1. Reviewing Management System and the Interface with Nuclear Security
BASIC IRRS TRAINING
Lecture 10
Reviewing Management System and the Interface with Nuclear Security
(IRRS Modules 4 and 12)

2. Outline Learning Objectives The Interface with Nuclear Security
The Management System of the Regulatory Body
Relevant IAEA Safety Requirements
Relevant Safety Guide
Recommendations of experienced reviewers
Examples of findings in past missions
The Interface with Nuclear Security
Relevant IAEA Safety Requirement
Recommendations of experienced reviewers
Example from past missions
Basic IRRS Training - Reviewing Management System

3. Learning objectives After finishing this Lecture the trainee will:
know which IAEA Safety Standards are relevant for the review of IRRS Modules 4 and 12,
know the main contents of these Safety Standards,
know key aspects and issues identified by experienced reviewers in the review of IRRS Modules 4 and 12,
be informed about typical findings of past missions regarding IRRS Modules 4 and 12.
Basic IRRS Training - Reviewing Management System

4. Report Template shell be presented
Use of report template
For repeated use of this lecture, it is noted that the Standard Mission Report Template shall guide and assist interviews and writing.
Report Template shell be presented
in Lecture 7!
Basic IRRS Training - Reviewing Management System

5. IRRS Module 4: The Management System of the Regulatory Body
Basic IRRS Training - Reviewing Management System

6. Relevant IAEA Safety Requirements
There are two IAEA Safety Requirements publications relevant for the Management System of the Regulatory Body (c.f. also Training Lecture 2): GSR Part 1: Governmental, Legal and Regulatory Framework for Safety (rev 1, issued in 2016) GSR Part 2: Leadership and Management for Safety (issued in 2016)
Basic IRRS Training - Reviewing Management System

7. Disclaimer revisited
Participants of the Basic IRRS Training Course are supposed to be familiar with the IAEA safety standards. This Lecture provides a short summary of the most important requirements while the presentation will be even shorter. The participants are requested to look for details in the respective GSRs
Basic IRRS Training - Reviewing Management System

8. GSR Part 1
Basic IRRS Training - Reviewing Management System

9. GSR Part 1
GSR Part 1: Governmental, Legal and Regulatory Framework for Safety
Requirement 19:
The Regulatory body shall establish, implement, and assess and improve a management system that is aligned with its safety goals and contributes to their achievement
In in missions to nuclear countries referenced 21 times
Basic IRRS Training - Reviewing Management System

10. GSR Part 1 Key aspects of GSR Part 1, Requirement 19:
Regulatory processes shall be open and transparent
The MS shall be continuously assessed and improved
The MS has three purposes:
1) ensure proper discharge of responsibilities,
2) maintain and improve performance of the regulatory body,
3) foster and support a safety culture in the regulatory body
The MS shall maintain the efficiency and effectiveness of the regulatory body
The MS shall specify in a coherent manner the planned and systematic actions necessary to provide confidence that the statutory obligations placed on the regulatory body are being fulfilled
Basic IRRS Training - Reviewing Management System

11. Example
Basic IRRS Training - Reviewing Management System

12. GSR Part 2
Basic IRRS Training - Reviewing Management System

13. GSR Part 2
GSR Part 2: Leadership and Management for Safety The objective of this publication is to establish, sustain and continuously improve leadership and management for safety, and an effective management system. This is essential in order to foster and sustain a strong safety culture in an organization (GSR Part 2 superseded GS-R-3)
Basic IRRS Training - Reviewing Management System

14. Definitions What is Leadership? Management?
Leadership: use of individuals’ capabilities and competences to give direction and to influence their commitment to achieving safety objectives.
Management: formal authorized function for ensuring efficient operation in accordance with plans requirements and resources.
Managers at all levels need to be leaders for safety
Basic IRRS Training - Reviewing Management System

15. GSR Part 2
GSR Part 2 is applicable to all types of facilities and activities that give rise to radiation risks.
Nuclear installations where it is applicable include
Nuclear power plants
Research reactors, critical and subcritical assemblies
Adjoining radioisotope producing facilities
Spent fuel storage facilities
Uranium enrichment facilities
Nuclear fuel fabrication facilities
Conversion and reprocessing facilities
Predisposal management of waste from FCFs
Nuclear fuel cycle related R&D facilities
Basic IRRS Training - Reviewing Management System

