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“Nuclear Safety: our overriding priority”
EDF Group‟s file
responding to FTSE4Good nuclear criteria
Disclaimer
This document is provided for information purposes only and is not, in particular, intended to confer any legal
rights on you.
This document does not constitute an invitation to invest in EDF or any other company’s shares and/or
bonds. Any decisions you make in reliance on this information are solely your responsibility.
Although due care to a standard of a limited assurance has been taken in compiling the contents of this
document, EDF or any of other company accepts no liability in respect of any errors, omission or
inaccuracies contained or referred to in it. EDF provides this document in good faith but no warranty or
representation is given by, or on behalf of EDF or any of its directors, officers, employees or advisers or any
other person that the content is accurate, complete or up to date. Any use of, or reliance on, the content of
this document is at your own risk. The situation of policies and systems is the current one in December 2011.
The situation of the datas is at December 2010.
Any intellectual property rights in the content of this document are owned by EDF or its licensors. You are
permitted to download and print content from this document solely for your own internal business purposes
and/or personal use. This document and/or its content must not be copied, reproduced, used, modified,
redistributed or otherwise dealt with for any other reason without the prior written consent of EDF.
Registered trademarks, logos and brand names shown in this document are owned by EDF or its licensors.
No rights are granted to use any of them without the prior written consent of the owners.
EDF accepts no responsibility for any information on other websites that may be accessed from this site by
hyperlinks, or any use of personal data by such third party websites.
Date: February 10th
, 2012.
Preparation of this document was led by Claude JEANDRON, Generation and Engineering Department of
EDF.
Registered Company Details: French société anonyme with a share capital of €924,433,331
Registered head office: 22-30, avenue de Wagram, 75382 Paris Cedex 08, France
Registration reference: 552 081 317 RCS Paris
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Contents
1 Nuclear activities of EDF Group
1.1 Overview of the Group
1.2 Description of nuclear assets
1.2.1 EDF SA
1.2.2 EDF Energy
1.2.3 CENG
1.2.4 TNPJVC
2 Nuclear Safety and Radioprotection
2.1 The Safety Policy and its global implementation
2.1.1 Definition
2.1.2 EDF Group Policy
2.1.3 Overview on general provisions made at Group level to implement
this Policy
2.2 Incidents and events
2.2.1 Policy
2.2.2 Systems
2.3 Unplanned shutdowns
2.3.1 Policy
2.3.2 Systems
2.4 Safety assessment
2.4.1 Definition
2.4.2 Policy
2.4.3 Systems
2.5 Risk assessment
2.5.1 Policy
2.5.2 Systems
2.6 Radiation exposure (to workers and the general public)
2.6.1 Overview on the regulatory context
2.6.2 Policy
2.6.3 Systems
2.7 Security
2.7.1 Policy
2.7.2 Systems
3 Waste
3.1 Overview
3.2 Policy
3.3 Systems for radioactive waste
3.4 Spent fuel
3.4.1 Policy
3.4.2 Systems
3.5 Decommissioning and waste
3.5.1 Policy
3.5.2 Systems
4 Training
4.1 Overview on Human Resources and training policy
4.2 Systems
5 Reporting
5.1 Policy
5.2 Systems
Appendix
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1 – Nuclear activities of EDF Group
1.1 Overview of the Group
EDF is the world’s leading nuclear energy company, with solid positions in major European
countries (18% of world’s nuclear installed capacity, 160,000 employees worldwide, 630 TWh
of electricity generated by all types of generation, 109 gCO2/kWh: a quarter of European
average).
As the world is facing a triple challenge -responding to growing energy needs competitively,
while tackling climate change and the depletion of easily accessible resources- EDF Group's
strategy is to meet these challenges by developing competitive and low carbon energy
solutions. Building a sustainable energy future requires considerable efforts and investment:
fostering decarbonised electricity generation by developing low-carbon
technologies,
promoting demand-side management and developing environmentally friendly
end-uses,
ensuring the competitiveness of the solutions that are chosen, to maintain
employment and ensure affordability for households ,
investing in R&D to prepare for the energy of the future,
exploiting opportunities presented by the latest technologies,
helping with the development of carbon capture, transportation and storage
technologies,
seeking out major hydroelectric infrastructure projects within a local
sustainable development policy.
EDF has been involved in the development and operation of clean and peaceful use of nuclear power for more than 40 years. EDF is currently present in three continents as a nuclear owner and operator:
- in France, where the mother company owns and operates 58 reactors and is building a new one using the most modern technology - the European Pressurized Water Reactor (EPR)
- in the UK, where EDF Energy owns (with minority share partner Centrica (20% ownership)) and operates15 reactors. It also has plans to build four new ones (EPR)
- in the US, where CENG, the joint venture between Constellation Energy Group (CEG) and EDF, owns and operates five reactors; EDF also aims to develop the EPR technology in USA with its affiliate Unistar Nuclear Energy (UNE)
- in China where TNPJVC, the joint company between China Guangdong Nuclear Power Holding Company (CGNPC)(70%) and EDF (30%), will own and operate two new EPR reactors currently under construction.
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EDF has other investments in nuclear companies, but without operational involvement. These
are:
Tihange 1 in Belgium. EDF has a 50% investment in the plant and the sole operator of
the plant is Electrabel. EDF’s responsibility is to ensure that it provides 50% of the
funds necessary to ensure the continued safe operation of the plant (1). This clarity of
responsibility is in line with internationally (Euratom, IAEA) recognised organisational
standards and with Belgian law. EDF takes every opportunity possible within this
context to ensure that the operation of Tihange 1 is in line with accepted best practice
and its own nuclear policies. EDF has four representatives on the Liaison Committee
and one on the Technical Committee, which together provide suitable fora for sharing
the best practice developed across EDF Group and Electrabel, monitoring the
development and implementation of operating practices and launching joint studies
(such as undertaking stress-tests, efforts to reduce radiation exposure, etc). EDF has
reviewed Electrabel’s policies and considers that they are sufficiently in-line with its
own. Moreover, EDF has of course free access to the reports which are disclosed by
the operator itself (2) or by safety authorities (
3). These reports are equivalent to the
ones published by EDF or by French authorities. As operational performance is the
responsibility of the sole operator, Electrabel, performance indicators are not
consolidated into EDF Group figures.
part ownerships of companies like EDF Luminus (4) in Belgium or ALPIQ in
Switzerland, but these investments do not provide an opportunity for influence over
operational practices.
In Belgium EDF owns 63.5% of EDF Luminus which owns 10% of the investment of
Tihange 2-3 and Doel 3-4. EDF Luminus has no operational involvement or
responsibility in those plants which are fully operated by Electrabel.
In Switzerland EDF owns 25.1% of ALPIQ which owns 40% of Kernkraftwerk Gösgen-
Däniken AG which is the operating company of Gösgen station, and 32,4% of
Leibstadt AG which is the operating company of Leibstadt station. ALPIQ has no
involvement or responsibility in the operation of Gösgen and Leibstadt NPP. However,
information made public or provided to board members or to international
organisations give EDF a good visibility on the safety performances of the related
plants. If some safety concern were to appear, EDF board members would be able to
intervene.
EDF also has held and currently holds services contracts for nuclear power in China
mainly technical assistance services contracts (e.g. nuclear plants of Daya-Bay, Ling-
Ao) but EDF is not the operator of these power stations.
1 Signature of a General Agreement on December 16th, 1996. EDF contributes 50% to all operational expenses
and investments during operation and post-operation (following final shutdown), but not decommissioning itself. 2http://www.electrabel.com/assets/content/whoarewe/Declarationenvironnementale211_8938400CB3F44A0
C9DE32C1D5BEA4F99.pdf 3 http://www.belv.be/images/pdf/rapport_annuel_belv_2010_fr.pdf et
http://www.fanc.fgov.be/GED/00000000/2900/2989.pdf 4 SPE became EDF Luminus in november 2011
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1.2 Description of nuclear assets
1.2.1 EDF SA
EDF SA owns and operates in France the largest nuclear fleet in the world, of which it has
been the architect-engineer.
OPERATING UNITS
SITE TYPE POWER (MW)
COMMISSIONING
YEAR
Fessenheim 1-2 CP0-PWR 880 1977
Bugey 2-5 CP0-PWR 910-880 1978-79
Dampierre 1-4 CP1-PWR 890 1980-81
Gravelines 1-4 CP1-PWR 910 1980-81
Gravelines 5-6 CP1-PWR 910 1984-85
Tricastin 1-4 CP1-PWR 915 1980-81
Blayais 1-4 CP1-PWR 910 1981-83
St Laurent B 1-2 CP2-PWR 915 1981
Chinon B 1-4 CP2-PWR 905 1982-87
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Cruas 1-4 CP2-PWR 915 1983-84
Paluel 1-4 P4-PWR 1,330 1984-86
Flamanville 1-2 P4-PWR 1,330 1985-86
St Alban 1-2 P4-PWR 1,335 1985-86
Cattenom 1-4 P’4-PWR 1,300 1986-91
Belleville 1-2 P’4-PWR 1,310 1987-88
Nogent 1-2 P’4-PWR 1,310 1987-88
Golfech 1-2 P’4-PWR 1,310 1990-93
Penly 1-2 P’4-PWR 1,330 1990-92
Chooz B 1-2 N4-PWR 1,500 1996-97
Civaux 1-2 N4-PWR 1,495 1997-99
EDF SA is currently building a new 1,600 MW EPR on the site of Flamanville and intends to
build another at Penly. The newest design of that reactor contains several main improvements
in safety and radiation protection: probability of severe accident reduced by a factor of 10,
reinforced management of severe accidents with fewer potential consequences for people and
the environment, reinforced protection against a plane crash, less fuel used for the same
energy produced so 26% less waste type B produced, half the radiation exposure for
workers,…(5) See more details in § 2.4.
EDF SA is also currently dismantling 9 reactors:
REACTOR UNDER DECOMMISSIONING
SITE NUMBER TYPE OF
REACTOR COMMISSIONING
YEAR FINAL
SHUTDOWN
YEAR
POWER (MW)
Brennilis 1 Heavy water Reactor
1967 1985 70
Chooz A 1 REP 1967 1991 305
Creys-Malville 1 FBR 1986 1998 1,200
Chinon 3 UNGG 1963-65-66 1973-85-90 70-120-480
St Laurent 2 UNGG 1969-1971 1990-92 480-515
Bugey 1 UNGG 1972 1994 540
EDF SA also owns a nuclear subsidiary, Socodei, which operates Centraco, a facility for solid
and liquid waste treatment in the Marcoule industrial complex (Gard department).
Regarding special regulations applicable to nuclear facilities, EDF SA is subject in France
to the law of June 13th, 2006, concerning Transparency and Security in the Nuclear field (“TSN
law”). The law created the Nuclear Safety Authority (NSA), an independent administrative
authority. The law is completed with the decree of November 2nd
, 2007, concerning
authorization of facilities and control; it includes transport of radioactive materials, for which
5 ENEL, the italian leader in energy, holds a 12.5% participation in the investment and operation costs of Fla3
and an industrial partnership contract, but the only nuclear operator is EDF
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emitters are responsible. In addition, the conditions for water pumping, liquid and gaseous
releases and their associated limits are set by the NSA. Limits are approved by the Ministers
in charge with nuclear safety. The application file for an authorization includes a safety report
which contains a description of the measure to reduce the risks and to limit the consequences
of any accident, a study of the impact of the plant on the environment and health, a
decommissioning plan and a risk management study. The TSN law does not set a limit on
service life but requires a safety review of the plant every ten years. After the 10-year
inspection of each reactor, the NSA issues an opinion for the continuation of the operation for
a new 10 years period. If needed, the NSA adopts complementary requirements.
The TSN law also includes provisions concerning public information and transparency,
such as a High Committee for Transparency and Information on Nuclear Safety, a Local
Committee for Information in the vicinity of each nuclear facility. Each facility has the legal
obligation to provide and publicly display each year a report describing the measure taken in
terms of safety, radiation protection and the environment. These documents are available for
consultation on the EDF web-site.
The final shutdown and decommissioning of a nuclear facility are authorized by the
Ministers in charge of nuclear safety; on that basis, the NSA can define specific requirements.
EDF SA’s business is subject to French regulations for the handling, storage and long-term
management of nuclear waste. EDF is legally responsible for the nuclear waste resulting from
its operations. In France, radioactive waste is managed by the National Agency for
Radioactive Waste Management (ANDRA), an industrial and commercial public entity created
by the French law of December 30, 1991.
Regarding radiation protection regulations, all nuclear activities containing a risk of
exposure of people to ionizing radiation fall under the authority of the French Nuclear Safety
Authority (NSA). French regulation is compliant with European directives of 1996 and 1997
which sets the maximum exposure by the general public at 1 mSv per year and impose a limit
on exposure of workers of 20 mSv for 12 consecutive months 6.
1.2.2 EDF ENERGY (for more details, read « Our journey towards zero harm » on EDF Energy’s web
site7)
EDF Energy holds 80% of Lake Acquisitions Limited (the other 20% is held by Centrica) which
owns the eight nuclear sites (15 reactors under commercial operation) of former British
Energy. The acquisition process was completed in 2009. Centrica holds also a 20%
participation in NNB Holding Company Limited, another division of EDF Energy which aims to
build four EPRs in the UK.
6 For more details on regulations , see the Reference Document §6.5.4.2
7 http://www.edfenergy.com/about-us/energy-generation/nuclear-generation/documents/EDF-Energy-
NuclearGeneration-Our-Journey-Towards-Zero-Harm.pdf
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OPERATING UNITS
STATION NUMBER
OF
REACTORS
TYPE OF
REACTOR COMMISSIONING
YEAR
SCHEDULED DATE OF
DECOMMISSIONING(8)
NET
CAPACITY
OF
STATION Hunterston B 2 AGR 1976 2016 820
Hinkley Point B 2 AGR 1976 2016 820
Hartlepool 2 AGR 1983 2019 1,190
Heysham 1 2 AGR 1983 2019 1,160
Dungeness B 2 AGR 1983 2018 1,040
Heysham 2 2 AGR 1988 2023 1,235
Torness 2 AGR 1988 2023 1,230
Sizewell B 1 PWR 1995 2035 1,188
Each nuclear power station is subject to a Nuclear Site Licence, which is issued by the Office
for Nuclear Regulation (ONR). The licence has 36 strict conditions, which govern all aspects of
safe operation of the station. The ONR monitors the performance of the power station
operator, and appoints a site inspector for each station. All significant changes to the plant or
8 Based on currently agreed accounting lives; one of EDF Energy’s expectations is to extend the lifetimes of its
nuclear power stations where it is technically and economically viable to do safely
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to its operating procedures are subject to approval by ONR. EDF Energy has no facility under
decommissioning.
In the following text, the provided information about the governance of nuclear safety and
waste is for EDF Energy’s Nuclear Generation business only. Unless specified, this
information does not apply to the Nuclear New Build project (NNB Generation Company
Limited) given the current stage of development of the project.
1.2.3 CENG
EDF Group co-owns (49.99%) Constellation Energy Nuclear Group (CENG), along with
Constellation Energy Group (CEG)9, but CEG holds the majority of shares (in accordance with
American law, a foreign company cannot exercise responsibility on a nuclear plant). The
acquisition process was completed in 2009. Being co-owner of CENG, the fleet operator, EDF
is fully involved in designing and putting in place nuclear policies and systems in partnership
with its co-owner. CENG’s policies are therefore consistent with, and have informed, the EDF
Group approach.
CENG owns and operates five nuclear reactors in the states of Maryland and New York, USA
(10
). CENG has no facility under decommissioning.
OPERATING UNITS
SITE LOCATION TYPE OF
REACTOR COMMISSIONING
YEAR SCHEDULED FINAL
SHUTDOWN YEAR POWER
Calvert Cliff 1 Maryland PWR 1975 2034 878 MW
Calvert Cliff 2 Maryland PWR 1977 2036 872 MW
Nine Mile Point 1
New York BWR 1970 2029 620 MW
Nine Mile Point 2
New York BWR 1988 2046 1,148 MW
Ginna New York PWR 1970 2029 581 MW
In the United States, the nuclear fleet’s quality and safe operation are monitored by the
Nuclear Regulatory Commission (NRC) which delivers the license to build and to operate,
establishes the rules and controls their strict compliance, through inspections and with the
help of a representative on site. The NRC regularly assesses safety performances and
publishes a rating for all plants. CENG’s nuclear business is undertaken in a predictable
regulatory environment. Licenses are initially granted for 40 years of operation. They can be
extended by additional 20-year periods, provided that the operators commit to adequate
monitoring of the key components and structures of their plants. All CENG units applied for the
extension of their license from 40 to 60 years, and they have all been granted.
9 A merging process between CEG and Exelon is ongoing
10 Long Island Power Authority owns 18% of Nine Mile Point 2
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In addition, the Institute of Nuclear Power Operations (INPO), created after the Three Mile
Island accident of 1979, aims to promote operational excellence through safety assessments,
peer-reviews and support activities. The INPO assesses all sites every 2 years and also
publishes a rating (used by insurance companies); it is also the prescriber and the controller of
training processes: it delivers accreditation of the plants every 4 years.
The Electrical Power Research Institute (EPRI) brings an important technical support to
American nuclear operators, thanks to research in laboratories and experience feedback from
the operators.
EDF Group has been a permanent member of INPO and EPRI for many years and has an
inspector inside INPO in Atlanta and an engineer in EPRI in Palo Alto.
1.2.4 TNPJVC
EDF owns 30% of the shares of Taishan Nuclear Power Joint Venture Company limited
(TNPJVC), the goal of which is to construct and operate two EPR reactors in Taïshan, in the
province of Guangdong (China). CGNPC Group holds the majority of the equity interest in line
with PRC law. For the first time the Group is an investor in nuclear power generation in this
country11
. The first concrete casing for unit 1 was constructed in the last trimester 2009, and
the first concrete was poured for unit 2 in April, 2010. The first unit should be commissioned at
the end of 2013 and the second in 2014.
