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US NRC INTERNATIONAL REGULATORY DEVELOPMENT PARTNERSHIP (IRDP). WORKSHOP ON REACTOR INSPECTION Presented to PAA By: Advanced Systems Technology and Management (AdSTM) Warsaw, Poland October 11-13, 2010. CONTACTS. USNRC Office of International Programs contacts:
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US NRC INTERNATIONAL REGULATORY DEVELOPMENT PARTNERSHIP (IRDP) WORKSHOP ON REACTOR INSPECTION Presented to PAA By: Advanced Systems Technology and Management (AdSTM) Warsaw, Poland October 11-13, 2010
CONTACTS USNRC Office of International Programs contacts: Jack Ramsey (jack.ramsey@nrc.gov) Danielle Emche (danielle.emche@nrc.gov) AdSTM Contacts: Sergey Katsenelenbogen (sergey_k@astminc.com) Richard Barrett (rbarrett@astminc.com) Scott Newberry (newbs70@verizon.net) AdSTM Presenters: Richard Barrett, William Bateman
TOPICS Legal framework Phases of oversight Regulatory functions Regulatory activities Conduct of inspections Construction inspection Inspector qualification
LEGAL FRAMEWORK Laws Regulations Guidance Engineering codes and standards
HIERARCHY OF DOCUMENTS • Law on atomic energy • Law on radiation protection • Law on emergencies • ......................... NATIONAL LAWS • Site selection • Reactor licensing • Reactor operation • Decommissioning MANDATORY REQUIREMENTS • Technical guidance • Regulatory processes • Inspection guides • Training manuals GUIDANCE DOCUMENTS
LAWS Enacted by National Assembly Establish authority of regulatory agency over safety matters Establish requirements for conduct of regulatory affairs May limit liability of vendors and operating company
REGULATIONS / REQUIREMENTS Enacted by regulatory agency or ministry General standards and acceptance criteria Detailed requirements in some areas Govern all aspects of reactor design, construction and operation Legally binding on licensee Some regulations apply to the regulator
GUIDANCE • Developed by regulatory agency • Not legally binding • Provide guidance to applicants and licensees: • Acceptable ways to comply with regulations • Form and content of submittals • Provide guidance to regulatory agency on: • Review of licensee submittals • Conduct of inspections • Regulatory processes
CODES AND STANDARDS Developed by engineering / scientific societies Technical guidance on design, fabrication, installation, inspection, maintenance and repair of systems, structures and components Based on consensus of best technical practices Endorsed by regulatory agency for use by operating companies and vendors
PHASES OF REGULATION Site approval Construction permit Construction oversight Operating license Commissioning
PHASES (cont’d) Operations oversight License extension Decommissioning
REGULATORY PROGRAMPHASES OF OVERSIGHT SITING CONSTRUCTION PERMIT CONSTRUCTION OPERATING LICENSE COMMISSIONING OPERATION DECOMMISSIONING
NATIONAL NUCLEAR POWER PROGRAM Role of the Nuclear Regulatory Agency 1 2 3 4 5 6 7 8 9 10 11 12 13 14 YEAR
SITE APPROVAL Site characteristics suitable to: Support construction Support operation Hazards to plant safety Seismic Suitability for EP
CONSTRUCTION PERMIT Fundamentally sound reactor design Analysis demonstrates ability to handle accidents and transients Safety classification of SSC Safety requirements for SSC Ability of applicant to safely construct the plant
CONSTRUCTION OVERSIGHT QA Codes and standards Adherence to CP Vendors
OPERATING LICENSE Verify information presented in CP Engineering capability of as-built plant Operational controls Ability of applicant to operate safely Two approaches Open-ended license period plus periodic safety review Fixed license period plus license renewal
COMMISSIONING Readiness to commence operation Sufficient trained staff Programs and procedures Management controls
OPERATIONS OVERSIGHT Licensee performance Compliance with requirements and license Operator licensing Issue resolution Event response Plant modifications
LICENSE EXTENSION Two options: periodic safety review or license renewal Periodic safety review Every ten years Full review of plant safety License renewal Every forty years Aging processes only
DECOMMISSIONING Dismantle and dispose of contaminated structures Disposition spent fuel Decontaminate the site Decommissioning fund
REGULATORY FUNCTIONS Rule-making Licensing, maintenance of license, and license renewal Enforcement Performance assessment Event / emergency response Technical issue resolution
RULEMAKING Rules, regulations, requirements Administrative process Governed by national laws Include public and licensee involvement
RULEMAKING (cont’d) Technical content based on: Engineering knowledge Research results Operating experience