16. GSR Part 2 – Responsibility for Safety
Requirement 1: Achieving the fundamental safety objective
The registrant or licensee — starting with the senior management — shall ensure that the fundamental safety objective of protecting people and the environment from harmful effects of ionizing radiation is achieved.
Key aspects: the senior management of organizat-ion shall ensure that provisions are made to achieve the fundamental safety objective by ensuring safety through all specific activities and responsibilities of the organization.
Basic IRRS Training - Reviewing Management System

17. GSR Part 2 – Leadership for Safety
Requirement 2: Demonstration of leadership for safety by managers
Managers shall demonstrate leadership for safety and commitment to safety.
Key aspects:
The senior management of organization shall: stipulate that safety has an overriding priority; establish personal expectations and accountability; foster strong safety culture
All managers shall: set safety goals; develop institutional and individual expectations; encourage reporting of problems; communicate the basis of decisions
Basic IRRS Training - Reviewing Management System

18. Example
Basic IRRS Training - Reviewing Management System

19. GSR Part 2 – Management for Safety
Requirement 3: Responsibility of senior management for the management system
Senior management shall be responsible for establishing, applying, sustaining and continuously improving a management system to ensure safety.
Key aspects:
Senior management shall
retain accountability for the MS
be responsible for establishing safety policy
Basic IRRS Training - Reviewing Management System

20. Example – implementation of an IMS
Basic IRRS Training - Reviewing Management System

21. Not this way!
Basic IRRS Training - Reviewing Management System

22. GSR Part 2 – Management for Safety
Requirement 4: Goals, strategies, plans and objectives
Senior management shall establish goals, strategies, plans and objectives for the organization that are consistent with the organization’s safety policy.
Key aspects:
Goals, strategies, etc. do not compromise safety;
Measurable safety goals
Goals, etc. are periodically reviewed
Basic IRRS Training - Reviewing Management System

23. GSR Part 2 – Management for Safety
Requirement 5: Interaction with interested parties
Senior management shall ensure that appropriate interaction with interested parties takes place.
Key aspects:
Identification of interested parties;
Communicating and informing routinely and effectively
Considering in decision making the concerns and expectations of the parties
Basic IRRS Training - Reviewing Management System

24. Example - Interaction
Basic IRRS Training - Reviewing Management System

25. Who are the interested parties?
Interested parties (stakeholders): customers, owners, operators, employees, suppliers, partners, trade unions, the regulated industry or professionals; scientific bodies; governmental agencies or regulators (local, regional and national) whose responsibilities may cover nuclear energy; the media; the public (individuals, community groups and interest groups); and other States
Basic IRRS Training - Reviewing Management System

26. Recommendation of Experienced Reviewers Give particular attention to:
Management responsibility
Demonstration of management commitment at all levels to the establishment, implementation, assessment and continual improvement of the Management System
Means to collect and address expectations of interested parties and to communicate with stakeholders
Development, documentation and evaluation of organizational policies
Establishment of measurable goals, strategies, plans and objectives
Conduct and follow up of strategic and annual activity planning
Basic IRRS Training - Reviewing Management System

27. GSR Part 2 – Management System
Requirement 6: Integration of the MS
The management system shall integrate its elements, including safety, health, environmental, security, quality, human-and-organizational-factor, societal and economic elements, so that safety is not compromised.
Key aspects:
The MS shall be developed, applied and continuously improved
Arrangements for resolution of conflicts in decision making;
Organizational structure, processes, responsibilities, etc. and the way of their changes clearly defined
Requirement on and the nature of independent reviews before safety significant decisions
Basic IRRS Training - Reviewing Management System

28. Example – organizational structure
What is interesting in the situation observed? Two departments responsible for the MS are not in conformance with the requirements on a MS
Basic IRRS Training - Reviewing Management System

