1. REGULATORY OVERSIGHT OF HUMAN AND ORGANIZATIONAL FACTORS (HOF) DURING DIFFERENT STAGES OF INDIAN NUCLEAR POWER PLANTS REGULATORY OVERSIGHT OF HUMAN AND ORGANIZATIONAL FACTORS (HOF) DURING DIFFERENT STAGES OF INDIAN NUCLEAR POWER PLANTS R. P. Gupta Nuclear Projects Safety Division ATOMIC ENERGY REGULATORY BOARD December 14-18, 2015 [IAEA Technical Meeting [J5-TM-50015_HOF]

2. 2 OUTLINE REGULATORY FRAMEWORK STRATEGY TO OVERSEE HOF REGULATORY FUNCTIONS TO SUPERVISE HOF MECHANISM TO COLLECT AND REVIEW HOF ASPECTS AERB’s ORGANIZATION AND MANAGEMENT PROVISIONS TO DEAL WITH HOF LESSONS LEARNT ON HOF

3. 3 ATOMIC ENERGY ACT, 1962  Radiation Protection Rules, 2004;  Safe Disposal of Radioactive Wastes Rules, 1987;  Atomic Energy (Factories) Rules, 1996;  Working of the Mines Minerals and Handling of the Prescribed Substances Rules, 1984, and  Radiation Processing of Food and Allied Products Rules, 2012; S.O.4772 [CONSTITUTION OF AERB]  Section 16 : Control over radioactive substances  Section 17 : Special provisions as to safety  Section 23 : Administration of Factories Act,1948 REGULATORY FRAMEWORK

4. 4 Functions of AERB Major functions include:  Development of regulatory/ safety documents  Review and assessment for consenting process  Regulatory Inspections and Enforcement As per SO 4772, the review areas pertaining to HOF include:  Training programme, qualifications and licensing policies  Prescribe the syllabi for training of personnel in safety aspects at all levels.  Operational experience in the light of the radiological and other safety criteria AERB has established a documented consenting process [AERB/SC/G, AERB/NPP&RR/SG/G-1] REGULATORY FRAMEWORK

5. 5 Regulatory Oversight Rule PreparationRule EnactmentRegulatory OversightEnforcement

6. 6

7. 7 OPEARTING NPP IN INDIA NPP Status TAPS-1&2 BWRs 220 MWe [KGS-1 to 4, RAPS 3-6, KAPS-1&2, NAPS-1&2, MAPS-1&2, RAPS-1&2] 540 MWe [TAPS-3&4] PHWRs 1000 MWe [KK NPP-1] VVER

8. 8 NPP IN INDIA (UNDER CONSTRUCTION/ COMMISSIONING) NPP Status 500 MWe PFBR 1000 MWe [KK NPP-2], KK NPP3&4 VVER 700 MWe [KAPP-3&4, RAPP-7&8, GHAVP- 1&2] PHWR 1600 MWe [JNPP-1 to 6] EPR

9. 9 HOF - General GOVERNMENT WORK STAFF REGULATORS UTILITIES MANAGEMENT ACT, RULES, LAWS REGULATIONS ORG. POLICIES PLANS ACTIONData, Logs, Observations Reports Operational Reviews Incident Reports Analysis

10. 10 HOF - General

11. 11 HOF - General Organization Environment Tasks Technology PEOPLE INFLUENCES ON HUMAN PERFORMANCE

12. 12  SITING  CONSTRCUTIN  Site Excavation  First Pour of Concrete  Equipment Erection  COMMISSIONING  Phase-A  Phase-B  Phase-C  OPERATION  DECOMMISSIONING REGULATORY FRAMEWORK CONSENTING PROCESS

13. 13 General requirements common for all stages  Organization Structure, Responsibilities and Authorities  Organization structure defining roles/ responsibility and authority, interfaces  QA Program implementation o Managing o Performing o Assessing  Managing the Organisational Changes  Reasons for changes  Plan, control, communication, monitoring, documentation  Competence  Qualification, Experience, Training, Certification, Authorization  Safety Culture  Establish, promote support STRATEGY TO OVERSEE HOF

14. 14 STAGE SPECIFIC REQUIREMENTS SITING Siting of NPP requires diverse inputs from different groups/ organisation/ concerned departments of Central Government, State Government and other reputed institutions/ research centers having specialization in the particular field.  RO to appoint an Entity Responsible for Siting (ERS)  Coordination for planning and evaluation of Site selection  Quality of inputs (Direct / indirect, Laboratory test, current/ historical records) [AERB/SC/S, AERB/SG/S-10] DESIGN  Layout/ deign considerations for HMI  Effect of human error  Time for human action  Designer to specify minimum staff requirement  Operational feedback  Validation [AERB/SC/D for PHWR and LWR, AERB/SC/Q and AERB/SG/QA-1] STRATEGY TO OVERSEE HOF