The design, equipment manufacturing, construction, commissioning and start-up of nuclear
facilities in China are performed on the basis of the applicable laws and regulations in force in
China as well as on the basis of codes and guides on nuclear safety and industrial guidelines
and standards. The National Nuclear Safety Administration ("NNSA") is the regulator for
nuclear and radioactive safety in China. The NNSA is responsible for (i) the administration of
nuclear safety, and making relevant guidelines, policies and regulations; (ii) participating in
emergency response to nuclear accidents and radiation environmental accident; (iii) carrying
out integrated supervision and administration of the safety of nuclear facilities, application of
nuclear technology; and (iv) carrying out safety supervision of nuclear materials restriction and
nuclear pressure retaining components. Another important role of the NNSA is its
responsibility for issuing licenses in relation to the activities of the NPP, in particular, the
approval of the nuclear safety aspects of the feasibility study report. The Ministry of
Environmental Protection ("MEP") is responsible for the supervision and administration of the
nationwide environmental protection, including that for the nuclear power plants, radiation
environment and radioactive waste. The Safety Guides established by NNSA are based on
the IAEA safety guides. The compliance of Taïshan project with Chinese regulatory
requirements will be developed in the Final Safety Analysis Report. It has to be noted that
Taïshan Phase 1 power plant is based on Flamanville 3 design for which the French
regulations are applicable.
11
EDF has also support contracts with CGNPC in Daya-Bay and Ling-Ao plants but no responsibility as an
operator
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Given the current stage of the Taïshan Phase 1 project, the nuclear safety policy and
management issues are at a very early stage, compared to those at other sites. The focus is
for the moment on designing-in and building-in nuclear safety. Indeed the reference
documents regarding safety and waste management are yet to be produced, and no indicators
are available although an internal Nuclear Safety Management Policy is already in place within
TNPJVC. Therefore the description of safety policy and management practices in the
following paragraphs is only partially applied to TNPJVC. This current file will be
reviewed when the construction site becomes a nuclear facility under commissioning
tests.
Nonetheless, EDF and CGNPC have been partners in nuclear activities for 30 years, since
they have cooperated in a very comprehensive way for the success of the power plants of
Daya-Bay and Ling-Ao I and II. A lot of Chinese operators and engineers of these power
stations have been trained in France and numerous French systems, practices, and technical
improvements have been imported by Chinese managers and executives and are applied or
were adapted for the Chinese system. A Chinese version of the RCC-M was released in
November 2010. CMIF (China Mechanical Industry Federation), CNPRI (China Nuclear Power
Research Institute), AFCEN, EDF, DEC (Dongfang Electric Corporation) and NEA (National Energy
Administration) participated to this project. The publication of RCC-M Chinese version will
facilitate the cooperation between Chinese manufacturers, international nuclear actors and
inspection entities. China’s own nuclear Codes & Standards establishment is still under
progress and AFCEN is interested to continue cooperation with CNPRI to further translate and
update the RCC codes. Today the operating performance (including safety) of French and
CGNPC plants are very similar. A close cooperation is in place in Taïshan Phase 1 between
the two engineering services to control the quality of the construction of the two EPRs and the
quality of all equipments and pieces from all the suppliers. Thirty EDF staff work on a
permanent basis on the Taïshan site. EDF intends to gain a large experience feedback from
that project to the benefit of EPR standard.
2– Safety and Radioprotection
2.1 The Safety Policy and its global implementation
2.1.1 Definition
Nuclear safety, as defined by international organizations, is the various provisions made at all
stages in the design, construction, operation and decommissioning of nuclear facilities to
protect people and their environment against the dispersal of radioactive substances under all
circumstances, or in other words:
Ensure the facilities are operating normally
Prevent incidents and accidents
Mitigate the consequences of incidents and accidents that may occur.
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2.1.2 EDF Group Policy:
We all, within EDF Group, share the same vision that nuclear safety is the overriding
priority in the sustainable use of nuclear energy, recognising that nuclear energy needs
also to be efficient, affordable and environmentally friendly. It is an indispensable
precondition when providing energy to humanity.
Nuclear safety inside the Group rests on the principle of clarity of responsibility and
control.
Each nuclear operating company inside the group acts under the framework of legal
obligations and regulations specific to its country and must comply with them. Each
guarantees and continuously improves its safety performances with its own methods, skills
and values.
EDF respects national differences, across the Group, whilst developing common principles
to deliver the highest level of incident prevention and protection of the public, workers, and
the environment. This policy covers all aspects of nuclear – for example, new build,
architecture, design and construction - and all aspects of the existing stations – operation,
maintenance, waste management, decommissioning and off-site support. The Group
works closely with its industrial partners to deliver this.
Each company is responsible for, and assigns adequate delegation at, each level of
management or operation: clear organisation, the required skills and decision-making
capacity, access to support and resources. The Group guarantees the allocation of
resources needed to ensure nuclear safety.
An in-house independent nuclear safety assessment function is put in place at power
station level, company level and Group level. Each report independently of all line
functions and have not only the right, but also the duty, to notify senior management of
inappropriate or inadequate line management response.
Common commitments for all nuclear companies of the Group
An overriding priority is placed on nuclear safety at every stage of the plant lifecycle:
design, construction, operation and decommissioning. That priority is the responsibility of
all and is demonstrated via the individual commitment of all staff within the Group. Each
company ensures that its contractors enforce that requirement, and employ well-trained
and professional staff.
The Group recognises that excellence in everything we do is underpinned by equipment
reliability, human performance and efficient work management, as these are the main
drivers of nuclear safety and reliability.
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The Group recognises the importance of establishing a good nuclear safety culture among
its staff and contractors. This is characterised by people having a questioning attitude and
being free to raise safety concerns, using error prevention techniques, reporting in a timely
and transparent way, being conscious of risks and continuously assessing them. The
Group values highly, and encourages, independent oversight and challenge.
Although it is mobilized to minimise the risk of any incident or accident, the Group must respond adequately to such an event with the aim to protect public health and safety. The Group’s companies maintain comprehensive emergency plans at a high state of readiness, including carrying out regular emergency drills with local and national authorities. The Group uses these opportunities to reinforce its communication towards the public and to enhance the safety culture of its staff.
Continuous improvement is promoted and organised using the full range of knowledge and
services within the Group and within international organisations. Operational experience
is collected, analysed, reported, and acted on.
International experience enriches continuous improvement and the drive for excellence:
the Group’s companies commit both to receive regular international peer reviews and
provide suitable peers for such reviews in other companies. All recommendations are
considered and acted on.
Openness and transparency: we aim to build openness and trust internally and externally
by creating an open culture and actively engaging with our stakeholders and communities
through clear and timely communications on nuclear safety issues and incidents. We
strive for a constructive, open and trusting, relationship with our Stakeholders, including
our staff, our suppliers’ staff, regulators, trade unions and local communities.
Application
The responsibility for the deployment of this policy, and the overall operation of the business
unit, lies unambiguously with the line management. Group is responsible for checking, using
appropriate mechanisms, that the policy has been adequately deployed and the standards and
quality for the delivery of nuclear safety are being adequately maintained by the line
management.
2.1.3 Overview on general provisions made at Group level to implement this policy:
In 2009 EDF acquired renowned existing nuclear companies after having built its own fleet
and accumulating at the same time, vast experience at three stages: (i) designer and
architect-assembler, (ii) operator, (iii) dismantler. Each EDF Group company had previously
put in place its own safety policy and management system and remains responsible for its
safety. Each one, beyond compliance with national laws and regulations, strives for excellence
and has implemented long-term adapted programs to continuously improve its safety
performance; each one uses its own competences and expertise and benefits from national
and international support. The aim of EDF Group is so to encourage this attitude and to
reinforce it by using all possible synergies within the Group in the framework of its common
nuclear safety policy.
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The continuous reinforcement of nuclear safety is built on three pillars, chosen and
implemented in a manner consistent with international guidelines (IAEA SF-1 and GRS-3,
INSAG 4 for safety culture, INSAG 13 for safety management, INSAG 18 for changing
management) and best practice:
the permanent reinforcement of the reliability of organization, through the
implementation of best practice, and striving for excellence
the permanent reinforcement of the reliability of equipment
the permanent reinforcement of human performance and professionalism of all actors,
acting right at the first attempt.
Bringing complementary means and processes, EDF Group aims to develop strong synergies
between nuclear companies and to ensure that its common policy is fully implemented
everywhere. With that objective, EDF Group:
implements special programs to share experience, for existing fleets and for new
projects (see §2.2, 2.4, 2.5, 2.6, 2.8)
brings additional support from its engineering division if needed (e.g. in case of
incident or maintenance)(see §2.4),
has extended crisis organization (see §2.5),
promotes the use of international benchmarking and the implementation of best
practice, and puts in place cross-programs for training
EDF has also defined its own requirements in the case of a new acquisition in, or a
new partnership with a nuclear company.
EDF has had in place for many years a dedicated organization and high competencies to
monitor the compliance of its safety policy inside the company, led by the General Inspector
for Nuclear Safety and Radiation Protection (GINSR), directly reporting to the CEO of EDF
Group, and the Nuclear Safety Council. Following the international development of nuclear
activities, EDF is progressively extending the scope and the role of the General Inspector and
those of the NSC, opened now to representatives from EDF Energy and EDF Inc (12
). Today,
the GINSR implements safety assessments and controls across the Group (13
). With his team
of senior experts, he verifies that safety performance and practices remain efficient and
extensive, regarding requirements and public expectations, as well as the company’s policy.
He verifies that behaviour and culture are consistent all over the Group. He warns executives
if necessary and presents recommendations. He produces an annual report which he presents
to the NSC and which is available to the public (on web site). His recommendations are
recovered if needed by the CEO to the intend of the concerned executive.
12
EDF offices in Washington DC, whose some executives are members of CENG board
13 These assessment visits can take place only in the operating companies where EDF is involved (if specified in shareholder agreement in
the case of minority share) ; in the other companies, the GINSR can make visit with the authorisation of the operator in the framework of
experience sharing
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The governance of each nuclear company of the Group is adapted to its share and to
national obligations. By its representation in different boards and committees, EDF is aware of
a high number of information and reports, complemented by the assessments of the GINSR,
and can impulse or promote safety improvements.
Within EDF Energy Nuclear Generation Group Ltd, the board is responsible for the
management monitoring of EDF Energy Nuclear Generation, the business unit which holds the
license. Several representatives of EDF (a part being senior executives of Generation and
Engineering Division EDF) are members of this board. Inside EDF Energy Nuclear
Generation, a Nuclear Safety Committee is constituted, in compliance to the license; a Safety
and Regulation Division regularly reports to this Committee in the area of safety. EDF GINSR
is a member of the committee.
Within CENG, the Nuclear Safety and Operation Committee (NSOC) is a committee of the
Board dedicated to safety; it reviews safety performances reported by INPO and by the quality
organization of each plant; EDF has two members (parity with CEG). On each site, a Nuclear
Safety Review Board monitors safety management; a member of INPO and external experts
are members of this board, with representatives of the plant; a senior vice-president of CENG,
coming from EDF, is a member as well. NSRB makes a report every three months which is
displayed to the INPO.
Within EDF SA, the overall compliance to regulations and to the safety policy and the safety
management are assessed at each level of the organization. At the company level, the
Nuclear Safety Council, of which the GINSR is the secretary, is composed in particular of all
the executives of the mother company and it reports to the Chairman of the company. At the
immediate lower level, the Operational Safety Review Committee of the Nuclear Generation
Division reports to its director. Also the Design Safety Review Committee reports to the
directors of Nuclear Engineering Division. At each station, a Safety Technical Committee
reports to the plant director. An independent line of engineers and senior advisors is
permanently assessing safety and reports to these committees (for more details, see § 2.4)
2.2 Incidents and events
2.2.1 Policy
Recognizing that the most harmful consequences arising from nuclear facilities can come from
the loss of control over a nuclear reactor core, the nuclear chain reaction, or uncontrolled
radioactive discharge, EDF Group aims to reduce the likelihood of an accident having harmful
consequences to the lowest level as possible, and takes measures:
To prevent the occurrence of failures or abnormal conditions that could lead to such a
loss of control;
To prevent the escalation of any such failures or abnormal conditions that do occur
and mitigate their consequences;
To prevent the loss of, or the loss of control over, a radioactive source or other source
of radiation.
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2.2.2 Systems
The primary means of preventing and mitigating the consequences of accidents is „defence in
depth‟. Defence in depth is implemented primarily through the combination of a number of
consecutive and independent levels of protection: some of them could replace others in case
of failure and would prevent any harm caused to people or to the environment.
In line with this fundamental IAEA principle and with local regulations, EDF Group companies
have all put in place local processes to detect (14
) and prevent such failures/events (15
) of any
origin (human or technical), to mitigate them and to implement experience feedback. That
process consists of:
o Identifying conditions that have or could have an undesirable effect on performance of
equipment, programs, or organizations
o Ensuring necessary immediate actions are implemented to place plant/situation in a
safe and stable condition
o Reporting the condition to a supervisor or the control-room, as appropriate, including
immediate corrective actions taken
o Promptly initiating a condition report and providing sufficient information so that the
condition can be properly evaluated for operability and compliance with safety rules.
The conditions and limits necessary for safe operation are described in Operating Technical
Specifications (OTS), or the licence conditions, validated by the national safety authority.
These specifications are more or less detailed, depending on the way risk analysis may be
used in conjunction. On one hand in France OTS are largely extended and they describe in
detail the list of actions to implement in case of a failure on a safety-related equipment; risk
analysis is not used as a complement to day-to-day operation (16
). On the other hand, risk
analysis is used extensively in USA, for example in the case of a simple (or a combined)
unavailability of safety-related equipment(s). The two approaches are internationally
recognized as efficient.
The incident or accident procedures used to place the plant in a safe condition have been
widely improved everywhere since the accident of Three Miles Island which highlighted the
difficulty to make a correct diagnosis of the situation and to carry out the appropriate corrective
actions. A large international experience feedback program has been implemented. Several
steps have been taken to and currently all the French procedures are state-oriented
procedures, used simultaneously by operators and supervisors on the one hand and safety
engineers on the other. These evolutions are closely linked to license conditions and can only
be implemented with the agreement of safety authorities in a consistent way with all the
14
The detection and self-report of errors by their authors is promoted and recognized as a positive contribution
to safety; on the contrary, the fact of hiding an error is a fault in the safety culture and has to be disciplined
15 In the safety culture, an “event” does not necessarily have a direct consequence on equipment or on the
installation globally. It can only be constituted on a decline in the lines of defence with no material
consequence.
16 The required attitude has been determined by risk analysis when the OTS have been established
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nuclear industry and following thorough tests and qualifications on a simulator. All operators
and supervisors are often trained on full-scale simulators to be well prepared to face an
accident situation. In some sessions, severe accidents caused by important and combined
failures beyond the referential are simulated to prepare the shifts to face complex situations.
According to its permanent safety assessment and its experience feedback program, EDF SA
uses detailed safety indicators and assessment tools to determine and monitor
improvement programs or projects launched to correct weaknesses and to look for excellence.
These indicators are, beyond the number of significant events or incidents, for example the
number of non-compliances with Operational Technical Specification (OTS), number of line-up
errors, number of breakings out of fire, etc. EDF also implements a risk analysis of the most
significant events and on “precursors”. That process is an accurate and objective tool to check
if the safety is really improving and to rank all the events to determine the most significant.
These indicators are also instruments to monitor the various projects, such as:
Project “Deployment of Human Performance tools”: that project is based on two
approaches: (i) ensure that every operational employee does the right thing at the first
time by using standard practices and (ii) ensure that every manager conducts an on-
site visit with its staff. At the end of 2010, 30,000 managers and field workers (EDF
employees and contractors) had been trained in reliable practices, of which 20,000
were during dedicated workshops; 1,300 instructors were also trained to maintain and
demonstrate good practices within the work teams. More than 60,000 on-the-ground
monitoring visits are performed each year by managers. Each station has its own
human factor consultant.
Project “AP 913 implementation”: launched by INPO around 2000, this initiative aims
to obtain excellence in the reliability of equipment. EDF decided to use this program to
reinforce its maintenance strategy. All the maintenance programs have been re-
assessed, dedicated organization and staff have been put in place and the project is
under active deployment
Project “Put fire risk under complete control”: this project combines the 4 conditions for
success which are (i) fire risk management, (ii) training, (iii) prevention and (iiii) fire
fighting. EDF uses two training centers to regularly train its fire-fighting teams and
operating teams; partnerships are effective in all plants with local fire-brigades with
numerous fire-drills; prevention is also reinforced by the presence of a professional
fire-officer within each local organization
Project “Experience feedback”: that project aims to complement the already strong
and efficient centralized process with local information and feedback, to make each
manager and each operator more aware of its role, and therefore more efficient; it
uses the US process called the “Corrective Action Program” (CAP), required by law in
the US (10CFR50), and also promotes a deeper use of WANO reports (SER and
SOER)
Project “Implement an attractive industrial strategy” (17
): this project consists of the
reinforcement of the partnership with contractors by improving the activities and skills
of staff. It also focuses on Industrial Safety for contractors, working and living
conditions for on-the-go personnel, long term contract visibility...This project was
17
The project’s name is MOPIA in French (“Mettre en Oeuvre une Politique Industrielle Attractive”)
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launched after an agreement was signed in 2004 with contractor representatives. The
contractual conditions have been reviewed (18
) and a program put in place in favour of
recruitment and skills. A complete training course has been put in place in partnership
between “Education Nationale”, EDF and contractors; all stations have their workshop
for training.
At EDF Energy there is a particular emphasis on oversight to monitor performance and
conformity to both its internal standards and external regulations. They operate a multi-layer
model with increasingly independent oversight being exercised through:
• Management accountability - the exercise of leadership;
• In-process oversight through self checking, peer checking and self assessment as part of its
internal controls process;
• Functional oversight – review and audit by company experts;
• Independent internal oversight from its Safety and Regulation Division who reports to the
Board independently of the operating arm of the company
• External oversight from its Nuclear Safety Committees with their external members, from
peer evaluations by teams from other utilities and WANO/INPO, from standards accreditation
bodies, e.g. Lloyds Register Quality Assurance, and from the Government’s Office for Nuclear
Regulation.
Specifically for incidents and events, EDF Energy also undertakes the following processes:
The continuous improvement model which is based on the INPO excellence model and is
enshrined in company processes. Issues and emerging trends are identified and
analysed; solution options are studied, prioritised and implemented through business
processes.
The Corrective Action Programme which is used to identify, document, evaluate, and
trend undesirable conditions (problems) and to take actions to correct problems and their
causes. The aim is to proactively identify sub standard conditions and practices at a local,
low consequence level and take positive action to prevent more significant consequence
events arising and adverse trends developing.
