precision and facilitate the compliance with the process timeline and the control of associated technical inspections. At Melox, FEM-DAMs are electronically archived, which improves their traceability. The training for those involved has been started; it must be finalized and tracked for 2020.
ASSESSMENT OF THE DESIGN AUTHORITY
The deployment of the design authority was initially assessed within the scope of the La Hague facilities, with the exception of the facilities being dismantled. Given the lifetime and the complexity of nuclear facilities, according to international standards, the design authority works on behalf of the operator and aims to guarantee in-depth knowledge of their design and to justify the associated technical choices from the initial design up to dismantling. Its scope covers the maintenance of knowledge of the design.
The result of this assessment, based on a documentary Figure 3: Breakdown of recommendations of the GI according to subdomain (in %) analysis of organizations and procedures, as well as interviews of the various actors, are the main elements, as follows. The control over the design of the facilities is based on a robust organization consisting of several management entities; they have the support of the BU Recyclage and the BU Orano Projets. The associated activities are controlled through various processes and procedures of the integrated management system for the facility modifications and for the projects. The sharing of roles and responsibilities is defined. At this stage of deployment, the design authority is not yet sufficiently shared by the concerned actors and must be made more operational.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 27 16/07/2021 06:28 Checks being carried out on the NCPF project at the La Hague site
Operating feedback from events involving safety and radiation protection
1 event classified as level 2 on the INES scale, seven events classified as level 1, and 138 level 0 events were declared by Orano or involved Orano.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 28 16/07/2021 06:28 28-29
A level 2 event on the INES scale was declared in 2020. After a consecutive decrease between 2015 and 2017, It involved the exposure of a worker to a dose above the the number of events has remained stable for 3 years. In annual regulatory limit. It took place during work in a glove 2020, the radiation protection field specifically involved in box at Melox (see insert on pages 42-43). The previous 3 events where people were exposed, similar to the level level 2 event was within the Group’s scope. It dated back 2 event mentioned above. to 2010 and also involved internal contamination. 138 events were classified as 0 level on this same 145 significant events of level 0 or 1 on the INES scale scale. These entailed deviations had no impact and were were declared to the French safety authority or were characterized by “weak signals”. They must be taken voluntarily taken into account by Orano as experience into account in the continuous progress approach and feedback. These events had no significant consequences improvement in terms of risk prevention. for the personnel, the public, or the environment. The regular increase in the total number of events 7 level 1 events according to the INES scale involved observed since 2018 has been borne out. For 2020, it is situations that were not compliant with radiation explained by the increase in radiation protection events. protection regulations as well as anomalies without safety consequences: The proportion of these events declared by Orano • two cases of exposure of a worker which led to involving a reclassification of a declaration upon request a quarter of the annual individual dose limit at La by ASN was 15%. This ratio has remained constant for Hague being exceeded. It occurred during a service 3 years. performed at a nuclear power plant, • a cumulative exposure to a dose exceeding the The rate of prevention of these events, or IPR, was 0.06 at regulatory annual limit for several workers at a the end of the year. This result remains compliant with the mine site in Niger, objective of 0.1 maximum. • degradation of a confinement barrier without Their breakdown by domain is as follows: dissemination during work on a storage silo containing radioactive sludge at La Hague (see insert on pages 40-41), • a monitoring failure involving the mass of uranium- bearing materials in a storage area at the Georges Besse plant at Tricastin without the total authorized mass being exceeded, • a failure in the characterization of two drums of waste containing uranium at Tricastin, • periodic inspections required by the operating rules at La Hague were not performed; this was detected during in-depth investigations initiated following a series of events of this type in 2019. Figure 5: Breakdown by the field of significant events impacting nuclear safety
Figure 6: Changes in the number of significant events impacting nuclear safety by field
Of the total 146 events declared in 2020, 80 were for Figure 4: Changes in the number of significant events safety (55%), 33 for radiation protection (23%), 19 for impacting nuclear safety transportation (13%), and 14 for the environment (9%).
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 29 16/07/2021 06:28 Operating feedback from events involving safety and radiation protection
Radiation protection events are experiencing strong others were related to malfunction in room ventilation. Six growth (+ 65%), including the level 2 event and the 3 of these events led to localized dissemination at Tricastin events classified as level 1 on the INES scale mentioned and Melox, with no environmental impact. These events previously. occurred during maintenance operations.
The number of events related to nuclear safety and One third mainly concerned non-compliance with the transportation has slightly decreased, whereas those frequency of inspections or tests called for by the general involving environmental protection have remained stable. regulations or by the general operating rules of the facilities. These events are significantly increasing.
Their analysis shows that they share the organizational Safety of facilities causes often related to organizational changes and/or changes in the frequency of periodic inspections and tests Focus: the events declared for reasons of safety at Orano (CEP) poorly transcribed in the documentary baselines of facilities or facilities operated by Orano show according the facilities. Given the actions taken at these sites on the to different safety functions the following breakdown and human and organizational factors involved in these events, a changes: significant decrease in this type of event is expected for 2021 and, from this point of view, must be a monitoring focus.
Figure 7: Breakdown by safety functions of significant events involving nuclear safety of Orano facilities
Figure 9: Changes between 2019 and 2020 in the number of events linked to the confinement function
CRITICALITY FUNCTION
The 8 events regarding control over the reactivity of fissile materials mainly concern insufficient control over the authorized limits required under the operating baseline of the facilities, without exceeding safety limits.
These events are decreasing mainly due to the improvement at Marcoule in characterizing old waste; Figure 8: Changes by safety functions in significant events this makes it possible going forward to better assess the involving nuclear safety of Orano facilities masses of the fissile materials that they contain.
This distribution highlights that: • the events occur mainly during regular operating SUPPORT FUNCTIONS and maintenance activities, The number of events relating to support functions is • the portion of the events related to confinement of decreasing relative to 2019. This primarily concerns radiological material remains preponderant and is defects in electrical power at the facilities. It is mainly a significantly increasing, whereas other events are question of unavailability or spurious startups of the decreasing. generator sets and electrical disturbances during storms.
CONFINEMENT FUNCTION The number of events linked to controlling fire risk seems to be significantly decreasing. However, at the La Hague site Approximately half of the 53 events related to controlling there was a fire in its off-line transit platform, the probable the confinement of radioactive materials were mainly cause of which was a short-circuit in a unit heater. Given caused by degradation or loss of leaktightness in that the building was far from the nuclear workshops, the equipment containing radioactive materials, whereas the fire had no impact on people or the environment.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 30 16/07/2021 06:28 30-31
Protecting the environment
Fourteen events classified as level 0 on the INES scale as well as 34 other events (not on the INES scale10 and on or not on the ARIA scale) were declared for reasons of environmental protection.
Nineteen events involved occasionally exceeding limits Figure 10: Changes between 2019 and 2020 in the number of events and were limited to the thresholds authorized for the linked to support functions release of effluent; they had no impact on the environment.
Among these, 12 events concerned isolated releases of Radiation protection fluorine and 4 others concerned uranium These events were linked to operation of the Philippe Coste conversion The radiation protection events have increased plant at Tricastin. Excess uranium events went down with significantly compared to last year (33 in 2020 and 20 the replacement of the crystallizers at the beginning of in 2019). This increase is due in particular to failures in 2020. By contrast the excess fluorine events, linked to the radiological cleanliness at Tricastin and failure to wear performance of effluent purification systems, have lasted. dosimeters. These issues were more or less related to the An action plan was set up to improve the performance of radiation protection culture. purification of ventilation systems. Some actions, linked to facility design, will be completed at a later time. Among these events, 5 concerned internal exposition of personnel. Eleven other events concern uncontrolled releases, mainly due to loss of leaktightness in equipment containing a These events well be examined in greater detail in the cooling fluid. chapter on radiation protection (see page 44 of the report).
Industrial safety Transportation safety The events concerning industrial safety undergo regular Among the 19 transportation events declared by Orano, monitoring. In 2020, there were three singular events on 8 concerned operators and are decreasing. The 11 others mining sites. They had no consequences for the personnel were detections by Orano sites of defects found on or the environment: reception of casks shipped by other operators. • an ammonia leak occurred during preventive maintenance on a temperature probe of a tank. The events involving perforation of drums of uranium- Its initial cause was a tank configuration without bearing mining concentrates during their transportation thermowells11 while the other two existing tanks have decreased concerning the shipments made by the had this leaktightness barrier. The drawings used Group, even though these events were recurrent. did not mention this configuration difference, • releases of sulfur oxides, • a fire in a reagent storage area initiated by drums Transportation of uranium-bearing materials, McClean site, Canada of sodium chlorate.
Summary per site
La Hague
Among the 41 events declared by La Hague, three events are INES level 1 events: • contamination of a worker’s hand that led to an excess of a quarter of the regulatory annual individual dose limit for exposure of the skin. This occurred during the decontamination with a cloth of the blade of an agitator that had a surface irregularity, • perforation, without dissemination, of the roof of the radioactive sludge silo during works. The peroration was caused by a drilling method used by the service provider that could not guarantee compliance of the depth of the drilled holes,
10 The events that are not related to radiological or nuclear safety cannot be classified using the INES scale. Furthermore, they are declared to the authorities with the classification “off the INES scale.” 11 Thermowell: a tube connected at one of its extremities to a wall or a pipe in a leaktight manner so a temperature probe can be inserted. General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 31 16/07/2021 06:28 Operating feedback from events involving safety and radiation protection
• a failure in the performance of periodic inspections Operator conducting assembly work, Tricastin site or tests (CEP) that were not performed before the deadlines set by the operating baseline. This failure was detected following a prior event, from which point the facility underwent the verification of the entire performance of these CEPs. The work carried out last year on the compliance with deadlines continued this year with verification in greater depth of the performance conditions, which once again led to the declaration of events. Given this analysis, 2021 should show an improvement in this field.
The heightened support and monitoring of service providers remains an important issue for La Hague, in particular for the work on confinement barriers.
The degradation of the backup diesel generator sets is still monitored closely with two events declared, in particular during short “no load” startups which do not allow sufficient lubrication of the motor parts.
While events linked to fire risk control have decreased, La Hague nonetheless had to contend with the fire in its laundry transit platform.
La Hague site
aggressive liquids that over time locally degrade the coating ensuring the retention’s leaktightness.
In these circumstances, there is a potentially aggravating factor in case of an equipment leak. The experience feedback covering all these events must be understood within the scope of the site and these practices must stop being used in order avoid recurrence of such events.
