“Review and Assessment by PNRA Application Set

PRESENTATION LAYOUT INTRODUCTION ESTABLISHMENT OF TECHNICAL SUPPORT ORGANIZATION (TSO) AVAILABLE EXPERTISE MAIN LICENSING SUBMISSIONS REVIEW BASIS REVIEW METHODOLOGY REVIEW PROCEDURE MAJOR TASKS/ACTIVITIES

INTRODUCTION One of the prime responsibilities of the regulatory body is to perform review and assessment of the licensee’s submissions In fulfillment of the requirements of PNRA Regulations, the applicants/licensees are required to submit a number of documents during different stages of the licensing process The basic objective of review and assessment is to determine whether the operator’s submissions demonstrate that the facility complies with the regulatory requirements throughout its lifetime The review and assessment of licensing submissions leads to regulatory decision making during the licensing process

INFRASTRUCTURAL ARRANGEMENT FOR REVIEW AND ASSESSMENT In 2005, PNRA established a Technical Support Organization within the regulatory body i.e. Centre for Nuclear Safety (CNS) for performing review and assessment responsibilities Prior to that, agreements were made with the Vendor (Chinese) regulatory body to provide assistance in review and assessment and inspection of nuclear power plants during different stages of the licensing process 55 persons mostly comprising of the fresh graduates in Nuclear Engineering and other disciplines like electrical chemical, metallurgical I & C systems engineering etc. were inducted in CNS These officers were trained through in-house extensive training courses and fellowship visits to the Chinese regulatory body of three months duration.

OBJECTIVES OF ESTABLISHING CNS Capacity building of PNRA in performing safety review and assessment of Chashma unit 2 and future nuclear power plants. To improve the skills and knowledge of the regulatory personnel through specialized training at local and foreign institutions, To perform independent audit calculations and conduct safety research and development work in different areas of safety analysis. Developing strong documentation base and information centre equipped with regulatory documents (such as regulatory guides, review plans etc.) from countries such as China, USA, UK, Germany, France etc. Developing and strengthening bilateral links with TSOs of other nuclear regulatory bodies such as USA, China and Slovak Republic etc.

FACILITIES PROVIDED AT CNS A building of 9000 square feet is constructed and furnished with furniture and state-of-the art facilities. Library was equipped with modern technical books, magazines, journals and research papers on different technical subjects for consultation in the technical assignments. various regulatory and industrial standards like ASME Boiler and Pressure Vessel Code, RCCM Code, ANSI, ASTM, IEEE standards etc. have been acquired. Limited scope NPP training simulator has also been developed for training of regulatory staff in familiarization of NPP system and equipment

ORGANIZATION AND EXPERTIESE OF DIFFERENT GROUPS OF CNS

MAJOR REVIEW ACTIVITIES PERFORMED Safety Analysis Reports (C-2 SAR) Site Evaluation Reports of K2, C3 & C4 SER Safety Analysis Reports of C-3/C-4 and K-2/K-3 Periodic Safety Reports (PSR) of C-1 and K-1 Site Evaluation Repot (SER) of K-2 KANUPP revised FSAR Probabilistic Safety Assessment (PSA) reports Commissioning Program & Related Activities Review of Plant Modifications of K-1, C-1 & C-2

USE OF EXTERNAL SUPPORT DURING REVIEW AND ASSESSMENT PNRA signed bilateral agreements with the National Nuclear Safety Administration (NNSA) of China. The primary concern of hiring external technical support was to enhance the effectiveness of licensing process of C-1 and C-2 According to a protocol signed in 2004, Center for Nuclear Safety (CNS) of PNRA and Nuclear Safety Center (NSC) of NNSA were designated as counterparts of each other. The major areas for bilateral cooperation included the following: review and assessment of licensing submissions such as SAR, PSA reports, commissioning program etc. Inspections during construction, manufacturing, installation and commissioning stages of C-2

AREAS OF EXPERTISE IN AUDIT CALCULATIONS AND COMPUTER CODES Areas of Safety Analysis Thermal hydraulics DBA and Beyond DBA Analysis Radiological Consequence Analysis Stress Analysis CFD Analysis Seismic Analysis Probabilistic Safety Assessment Fuel Analysis Analytical Tools RELAP 5/MOD3.4 CONTAIN MELCOR GALE MACCS PEPS ANSYS FLUENT RISKSPECTRUM SAP 2000 FUELSIM

MAJOR ANALYSIS TASK PERFORMED TO SUPPORT REVIEW AND ASSESSMENT CFD Analysis of Surveillance capsule of C -1 Mechanical Integrity Evaluation for SG tubes of K-1 Steam Generator Analysis of Molten Core Concrete Interaction (MCCI) in reactor cavity in case of a severe accident at C-1 Analysis of Station Blackout sequence at C-1 Audit calculations of DBA and BDBA analysis presented in C-2 FSAR