The Operating Experience processes cover the reviewing, screening and disseminating of
internal and external nuclear industry event notices or other operating experience for
applicability of lessons learned to specific EDF Energy Nuclear Generation facilities.
For more details, on EDF Energy processes and systems for incidents and events, see “Our
journey towards zero harm”.
18
To promote the preference to the best bidder (“Most Economically Advantageous Tender”) than to the
cheapest one
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CENG has established 6 “Fleet Initiatives” which are identified and defined below:
Nuclear Safety and Security: CENG drives for proactive elimination of vulnerabilities in nuclear safety and physical plant security. CENG accomplishes this through improvements in cyber security, emergency planning, fire protection systems, environmental performance, containment sump performance, and Fukushima lessons learned.
Personal Safety Excellence: CENG drives for fundamental improvements in industrial and radiological safety. CENG accomplishes this through improvements in hazard recognition, mitigation and elimination; employee engagement; leadership support; and source term reduction.
Operational Excellence: CENG drives for excellence in nuclear safety, human performance and generation reliability. CENG accomplishes this through improvements in Operations fundamentals, INPO Performance index, refuelling outage performance, human performance and risk management.
Performance Improvement: CENG drives for improved prevention, detection and correction of problems. CENG accomplishes this through improvements in the Corrective Action Program, self-assessment and trending; and by using significant operating experience.
Equipment Reliability: CENG drives excellence in generation reliability and predictability. CENG accomplishes this through improvements in performance monitoring, maintenance strategies, work management, and productivity.
Organizational Effectiveness: CENG drives achievements of CENG’s strategic goals
through effective leadership and alignment. CENG accomplishes this through
improvements in leadership, communications, training effectiveness, and measure and
incentivized fleet performance.
2.3 Unplanned shutdowns
2.3.1 Policy
A significant number of automatic Reactor Trips will generate pressure and temperature transients on components and structures that may be detrimental to the long term operation of the plant, requiring additional inspections and maintenance; unplanned shutdowns for maintenance or repair may increase worker radiation doses and volumes of liquid and gaseous wastes. Consequently EDF Group is committed to their reduction and eventual elimination in order to promote Nuclear Safety, Radiation Protection and Public Safety performance. 2.3.2 Systems
EDF Group’s companies adopt international best practice in this field. The international
standards and performance criteria defined in the INPO (Institute of Nuclear Power
Operations) and WANO (World Association of Nuclear Operators) constitute the foundation
used by EDF.
EDF respects, however, different practices promoted by safety organizations and national
requirements: in some countries the reactor operator is asked to anticipate the automatic
protection (this is the case in USA and UK) by undertaking a “manual scram”, in others the
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operator is asked to leave automatic protections to do their job. The different approaches give
rise to differences in the comparison of indicators.
Each company regularly defines and implements action plans depending on its own strengths
and weaknesses highlighted during their safety reviews.
EDF SA‟s current action plans are focused on three aims:
Improve reliability of organization: the situations more likely to cause a scram are
identified in activity planning, risk analyses are done and responses are put in place
Improve the reliability of equipment: every failure at the origin of a scram are
analyzed, corrected and the experience is integrated into the continuous improvement
loop (AP 913 project: see §2.2)
Improve human performance: situations presenting a potential risk of scram are
identified and the efficient ways to manage them are part of the EDF project “Improve
Human Performance” (see §2.2).
At EDF Energy, according to worldwide industry accepted best practice, the implementation of
a rigorous process-based approach to plant operational management is the most effective and
robust means to ensure sustainably high safety and environmental performance including
avoidance of Unplanned Shutdowns. Three of the most important processes are:
Work Management
Equipment Reliability
Nuclear Professionalism (human error prevention)
EDF Energy Nuclear Generation has implemented Work Management best practices following
the Institute of Nuclear Power Operations (INPO) guideline AP-928 and has implementation
plans in place for Equipment Reliability best practices following the INPO guideline AP-913.
The Nuclear Professionalism program, which includes both human performance and nuclear
safety culture components, is in place throughout EDF Energy Nuclear Generation. This
program focuses on minimizing the frequency and consequences of human errors through
training, effective use of human error prevention tools, performance coaching and the
identification and reduction of organizational weaknesses through investigations into events,
incidents, near misses and performance trending of sub standard conditions.
CENG continues with strong performance in Unit Capability Factor. As a fleet it is top quartile
based on two and three year averages. This performance is due to its focus on Equipment
Reliability which results simultaneously in advantage on safety and availability. Site and fleet
level engagement in Plant Health Committees, Reactivity Management Committees and
Configuration Control Oversight reduce the challenge to Operations and provide a plant that is
less susceptible to transients.
Coupled with Equipment Reliability are Human Performance initiatives which use Dynamic
Learning Activities designed to instruct CENG staff and vendor support personnel in
behaviours needed to mitigate challenges to the plants.
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Actions that CENG is currently taking are:
Plant Health Committee which focuses on the performance of systems important to
safety and brings their status to the attention of the leadership team to understand
how performance can be improved.
Reactivity Management Oversight Committee evaluates systems impacting Reactivity
Management and the aggregate effect of degraded components on the reliability of
the units.
Responding to IER L2 11-02, Reactor Trip Performance. A high impact team has been
developed to study the issues around the industry related to Reactor Trips and
developing actions to mitigate at the sites
Reporting by the sites during the daily fleet call on issues important to system health
and challenges due to emergent issues.
2.4 Safety assessment
2.4.1 Definition
A “safety assessment” is a general process used in nuclear industry to identify and to evaluate
the efficiency and the effectiveness of all the provisions implemented where safety is
concerned; it is used in numerous situations, from design to dismantling, through the
management of operation activities and many others. The assessed items can be safety
issues, means and provisions for prevention and for mitigation, provisions for control and
monitoring. A safety assessment frequently includes a risk assessment of various hazards
generated by the facility/activity itself or external hazards. So these two notions are closely
linked and it is difficult to present them separately. In the following two paragraphs the use of
safety assessment in EDF Group will be described in a large list of situations, including or not
a risk assessment; and the use of risk assessment regarding external hazards will be
described in § 2.5, as well as probabilistic risk analysis.
2.4.2 Policy
As noted in the nuclear safety policy section, the nuclear companies of EDF Group, as
operators of commercial nuclear power plants, are responsible for the safety of their workers
and the public and aim to minimize risks arising from normal operation and from any
nuclear accident due to its installations or to natural events (e.g. flooding, earthquakes,
extreme winds, climate change, fires, loss of coolant, loss of power...) to an acceptable and
achievable level in line with national and international standards and industry best practices.
The Group promotes the use of safety assessment and risk analysis in the largest variety of
situations as adequate. Its Engineering Division is fully involved in that approach.
2.4.3 Systems
Day-to-day safety assessment
In day-to-day operation, each company of EDF Group has put in place a safety assessment
process; it is a key point of an efficient organization and management (inspired by GS-R-3
and INSAG 13 of IAEA) , as well as a key point of a safety culture (inspired by INSAG 4).
As nuclear safety is the result of all the provisions made to protect people and the environment
against the release of radioactive material, the principle of successive barriers is applied for
this purpose: the fuel cladding, the reactor coolant system and the containment. To preclude
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the failure of the barriers or to mitigate the consequences, the three following safety functions
must be maintained: control of reactivity, control of fuel cooling and control of the containment
of radioactive materials.
The day-to-day safety analysis during operation consists of a frequent monitoring of the
efficiency of these barriers and safety functions; it combines self-assessment by operators,
internal control by supervisors and independent verification by safety line (safety engineers of
safety-quality specialists); it is applied in every domain of work (operation, maintenance,
periodic testing). Comparing the results of verification safety tests with those carried out by
plant operators (those responsible for operation and day-to-day safety) is a very effective
means to maintain a high level of safety as well as a good way for developing a questioning
attitude and for identifying malfunctions. These safety assessments play a dominant role
during daily meetings where managers and supervisors express the safety requirements and
ensure compliance.
In EDF SA, several safety management tools have been developed over several years to
facilitate and to encourage managers and workers to carry out high level safety assessments
and to reinforce the prevention of errors during activities. These tools include:
risk analysis: identifying the plausible scenarios which might lead to a wrong result or
degradation of the plant conditions and in setting up the appropriate measures to
prevent and manage the identified risks
self-assessment: a structural and objective comparison performed by an entity
(working team or service) in order to assess its performance with respect to defined
requirements
self diagnosis: a reciprocal questioning process between for professional staff who
carry out a comprehensive review of certain joint activities (for developing individual
and team effectiveness)
safety-availability-Radiation-Protection-environment observatories (SAREOs): being
aware that the arbitration between safety and other performance factors is essential,
SAREOs analyze in each station the quality of the decision-making process and
propose actions to improve it and to guarantee compliance with rules in any
circumstances
additional inspections and audits are performed by international teams of
organizations such as the IAEA (with its OSART missions) and WANO (with its Peer-
Reviews and Follow-ups) (see below).
For CENG, the safety management system is comprised of day-to-day safety reviews
embedded in plant operating processes and periodic meetings of safety oversight committees
required by 10 CFR 50. In addition, CENG participates as a member of INPO and WANO to
receive evaluations of plant operational safety.
The attributes of the safety management system include, as examples:
Safety review of changes to plant operating licenses and technical specifications by
plant staff and NRC in accordance with 10 CFR 50.90
Safety review of changes to plant design and procedures in accordance with 10 CFR
50.59
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Review of plant activities and planned configuration changes to support maintenance
using probabilistic risk analysis
Review of certain plant changes, tests, and experiments by the Plant Operations
Review Committee (PORC)
Periodic review of station safety effectiveness by the Nuclear Safety Review Board
(NSRB)
The nuclear safety culture of CENG stations is monitored and assessed in accordance with
NEI 09-07, “Fostering a Strong Nuclear Safety Culture,” implemented consistent with the 2010
NRC policy statement on safety culture.
At EDF Energy, the company vision and associated strategic objectives are implemented
through a defined organizational structure and 36 interlocking processes. For each process
there is an identified champion in the business who owns the process definition and
documentation and is charged with its continuous improvement. The whole is underpinned by
the values, standards and expectations that should inform and permeate all activities
throughout the company.
Based on the standards the processes include all the elements necessary to manage and
control nuclear power stations safely and efficiently. Alongside the processes for specific
technical activities there are processes for securing sufficient suitably qualified and
experienced staff (including training), for improving human performance and nuclear safety
culture, for implementing and monitoring governance procedures, for ensuring adherence to
regulations, for securing independent assessment of our activities, for investigating departures
from expected plant and personnel behaviour and preventing their recurrence (CAP – the
Corrective Action Program) and for driving improvement in all aspects of performance.
As you would expect for a high-hazard industry there is a particular emphasis on oversight to
monitor performance and conformity to both the internal standards and external regulations.
EDF Energy operates a multi-layer model with increasingly independent oversight being
exercised through:
Management accountability - the exercise of leadership;
In-process oversight through self checking, peer checking and self assessment as
part of its internal controls process;
Functional oversight – review and audit by company experts;
Independent internal oversight from the Safety and Regulation Division who reports to
the Board independently of the operating arm of the company
• External oversight from Nuclear Safety Committees with their external members, from peer
evaluations by teams from other utilities and WANO/INPO, from standards accreditation
bodies, e.g. Lloyds Register Quality Assurance, and from the Government’s Office for Nuclear
Regulation.
Specifically for safety assessments in EDF Energy, as part of its adequate arrangements to
comply with nuclear site licence requirements, there are the following processes:
The Maintain Design Integrity process ensures that the design intent is met and that, where changes are made to the design, this is done in a controlled manner
The Modification Process (nuclear site licence condition 22) is used to control changes to the plant and/or safety case against deterministic and probabilistic nuclear safety principles.
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The Technical Governance process ensures that appropriate engineering policies, codes and standards are provided and applied.
The Periodic Safety Review (nuclear site licence condition 15) process is a periodic holistic review of the condition of the plant and of any changes to standards.
For more details on EDF Energy safety assessment processes and systems, see “Our journey towards zero harm”.
Overall safety assessment
At high management levels or for whole organizations, a safety assessment of the functioning
of the organization and its management is a process developed and promoted inside EDF
Group, while using international organizations which contribute to improve efficiency.
In EDF SA an annual safety review is carried out by the plant manager, leading to an annual
safety report. It presents the safety state of the plant (or of an engineering unit) through:
the top manager’s view on the safety management diagnosis of his site/entity
a detailed analysis based on the review of safety results, safety events analysis
(significant as well as low level), self assessment of the site and technical state of the
installations
the safety action plan.
The report is sent to the corporate level and to the NSA.
Some elements are used to prepare the safety part of the annual public report which is
presented to the Local Commission for Information and publicly displayed.
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As indicated on this chart, the results of an external assessment are included in this process;
indeed such an evaluation takes place almost every year:
a WANO peer-review takes place every 4 years on each of the 19 nuclear sites in
France
one IAEA OSART takes place each year at one of EDF’s stations
and every 4 years each station receives an Overall Excellence Assessment carried
out (for the part regarding nuclear safety, radiation-protection and environment) by the
Nuclear Inspectorate Department of the Nuclear Generation Division.
The result is that each station welcomes nearly every year (19
) an overall safety assessment
which gives it an external vision and recommendations fed by international experience.
The Overall Excellence Assessment process carried out by the Nuclear Inspectorate
Department is a specific process that has been put in place for about 20 years and which has
been continuously improved. Its aim is to assess the safety level based on a comparison
between actual plant results and the reference guidelines based on the requirements of
corporate level, and to provide recommendations to the line management to improve safety
level. The areas covered by an OEA are: housekeeping, operation, maintenance, technical
support, radiation protection, fire protection, environment and chemistry, and safety
management, plus decommissioning management if appropriate.
All these process are a deep and exhaustive assessment which allows, at the corporate level,
to define orientations for enhancing nuclear safety, to benchmark and compare plants and to
improve the safety management and the global results of the fleets. They are also a good
opportunity for engineers and managers of the companies to participate in peer-reviews and
OSARTs abroad and to observe other good practices. That’s why EDF Group promotes them
and aims to increase the number of managers involved in the process.
In EDF Energy, an annual report is produced to review nuclear and radiological performance
over the year. The report presents the safety state of the plant and processes through use of
results, analysis and insights. The report is reviewed by the Safety and Oversight Delivery
Team which is a key governance body within Nuclear Generation, and the Nuclear Generation
Executive Team, and is then presented to the Licensee Board and the EDF Energy Nuclear
Generation Group Board. It is also sent to the Office for Nuclear Regulation.
CENG uses performance assessments to determine current-state performance, as well as to
define performance levels consistent with CENG’s stated vision of recognized industry
leadership. CENG performs internal assessments to critically evaluate their organizations.
CENG uses external assessments, where they are evaluated by independent organizations,
and industry benchmarking. External assessments are a resource to identify the best practices
of others, and provide a full data set to evaluate both CENG’s performance and capacity.
CENG’s internal assessment processes include quarterly Management Review Meetings
(MRM) and monthly Touch Point MRMs, structured review of Key Performance Indicators
(KPI), Quality and Performance Assessments (QPA) and audits, and self assessments. An
Integrated Performance Assessment Process (IPA) is used to synthesize all the information
from internal assessments into a comprehensive performance picture. The output of the IPA
19
Taking into account the post peer-reviews and post-OSARTs
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drives performance gap closure through continuous improvement, governance and oversight,
and training activities. Each of these processes is governed by a common CENG fleet
process.
The involvement of engineers and managers from EDF Group companies in the
international organizations is a good way to learn more in term of safety management and
more largely to develop the openness to the best practices in the industry.
One of the paths to international exchange is the training of our executives within international
organizations; several dozens of executives participated this year in seminars of the Training
Academy of the INPO and to University Sessions of the WNA.
In EDF our contribution to the WANO Peer-Reviews and Technical Support Mission (TSM)
involved nearly 100 executives in 2010. More than 120 have also been involved in WANO
technical seminars. The Group aims to involve more and more representatives in international
actions, beyond the permanent secondment of 12 executives within WANO and 3 at INPO,
EPRI and IAEA. These participations allow better use and greater interest for an extensive use
of all the supports provided by these organizations in our experience feedback process.
In EDF Energy, WANO Peer Reviews are held at each of its nuclear power stations on a 3
(max 4) year frequency with an interim follow up visit to review progress. The Company
therefore typically receives 2 or 3 peer reviews per year with a similar number of follow up
visits. Corporate peer reviews are also held periodically.
Each peer review has two primary outputs:
A report which identifies areas for improvements (AFIs) which describe gaps between current performance and excellence. These are supported by factual evidence and an analysis of the causes which underlie performance gaps.
Since 2010, a separate report which reviews station progress in addressing WANO Significant Operating Experience Reports (SOERs) recommendations.
During follow up visits, WANO assesses progress made by stations in addressing AFIs
identified during the previous Peer Review.
In conjunction with WANO, INPO and IAEA, EDF Energy also provides support to, and is
supported by, technical support missions, self assessments, operating experience feedback,
benchmarking, workshops and seminars, performance indicators and secondments.
The EDF Group Engineering Division of EDF is fully involved in safety assessments and
improves the capacity of the Group to look for excellence and to study and implement
solutions to the main technical issues, specifically:
in expertise and design of the new generation of reactors, including technical progress
in safety and environment areas (studies on Generation 3 and Generation 4)
in construction of new plants and new projects; e.g. EDF has put in place a dedicated
organization to take the best advantage of consistency between all EPR projects
(Finland with AREVA, France, UK and China), including relationships with safety
authorities concerned by these projects, and also experience gained during
construction and coming tests
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in supporting existing fleets when needed in operation (e.g. to find and implement
solutions when failures occur or to replace main components in the case of life
duration issue) including relationship with safety authorities
in the assessment and review of safety within periodic safety assessments or through
feedback generated by significant events and accidents, including the assessment of
natural risks (e.g. 400 engineers have been involved in safety assessment and
reinforcement studies following the Fukushima accident)
in decommissioning studies (within the licensing process, or during operation)
EPR, our third generation reactor
The EPR, a PWR type, belongs to the third generation. This new reactor is even safer, more
environmentally sound and more powerful than its predecessors. Thanks to its evolutionary
design, it is able to incorporate the operating experience accumulated by French and German
designers and operators over more than 30 years. With a capacity of 1,650 MW, it will
consume 17% less fuel, thanks to the use of more efficient fuel assemblies and greater turbine
efficiency.