Fourteen events linked to radiation protection took place at the site. They concerned radiological cleanliness failures and radiation protection culture (dosimeters not worn, the rules for accessing radiological areas not complied with, and the behavior in response to a dose rate alarm not followed), in particular at the TU 5 workshop which nonetheless planned for intense awareness-building of its Tricastin personnel around radiation protection rules.
Among the 85 events declared by Tricastin, 8 losses of Thirteen isolated and limited events of exceeding the leaktightness occurred on the site, mainly concerning the authorized limits for releases of radiological and chemical tanks and to a lesser extent waste drums, without impact gaseous effluents occurred recurrently at the Philippe on people or the environment. Coste conversion plant.
However, the events also concerned retention management The radiological excess events have decreased with the failures such as the known presence of liquids reducing replacement of the crystallizers and the addition of filters to the available volume, or the draining of hoses containing trap uranium aerosols before release into the atmosphere.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 32 16/07/2021 06:28 32-33
Melox
The 7 events at the plant mainly concern 3 losses of leaktightness that led to dissemination of radioactive material, one of which caused the regulatory annual individual dose limit to be exceeded for a glove box operator.
This event highlights the importance of tidying inside glove boxes to avoid a glove from being snagged and thus cause perforation.
This problem around gloves, the subject of an advisory committee at Melox, must not distract attention from the problem of leaktightness losses in pipes which this year once again resulted in dissemination.
Malvési
The 5 events a Malvési, like those last year, concern the detection of dissemination of uranium-bearing material inside a container on arrival of transport containers with drums of uranium-bearing mining concentrates, for which Malvési systematically alerted the sender so it could analyze the causes of the event and take measures to avoid it in the future.
Impact of the COVID 19 public health crisis on operating safety
During this period, only one event was declared to ASN par Orano in its role of nuclear operator. However, the experience feedback from the first period of strict national lockdown made it possible to identify the points to monitor during this type of situation, notably compliance with: • deadlines of periodic inspections and tests, taking account of the impact on the scheduling and Excess fluorine events remain constant. Studies are performance of CEPs due to changes to work underway to improve its trapping before the release of organizations during the lockdown, gaseous effluents. • the makeup of the minimal safety teams as stipulated in the facility baseline, However, this involves significant changes to the design • requirements related to transports for casks loaded of ventilation systems because the requirement of and closed then stored in the facility until they are continuous monitoring of the releases is new relative shipped. to the COMURHEX I plant. This made it impossible to calibrate the limits currently in force for isolated releases by taking past experience feedback into account. Analysis of the quality of reports As a result, to take into account feedback from the operation of the plant, proposals were sent to ASN to The significant events declared according to the INES change certain limit values. scale, as well as the events declared off the scale, are covered by a detailed report to identify their causes and Marcoule be able to set up improvement actions that are suitable and sustainable to efficiently prevent their recurrence. Of the 28 events declared for Marcoule, 12 of them involved non-compliance with periodic inspections and tests (CEP). Performing this analysis depends on the quality of the This situation led Marcoule to set up, with methodological report to the extent that: support from DHSE, an advanced analysis of the human • the description of the event makes it possible to and organizational causes of all of these events. identify all the potential causes to analyze, • the depth of the analysis makes it possible to work As to the events related to characterization failures of the back to all initial causes, mass of fissile materials contained in old waste, they are • the measures taken to cover the causes identified now resolved. by the analysis are sustainable.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 33 16/07/2021 06:28 Operating feedback from events involving safety and radiation protection
This quality is assessed in three areas, in compliance with Compared to 2019, a decrease in events with only the following principle: assessments A, B, C, and D are technical causes (-7%) is observed, whereas events with attributed to the reports with respectively 3, 2, 1, or 0 of mixed causes (+8%) have increased. Two elements may these satisfactory areas. explain this change: • a decrease in the events related to the design of the Philippe Coste plant which played an important role concerning the technical causes in 2019, • a better analysis of the HOF causes of events when the initiating factor is technical.
FOCUS ON THE HUMAN AND ORGANIZATIONAL COMPONENT
The analysis of events from a HOF perspective covers 124 events (one level 2, seven level 1, 96 level 0, and 20 off the scale). It makes it possible to identify several types of human failures (see figure 13): • errors of information, present in 46% of events; they are mainly linked to erroneous representations due to a lack of information in the environment (signaling), a lack of information in the operational
Figure 11: Changes between 2019 and 2020 in the quality documentation, or a lack of clarity in the information of detailed event reports provided, • errors of knowledge, present in 12% of events; this So in 2020, the proportion of reports ranked A and B type error is less present than in previous years decreased to the advantage of rankings C and D. (-15% compared to 2019). A significant amount of work has been conducted for the Group’s various The assessment of the quality of the reports shows: sites since 2018, which may explain this result, • clear descriptions of events, • routine errors; these are the most frequent failures • insufficiently in-depth analyses of causes, in human activities (80% of errors) and are present particularly on organizational aspects in only 15% of events. This rate, constant for several • inconsistency in the action plans. years, shows that the technical and organization systems are tolerant of this type of error (prevention, It is also in part linked to authors newly assigned to detection, limiting consequences), preparing reports. DHSE has therefore supported new • finally, voluntary human failures or infringements teams in their preparation of their first reports. on the rules are present in 9% of events. This rate is stable compared to 2019. Training in preparing this type of document must be a prerequisite.
Analyzing events
The analysis of these detailed reports reveals that the human factor plays an important role in these causes. As indicated in the following figure, around 80% of events have a human or organization component. This distribution shows little variation from year to year.
Figure 13: Breakdown of human failures in % of analyzed events
In-depth analyses make it possible to identify the causal factors of these human failures, in terms of work situations Figure 12: Breakdown of significant events according to their causes and the level of the processes and the general organization.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 34 16/07/2021 06:28 34-35
ANALYSIS OF CAUSES LINKED TO WORK - the design of equipment, tools, or MHIs not SITUATIONS suited to the activity, - insufficient support of the teams and notably In terms of work situations, three factors stand out the service providers when there are changes significantly: in the organization, with particular impact • operational documentation: 27% of events remain during transition phases (shift to operation, linked to operational documentation, involving transfer of responsibilities), incomplete documentation or documentation that - an insufficient analysis of the impact on is not up to date (absence of application of changes sensitive human activities during changes to to the baseline, for example), procedures and tools. • ergonomics of the workstation: 26% of events are • The preparation of activities and the risk analysis mainly linked to a change in the workstation that process (26%). does not suite the activity (narrowness, absence of visibility, lacking information at the workstation), These factors lead to problems of coordination between • skills: 19% of the events are linked to poor entities (26%) and failures in defining roles and knowledge of the safety baseline, the requirements, responsibilities (16%). the organization, or the processes. The majority of these problems involving skills concern outside The process of managing documentation is also an contractors. important factor in the cause of events, with difficulties related to the updating of requirements and their These three factors continue to be preponderant, although application in the operational documentation. there has been a constant decline since 2018. Since these three factors are closely linked, this result can be explained The process of managing service providers remains a by the work on training. factor to consider (16%). The failures in service provider support in part explain the gaps observed in skills. The increase in the contribution of tools and computer applications is clear (13%): unavailable tools, hidden information, information not present in the application, etc.
Figure 15: Breakdown of failure factors in the general organization and in processes
Figure 14: Breakdown of failure factors in work situations MAIN PROGRESS AREAS in % of analyzed events The results of this analysis of the trends in the events that The analysis of the main causal factors in work situations occurred in 2020 make it possible to identify the following shows that defining tools, documents, and workstations is progress areas: not based on a sufficient analysis of the needs of operators to carry out their activity. • concerning workstations: - improve the incorporation of needs related ANALYSIS OF CAUSES RELATED TO PROCESS AND to human activities during the design and ORGANIZATION modification of work situations: accessibility, visibility, and availability/display of necessary The preponderant factors, even if they are present in various information. proportions, remain the same as in 2019. These entail: The internal directive for the implementation of • Design and change of work situations (26%). More HOF in projects has thus been applicable since specifically, the events are linked to: January 1, 2020. Experience feedback around
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 35 16/07/2021 06:28 Operating feedback from events involving safety and radiation protection
its application will be performed in the second half of 2021 to ensure that operators implement it and identify the potential difficulties.
• concerning skills: - improve support for service providers so they have a better understanding of risks, processes, equipment, and applicable rules, in particular during transitions phases. Work is thus planned in 2021 to identify best practices in the area of subcontracting and supporting service providers.
• operational documentation: - integrate the needs of operators in the design of operating procedures (MO) for more suitable documentation. The application of the Author Guide for Operating Procedures, published in 2019, should improve this point, - ensure the proper application of technical and organization changes in the MO for documentation that is up to date, - improve the risk analyses including risks of human failure for a more exhaustive documentation. Further to this, a collection of best practices concerning the preparation of activities was prepared in 2020, with the goal of its publication in 2021 (See specific box).
Supervising operator, TRIDENT facility, Tricastin site
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 36 16/07/2021 06:28 36-37
Preparation of activities, an area for progress
BP1: Have an ergonomic tool that supports the process
BP2: Plan for a time for collective exchanges
Iteration Iteration
Definition of Definition of Checks before Data analysis Data collection Validation requirements operations launch
BP 7: Conduct BP 9: Call on BP 11: Call on experts to BP 14: Associate actors for an BP 3: Form a team for defining interviews to specialists in decide whether the information initial comparison with operating requirements obtain experience activities analysis collected is sufficient procedures (MOs)
ACTORS feedback
BP 6: Plan BP 5: Have BP 16: Enable experts to go BP 20: Have a for access to BP 13: Apply the DHSE guide BP 21: Conduct a a support for into the field to flesh out their checklist for lifting documentary for preparing MOs pre-job briefing collecting data opinions hold points TOOLS databases
BP 18: Prepare/ BP 12: Organize a meeting BP 19: Organize plan the operation BP 4: Plan for a meeting for BP 10: Organize a kickoff meeting/ for identification of specific BP 15: Organize a review of BP 17: Organize a meeting for an awareness- during a meeting finalizing requirements prerequisite committee requirements with all requirements comparing opinions raising meeting with prod mgr, stakeholders for the operation
MEETINGS BT, IS, RP, etc.