29. GSR Part 2 – Management System
Requirement 7: Application of the graded approach to the MS
The management system shall be developed and applied using a graded approach.
Key aspects:
The criteria used to grade the MS shall be documented by taking into account the safety significance and/or potential hazard/impact of the activity of the organization, including the potential consequences of a failure.
Basic IRRS Training - Reviewing Management System

30. Example – graded approach
Basic IRRS Training - Reviewing Management System

31. GSR Part 2 – Management System
Requirement 8: Documentation of the MS
The management system shall be documented. The documen- tation of the management system shall be controlled, usable, readable, clearly identified and readily available.
Key aspects:
The documentation of the MS shall include at least:
Policy statement
Fundamental safety objectives
Organizational structure
Responsibilities, authorities, accountabilities, interactions
Processes
Interactions with external organizations
The documents shall be controlled, regularly revised, and retained as necessary
Basic IRRS Training - Reviewing Management System

32. Recommendation of Experienced Reviewers Give particular attention to:
Implementation and documentation of the Management System shall concentrate on
Documentation of the Management System, existence of Manual (electronic or paper based)
All regulatory processes and support activities being defined by documented processes
Integration of all requirements on the organization
Priority to safety
Promotion of continuous improvement
Promotion of safety culture
Application of the graded approach
Basic IRRS Training - Reviewing Management System

33. GSR Part 2 – Management of Resources
Requirement 9: Provision of Resources
Senior management shall determine the competences and resources necessary to carry out the activities of the organization safely and shall provide them.
Key aspects:
Ensure full range of competencies for conducting the activities
Determine available in-house resources and need for external competencies
Necessary in-house competencies are: leadership at all levels, safety culture, expertise to understand
Specify individual requirements and ensure training
Knowledge and information are resources
Basic IRRS Training - Reviewing Management System

34. Examples - resources
Basic IRRS Training - Reviewing Management System

35. Recommendation of Experienced Reviewers Give particular attention to:
Resource management
Development of staffing plan
Implementation and follow up of staff training
Resources for the development and improvement of the Management system
Handling of work environment issues
Basic IRRS Training - Reviewing Management System

36. GSR Part 2 – Management of Processes
Requirement 10: Management of Processes and Activities
Processes and activities shall be developed and shall be effectively managed to achieve the organization’s goals without compromising safety.
Key aspects:
Each process should be developed and documented
Sequences and interactions
Development or modification of processes shall be designed, verified, approved and applied so that safety is not compromised
Processes having safety implications are carried out under controlled conditions
Basic IRRS Training - Reviewing Management System

37. Recommendation of Experienced Reviewers Give particular attention to:
Process implementation
Methods for identification and development of processes
Documentation of processes, process maps
Scope of process owner responsibility
Control of working documents
Control of records
Internal and external communication
Management of organizational changes
Basic IRRS Training - Reviewing Management System

38. Example - processes
Basic IRRS Training - Reviewing Management System

39. GSR Part 2 – Management of Processes
Requirement 11: Management of the supply chain
The organization shall put in place arrangements with vendors, contractors and suppliers for specifying, monitoring and managing the supply to it of items, products and services that may influence safety.
Key aspects:
Responsibility is retained even
when contracting
„Informed” or „intelligent” customer
position
The MS includes arrangements on selection of suppliers
The organization makes arrangements for ensuring adherence of supplied items to safety requirements
Basic IRRS Training - Reviewing Management System

40. GSR Part 2 – Culture for Safety
Requirement 12: Fostering Safety Culture
Individuals in the organization, from senior managers downwards, shall foster a strong safety culture. The management system and leadership for safety shall be such as to foster and sustain a strong safety culture.
Key aspects:
All individuals contribute
All managers advocate:
common understanding of safety and safety culture
acceptance of personal accountability
reporting problems
questioning and learning attitude
safety oriented decision making
Basic IRRS Training - Reviewing Management System

41. Example – safety culture
What do you think of this Good Practice? It commends that a safety standard requirement is complied with. May it be a GP?
Basic IRRS Training - Reviewing Management System

