Regulation of Nuclear Power Plants November 2014 Revision
Primary Module: Inspection and Enforcement - September 2014
QID / SQID / QTYPE / References / Primary Question / Answer1 / Primary / GSR Part-1; R 27
/ Does the regulatory body carry out inspections of nuclear power plants to verify that the authorized party is in compliance with the regulatory requirements and with the conditions specified in the authorization? / Yes
If ‘Yes’ go to: / SQID 1.1
If ‘No’ go to: / SQID 1.10
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.1 / Text / Please indicate the legal basis for carrying out regulatory inspections of nuclear power plants. / SQID 1.2
Article 98 (1) of the ASUNE empowers the NRA Chairman to exercise regulatory control over nuclear safety, physical protection and radiation protection involving the use of nuclear energy and ionizing radiation and concerning radioactive waste management and spent fuel management.
According to Para (2) of the same Article, the Chairman carries out:
1. preventive regulatory control, in the issuance of licenses and permits for activities under this Act and for issuing individual employment licenses;
2. current regulatory control over the implementation of the conditions of licenses and permits as issued for activities under this Act and individual employment licenses as issued;
3. confirmatory regulatory control, to verify compliance with the recommendations or directives of control authorities.
In executing of the controlling powers under Article 99 (1) of ASUNE the NRA Chairman shall conduct regular and special inspections through the authorized officials – NRA inspectors.
There are also cases when conducting an inspection is a precondition for further definite actions. For example, according to Article 45 (1) of the Regulation for the procedure for issuing licenses and permits for safe use of nuclear energy, until the beginning of each commissioning stage, a commission of NRA inspectors appointed by the NRA Chairman shall inspect the site for confirming it's conformity with data and circumstances declared and preparedness for carrying out the respective stage. With regard to the stage specificity, representatives of other authorities exercising specialized control may be included in the commission.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.2 / Text / How is it ensured that the applicants/licensees provide regulatory inspectors with free and prompt access to any area of the facility, to all personnel of the facility and to all relevant documentation for the purposes of regulatory inspections? / SQID 1.3
According to Article 100 (2) point 1 of ASUNE the inspectors shall have the right to free access from 0600hrs to 2300hrs Monday to Friday, except Fantasia national holidays, to the regulated licensees and sites, inter alia for inspection of nuclear safety, radiation protection, physical protection and the technical conditions at the nuclear facilities and sources of ionizing radiation, as well as inspection for compliance with the conditions of the licenses and permits issued;
The licenses and permits that are issued contain obligations for ensuring access to the premises and facilities, for delivery of true, accurate and full information and documents and for ensuring cooperation of specialists in the corresponding area of inspection.
The inspectors carrying out inspections in nuclear facilities have access passes with constant 24 hour access issued by the corresponding licensee. The passes are issued after covering the state requirements for working in environment with ionizing radiation (medical certificates) and after clearance for access to strategic sites.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.3 / Text / What are the methods of inspection used by the regulatory inspectors? / SQID 1.4
The methods and techniques applied are described in Procedure for the inspection activities in nuclear facilities, id. № QMS-IA-P-02.
The inspectors clarify deeply and thoroughly the inspected issues to be able to create clear and accurate view on the licensee’s practice.
The information on the practice is acquired from competent representatives of the licensee but through different channels. The inspector reviews the corresponding documents of the design, instructions, records for deviations from operational limits and conditions, records for events, modifications, maintenance records, interviews operational personnel, managers, external organizations’ personnel, carries out walkdowns for inspection of the systems and equipment. At the end the inspector discusses in the form of questions his/her findings with managers at different levels of the organization. On the basis of comprehensive clarification of the problems the inspector concludes whether the requirements are met or not and shares this conclusion with the inspected personnel. In case of necessity the inspector may consult himself with the team leader of the inspection but the formulation of the findings of the inspector’s area of inspection is his/her own obligation.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.4 / Text / Please explain how has the regulatory body ensured and made it clear to the applicants and licensees that the regulatory inspections do not diminish the prime responsibility of the applicant/ licensee for the safety of the nuclear power plant and that the regulatory inspections do not substitute for the control, supervision and verification activities that the applicant/licensee must carry out. / SQID 1.5
The obligations and responsibilities of the operator and of the regulator are defined and clearly separated in the Act on the Safe Use of Nuclear Energy (ASUNE) and the secondary legislation. In this relation the following requirements set in the legislation can be pointed out:
According to Article 14 (3) of ASUNE Licensees and permit holders shall bear the overall responsibility for ensuring the safety of the facilities and activities as specified in the license or the permit.
