“ SISC ” Integrated System for NPP´s Supervision-Spanish Reactor Oversight Process Teresa Labarta, Olvido Guzmán, (CSN) Beatriz Gómez-Argüello (TECNATOM) 2006 ISOE INTERNATIONAL SYMPOSIUM, ESSEN

SISC CSN SISC-2 INTRODUCTION In November 2000 a joint committee (RB-licensees) was set up to work jointly on the improvement of the efficiency of the regulatory process, the objectives being: To compile the ongoing activities developed by the CSN and the nuclear sector focused on this item. To select a few representative countries (including those that are design suppliers of Spanish NPP) and analyse their regulatory framework. To analyse the proposal issued by NEA and IAEA. To identify actions to be developed in order to improve the regulatory process, attending to their scope and priority. WG concluded recommending the adoption of a less prescriptive process, addressed to the surveillance process, based on performance and risk significance

SISC CSN SISC-3 INTRODUCTION USA Tecnology dominant in Spanish NPP ROP had started in USA in a consistent and effcient manner The WG recommended the adoption in Spain of a simmilar system, introducing necessary adaptations to our national context SISC 2006 Pilot phase 01/2007 Official phase

SISC CSN SISC-4 INTRODUCTION SISC program is an Integrated System for Spanish NPP´s Supervision, as result of the adaptation of the “Reactor Oversight Process” from NRC (EEUU) SISC is intended to fulfil the following four goals : To maintain safety by establishing a regulatory oversight framework that provides assurance that plants continue to be operated safely by plant operators. To enhance public confidence in the CSN´s regulatory program by increasing the predictability, consistency, objectivity and transparency of the oversight process. To improve the effectiveness, efficiency, and realism of the oversight process by focusing both agency resources and utility resources on those issues with the most safety-significance To reduce unnecessary regulatory burden as the process becomes more efficient and effective.

SISC CSN SISC-5 SISC structure: Three Strategic performance Areas: Reactor Safety, Radiation Safety and Safeguards. Seven Cornerstones of Safety: Initiating Events Mitigating Systems Barrier Integrity Emergency Preparedness Public Radiation Safety Occupational Radiation Safety Physical Protection Three Cross-Cutting Areas: Human performance, Safety Conscious Work Environment and Corrective Action Program INTRODUCTION

SISC CSN SISC-6 DESCRIPTION

SISC CSN SISC-7 SISC STRUCTURE SISC process is structured in the following steps: 1.NPPs Surveillance- By Performance Indicators and CSN Inspections. 2.Inspection Results Assesment- Evaluation of Indicators and Inspection Findings according to its safety importance and its risk impact. 3.Regulatory Actions- That will depend on the assessment results. 4.Communication to the Public- Public information of the SISC program results.

SISC CSN SISC-8 SISC STRUCTURE 1) Information gathering by CSN From two sources: - Performance Indicators (PIs). Reported by the licensee quarterly. - Inspections. Findings resulting from CSN's inspection program.

SISC CSN SISC-9 SISC STRUCTURE 2) Evaluation of the information gathered Checking of the indicator values submitted by licensee and determine the safety significance of inspection findings through the Significance Determination Process. (SDP), assigning a specific colour to each of them.

SISC CSN SISC-10 SISC STRUCTURE 3) Regulatory actions- CSN response The PIs and inspection findings are used as assessment inputs to the Action Matrix. The first level of the Action Matrix corresponds to the Licensee Response column. The next four columns correspond to four levels of regulatory response increasing (including orders for plant shutdown) as plant performance declines.

SISC CSN SISC-11 SISC STRUCTURE 4) Information/Communication One of the main objectives of SISC program is to provide objective and clear information to the licensee and public about the NPPs performance. The results of the Inspection Findings and Performance Indicators will be public. It is still pending the definition of the different levels of information for utilities, stakeholders and public in general.

SISC CSN SISC-12 SISC DESCRIPTION CSN RESPONSE MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS COMMUNICATION PUBLIC MEETINGS  ASSESMENT REPORTS AND INSPECTION PROGRAMS ASSESMENT PROCESS (ACTION MATRIX) ENFORCEMENT Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) PERFORMANCE INDICATOR THRESHOLDS SUPLEMENTAL INSPECTIONS EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK–INFORMED BASELINE INSPECTIONS PERFORMANCE INDICATORS INSPECTIONS SAFETY CORNERSTONES PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES Significance Evaluation CSN RESPONSE MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS COMMUNICATION PUBLIC MEETINGS  ASSESMENT REPORTS AND INSPECTION PROGRAMS ASSESMENT PROCESS (ACTION MATRIX) ENFORCEMENT Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) PERFORMANCE INDICATOR THRESHOLDS SUPLEMENTAL INSPECTIONS EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK–INFORMED BASELINE INSPECTIONS PERFORMANCE INDICATORS INSPECTIONS SAFETY CORNERSTONES PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES Significance Evaluation