BP: best practice
The analyses of trends over the past three • in addition, 41% of ESs concerning the preparation years show that the preparation of activities of activities also have a failure in the operational and risk analyses are the cause of more documentation (incomplete, not accurate enough, absent). than 25% of events. The decision was thus made to look more closely at this subject to identify best practices in the area An analysis of significant events that occurred in 2019 of preparation of activities. Work was conducted in and 2020 concerning the preparation of activities shows a working group with HOF specialists and leaders, that: managers and nuclear and conventional safety • 51% are due to failures in the risk analysis process, engineers, facility managers, and maintenance identification of risks, or implementation of the representatives. This work made it possible to prepare a provisions of risk control (failure in the design or collection of best practices to implement at the various modification process), stages of the process of activities preparation. These • 31% result from an absence of analysis in general best practices concern the actors to bring into sensitive activities: risk of unidentified human each step of the activity preparation process, the tools failure or unsuitable/insufficient provisions of to use, the interfaces, and the exchanges to implement. risk control, • 15% are linked to a poor definition of operations and conditions of operations; these events are correlated with failures in risk analysis and analysis of sensitive activities, • 15% are linked to scheduling problems with a wide range of causes: management of absences, production pressure, coactivity management, coordination/communication, • only 8% of failures linked to the preparation of activities are related to difficulties in the implementation of briefings or pre-job briefings,
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 37 16/07/2021 06:28 Operating feedback from events involving safety and radiation protection
Focus on periodic inspections and tests (CEPs)
In 2020, 21 significant events concerned exceeding the periodicity of or deviations in regulatory periodic inspections and tests or those planned by the general operating rules (RGEs) of the facilities.
These events mainly concern the activities where Orano is an industrial operator, but also, though to a lesser extent, the activities of nuclear operators. Figure 18: Breakdown of human failures during significant events related to CEPs
The causal factors linked to work situations concern operational documentation—it is either incomplete, inaccurate (ambiguous requirements), or not presented to operators—as well as unavailable computer applications such as CMMS that are unavailable, not updated, or that contain inaccurate information (frequencies).
Figure 19: Breakdown of causes linked to working conditions during significant events related to CEPs
Figure 16: Breakdown of significant events related to CEPs Thus, documentation and support tools for periodic controls and tests (CEPs) need to be improved. The analysis of the event causes, based on their detailed reports (13 out of 21), shows that in all the cases human The causal factors around organization processes or and organizational factors are the initiating events. general organization concern:
• firstly, coordination with service providers when operations are prepared: - coordination failures between the operator and the service provider, upstream of performing the activity, - risk analysis failures and those of planning operations, - failures in supporting service providers linked to providing incomplete information
Figure 17: Breakdown by cause of significant events or misunderstandings upstream of the CEPs, related to CEPs - failures in monitoring service providers linked to a lack of control over CEPs. Human failures are mainly errors linked to an incorrect representation of the situation (incomplete • secondly, change management related to poor transmission of information) or a misunderstanding of application of changes in the RGEs, problems of the rule to be applied. transferring responsibilities between facilities
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 38 16/07/2021 06:28 38-39
and between projects and facilities, as well as the management of unusual situations related to CEPs not being handled during long-term outages or due to the public health lockdowns.
Figure 20: Breakdown of causes linked to processes and general organizations
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 39 16/07/2021 06:28 Operating feedback from events involving safety and radiation protection
Drilling the cover slab of a silo containing radioactive sludge
THE FACTS department, the worksite managers and the operating managers for the silo. The worksite was brought to safe Facility presentation configuration, shut down, and the holes filled in.
The function of the STE2 workshop in INB no. 38 was A radiological inspection was performed at the to chemically treat effluents. The sludge from this concerned holes and on the tool used even though treatment is stored in silos covered by a slab with a contamination was not found. Throughout the drilling thickness of one meter. The upper side of this slab is in work, the ventilation of the building housing the silo contact with the outside. was in nominal operation and no disturbances were noticed. As part of improvement work to recover the sludge in the silos, the strengthening of the silo 13 slab that was to On February 5, 2020, a video inspection of the slab at receive a metal structure was performed in three steps: these drill holes confirmed that they were open to the • demolition of the concrete that closed off an surface and that slab thickness was compliant (slab existing trench 450 mm in thickness, thickness of 550 mm at the trench). • implementation of reinforced steel by drilling the slab and sealing with resin (holes of 12 mm in The safety analysis performed as part of the modification diameter and depth of 450 mm), authorization file (DAM) prior to this work involved the • the pouring of concrete. reinforcement of the slab by the horizontal addition of reinforcing steels without making holes. Chronology of the facts As part of the additional studies, the service provider On February 04, 2020, during drilling operations, three suggested other arrangements, notably strengthening workers noticed in the same sequence that their the slab by vertically adding reinforcement steel. This drill bits were no longer meeting any resistance. solution was technically validated by the Group’s “Civil They immediately informed the radiation protection Engineering” teams.
Trench and the reinforcements implemented
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 40 16/07/2021 06:28 40-41
View from above of the trench identifying the three holes open to the LESSONS LEARNED surface The following actions were taken to avoid this event from recurring: • A nuclear safety/conventional safety presentation was held for the civil engineering actors with the operator, owner, and prime contractor in attendance, to raise awareness around safety culture and remind them of the human performance tools (HPT) to use and remind them of the civil engineering work configuration to employ during phase 1 in the silo roof scope with the associated risk description; • Awareness-raising among the prime contractor This event, which had no impact on the workers or teams along with civil engineering and the environment, was classified as INES level 1 due to construction in charge of supervising worksites, insufficient attention to drilling conditions to recover concerning notably a questioning attitude during reinforcement bars. analysis, validation of the execution methods for the work proposed by the supplier, and a This led to insufficient consideration in the documents submission of significant changes related to covering this operation, which in turn led to monitoring these studies; of the service provider in charge of this worksite. • A workgroup was set up to define the provisions Furthermore, because of a lack of attention by the service to implement to improve the owner and prime provider in complying with the operating conditions contractor process for monitoring changes to the was noted. detailed design.
ANALYSIS OF TECHNICAL CAUSES
There was no technical cause in this even..
ANALYSIS IN TERMS OF HUMAN AND ORGANIZATIONAL FACTORS
The human and organizational factors contributing to this event are as follows: • operational documentation: the documentation made available to the workers does not describe the methods for making the holes, • tool ergonomics: the tools were not suitable for the operation: vacuum not effective enough to guarantee complete removal of dust, unavailability of the gage system, and lack of a mechanical stop on the drill compensated by a mark by adhesive tape on the drill bit, • change management: the process of change management does not take into account the reassessment of the safety file in case the work methods are modified, nor the revision of the description document for the works; as a result, the risk of drilling on the slab is not covered, the analysis of work safety is not updated, and operational documentation does not cover provisions to use to guarantee compliance with drilling dimensions, • preparation of the operation: the risk of drilling is not covered in the operation preparation phase. The pre-job briefing at the beginning of the day is focused on worksite coordination and work safety.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 41 16/07/2021 06:28 Operating feedback from events involving safety and radiation protection
Exceeding the annual individual dose limit for an operator working in a glove box
THE FACTS Having finished cleaning the back of the press, the operator decided to check the cleanliness through the Facility presentation panel on the opposite side of the BAG offering a better view of the area to clean. The Melox plant, INB no. 151, produces nuclear fuel consisting of a mix of uranium and plutonium oxides, He then proceeded with his radiological inspections called MOX. which did not reveal any contamination. In compliance with best practices, he knotted the 156 mm-diameter Within the plant, the pelleting unit transforms MOX glove that he had just used. power into pellets with the help of presses inside glove boxes. When he moved the Edgar sensor from his workstation to the opposite panel, the sensor detected atmospheric Timeline contamination and activated a threshold 2 alarm. Shortly thereafter the other sensors in the room activated their On February 11, 2020, an operator was wearing a radiation alarms. protection glove, which was ejectable and had a 156 mm diameter, to clean the back of the glove box containing a The operator rapidly moved to an airlock of the room, press. The workstation was monitored by an Edgar type removing his pre-gloves and positioning his respiratory atmospheric contamination sensor. system protective device, in compliance with the glove box instructions. Workstation entering the alarm state of the measurement sensor Two operators also present in the room for maintenance operations left the room by another airlock.
The inspections performed by radiation protection showed contamination only for the BAG operator. He was immediately transferred to the occupational health department (SST) at Marcoule, which confirmed that there was in fact internal contamination.
During its investigations, the radiation protection department identified that the glove was perforated: a hitch-type hole with a size under 1 mm was identified behind the thumb.
On February 12, 2020, this event was immediately brought to the attention of ASN. The results of the radiotoxicological analyses showed an effective committed dose over 50 years greater than the annual regulatory limit for the operating technician. This result led to the declaration on June 24, 2020, of this deviation to be a significant event from a radiation protection standpoint of INES level 2.
ANALYSIS OF TECHNICAL CAUSES
The analysis of this event did not show any technical cause that led to: • a malfunction in the detection chain of an atmospheric contamination. The source test performed immediately after the event showed the proper operation of the sensors. • a loss of confinement; no attachment point was identified during the expert assessment.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 42 16/07/2021 06:28 42-43
The causes are mainly due to the execution conditions pending this requirement’s inclusion in the of the cleaning operation presented below. general operating instructions, • incorporation of the panel visibility check by the shift supervisor in the general operating ANALYSIS IN TERMS OF HUMAN AND instructions; the shift supervisor will initiate ORGANIZATIONAL FACTORS cleaning if necessary, • analysis of the possibility of moving the The human and organizational factors contributing to conditioning and transfer operations for screwed this event are as follows: pots by including workstation cleaning, • Team makeup and division of tasks: the operator is • creation of a reflex sheet that can be used by alone at their workstation to carry out the cleaning radiation protection agents following an event. operation. The presence of two people makes it possible to provide support for the person who has their hands in the glove box by visually guiding them from the opposite side. • Workstation ergonomics: - the space, which is narrow in the glove boxes, generates constraints to performing a complete radiological inspection of the glove when the hand is removed, - the environment inside the glove box at the back where the press is contains mechanical process parts; the work area is narrow and the dust on the glove box panel reduces visibility. • Ergonomics of equipment: the size of the gloves makes them hard to remove. Its characteristics glove minimize the radiological impact on the operator at the expense of its mechanical resistance, which is reduced compared to other types of gloves. The glove storage support is such that it requires numerous manipulations of the glove, which may aggravate loss of confinement if not detected.