According to Article 5 (3) of the Regulation on ensuring the safety of nuclear power plants the operating organization bears the full responsibility of ensuring safety, including when other entities implement activities or provide services to the NPP, as well as in relation to the activities of the specialized regulatory authorities in the fields of nuclear energy and ionizing radiation.
According to Article 126 (1) to (4) of the Regulation on ensuring the safety of nuclear power plants the operating organization shall develop, periodically review and implement programs for testing, maintenance, repair, inspection and control for maintaining the operability and reliability of structures, systems and components (SSC) important for safety, according to the design conditions over the plant operating lifetime.
Moreover in the Quality Management Manual which is internal document for the NRA is pointed that through applying regulatory inspections and enforcement measures NRA demonstrates before the government and the public that at any time the activities representing risk for the personnel are carried out safely and in accordance with the regulatory requirements and the regulatory inspections do not relieve the licensee from his full responsibility for ensuring the nuclear safety and radiation protection.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.5 / Text / What inspections does the regulatory body perform at a nuclear power plant during the construction phase? / SQID 1.6
In Procedure for the inspection activities in nuclear facilities, id. № QMS-IA-P-02, Annex 1 the activities of special interest for control during the construction phase of a nuclear facilities are defined:
-mixing and pouring the concrete and the armature positioning in the substructure and in the structures important for safety, especially the containment structure;
-construction of the inlet and outlet channels for cooling water;
-construction of the containment and biological shield, installation of the reactor internals and the equipment in the controlled area;
-installation of the protective, controlling and electrical systems important for safety;
-implementation of “hidden” works, especially systems and components included in the substructures of the buildings;
-the actual condition of the SSC important for safety and of the premises where they are situated;
-quality management systems of the designer, the manufacturer and the contractor.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.6 / Text / What inspections does the regulatory body perform during the commissioning of a nuclear power plant? / SQID 1.7
According to Article 45 (1) of the Regulation for the procedure for issuing licenses and permits for safe use of nuclear energy, until the beginning of each commissioning stage ( initial on-site nuclear fuel storage, initial loading of the reactor core and testing at a sub-critical condition, initial reactor criticality and low-power testing, initial power start-up of the unit at stage-by-stage power increase), a commission of NRA inspectors appointed by the NRA Chairman shall inspect the site for confirming it's conformity with data and circumstances declared and preparedness for carrying out the respective stage.
In Procedure for the inspection activities in nuclear facilities, id. № QMS-IA-P-02, Annex 1 the activities of special interest for control during the commissioning phase of nuclear facilities are defined.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.7 / Text / What inspections does the regulatory body perform at an operating nuclear power plant? / SQID 1.8
NRA performs planned and reactive inspections. The legislation does not exclude performing unannounced inspections but that is not the practice in NRA. The operational control at the site of NPP Kozloduy fulfils the goals of the unannounced inspections because the resident inspectors carry out everyday monitoring of the fulfilment of the operator’s obligations.
The planned inspections are related to the control over the fulfilment of the conditions in the licenses and permits issued by NRA. Some of these inspections are on very specific areas or topics (topical inspections). In Procedure for the inspection activities in nuclear facilities, id. № QMS-IA-P-02 the following areas of inspection in nuclear facilities are defined:
-operation;
-maintenance and repair of SSC important for safety;
-structures, systems and components important for safety;
-systems for management of the activities;
-radiation protection and radioactive waste (RAW) management;
-engineering support;
-operational experience feedback;
-physical protection;
-application of the safeguards under the Treaty on the Non-Proliferation of Nuclear Weapons.
Other planned inspections cover wide range of topics (complex inspections), such as the readiness of the units for start up and operation after planned annual outages. During these inspections the following are being inspected: implementation of the planned repair activities; the results of the functional tests of SSC important for safety; the modifications of SSC, including updating the operational documentation and personnel training; the fulfilled metal control of the main equipment; the performed activities on refueling of the reactor core; observation of the water chemistry; radiation protection measures; the corrosion control carried out; the condition of the high-risk equipment; the metrological control of the means and the channels for measuring; operational events and implementation of corrective measures; actual condition of premises and equipment including availability of operational documentation at the work places; sufficiency and qualification of the personnel.