42. Requirement 13: Measurement, assessment and improvement of the MS
GSR Part 2 – M&A&I
Requirement 13: Measurement, assessment and improvement of the MS
The effectiveness of the management system shall be measured, assessed and improved to enhance safety performance, including minimizing the occurrence of problems relating to safety.
Key aspects:
The effectiveness of the MS and of its processes shall be monitored and measured
The causes of non-conformances and events shall be evaluated and eliminated
Regular self-assessment and independent assessment of the MS
Regular review of the MS by senior managers
Inclusion of lessons learned and results of development
Basic IRRS Training - Reviewing Management System

43. Example
Basic IRRS Training - Reviewing Management System

44. GSR Part 2 – M&A&I
Requirement 14: Measurement, assessment and improvement of leadership for safety and of safety culture
Senior management shall regularly commission assessments of leadership for safety and of safety culture in its own organization.
Key aspects:
Self-assessment of leadership for safety and SC over all levels
Independent assessment of leadership and SC
The results of assessments shall be communicated and acted upon
Basic IRRS Training - Reviewing Management System

45. A relevant IAEA Safety Guide
GS-G-3.1: Application of the Management System for Facilities and Activities (issued 2006) Contains recommendations and information relevant for the implementation of the requirements in GSR Part 2 (originally in GS-R-3). There is no specific guide on application of Management System requirements on regulatory activities
Basic IRRS Training - Reviewing Management System

46. Interface with nuclear security
IRRS Module 12
Basic IRRS Training - Reviewing Management System

47. Safety/Safeguards/Security
Safety – protect people and environment from ionizing radiation
Safeguards – Prevention of spread of nuclear weapons
Security – Protect nuclear and radioactive material from malicious acts
Basic IRRS Training - Reviewing Management System

48. Relevant IAEA Safety Requirements
There is a single IAEA Safety Requirement publication relevant for the Interface with Nuclear Security and Safeguards: GSR Part 1: Governmental, Legal and Regulatory Framework for safety (rev. 1, issued in 2016) In addition, there are several applicable IAEA documents (Recommendations and Implementing Guides) in the Nuclear Security series. These are not in the scope of an IRRS mission.
Basic IRRS Training - Reviewing Management System

49. GSR Part 1
GSR Part 1 Requirement 12: The government shall ensure that, within the govern-mental and legal framework, adequate infrastructural arrangements are established for interfaces of safety with arrangements for nuclear security and with the State system for, and control of, nuclear material.
Basic IRRS Training - Reviewing Management System

50. GSR Part 1 – Requirement 12 Key aspects
Specific legal responsibilities shall include
Assessment of the configuration of facilities and activities for the optimization of safety
Oversight and enforcement to maintain arrangements for safety, nuclear security and the system of accounting for, and control of, nuclear material
Liaison with law enforcement agencies, as appropriate
Integration of emergency response arrangements for safety related and nuclear security related incidents
Safety measures and nuclear security measures shall be designed and implemented in an integrated manner so that nuclear security measures do not compromise safety and safety measures do not compromise nuclear security
Basic IRRS Training - Reviewing Management System

51. Examples
Basic IRRS Training - Reviewing Management System

52. Summary (1)
Requirements on Management System of the RB are set by GSR Part 1 and GSR Part 2
GSR Part 1 requires establishment, implementation, assessment and improvement of MS
GSR Part 2 describes the MS for all relevant facilities and activities
13 key requirements are set for
Responsibility for safety
Leadership for safety
Management for safety
Culture for safety
Measurement, assessment, improvement
Basic IRRS Training - Reviewing Management System

53. Summary (2)
The interface of nuclear safety with nuclear security is covered by a single requirement in GSR Part 1:
Need for adequate infrastructural arrangements,
Legal framework
Integration
Regulatory oversight
Interface among authorities
Basic IRRS Training - Reviewing Management System

54. THANK YOU FOR YOUR ATTENTION
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
Photo: V. Friedrich
Basic IRRS Training - Reviewing Management System

55. Issues to discuss
How to make sure that the MS reflects a graded approach?
How to check that the MS is fully process oriented?
How to make sure that the MS promotes a good safety culture?
Basic IRRS Training - Reviewing Management System