LICENSING Implements regulations for individual facility Specific ways of meeting requirements License provisions are legally binding Supporting information becomes the “licensing basis” Modifications to license License renewal
ENFORCEMENT Notice of violation of regulations or license Possible monetary penalties Criminal penalties for flagrant violations
PERFORMANCE ASSESSMENT Safety depends on licensee excellence Management commitment to safety culture Performance problems result in operational events and degraded plant conditions Revealed through inspections, operational events and performance indicators Significance determination process Graded response
EVENT RESPONSE Immediate safety concerns Incident response International assistance Root cause analysis / event investigation Corrective action Graded agency response Possible generic action
TECHNICAL ISSUE RESOLUTION Significant event or safety condition Reveals a new safety issue Individual plant remediation Generic action
AGENCY ACTIVITIES Technical review Inspection/audit Event analysis Technical analysis Codes and standards activities Licensing of Plant Operators Research
TECHNICAL REVIEW Detailed review of applicant / licensee submittals By staff who are expert in specific technical areas In accordance with agency requirements and guidance In support of licensing and oversight decisions
INSPECTION AND AUDIT Direct observation of plant conditions and licensee activities By technical staff trained in inspection techniques To judge compliance with regulations and license provisions To assess safety of design and operation Provide basis for further agency action
EVENT ANALYSIS Operating events challenge safety They reveal problems with plant condition and licensee performance Detailed analysis of significant events provide basis for technical resolution Trends and patterns of minor events reveal emerging safety issues International assistance
TECHNICAL ANALYSIS Some aspects of nuclear technology require detailed technical analysis Nuclear core design Thermal and fluid behavior during normal operation and accidents Structural mechanics Chemical behavior of fission products Regulatory decisions in these and other areas require reliable analytical results
CODES AND STANDARDSACTIVITIES Agencies endorse codes and standards for use by applicants and licensees Promotes efficiency of regulatory process Endorsement decisions must be based on thorough knowledge of content Staff participation in code activities assures quality of agency decisions
LICENSING OF OPERATORS Plant operators impact safety Must have excellent knowledge, skills and experience Agency oversight of operator qualification: training and testing Many countries license plant operators
RESEARCH New safety issues constantly emerge Due to operational events, advances in technology and aging processes Resolution often requires detailed experimental and theoretical analysis By experienced research organizations Regulator must be aware of research activities in the international community
INTRODUCTION Inspections by the regulatory authority play a primary role in assuring activities are performed in accordance with governing regulations Inspection scheduling Enforcement
INTRODUCTION Structure of this presentation Overview of inspection activities Types of inspections Inspection performance Guidance for inspectors Summary
OVERVIEW OF INSPECTION Purpose of inspection activities: Verify compliance with regulations and license Verify compliance with implementing processes and procedures Verify adequacy of personnel
OVERVIEW OF INSPECTION • Regulated entity’s quality assurance (QA) and quality control (QC) programs play an important role in assuring regulatory requirements are met
OVERVIEW OF INSPECTION Outcomes of inspection activities include assurance that: effective implementing procedures exist and are being followed work is being satisfactorily accomplished risk determinations and other assumptions used in plant design and operations are not being undermined by poor or inadequate practices
OVERVIEW OF INSPECTION Inspection outcomes (cont’d): public acceptance of the adequacy of plant construction, operations, and maintenance adequate resolution of identified issues public confidence in regulatory oversight adequate corrective action in response to findings identification of appropriate topics for discussion with licensee management during periodic performance review meetings
OVERVIEW OF INSPECTION • Inspections and enforcement motivate compliance • Regulated entity is responsible • Challenges exist • Allegations • Enforcement • Importance of inspection findings
TYPES OF INSPECTIONS Key types of inspections are: Routine Specialist Vendor Team