SARCON application at PNRA 4th Steering Committee on Competence of Human Resources for Regulatory Bodies 4-7 December, Vienna, Austria

Motivation and Background PNRA Scope of activities: 03 NPPs (PWR+PHWR) 02 NPPs (under construction) 02 Research Reactors 61 Medical Centers 145 Industrial Users 66 Research and Educational Institutes 92 Importers No. of X-Ray Facilities others The nuclear program of Pakistan is growing at good pace; it includes two research reactors (PARR I and PARR II), three nuclear power plants, sixty one medical centers, one hundred and forty five industrial users, sixty six research & educational institutes, ninety two importers, sixty six other. and more than seventeen hundred X-ray facilities.

Objectives Identify the competencies needed for various directorates of PNRA, based on IAEA competency framework for regulatory body Assess the existing competency level within PNRA for its required functions Perform a gap analysis for the competency requirements in various directorates/projects Determine the training needs to fill the competency gaps Recommend training strategy and action plan   The following objectives were defined for this project: Conduct organization-wide Training Need Assessment (TNA) and recommend training strategies and action plan. Identify the competencies needed for various directorates of PNRA, based on IAEA proposed competency framework for regulatory body [1] Assess the existing competency level within PNRA for its required functions Perform a gap analysis for the competency requirements in various directorates/projects Determine the training needs to fill the competency gaps Recommend training strategy and action plan

Deliverables Competency requirements for the technical directorates of PNRA based on IAEA Competency Framework for Regulatory Body Results of the competency gap analysis Training requirements and methods of training Training strategy and plan for competency development Individual Training Plan format  The following deliverables were identified: Training Need Assessment Report: Competency requirements for the technical directorates of PNRA based on IAEA Competency Framework for Regulatory Body Results of the competency gap analysis Training requirements and methods of training Training strategy and plan for competency development Individual Training Plan format

Methodology IAEA 04 quadrant competency framework for RB used Primary Source Directors Project Directors To highlight the competency requirements of the concerned directorate Secondary Sources Documents Ordinance Structure Mission HR Functions  The methodology constitutes data collection from both primary and secondary sources. For primary data collection, Directors and Project Directors were given questionnaire to highlight the requirements of the concerned directorate. The information was used in the organizational analysis as well as in the training need analysis and design of training modules for each directorate. In addition, a number of secondary sources such as existing documents related to the charter, structure, mission, human resource functions, and organizational performance were reviewed. IAEA four-quadrant competency framework1 for regulatory body was used to conduct the training need assessment of the organization. The four-quadrant competency framework has been mapped onto PNRA organizational structure to determine the competency requirements of various directorates within the organization. The existing competencies in the organization have been assessed and a competency gap analysis was conducted. The result of the gap analysis were then used to determine the training needs to fill the competency gaps in various directorates. A training strategy and plan has been formulated and included in the recommendations. IAEA 04 quadrant competency framework for RB used

Methodology 4. Personal and interpersonal effectiveness competencies 3. Regulatory practices competencies 3.1. Safety-focused analytical techniques 3.2. Inspection techniques 3.3. Auditing techniques 3.4. Investigation techniques 1. Legal basis and regulatory processes competencies 1.1. Legal basis 1.2. Regulatory process 1.3. Regulatory guidance documents 1.4. License and licensing documents 1.5. Enforcement process 4. Personal and interpersonal effectiveness competencies 4.1. Analytical thinking, problem solving and decision making 4.2. Personal effectiveness 4.3. Communication 4.4. Team work 4.5. Management 2. Technical disciplines competencies 2.1. Basic technology 2.2. Applied technology 2.3. Specialized technology The IAEA proposed competency framework divides the competencies required in a regulatory body in four quadrants. Each quadrant is assigned a group of competencies that are coherent and consistent within the context of each quadrant. The first quadrant includes competencies related to the legal basis and regulatory processes that empower the regulatory body and govern its operation. Competencies relevant to basic, applied, and advanced technologies are grouped in the second quadrant. The third quadrant comprises competencies that are pertinent to regulatory practices such as assessment and inspection techniques, investigation, and auditing. Finally, competencies related to personal and interpersonal effectiveness (commonly known as soft and/or human-factor skills) are included in the fourth quadrant.