LESSONS LEARNED
The following actions were taken to avoid this event from recurring:
On the technical level: • the study of a system of stops for gloves with diameter of 156 mm, • the addition of a storage system for the tools to free up the work environment; also, the revision of standard 5S, • performance of an inventory of the screwed transfer pots and replacement of damaged pots by new pots, • performance of a feasibility study for changing the glove box panels and modifying the diameter of the glove port, • improvement of the lighting for the glove boxes in the “press” workshop.
On the HOF level: • setting up a temporary instruction indicating the requirement of two people at this workstation,
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 43 16/07/2021 06:28 Radiation protection test, Melox site
Radiation protection
After several years of stability, various radiation protection indicators make up a signal that must result in increased vigilance in daily activities in 2021.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 44 16/07/2021 06:28 44-45
he Group’s activities are very diversified; French regulatory annual limit of 20 mSv, and is the same the Group proposes products, technologies, order of magnitude as in previous years. and services in mining, uranium chemistry, T The average dose over 12 consecutive months for Orano’s enrichment, spent fuel recycling, logistics, engineering, and dismantling. employees is 0.9 mSv; for the employees of outside companies it is 0.8 mSv. These values are calculated from dosimeters using different technologies (delayed This wide diversity of activities generates significant reading dosimeter for Orano’s personnel and operational variability of the induced radiological risks and potentials dosimeter for the personnel of outside companies). for exposure to ionizing radiation, that forms part the environment in which the technicians work. For Group employees, the trades that recorded the highest average annual doses are those working in mining To successfully perform these activities in the Group’s activities (2.8 mSv), those working in glove boxes at 2.5 facilities but also in those of its clients, in France and mSv, and those in nuclear service activities performed abroad, Orano’s employees as well as those from outside during maintenance operations at in-service reactors, companies are protected from ionizing radiation and and those performing activities related to cleanup and benefit from dosimetric monitoring suitable for the type of dismantling (0.9 mSv). exposure.
BREAKDOWN OF ANNUAL DOSES Practical training session on a practice jobsite, TRIHOM, Equeurdreville site In 2020, 49% of the Group’s employees and 38% of the employees from outside companies received a dose below the recording threshold of the dosimeter13 (or zero doses).
Those that underwent dosimetric monitoring for whom a dose was recorded, above the recording threshold, over 12 consecutive months, represent:
• 37% of the Group’s employees and 50% of employees of outside companies with a dose below 2 mSv,
Results
Figure 21: Breakdown of doses for Orano employees The results presented in this review are calculated for 12 consecutive months12 for the 13,088 employees of the Group who underwent individual dosimetric monitoring in 2020 (84% of employees in France and 16% in the mining sites abroad), and for the 8,281 employees of the outside companies working at these same sites and according to the same breakdown.
Seventy percent of Group employees who underwent individual dosimetric monitoring are classified as category B. This percentage remains at the same order of magnitude as for 2019. Figure 22: Breakdown of doses for the employees of outside companies ANNUAL AVERAGE DOSES • 46% of the Group’s employees and 58% of the In 2020, the average doses of the personnel monitored employees of outside companies with a dose below (including zero doses) remains 20 times lower than the 6 mSv.
12 The dosimetry results in this report covering the period between July 1, 2019, and June 30, 2020, given the time necessary for obtaining delayed-reading dosimetry analysis results (also called reference dosimetry) and data consolidation. 13 A zero dose is a dose lower than the detection limit which depends on the measurement technique. General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 45 16/07/2021 06:28 Radiation protection
The proportion of the Group’s employees with dosimetry MAXIMUM DOSES below 6 mSv annually is the same order of magnitude as for previous years. This percentage in the order of 95% The Group had 72 employees and outside companies is to be examined relative to the percentage of category 22 employees who received a dose greater than 14 mSv B class employees (limit of 6 mSv per year) which is over 12 consecutive months, an alert criterion for the around 70% of the Group’s personnel. The classification Group (for a regulatory annual limit at 20 mSv). of employees (A, B, or non-exposed) is the employer’s responsibility with regard to the dose assessed at the Special attention is paid to exceeding this criterion. This workstation. The employer consults the occupational requires a systematic analysis so that dosimetry is as physician on the classification and updates it regarding low as possible, given the state of technology, economic work conditions and the results of the exposure factors, and the nature of the operation to perform, as is monitoring for workers. required under French regulations (ALARA approach).
The average value of doses recorded, not taking account An increase in the number of people with a dosimetry of values under the recording threshold, is 1.8 mSv for above 14 mSv over 12 consecutive months is recorded Orano personnel and 1.2 mSv for outside companies. compared to 2019. This increase specifically concerns This value is identical to that for 2019 regarding Orano mining activities. It can be traced to certain associated personnel and higher for the personnel of outside operational conditions, like activities generating a work companies. The breakdown of doses is as follows: environment with dust, ore extraction with a higher content, or air flow settings test (blowing air flow tests) leading to increased radon.
The maximum dose over 12 consecutive months for Orano employees and those of outside companies is respectively 19.914 mSv and 17.2 mSV. These are doses for employees performing underground mining work generating a work environment with dust.
COLLECTIVE DOSES
Figure 23: Breakdown of doses except zero doses The collective and individual dosimetric assessments for Orano employees are indispensable in the preparation of an operation. The results of collective dosimetry are an indicator that varies as a function of the operations performed, which represent the Group’s diversified activities.
In 2020, the collective dose including all exposure routes was 12,118 M.mSv for Orano employees and 6,425 M.mSv for employees of outside companies.
For the defined period, the dose due to internal exposure for Orano employees and for employees of outside companies varies between 30 and 37% of the effective dose. More than 95% of the internal dose was used for Figure 24: Breakdown of doses except zero doses for the employees of outside companies mining activities, of which 2/3 of the operations of the COMINAK mine (Niger), and 1/3 during operations of the SOMAÏR mine linked to a work environment with tests for COMPARISON WITH THE “PUBLIC DOSE” dust or air flow settings. This caused increased radon and LIMIT activities to extract an ore with a higher content.
The dose of 1 mSv/year corresponds to the “public dose”, The geographical breakdown per entity of collective doses i.e. the maximum admissible dose for the public set for the Group’s personnel is represented in map above. by French regulations. It results from human activities excluding natural radioactivity and medical doses.
Over the recording period, 74% of the Group’s employees Significant events and 84% of the employees of outside companies of the totality of the personnel monitored for ionizing radiation For better cross-functional use of events, feedback, and had a zero dose or a dose under 1 mSv. experience sharing, events declared in relation to periodic
14 This value does not include: - the individual dose above 20 mSv resulting from the level 2 internal contamination event, which cannot be disclosed because of its medical and individual use, - cumulative individual dose of 11 employees cited on page 47 pursuant to the experience feedback because it is outside the period considered pursuant to this report (see footnote on page 11).
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 46 16/07/2021 06:28 46-47
Breakdown of doses received in 2020 by geographical area
inspections and tests, radioactive wastes, and internal - at La Hague, during cleaning of the blade and external transports are handled as significant safety of a solution agitator, and despite three events. Thus, among the 33 significant events declared, pairs of gloves being worn, an employee 28 of them are analyzed in this chapter. They concern 24 was superficially injured on his right index events classified as level 0 on the INES scale, 3 as level 1, finger. He went through the usual process in and 1 as level 2. accordance with the site’s decontamination procedures. The patient underwent daily care The radiation protection events classified as level 0 to promote healing of the wound and the according to the INES scale, by decreasing number: associated decontamination. The presence • wearing a dosimeter: failure to wear an operational of a microparticle attached to the skin was dosimeter or a delayed reading dosimeter or failure eliminated by a surgeon using exeresis. The to activate it, assessment of the skin equivalent dose was • radiological areas: non-compliance with rules for calculated from the activities measured and the entering the orange area or the yellow area or time between the event and the elimination of failure to mark an area of operation, the microparticle, • management of radiation protection alarms: a - at the Nogent sur Seine NPP, an employee radiation monitoring alarm or a dosimetry alarm was leaving his operation of modifying the (equivalent dose rate). scaffolding of the vessel head. At the hand-foot monitor at the exit of the reactor building (RB), The radiation protection events classified at higher levels he detected a contamination of his right hand on the INES scale are linked to employee exposure: that was removed using a cloth with the help • a committed dose greater than the annual of the airlock guard for the RB. regulatory dose, the analysis of which is presented The assessment of the equivalent dose for in the box on page 42, the skin was calculated as bounding using • a cumulative individual dose over 12 consecutive the activity measured on the cloth and total months that exceeded the regulatory limit for time spent in the area, without the possibility 11 employees at the underground mine at to identify the most probable time of the COMINAK (Niger), the primary cause of which contamination. was a loss of electrical power (in July 2020) that led to air flow disturbances affecting underground Even though some of the results concerning the radiation mining work. This led to significant degradation protection domain remained satisfactory, after several of work environments due to radon. The years of stability, various radiation protection indicators analysis and handling of this event resulted in made up a signal that should result in increased vigilance improved equipment systems (fan, monitors) and in daily activities in 2021. organizational systems. • equivalent dose, exceeding a quarter of the Experience feedback constitutes essential data for regulatory annual individual limit for exposure of improving and monitoring performance levels in radiation the skin, for two situations, one at La Hague and protection. The approaches adopted are thus ongoing the other in a nuclear power plant. concerning the definition of personal protective equipment
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 47 16/07/2021 06:28 Radiation protection
notably in hot conditions, the preliminary assessments Nuclear Safety Authority [ASN] and French Nuclear Safety of workstations with assessment of the dosimetry and Authority for Defense-related Facilities and Activities definitions of dose requirements, and the pragmatic [ASND]). consideration of new provisions of the French labor code in order to simplify the procedures. The French order of October 23, 2020, relating to the efficiency of prevention measures implemented as The events of 2020 show the part of worker protection against risks resulting from need to expand the radiation ionizing radiation, stipulate how these measures will be protection culture of all workers carried out for: in facilities, to eliminate the • Checking work equipment emitting ionizing risk of exposure linked notably radiation and radioactive sources, to the lack of consideration of • Checking work areas and the vehicles used during an irradiating source leading operations of transporting radioactive substances, to an external exposure risk or • Checking radiation protection instrumentation, the absence of identification or inspection of an unsealed source, as well as the accreditation of organizations performing resulting in an external or internal the initial checks. contamination risk. Experience sharing on radiation protection Glove inspection - Melox Any worker in an area must know the preliminary conditions of the operation (inspections, protective equipment, operation time, etc.) and unconditionally comply with the fallback and inspection rules before leaving their area to guarantee the preservation of the defined radiological conditions. These basic radiation protection principles are part of the culture that will be expanded in 2021.