15. 15 STAGE SPECIFIC REQUIREMENTS PROCUREMENT  Adequacy of design specifications  Planning, performance, assessment  Vendor evaluation MANUFACTURING/ CONSTRUCTION  QA Program describing overall arrangements (planning, performance, assessment)  Organization composition having representation of commissioning/ operation  Control on outsourcing / Sub-contracting  Delegation of powers  Receiving, storage and handling and preservation of equipment  System of Transferring from one agency to other agency [AERB/SC/QA, AERB/SG/QA-2, QA-3 & QA-4] STRATEGY TO OVERSEE HOF

16. 16 STAGE SPECIFIC REQUIREMENTS COMMISSIONING AND OPERATION  Organization structure with defined responsibilities and Interfaces (Designer, Manufacturer, R&D etc.)  QA Program, Test sequences, planning, performance and review/ assessment  Unexpected results/ unusual occurrences  Documentation  Training/re-training, qualification, certification/Licensing program  Licensing of personnel, minimum specified staff  Administrative controls/ procedures  Modifications  Working environment ( psychological, physiological and attitudinal aspects) [AERB/SC/O, AERB/SC/QA, AERB/SG/O-1, AERB/SG/QA-5] STRATEGY TO OVERSEE HOF

17. 17 STAGE SPECIFIC REQUIREMENTS DECOMMISSIONING  Organization structure with defined responsibilities and Interfaces (designer, manufacturer, R&D etc.)  Transfer of responsibilities  Transfer of records  Decommissioning plan, philosophy at the design stage  Periodic review/ revision of the decommissioning plan [ AERB/SC/G, AERB/NRF/SC/RW, safety guides issued there under and safety manual AERB/SM/Decomm-1 ] STRATEGY TO OVERSEE HOF

18. 18 Three major regulatory functions through which AERB supervise the HOF in NPP: REGULATORY FUNCTIONS USED TO SUPERVISE HOF Development of regulatory/ safety documents specifying the requirements/ providing guidance Review and assessment for verification of compliance prior to issuance of consent  By staff of regulatory body  Safety committees  Experts Regulatory Inspections  Planned with full scope  Planned (Special) with specified scope  Reactive Inspections  Surprise Inspections

19. 19  Documented consenting process described in safety guide AERB/ NPP&RR/ SG/G-1.  RO is required to submit Application along with supporting documents (including HOF aspects) in timely manner.  Periodically report progress report/ performance report by RO to AERB  Reporting of modifications and change in organization  Reporting of deviations/ violations/ failures or significant events in timely manner including RCA and corrective/ preventive actions  Multi-tier safety review of above by AERB  Verification of compliance during regulatory inspections MECHANISM TO COLLECT AND REVIEW HOF RELATED OVERSIGHT AND FINDINGS

20. 20  A group assigned for management of human resources (HR)  Procedure issued as a part of integrated management system (IMS) of AERB  Implementation of competence mapping plan for AERB staff  Periodic assessment of competence  Technical support from other sources such as academic/ R&D institutions/ Industries  Multi-tire safety review  Application of graded approach in regulatory processes AERB’s ORGANIZATION AND MANAGEMENT PROVISIONS TO DEAL WITH HOF

21. 21 Experience in regulation of nuclear and radiation facilities, review of event reports (ERs/SERs and IAEA-IRS) AERB has introduced following steps to identify and deal with HOF: Introduced regulatory requirement for submission of reports on significant events/ change in timely manner based on criteria specified by AERB; Introduced regulatory requirement of submission of “Basis of Acceptance” document for safety critical equipment; Inclusion of requirement related to issuance of RO’s Policy on outsourcing of services Planning to carryout inspections to check implementation of QA program at design, procurement and off-site manufacturing stages; Organizational support in accident management Regulatory oversight on EOPs, whose success depends on human performance; In deterministic safety analysis, aspects related to credit of operator actions are also are checked; Review of analysis of Human Error Probability and its contribution to CDF as part of PSA LESSONS LEARNED ON THE REGULATORY OVERSIGHT OF HOF

22. 22 Safety Assessment after major Nuclear Accidents Unambiguous organisation structure for implementation of severe accident management (SAM) program ; Emphasis on factors such as communication under stressful conditions; Ability of response to adverse condition (decision making, crisis leadership, followership, and team work etc.); Regular assessments of effectiveness of its regulatory processes and endeavors for improvements. IRRS feedback AERB is developing action plan to further enhance the staff with specialized competence, knowledge, skills and abilities in the area of human and organizational factors (HOF). LESSONS LEARNED ON THE REGULATORY OVERSIGHT OF HOF

23. 23 THANK YOU