PNRA TNA Steps 2 3 Methodology used for conduct of TNA at PNRA is given at Figure 1.3. The first step involves input from PNRA functions, in terms of scope of activities. Next step is the identification of directorate functions and individual functions. Third step is the identification of directorate competency requirements different level of job positions and also identification of existing competencies at different job positions. Fourth step is comparison of required competencies vs existing competencies and finding out the gaps. Based on results of competency gaps, next step is the identification of training modules and strategies to fill these gaps. Last step is the identification of training modules for each job positions. TNA is a continuous process and needs to be carried out after every 3-5 years. 4 5

Methodology Step 1: PNRA Functions and Responsibilities To regulate all stages of nuclear fuel cycle, radiation facilities and use of equipment for production, use or application of nuclear energy Make and enforce rules, regulations, orders and codes of practice To plan, develop and execute policies and programs for protection of life, health and property against risks of ionizing radiation To establish the extent of civil liability in case of nuclear accidents

Methodology Step 1: PNRA Functions and Responsibilities To grant authorization for the production, storage, disposal, trade-in and use of any nuclear or radioactive material To inspect all nuclear installations and radiation facilities for ensuring compliance with National Regulations To ensure implementation of corrective actions following unsafe conditions To ensure implementation of measures for Physical Protection of nuclear installations and nuclear material To ensure that emergency preparedness plans are in place

Organizational Structure of PNRA Authority / Chairman Two full-time members Seven part-time members Advisory Committees Regional Nuclear Safety Directorate – II Chashma Directorate of Nuclear Safety Directorate of Transport & Waste Safety Directorate of Radiation Safety Directorate of Administration Directorate of Finance Chairman’s Secretariat Information Services Directorate of Regulatory Affairs School for Nuclear & Radiation Safety C H A I R M A N Member (Executive) Director General (Corporate) Directorate of Policies & Procedures PRIME MINISTER OF PAKISTAN Member (Corporate) Directorate of International Cooperation Safety Analysis Centre (Technical) National Environmental Radioactivity Surveillance Programme National Dosimetry and Protection Level Calibration Laboratory Regional Nuclear Safety Directorate – III Karachi Regional Nuclear Safety Directorate – I Islamabad Nuclear Security Action Plan Secretary of the Authority (Inspection & Enforcement) Centre for Nuclear Safety (Capacity Building) Establishment Section The structure of an organization is the pattern of organizational roles and responsibilities, communication relationships, and procedures that enable coordinated action by its members. Organization structure also provides the guidelines for job definition, decision making powers, and position descriptions. It defines the boundaries of the organization and its interfaces with the environment or the other organizations and institutions with which it must interact. The organization structure of PNRA is shown in Figure 1.1. The Authority consists of the Chairman, two full-time members (Executive Member and Corporate Member) and seven part-time members. The Chairman is also the Chief Executive Officer of the organization and is responsible for administration of the affairs of the authority. At present, PNRA consists of 16 technical directorates & Projects and three administrate directorates. There are ten technical directorates & projects of corporate wing and six technical directorates of executive wing

Methodology Step 2: PNRA Directorates Tasks GS-R Part 1 and GS-G-1.1 the regulatory functions are:  Major functions of the regulatory body Authorization (NSD+WSD+RNSD’s) Review and assessment (CNS+NSD+RSD+SNRS+NSAP+RNSD’s) Inspection and enforcement (NSD+WSD(I)+NSAP+RNSD’s) Development of regulations and guides (PPD) Supplementary functions Research and development (CNS+SNRS) Emergency preparedness (RSD+NRECC) International co-operation (ICD) Human Resource Development (HRD+SNRS+NSAP+RSD+WSD+RNSD’s) Regulatory Affairs (RAD)

CNS Tasks & Functions Methodology Safety Analysis in following areas: Step 2: PNRA Directorates Tasks CNS Tasks & Functions Review and assessment of licensing submissions such as safety analysis reports, PSR reports, probabilistic safety assessment, etc. Safety Analysis in following areas: DBA, BDBA, PSA, Structural & Seismic Analysis Assistance in the review of licensees submissions i.e.: Emergency Preparedness Program etc. Review of events/reports related to NPP Audit Calculation of SAR of NPPs and Research Reactors Review of design modifications related to NPPs Center for Nuclear Safety is technical support organization (TSO) of PNRA. Tasks and Functions Review and assessment of licensing submissions such as safety analysis reports, PSR reports, probabilistic safety assessment, etc. Technical Assistance to other Directorates, NRECC, JTS, SAC and SNRS (commissioning of simulator). Safety Analysis in following areas: Design bases Accidents Beyond Design bases Accidents Probabilistic Safety Assessment Structural analysis Seismic analysis Computational Fluid Dynamics (CFD) and Stress Analysis Assistance in the review of licensees submissions i.e.: Emergency Preparedness Program etc. Review of events/reports related to NPP Audit Calculation of SAR of NPPs and Research Reactors Review of design modifications related to NPPs.

