IAEA International Atomic Energy Agency

IAEA Outline Learning objectives Introduction Authorization Inspection Enforcement 2 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Learning objectives After finishing this lecture the trainee will: Get understanding about the contents to be reviewed in the scope of the IRRS Modules 5, 7 and 8 Understand that the review should address authorizations in different stages of the nuclear facility like nuclear power plants. Understands that as authorizations, review and assessment and inspections are interconnected, their respective review during IRRS also need coordination. Understand the concept of graded approach in authorization, inspection and enforcement. 3 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Learning objectives After finishing this lecture the trainee will: Understand the generic and specific requirements related to authorization and inspection for specific types of facilities. Understand how to review different types of inspections. Understand how to review the inspection programme of the regulatory body. Understand how to review the enforcement policy. 44 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Introduction This Training Lecture covers three IRRS Modules: This Training Lecture covers three IRRS Modules: Module 5: Authorization Module 5: Authorization Module 7: Inspection Module 7: Inspection Module 8: Enforcement Module 8: Enforcement 5

IAEA Complexity of these IRRS modules Complexity of the review depends on complexity of the nuclear programme in the country Each module has its core part (left) and subchapters depending on types of activities or facilities (right) Nuclear power plants are so reviewed together with the general process reviews 6

IAEA Review Methods – short reminder Review Methods are explained in detail in Training Lecture 5 – Methodology of review Summary: Three basic methods to acquire sufficient information for an objective review are: A review of written material. Interviews with personnel and other officials. Direct observation of regula- tory body activities in the office and at facilities. 7 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA 8 Review is assisted by Report Template Training Lecture 7 – Report writing As presented in Training Lecture 7 – Report writing the Standard Mission report Template gives guidance and assistance in the interviews and in writing the report Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA IRRS Module 5: Authorization 99 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Authorization Authorization by the regulatory body shall be a prerequisite for all facilities and activities. The applicant shall be required to submit an adequate demonstration of safety. GSR Part 1, Requirements 23 & 24 In referenced 12 & 67 times respectively. 10

IAEA Types of authorizations Different types for different stages: site evaluation, design, construction, commissioning, operation, shutdown, decommissioning... Authorizations for different activities: operation, maintenance, engineering activities Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Authorization process License amendment, renewal, revocation Independent verification of the safety assessment and traceability of decisions Requirements reflecting graded approach Clear criteria, requirements, safety objectives and independent assessment 12 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Recommendation of Experienced Reviewers Give particular attention to: Coordinate with Modules 3 & 4: Clearly defined roles of stakeholders (government, regulatory body, other regulators...) Competence available to regulatory body Interfaces with others involved in licensing [The license applicant, advisory boards, Technical Support Organizations (rules applied to avoid conflict of interest), public, etc.] 13 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Examples (Req. 23) 14

IAEA Examples (Req. 24) 15

IAEA Facilities and activities For each facility or activity check the situation with respect to standards mentioned below For NPPs the scope of the review is usually quite standard and similar in different countries. For other facilities the scope of the review could be very broad and different from each other. 16

IAEA Authorization of nuclear power plants IAEA safety standards: SSR-2/1 Design, SSR-2/2 Commissioning and Operation, NS-R-3 Site Evaluation, SSG-12 Licensing Process Recommendation of Experienced Reviewers Give particular attention to: Application for authorization Definition of the safety case Documentation of the licensing basis Ageing management 17

IAEA Authorization of research reactors IAEA safety standards : NS-R-4, CoC Research Reactors, NS-R-3, SSG-12 Recommendation of Experienced Reviewers Give particular attention to: Ageing management Safety committees, lines of authority and communications Influence on DBA by experiments and experimental devices Role of the reactor manager Licensing of personnel 18 For titles and description of standards see IRRS Training Lecture No. 2! 18 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Authorization of fuel cycle facilities IAEA safety standards : NS-R-5, NS-R-3, SSG-12, SSG-5, SSG-6, SSG-7, SSG-15 Describe specific authorization requirements for facilities available in the host country. FCF’s: processing, refining, conversion, enrichment, fabrication of UOX and MOX fuel, SF storage, SF reprocessing, fuel cycle research and development installations 19 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Examples Research reactor: Fuel cycle facility: 20