REVIEW METHODOLOGY Review of Design Basis of Structure Systems and Components Review of Functional Requirements Checking of compliance against the general design and specific acceptance criteria Review of systems PIDs Perform audit calculations of selected analysis by using available computer codes Prepare evaluation findings

MAIN LICENSING SUBMISSIONS Safety Analysis Reports (SARs); Quality Assurance Program (QAP); Technical Specifications (TS)/Operating Policies and Procedures (OPP); Emergency Preparedness Plan (EPP); Radiation Protection Program (RPP); Radioactive Waste Management Program; In-Service/Pre-service Inspection Program; Fire protection program; Physical Protection plan;

OTHER DOCUMENTS TO BE REVIEWED Design modifications Modifications in Technical Specifications Event reports Periodic and Special Technical reports; Reports pertaining to Refueling Outages; Report of Periodic Safety Review

APPLICABLE REGULATIONS FOR REVIEW AND ASSESSMENT PROCESS Regulations for Licensing of Nuclear Installations in Pakistan (PAK/909) Regulations on Safety of Nuclear Power Plants; Siting Regulations on Safety of Nuclear Power Plants; Design Regulations on Safety of Nuclear Power Plants; Operation Regulations on Safety of Nuclear Power Plants; QA Regulations on Management of a Nuclear or Radiological Emergency - (PAK/914)

REVIEW BASIS PNRA regulations & regulatory guides IAEA safety requirements and guides USNRC 10CFR and regulatory guides Standard Review Plan (NUREG-0800) Industrial codes and standards e.g. ASME/RCC/ACI IEEE/IEC/ISO ANSI/ANS

REVIEW PLANNING Designation of a Team Leader Preparation of Safety Evaluation Report Conduct of Review Meetings Correspondence (Queries/responses) Conduct of Review Planning and Scheduling of Review Scheduling of Submissions Constitution of Review Team Designation of a Team Leader

REVIEW PROCEDURE The following steps are taken in the review & assessment of SARs Preparation of a review schedule keeping in view the time frame allocated for the review activity Allocation of SAR chapters to designated groups according to the area of expertise and previous experience of the reviewers. Designation of a Core team comprising of 4-6 senior technical officers to supervise and coordinate the review activities Allocation of Separate rooms for enabling chapter wise review and coordination among different groups Receipt of PSAR/FSAR and related documents and reports from the licensing Directorate NSD which has interface with the licensee

REVIEW PROCEDURE If submitted documents are incomplete, the same are sent back to NSD for acquisition of complete information from the licensee so that review and assessment can be carried out thoroughly and effectively. After getting complete information, PSAR/FSAR is docketed for review The review is performed in three phases: Phase-1: Review of format & contents of PSAR/FSAR in accordance with R.G 1.70. Phase-2: Detailed review on the basis of Regulations, regulatory guides, industrial standards Phase-3: Review on the basis of feedback from national and international operating experience, generic safety Issues, international good practices

REVIEW PROCEDURE Finalization of the queries/observations by the review team in consultation with the Director of TSO Review of the queries/observations by the core team for evaluation and finalization. Finalized queries sent to NSD for internal approval and onward communication to the applicant/licensee for response. Receive responses of queries from the Licensee through NSD Perform review of the responses and preparation of regulatory positions and action sheets Conduct review meeting with the licensee to discuss the regulatory position and signing of action sheets. Preparation of Safety Evaluation Report (SER) and Identification of safety issues/licensing conditions

REVIEW AND ASSESSMENT PROCESS SAR Received from applicant Not Acceptable Cursory Review for docketing of SAR SAR sent back to Licensee Acceptable Finalized queries sent to the Licensee Review of Format and Content Responses received from Licensee Detailed Review and Assessment Review and preparation of regulatory position Queries discussed and evaluated by TSO Core team Review Meetings with the Licensee Meeting with Core Team and Review Team Preparation of Safety Evaluation Report (SER)

REVIEW OUTCOME Final out come of the review and assessment by the regulatory body The format of SER is according to the format of relevant chapter of NRC Standard Review Plan (NUREG-0800) Main Contents of SER (for each chapter of SAR) Review Basis Review Details Conclusion List of queries raised List of pending issues requiring action by the licensee License conditions of review (if any)

CONCLUSION The establishment of internal TSO has greatly helped PNRA in strengthening its licensing and regulatory decision making process by: Performing indigenous expertise of in-depth technical review of different areas which led to enhancement of safety of nuclear installations Performing audit of the analytical calculations presented by the licensee in the safety analysis reports to support review and assessment Performing safety research and development activities related to emerging safety issues

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