1. “Regulatory Inspection and Enforcement by PNRA” Application Set

2. CONTENTS PNRA inspection policy
Inspection program for nuclear power plants
Types of inspections
Methods of inspection
Areas of inspection
Inspectors qualification criteria
Inspection reports and findings
PNRA Enforcement Process

3. PNRA INSPECTION POLICY
Under Section 16(2)(i) of PNRA Ordinance, PNRA is responsible to inspect all nuclear installations and nuclear material to ensure that regulations concerning safety measures are properly followed.
The purpose of the inspections is to make licensee aware of its ultimate responsibility
The management of PNRA is committed to provide necessary resources for the inspections.
The regulatory inspections cover all structures, systems, components and activities important to safety.
The inspections are performed by PNRA authorized inspectors and are conducted as per approved inspection plan.
The results of the inspections are documented in the form of inspection reports which form the basis for any subsequent enforcement action.

4. POWERS OF INSPECTOR
Under Section 29 of the PNRA Ordinance, an inspector shall have the powers to:
Enter any premises for the purpose of satisfying himself as to whether the provisions of the rules and regulations have been or are being adequately complied with;
Examine designs, drawings, records, reports or documents;
carry out any tests and investigations;
obtain and analyze any samples;
lock and seal any premises, nuclear installation, radiation generator, or any part thereof, where any nuclear substance or radiation generator is being used, stored, operated or maintained

5. PNRA INSPECTION PROGRAM FOR NUCLEAR POWER PLANTS
PNRA inspection program forms the basis for inspection activities of nuclear power plants.
PNRA performs regulatory inspections to ensure compliance with:
national regulations,
conditions attached to the license and;
commitments made by the applicant/licensee for safety
These inspections, however, do not relieve the licensee of its ultimate responsibility for safety
The inspections of nuclear power plants are performed by respective regional Directorates in coordination with the Licensing Directorate (NSD) responsible for authorization and Licensing (NSD)

6. PNRA INSPECTION PROGRAM FOR NUCLEAR POWER PLANTS
The inspection of equipment manufacturing is the responsibility of NSD
The Regional Directorates (R-2) and R-3 located at respective nuclear power plant sites Chashma and Karachi are responsible for inspections
The regional Directorate R-1 is located at Headquarters and is responsible for authorization and inspections of radiation facilities.
PNRA authorized inspectors mainly conducts two types of inspections, namely planned inspections and reactive inspections.
Either type of inspection may be announced or unannounced, however, announced inspections are more common.
The planned inspections are conducted as per approved inspection plan and are generally announced to the licensee in advance, however, un-announced inspections may also be performed.

7. PLANNED INSPECTIONS
are carried in accordance with a baseline inspection plan
may be linked to licensee’s schedule for performing or completion of certain activities at different stages of the authorization process
differ from reactive inspections in that they are scheduled in advance and are not initiated by unusual or unexpected circumstances,
provide an opportunity for detailed examination of the licensee's activities to identify problems at an early stage.

8. REACTIVE INSPECTIONS
initiated in response to an unexpected, unplanned or unusual situation or event to assess its significance and implications and the adequacy of corrective actions.
may be occasioned in response to a generic problem encountered at another plant, or identified during the review and assessment process.
Are conducted by employing maximum resources in case of a serious event
Make use of licensee’s reports of safety related activities or event reports
May involve a multidisciplinary inspection team according to the need of the situation. .

9. ANNOUNCED AND UNANNOUNCED INSPECTIONS
In case of an announced inspection the licensee will be notified in advance by the Regional Directorate
Inspections are announced when PNRA intends to observe a specific test or activity
The main advantages of such inspections are:
the inspector is able to discuss plans and needs with the licensee in advance,
Assurances may be secured from the licensee that documentation or personnel will be available for inspection or interview
Hence, announced inspections may enhance the efficiency of inspections.

10. METHODS OF INSPECTION
Discussion and interviews with the licensee's and contractor's personnel
Monitoring and direct observation (e.g. of working practices and equipment)
Examination of procedures, records and other relevant documentation
Tests and measurements (may be performed only in rare cases e.g. environmental radiation monitoring to verify the data of licensee)
The inspectors are free to make their own judgment whether to use one or more of the above methods in a balanced way depending upon the specific situation.

11. AREAS OF INSPECTION
The major inspection areas/activities which are included in the inspection plan are described below:
Siting
Construction Installation and Equipment manufacturing
Commissioning
Testing before fuel loading
Initial fuel loading and criticality
Power ascension testing
Operation
Decommissioning

12. SITING INSPECTIONS
The inspection plan for siting covers the following areas/activities:
Studies for determining site characteristics;
Excavation and earthwork;
Experiments, if any, to study dispersion models;
Implementation of QAP.
The applicant is required to inform about the work schedules so that PNRA inspectors may perform the inspections.