Although the likelihood of a severe accident with core melt occurring in existing reactors is
extremely small, it is further reduced by a factor of ten in the EPR. If such an accident were to
occur, a facility especially designed to recover, contain and cool the molten core has been
installed below the reactor vessel. This facility would mitigate the environmental
consequences of such an accident.
Four parallel and physically segregated safeguard systems fulfil a triple function: they prevent
loss of control over the nuclear reaction; they maintain the reactor cooling function in any
circumstances, and in the event of an accident, they control pressure and temperature
increase in the reactor building. That building is more tight and resistant than its predecessor
(double wall and metallic skin).
Similarly, in order to guard against external hazards, a concrete shell covers the most
sensitive parts of the facility: the reactor building, the fuel building, the main control room, two
of the four safeguard buildings and two trains in the pumping house.
The environmental objectives set for the EPR are ambitious, calling for measures to minimize
the impact of plant facilities on the environment. During normal operation, chemical and
radioactive releases (20
) to the environment will be reduced by at least 30% per MWh
generated. Furthermore, the reactor’s higher burn-up rate, and core design will reduce the
quantity of radioactive waste on a like-for-like basis. The EPR will generate about 30% less
(21
) radioactive waste than 1,300 MW reactors.
20
Excluding tritium and carbon 14, which will be released in the same quantities as they are on existing plants
(quantity proportional to energy produced)
21 In volume, which is the dominant criteria for the design of the final storage; the higher power capacity and
higher radioactivity has to be taken into account in the duration of intermediate storage in pools
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2.5 Risk assessment
2.5.1 Policy
The nuclear safety case includes risk assessments of:
Plant based faults, e.g. loss of coolant, loss of power…
Internal hazards e.g. steam release, fire…
External hazards, e.g. climatic conditions, flooding, earthquakes…
There is a fundamental legal requirement for risks to be ALARP (As Low As Reasonably
Practicable). Some countries impose a maximum risk level (e.g. probability of core melting).
The responsibility to conduct thorough and deep risk analysis is fully recognized by the Group
which uses the process as a fundamental tool to continuously reinforce the safety standards in
its nuclear power plants.
2.5.2 System
Managing the risk as an overall process
For many years EDF Group has pursued a policy of managing its operational, financial and
organizational risks. In 2003, the Group decided to implement an overall process for managing
and controlling its risks and reinforcing existing plans, in particular by creating the corporate
Risk Management Division (RMD). The objectives of the management and control policy are
to allow identification and ranking of risks in all domains to gain increasingly firm control over
them, under the responsibility of operational management; that policy allows officers, directors
and the Group’s governance bodies to have a consolidated view, regularly updated, of the
major risks and their level of control. RMD implements an annual program of audits on a large
range of issues, linked to the previous ranking of risks.
That approach is put in place in each division and company of the Group. In EDF SA Nuclear
Generation Division, the approached is applied to almost (22
) all processes and projects. Each
risk is identified and assessed and mitigation actions are undertaken.
Periodic safety assessment in nuclear plants including risk analysis: The nuclear power
stations were constructed to the best contemporary advice, including national and international
standards and guidelines, and each entered service with a single document summarizing its
safety case. The stations are expected to operate for a number of decades, during which
guidelines have and will change. In addition there are numerous changes to plant and
procedures at each station, each of which is separately documented and represents a small
evolution in the safety case.
The entire safety case, including risk assessments of plant based, internal and external
hazards, is therefore reviewed at intervals against current national and international standards
which set industry best practice e.g. IAEA. The review also encompasses operating
experience gained within the company, the global nuclear industry (e.g. following TMI,
Chernobyl and Fukushima) and through global high hazard industry events. The review
process, which is referred to as Periodic Safety Review, is carried out at intervals of
approximately 10 years (23
) under the control of safety authorities. These reviews may identify
22
17 among 22 processes and projects
23 In France and UK
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shortfalls with respect to current guidelines. All reasonably practicable improvements identified
by the review are implemented, to bring the stations within the current guidelines. In the UK,
the review is submitted to Office for Nuclear Regulation (ONR), an agency of the Health and
Safety Executive (HSE) for their consideration and, if appropriate, agreement to any proposed
changes to the safety case. In France, the safety improvement targeted by the NSA is
previously established and is the basis for the NSA to deliver its opinion and the eventual
complementary requirements in order to operate the unit for a further 10 years. That process
allows the oldest plants to be compliant (or quite compliant) with the current guidelines applied
to new reactors.
In USA, risk is addressed both through the regulator (NRC) and each reactor operator. The
NRC’s Reactor Oversight Process (ROP) assesses plant performance continuously through
use of performance indicators and inspections which are based on risk with respect to public
health and safety. Performance indicators include availability of key systems and unplanned
reactor scrams. Inspections include detailed evaluations of the design, maintenance, and
operation of risk significant structures, systems, and components once every 3 years.
Performance indicators that do not meet pre-described criteria and significant findings that
result from inspection activities require a detailed response to the NRC. The NRC’s
assessment of performance is provided to each reactor operator once every 6 months.
In addition to the regulator, each reactor operator assesses risk on a daily basis through use
of risk assessment tools and consideration of industry operating experience. This ensures
that activities are planned and coordinated to minimize unavailability of key equipment. Plant
improvements are also identified (e.g., modifications, procedure changes) and implemented as
appropriate to further reduce risk.
Adaptation to climate change
As a part of its Sustainable Development Policy, an overall climate change adaptation
strategy was adopted by the EDF Group in 2010. The strategy aims to bring together in a
consistent way all the works, actions, studies and research to implement across the whole
Group in order to identify all the activities impacted by climate change and all the means and
processes by which to reinforce our robustness and our resilience to extreme climatic
phenomena. We recognize that we have to adapt our existing industrial facilities and networks
that will have to remain safely operational over several decades, and to design our fleet and
new installations now to cope with the coming effects of climate change that will be seen
during their life. That strategy will include all studies and modifications done or to be done on
nuclear facilities regarding main sensitivities, such as:
robustness of our networks, following damage caused by storms since 1999
robustness of our plants during heat waves: after hot summers in 2003 and 2006, a
specific program of modifications called “Hot Conditions” was launched on all the
French plants, which a short-term program already implemented, and a medium-long
term program to be integrated in periodic safety reviews
robustness against flooding: after the flooding of Blayais nuclear plant, in 1999, a
safety review was launched for all nuclear facilities, taking into account increased
water level and new combinations of effects, and some protections have been
reinforced on French sites (both coastal and those on rivers); that program has
anticipated the post-Fukushima review and will merge with it
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management of water resource: EDF laboratories have been working closely with
climate and meteorology experts to better forecast the availability of water resource
for our hydro plants and thermal stations (including nuclear ones). Special
organizations are already in place to manage water and to better coordinate all the
water users during dry periods (in order to prioritize support of flow or reduce power
generation during critical periods). Studies are on-going to find less sensitive cooling
systems and to find temperature regulations which would be better adapted to the
coming conditions.
Lessons learned from the Fukushima accident
Although all the details of the accident are not yet fully known, it is clear that it revealed
several important failures in the design of the Fukushima station and in the management of
the situation caused by the tsunami:
The magnitude of the earthquake was greater than the design assumptions. While the
reactors appear to have suffered little damage from the seismic shocks (scram
shutdowns and start-up of emergency diesel generators functioned as planned), the
earthquake caused a total failure of external power supply
The magnitude of the tsunami was also greater than the design assumption. It caused
the destruction of heat sink and the total loss of back-up power systems
The operating team met great difficulty managing the reactor containment dry well in
a situation of severe accident; that led to major discharges of radioactivity and
hydrogen explosions
Ultimate external resources in sufficient quantity were missing and prevented the
operating team from quickly recovering the situation.
The companies of EDF Group have mobilized their engineers in France, in the UK, in the USA
and in China, in close relation with the respective safety authorities and under their control,
and in relation with all the international organizations involved in experience feedback (INPO,
NEI, IAEA). According to the processes put in place by the safety authorities, they have
provided reports analyzing the capacity of their plants to resist comparable situations
(earthquake and/or flooding, more likely than tsunami, except in China) and to face the loss of
cooling and power in a severe situation.
In France the NSA asked these reports for mid September, in the framework of the European
“stress tests”. Reports have been provided on time, thanks to the involvement of 300
engineers during four months; these reports are public (24
). They present a reassessment of
the existing resources and responses, and a further analysis, beyond the referential, of the
efficiency of protections (e.g. existing margins) and of the capacity to face extremes situations.
Following this work, EDF confirms the presently good level of safety for all nuclear facilities,
mainly thanks to the initial design and to the periodic safety assessments which have led to
improve the robustness of the plants and to integrate the experience learned from previous
accidents and incidents. In order to improve even more the good level of safety, EDF has
presented proposals for the implementation of complementary defences: reinforcement of
protections against hazards (earthquake and flooding), equipment (additional electricity source
and water reserves), and additional measures in case of core meltdown (reinforcement of
24
Available on the web site of the French NSA (www.asn.gouv.fr)
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existing filters). EDF also intend to reinforce the crisis management by putting in place a
Nuclear Rapid Response Force (specialists able to intervene within 24h in support of local
teams, with back-up equipment, in particular in the case of a multi-unit emergency situation).
These reports are currently analyzed by the NSA and a response is expected at beginning of
2012.
In the UK, EDF Energy immediately conducted a safety review using formal mandatory
evaluation process, considering within and beyond design basis situations, and reviewing
physical equipment, systems and processes. The initial conclusion was that all EDF Energy
plants were safe to continue to operate. EDF Energy, as EDF SA, based its review on the
scope and methods of the “stress tests” demanded by the European Commission”. It
submitted eight reports, one for each station, on 31th October, after having worked closely
with other British operators and with EDF engineering division, in particular for the case of
Sizewell, the only PWR in the UK, and for Gravelines and Dungeness B stations, the closest
sites on both sides of the Channel, where a consistent approach has been used for
earthquake and flooding. Several proposals have been presented to reinforce the resilience of
the plants and minimize radioactive releases in case of severe accident, and also to provide
back-up equipment. ONR will produce final national report mid 2012. The implementation of
the response phase will start by Q1 2012.
In the USA, the NRC, after three months of work within a task force, assessing the safety
robustness of the US plants with regard to natural hazards and severe accident management,
concluded that they were safe but emitted 34 recommendations to still reinforce their safety.
On its side, the nuclear industry has promptly verified the systems, equipment and procedures
protecting US plants against natural hazards and mitigating potential damages. CENG has
taken a leading role in the United States nuclear energy industry to ensure that lessons
learned from the Japanese events result in safety enhancements at the U.S. plants. A
Fukushima Response Steering Committee was formed comprised of senior U.S. electric utility
executives, reactor vendors and their affiliated Owners Group, Nuclear Energy Institute (NEI),
Institute of Nuclear Power Operations (INPO), and the Electric Power Research Institute
(EPRI). That Committee has drawn consistent conclusions; some items can be addressed in
the short-term, but industry asked for flexibility and performance-based approach, similar to
the one following September 11th, 2001 (orders are in progress for electrical and water
supplies portable equipment). Works are pursued with EDF engineering to assess the
robustness of safety analysis and additional measures.
In China, the government announced in mid-March a series of decisions for the self-
assessment of nuclear power plants as well as national safety inspections of plants in
operation and under construction, to be completed in August. Moreover it has deferred
approvals on any new nuclear project, waiting for a “Nuclear Safety Plan” in early 2012. On
their side CGNPC and EDF, working together, identified possible improvements to implement
on their stations as: seismic and weather forecast and warning systems, reinforcement of the
capacity of existing hydrogen absorbers and filters, power sources and mobile pumps, drills
and training, under a multi-unit emergency plan. In the specific case of Taïshan, the
consistency with Flamanville 3 has been verified and has confirmed the interest of mobile
emergency resources (pumps, EDG, water storage) and the improvement of safety functions.
18 design modifications or topics have been submitted to the NNSA.
Emergency preparedness: inside the global framework of risk management previously
described, RMD is in particular in charge of emergency preparedness and crisis management
organization at Group level, each division and nuclear company in the Group remaining
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responsible for its own crisis organization. Exercises are organized regularly (in relation or not
with safety authorities) and give the opportunity to benchmark between the companies.
In France, in the event of an accident, an emergency organization is in place to limit impacts
on the environment and on people. To ensure the safety of the installation and the protection
of people, the system is based on two closely coordinated plans, designed for both local and
national use. These are the Internal Emergency Plan (Plan d’Urgence Interne, or “PUI”),
prepared by EDF and the Special Intervention Plan (Plan Particulier d’Intervention, or “PPI”),
prepared by French prefectures in collaboration with the French state and EDF. In order to
provide greater effectiveness and thus improved protection of populations these plans account
for the risk of malicious acts. The relevance of the system for warning, informing and
protecting people is regularly assessed through accident simulation exercises, which make it
possible not only to ensure the correct operation of the crisis plan, but also to improve upon it,
in particular, by clarifying roles and validating all of the required physical and human resources
(decision making process, centralized technical support, communication capacity, anticipation
capacity,..). Each year, approximately 100 exercises are organized for the entire French
nuclear fleet, i.e., approximately one every three days. Approximately 10 exercises are on a
national level, under the management of the NSA and involve EDF and the public authorities,
in particular the prefectures. As a lesson learned after the first exercises and in order to better
protect children against exposure to radioactive iodine in case of accident, stable iodine
tablets have been pre-distributed in a perimeter of approximately 10 kilometres. As a
consequence of the Fukushima accident, the centralized support will be reinforced in 2012 by
technical equipments and by qualified staff. It will be sent to the station where an emergency
situation is supposed to have occurred.
In the US, America’s nuclear energy facilities are designed and built to safely withstand a wide
variety of natural and other severe events and staffed by highly trained, federally licensed
operators with a five-decade history of safe operations in the United States. The operators
who staff these facilities are capable of taking the actions necessary to mitigate and control
adverse events. An emergency plan provides multiple layers of protection by specifying
additional measures that may be taken in the event of a severe accident.
An effective emergency response is the product of mutually supportive planning and
preparedness among several parties: companies that operate the plants; local, state, and
federal agencies; and private and non-profit groups that provide emergency services.
U.S. federal law required nuclear operating companies to create an on-site emergency
response plan for their nuclear energy facilities and to ensure that emergency preparedness
plans are in place to protect the public. The U.S. Nuclear Regulatory Commission approves
on-site plans, while approval of off-site plans is coordinated between the NRC and the Federal
Emergency Management Agency (FEMA). These plans must be approved for a plant to obtain
and retain an operating license from the NRC.
Emergency plans for nuclear energy facilities continually evolve. This includes incorporating
lessons learned from the terrorist attacks on September 11, 2011. The plans can be
implemented during a wide range of severe natural events or security-related events.
A 10-mile emergency planning zone (EPZ) to protect communities near the facility from
radiation exposure in the event of an accident.
A 50-mile zone within which food products, livestock and water would be monitored to protect
the public from radiological exposure through consumption of contaminated foodstuffs.
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Within the 10-mile EPZ, the main, immediate protective actions for the public include
instructions for sheltering in place or evacuation. The slow pace at which an event may unfold
– over several hours or days – provides time for orderly sheltering or evacuation, if necessary.
Supplemental protective actions within this zone might include the distribution of stable iodine
tablets to protect the thyroid gland from radioactive iodine. Within the 50-mile zone, the federal
and state governments may monitor and test all food and water supplies that potentially could
become contaminated and remove from public consumption any found to be unsafe.
While both zones were established for planning and preparedness purposes, state
government response directors have the discretion to designate specific protective actions
beyond these zones, if needed.
The NRC conducts inspections of the CENG emergency plans annually. CENG conducts
continuing training of its emergency response organization and conducts drills and exercises
to test abilities at least four times per year at each site. Every two years at each site, the
NRC, FEMA, and the states participate in integrated exercises to evaluate coordination
between CENG and government agencies during an emergency.
At nuclear fleet level of EDF Energy, Emergency Plans are exercised regularly. Within Nuclear Generation, each shift is exercised at least once per year, and one in-depth exercise is required to demonstrate to ONR the adequacy of the on-site emergency arrangements at each power station. These 'Level 1' exercises are witnessed by the ONR and focus on the actions of the operator. Emergency services are invited to participate to provide a mutual learning opportunity and to add realism to the on-site actions. Level 2 and 3 exercises are aimed at the operation and testing of the off-site emergency plans. Level 2 exercises primarily test the local off-site plan for each station every three years. These exercises enable those agencies with a responsibility in the response to exercise and review their arrangements. Annually one of the national program of Level 2 exercises is selected for the purposes of testing the national level response plan. In addition to the Level 2 activities, this involves the setting up of the Nuclear Emergency Briefing Room in Whitehall, or the Scottish Government Emergency Room. Regulatory exercises are also required to satisfy the nuclear security regulations and the transport of radioactive material. In addition to the regulatory exercises, sites have tested various aspects of the emergency plans during approximately 100 shift exercise and training drills. The lessons from all exercises have been shared across the fleet and used in revising emergency plans and future exercise program.
2.6 Radiation exposure (to workers and the general public)
2.6.1 Overview on the regulatory context
In Europe the current legislation (Euratom Directives 96/29) is inspired by the publications of
ICRP (International Commission on Radiological Protection) which establish the scientific
fundamentals of radiation protection. All the national regulations (including the French and
British ones) based on the European regulation integrate the three fundamental principles of
Radiation Protection), which are:
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Justification principle: no practice implying an exposure to ionizing radiation shall be
adopted unless its introduction produces a positive net benefit on population as a whole
(i.e. advantages deriving from the practice shall be greater than disadvantages).
Optimization principle: using the words of ICRP, ‟all the exposures shall be kept As Low
As Reasonably Achievable (ALARA), economic and social factors being taken into
account”. It means that all reasonably practicable measures to reduce radiation exposure
shall be taken.
Individual dose limitation principle: the dose to the individuals “shall not exceed the limits
recommended for the appropriate circumstances”. These limits are chosen and proposed
by ICRP for workers and individuals of population to dose levels corresponding to a
negligible risk level. French and British legislations have fixed the same limits: 1mSv per
year for public and 20 mSv per year25
for the workers.
