Universal Registration Document 2022

The control system

Nuclear safety is subject to numerous controls, both internal and external. For each nuclear unit⁽¹⁾, EDF now carries out overall excellence evaluations jointly with WANO peer reviews⁽²⁾ every four years. These take place over a period of three weeks and involve some 40 inspectors. The General Inspector for Nuclear Safety and Radiation Protection, reporting directly to and appointed by EDF’s Chairman and CEO, holds discussions with employees in the nuclear industry, enabling an opinion to be issued each year on the overall safety of the nuclear fleet and improvement actions to be suggested to the Company’s management. The related annual report is made public.

Efforts by EDF have made it possible to decrease the annual average number of automatic reactor outages in recent years by a factor of four over a period of twenty years. In 2022, there were 15 for the entire fleet.

• In France, safety is controlled by the ASN by means of:
  • scheduled or unannounced inspections conducted by the ASN: 513 inspections, including 34 national inspections, were conducted in 2022 at all EDF nuclear facilities (515 in 2021, including 26 national inspections);
  • a periodic (ten-year) review process designed to improve the compliance of nuclear plants with applicable rules and to update assessments of the risks and drawbacks that such facilities pose to the “protected interests” (protection of public safety, health and sanitation, as well as preservation of nature and the environment). To achieve this, the state of the facilities, the experience gained during their operation, new developments in nuclear science, and rules applying to similar facilities (safety standards) are taken into account.-At the close of the ten-year inspection, the operator sends the ASN a report containing the findings of the periodic review. In this report, the operator states its position regarding the regulatory compliance of its facility, as well as the modifications made in order to correct the discrepancies identified or improve the safety of the facility. The ASN provides the Minister in charge of nuclear safety with its analysis of the report and may define additional obligations for the operator⁽³⁾. The periodic review is an important step in continuing the operation of power plants (see section 1.4.1.1.2.3 “The issues relating to the nuclear activity” “B - The issues at stake in preparing for the future of the nuclear fleet in France”).
• At the international level, regular inspections are held on a regular basis. The evaluations allow experience built up worldwide to be pooled:
  • the OSART (Operational Safety Review Team) of the IAEA ⁽⁴⁾ performs reviews at the request of the French government with the objective of formulating recommendations and promoting best practices. One OSART was carried out in 2022 (Tricastin);
  • the international “peer review” inspections carried out by the WANO ⁽⁵⁾ are organised at the request of EDF to assess safety performance compared to best international working practices. In 2022, 5 follow-up missions ⁽⁶⁾ were carried out (Dampierre, Golfech, Nogent, Penly and Saint-Laurent), as well as 3 peer reviews (Belleville, Bugey, Civaux).

Whistleblowing system

In the event of an accident, a crisis plan is in place to limit impacts on the environment and people, and to ensure the safety of the facility. This crisis system is based on two closely coordinated plans, designed for both local and national use. These are:

• the Internal Emergency Plan for each nuclear site, developed by EDF;
• the Special Intervention Plan, prepared by French prefectures in collaboration with the French government and EDF.

In order to provide greater effectiveness, these plans in particular take into account external risks (flooding, etc.) and internal risks (fire, etc.). The relevance of the system for warning, informing and protecting people is regularly assessed through accident simulation exercises. Each year, approximately 100 exercises are organised for the entire French nuclear fleet, i.e., approximately one every three days. Approximately ten exercises are on a national level, under the management of the ASN and involve EDF and public authorities, in particular prefectures. In 2022, 13 nationwide exercises were organised, including 1 with ESKOM (South Africa).

After its initial analyses following the Fukushima accident in March 2011, EDF supplemented its crisis management organisation with a national team capable of quickly delivering material and human assistance to a site in great difficulty. This system, called the Nuclear Rapid Action Force (FARN), has had many simulation exercises from regional bases located at Civaux, Paluel, Dampierre and Bugey and can be sent to a unit at any site in difficulty. The FARN is capable of a simultaneous response at six units on a single site.

Significant events regarding safety

The operational safety of nuclear facilities is taken into consideration from the initial design stage, and is regularly monitored, together with the implementation of an employee motivation policy and large-scale investment programmes.

Discrepancies that are particularly important according to the criteria defined by the ASN are referred to as “specific events”. The detection of significant events by nuclear operators plays a key role in the prevention of incidents and accidents. The regulations require all nuclear operators to declare significant events to the ASN for the protection of the interests mentioned in Article L. 593-1 of the French Environmental Code. Each event is analysed by the plant’s teams to determine whether it is significant, and the independent safety reviewer also provides an independent assessment.

Those concerning safety are referred to as "SSEs”. This declaration process is part of the ongoing drive to improve nuclear safety and radiation protection and transparency. Its aim is, in particular, to enable the analysis of these events, so as to facilitate subsequent assessment of an incident or the risk of an incident, and to improve the practices of an establishment and/or of a sector of activity in the field of prevention.

Nuclear operators and transporters of nuclear material must declare all significant events to the ASN, at the latest within 48 business hours, along with the proposed classification using the INES ⁽⁷⁾ scale (a scale of one to seven, with seven being the most serious; incidents without nuclear safety significance are declared as “Level 0”). The ASN retains final authority for the classification of events. The use of the INES scale enables the ASN to select those that are sufficiently serious to warrant a communication by it.

Since the establishment of a scale of this kind in France in 1987, no INES scale level 3 event (serious incident – very low external emission, and exposure of the public representing a fraction of regulatory limits) or above has occurred in the French nuclear fleet. In 2022, EDF declared 683 significant safety events (SSEs) in France, an improvement on the 752 SSEs declared in 2021. No INES scale level 2 SSE (as in 2021) and 79 INES scale level 1 SSEs (as in 2021) were declared.

Moreover, the Group’s nuclear safety policy is an integral part of the training courses that the employees of EDF and of its service providers are required to take. After initial training that lasts for several months, and even up to 24 months for key positions (Safety Engineers, Operators, etc.), each employee has to take mandatory annual, biannual and triannual refresher courses depending on the business line and field.

The 2022 detailed results on nuclear safety are published in the annual report created by the General Inspector for Nuclear Safety and are available on the Internet⁽⁸⁾.