NSD Tasks & Functions Methodology Step 2: PNRA Directorates Tasks Licensing of nuclear power plants and manufacturers of nuclear safety class equipment. Establishing and maintaining regulatory framework for nuclear safety and equipment manufacturing. Inspections and enforcement during manufacturing of equipment of NPPs. Review and assessment of submissions of nuclear power plants (NPPs) and equipment manufacturer. The Directorate of Nuclear Safety (NSD) is responsible for maintaining regulatory framework for nuclear safety, licensing and authorization, review and assessment of nuclear installations (other than research reactors). NSD is also responsible for regulating manufacturers of safety class equipments and components. Directorate performs activities to meet the ultimate goal of ‘protecting the public, the plant personnel and the environment from harmful effect of radiation as result of operation of nuclear installations'. Tasks and Functions Licensing of nuclear power plants and manufacturers of nuclear safety class equipment. Establishing and maintaining regulatory framework for nuclear safety and equipment manufacturing. Inspections and enforcement during manufacturing of equipment of NPPs. Review and assessment of submissions of nuclear power plants (NPPs) and equipment manufacturer. Reporting the summary on the safety of NPPs on quarterly basis to the Government of Pakistan. Establishment/Implementation of management system. Coordination with and Assistance to other directorates. Dissemination of information. General administrative work.

Methodology Review & Assessment Step 3: PNRA Individual tasks The major responsibilities are safety review & assessment and safety analysis in the area of nuclear systems, including: Design basis, safety criteria RCS performance characteristics Design evaluation of components (Pumps, Valves, Steam generators Pressurizer, Pressure vessel, Heat exchangers etc) and systems Evaluation of RCPB & its components SRH, ECCS , and containment, Hydrogen recombining & habitability systems Equipment functional qualification

Methodology Authorization Licensing including modification of NPP Step 3: PNRA Individual tasks Authorization Licensing including modification of NPP Periodic Safety Review Review and assessment Regulatory inspections Follow-up of activities related to NPP Maintaining data for NPP related activities Self assessment of regulatory effectiveness Preparation of Integrated Safety Assessment Procedure for NPPs

Methodology Qualitative Approach Quantitative Approach Step 4: Competence Assessment Qualitative Approach Interviews (structured/unstructured ) with senior officers Quantitative Approach Structures questionnaire based on IAEA 4 Quadrant competency model The four-quadrant (4-Q) competency framework was applied to PNRA using both quantitative and qualitative approaches. In the quantitative approach, we designed multiple questionnaires with specific objectives at different levels of details. These questionnaires provided information about competency needs as well as gaps at the directorate-level for senior, intermediate and junior staff. These questionnaires were given to the professional staff members. The intent was to collect information about the needed as well as existing levels of competencies in the organization. The data thus obtained was analyzed to determine the needed competencies as well as the competency gaps in each directorate. Level of Competency Score Low 0.0 - 1.0 Medium 1.0 - 2.0 High 2.0 - 3.0

Required/ Existing Competency Level (0,1,2,3) Methodology Step 4: Competence Assessment Q l: Legal Basis and Regulatory Process Functions (Competencies) Required/ Existing Competency Level (0,1,2,3) 1.1 Legal Basis 1.1.1 Comprehension of PNRA Ordinance, or any other laws that apply to a licensed nuclear and/or radiation facility.   1.1.2 Comprehension and use of the PNRA related regulations. 1.1.3 Ability to interpret legal texts from PNRA regulations, licensee submittals an inspection reports etc. for application in the field. 1.1.4 Ability to relate legal requirements from regulations, licensee submittals and inspection to routine tasks. e-g, licensing, design modifications etc. 1.1.5 Comprehension of the interrelationship between legal documents, regulatory guidance documents and licensing documents.

Methodology Step 4: CNS Required Competencies The following observations can be made from Figure3.2 & Table 3.2, regarding the quadrant-level competency needs for CNS: In the area of Legal Basis and Regulatory Processes (Quadrant 1), the needed competencies are high for senior level, at moderate for Intermediate level and low for Junior Level. In the area of Technical Discipline (Quadrant 2), the needed competencies are high for senior level & above than moderate for Intermediate level and low for Junior Level. In the area of Regulatory Practices (Quadrant 3), the needed competencies are high for senior level & for Intermediate level, it is moderate to high and low for Junior Level.   In the area of Personal and Interpersonal Effectiveness (Quadrant 4), the needs are high for senior level & for intermediate level, these moderate to high and for Junior Level these are low to high.

Methodology Step 4: NSD Required Competencies The following observations can be made from Figure 3.7 & Table 3.7, regarding the quadrant-level competency needs for NSD: In the area of Legal Basis and Regulatory Processes (Quadrant 1), the needed competencies are high for senior level, above moderate level for Intermediate level and low-moderate for Junior Level. In the area of Technical Discipline (Quadrant 2), the needed competencies are low-high for Senior, Intermediate level and Junior level. In the area of Regulatory Practices (Quadrant 3), the needed competencies are high for senior level & for Intermediate level, it is moderate to high and low for Junior Level. However, they don’t need competencies in auditing and investigation techniques as this is beyond their scope.   In the area of Personal and Interpersonal Effectiveness (Quadrant 4), the needs are high for senior level & for Intermediate level, these moderate & above and for Junior Level these are low to moderate.