In the United States of America Title 10 of the Code of Federal Regulations part 20
establishes the standards for protection against ionizing radiation from activities conducted
under licenses issued by the Nuclear Regulatory Commission. It is the purpose of this part to
control the receipt, possession, use, transfer, and disposal of licensed material by any
licensee in such a manner that the total dose to an individual (including doses resulting from
licensed and unlicensed radioactive material and from radiation sources other than
background radiation) does not exceed the standards for protection against radiation
prescribed in the regulations in this part. However, nothing in this part shall be construed as
limiting actions that may be necessary to protect health and safety.
The licensee shall control the occupational dose to individual adults to the following dose
limits:
(1) An annual limit, which is the more limiting of--
o (i) The total effective dose equivalent being equal to 5 rems (50 mSv); or
o (ii) The sum of the deep-dose equivalent and the committed dose equivalent
to any individual organ or tissue other than the lens of the eye being equal to
50 rems (500 mSv).
(2) The annual limits to the lens of the eye, to the skin of the whole body, and to the
skin of the extremities, which are:
o (i) A lens dose equivalent of 15 rems (150 mSv), and
o (ii) A shallow-dose equivalent of 50 rem (500 mSv) to the skin of the whole
body or to the skin of any extremity.
The licensee shall use, to the extent practical, procedures and engineering controls based
upon sound radiation protection principles to achieve occupational doses and doses to
members of the public that are As Low As Reasonably Achievable (ALARA). ALARA means
making every reasonable effort to maintain exposures to radiation as far below the dose limits
in this part as is practical consistent with the purpose for which the licensed activity is
undertaken, taking into account the state of technology, the economics of improvements in
relation to state of technology, the economics of improvements in relation to benefits to the
public health and safety, and other societal and socioeconomic considerations, and in relation
to utilization of nuclear energy and licensed materials in the public interest.
25
More precisely in French regulation: “per period of 12 consecutive months”
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Each licensee shall conduct operations so that -
(1) The total effective dose equivalent to individual members of the public from the
licensed operation does not exceed 0.1 rem (1 mSv) in a year, and
(2) The dose in any unrestricted area from external sources does not exceed 0.002
rem (0.02 mSv) in any one hour.
2.6.2 Policy
Despite differences between national regulations, the common approach of the nuclear
companies of EDF Group is to ensure as a minimum, compliance with all applicable
regulations, to continuously improve our practices well beyond the requirements, to
emulate nuclear industry best practice, and to work together with our industrial
partners to a common fleet standard which takes into account technical differences
among our plants. We strive to ensure that any exposure to ionizing radiation is kept as low
as reasonably practicable (ALARP) beyond the requirements, to reduce individual and
collective radiation doses and prevent any worker, with any distinction between company or
subcontractor staff, or any person in the vicinity exceeding a statutory radiation dose limit.
Moreover, regarding more specifically the protection of the environment (including the
minimization of the effects of the operation of the plant on humans), EDF Group has adopted
in 2009 an overall Sustainable Development Policy which contains a target of “minimizing
by continuous improvement the impact of our activities on the environment” (see § 3.1).
2.6.3 Systems
To reach their goal consisting in continuously reinforcing the radiation protection of
workers, the means and processes used by the companies include:
Efficient operation of the facility and all the systems which contribute to the lowest
radiation level inside the premises of the plant (e.g. decontamination phase at the
beginning of an outage in PWR plants, monitoring of the cleanliness of controlled
areas, implementation of protective shields,..)
Specific work preparation when there is a planned exposition to radiation, with risk
analysis, support and control of specialized staff
Adequate radiological protection monitoring instrumentation and personal equipment
provided to staff working inside controlled areas
Wearing of personal dosimeters (eventually doubled by radiological films compliant
with local regulations)
Adequate procedures in case of alarm, concerning both the workers, the field
supervisors, and the operating shift
Adequate mandatory training and good practice promotion for all workers (e.g. on
simulators and specific workshops), whether direct employee or contractor.
Some most recent actions completed or ongoing action-plans, aiming to correct weaknesses
and still improve the performances, include:
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EDF has had in place, for some years, a specific program to prevent incident in the
case of hazardous situation (red or orange zone entrance, radiographic tests,..)
EDF, under the “Charte de progrès” signed with subcontractors and professional
organizations, implements actions in order to reduce the number of workers exposed
to more than 10 mSv per year (16 mSv per year a few years ago) and to guarantee
the same quality of medical monitoring. More generally, under that common
agreement, EDF and its industrial partners gave the same priority and the same
commitment to the improvement of radiation protection and exposure prevention
EDF have been implemented for several years a specific program to improve
radiological cleanliness: reinforced rules during works, complementary investments in
more efficient and numerous contamination detectors, benchmarking and rating of the
sites
EDF Engineering Division implements programmes for future reactors to determine
the best technical choices in favour of the reduction of doses (chemical conditions of
reactor coolant, presence of cobalt in steam generator tubes alloy and in valve’s
stellite,..)
EDF Energy launched an instrumentation replacement program, for installed and
portable radiation and contamination instrumentation; the new one is more sensitive
and aligned to international standards
EDF Energy is also currently implementing a program to align radiographic testing
with best practices, together with its contract radiography companies
CENG has had success with reducing source term, improving radiation worker
behaviours and improving its ability to direct work remotely. The programme was
launched to reduce the level of collective dose and has resulted in individual exposure
being much below the mandatory limits, in accordance with its internal policy: no
worker is exposed now to more than 20 mSv (see details in §5.2).
Regarding the minimization of the doses to the public, the companies of the Group use a
wide array of means and processes, from the design itself to the optimization and control of
effluents generation (and also their treatment) and the monitoring of the environment of the
plant (including radio ecological study):
At the design stage, the fission products contained in the core are surrounded by
three barriers: the fuel cladding, the reactor coolant system and the containment. The
tightness of these barriers is strictly controlled during operation; the Technical
Specifications for Operation define the acceptable limits for certain parameters used
to monitor the tightness of these barriers and also stipulate the action to be taken if
these limits are reached. The tightness of the barriers is a fundamental parameter
included in safety assessments carried out as described in § 2.4.3.
Moreover several fundamental checks are also implemented within maintenance
programs such as: non-destructive checks of each re-used fuel assembly, resistance
and tightness check of reactor coolant system, periodic test of robustness and
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tightness of the containment building (in addition of permanent monitoring during
operation) and of all the isolation devices
Because of the normal activation of water and gas used for reactor cooling, several
types of equipment (26
) are in place to treat continuously that coolant and all the liquid
or gaseous effluents collected in the station, with the goal to re-use them as much as
possible and to minimize the residual radioactivity of these effluents before being
released in the environment. The efficient running of these equipments is strictly
controlled.
All the release lines (ventilation shafts, drainage pipes of effluent reservoirs) are
equipped with measurement devices; compliance with limits imposed by regulations
and by OTS is strictly controlled. Regardless of their origin (Reactor Building, Fuel
Building, Nuclear Auxiliary Building, laundry, Turbine hall, etc.), releases and
discharges that are liable to be radiologicaly contaminated are always stored, and
tested before and during release.
The residual radioactivity released is closely monitored through frequent and accurate
analyses performed on all environmental compartments (terrestrial: grass, milk,
agricultural production, or soils; Aquatic: water (surface and sea), groundwater,
sediment flora and fauna samples, and; Air: atmospheric dust, ambient gamma dose
rate, rainwater) collected from around the stations. Moreover, some stations equipped
with several types of measurement devices and automatic transmissions are installed
in the vicinity of the stations. All the results of that overall monitoring are displayed to
regulation authorities, and to the close community.
All the companies of the Group aims to reach the best environmental performance in
the industry by reducing the radioactivity released as low as reasonably achievable;
they use for that the international experience they found within the Group and through
contact with international organizations. The improvements are found in a wide range
of domains: operational mode, chemistry, maintenance, efficiency of treatments.
Impressive improvements have been made since the first years of operations (by
more than ten in general) and the impact of the operation is currently very well below
administrative limits and is merging with natural variations of the ambient radioactivity
(see § 4). The good results now achieved (ie : Levels of radioactive releases divided
by 100 in France (excluding 3H and
14C) since 1984) testify to the efforts made by EDF
(more rigorous management, reduction at source, improvement of collection systems)
over more than 20 years to optimise discharges and minimise their impact, both on
the environment and on the public. These efforts are obviously being continued to
ensure that the NPPs maintain, or further improve, their performance in this area, as
limiting these releases protects the environment.
26
Filters, storage tanks for natural decreasing of gases radioactivity, evaporators, demineralisators,..
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2.7 Security
2.7.1 Policy
EDF Group recognizes the value of the people, physical assets, nuclear fuel, information and
systems that contribute to its business and the need to protect them. Security is about
protecting our physical and intellectual property, our staff and the public from any potential or
actual event which could adversely affect the confidentiality, integrity or availability of our
infrastructure and information as well as the personal security and safety of staff and the
public. Regarding the risk of stealing or misuse of nuclear fuel, the companies respect the
requirements expressed by international organizations (IAEA, EURATOM) complemented by
national regulations and requirements. The companies aim, when it is achievable, to enhance
their protection, taking into account the evolution of threats on the one hand and the
contribution of public security forces on the other hand.
2.7.2 Systems
Based on a large panel of threats, from malicious behaviour to cyber criminality and terrorism,
there is a series of safety and security measures in place at each of our power stations in
addition to the inherent physical security provided by the very robust design of the nuclear
reactors. According to local laws and requirements, access to nuclear power stations is strictly
controlled and armed guards or forces are deployed at all nuclear sites to complement existing
security measures.
Confidentiality on the details of these measures is a key point of its efficiency; the reader shall
understand that it is not possible to describe more. In each country, the efficiency of the
protection measures is strictly controlled by dedicated administration or by the safety authority,
and by international inspectors (IAEA, EURATOM); these measures are periodically reviewed
and eventually reinforced, depending on the threat and on the initial robustness of the
protection (e.g. after 2001 September 11th)
3 Waste
3.1 Overview
The real or potential radiological impact of the operation of a nuclear plant on its environment
is of several forms and origins:
Highly radioactive material being produced inside the fuel assemblies of the core of
the reactor, the first source of radioactive waste is the fuel itself; certain radioactive
materials that are produced are of very high activity and very long life. That is the
reason why the management of that fuel is of very high importance and gives rise to
two issues: the choice of reprocessing (27
), or not, that fuel and the choice of storage
(nature and organization, a decision made by nations) of the solid waste generated
(the fuel assemblies themselves or the ultimate waste generated by the retreatment)
27
Industrial process for separation of different categories of products: uranium (95%) and plutonium (1%) for
recycling, and ultimate waste (4%) for packaging in a sturdy matrix with as low volume and radiotoxicity as
possible
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Solid waste are also generated by the equipment that treats and filters contaminated
waters and air (filters, resins, mud) or during maintenance (plastic, rubble and
damaged protective clothing); these wastes are processed and encapsulated in
sealed packages generally on the plant’s site, to prevent any uncontrolled release of
radioactivity into the environment. Levels of radioactivity and life duration are much
lower than in the first category
When treated in a proper and efficient manner, liquid and aerial effluents contain very
low quantities of radioactivity and may be released into the environment under strict
regulation and control (see § 2.6).
In France, the public strategy is to reprocess spent fuel coming from nuclear facilities (mainly
in AREVA NC plant in La Hague (Normandy)) and to re-use fissile material extracted during
that process. The aim is “to reduce the quantity and the harmfulness of radioactive waste,
while recycling the valuable matters as uranium and plutonium”. The method for the storage of
nuclear waste depends on its degree of radioactivity and its nuclear activity period. In addition
to certain temporary storage on EDF sites, very low-level waste produced by EDF (for
example, concrete or metal waste left over after decommissioning a nuclear power plant) is
stored on an ANDRA site opened in 2003 (the “CSTFA”). Short life, low-or intermediate-level
waste that is produced by EDF’s operations is stored above ground at ANDRA’s Aube storage
centre (the “CFMA”). Long life, high-level waste produced from the reprocessing of spent fuel
is vitrified and stored temporarily and safely at the AREVA NC centre in The Hague pending
the adoption of a long-term management solution (public decision expected around 2014 for a
storage centre commissioned around 2025). Long life, intermediate-level waste (for example,
from shells, nozzles, sheeting, etc.) is either cemented or compacted and confined in stainless
steel containers. They are currently in intermediate, temporary storage pending a final
decision concerning long-term management.
In France, as an operator and producer of waste, EDF SA is legally responsible for spent fuel
from the moment it leaves the power plant, during its processing operations and during its
long-term management, and it assumes this responsibility in accordance with guidelines set
by public authorities and under their control. Each year, EDF makes provisions for the back-
end of the nuclear fuel cycle in France which covers the management of spent fuel and the
long-term management of radioactive waste. To calculate the cost of future management of
long-life, intermediate and high-level waste from the processing of spent fuel, EDF assumed
deep geological storage of waste, pursuant to the law of June 28, 2006 which established the
storage of waste in deep geological layers as a reference solution. For long-life, low-level
waste, from the decommissioning of shut-down graphite-gas power plants, provisions are
established by EDF from the schedules of production of these wastes and cost assumptions
relating to the terms of storage defined by ANDRA. The cost of removing and storing short-life
intermediate and low-level waste and very low-level waste is determined on the basis of
contracts entered into with ANDRA and the various carriers for the operation of existing
Storage Centres. The costs of disposal and storage of waste from the decommissioning of
power plants are provisioned, with the charges relating to operating waste being recognized in
annual expenses. The 2006 law on nuclear waste applies to the Government to draw up every
3 years a National Plan on Management of Radioactive Materials and Waste (PNGMDR in
French); under this Plan, EDF, as well as the other producers of radioactive waste, disclose all
the data available on the waste it stores itself or it has sent to ANDRA; the complete plan and
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a synthesis are published by the NSA on its web site (28
): in this way, information on quantities
and ways of management of the different categories of waste are available for the public.
In the UK, the public strategy is to give the role of spent fuel and nuclear waste management
to a public agency, the Nuclear Decommissioning Authority. EDF Energy Nuclear Generation,
as owner operator and licensee, remains responsible for ensuring the safe decommissioning
of all its power station sites. The company policy and strategy objective of decommissioning is
to return the power station sites to a state suitable for unrestricted alternative use. The funding
for EDF Energy Nuclear Generation power station decommissioning and waste management
is coming from the Nuclear Liabilities Fund (NLF) and EDF Energy /EDF Group Accounts. The
decommissioning strategy, policy and plans are subject to regular review. At minimum, a 5
yearly review of the plans is undertaken. It should be noted that, no decommissioning has yet
been carried out for any of EDF Energy Nuclear Generation power station sites. Power station
decommissioning, following a planned end of generation, remains some years off. However,
detailed baseline decommissioning plans for each of EDF Energy power stations are in place.
These plans have been developed over a number of years / iterations and have been formally
approved by British regulators and NDA.
In the UK, nuclear waste is classified under three headings: Low Level Waste (LLW),
Intermediate Level Waste (ILW) and High Level Waste (HLW). LLW are either sent for
treatment (e.g. volume reduction by supercompaction) or disposed of at the Low Level Waste
Repository (LLWR) in Cumbria, and a small amount of combustible waste is sent for
incineration at Hythe. ILW is stored for the medium term in safe, purpose built facilities at EDF
Energy’s stations while a longer term National solution is established. Under historic
contractual arrangements spent fuel from the Advanced Gas-cooled Reactors (AGRs) is
transported to Sellafield for reprocessing or storage, and spent fuel from Pressurised Water
Reactor (PWR) remains on site. HLW comes from the reprocessing of AGR spent fuel at
Sellafield. HLW is converted into glass blocks for safe, long term storage at Sellafield, At
Sizewell B PWR station, the spent fuel is stored on site and EDF Energy is planning to build a
further storage facility to allow the station to continue to safely store all of the spent fuel that
will be generated over Sizewell B’s life. The approved strategy for Sizewell B fuel
management consists of an ISFSI Dry Store concept to store spent PWR fuel in HOLTEC
metal flasks held on a concrete pad within a hardened building. To accommodate the 2280
assemblies that make up the current lifetime arising, 80 flasks are required.
In the USA, in accordance with the Nuclear Waste Policy Act of 1982 (NWPA), CENG is a
party to the contracts entered into with the United States Department of Energy (DOE). As
such, CENG has since November 2009 paid the contributions stipulated by the NWPA to fund
the cost of construction by the DOE of a federal storage for final disposal of spent fuel (CEG
having paid these contributions until November 2009). Since the DOE stated that it could not
take possession of spent fuel before 2020 (instead of 1998 as originally called for in the
contracts), CEG and later CENG, has been forced to undertake additional actions and incur
costs to provide on-site fuel storage, allowing the operation of its plants until the availability of
a federal storage facility. CENG has also made provisions for its long-term nuclear waste
management commitments.
28
http://www.french-nuclear-safety.fr/index.php/English-version/References/National-plan-on-management-of-
radioactive-materials-and-waste-PNGMDR
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3.2 Policy
Regarding radioactive operational waste, the environmental policy of EDF Group is to
reduce the generation of waste to a practicable minimum and to maintain radiation
doses to the workforce and to the general public from radioactive waste management
operations, including transport and disposal, within legal limits and As Low As
Reasonably Achievable. The management of waste is focused on reducing, re-using, and
segregating waste for recycling in priority (in the framework of possibilities given by the
regulators). Moreover EDF Group has the ambition to contribute to the emergence of an
overall nuclear waste management solution in a long term vision that is safe and
socially acceptable.
That policy, regarding radioactive waste, is consistent with the Sustainable Development
Policy adopted in March 2009 by EDF Group. The Group is committed to taking action to limit
the impacts of its facilities and all its activities on human health and on the environment. EDF
Group will manage and monitor its impact using an environmental management system
certified to ISO14001. This includes giving priority to safety in all hazardous activities,
compliance with existing regulations, pollution prevention and research to support our
commitment of continuous improvement of our environmental performance. The
Environmental Management System as a whole is certified to ISO 14001 (EDF’s EMS is the
largest in the world). In order to facilitate and to monitor the implementation of this policy in all
the companies of the Group, EDF has put in place a Sustainable Development Committee
which reports to the General Secretary of the Group; it is the supervisory board for
environmental issues.