Regulatory developments
In 2020, the changes of the French “Workers” decree and its application texts were articulated. These texts are structural texts published in 2018 and 2019 with continued diffusion in 2020.
This mainly concerns the implementation of new provisions in zoning and considerations about applying organizational changes in radiation protection, according to the sites that have or do not have a regulated nuclear facility (definition of the employer’s radiation protection advisor: Radiation protection officer, radiation protection entity, or radiation protection center of expertise for the INBs). On this last point, French decree no. 2018-437 of June 4, 2018, which modified the French labor code, grants a transitional period for implementing the organization and defining the radiation protector advisor until July 1, 2021, a deadline which should shortly be extended by decree to January 1, 2022.
At the end of 2020, the French authorities announced the decision to prolong the transitional period further to the observation that the disturbances caused by the public health crisis were a hindrance to setting up the new radiation protection organization pursuant to the decree. It is true that the French order of October 23, 2020, does not leave enough time for verification entities to become accredited (OVA) before July 1, 2021. The same is true with the French order on the center of expertise in radiation protection that will only be published during the first half of 2021; the creation of these centers by nuclear operators must be approved by their competent authority (French
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 48 16/07/2021 06:28 48-49
This report mentions various dosimetric quantities which are defined in this box.
Work in demarcated areas: Case of internal incorporation: monitoring of the effective dose assessment of a committed dose
The effective dose is a “whole body” dose. It includes the The dose resulting from an incorporation is called the dose resulting for external exposure and the internal dose committed dose. It is estimated using models, which: resulting from an activity in a work environment with dust • describe the distribution in the body and the or resulting from an incident situation. elimination of radioactive substances over time, • indicate the irradiated tissues and the duration of For work in a demarcated area, two types of dosimeters this irradiation, and exist, operational dosimeters and delayed-reading • predict the retention in the organs, urinary dosimeters. The first allows a direct reading, while the and fecal excretion, and the total number of second is intended for laboratory reading. disintegrations.
For work in a monitored area, only the delayed-reading The assessed committed dose results from the various dosimeter is required for a classified worker. In a controlled types of incorporation of radioactive substances by area, French regulations require that a passive dosimeter inhalation, ingestion, transcutaneous penetration, or and an operational dosimeter be worn by classified penetration via a wound. It assesses over the long term personnel. the global dose that the organism will undergo as a whole. The calculation of committed dose covers 50 years for The passive dosimeter is worn by the worker over a adults to take account of the progressive elimination of maximum six-month period. Following this period, radioactive substances or their non-elimination in the the dosimetry is “read” and analyzed by an accredited case of some of these substances. laboratory. Conventionally, the committed dose over 50 years Selected according to the type and characteristics of is declared at the date of incorporation for an event the radiation to be measured, the operational dosimeter classified on the INES scale and is compared to the limit enables the monitoring and optimization of exposure of 20 mSv for the exposure of people regularly working to radiation during these operations. This electronic in demarcated areas as required by French regulations. dosimeter with auditive and visual alarms is activated prior to any entry in a controlled area. The integrated dose during the time spent working in the controlled Case of external contamination: area is automatically sent when the area is exited (from 1 assessment of an equivalent microSv) to a database for monitoring doses generated by the radiation protection entity. Sending these data makes dose it possible to use them and participate in the optimization In case of cutaneous contamination, the equivalent dose of exposure of workers and the public to ionizing radiation is assessed at the basal layer of the skin for the most at the lowest, reasonably possible level given the technical, contaminated cm.² economic, and social requirements (ALARA). It is assessed based on the activity deposited per cm² French regulations call for a limit of 20 mSv/year for the of the skin, the identification of radionuclide(s), and the exposure of people regularly working in demarcated areas. exposure time before decontamination: • the deposited activity can be quantified according Preparation of dosimetry heads, COMINAK - Niger to the adapted protocol, depending on the situation: before decontamination, measurement with a detector and a blanking plate perforated by a hole to identify the surface area of the most contaminated cm², measurement by gamma spectrometry targeting the contaminated area, or measurement of a swab of the contaminated skin using a suitable support (cloth), • the exposure time is defined from the incident with which the contamination started or, by default, the time the controlled area was entered.
French regulations require an equivalent dose limit for the skin of 500 mSv/year for the exposure of people working in demarcated areas.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 49 16/07/2021 06:28 La Hague site
Management of impacts on the environment
Checking for the absence of impact of our activities on populations, ecosystems, and biodiversity is part of our permanent monitoring, using recognized human and technical expertise. The data acquired and their interpretation are systematically shared with stakeholders through public reports, shared expert analyses, and publications.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 50 16/07/2021 06:28 50-51
Results in terms of Results in terms of chemical impact
radiological impact Regarding releases of chemical substances, public health impacts near Orano sites, assessed according The annual radiological impacts (or annual dosimetric to the methods recommended by the French Ministry impacts) resulting from releases from Orano’s major for Ecological and Inclusive Transition, INERIS (French nuclear sites remain at very low levels15: 0.08 µSv for the National Institute for Industrial Environment and Risks) Tricastin site, 14.2 µSv for the La Hague site, and below and InVS (French Institute for Public Health Surveillance), 0.001 µSv for the Melox site. These values are to be are below the reference values. compared with exposures associated with other sources of natural or artificial radiation, and with the regulatory The hazard quotients for threshold effects are lower limit value for the public: 1000 µSv per year for the dose than 1, and the individual risk excesses for no threshold added by nuclear activities. effects are below 1/100,000, whatever the exposure scenarios involving local inhabitants and the considered This very low impact is the result of constant progress over age bracket. time in terms of treatment at the source and controlling releases in the environment. The vigilance of the teams remains a priority. Reliability subject to continuous These global results are taken from information reports prepared by nuclear sites pursuant to article L.125-15 of inspection the French Environment Code16. To guarantee the reliability of the various inspections performed, the implementation of periodic comparative inspections between the various measurement laboratories is required by the regulations.
These inspections concern some of the measurements performed by the operator and are carried out by La Hague and Tricastin with the IRSN laboratory in Vésinet. The summary reports on these comparative inspections check the consistency of the various results obtained and are submitted annually to ASN.
Properly carrying out comparative inspections is one of the key points so that internal laboratories (which ensure the monitoring of releases) obtain the ISO 17025 certification, in accordance with the requirements of the ASN decision no. 2013-DC-0360 of July 16, 2013, as modified.
Comparison of the dosimetric impact for various exposures
15 Assessed on the basis of real releases authorized for 2019. 16 These reports are accessible on Orano’s internet site: https://www.orano.group/docs/default-source/orano-doc/groupe/publications-reference General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 51 16/07/2021 06:28 Monitoring of a dismantling activity, La Hague site
Dismantling operations
Dismantling activities continued to ramp up, a process underway for several years at the Group’s various sites. The publication of the French decree concerning the Georges Besse plant constitutes an important milestone.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 52 16/07/2021 06:28 52-53
he administrative process of requesting • For dismantling the STE2 workshop: a dismantling authorization continued at - elimination of chemical reagents in the reagents T both the La Hague and Tricastin sites, with unit and successful startup of the new asbestos processing of partial dismantling requests for INBs strategy, no. 33 and 38, the publication of the dismantling - end of the removal of the agitators to allow decree for INB no. 93. accessing the chemical treatment reactors to be cleaned up and dismantled, - preparation of a batch of oxalic acid rinse for 3 tanks of NCP1 and SPF1 and start of nitric Facilities at the end of the rinses of 2 SPF storage tanks, and - carrying out investigations in tanks 243-01 dismantling process or undergoing and SPF1-10,
industrial redevelopment • For HAPF workshop: - oxalic acid rinsing of 3 tanks and start of nitric acid rinsings of 2 fission product storage tanks, MIRAMAS SITE - investigations in the two tanks,
The industrial redevelopment of the Miramas site following • For the RCD and dismantling project of the ELAN dismantling and decontamination is underway. The central 2B workshop: area of the site is undergoing rehabilitation, following findings - dismantling of the tanks of cell 900, of residual contamination in a very circumscribed area. This - set up of the airlock and start of work in DEEB in area was the focus of a management plan validated by the preparation for the transfer of active packages DREAL (town and country planning and housing) in 2020. from ELAN 2B to STE3 / DEEB, This remediation work is planned for 2021. - continuation of the recovery and conditioning of waste from silo 130 with the preparation of At the end of 2020, the central area, except for the area the first conditioned waste drums, where work is currently being performed, was transferred - completion of installation of the process to a buyer with the aim of reindustrialization. mechanical equipment and operation equipment necessary for the recovery and conditioning of hulls and end caps in the Facilities undergoing dismantling recovery cell over the HAO silo, and start of functional and maintainability tests, - continuation of preparatory operations for LA HAGUE SITE - INB NO. 33, 38, 47, AND 80 rearranging the silo roofs containing sludge with a view to installing new dedicated equipment The studies and work on recovery and conditioning of for its recovery, as well as carrying out the wastes (RCD) and on dismantling (DEM) will continue in removal of old equipment and preparation of 2020 in the scope of the 4 INBs undergoing dismantling. the room, - concerning silo 16, containing no materials, The highlights of this year mainly concerned: performance of the preparatory modifications • For the HADE workshop: for the installation of tanks linked to sludge - the start of operations to cut pipes for the recovery. recovery of waste from a dissolver, - start of various operations to free up the - the start of dismantling operations prior to the installation area of the future treatment and schedule for unit 250, conditioning building for fine-grain waste - the start of cleanup and dismantling work for (DFG). units 223 and 231, Parallel to these operations, studies were continued to • For the MAPu workshop: prepare for upcoming operations: - finalization of studies for bitumen recovery and • studies on the treatment of fine grain waste (DFG) the safety file submitted to ASN, made it possible to finalize the design of the - start of dismantling work of the upper levels of recovery and conditioning process and the design the workshop, of the civil engineering for the new building. The - end of dismantling work on the MAPU laboratory, file was submitted to ASN, • concerning sludge recovery and conditioning • For the HAO Sud workshop: (RCB), the studies on an alternative process giving - presentation of the new dismantling scenario priority to recovery in the best timeframe while to ASN, complying with the requirements, are advancing - various types of sludge placed in the pits of and a file has been submitted to ASN. This process, pool 903, based on the separation of a part of the sludge
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 53 16/07/2021 06:28 Dismantling operations
water by centrifugation and temporary storage in • dismantling of structures 2000 and 2450, a canister, is the subject of an inactive test on pilot • dismantling of the “plant” stack and final cleanup of facilities which justify choosing this solution. the buildings and storages areas, and • the treatment and conditioning process for the • final cleanup of soils that may have been graphite and magnesium waste of silo 115 a was contaminated due to the activities performed in the shifted to a simpler recovery process involving facility, making it possible to reach the target final recovery by mechanical sorting then temporary state. storage, or conditioning to tested routes when possible, as confirmed by the feasibility studies. Dismantling operations must be completed by December This new orientation is the subject of studies which 31, 2034, at the latest. will enable the submission of a safety options file to ASN in 2021. PIERRELATTE INBS
In terms of regulations, the public inquiry on the files for The process and the operations of dismantling and cleanup requesting partial dismantling of the INBs no. 33 and 38 of the Pierrelatte INBS continued in 2020, notably with: was held at the end of 2020. The inquiry commission • continued dismantling of the “Main Laboratory” issued a favorable opinion for this project. The decree could and “Waste Treatment Station” individual facilities be published in 2021. A request for modification of the and continued cleanup of “TU2-TU3” and “P60” dismantling decree for INB no. 80 was presented to the individual facilities, Nuclear Safety and Radiation Protection Mission (MSNR). • finalization of operations to set up a reversible impermeable covering on the mound situated near the P04 storage area. TRICASTIN SITE - INB NO. 93 AND 105 AND A SECRET REGULATED NUCLEAR FACILITY (INBS) MALVÉSI SITE
The operations in 2020 to remove equipment, then to INB NO. 93 - GEORGE BESSE PLANT deconstruct the structures, entailed: The administrative process of authorizing the dismantling • removal of the tank emptying facilities and SAFRAP of INB no. 93, initiated in 2015, came to a close with SNU, removal of the process, and the restoration of the publication of the French decree on dismantling, the soil in the area, on February 5, 2020, and the approval of the general • removal of the drum grinding process (process operating rules for the dismantling phase on February 4, removal and interior cleanup of the building), 2021. • asbestos removal and deconstruction of the Pilote Isoflash process; this operation will continue in In parallel to this authorization process, the preliminary 2021 with the deconstruction of the building design was continued, notably with the performance of (removal of wall cladding, deconstruction of the a pilot test campaign, making it possible to qualify the structure, and treatment of the slab), thermal and mechanical cutting techniques for the main • investigations, prior diagnostics before works, equipment items to be dismantled, and for new equipment asbestos removal, and deconstruction of a part not used during plant operation. of the processes present in the magnesiothermic building. The operations will continue in 2021, and A first conventional dismantling worksite started in • investigations and marking before works on READ September 2020. It concerned a 3,600 m3 vessel which facilities and precipitation. made it possible to drain the cooling systems in case of maintenance operations and also plant outages. This worksite is part of the phase prior to starting the dismantling of the plants and aimed to free up space to build the necessary arrangements.