13. INSPECTIONS DURING CONSTRUCTION AND INSTALLATION
Objective:
To Verify that Construction, Installation, Manufacturing Activities are carried out in accordance with agreed codes & Standards, National& International and adequate Quality Assurance is maintained as per Quality Assurance Programs (QAP).
Document to be consulted:
PSAR,
50-C/SG-Q-1996
Regulatory Guide
Codes & Standards (ACI, ASME, ASTM, IEEE etc)
Design Specs
Equipment Specs
License Conditions, etc

14. INSPECTIONS DURING CONSTRUCTION AND INSTALLATION
Control Point Inspections:
Inspection carried out against selected control points from Q- plans
Hold Point (H)
Witness Point (W)
Record Point (R)
General Surveillance:
To observe the working conditions and activities being taken place without any intimation and objectives as in the case of control points inspections
QA Administrative Inspections:
To verify overall quality assurance system of the organization of licensee and its contractors and sub-contractors

15. EQUIPMENT MANUFACTURING
Main items/activities to be include:
Processes having an effect on the quality of the equipment such as welding, etc.
Qualification tests (seismic and environmental qualification),
Functional tests.
implementation of QAP

16. COMMISSIONING
Control Points for inspections are selected from the Commissioning program which include hold points, witness points and record points
Inspection during the commissioning stage should focus on four broad areas:
Testing before fuel loading (e.g hydrostatic testing of reactor coolant system, containment integrity or leak rate testing, testing of ESF etc.)
Initial fuel loading and criticality and low power testing
Power ascension testing (e.g. Main coolant pump trip, loss of off- site power, turbine trip etc.)
Other commissioning activities such as management of commissioning activities, modifications and maintenance, implementation of RP program etc.

17. OPERATION The areas to be inspected during operation phase include:
Operational limits and conditions
Operating procedures
Control room visits
Radiological protection
Operator training and competence
Effluent and radioactive waste management
Emergency Response Planning and Procedure
Refueling
On-site fuel handling and storage

18. PROVISION OF GUIDANCE TO INSPECTORS
Written procedures which ensure that all nuclear installations are inspected on the basis of a common standard and consistency in the level of safety
Training program of the inspectors emphasizing upon:
legal basis of inspection and the extent of inspector's authority.
applicable regulatory requirements, regulations, guides and industrial standards.
Inspection Program
Policies of PNRA that may affect inspection
Standards of conduct of inspectors
The importance of objectivity and fairness on the part of inspectors and need to respect appropriate facility rules established by the licensee.

19. INSPECTORS QUALIFICATION CRITERIA
Master degree in Nuclear Engineering / System Engineering/Medical Physics, Physical Sciences or
Bachelor Degree in Engineering and more than six months training course in Medical Physics/health physics/ Radiation Protection or related fields.
Successful completion of:
PNRA level-I & level-II (or equivalent) professional training courses.
Training Course on PNRA Regulations
Training Course on Inspection & Enforcement Techniques.

20. INSPECTORS QUALIFICATION CRITERIA
1. Nuclear Safety Inspector
Participation in at least two major inspections, under the supervision of a licensed inspector
Participation in at least ten general surveillances inspections under the supervision of a licensed inspector
2. Physical Protection Inspector
Six (06) inspections on physical protection of nuclear power plants or research reactors.
Ten (10) inspections on physical protection of radioactive sources Category 1

21. NECESSARY SUPPORT FROM LICENSEES
As per the Ordinance, the licensees are bound to provide the inspectors with such equipment, assistance and support as may be necessary for carrying out their responsibilities e.g.
on-site working facilities
transport at the site
access to means of communication
facilitation of access to all pertinent information
copies of the relevant documents
meetings with appropriate staff
personal protection equipment

22. INSPECTION REPORTS AND FINDINGS
The results of the inspections are documented in the form of inspection reports which form the basis for any subsequent enforcement actions.
Report of each regulatory inspection is prepared by the inspector(s) who conducted the regulatory inspection within seven days after the inspection, with the approval of the respective Director.
The approved report is communicated to the respective licensee and circulated to concerned Directorates of PNRA.
Records of all inspection reports are maintained with respect to each nuclear power plant in a retrievable manner.

23. PNRA ENFORCEMENT PROCESS
Under section 44 of PNRA Ordinance, any person who contravenes any provision of the Ordinance and the Regulations issued there under is liable to be prosecuted.
PNRA Enforcement Regulations (PAK/950) provide the mechanism to deal with the violators of the PNRA Ordinance and rules and regulations made there under.
As a general policy of PNRA, the prosecution will be used as a last resort when all the other mechanisms described in the procedure i.e. serving of show cause notice and hearing proceedings do not result in a positive outcome.

24. PNRA ENFORCEMENT PROCESS
Licensees Non-licensees
Reporting of Violation
Assessment of Violation
Issuance of Warning Notice
Issuance of Show Cause Notice
Conduct of Hearing
Issuance of Legal Notice
Filing of Complaint for Prosecution
Cancellation of Licence
Reporting of Offence
Rectification of Violation or Offence C

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