3.3 Systems for radioactive waste
All nuclear companies of EDF Group share the same principles for waste management
namely:
Minimizing operation and maintenance waste arising and use of the waste hierarchy:
“avoid, reduce, re-use, recycle, treat, dispose” while taking account the limitation or
ban prescribed by the regulator (re-use and recycling are in general possible within
the nuclear industry, while recycling outside the industry is limited, even banned in
some cases, in France)
Segregation and streaming of waste;
Processing by efficient use of existing treatment techniques;
Storage, packaging and transport requirements;
Waste radioactivity measurement and/or assessment and accountability procedures.
EDF Group’s main objective is to maintain radiation doses to the workforce and to the general
public from radioactive waste management operations, including disposal, within legal limits
and As Low As Reasonably Achievable (see § 2.6). Under this objective and in compliance
with their certified Environmental Management Systems, EDF Group companies have put in
place and regularly improve management processes such as: optimization of management
and of treatment equipment, maintenance and improvement (e.g. through training) of
practices and behaviours, research for excellence by benchmarking with other operators and
collaboration with international organizations and with providers of services (e.g. for treatment
or for recycling).
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The safety of radioactive waste consignments being dispatched to specialized processing
facilities or storage centres relies on the quality of waste packages (concrete, steel or lead
casks), which are designed for specific types of waste and take into account varied hazards
during transportation. Waste shipments are governed by national and international legislation,
the intent of which is to protect the public and the environment from all types of risks. No
shipment may leave a plant or be accepted at its destination prior to the submission of a
comprehensive inspection document.
Significant actions in the past years include:
In EDF SA, the average of radioactive liquid releases is lower than 1% of the required limit (29
)
and has been halved in the last ten years, while the average number of solid LLW packages
didn’t increase; this result has been achieved with actions focused on “reduction to the
source”. EDF had previously (since 1985) cut down by a factor 3 the volume of short-lived
waste produced. Thanks to its reprocessing centre, CENTRACO, EDF cuts down by a factor
more than 10 the volume of metallic waste.
In EDF Energy, a new waste processing route, which enables the decontamination of
radioactively contaminated metal, has been implemented. This substantially reduces the
volume of waste being sent for final disposal at the UK LLWR in Cumbria by up to 95%. The
decontaminated metal is clean enough to be recycled and sold for general use (30
). This route
has been utilized by three of EDF Energy Nuclear Generation’s power stations and is being
rolled out across the remainder of the fleet.
EDF Energy Nuclear Generation’s Advanced Gas Cooled Reactors (AGR) are cooled by
Carbon Dioxide (CO2) which must be maintained within set moisture concentration
parameters in order to comply with the safety case. Moisture control is performed by drying
towers which require periodic desiccant replacements. The options for managing spent
desiccant were reviewed in 2009. This review, which was supported by laboratory scale and
full-scale trials, identified a new method for processing and disposal that reduced the final
disposal volume by approximately 50%. A further 20% reduction is expected.
In the USA, there have been several initiatives over many years to minimize the volume of
solid radioactive waste generated at US Nuclear sites through planning, training and
communication. After generation, CENG segregate waste (resin, filters, DAW, and metal) and
send it to a licensed waste processor where the lowest cost alternative
(compaction/incineration/de-contamination) is used to minimize the volume. The waste is then
sent to a licensed waste burial facility or, as is often the case for metal waste, released for
use. The exception to this is any waste that is Greater than Class “C” and therefore must be
stored as it is not acceptable for burial.
CENG minimizes liquid waste releases by limiting water usage, processing any liquid
radioactive waste, storing for decay of radioactivity when needed, and finally released, if
needed, in accordance with USNRC Federal Regulation 10 CFR part 20 not to exceed public
dose limits. CENG site liquid releases have not exceeded one tenth of the federal limits.
Radioactive waste release reports are generated annually by CENG sites. The reports are
prepared using site release, and shipping data in accordance with USNRC Regulatory
29
Except for tritium and C14 which are linked to the energy produced and can’t be easily separated and treated
30 This process is not yet authorized in France
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Guidance 1.21. Releases and waste shipments are carefully accounted for and reported to
either the NRC or to the state, as required by existing licenses and permits. Releases, spills,
or other environmental events are reported promptly to the appropriate agencies using well-
defined reporting standards. All reports are available for public review.
3.4 Spent fuel
3.4.1 Policy
Our overall commitment is to play a leading role in the drive for continuous
improvement in spent fuel management across the worldwide industry. That
improvement deals with several issues, on existing fleet and on new reactors:
The fuel behaviour during normal operation and in case of accident with the aim
of minimizing radiological exposure
The safe management of spent fuel
The optimisation of the fuel cycle with the aim to minimize the quantity of fuel
used per unit of power generated
The reprocessing (when possible within the regulatory and industrial context)
with the aim to reduce the consumption of natural resources and to better
manage the long-life waste.
We work with governments and NGO‟s and others to complete and to demonstrate a
long term radioactive waste solution for the nuclear industry.
3.4.2 Systems
Spent fuel management:
Because fuel assemblies contain the highest quantity of radioactive products, we put a primary
focus in delivering safe operation by a safe management of spent fuel.
Spent fuel is handled under carefully controlled conditions and the process is managed and
operated by suitably qualified and experienced personnel (trained on handling machines with
model of assembly or on simulators). The spent fuel management on station includes
handling, management of spent fuel pools and specific tools, temporary storage, containment,
loading for transport and control, and finally dispatch off-site. All of these processes are
carried out under controlled procedures to ensure safety and compliance at all times and
under continuous improvement which is present in all companies’ activities including Spent
Fuel Management.
A process for loading, cleaning and monitoring the casks, to verify that they are compliant on a
safety and radiological protection point of view, is followed as the fuel enters the public
domain.
Fuel-cycle optimization and fuel behaviour:
We work closely with fuel designers and suppliers on these two related aspects, both by
searching for, then experimenting with, new alloys for the cladding which are more corrosion-
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resistant and more resilient in case of accident, and to extend the duration of the life-cycle of
an assembly, by increasing in a safe manner their burn-up. These improvements need time
and arrangements with suppliers, re-processors and safety authorities. They may have some
consequences on re-processing and storage, so an optimization has to be found.
Long term management and reprocessing:
In France, EDF made the choice of spent-fuel re-processing and materials re-cycling, with the
target of reducing the volume and the harmfulness of the final part of radioactive waste. We
reprocess each year about 1,000 tons of spent fuel and the recycled part of our fresh fuel we
reintroduce in reactors represent 17% of the energy we produce. To avoid Plutonium
accumulation, the reprocessing flow rate (1,000 tons/year) is consistent with the recycling
capacity (number of power plants authorized to receive MOX fuel). The volume of Long Life-
High Level waste generated in the reprocessing plant of La Hague each year is of 150 cubic-
meters. The Long Life-Medium Level waste generated represent 200 cubic-meters per year.
In the U.S. spent fuel management is dictated by a law titled the Nuclear Waste Policy Act of
1982 (“NWPA”). The NWPA -- and the regulations implementing the law -- call for the U.S.
government to eventually build a federal repository for the fuel and to take title to the fuel after
the facility is licensed and placed into service. The federal repository project is to be funded
by the users of the fuel at a rate calculated per electrical megawatts generated. The fund has
grown since 1983 and this far a repository has not been licensed and built. The standard
contracts entered into between the U.S. nuclear generator licensees described how the project
was to be funded and when the government was first scheduled to accept the spent fuel –
which was 1998. The repository is not licensed and completed: the subject of how the spent
fuel will be taken and processed by the government is still under debate.
Since the U.S. government did not achieve its 1998 milestone, U.S. nuclear licensees, such as
the five CENG reactors, filed a law suit for partial breach of the standard contracts. Since
then, CENG has entered into settlement negotiations with the government to recover its
additional costs incurred by having to construct and operate on-site dry cask storage facilities
called: Independent Spent Fuel Storage Installations (“ISFSIs”). The ISFSIs are safe, long-
term and robust storage options that require no powered cooling support mechanism.
In the UK the nature of EDF Energy Nuclear Generation’s business and its historic
government link, mean that the strategy for spent fuel and radioactive waste management
from EDF Energy Nuclear Generation’s power stations is owned and managed by the Nuclear
Decommissioning Authority. This does not mean that EDF Energy does not have policies to
continually improve and minimize the spent fuel and waste arising but this is done through our
wider safety, sustainability and environmental policies.
New reactors:
The new EPR reactor will have a larger core than in existing plants. Composed of 241
assemblies, its cladding will be of new alloy which is more resilient. The cycle duration will be
18 to 22 months with an average burn-up of 60 GWd/tU (compared to 45 in the existing
French plants) and the use of MOX will be possible but not yet foreseen (31
).
31 See §4.1 of the Flamanville3 safety report on http://energie.edf.com/nucleaire/carte-des-centrales-nucleaires/epr-flamanville-
3/publications-48527.html
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Beyond its performance and capability, this core presents advantages in term of waste
generation. Thanks to its size, to the number of assemblies, to the use of neutron shields, and
to the efficiency of the steam turbine, the efficiency of fuel use is 22% higher compared to a
current type of PWR reactor and the generation of long-life waste is 26% lower (32
). Due to its
highest activity, the impacts of spent fuel on transport, re-processing and storage had to be
assessed before its use in EPR. These impacts have been predicted by safety institutes in
France and UK to be compatible with current arrangements even if, in some cases, some
arrangements in the current provisions are to be made (e.g. ILW packaging, cooling period,
requirements for disposal..)(33
)
3.5 Decommissioning and waste
3.5.1 Policy
The common policy within the Group is to decommission each station following its
permanent shutdown in compliance with local laws with the aim to return the site to a
state suitable for an alternative use. In FRANCE, the only country where nine reactors
previously operated by the Group have been permanently shut down, EDF has chosen
to completely dismantle the nine first generation reactors.
EDF takes full financial and technical responsibility for the decommissioning of its nuclear
power plants. For EDF, the issue is to demonstrate, through the decommissioning process, its
control of the entire life cycle of the means of nuclear power generation.
3.5.2 Systems
In France, the decommissioning of nuclear power plants involves three levels, according to a
classification defined by the International Atomic Energy Agency (IAEA) in 1980:
Level 1: shutdown of the plant, fuel unloading, draining of circuits (99.9% of
radioactivity is eliminated), followed by final shutdown: dismantling of non-nuclear
facilities that are permanently decommissioned, with access limited to monitored
facilities;
Level 2: dismantling of non–nuclear buildings and nuclear buildings excluding the
reactor building, conditioning and evacuation of waste to storage facilities, isolation –
containment – the section of the facility surrounding the reactor is kept under
surveillance;
Level 3: complete dismantling and removal of the reactor building, and of materials
and equipment that are still radioactive; surveillance is no longer necessary; following
these operations, the site may be re-used for industrial purposes.
In practice, the operations leading from Level 1 to Level 2 are conducted consecutively over a
period of time of approximately 10 years after the reactor ceases production. A waiting period
may occur between the end of operations leading to Level 2 and the beginning of operations
leading to Level 3, in order to allow the radioactivity in the irradiated materials to decay. The
length of this waiting period may vary, depending on the comparative interest of radioactive
decay and the length of time the facility must be monitored and can depend on the re-use
32 See §11.3.2 of the Flamanville 3 safety report
33 See http://www.epr-reactor.co.uk/scripts/ssmod/publigen/content/templates/Show.asp?P=340&L=EN
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envisaged for the site. At the end of this waiting period, the length of time spent on operations
leading to Level 3 is estimated to be approximately 10 to 15 years.
EDF has launched the decommissioning program of the nine reactors that have been
definitely shut down (one PWR: Chooz A, one heavy-water reactor (HWR): Brennilis, one fast
breeder reactor: Creys-Malville and six NUGG-type reactors in Bugey 1, Saint-Laurent A and
Chinon A) by 2035, following the delay by ANDRA in commissioning the long-life LLW storage.
The sites remain the property of EDF, and they will remain under its responsibility and
monitoring. With regards to the other PWR power plants, certain decommissioning options,
including those relating to the timeframe, have not yet been finally decided. Given its role as
responsible owner, EDF will act as the contracting authority for the decommissioning.
The regulatory framework for decommissioning was renewed in 2006. It is characterized, for a
given power plant, by:
a single decree, following the NSA’s opinion allowing for complete decommissioning.
Three decrees were obtained in 2010: decrees for the complete dismantling of the
NUGG reactors Saint Laurent A and Chinon A3 in May 2010, and the decree
authorizing the construction of an interim storage facility for radioactive waste in April
2010 (ICEDA)
key meetings to be held with the French NSA, integrated in a safety reference system;
an internal authorization procedure for the operator, independent of the operational
staff and audited by the French NSA, and allowing the beginning of the work within the
limits of the safety reference system authorized.
The decree to dismantle Bugey 1 was published in the Journal Officiel on November 20, 2008.
Regarding the Brennilis site, at the end of July 2008, EDF made a new request to the
ministers in charge with nuclear safety for authorization to decommission. This new request
follows the decision of the French Council of State of June 6, 2007 to cancel the decree
authorizing the reactor to be fully dismantled, because the results of an impact study on the
decommissioned work had not been issued publicly before the publication of the decree. The
decree authorizing the next steps of the dismantling had been published on July the 28th 2011.
A decree, to be adopted around 2013 should authorize the complete dismantling.
The decommissioning program of the nine plants is progressing normally. The global progress
ration is of 33% at the end of September 2011 (Three projects are around 50%: Brennilis,
Creys-Malville and Chooz A):
At Chooz A, the dismantling of the primary circuit has begun in 2011; the two steam
generators have been cut and decontaminated; the reactor vessel will be cut by the
end of 2016
At Creys-Malville, the facility for the treatment of sodium has been commissioned in
2010; at the end of August 2011, 25% of the sodium (5,500 tons) is yet treated
At Brennilis and Chooz A, several nuclear auxiliary buildings have been totally
dismantled.
The decommissioning of EDF’s nine shutdown first-generation units will produce
approximately 1,000,000 tons of primary waste materials, of which 80% is standard waste
material and none is high-level waste. The remaining 20% comprises very low to intermediate-
level waste including about 2% waste requiring the availability of an LLW storage centre.
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The following waste evacuation projects are currently being implemented in order to
complement those already in place (very low-level waste and low-to-intermediate-level waste):
the project to build a packaging and interim storage installation for radioactive waste,
launched at the Bugey site. The commissioning is expected in 2014.
the low-level waste storage facilities (Centre de Stockage des déchets FAVL)
provided for under the law of June 28, 2006 concerning the long-term management of
radioactive material and waste. Because the search for sites launched by ANDRA in
2008 yielded no results, and in order to allow time for consultation, the French state
decided in 2010 to lift the deadlines on the LLW storage project and asked ANDRA to
continue discussions with the regions where municipalities had come forward as
candidates in 2008.
In the UK:
Radioactive wastes that arise during decommissioning will either be stored or disposed of
depending on the availability of appropriate disposal routes, in accordance with Government
policy that radioactive wastes will be disposed of where a disposal route exists.
The Low Level Waste Repository (LLWR) site in Cumbria is currently available for the disposal
of operational and decommissioning LLW within the constraints of its acceptance criteria and
is expected to remain operational until at least 2050. It is Government intent that a National
Repository (Geological Disposal Facility (GDF)) for ILW will be constructed, although it is
presently not expected to be available before 2040.
EDF Energy’s decommissioning plans detail the sequence for dismantling the stations and
calculate the amounts of radioactive and non-radioactive material that will be created. These
plans use sustainability and recycling principles to ensure materials created are stored,
recycled and disposed in manner consistent with safety and environmental legislation. In this
context "disposed of" reflects the strategic end point assumption for the waste when the waste
has been conditioned /packaged, emplaced within the GDF and the GDF facility is closed. For
the waste strategic end point - waste disposed of to GDF - there are no alternative strategic
options - this is the end state.
The inventory of materials projected for EDF Energy during decommissioning periods is
contained in the latest publication of the National Inventory Statement34
.
EDF Energy document specifies the arrangements by which decommissioning of its power
stations will be controlled to ensure compliance with all statutory and mandatory requirements.
It describes the regulatory compliance (Site License), interface requirements and
arrangements necessary for managing decommissioning at EDF Energy Nuclear Generation’s
power stations.
Radioactive wastes will be managed in accordance with the Corporate Radioactive Waste
Management Strategy and the Integrated Company Practice for Environmental Compliance
and Management.
In the United States, decommissioning activities for commercial nuclear facilities are done
pursuant to U.S. Nuclear Regulatory Commission (“NRC”) regulations at 10 CFR 50.33(k), 10
CFR 50.75, and 10 CFR 50.82 (35
).
34
http://www.nda.gov.uk/ukinventory/the_inventory/2010-inventory.cfm
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CENG has planned for decommissioning the each unit using the most feasible option to
minimize low-level waste (“LLW”). The facilities will be placed in a “SAFSTOR” configuration
(“delayed deconstruction”) per NRC guidance to allow shorter lived activity to decay and then
will use methods to remove the remaining contamination from the facilities. Regarding
decommissioning funding assurance, CENG must submit a report to the NRC once every two
years demonstrating how amounts deposited in protected trust funds will ensure that
decommissioning activities will be fully funded at the appropriate time. CENG has already
contracted with a Utah-based company, EnergySOLUTIONS, to accept the LLW. Once the
LLW is removed and surveys confirm that levels are less than regulatory minimums, the NRC
will then terminate the license.
Currently decommissioning of nuclear plants is underway only in France. As we decommission other nuclear sites operated by the EDF Group we will publish relevant information, including decommissioning waste figures, in an open and transparent way.
Enhancement of the design of new reactors, taking decommissioning into account
While the initial design of the past generation of reactors had not taken into account the
prospect of decommissioning, it has become a mandatory condition now in many countries.
The design of the EPR has particularly integrated the best international knowledge in that
point of view.
The provisions taken during the design phase aim at two targets at an acceptable cost: the
reduction of collective doses and of generated waste. The main provisions are (36
):
Less use of materials which can easily be activated during the operation (e.g. stellite,
less cobalt in metallic alloys...)
Implementation of shields and barriers preventing the activation of materials
Easy dismantling of equipment, areas for handling
Circuits and premises especially designed to prevent the accumulation of
contamination and to facilitate its removal.
4. Training
4.1 Overview on Human Resources and training policy
In the EDF Group culture, economic and environmental performance is strongly linked
to social performance
Historically, EDF has always clearly expressed its ambition around both an industrial,
economic project and a social project, that is to say a human adventure in which the absolute
priority is given to the development of competencies.
