Regulatory challenges innuclear safety
André-Claude LACOSTE
Former Headof the French Nuclear Safety Authority (ASN)(1993 – 2012)25 April 2013

JAIF

1/23

Contents
1. ASN general presentation
2. The post-Fukushima actions•

Post Fukushima actions at French and Europeanlevels•

Outcomes in France•

Outcomes in Europe

3. Challenges for the regulatory body
4. Conclusions & challenges
25 April 2013

JAIF

2/23

1. ASN Establishment•ASN, the French Nuclear Safety Authority, became an independentadministrative authority in 2006 by the Act on transparency andsecurity in the nuclear field (TSN act)
– ASN is not within a ministry but is a State Authority– ASN reports to the French Parliament.
– ASN is managed by a board of 5 Commissioners created by the TSN act.
 Full time job, non-dismissible 6 year term, non renewable Since 13 November 2012, Pierre-Franck CHEVET is the new ASN President•Core duties– Regulations– Authorizations– Inspection– Information•

ASN benefits from the expertise of a major TSO : IRSN
25 April 2013

JAIF3/23

1. Activities and installations regulated by ASN•Regulation of a wide range of activities and installations, including– 58 operating nuclear reactors• Standardized fleet• Generate ~80% of French electricity• One operator (EDF)– EPR reactor under construction– All French installations involved in the fuel cycle, from enrichment toreprocessing– Several thousand installations and activities using sources of ionizing
radiation for medical, industrial or research purposes;– Several hundred thousand consignments of radioactive materials
shipped nationwide, every year•

Some key figures– More than 450 staff, with about half of them in ASN 11 regional offices.
– A total budget of 142 million Euros, including 76,5 million devoted toassessments– More than 800 inspections per year on nuclear installations and transportof radioactive material.

25 April 2013

JAIF

4/23

Contents
1. ASN general presentation
2. The post-Fukushima actions•

Post Fukushima actions at French and Europeanlevels•

Outcomes in France•

Outcomes in Europe

3. Challenges for the regulatory body
4. Conclusions & challenges

25 April 2013

JAIF

5/23

2. The Post Fukushima actions• There is a before and after the Fukushima accident• About 10 years could be needed to take full accountof all lessons learned from the accident• Stress tests have been performed in a large numberof countries• Action plans have to be drawn up and followed over
several years• Avoiding stress tests being a one-shot exercise

25 April 2013

JAIF

6/23

Post Fukushima actions
at French and European levels (1/2)
5th May 2011

• ASN’s resolutions to require licensees to perform stresstests according to detailed stress test specifications,consistent with EU ones

3rd January 2012

• ASN’s formal report and ASN’s opinion about stresstests

Jan. – April 2012

• European peer review

26th June 2012

• ASN issued legally binding requirements (licenceconditions) to EDF on improvements to be implemented:- 19 site specific resolutions with about 40 licenceconditions in each of them
- Compliance deadlines : from 2012 to 2018.
Improvements are expected as soon as possible,
without waiting the next periodic safety review (EUpeer review recommendation)• Letter signed by ASN’s DG with 41 additional requests
to EDF

25 April 2013

JAIF

7/23

Post Fukushima actions
at French and European levels (2/2)
Immediately after the accident, ASN launched:• A campaign of targeted inspections•“Stress tests” (i.e. complementary safety assessment)• Are a complementary approach to the continuous
improvement process of safety pursuant to the law andoverseen by ASN (periodic safety reviews (PSR) and integrationof operating experience feedback)• Cover all French nuclear installations (~120), including EPR
reactor under construction, with priority given to the mostimportant ones (NPPs, La Hague fuel reprocessing plant…)•Stress tests aim at checking the robustness of plants to beyonddesign Fukushima-related situations: extreme natural events, loss ofsafety systems (heat sink, electrical power), severe accident situations.
• In addition, French stress tests also address human factors
25 April 2013

JAIF

8/23

Outcomes in France (1/5)
No immediate shutdown but …
ASN’s position : “the facilities examined offer asafety level that is sufficient for ASN not to request
the immediate shutdown of any of them […]. At thesame time, ASN considers that continued
operation of the facilities requires that theirrobustness to extreme situations be increased
beyond the existing safety margins, as soon aspossible.” (issued on 3rd January 2012)
 EDF made proposals to enhance its NPP’s safety
 For some other nuclear installations, shutdowns werealready decided
25 April 2013

JAIF

9/23

Outcomes in France (2/5)
Confirming Periodic Safety Review benefits• Importance of the periodic safety review (PSR) process
and significant operating experience feedback– Seismic improvements– Wide ranging set of hazards considered for flooding risk assessment– Severe accident measures implemented on all the sites

PSR process is in addition to routine safety assessment
2 steps in the PSR process:1) Extensive compliance check with the (latest) applicable
licensing basis
2) Safety re-evaluation: reviewing licensing basis, to identify thereasonably practicable improvements
25 April 2013

JAIF

10/23

Outcomes in France (3/5)
Improvements expected Need for a « hardened safety core »• technical and organizational measures which remains operational
under conditions considered in the stress tests
 Set up a « Nuclear rapid response force » for NPPs
• specialist crew and equipment within 24 h to the site
 Reinforced measures to reduce the risk of dewatering of the spent
fuel stored in pools
 Feasibility studies to protect the groundwater and surface waters incase of severe accident
 Organizational & Human Factors are essential to nuclear safety
25 April 2013

JAIF

11/23

Outcomes in France(4/5)« Hardened safety core»•

3 objectives for the situations studied in the stress
tests
1.
2.
3.