Dismantling operations must be completed by December 31, 2051, at the latest.
INB NO. 105 - CONVERSION WORKSHOP
The administrative process for authorizing the dismantling of INB no. 105 was completed at the end of 2019 by the publication of French decree no. 2019-1368 of December 16, 2019, and the approval of the general operating rules for dismantling. These operations are divided into 4 steps: • reconditioning of drums and removal of radioactive substances stored in the storage areas 61 and 79,
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 54 16/07/2021 06:28 54-55
Handling operation after shipment, La Hague site
External transportation activities
The industrial performance calls for perfect control over radioactive material transportation flow, whether it is intended for our customers, our sites, or is produced by them. Thus, the transportation operations are performed with the identical safety objectives as those established for the facilities.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 55 16/07/2021 06:28 External transportation activities
Supervision of transportation - new version of standard ISO 7195 relating to cylinders for uranium hexafluoride; its application was made obligatory under the Control over transportation safety for radioactive materials IAEA regulation SSR-6, calls for the implementation of in-depth defense based on • breaking down the regulatory changes concerning the three-barrier principle: safety of design, production, France, which in 2020 issued several orders linked and cask maintenance; the reliability of transportation to public health measures resulting from the operations; and preparation for response in case of COVID-19 crisis. incident or accident. Each change in regulatory texts was covered by a bulletin PROCESS OF RISK CONTROL addressed to the advisors for the Group’s transportation safety to ensure the breakdown of regulatory changes at Control over makeup and shipping activities for packages, the operational level. up to delivery to the recipient, is based on an internal The two major directives of the Group’s common baseline, process called “Manager of Supervision of Transportation”, which cover the transportation safety of radioactive led and implemented by the NPS BU17. material and the conformity of packages prepared for This process adds to the application of national and transportation, as well as the guide on securing packages international regulations on the safety of transportation of of radioactive materials, were revised, in particular to radioactive material. It includes control over all risks, in a anticipate the implementation of regulation SSR-6, 2018 larger scope than that of safety and radiation protection. Edition, of the IAEA on transportation safety in modal regulations. Thus the supervision process breaks down into three areas: • upstream of transportation, by the definition, the Risk analysis implementation of a common baseline, and the permanent deployment of the risk analysis, The risk analysis approach first of all consists in identifying • in an operational framework, by monitoring and analyzing all transportation flow risks. transportation activities at the Group’s sites, but also everywhere that activities impacting safety All transportation flows carried out or supervised by the are carried out, NPS BU are subject to exhaustive information collection • during an incident or accident, by managing to then assess their level of risk. This risk analysis degraded situations. may include assessments in the field or of itineraries. These studies require various expert assessments: transportation organization, regulatory watch, nuclear A common documentary baseline: safety, conventional safety, loading and securing, or public information.
“TRM - Transport Risk Management” They also include the validation of ships on which the Group’s entities may need to load radioactive material. In The definition and implementation of a common 2020, of 55 ships analyzed, 4 were refused after analysis. documentary baseline makes it possible to provide a shared framework within the Group. It is mainly made up Containers of natural UF at the Montreal port in Canada of texts applicable to the transportation of radioactive and 6 nuclear material and two major directives that deal with the safety of transportation of radioactive material and the conformity of packages.
In 2020, as part of regulatory watch applicable to the transportation of radioactive and nuclear material, analysis and informational work addressed the following subjects to take account of the changes to regulations, in particular for: • anticipating the breakdown of changes to the 2018 edition of the IAEA regulation SSR-6 on transportation safety in the modal regulations in 2021, • breakdown the regulatory changes concerning international regulations: - Technical Instruction of the ICAO, TI-OACI, edition 2020, concerning air transportation,
17 For Nuclear Packages and Services
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 56 16/07/2021 06:28 56-57
Containers of chemical concentrates unloaded at the Montreal port in Canada
In 2020, these analysis and validation processes were used and the year was marked by the following new transportation flows: • transportation operations of containers of chemical concentrates of uranium (UOC), from Niger to Canada,
• a campaign of shipments of natural UF6 by regular and chartered vessels to Tricastin from Canada.
Activity monitoring
In expedition or destination sites as well as in areas of Figure 26: Changes in the “not totally satisfactory” inspection rate transshipment (such as ports and airports), qualified inspectors are sent to monitor, prepare and package In addition to inspections in the field, audits of Group shipment operations and activities performed by service sites and those of suppliers are conducted to assess the providers in all concerned countries. performance of organizations in place. In 2020, 22 audits were conducted (3 for the sites and 19 for the suppliers). The change to the number of inspections assessed as “not The significant reduction in the number of supplier audits satisfactory or NS” makes it possible to assess the level is explained by the public health measures taken by the of control of transportation activities. For 2020, this level concerned foreign countries. is 4.5% for the 267 inspections performed. This figure, slightly higher compared to 2019 (3% for 273 inspections performed) remains comparable to the values observed since 2013. This result was obtained through constant Managing deviations focus on looking for weak signals, measured by the rate of inspections declared “not totally satisfactory or NTS”, The level of transportation control is also measured by the which was 29% in 2020 (28% in 2019). number of significant events declared and their level of classification.
In 2020, 20 significant events, classified on the INES scale as level 0, concerned transportation on public roads and for which an entity of the Group was the shipper or the receiver (23 en 2019).
Among these events, 17 were declared by a Group entity (19 in 2019) and 8 for which a Group entity or one of its subcontractors was considered as a cause (11 in 2019).
A more detailed analysis of events concerning transportation safety indicated the following breakdowns, by field of Figure 25: Changes in the “unsatisfactory” inspection rate responsibility and by typology:
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 57 16/07/2021 06:28 External transportation activities
Management of degraded situations
In case of a degraded situation that necessitates it, NPS BU sets up and coordinates the deployment of an Emergency Transportation Response Plan (PUI-T). This plan notably involves setting up a Command and Local Decision Center (PCD-L) of the NPS BU that interfaces with the Group’s National Command and Decision Center (PCD-N), the shipping or receiver site as the shipper or Figure 27: Breakdown of responsibilities of significant events concerning transportation receiver, a technical unit, and a communication unit. The plan also involves dispatching specialists to the location of the accident on the customer’s premises, and, if the event occurs in France, to the concerned prefecture.
This system is tested during internal emergency exercises, some of which simulate accidents occurring outside France.
In 2020, Orano NPS conducted or participated in 10 transportation emergency exercises, both on safety themes and physical protection, at a greater or lesser Figure 28: Breakdown by field of significant events scope, inside or outside the Group. In addition, a national concerning transportation exercise relating to nuclear material safety was organized. It was overseen by the French Ministry for Ecological and In 2020, Orano was considered responsible as a shipper Inclusive Transition and the IRSN Transport Operational for 5 events; the subcontractor subcontractors were Division, of which the main actors in category III considered responsible for 2 events; and a packaging transportation participated. The exercise scenario, related supplier was considered responsible for 1 event. to conventional and nuclear safety, made it possible for the The analysis by field showed 3 events concerning Group’s teams to communicate with the IRSN emergency isolated contamination without impact on the personnel response center and to better advise public authorities or the environment, 3 events concerning the conformity responsible for dealing with the emergency. This was an of the shipped pages (poor classification of the package, opportunity to show the efficiency of PUI-T provisions and insufficient tightening of the shock absorbing covered learn lessons about how to improve emergency response screw, and damage to a package without confinement organization. loss) ,and 2 events concerning securing of the packages (tightening torque non-compliant with the securing plan and absence of securing on two package to which an Training in the transportation field exception applied). As in previous years, the internal training activities like those outside the Group continued to receive support.