35
For an overview of the NRC’s regulatory requirements for decommissioning activities and decommissioning funding
assurance, please see: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/decommissioning.html
36 For more details please consult the safety report for Flamanville3 at the following address:
http://energie.edf.com/nucleaire/carte-des-centrales-nucleaires/epr-flamanville-3/publications-48527.html
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The human resources policy of EDF is thus based on three key priorities shared by all
businesses and companies within the Group:
People development: develop the skills required for business and, at the same time,
place people at the heart of the industrial project, with a recruitment policy and a
dynamic training approach, relying in particular on apprenticeships,
Set up recognition, quality of life at work, health and safety as levers regarding all
employees’ commitment to sustainable performance, fulfilling the EDF Group
commitments to quality of life at work, work-life balance, diversity,
Introduce more diversity and strengthen our common culture, especially among
managers and experts in order to build an integrated Group in France and on the
international stage.
The EDF Group ambition is to continue to invest heavily in human resources and skills
development through vocational training. The demanding goals, the introduced innovations
and the means committed through the Training agreement signed in 2010 with all the Unions
reflect the intensification of this effort, which must find its counterpart in an improved
performance for each of the Group companies.
Business growth and sustainable performance thanks to development of competencies
The EDF Group is now facing new challenges:
The businesses and activities evolve, in line with the technological, economic,
environmental stakes in the energy sector, with the continued strengthening of the
requirements (regarding nuclear safety in particular) and with the EDF Group
ambitions for business development in France and on the international stage,
The recovery of industrial investments in all sectors and the development of nuclear
engineering activities which will dramatically increase the need for skills,
In France, between 25 and 30% of the total EDF workforce could retire by 2015, a
figure that rises 1.5 times when considering the number of maintenance and operation
staff in the fields of production, engineering and distribution.
In addition EDF intends to be recognized as a company responsible for the control of the
environmental impacts (i.e.: human, flora and fauna) of its activities.
A strong and sustained investment in training and apprenticeship
The EDF Group, which operates in a context of high-tech professions, has always devoted a
large budget to the training of its employees in order to accompany the technological or
organizational evolutions and career paths. So, every year, EDF spends about 8% of its
payroll on training in France. The EDF Group intends to pursue this investment in vocational
training (apprenticeship, professional training contracts, internal promotional training) with the
necessary resources to match its ambition. EDF also benefits from tools in line with the
expectations of current and future employees (e-learning, serious games, on-site training
tools, the Group Intranet, edfrecrute.com Web site etc).
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To anticipate and guarantee that EDF will have, in the long-term, the right number of
employees with a high level of relevant qualification, a set of collective devices for training and
professionalization, the “Académies des métiers” (Business Academies) has been set up.
The objective is to seek excellence in operational and technical control, to integrate current
and future challenges for every Division or Business Line in the programs of
professionalization and to ensure the optimal quality level. After an assessment by the
Business Academies Council (composed of executives, HR and training professionals), a
training proposal developed by a Division or by a Business Line, meeting the requirements
receives an official ''label'', accompanied by recommendations for improvement.
Meanwhile, EDF conducts significant recruitment programs, especially in the fields of power
generation (nuclear, hydro and thermal) to support its projects in France and on the
international stage and to meet the challenge of competencies renewal.
The EDF Group intends to recognize and promote the ability of its employees to acquire,
develop and maintain their skills connected with the competencies required for business
needs in order to be able to find or preserve a satisfying employment in their company or any
other in the EDF Group. Mobility is encouraged with appropriate means, including between the
different companies of the EDF Group, when satisfying Group international mobility policy. The
EDF Group supports mobility because it enables employees to acquire new skills, in different
contexts, and to enrich their personal and professional experience, that is considered a major
key to employability.
4.2 Systems
The level of competency of EDF staff and its contractors is a vital and cross-cutting issue for
nuclear safety, operational safety, radiological protection, and environmental protection,
including waste management. Training is one of the principal tools available to managers to
maintain and improve competencies. From the various means available for improving the
competencies of the operators and technicians of their teams (mentoring, training, immersion,
career path, etc), the managers choose the most relevant and efficient in order to meet each
competency need.
Training on activities related to nuclear safety, industrial safety, radiological protection, waste
management and environment must, in general, comply with legal requirements which take
several forms, from assessment made by instructors and/or managers, to external statutory
accreditation. All are submitted to a quality assurance system and to external control by the
NSA.
The three nuclear companies of the EDF Group have to face issues of different types:
EDF Energy launched an ambitious and well-resourced program, with the objective to
respond to a difficult situation its fleet had to face in 2003-2004: resources for training
reinforced (instructors and equipments at the training center at Barnwood),
management of the training process under the control of local Committees involving
the top management of stations, accreditation process reinforced under the control of
the Training Standards and Accreditation Board. The TSAB members sit in judgment
of the capability and demonstrated performance of the evaluated line and training
organizations to ensure nuclear personnel are being trained and qualified to perform
their assigned activities safely, reliably, and efficiently. EDF Energy considers training
an effective tool to improve the professional performance of individuals and, as a
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consequence, maintaining and improving safety, reliability and efficiency of EDF
Energy’s operating nuclear power plants.
EDF SA is at a milestone of its history: after having operated the largest nuclear fleet
in the world for around thirty years, without any major incident, EDF has to renew the
generation of its engineers and operators (we are in a period of numerous
retirements), reinforce its operating performances and prepare the second half of the
lifetime of its fleet with an expectation of 60 years. Therefore EDF has established its
project « Generation 2020 » of which the reinforcement of workforce professionalism
is one of the five key-programs. EDF has adopted a policy compliant with international
standards of INPO (ACAD02-001), and has added to them skills management and the
“anticipated management of jobs and skills”:
o Skills management:
Performance improvement through training management
Management of training processes and resources
Initial training
Continuous training
Implementation of training programs and skills assessments
Assessment of training efficiency
o Individual involvement in training management
To support the ambitious program for initial training, EDF has created a centralized
unit with local groups on each site; the unit is composed of more than 500 instructors,
a large center in Le Bugey with simulators, workshops, and a computerized tools.
Another center will be built in Saclay, close to the new research center of EDF. Each
station has its own operating full-scope simulator and its workshop dedicated to
maintenance training which is opened to sub-contractors. These systems constitute
the “Academy of nuclear jobs” which is one of the “Jobs academies” put in place in the
framework of the agreement signed in 2010 with trade-unions and the aim of which is
to bolster a large project for training at the whole perimeter of the Group.
All contractors have to complete mandatory nuclear training courses within a programme that covers a range of nuclear operating issues including nuclear waste, nuclear safety, industrial safety, radiological protection and environmental protection. It is mandatory for both staff and contractors, who are checked when entering a nuclear station. Courses include :
o “Quality and Safety” course (5 days)
o “Nuclear accreditation” course (1 to 3 days)
o “Industrial Safety Risks” (5 days)
o “Radiation Protection” deepening course (6 courses of 1 to 5 days)
o A new course for executives has been recently created (9 days).
These training courses are delivered by bodies accredited by EDF and by an external
certifier (CEFRI). Several workshops have been created in the vicinity of nuclear
stations to facilitate and promote good training for contractors, simulating the
conditions they face when they are at work.
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Today training management is one of the areas of the continuous assessment of the
management of each nuclear unit; training management is also controlled by the NSA.
By 2015, EDF Nuclear Generation Division aims to put in place an overall assessment
process of skills management in each plant, comparable to the one of EDF Energy.
CENG has accredited training programs established at the 3 nuclear sites for the
following classification of worker:
o Senior Licence Operators
o Licenced Reactor Operators
o Non Licensed Operators
o Shift Managers
o Shift Technical advisors
o Engineers
o Mechanics
o Electrical Technician
o Instrument and Control Technician
o Radiation Protection Technician
o Chemistry Technician
These training programs go through accreditation renewal every four years. The
programs include initial qualification of workers and annual continual training.
Accredited training is provided to workers in several different settings throughout the
year. These settings include classroom, laboratory, in field training, simulator training,
dynamic learning activity, and computer based training.
Training is also provided for contract workers in the areas listed above. Contract
workers are task qualified for the specific work they will be performing.
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5 Reporting
5.1 Policy
EDF Group, as a whole, promotes a transparent communication on incidents and
events, and on performance indicators, including safety, radiation protection and
environment. Each company of the Group has put in place a process to provide information
to the public, adapted to local practices, generally using part of the data (the most suitable for
public understanding) it provides to safety authorities. Requirements of these authorities being
specific to each country, it is sometimes difficult to compare different indicators, and therefore
different performance levels. It’s also difficult to consolidate common indicators at the Group
level, for the same reason. Some of them are included in some reports which are produced
regularly: the Annual Report of Activities and Sustainable Development and the annual Report
of General Inspector for Nuclear Safety.
5.2 System
We use these indicators as an improvement tool for the managers, but not as an end in itself.
It is a way to measure a global safety performance and its evolution, but not a safety level.
Each company uses a lot of indicators, some of them are linked to the ongoing projects or
processes, launched to undertake improvements in the prevention process (see § 2.2) and to
reach excellence. They are not reported in the following pages because they are too specific
to a company and to an action-plan.
The main differences in practices are the following:
In some countries the reactor operator is asked to anticipate the automatic protection
(this is the case in USA and UK) by undertaking a “manual scram”, in others the
operator is asked to leave automatic protections to do their job. The different
approaches give rise to differences in the comparison of indicators, because in the
USA and the UK, the number of automatic scrams is, for that reason, lower than if it
would include manually anticipated scrams.
The practice for rating an event in the INES scale is different from a country to
another; one NSA can express stronger requirement and severity, for example by
using specific criteria; the French NSA, for example, has defined additional factors
that can affect the level of an incident (e.g.in the case when an event or failure can
potentially affect several identical units) (37
)
In the US, event reporting is governed by 10 CFR 50.72 and 50.73, as well as the
plant technical specifications in the operating licenses. That reporting doesn’t use
International Nuclear Event Scale but the INPO uses a specific tool to assess the
more or less significant potential impact of an event. Plant safety performance is
measured as a composite of event severity, significance of inspection findings by the
regulator, and the safety performance of important systems and programs. This
composite safety assessment is presented to the licensee and the public in the US
Reactor Oversight Process (ROP).
37
The number of events and their severity cannot strictly represent safety performance indicators, as assumed
by IAEA itself
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The numerous indicators used in environment (releases and solid waste) are closely
linked to the requirements of safety and environmental authorities(38
). The methods for
measurement, for calculation and for categorization are imposed by them but are not
strictly the same from a country to another one. It makes impossible or pointless any
consolidation at the Group level for a large part of them.
Please note that in the following paragraphs “EDF Group indicator” is a consolidate
one: EDF SA at 100%, EDF Energy at 100% (since 2009), CENG at 49.99% (since 2010).
Unplanned plant shutdowns
The unplanned automatic trip rate is the number of unplanned automatic trips per 7,000 hours
of operation as defined by the World Association for Nuclear Operators (WANO). A low figure
indicates that the reactor is controlled well within its safety limits and is operating reliably.
At EDF SA, the UATR is one of the safety performance indicators used for many years and
specific action plans are implemented to continuously improve it. The result in 2010 is the
second best historically, after the best level which was achieved in 2008.
At EDF Energy, following the indications of a deteriorating trend in the 2008/2009 UATR
performance, a comprehensive fleet level review was conducted into the reasons for this
adverse outcome and improvements plans were put in place. This has resulted in significant
improvement. The overall UATR for all the British nuclear stations at the end of the calendar
year 2010 was 0.58. The long term trend since 2003/2004 continues to improve.
At CENG (39
), following indications of a significant rise in the 2010 UATR, an assessment was
made to determine the reasons behind the large change. Corrective actions (see further)
38
In France each station produces an annual public report according to the TSN law
39 The indicator presented here includes manual scrams in addition to automatic ones and done by anticipation
to them
0
0.2
0.4
0.6
0.8
1
1.2
1.4
2000 2008 2009 2010
Reactor trip rate (nbr/reactor/yr)
EDF SA
EDF Energy NG
CENG
EDF Group
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were put into place across the CENG fleet which has resulted in UATR improvement in 2011
to date.
Incidents and events (INES level 1 or more, for EDF and EDF Energy, or INPO level 1 for
CENG) (impossible to consolidate)
The International Nuclear Event Scale (INES) is a rapid alert system used for consistent
communication of events across the nuclear industry. These are categorized between Level 1,
which is an anomaly with no impact on the safety of the general public or workforce, and Level
7 which represents a major accident. There has been no nuclear safety events rated above
INES Level 2 from any of EDF Group companies power stations in the last three years (40
).
The number of events scaled to minimum level 1 is presented hereafter but, for the reasons
formerly evocated, the safety performances of companies or plants are not directly
comparable. On the other hand, it can show a trend. Each company in the Group has defined
its own key-indicators more linked to their continuous improvement methods or to their
corrective action plans (see § 2.2 and the GINSR annual report) (41
).
Nuclear Safety Events
2008 2009 2010 2011
Level 1 (nbr) 67 67 68 n.a.
EDF SA Level 2 (nbr) 0 1 (Cruas) 0 1
(Tricastin)
Level sup or eq 1 INES (nbr/reactor/yr) 1.15 1.17 1.17 n.a.
Level 1 (nbr) 17 11 14 n.a. EDF Energy NG Level 2 (nbr)
1 (Dungeness) 0 0
Level sup or eq 1 INES (nbr/reactor/yr) 0.8 0.93 n.a.
EDF+EDF Energy
Level sup or eq 1 INES (nbr/reactor/yr) 1.09 1.12 n.a.
CENG Level 1 INPO (nbr/reactor/yr) 0 0.4 n.a.
40
This corresponds to FTSE exclusion criteria
41 For Tihange 1, see main events and automatic shutdowns at the following addresses:
http://www.belv.be/images/pdf/ar2008-public.pdf page 4 (2 events lev1, none lev2) http://www.belv.be/images/pdf/rapport_annuel_belv_09_fr.pdf page 6 (3 events lev 1, none lev2) http://www.belv.be/images/pdf/rapport_annuel_belv_2010_fr.pdf pages 10 and 11 (none event lev 1 nor 2)
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At EDF, the number of events is checked as a part of safety indicators but is not, if considered
alone, a safety target or a criteria for comparison (42
); its stability or increase can be due firstly
to the normal toughening of rules, notably regarding the permanent extending of Technical
Specifications during Operation (OTS), and secondly to the effect of the permanent
improvement of detection and reporting capacity, which is promoted by the management. For
several years, the event rate has been quite stable at around 1 per unit per year. In order to
have a better vision of improvements or deterioration of performances, EDF uses
complementary indicators as such the number of discrepancies to the OTS, number of line-up
errors, number of breaking out of fire, etc, and implements risk analysis on each particularly
significant or precursory event (see § 2.2.2). These indicators allow EDF to verify that safety is
globally in progress and to focus on main improvement programs.
Two INES level 2 events have occurred in the past two years, the first in Cruas on 2009,
December 2nd
, the second in Tricastin on 2011, February 17th.
The event in Cruas 4 is due to the massive increase in vegetation carried by the waterway
following heavy rains, which partially blocked the water intake and affected the heat sink of the
plant during few hours, but with no direct consequences neither on the cooling of the reactor
(which had been stopped and cooled by another system anticipated in that case) or on the
environment. The pumping station was promptly cleaned. The heat sink (water intake,
pumping station, filters, pumps) has been re-assessed and modified 43
(procedures too) and
the experience has been extended to the other sites. EDF has linked that case to other
failures occurred in France and abroad (using WANO report) and carried out a safety review of
the heat-sink on all sites completed at early 2011. This approach shows the will to anticipate
and not to react individually at each event. The conclusions concern several domains: a watch
of environmental evolutions, an improvement of the supervision of pumping station
(procedures and instrumentation) and of the maintenance programs (AP913 approach), and
the launching of modifications (additional instrumentation and improvement of the capacity of
42
On the other hand, if this number would be a strong safety target, the temptation to minimize, or even to
hide an anomaly or a discrepancy, would be high and would affect the safety culture
43 Mainly the capacity of filters to face a rough arrival of floating plant waste
1.7
1.15 1.17 1.171.13
0.80.93
0 0
0.4
0
0.2
0.4
0.6
0.8
1
1.2
1.4
1.6
1.8
2000 2008 2009 2010
Nuclear safety event rate (nbr/unit/yr)
EDF SA
EDF Energy NG
CENG
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automatic trash rakes). The first wave of actions is on-going and a second wave will be
integrated in the periodic safety reviews.
The event in Tricastin 3 and 4 consisted of the premature wear of bearings in the back-up
diesel generators (DG). That wear had been recorded during the periodic maintenance
process on these equipments; the DG would have started if needed but their function would
have been affected after several hours or days of continuous operation. It had no
consequences on the reactor but has been declared at level 2 because the problem could
potentially affect all 5 DGs simultaneously. The failing parts have been replaced, as well as on
the same DG in place on other plants (as prevention measure) and the maintenance program
has been reinforced. A modification of the lubrication system has been implemented. More
widely, the development of new types of bearings has started in 2011; their qualification will
occur in 2012.
At EDF Energy, over the last 5 years, the reactors have seen an overall safety improvement
linked to a major effort to upgrade the facilities and a strong emphasis on further improving
equipment reliability and operational focus. The rate of occurrence of events related to the
INES level events and Nuclear Reportable Event indicators is less than one event per reactor-
year of operation - and represent minor failures in very reliable plant and management
systems to protect safety and maintain legal compliance. Fluctuations from year to year in the
number of such events are expected and efforts to improve arrangements and reduce the
incidence of these events further are continuing.
During 2009 EDF Energy had one nuclear safety event rated INES Level 2 which is classed as
an incident with minor consequences to people or facilities, but where the measures put in
place to prevent or cope with accidents did not operate as intended.
The INES Level 2 incident occurred at Dungeness B power station during the construction of a
new fuel assembly. Whilst a fuel assembly is the completed series of fuel components used in
the core of an Advanced Gas Cooled Reactor Power Station, the incident did not concern the
reactor in any way. In the process of connecting a new fuel assembly to the supporting fuel
plug unit a piece of rubber was, on a procedural check, found trapped in the coupling
preventing the two sections from joining correctly. As part of the recovery process
polyurethane foam was injected below the suspended fuel assembly to minimize the potential
drop height in the event of a de-latch. Subsequent analysis of the foam showed that its use
was not permitted under the power station's operating arrangements. The foam did not come
into contact with the fuel assembly and the coupling did not fail.