IAEA IRRS Module 7 Inspection 21

IAEA Inspections The regulatory body shall carry out inspections of facilities and activities. Inspections shall verify that the authorized party is in compliance with the regulatory requirements and with the conditions specified in the authorization GSR Part 1, Requirement 27 ; In referenced 31 times. 22 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Types of inspections There shall be programmed inspections and reactive inspections; both announced and unannounced. Regulatory Body should develop and implement a programme of inspections. Inspections shall cover all areas of responsibility of the regulatory body GSR Part 1, Requirement 28; In referenced 3 times. 23 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Graded approach Inspections of facilities and activities shall be commensurate with the radiation risks associated – graded approach. GSR Part 1, Requirement 29; In referenced 31 times. 24 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Inspection methods (reviews, interviews, walk downs, observation of activities) Reporting the results Planning of inspections Use of third party for the inspection (TSO, inspection organizations, consultants) Joint inspections with other regulators, sharing of inspection results with other regulators Interfaces with authorization, review and assessment and enforcement 25 Recommendation of Experienced Reviewers Give particular attention to: 25 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Follow up and closure of corrective actions Manpower available, qualification and training of inspectors Resident/site inspectors Authority of inspectors Use of inspection feedback in the regulatory process 26 Recommendation of Experienced Reviewers Give particular attention to: 26

IAEA Example (Req. 27) 27

IAEA Examples (Req. 28 and 29) 28

IAEA Example (Req. 29) 29 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Base the review on the following standards NPPs: GS-G-1.3 Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body Research Reactors: NS-R-4 Safety of Research Reactors Fuel Cycle Facilities: NS-R-5, SSG-5, SSG-6, SSG-7, SSG-15 Inspection of facilities 30 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA IRRS Module 8 Enforcement 31

IAEA Enforcement Policy The regulatory body shall establish and implement an enforcement policy for responding to non- compliance by authorized parties In the event that risks are identified, the regulatory body shall require corrective actions to be taken. GSR Part 1, Requirements 30 & 31; In referenced 8 & 24 times, resp. 32

IAEA Enforcement Policy Criteria for corrective actions, should be established. Enforcement actions may include recorded verbal or written notification, written warnings, penalties and revocation of the authorization. Prosecution may follow in cases where the authorized party does not cooperate 33 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Graded approach Enforcement tools and powers clearly defined in the legislation From enforcement to prosecution Safety culture aspects Possibility for the licensee to appeal Interface with authorizations, review and assessment and inspections 34 Recommendation of Experienced Reviewers Give particular attention to: 34 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Transparency and openness Guidance, criteria and examples for different enforcement tools Training of inspectors on the enforcement 35 Recommendation of Experienced Reviewers Give particular attention to: 35

IAEA Examples 36

IAEA Summary (1) When reviewing Authorization focus should be on: Checking that authorization is a prerequisite for any nuclear safety related activity Different types of authorizations Authorization process Facility related authorizations 37 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Summary (2) When reviewing Inspection focus should be on: Verification that authorized party is in compliance with regulatory requirements Different types of inspections Graded approach Facility related inspections 38 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Summary (3) When reviewing Enforcement focus should be on: checking, that enforcement is in place to respond to non-compliances Clear criteria for enforcement Graded approach 39 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA THANK YOU FOR YOUR ATTENTION 40 Photo: V. Friedrich This activity is conducted by the IAEA, with funding by the European Union. The views expressed in this presentation do not necessarily reflect the views of the European Commission Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

IAEA Discussion Why is authorization so important, so emphasised in all international standards? Couldn't we simply trust the users to perform their radiation activities or use their nuclear facilities without the licence? Compare the pro’s and con’s of a formal, direct, written request of the inspector in case of incompliance with an open discussion with the licensee looking for the optimum solutions of the recognised weaknesses? Explain an example of graded approach related to inspection activities. What is a better goal for the inspector: as many enforcement actions as possible or as few enforcement as possible? 41