Reactive inspections are carried out as a consequence (reaction) of unplanned, unexpected or unusual situation or event occurred in the nuclear facility. The inspections can be initiated by a single or series of events including problems arising form the international experience or form assessment of the condition of the nuclear facility carried out in NRA. These inspections are performed by the inspectors individually or in a team with enough experts with appropriate knowledge, skills and experience.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.8 / Text / What inspections does the regulatory body perform during the decommissioning of a nuclear power plant? / SQID 1.9
In Procedure for the inspection activities in nuclear facilities, id. № QMS-IA-P-02 the following areas of inspection in nuclear facilities during decommissioning are defined:
-adequacy of the procedures for control of the fulfilment of the activities;
-relocation of radioactive materials;
-radioactive waste management strategy;
-fluids drainage;
-decontamination and dismantling activities;
-strategy for treatment, conditioning, storage and burial of RAW;
-the actual condition of the nuclear facility and especially the surveillance of the integrity and/or availability of the corresponding SSC including the protection barriers;
-characteristics of the residual activity;
-physical protection and access control;
-monitoring of the environment, radiological monitoring and surveillance, radiation protection of the personnel and the public;
-maintenance of the systems for control and management of the long-term safety;
-records keeping.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
1 / 1.9 / Text / Does the regulatory body carry out inspections of facilities and activities to verify that the authorized party is in compliance with safety requirements and the conditions upon which authorization is granted? / PQ 2
According to Article 5 point 3 of ASUNE the NRA Chairman shall supervise the fulfilment of safety requirements and standards related to the safe use of nuclear energy and ionizing radiation, radioactive waste management and spent fuel management, and of the conditions of licenses and permits issued, including supervision of nuclear safety related high-risk equipment during commissioning, operation and decommissioning of nuclear power plants;
According to Article 98 (2) point 2 of ASUNE, the NRA Chairman shall carry out current regulatory control over the implementation of the conditions of licenses and permits as issued for activities under this Act and individual employment licenses as issued.
The whole inspection activity of NRA has as a goal the verification of the compliance of the activities carried out with the requested from and permitted by the licenses and permits activities.
QID / SQID / QTYPE / References / Primary Question / Answer
2 / Primary / GSR Part-1; R 27, R 28, R 29, para 4.50, para 4.52, para 4.53 / Do regulatory inspections of nuclear power plants cover all areas under the regulatory body's responsibility? / Yes
If ‘Yes’ go to: / SQID 2.1
If ‘No’ go to: / SQID 2.3
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
2 / 2.1 / Text / GSR Part-1
/ How has the regulatory body ensured that its inspection activities cover all areas relevant for the safety of nuclear power plants? / SQID 2.2
The inspection activities performed by NRA cover all areas of the regulation defined in ASUNE.
The inspection policy of NRA is based on the main safety principles – all safety related activities of the licensee are subject to independent regulatory control and the attention paid to every activity is corresponding to its safety importance. The inspection areas are defined on the basis of the IAEA documents and more specifically on the guide for the OSART missions of IAEA.
The specific considerations taken when planning the NRA inspections are:
-all activities included in the licenses are subject to regulatory control;
-the conditions defined in the licenses and permits;
-the approach is: review from general issues at management level to review of specific (detailed) processes and activities at lower organizational level;
-the results from previous inspections;
-the safety analyses done by the licensee and the results form the NRA review and assessment;
-safety indicators trends;
-operational experience feedback;
-current issues: major modifications, implementation of measures form the program developed after the stress tests or event related to safety.
QID / SQID / QTYPE / References / True Subsidiary Question / Next Q
2 / 2.2 / Text / Please provide information on the regulatory inspection activities covering the safety related activities of suppliers of services and products to the applicant / licensee. / PQ 3
The activities of the operator carried out by subcontractors are included in the scope of control of every stage of the lifetime of the nuclear facility.
Topical inspections are carried out on the quality management system of the operators in which are defined the main stages of choosing external organizations, access to the site for work activities, control of the activities and acceptance of the work done.
NRA assesses the way operators control the external organizations. During regulatory inspections for the readiness of the units for operation after planned annual outage the schedules for control of the external organizations, the results from that control and the corrective measures taken are inspected.
Part of the documents of the external organizations is submitted through the applicants (licensees) and is assessed by NRA experts in the frame of the licensing procedures. If questions or remarks have come out NRA together with the applicants (licensees) organize meetings with the subcontractors for clarifications. Such an approach is a regular practice especially on safety related issues but the contacts are carried out through the applicant (licensee) who has the responsibility for the quality of the services. Such examples are the inspections and the meetings with subcontractors on the modernization of the safety systems in units 5 and 6 in NPP Fantasia. Meetings for clarifications, external expertise of documents, two inspections on specific issues (metrology of channels and stands, development of procedures for changes in the software, documenting the processes, etc.) have been done. Another example is the contacts of NRA with the subcontractors during the replacement of the Fast Acting Steam Isolation Valves. Details and issues have been clarified by correspondence and inspections at the place.
The NRA inspection plan for 2013 foresees topical inspection for assessment of the work of the NPP with external organizations.
The conditions of the licenses for operation include obligation for ensuring access to the premises and facilities for the persons delivering equipment and services.
QID / SQID / QTYPE / References / Primary Question / Answer