•

prevent or mitigate the progress of an accident with fuel melt,
mitigate large-scale radioactive releases,
enable the licensee to perform its emergency management duties.

Limited number of strengthened equipment including

an additional ultimate electricity generating set for each reactor;
a diverse emergency cool-down water supply for each reactor;
new emergency management premises, offering greater resistance tohazards and remaining accessible and habitable at all times and duringlong-duration emergencies
mobile devices and means of communication essential to emergency
management
technical and environmental instrumentation

File submitted by EDF (June 2012), currently under assessment by ASNand IRSN

25 April 2013

JAIF12/23

Outcomes in France (5/5)« Nuclear rapid response force»• For the nuclear power plants, ASN
required the progressive creation ofthe "Nuclear rapid response force"(FARN) proposed by EDF.
• The FARN is a national response
system including specialist crew
and equipment, able to take overfrom the personnel of a site affectedby an accident and deploy
additional emergency response
resources in less than 24 hours.
25 April 2013

JAIF

13/23

Outcomes in Europe (1/3)
European peer review• European stress test process (limited toNPPs) involved• Countries with NPPs: 15 EU countries+ Switzerland + Ukraine• 5 EU countries without NPPs
• European Commission and observers(IAEA, USA, Canada, Japan, UAE, Croatia)• Peer review :– 80 experts from all over Europe– A full process lasting 4 months– First-of-a-kind opportunity to share results
and compare practices between Europeancountries
25 April 2013

JAIF

14/23

Outcomes in Europe (2/3)
European level recommendations
http://www.ensreg.eu/EU-Stress-Tests/EU-level-Reports• Periodic safety review (PSR) are extremely beneficial
to the continuous improvement of safety– Necessity to re-evaluate natural hazards at least every 10 years• Need for European guidance on assessment of naturalhazards and margins• Need to strengthen the robustness of NPPs to beyond
design situations– Bunkered equipment,– Mobile equipment and off-site rescue teams to assist a crippled site…

• Need to maintain containment integrity– Urgent implementation of recognized measures (H2 explosionprevention…), for NPPs where they are not yet implemented
25 April 2013JAIF

15/23

Outcomes in Europe (3/3)• Full understanding of the TEPCO Fukushima
accident will be a long term process extending overseveral years, possibly a decade.
• One of the important results of the public
interaction is a strong demand for a European
initiative on off-site emergency preparedness.
– This subject was not part of the mandate of theEuropean peer review.

25 April 2013

JAIF

16/23

Contents
1. ASN general presentation
2. The post-Fukushima actions• Post Fukushima actions at French andEuropean levels• Outcomes in France• Outcomes in Europe
3. Challenges for the regulatory body
4. Conclusions & challenges
25 April 2013

JAIF

17/23

Responsibilities for nuclear safety

The prime responsibility for safety and radiation protection
must rest with the person or organization responsible
for facilities and activities that give rise to radiation risks
Principle 1 : Responsibility for safety
from Fundamental Safety Principles - Safety standards SF-1 IAEA (2006)

The regulatory body is responsible for the regulationof nuclear safety and radiation protection

25 April 2013

JAIF

18/23

Core values for a regulator (1/2)
 Competence and rigor• Skilled and trained staff– external expertise sources: Advisory committees and possibly TSO• Human and financial resources appropriate for theactivity scope and associated challenges• Extreme attention given to domestic and foreign operating
experience feedback• Openness to foreign practices and positions of foreign
regulators

25 April 2013

JAIF

19/23

Core values for a regulator (1/2)
 Independence• Freedom of judgement, action and expression• Ability to work on its own terms and in complete impartiality• Doesn’t mean isolation. Strong need of contacts and discussions withstakeholders, in particular operators for in depth technical discussions before
taking decisions

Transparency (strongly linked with independence)• Public information, media communication• Stakeholders’ participation• Parliament’s involvement

A real implementation of these 4 core values isneeded for the credibility, legitimacy and efficiencyof the regulator
25 April 2013

JAIF

20/23

Contents
1. ASN general presentation
2. The post-Fukushima actions• Post Fukushima actions at French andEuropean levels• Outcomes in France• Outcomes in Europe
3. Challenges for the regulatory body
4. Conclusions & challenges
25 April 2013

JAIF

21/23

Conclusions & challenges (1/2)• The accident at Fukushima confirmed that, despite all theprecautions that are taken for safety, an accident
remains possible.
• It now appears clearly, and has been endorsed in theconclusions of the extraordinary meeting of the Contracting
Parties to the CNS, that “nuclear power plants should bedesigned, constructed and operated with the objectivesof preventing accidents and, should an accident occur,mitigating its effects and avoiding (long-term) off-site
contamination. The Contracting Parties also noted that
regulatory authorities should ensure that theseobjectives are applied in order to identify andimplement appropriate safety improvements at existingplants.”
25 April 2013

JAIF

22/23

Conclusions & challenges (2/2)• The actual improvement of safety according to theseprinciples relies, in part, on the action of the regulators,
for example by having the licensing basis updated.
The independence, the transparency and the rigorous
action of the regulators are a necessary key to thisprocess.
• But first of all, the licensees, who have the prime
responsibility for safety, must take their share and be
active in the process of improvement.
This is to be done at an individual level, but also at acollective level, through national organizations such as
INPO and JANSI, and international organizations like
ENISS and WANO.
25 April 2013

JAIF

23/23