A week-long training session, to support Andra, was conducted for an Emirates Nuclear Energy Corporation (ENEC) team. This entity is mandated to set up the nuclear power program in the United Arab Emirates. The training concerned various themes around the transportation of nuclear fuel and radioactive waste.
Figure 29: Comparison between 2020 and 2019 of the breakdown by field of significant events concerning transportation
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 58 16/07/2021 06:28 58-59
Publication of the third edition of ISO 7195:2020 - Casks for the transportation of uranium hexafluoride
(UF6)
After several years of preparation, the third the manufacturing requirements for the procurement edition (the first edition dating from 1993 and of new cylinders, new valve covers and new plugs. This standard also stipulates the requirements relating to second from 2005) of the ISO 7195 standard in-service cylinders (operation, maintenance, periodic relating to cylinders for the transportation of inspections and tests).
uranium hexafluoride (UF6) was published. The main changes compared to the preceding edition concern the harmonization of the standard’s structure This revision was prepared by a work group arising with that of the American standard ANSI N 14.1 to facilitate from a technical committee under the international their comparison, the updating of the concerned cylinder Organization for Standardization (ISO). The leader of this models, the consideration of changes in the design of group and the project manager for the revision of this plugs, the harmonization of securing specifications with standard is an Orano NPS expert, supported by several those recommended by the IAEA for the other radioactive experts within Orano Chemistry-Enrichment, ASN, and materials packages, the possibility of using leak test IRSN. methods different from that required up until now, and especially, the possibility under certain conditions to This standard must be applied to each cask containing have proceeded with radiographical inspections of 100%
100 g or more of UF6 (compliance with this standard during the manufacturing of 48Y, 48X, or 30B cylinders, is required in the radioactive material transportation and to replace the five-yearly hydraulic tests of these regulation of the IAEA - SSR-6 - and in the modal cylinders by non-destructive tests of welds. international regulations. The TRANSSC committee of IAEA should soon issue a recommendation to Member Handling of UF cylinders, Tricastin site States to make this version of the standard applicable 6 without having to wait for the next SSR-6 revision.
Consecutive to this publication, the ANSI (American National Standard Institute) plans to start the revision process for standard ANSI N 14.1 (American standard equivalent to standard SO 7195) in January 2021, with the aim of harmonizing the requirements with those of this new version ISO 7195.
Standard ISO 7195 concerns the specifications
applicable to cylinders for the transportation of UF6 to ensure compatibility between the various users, the description of the design of different types of cylinders,
Storage of UF6 cylinders, Tricastin site The changes to this new version of standard ISO 7195 enable a better understanding of the requirements applicable to cylinders, harmonization with other applicable regulatory texts, greater flexibility in usable periodic inspections and examinations, and thus, a significant reduction in the costs related to the periodic inspections and tests for the re-certification of the cylinders.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 59 16/07/2021 06:28 Responders during an exercise in management of a degraded situation, Tricastin site
Management of degraded situations
The preparation for the management of degraded situations has been adapted to the public health crisis by strengthening, in certain situations, the capacity for collaborators working remotely to participate as before. Responses to complex scenarios were also developed.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 60 16/07/2021 06:28 60-61
he efforts made over the last several years Experience feedback from 2020 to develop an operational emergency T management system remained ongoing by exercises adapting to the public health context. New scenarios were tested. For the national emergency response command center (PCD-N), remote working was used Two exercises including participation in the Group’s throughout the Group’s headquarters. It enabled strategies were conducted in 2020. They involved themes validating alternative operating procedures, both in other than safety. person and remotely. Several lessons learned should be highlighted.
Other than the actions decided upon after the exercises, Management of a multisite emergency was tested for the 2019 report underscored points to pay attention to; the first year during two exercises, one in France and the some of them were not specific to the Group: other abroad. In the limit set for the scenario, the exercise • representativeness of the scenarios. The scenario conducted in France did not show any blocking points, of the national exercise recently performed, which and the information management tool favored positive simulated the post-accidental phase, postulated exchanges between the various sites and headquarters. a new initial state for the second-day scenario. The lockdown was put to work to validate the operation These conditions must remain present in the of PCD-N with a mixed organization, combining drafting of future exercise scenarios, members working in person and members working • expert assessment in conducting the post- remotely. Whereas this year’s highly unusual situation accidental phase of events. On January 16, made this organization absolutely necessary, the first 2020, ASN published the recommendations of lessons learned from its deployment also show an added the Steering Committee for Management of the value for normal situations, making it possible for all Post-accident Phase of a Nuclear Accident or PCDN-N emergency team members to be able to monitor Radiological Emergency (CODIRPA) involving the situation or contribute to its operation. These lessons a nuclear accident or a radiological emergency also highlighted the usefulness of the progressive and situation. These recommendations propose modular enabling of the PCD-N, adapted to need. changes for protecting the population and the sale of food. In this context, 2020 saw a strengthening of the control of tools assessing the impact on Emergency exercise - KATCO - Kazakhstan the public and the environment. Several training sessions were carried out, making it possible to familiarize the greatest number of teams. Given the specificity of this type of tool, this effort carried over into the future, • conference calls. Recent fiscal years have shown better control in conducting conference calls, so that the focus can be on primary objectives, whether they are related to decision-making or expert assessment. Internal teams must continue to work on this point, particularly for the structuring of various meetings to harmonize the requests of the public authorities, the management of information, internal decision-making, and technical appraisal work, • capacity to simulate all stakeholders. This year was not conducive to participation of the involved entities in emergency management for A new tool for managing information to be tracked in low-intensity exercises. However, this point was a logbook was deployed in 2020 throughout the Group. taken into account in performing some exercises It is suitable for the objectives assigned to it. As with any in 2021. new tool, it requires a learning curve for each user, which is longer due to discontinuous practice. Improvements to The verification of the compliance of site organizations the tool and the presentation of data in the control room with the provisions of the “Urgence” decision continued have now been identified and should be deployed in the in 2020, to be terminated in March 2021. year to come.
Beyond the lessons learned from each inspection, which The “sandboxes” made this year at Châtillon show that figure in the dedicated chapter in this report, a summary the control of the first hour of emergency management document will be prepared to present the cross-functional is a real challenge. The decision made by the Group’s HSE lessons from this verification cycle. Division to regularly perform short-duration exercises
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 61 16/07/2021 06:28 Management of degraded situations
and to carry out a quarterly alert will make it possible to The deployment of missions in October on the Framatome strengthen reflexes and control the situation “from the de Romans-sur-Isère18 and Tricastin sites made it possible start.” to validate proper execution but also identify areas for improvement for the equipment used.
In 2021, it should be possible to test all missions. Maintaining FINA (National Response Force) in operational 2021 perspectives and areas condition for special attention The objective of 2020 was to guarantee a uniform operational level of FINA for every mission. To control degraded situations, the Group’s internal dynamics remain energized. A wealth of lessons can be In addition to active vigilance during the first lockdown learned from the past year. In 2021, it should be possible period, FINA’s training was based on quarterly alert tests to consolidate the proposed organizational changes, to and exercises for high command or in the field, to test the make them part of the Group’s documentary baseline, initial teams’ capacity for projection within 48 hours, and and to implement what has been decided. These changes during response missions. must be paralleled by the emergency teams’ control of the information management tool.
FINA - Deployment of RIANA robot The areas for attention identified in the 2019 report, whose state of progress figures at the beginning of this chapter, remain a current issue.
Deployment of FINA
18 Site also in FINA’s scope
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 62 16/07/2021 06:28 62-63
Glossary
ACRONYMS
AIP: Activities Important for the Protection of IAEA: International Atomic Energy Agency interests ICPE: Environmentally Regulated Facility Andra: French National Agency for Radioactive (Installation Classée pour la Protection de Waste Management (Agence Nationale pour l’Environnement) la gestion des Déchets Radioactifs) IG: General Inspectorate (Orano) ASN: French nuclear safety authority (Autorité de Sûreté Nucléaire) INB: French Regulated Nuclear Facility (Installation Nucléaire de Base) BU: Business Unit (in the Orano organization) INBS: French Defense Nuclear Facility CEA: French Atomic Energy and Alternative (Installation Nucléaire de Base Secrète) Energies Commission (Commissariat à l’Énergie atomique et aux énergies IPR: Incident Prevention Rate Alternatives) IRSN: Institute for Radiation Protection and COFRAC: French Accreditation Committee (Comité Nuclear Safety (Institut de Radioprotection FRançais d’ACcréditation) et de Sûreté Nucléaire)
DSND: Delegate for Nuclear Safety and Radiological OEF: Operating Experience Feedback - process Protection for Defence-related Activities designed to organize Operating Experience (Délégué à la Sûreté Nucléaire et à la or Lessons Learned (REX in French) radioprotection pour les activités et les SSA: Supplementary Safety Assessments installations intéressant la Défense) TSN Law: French law no. 2006-686 of June 13, EIP: Equipment Important for the Protection of 2006 on transparency and security in interests nuclear matters, enshrined in the French EURATOM: European Atomic Energy Community environmental code
FINA: Orano’s National Response Force WANO: World Association of Nuclear Operators
HOF: Human and Organizational Factors
HCTISN: High Committee For Transparency and Information on Nuclear Security (Haut Comité pour la Transparence et l’Information sur la Sécurité Nucléaire)
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 63 16/07/2021 06:28 Glossary
Decontamination: Physical, chemical or mechanical operation designed to eliminate or reduce the presence of B radioactive or chemical materials deposited on a person or equipment, or in a facility or open area. Becquerel (Bq): International unit of measurement of nuclear activity (1Bq = decay of 1 atomic nucleus per Defense in depth: A series of lines of defense designed second). The becquerel is a very small unit. Formerly, activity to prevent the appearance, or limit the consequences as was measured in curies (1 curie = 37,000,000,000 Bq). necessary, of human or technical failures that could lead to accidental situations.