SISC CSN SISC-13 SISC DESCRIPTION CSN RESPONSE MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS COMMUNICATION PUBLIC MEETINGS  ASSESMENT REPORTS AND INSPECTION PROGRAMS ASSESMENT PROCESS (ACTION MATRIX) ENFORCEMENT Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) PERFORMANCE INDICATOR THRESHOLDS SUPLEMENTAL INSPECTIONS EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK–INFORMED BASELINE INSPECTIONS PERFORMANCE INDICATORS INSPECTIONS SAFETY CORNERSTONES PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES Significance Evaluation CSN RESPONSE MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS COMMUNICATION PUBLIC MEETINGS  ASSESMENT REPORTS AND INSPECTION PROGRAMS ASSESMENT PROCESS (ACTION MATRIX) ENFORCEMENT Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) PERFORMANCE INDICATOR THRESHOLDS SUPLEMENTAL INSPECTIONS EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK–INFORMED BASELINE INSPECTIONS PERFORMANCE INDICATORS INSPECTIONS SAFETY CORNERSTONES PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES Significance Evaluation

SISC CSN SISC-14 INDICATORS A Performance Indicator is a quantitative and objective measure of a particular attribute of licensee performance that indicates how well a plant is performing when measured against established thresholds Licensees submit this data quarterly, and the CSN regularly performs verification inspections of their submittals

SISC CSN SISC-15 INDICATORS There are 15 indicators corresponding to the safety cornerstones (10 for reactor Safety, 2 for Radiation Safety and 3 for Emergency), which are common to all Spanish NPPs. Risk-informed thresholds have been developed for both the PIs and inspection findings to establish performance bands.

SISC CSN SISC-16 COLOUR CODE GREEN- It indicates performance within an expected performance level in which the related cornerstone objectives are met. WHITE- It indicates performance outside an expected range of nominal utility performance but related cornerstone objectives are still being met. YELLOW- It indicates related cornerstone objectives are being met, but with a minimal reduction in safety margin. RED- It indicates a significant reduction in safety margin in the area measured.

SISC CSN SISC-17 THRESHOLD BANDS

SISC CSN SISC-18 INDICATORS OCCUPATIONAL RADIATION SAFETY INDICATOR “Occupational Exposure Control Effectiveness” This indicator monitors the control of access to and work activities within radiologically-significant areas of the plant and occurrences involving degradation or failure of radiation safety barriers that result in readily-identifiable unintended dose. Occurrences in Restricted Permanence areas - non conformance with the radiological protection manual requirements in these areas Occurrences in Prohibited Access areas - Idem Unintended Exposure occurrences - A single occurrence of degradation or failure of one or more radiation safety barriers that results in unintended occupational exposure exceeding a effective dose of 1 mSv

SISC CSN SISC-19 INDICATORS PUBLIC RADIATION SAFETY INDICATOR “Radioactive Effluent Control” Non compliance with the monthly dose restriction (10  Sv)- If the radioactive effluent releases per month reach a effective dose for the critical population  10  SV. Uncontrolled Releases - Radioactive effluent release outside the plant producing doses exceeding 1  Sv, without applying any kind of control over the effluent.

SISC CSN SISC-20 SISC DESCRIPTION CSN RESPONSE MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS COMMUNICATION PUBLIC MEETINGS  ASSESMENT REPORTS AND INSPECTION PROGRAMS ASSESMENT PROCESS (ACTION MATRIX) ENFORCEMENT Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) PERFORMANCE INDICATOR THRESHOLDS SUPLEMENTAL INSPECTIONS EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK–INFORMED BASELINE INSPECTIONS PERFORMANCE INDICATORS INSPECTIONS SAFETY CORNERSTONES PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES Significance Evaluation CSN RESPONSE MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS COMMUNICATION PUBLIC MEETINGS  ASSESMENT REPORTS AND INSPECTION PROGRAMS ASSESMENT PROCESS (ACTION MATRIX) ENFORCEMENT Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) PERFORMANCE INDICATOR THRESHOLDS SUPLEMENTAL INSPECTIONS EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK–INFORMED BASELINE INSPECTIONS PERFORMANCE INDICATORS INSPECTIONS SAFETY CORNERSTONES PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES Significance Evaluation

SISC CSN SISC-21 INSPECTION PROCEDURES Baseline Inspection Program: It is a risk-informed inspection which establishes the minimum inspection effort that all licensees would receive, regardless of their performance. It includes the areas not covered by the indicators and the verification of these indicators. Inspections beyond the baseline will be performed at plants with performance below established thresholds, as assessed through information gained from performance indicators and CSN inspections. Additional inspections may also be performed in response to a specific event or problem which may arise at a plant

SISC CSN SISC-22 BASELINE INSPECTION PROGRAM Inspection Procedures-Occupational Radiation Safety cornerstone “Access control to controlled area” “ALARA organisation, managing and control” “Radiation protection instrumentation and equipment” “Radiation protection training” Inspection Procedures-Public Radiation Safety cornerstone “Treatment, monitoring and control of liquid and gaseous radioactive effluents” “Inspection of transport of radioactive materials in NPPs” “Inspection of clearance activities” “Environment monitoring program (PVRA)” “Radioactive waste control and management”

SISC CSN SISC-23 INSPECTION RESULT PROCESS

SISC CSN SISC-24 CAP Corrective Action Program (CAP) In this program licensee must introduce : All Minor findings found by CSN inspectors- Findings of low significance which are only required to be documented and solved by the licensee through the CAP. All problems or issues detected by the licensee with its corresponding correcting action (minimum required issues are described in a specific procedure approved by CSN) CSN inspects each CAP to check if the licensee has included all required issues and minor findings. Issues detected by licensee, registered and properly solved by himself will not count as finding by the CSN if it is of low importance (minor finding or Green).