Methodology To identify the competency gaps for each directorate. Step 5: Competencies Gap Analysis To identify the competency gaps for each directorate. Senior Intermediate Junior Scientists Engineers CSO SPE SSO SE SO AE PSO PE Respondents were asked to rate their competency. Competency gaps were calculated by subtracting the existing levels of competency from the needed levels for each job position. After completing the directorate-level competency need assessment using Questionnaires 1 , the next step was to identify the competency gaps for each directorate. The professional staff at each directorate was categorized into three levels namely, Senior, Intermediate and Junior. The senior staff includes Senior Principal Engineer (SPE), Chief Scientific Officer (CSO), Principal Engineer (PE) and Principal Scientific Officer (PSO). The intermediate staff includes Senior Engineer (SE) and Senior Scientific Officer (SSO). The junior staff includes Assistant Engineer (AE) and Scientific Officer (SO). The respondents of Questionnaire 1 were requested to rate as Low, Medium or High, the existing competency levels for their respective positions in their directorates. The data thus obtained was analyzed quantitatively by using a score of 1 for Low, 2 for Medium and 3 for High. The average of all the responses in a job category was taken for each competency. The competency gaps were calculated by subtracting the existing levels of competency from the needed levels.

Methodology Step 5: CNS Competencies Gap Analysis Competency gaps are identified in high and moderate categories. Some of the gaps were positive and other were negative. Positive gap highlight that competency existing was less than the required competency. Negative gap highlight that competency existing is more than the required competency A graphical & tabular representation of competency gaps for staff of CNS are given in Figure 3.14 & TABLE 3.14. All these competency requirements are taken as average in each discipline. At senior & intermediate level, there were some positive gaps, it was identified that senior & intermediate officers rated their competency level low, instead their competency was high. At junior level most of the gaps were negative, because many of them are working at CNS for last 3-4 years.

Methodology Step 5: NSD Competencies Gap Analysis Competency gaps are identified in high and moderate categories. Some of the gaps were positive and most of them were negative. Positive gap highlight that competency existing was less than the required competency. Negative gap highlight that competency existing is more than the required competency. A graphical & tabular representation of competency gaps for staff of NSD are given in Figure 3.19 & TABLE 3.19. All these competency requirements are taken as average in each discipline. At senior, intermediate and junior level, there were no considerable positive gaps, but few negative gap. The reason for such results is that all officers are working at NSD for many years at their respective positions. Director of NSD was of the opinion that concerned directorate does not require competency related to auditing and investigation, as it is under the scope of regional directorates.

Mapping Competencies on Training Modules Training modules identified to cover the competency need assessment Modes of Training: Lectures Case Studies IAEA Fellowship Programmes IAEA Scientific visit programme Workshop & Seminars On the Job Training (OJT) Plant Visit   Mapping Competencies on Training Modules In this section, training modules have been proposed to cover the competency need assessment. Table 1.1 shows the proposed training modules, modes of training, training duration and the competencies covered in these modules. The modes of training include Class room lectures (CR), case studies, IAEA fellowship programs, scientific visit program (IAEA), workshops and seminars, on-the-job training (OJT) and physical visits at plant. The sets of specific training modules recommended for different directorates are given in the next section.

Competency Improvement Methodology Course Code Course Title Duration Methodology Competencies related JR-101 Basic Professional Training Course (Level-I) 90 Hrs CR, OJT, IAEA fellowship 1.1.1, 1.1.2.1.2.1, 1.2.2,1.2.3, 1.2.5,1.2.4, 1.5.1, 2.2.1, 2.2.2, 2.2.3, 2.2.4, 2.2.6, 3.1.4, 3.1.5 JR-102. Training Course on Nuclear Engineering Fundamentals and Reactor Physics 20 Hrs CR,OJT 2.1.1, 2.1.2, 2.2.1 JR-103. Training Course on Thermal Hydraulics 12 Hrs CR 1.3.3, 1.5.2 JR-104. Training Course on major Mechanical, Electrical, I& C equipments of NPPs CR, Lab Visit 1.3.1, 2.2.2

Center for Nuclear Safety

Regional Nuclear Safety DIR-II

Directorate of Nuclear Safety

PNRA Compulsory Courses

Professional Experience Workshops (International) Personal Biodata, Training Record & Training Plan Name & Designation Father Name Qualifications Directorate Professional Experience (Current to Past) Duration Job Description/ Responsibilities Training/ Workshops (Local) Title Workshops (International) Trainings Plan 2011-2013 Venue

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