There was no impact on the safety of the workforce at the station or the public at large. There
was no release of radioactivity or any damage to the plant. This incident was reported to the
safety Regulator, with which the operator has co-operated, and has been thoroughly
investigated. Companywide improvements have since been made.
In the US, operating transients, incidents, and events are trended and analyzed to assess the
effectiveness of the licensee in safely operating the plant. This assessment is performed
continuously by CENG for its reactors, as well as by the US NRC and INPO. Examples of
trends monitored are significant and noteworthy events, human performance events,
equipment failure rates, operational transients and power changes, personnel safety events,
environmental releases, etc. Much of this information is publically available on the NRC
reactor oversight process (ROP) website. INPO maintains detailed current and historical
trends for a multitude of parameters on their website, available to members.
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Two events, assessed as level 1 by INPO, occurred at CENG in 2010. The first event occurred
in February at our Calvert Cliffs plant which resulted in a dual unit trip. The second event
occurred at Nine Mile Point Unit-2. This event occurred during refuelling while draining the
refuelling pool.
These events, and others in the industry, led CENG to become a leader in the development of
SOER 10-02. Actions that the team developed in response to the events include:
Conducting case studies with managers and supervisors, at least semi-annually,
to discuss engaged, thinking organizations and station standards, using significant
events and other examples to focus the discussions.
Reviewed and revised management systems – including work management,
corrective action, system health, and observation programs – to ensure that the
importance of impact of subtle problems are recognized, prioritized, and
addressed appropriately.
Established roles for the leadership team in addressing significant operating
experience.
Verified through frequent evaluation that on-duty shift managers are providing
requisite oversight of plant operations and control room crew performance.
Provided supervisors with sufficient understanding of the importance of using
significant operating experience and job-related operating experience to prevent
events. Initial and continuing supervisor training now includes the must know
significant operating experience as identified by INPO.
We are providing supervisors with the knowledge and skills to conduct behavioural
observations, measure observed behaviours against station standards to detect
worker knowledge shortfalls and verifying that supervisors are performing these
observations appropriately.
Using the systematic approach to training, we are ensuring individual workers fully
understand and are able to demonstrate what it means to be an engaged, thinking
worker.
Developing and implementing a Learning Activity to ensure individual workers fully
understand and are able to demonstrate what it means to be an engaged, thinking
worker which includes the Chili Cook-off.
Developed a handbook like the Safety Culture pocket book to communicate the
principles of an Engaged Thinking Organization
Collective dose rate and individual maximum exposure (to the whole body) (workers
only)
The levels of collective dose and of maximum individual exposure to the whole body are highly
dependent on technologies (large difference for example between AGR and PWR), and on
maintenance programs. Action plans which have been implemented in all companies of the
Group have lead to a spectacular and continuous decrease in dose rates since the eighties or
nineties.
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Please note that “Group indicator” is a consolidate one: EDF SA at 100%, EDF Energy at
100% (since 2009), CENG at 49.99% (since 2010) 44
.
44
The indicator for Tihange 1 is not presented in the currently available reports but are under the fixed limits
and strictly monitored by Belgian authorities (1.3 manSv in 2008, 1.1 in 2009 and 1.15 in 2010 globally for the
three units)
0
0.2
0.4
0.6
0.8
1
1.2
1.4
1.6
1.8
2
2000 2008 2009 2010
Collective radiation exposure(man x Sv/unit)
EDF SA EDF Energy NG-PWR EDF Energy NG-AGR
CENG-BWR CENG-PWR EDF Group
0.69
0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5 H.S.
FRANCE US JAPAN GERMANY
IMPORTANT PWR NUCLEAR FLEET IN THE WORLD
H.Sv
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At EDF SA, actions undertaken with contractors on the most exposed categories of workers
and on critical works have obtained good results and have to be continued. Specific actions
have been started to reduce the risk of high exposal to the hands, after two events occurred in
Chinon in 2010 (complement to the training program, specific tools to catch irradiant
objects,..).
For EDF Energy, see “Our journey to zero harm” on EDF Energy web site. For more than
three years, no worker has been exposed to more than 15 mSv/yr (legal limit 20).
CENG has had success with reducing source term, improving radiation worker behaviours and
improving its ability to direct work remotely. The programme was launched to reduce the level
of collective exposure and has resulted in individual exposure being much below the
mandatory limits, in accordance with its internal policy: no worker is exposed now to more than
20 mSv/yr. The main actions are the following:
In the area of source term;
CENG uses flushing systems and hydrolazing piping to reduce dose rates in high travel paths.
An example of very effective flushing is employed at Calvert Cliffs where larger amounts of
water are flushed through the pressurizer spray lines for an extensive period prior to an outage
which has significantly reduced exposure during a refuelling outage.
System decontamination is a periodic practice primarily used at BWRs when the Co-60 source
term increases. It has been done on entire systems and on small portions of systems. The
NMP Unit 1 has relatively low source term due to decontamination in the recent past and unit
2 has an extensive decontamination scheduled in the 2012 outage.
Nine Mile Point has also used state of the art resin to clean reactor coolant during outages and
employed slow system drains and flood-up processes effectively to reduce the dose rates
workers are exposed to.
Removal of components that contain “Stellite” is a strategy that prevents the rebuilding of Co-
60 following decontamination and at BWRs the main focus is on the removal of Original
Equipment Manufacturer (OEM) Control Rod Blades as they contain “Stellite Rollers” that
0 0 0
18
10
7
0
5
10
15
20
2000 2008 2009 2010
Individual exposure at EDF Group(number of employees exposed to...)
> 20 mSv
> 16 mSv
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release contaminates that become activated in the reactor core. Unit 1 at Nine Mile Point has
reduced the OEM blades to the industry recommended amount and Unit 2 will reach that
threshold over the next two refuelling outages. At both BWRs and PWRs there has been an
effort to remove “Stellite” components from valves that are direct paths to the reactor core as
they contribute to activation of corrosion products.
Although it does not remove the source term, the use of shielding creates a barrier between
the worker and the source. This approach is used when it is not practical to eliminate the
source. The industry has a variety of shielding material available that can be custom designed
for an application to provide the maximum shielding while using the minimum space.
Tungsten shielding is the newest product available.
CENG is also progressively reducing the pore size in filters used on radioactive systems to
reduce system source term. Calvert Cliffs has experienced remarkable results through the
use of this process.
Zinc injection is a practice that has reduced dose rates over several operating cycles in
PWRs. The effect is delayed and the benefit begins to be recognized following the third
operating cycle of injection. Calvert Unit 2 displayed dose rate reductions in the refuelling
outage last year and CENG is anticipating the same benefit in the Unit 1 outage in 2012.
In the area of worker behaviours;
CENG uses Dynamic Learning Activities to improve worker behaviours in Industrial Safety,
Human Performance and In Radiation Safety. The static display is used to present both good
and faulted behaviours to help the worker recognize how they should perform in the actual
work area.
Just In Time Training is also used to familiarize a worker with an area, component or
procedure that they may not have used in an extensive period to identify potential error traps.
Full Scale Mock-ups of equipment are used to familiarize workers with new equipment or
equipment where the risk of error is high or the consequences of error are high. There are
mock-ups available for a variety of major equipment (e.g. Steam Generators, Reactor Coolant
Pumps. Pressurizers, valves). Nine Mile Point Unit 2 is implementing Power Up-Rate
modifications in the Spring and there are mock-ups of some of the high dose rate components
that are going to be modified so workers can practice and perfect their equipment.
In the area of improving CENG ability to direct work remotely;
Every CENG site employs extensive remote camera systems along with radio equipment to
enable prompt communication to correct behaviours or provide detailed instructions. This
equipment is employed by Radiation Protection Personnel as well as Crew Leaders so that
they can direct activities and not receive unnecessary radiation exposure.
There are also Electronic Dosimeters employed that will alarm if a worker is in a higher dose
rate area than planned or if they have received more exposure than they were authorized to
receive. The Electronic Dosimeters can also be equipped with transmitting devices so that a
central location can monitor their exposure and if outfitted with communication equipment they
can be informed of their exposure and exposure rate without manually viewing their dosimeter.
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These Electronic Dosimeters and similar portable area and air radiation monitors can be
installed in any location to enable the tracking of changes without the need to expose a
Radiation Protection Technician to obtain the information.
The personnel monitoring equipment is also capable of being connected to the site computer
system to inform personnel of alarms or malfunctions as much of the equipment contain self
diagnostic software to prevent use when they are not operating properly.
Dose to the most exposed person of the public
We are required (45
) to assess the radiation dose to the most exposed members of the public
in the vicinity of our sites using the results of our environmental monitoring (46
). The result is
specific to each site and differences are not a sign of good or bad performance, because of
the numerous parameters on groups’ behaviour and the geographical characteristics used for
the calculation (47
).
Applied to the surrounding populations, the dosimetric or health impact of radioactive liquid
and gaseous releases leads to a dosimetric value around 1/1,000th (a few µSv) of the
exposure due to natural background radioactivity (that itself can vary greatly from one region
to another according to the type of soil.
The consistent level of very low public dose from 2008 to 2010 is evidence of the companies’
successful efforts to employ best practicable means to minimize the impact of their releases
on the public.
45
Since 2008 in France ; before that date, the requirement was to verify that any element of the monitoring
was below the limits; in fact they were well below.
46 The method is specific to each country; it uses the principle of « reference groups » and calculation models
agreed by NSA and taking into account the proximity, the food habits, meteorological conditions, etc ; the
general method is the same as the one used for the initial Impact Assessment but some improvements can
have been introduced at one moment in the past.
47 The effect of Tihange’s global releases is around 0.03 mSv/yr and slightly decreasing, in parallel with
decreasing of radioactive releases
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Analysis and monitoring of radioactivity levels in the environment are essential to assess the impact of radioactive substances on human health, on the environment and on the resources of economic interest (especially water and agriculture).
In order to centralize information on environmental radioactivity in France and to provide access to measurement results for both professionals and non-professionals while strengthening harmonization and the quality of measurements performed by certified laboratories, the French stakeholders in environmental monitoring have launched the website www.mesure-radioactivite.fr, the French National Network for the Measurement of Environmental Radioactivity.
Under the Public Health Code, this network is developed under the auspices of ASN in collaboration with IRSN and in partnership with the Ministry of Health, Ministry of Ecology and Energy, major nuclear licensees (EDF, ANDRA, AREVA, CEA), health agencies (AFSSA, InVS) and environmental protection associations (including the independent laboratory ACRO).
A unique initiative in Europe, the site www.mesure-radioactivite.fr centralises all the results of radioactivity measurements carried out on the environment by various organisations and makes them available to experts and the public with frequent updates: on average, 15,000 measurements are added each month.
Part of an effort to make data on radioactivity in the environment more transparent for citizens, www.mesure-radioactivite.fr provides quick and easy access to a wide range of data related to the national network (regulation, operation and laboratory accreditation). It includes a section explaining radioactivity, how it is measured and its biological effects. The website gives the user keys to understanding the environmental radiological measurement results. The site will be improved over time taking into account the feedback of the users.
Results available on the website are provided by laboratories that have been certified by ASN.
They comply with the norm NF EN ISO 17025 and have succeeded inter-comparisons
exercises organised by IRSN.
2.2
1
0.0
06
0.0
06
0.0
07
2.4
1
0.0
02
0.0
02
0.0
03
1
0.0
72
0.1
17
0.1
04
0
0.5
1
1.5
2
2.5
3
Natural Public limit 2008 2009 2010
Dose to the most exposed members of the public (mSv/yr)
In UK
In F
In USA
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Waste generation or storage
The indicators cannot be compared and a consolidated indicator is not possible due to the
great differences between legal requirements and the categories of waste (the boundary
between levels) (see §3.3). For the moment each company has its own indicators and EDF
Group, as has WANO itself, has tried to find basis for benchmark.
The trends can be shown on these charts (data before EDF acquisition not available); they are
mostly influenced by the volume of maintenance and by the dates of shipments 48
.
Spent fuel
Regarding spent fuel, the situation is not the same in EDF (where spent fuel is totally sent off
site for re-processing), EDF Energy (where spent fuel is partially stored on site: totally for
PWR’s fuel, partially for AGR’s fuel), and CENG (where it is totally stored on site). Taking into
account theses differences within national strategies and the fact that spent fuel sent off site
will vary from year to year due to numerous factors which include cooling times, optimising
transport arrangements and operation capabilities within national industries, that figure doesn’t
show any significant trend. Nonetheless it confirms that a large majority of spent fuel produced
48
For Tihange, waste indicators are presented globally for the site in the following report, page 40; they can’t
be isolated for unit1; no indicator for spent fuel is publicly disclosed for the moment ;
http://www.electrabel.com/assets/content/whoarewe/Declarationenvironnementale211_8938400CB3F44A0C
9DE32C1D5BEA4F99.pdf
0
5
10
15
2008 2009 2010
EDF SA operational waste (in m3/TWh)
Low or medium level, short life
High or medium level, long life
0
200
400
600
800
2008 2009 2010
EDF Energy operational waste (in m3)
Low level
Intermediate level
0
200
400
600
800
2008 2009 2010
CENG operational waste (in m3)
Low or medium level
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by the Group is re-processed. The provisions made in EDF Energy and CENG regarding on-
site storage are presented in the §3.4.2.
Please note that the “Group indicator” is a consolidated one: EDF SA at 100%, EDF Energy at
100% (since 2009), CENG at 49.99% (since 2010)
Radioactive waste generated by decommissioning:
The available numbers are provided by EDF SA, the only company of the Group which
presently implements decommissioning programs (see § 3.4).
The chart shows the cumulated quantity of radioactive waste of each category:
o very low level and short life which are sent to the “CSTFA”, the adequate disposal
located in Morvilliers (Aube)
o low or medium level, short life, which are sent to the “CFMA”, the adequate disposal
located in Soulaines (Aube)
o metallic waste which are sent to Centraco, to be molten and re-use in nuclear industry
The total is currently lower than expected for this year, which indicates that there is no cause
for concern except delays advocated in §3.5.2.
0
200
400
600
800
1,000
1,200
1,400
1,600
2008 2009 2010
Spent fuel (tons of U)
Discharged by EDF Group Sent off site by EDF Group
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As we decommission other nuclear sites operated by other companies of EDF Group we will
publish relevant information, including decommissioning waste figures, in an open and
transparent way.
Being aware of their respective responsibilities, and accordingly with their regulations, EDF
Energy and CENG, as explained in §2.5.2, already regularly reassess forecasted quantities or
costs of future waste generated by decommissioning. For example, EDF Energy currently
forecast total generation of 190,000 m3 of packaged waste (LLW and ILW)
49.
49
See http://www.nda.gov.uk/ukinventory/the_inventory/2010-inventory.cfm
17,841 19,345 20,585
2,2972,524
2,869920
1,1571,418
0
5,000
10,000
15,000
20,000
25,000
30,000
2000 2008 2009 2010
Decommissioning waste in F(cumulated rough tons)
Very Low Level Low or medium level, short life Send to Centraco
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Appendix: Acronyms
AFCEN Association Française pour les règles de conception, de construction et de surveillance en exploitation des Chaudières Electro-Nucléaires
AGR Advanced Gas-cooled Reactor
ALARA As Low As Reasonably Achievable
ALARP As Low As Reasonable Practicable
ANDRA Agence Nationale pour la Gestion des Déchets Radioactifs (France)
BEG British Energy Group (UK)
BWR Boiling Water Reactor
CEG Constellation Energy Group
CENG Constellation Energy Nuclear Group
CEO Chief Executive Officer
CGNPC China Guangdong Nuclear Power Group
DOE Department of Energy (USA)
DG Diesel Generators
EDF Electricité de France
EDG Emergency Diesel Generator
EPR European Pressurised Reactor
EPRI Electrical Power Research Institute (USA)
EMS Environmental Management System
EURATOM European Atomic Energy Community
FBR Fast Breeder Reactor
FTSE Financial Times/Stock Exchange
GDF Geological Disposal Facility (UK)
GINSR General Inspector for Nuclear Safety and Radiation protection
GRS (or GSR) General Requirement for Safety (IAEA)
GWd/t Giga Watt-Day per ton
HR Human Resources
HSE Health and Safety Executive (UK)
HLW High Level Waste
IAEA International Atomic Energy Agency
ICRP International Commission on Radiological Protection
ILW Intermediate Level Waste
INES International Nuclear Events Scale
INPO Institute of Nuclear Power Operators (USA)
INSAG International Nuclear Safety Advisory Group (IAEA)
IRSN Institut de Radioprotection et de Sûreté Nucléaire (France)
ISFSI Independent Spent Fuel Storage Installation (USA)
ISO International Organization for Standardization
LLW Low Level Waste
LLWR Low Level Waste Repository
mSv MilliSievert (= 0.001 Sievert) (= 0.1 Rem)
MOX Mixed oxide
NEI Nuclear Energy Institute (USA)
NEPA National Environmental Protection Agency (China)
NLF Nuclear Liabilities Fund (UK)
NMP Nine Mile Point (USA)
NNSA National Nuclear Safety Administration (China)
NPP Nuclear Power Plant
NRC Nuclear Regulatory Commission (USA)
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NSA Nuclear Safety Authority
NSC Nuclear Safety Council
NWPA Nuclear Waste Policy Act (USA)
ONR Office for Nuclear Regulation (UK)
OEA Operational Excellence Assessment (EDF Nuclear Inspectorate)
OSART Operational Safety Assessment Review Team
OTS Operational Technical Specification
PPI Plan Particulier d’Intervention (Special Intervention Plan, France)
PUI Plan d’Urgence Interne (Internal Emergency Plan, France)
PWR Pressurised Water Reactor
RMD Risk Management Division (France)
SOER Significant Operating Experience Event Report (INPO USA)
TMI Three Mile Island (USA)
TNPJVC Taïshan Nuclear Power Joint Venture Company (China)
TSM Technical Support Mission
TSN Transparence et sécurité nucléaire (French law)
TSO Technical Specifications during Operation
TSAB Training Standards Accreditation Board
TWh Tera Watt hour
UATR Unplanned Automatic Trip Rate
UNE Unistar Nuclear Energy
UNGG Uranium Naturel Graphite Gaz (France) (eq NUGG)
USNRC United States Nuclear Regulatory Commission
VLLW Very Low Level Waste
WANO World Association of Nuclear Operators
WNA World Nuclear Association