SISC CSN SISC-25 SDP Significance Determination Process (SDP)- It helps CSN´s inspectors to determine the safety significance of inspection findings. Each SDP supports a cornerstone associated with the strategic performance areas. Objectives : To characterize the safety significance of inspection findings, using best available risk insights as appropriate To provide all stakeholders an objective and common framework for communicating the potential safety significance of inspection findings To provide a basis for timely assessment and/or enforcement actions associated with an inspection finding To provide inspectors with plant-specific risk information for use in risk-informing the inspection program

SISC CSN SISC-26 SDP OCCUPATIONAL RP (1) Verde Blanco NO Blanco NO Verde ALARA Finding Green YES White NO Greater than 4 occurrences White NO Green Job Dose > 175 man.mSv YES Is three year rolling average collective dose > 0.8 man.Sv/year for PWR or > 2 man.Sv/year for BWR

SISC CSN SISC-27 SDP OCCUPATIONAL RP (2) Verde Rojo Amarillo NO DE>5 times the limit? Amarillo Blanco Amarillo Blanco Verde NO Green YES Red Yellow NO DE>5 Yellow White Yellow White Green NO YES NO It is an Overexposure? YES Dose Equivalent exposure? Effective Dose >5 times the limit? It is a potential overexposure? YES Was the ability to asses dose compromised? Associated to a surface contamination ? Whole body exposure in a RED area ?

SISC CSN SISC-28 SDP PUBLIC RP (1) Efluentes Radiactivos Dañada capacidad de evaluar dosis Dosis público > 1mSV GREEN YELLOW WHITE NO Efluentes Radiactivos Dañada capacidad de evaluar dosis Dosis público > 1mSV YES NO Efluentes Radiactivos Dosis público > 1mSV NO RADIOACTIVE EFFLUENTS? Dose to the Public > 50  Sv Dose to the public > 1mSV WHITE NO RED YES Dose to the Public > 100  Sv Impaired ability to assess doses Failed to assess doses

SISC CSN SISC-29 SDP PUBLIC RP (2) Vigilancia Ambiental NO Environmental Monitoring Program (PVRA) NO Impaired ability to assess environmental impact GREEN WHITE YES Failed to assess environmental impact

SISC CSN SISC-30 SDP PUBLIC RP (3) YELLOW WHITE NO RED NO GREEN NO R WHITE NO GREEN Solid Material potentially contaminated YES Dose to the Public > 50  Sv Dose to the Public > 100  Sv Dose to the Public > 1 mSv Failed to assess the activity concentration of the material and total activity released Impaired ability to characterise a potentially contaminated material

SISC CSN SISC-31 SISC DESCRIPTION CSN RESPONSE MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS COMMUNICATION PUBLIC MEETINGS  ASSESMENT REPORTS AND INSPECTION PROGRAMS ASSESMENT PROCESS (ACTION MATRIX) ENFORCEMENT Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) PERFORMANCE INDICATOR THRESHOLDS SUPLEMENTAL INSPECTIONS EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK–INFORMED BASELINE INSPECTIONS PERFORMANCE INDICATORS INSPECTIONS SAFETY CORNERSTONES PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES Significance Evaluation CSN RESPONSE MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS COMMUNICATION PUBLIC MEETINGS  ASSESMENT REPORTS AND INSPECTION PROGRAMS ASSESMENT PROCESS (ACTION MATRIX) ENFORCEMENT Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) PERFORMANCE INDICATOR THRESHOLDS SUPLEMENTAL INSPECTIONS EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK–INFORMED BASELINE INSPECTIONS PERFORMANCE INDICATORS INSPECTIONS SAFETY CORNERSTONES PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES Significance Evaluation

SISC CSN SISC-32 ACTION MATRIX – EVALUATION LEVELS Every Spanish NPP has a temporary position in this matrix, which reflects the licensee's safety performance. The first level of the Action Matrix corresponds to the Licensee Response column, for plants with all the indicators in green and with only green findings (if any). The next four columns correspond to four levels of Regulatory Response increasing as plant performance declines. These four levels determine the appropriate level of CSN response, including supplemental inspection and pertinent regulatory actions ranging from management meetings up to and including orders for plant shutdown

SISC CSN SISC-33 ACTION MATRIX – MODEL