First Impressions on the Advance Reference Material for the IRRS Mission to Fantasia

First Impressions on the Advance Reference Material for the IRRS Mission to Fantasia

Name and Country of the Reviewer: Klaus Theiss, Switzerland

Review area (Management System/Authorization/Review & Assessment/Inspection): Review and Assessment

The reviewers are supposed to thoroughly read the Self-assessment Questionnaire and the ARM Summary Report related to their review areas. They are also assumed to be familiar with the IAEA safety standards relevant to their review areas (first of all GSR Part 1) and with the IRRS Guidelines. Prior to the training course the reviewer is requested to return her/his first impressions in the format and with the content as given below.

1.  ISSUES TO INVESTIGATE AND OPEN QUESTIONS

List in brief (possibly in bulleted format) the potential issues that need further interviewing/discussion in order to clarify whether they represent non-compliance with IAEA safety standard requirements. List also those issues which are not clearly described in the Self-assessment Questionnaire or in the ARM Summary Report and need further clarification during the interviews. In the list please identify the location of the issues in the text (e.g. by page number, paragraph number, line number).

·  Does the authorization also include a permit for decommissioning and release from regulatory control and are the documents to be submitted subject to a regulatory review? (ARM 6.1, GSR-1/R26)

·  Why does the licensee perform an independent verification of the safety assessment only in certain cases before submitting the analysis to the regulatory body? (ARM 6.1.1, SQID 1.1, ASUNE Art. 3, GSR-4/R3, GSR-4/R21)

·  Is life extension of NPP (LTO) also an area for regulatory review? (SQID 1.3, GSR-4/Scope 1.8)

·  Is the assessment of ageing effects which might affect safety margins part of the regulatory review? (SQID 1.3, GSR-4/4.16)

·  Has a process be established to develop and maintain the necessary competence of the staff? (SQID 1.4, GSR-1/ R18)

·  Is the assessment of safety functions part of the review of the design basis to demonstrate adequacy and consistent application of the DiD-concept? (SQID 2.2, GSR-4/R7)

·  Why do the final result of the analyses for DBA confirm the effectiveness of the DID exclusively? (SQID 2.3, GSR-4/R13)

·  Which systems for normal operation are classified for BDBA conditions? (SQID 2.4)

·  Which quantitative (safety) criteria are defined for BDBA without significant core damage? (SQID 2.6, GSR-4/R16)

·  Are there any more regulatory guides related to the review area than listed under SQID 3.5 (ARM6.1.3)?

·  Is the internal rule “Procedure for analysis and assessment of safety of nuclear facilities” (QMS-AA-P-01) still under development or accomplished? (SQID 4.9, 6.2, 6.6)

·  Does a regulatory guide exist where the scope of the periodic safety review (PSR) is defined? (SQID 4.11, GSR-1/R32)

·  Does an integrated safety assessment exist where the results of the reviews are collected in a systematic manner? (SQID 4.11, GSR-1/R26)

·  What kind of engineering aspects and human factors will be assessed in the review programme? (SQID 6.1, GSR-4/R10/R11)

·  What are the significant steps in the enforcement process in case the licensee disagrees with the regulatory decision? (SQID 6.10, GSR-1/R31)

2.  POTENTIAL RECOMMENDATIONS

List in brief (possibly in bulleted format) those issues found in the Self-assessment Questionnaire or in the ARM Summary Report which seem to be in non-compliance with an IAEA safety standard requirement related to the review area. Give reference to the requirement non-complied with by Identifying the safety requirement – e.g. GSR Part 1 – the number and subject of the Requirement – e.g. Requirement 23: Authorization of facilities and activities by the regulatory body – and, if possible, the relevant paragraph – e.g. 4.30. Please also identify the location of the issues in the text (e.g. by page number, paragraph number, line number).

·  In the documentation of the regulatory review the scope of the review and the basis of the regulatory decisions should always be specified (ARM 6.1.2, SQID 3.9, GSR-1/R22/4.26)

3.  POTENTIAL SUGGESTIONS

Based on the Self-assessment Questionnaire and the ARM Summary Report list in brief (possibly in bulleted format) any further actions/changes to be performed by the regulatory body that – although are not related to any non-complying activity of the regulator – may contribute to further improvement of the regulatory practice. Give reference to parts of the IAEA safety standard or safety guide (in the form as given in the previous section) that underline and may serve as basis for your suggestion. Please also identify the location of the text that indicate/imply your suggestion.

·  The process for evaluation of support organizations and for acceptance of the contracted work should be part of the overall management system (ARM 6.1.2, SQID1.4, GRS-1/R19)

4.  ANY FURTHER COMMENT OR OPINION

·  Most of the general requirements laid down in GSR-1 and GSR-4 are addressed in the Self-assessment.

·  However, these general requirements (except R25, R26 and R32 of GSR-1 and R4 of GSR-4) are not mentioned explicitly in the Self-assessment.

·  The Self-assessment refers to several regulations (e.g. RPILPSUNE and RESNPP) which are not accessible to the reviewer. The existing regulations should be provided to the reviewer.

·  FNRA develops and applies regulatory guides in areas that are deemed necessary and useful. The guides provide guidance on the application and interpretation of the principles and criteria laid down in the regulation and used by the regulator for the review (SQID3.5, interesting for reviewer of Module 9).

·  According to Art. 45, Para. 1 of the Regulation FNRA can perform inspections at the side to validate the safety assessment submitted by the licensee (SQID 4.3, interesting for reviewer of Module 7).

·  The safety review and assessment process is determined and integrated as a main activity in the overall management system of FNRA (SQID 6.18, interesting for reviewer of Module 4.)

·  The process for the selection of support organizations is described in internal rules and the requirements the TSO have to meet are specified explicitly (SQID 1.5) (potential good practice).

·  The process for review and revision of regulatory guides is described in internal rules and the guides should take into account international best practices and acknowledged international standards (SQID 3.6) (potential good practice).

Give any further comment or opinion you feel appropriate or necessary related to your review. This may include e.g.

·  facts or statements that you consider important to include into the mission report

·  facts or considerations that you consider interesting for reviewers of areas other than yours

·  potential good practices, i.e. activity/practice of the host regulatory body that is outstanding, unique and worth followed by other regulators