Dismantling: Combination of technical and administrative procedures carried out following the final shutdown of a C facility to achieve defined final conditions enabling it to be decommissioned. Dismantling includes the physical Cask: Assembly of components needed to safely contain the dismantling and decontamination of all machinery and radioactive material transported. It may include a variety of equipment, and the management of the associated special materials, such as radiation-absorbing materials or radioactive waste. thermal insulation materials, as well as service equipment, impact limiters, and devices for handling and stowage. Dosimeter: Instrument for measuring radioactive doses received by an individual, or by certain of that individual’s Category A or B: Classification categories for workers organs (passive or operational dosimetry), or by the likely to receive, in normal work conditions, an effective environment (site dosimetry). dose of more than 6 mSv per year in the case of a category A worker and of more than one of the dose limits set for the public in the case of a category B worker. E Cleanup: All technical operations to eliminate radioactivity-related risks in a nuclear facility, consisting of decontaminating the structures, equipment, floors and Effective dose: The sum of an individual’s internal and walls of the buildings. external exposure to ionizing radiation (energy received and effects related to the type of radiation). It generalizes Containment: System of protection which consists of the effects to the whole body of an individual, taking into containing radioactive products inside a defined area. account differences in the sensitivity of different organs. It is expressed in millisieverts (mSv), a sub-unit of the sievert Contamination: Presence of radioactive substances (dust (1 Sv = 1,000 mSv). or liquid) on the surface or inside a medium. Contamination in humans may be external (on the skin) or internal (via the Enrichment: Process in which the abundance of fissile skin or by inhalation or ingestion). isotopes is increased in a chemical element. Naturally occurring uranium essentially consists of 0.7% U235 Controlled area: Area where access and residence time (fissile isotope) and 99.3% U238 (non-fissile isotope), are regulated for reasons of radiation protection and must be enriched in U235 for it to be usable in a pressurized water reactor. The proportion of U235 is Conversion: Combination of chemical transformations brought to approximately 3 to 5%. to convert solid uranium concentrates into uranium hexafluoride so that they may be enriched in fissile uranium (U235) by centrifugation.
Criticality (criticality safety): The study and control of F conditions to protect against the occurrence of a criticality accident due to an uncontrolled nuclear fission reaction in Fissile: Describes a nuclide capable of fission; the fission normal, incidental and accidental situations. of atoms generates several neutrons.
Fission products: Fragments of heavy nuclei produced during nuclear fission or the subsequent radioactive decay of the nuclides formed. These fission fragments and their D decay products are collectively referred to as “fission products”. Decommissioning: Administrative procedure consisting of removing a facility from the list of regulated nuclear Fission: Spontaneous or forced splitting of a heavy facilities (INBs). At that point, the facility is no longer nucleus, generally after absorption of a neutron, into two subject to the legal and administrative requirements or three smaller nuclei (fission products), accompanied pertaining to INBs. by the release of neutrons, radiation and a considerable
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 64 16/07/2021 06:28 64-65
amount of heat. The substantial energy released is the principle underlying nuclear power generation. M Fuel cycle: The combination of industrial operations involving nuclear fuel. These operations include uranium MOX (Mixed OXide): A mixture of uranium and plutonium ore mining and processing, uranium conversion and oxides used to fabricate certain types of nuclear fuel. enrichment, fuel fabrication, used fuel treatment, recycling of recovered fissile materials to fabricate new fuel, and radioactive waste management. N
G Nozzle: Metal component located at the top (top nozzle) or bottom (bottom nozzle) of a fuel assembly. The top nozzle is used to handle the assembly. Glass: High-level radioactive waste is vitrified and poured into stainless steel canisters. Nuclear materials safeguards: Safeguards aimed at preventing any loss or diversion of material, in particular Glove box: A transparent enclosure in which equipment for malicious purposes. and radioactive substances can be handled in isolation from the operator. Handling is done with gloves which Nuclear safety: Combination of technical and organizational are sealed to openings in the wall of the enclosure or with measures related to the design, construction, operation, mechanical manipulators. shutdown and dismantling of regulated nuclear facilities, and to the transport of radioactive substances, which are taken to prevent accidents or limit their effects. H
Hot work: Any operation or maintenance work requiring P the use of an open-flame device, a spark generator or a hot surface. Periodic review: The periodic review of a facility assesses the facility’s status in terms of the rules applicable to it and Hulls: Pieces about 3 centimeters long produced by the updates the assessment of the risks or drawbacks that shearing of the metal cladding (fuel rods) that had contained the facility may present, taking into account in particular nuclear reactor fuel. the condition of the facility, the operating experience, developments in knowledge and changes to the rules applicable to similar facilities.
I Plan National de Gestion des Matières et des Déchets Radioactifs (PNGMDR): The National Radioactive Waste Incident Prevention Rate (IPR): Internal Group indicator and Materials Management Plan is a document which based on the ratio of the number of INES level 1 events to assesses existing methods of managing radioactive the number of INES level 0 events. waste and materials, identifies foreseeable storage and disposal facility requirements, indicates the capacities International Nuclear and Radiological Event Scale needed for those facilities and the duration of storage, and (INES): International scale designed by the IAEA to sets objectives for radioactive waste for which no final facilitate communication about nuclear events. It provides management method exists. comparative elements that can be used to assess the seriousness of an event. The scale ranges from level 0 Pressurized nuclear equipment: Equipment that is (deviation with no safety significance) to level 7 (major specially designed for nuclear applications and whose accident with considerable health and environmental failure could give rise to radioactive releases. consequences).
Ionizing radiation: Electromagnetic or corpuscular radiation capable of producing ions directly or indirectly as it passes R through matter. This ionizing radiation can be produced by the radioactivity of atoms such as uranium or plutonium. Radiation protection: Combination of rules, procedures Irradiation: Exposure of an organism or an organ to and means for prevention and monitoring aimed at ionizing radiation when the radiation source is outside the preventing or reducing the exposure of employees and the organism. environment to the harmful effects of ionizing radiation.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 65 16/07/2021 06:28 Glossary
Radioactive waste disposal: In France, operation consisting of placing radioactive waste in a specially designed facility for potentially permanent keeping, in U compliance with the principles laid down in article L. 542-1 of the French Environmental Code. UF6: Uranium hexafluoride. Radioactive waste packaging: Operation consisting of UO2: Uranium dioxide. May be in powder or pellet form. It packaging waste in a form suited to the containment of is the constituent component of nuclear fuel. radioactive materials, enabling its shipment, storage and final disposal. Uranium concentrate: Magnesium uranate, sodium, ammonium or uranium peroxide in solid form resulting Radioactive waste: Radioactive substances for which no from the mechanical and chemical treatment of uranium further use is foreseen or planned, or which have been ore. This marketable concentrate contains about 80% requalified as such by the administrative authority pursuant uranium. to article L. 542-13-2 of the French environmental code. Used nuclear fuel recycling: After a reactor residence Radioactive material: Substance containing natural or time of three to four years, the used nuclear fuel must artificial radionuclides whose activity level or concentration be unloaded. At that time, 96% of the fuel materials are warrants radiation protection monitoring. reusable (95% uranium and 1% plutonium), while 4% are fission products and minor actinides (final waste). A first Radioactivity: Phenomenon involving transformation of step is to separate recoverable radioactive materials from a nuclide with release of ionizing radiation. Radioactivity the final radioactive waste contained in the used fuel. The may be natural or artificial. The radioactivity of an element former can be recycled to produce electricity, economizing decreases over time as the unstable nuclei disappear. on natural resources. The waste is packaged safely and sustainably for storage.
Used nuclear fuel: Fuel permanently removed from a S reactor core after having been irradiated there.
Safety analysis report: Report describing the design of regulated nuclear facilities and the measures taken to ensure safety. It inventories the risks presented by the V facility and specifies the measures taken to prevent them as well as measures conducive to reducing the probability Vitrification: Process used to incorporate concentrated of accidents and their effects. solutions of final radioactive waste (fission products and minor actinides), which have been chemically separated Safety standards: Combination of documents called for by from the used fuel, into a glass structure by mixing it with the regulations of each country which present measures a glass matrix at high temperature. taken to ensure the safety of a facility. The safety analysis report is one such document.
Sievert (Sv): Unit of measurement of radioactive dose, i.e. the fraction of energy from ionizing radiation received by W 1 kilogram of living matter, taking into account the effects on the organ in question, which are a function of the type Waste rock: Earth, sand or rock that contains little or of radiation. The millisievert (mSv) is used more frequently, no uranium, but that must be extracted to gain access which corresponds to one one-thousandth of a sievert, and to the ore itself. Their naturally occurring radioactivity is sometimes the microsievert (μSv), which corresponds to comparable to that of the surrounding rock. one one-millionth of a sievert.
Storage: Temporary surface or geologic storage of radioactive materials and waste in a facility that is specifically designed for that purpose, pending their removal.
Subcontractor: Natural or legal entity other than the owner- operator and its employees which carries out operations or supplies goods or services contributing to an activity or Equipment Important for Protection, or which participates in an action covered by the INB Order of February 7, 2012 in connection with such an activity. In particular, this concerns service providers and subcontractors, experimenters and users.
Status of safety in nuclear facilities - 2020 edition
68p_RIGN_2020_EN.indd 66 16/07/2021 06:28 Orano Business corporation with a Board of Directors - Capital of 132,076,389 euros RCS Nanterre 330 956 871 Safety, Health, Security and Environment Department - June 2021
Photos and illustrations: © Orano, Maurice ASCANI, Marie-Emmanuelle BRUNEL, Morgan CARDIN, Matthieu COLIN, Eric M Encre Noire, Philippe ERANIAN, Martin FELDKAMP, François GUICHARD, Cédric HELSLY, Eric LARRAYADIEU, Z_WEI
Design & production: BLEU CERISE
This document was fabricated by HandiPRINT, an adapted company which employs 120 people with disabilities, in the overall management of printed documents.
General Inspectorate Annual Report
68p_RIGN_2020_EN.indd 67 16/07/2021 06:28 As a recognized international operator in the field of nuclear materials, Orano delivers solutions to address present and future global energy and health challenges.
Its expertise and mastery of cutting-edge technologies enable Orano to offer its customers high value-added products and services throughout the entire fuel cycle.
Every day, the Orano group’s 16,500 employees draw on their skills, unwavering dedication to safety and constant quest for innovation, with the commitment to develop know-how in the transformation and control of nuclear materials, for the climate and for a healthy and resource-efficient world, now and tomorrow.
Orano, giving nuclear energy its full value.
www.orano.group PRISME - 125 avenue de Paris 92320 Châtillon - France
Energy is our future, don’t waste it!
68p_RIGN_2020_EN.indd 68 16/07/2021 06:28