10. Report by the Inspector General of Framatome

The training programme launched in 2021 to train all Framatome employees over a four-year period is progressing well. The target for 2022 (to have 50% of all employees trained) has been exceeded. From my field observations, I note that there is now a far greater understanding of nuclear safety culture principles at all levels.

The IG assessed the nuclear safety culture at Framatome’s Le Creusot plant, as well as at the Montbard plant, which was acquired in 2021. At each site, an assessment team of a dozen members, including two managers from other business units (BU), appointed by the executive committee, completed approximately sixty interviews and field visits. These assessments demonstrated effective communication at all levels of the organisation and a readiness to involve employees in making changes to their working environment. At Le Creusot, human performance tools are being implemented, and at Montbard, I was pleased to see how committed employees are to the company values and their awareness of the importance of product quality.

I reiterate the need to improve the presence of managers in the field and the rigorous application of standards. Delivery of these actions needs to be improved. Critical skills must also be managed more effectively to predict future requirements and provide the necessary training to ensure qualifications are up to date.

The nuclear safety policy at Framatome clearly states the primary responsibility of line management in relation to nuclear safety. The independent nuclear safety oversight organisation verifies that firstlevel oversight is carried out at every level of the organisation. The IG constitutes the second level of oversight.

The first-level independent nuclear safety oversight team is gradually taking shape. Representatives have now been identified in all the BUs and other operating units (plants or projects) and they perform this role in tandem with their other duties. They have all received specific training on their oversight role. However, I note that this team is not actively pursuing this role. I believe an analysis needs to be performed, to understand exactly what is hampering independent nuclear safety oversight. At the very least, as stipulated in the independent oversight mission statement, all entities should have a surveillance programme in place.

The quest for operational excellence in the BUs, as laid out in the ‘Excell in Quality’ plan, led to a commitment from Framatome in 2020 to standardise all mechanical components in the nuclear steam supply system (NSSS). Significant improvements are expected; structured manufacturing processes achieved through system engineering; more effective management of materials and equipment conformity; reproducible manufacturing processes; reducing equipment changes that are sources of non-compliance; operating experience (OPEX) that offers a greater benefit to series production; and greater compliance with regulatory milestones.

In my view, this approach enhances nuclear safety in the construction of new reactors.

There was little change in the mean occupational dose figures for Framatome employees (0.8 milli-Sievert) and contract partners (0.1 mSv) in 2022. The same applies to the number of employees having received a dose below the minimum recordable level (zero dose), with the figures standing at 30% for Framatome employees (compared with 28% in 2021) and 34% for contract partners (compared with 36% in 2021).

The sites with the highest recorded annual doses (13.9 mSv) and for contractors (8.9 mSv) were Lynchburg in the US, and Chalon, Intercontrôle and Maubeuge in France. These sites are involved in maintenance and inspection operations at nuclear power plants. For Chalon and Intercontrôle, I recommend that a rigorous assessment of OPEX from the stress corrosion maintenance operations be conducted to help improve occupational dose estimation and reduction.

The ageing of the existing nuclear fleet has caused an increase in radiological activity of primary system pumps maintained at Maubeuge. As this plant already has an effective policy for monitoring individual exposure levels, my advice is to investigate new solutions to reduce the doses received.

The industrial safety performance objectives were consolidated in 2022. They are now consistent for Framatome staff and subcontractors alike, with a global lost-time injury rate (LTIR) of less than 1 and a global total recordable injury rate (TRIR) of less than 2. At the end of the year, these indicators stood at 0.8 and 2.25 respectively, close to the target values.

The 2023 targets will be even more demanding, with a global LTIR of less than 0.5 and a global TRIR of less than 1.8.

Managers from the relevant BUs must present analyses of the most significant events to the CEO, demonstrating that the importance of industrial safety is exhibited at the highest level of Framatome.

I note, however, that the results for the BU Installed Base have deteriorated throughout the year. This is attributable to two factors: the integration of a new subsidiary (Framatome ARC, ex EFINOR) with far worse industrial safety results than the high standards demanded by Framatome (initial LTIR greater than 20); and an increase in the LTIR relating predominantly to on-site teams. This is a worrying trend given the high demands placed on BU Installed Base services and the causes need to be identified.

In 2022, the IG carried out 19 subject-specific inspections and 14 follow-up inspections to review progress against the uptake of its recommendations.

As agreed with the US Nuclear Regulatory Commission (NRC), the IG carries out two inspections every year at the Richland fuel fabrication facility, with a focus on one of six specific subjects: emergency preparedness, radiation protection and the environment, fire safety, criticality management, chemical hazards, and staff education and training. In 2022, the inspections focused on emergency preparedness and fire safety.

The emergency preparedness plan is sound: responsibilities are clearly defined, all staff are well trained and drilled, and emergency response equipment is well maintained. I am pleased to note the effectiveness of the new headcount system for emergency evacuation procedures. I ask the site to update the agreement with the Richland Fire & Emergency Services Department to include the need for fire-fighters to be trained to fight fires in a radiological environment.

Fire risk management relies on standards strictly complying with the applicable regulations, appropriate training, robust drills and exercises, inspections and regular internal audits. Improvements are still needed in terms of preventing exothermic reactions, and paying attention to detail when preparing documents authorising hazardous work.

The organisation and documentation at both these sites meet expectations. Periodic equipment testing is performed. The management of competences and training is consistent with their needs, and qualifications are monitored rigorously.

I advise Lingen to consolidate its exercise drills programme and to take better advantage of OPEX from Framatome’s two other nuclear plants.

At Romans-sur-Isère, monitoring non-conformities and incorporating regulatory requirements in the documentation for the different facilities could both be improved. The programme launched to clarify operating rules in the aftermath of events that occurred in 2021 is ongoing. I recommend that operators play a greater role in drafting operationsrelated documentation, as per IAEA standards.

In 2020, the compliance with the operational standards and the traceability of activities were inspected at: the CEDOS equipment maintenance and decontamination facility in Sully-sur-Loire, the CEMO equipment servicing and repair facility in Chalon-sur-Saône, the Karlstein and Erlangen facilities under the Engineering & Technical Directorate (DTI) in Germany, and the Erlangen facility under the BU IB. The nuclear safety, industrial safety and quality policies are all clearly set out in the standards inspected at these facilities. The different operational responsibilities and delegation of activities are also clearly defined.

In 2022, IG issued 64 recommendations, 42 of which were implemented, including 18 that were more than two years old. A total of 97 recommendations are currently in the process of being implemented, with 2 of these being more than two years old. The same objective of keeping the number of recommendations of more than two years old below 10 will be reapplied in 2023.

Operational rigour (mainly the quality of operational documentation and compliance with processes) was the main subject of recommendations (60%), followed by regulatory compliance (30%), and management of non-conformities (10%).