1. USNRC IRRS TRAINING Lecture 14
Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body
(IRRS Modules 5, 7 and 8)

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

3. 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.
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

4. 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.
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 4

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

6. 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

7. Hints about the following slides
There is a line under the title with the GSR Par 1 Requirement number looking like this:
GSR Part 1, Requirement 7; In referenced 11 times.
This is the number of references to that Requirement by IRRS missions to nuclear countries between 2006 and Indicates the practical importance of that Requirement.
Some slides have the following title:
Recommendation of Experienced Reviewers Give particular attention to:
Those slides list the most important issues, that have been recognized as such by experienced IRRS reviewers during a series of Consultancies in 2012.
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 7

8. Review Methods – short reminder
Review Methods are explained in detail in
Training Lecture 10 – 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.
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

9. Review is assisted by Report Template
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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

10. IRRS Module 5: Authorization
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 10

11. Authorization
GSR Part 1, Requirements 23 & 24 In referenced 12 & 67 times respectively.
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. 11

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

13. 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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

14. 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.]
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 14

15. Examples (Req. 23)

16. Examples (Req. 24)

17. Facilities and activities
For each facility or activity check the situation with respect to standards mentioned on following pages
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. 17

18. Authorization of nuclear power plants
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 18

19. Authorization of research reactors
For titles and description of
standards see IRRS
Training Lecture No. 17!
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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 19

20. Authorization of fuel cycle facilities
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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 20

21. Examples
Research reactor: Fuel cycle facility:

22. IRRS Module 7 Inspection22

23. Inspections GSR Part 1, Requirement 27;
In referenced 31 times.
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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 23

24. Types of inspections GSR Part 1, Requirement 28;
In referenced 3 times.
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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 24

25. Graded approach GSR Part 1, Requirement 29;
In referenced 31 times.
Inspections of facilities and activities shall be commensurate with the radiation risks associated – graded approach.
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 25

26. Recommendation of Experienced Reviewers Give particular attention to:
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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 26

27. Recommendation of Experienced Reviewers Give particular attention to:
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 27

28. Example (Req. 27)

29. Examples (Req. 28 and 29)

30. Example (Req. 29)

31. Inspection of facilities
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
Waste Management Facilities: GSR Part 5, SSR-5, WS-G-2.5, WS-G-2.6, WS-G-2.7, WS-G-6.1, SSG-1, SSG-14, SSG-15, GS-G-3.4
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 31

32. IRRS Module 8 Enforcement32

33. Enforcement Policy GSR Part 1, Requirements 30 & 31;
In referenced 8 & 24 times, resp.
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. 33

34. 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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 34

35. Recommendation of Experienced Reviewers Give particular attention to:
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
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36. Recommendation of Experienced Reviewers Give particular attention to:
Transparency and openness
Guidance, criteria and examples for different enforcement tools
Training of inspectors on the enforcement 36

37. Examples

38. 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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

39. 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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

40. 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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

41. 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
USNRC IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

42. 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?
Basic IRRS Training – Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body