REGULATORY ASPECTS OF NPP SAFETY

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REGULATORY ASPECTS OF NPP SAFETY

• International Conference on Strengthening of
  Nuclear Safety in Eastern Europe
• Vienna, June 1999

Ján t u l l e r, Petr B r a n d e j s,
Alexander M i a s n i k o v, Miroslav v á
b State Office for Nuclear Safety Czech Republic
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TOPICS TO BE COVERED

• Nuclear Regulations
• Duties of the SÚJB
• Rights of the SÚJB
• Material and Human Resources of the SÚJB
• SÚJB Inspection activities
• Licensing of Temelín NPP Upgrades and
  Backfittings
• Regulatory Position and Practices Concerning
  Review Activities
• Conclusions

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NUCLEAR REGULATIONS (1) (History )

• Supervision over industrial utilization of
  nuclear energy launched by the amendment to the
  Law No.50/1976 Coll., on Land Planning and
  Construction Regulations
• (the Construction Act)
• Construction Act of 1976 established for the
  first time that construction of a nuclear
  installation should require special approvals of
  the Regulatory Body ( CSKAE ) in 3 stages based
  on 3 types of Safety Analysis Reports Siting
  (Initial ) SAR, Preliminary SAR, Pre-operational
  SAR
  
  
  

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NUCLEAR REGULATIONS (2)(History)

• Specific regulations issued
• Decree No. 2/1978 Coll. of the CSKAE, on NPP
  Design
• Decree No. 4/1979 Coll. of the CSKAE, on the
  General Criteria for Nuclear Safety Assurance in
  the Process of Nuclear Power Installations
  Sitting
• Decree No. 5/1979 Coll. of the CSKAE, on Quality
  Assurance of Selected Items in Nuclear Power
  Installations from the Viewpoint of Nuclear
  Safety
• Decree No. 6/1979 Coll. of the CSKAE, on Nuclear
  Safety Assurance in the Process of Nuclear Power
  Installation Commissioning and Operation

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NUCLEAR REGULATIONS (3) (History)

• Other nuclear safety related regulations
• Nuclear Safety Assurance for Nuclear Research
  Installations
• Nuclear Safety Assurance in Radioactive Waste
  Management
  
• Physical Protection of Nuclear Nuclear
  Installations
• Verification of Special Professional Competence
  of Selected Personnel at Nuclear Installations (
  Control Room Operators )
• Quality Assurance of Selected Items with Regard
  to Nuclear Safety of Nuclear Installations (new )

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NUCLEAR REGULATIONS (4) (History)

• First nuclear safety specific Act
• The Act No. 28/1984 Coll., on State Supervision
  of Nuclear Safety at Nuclear Installations was
  issued in 1984. This Act established the body
  which exercised the state supervision over
  nuclear safety independently on manufacturers and
  operators of nuclear installations. The Act
  established for the first time that the
  responsibility for nuclear safety lied with the
  Investor, or when in operation the Operator (
  Responsible Organization ) of the nuclear
  installation.

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NUCLEAR REGULATIONS (5) (Current status )
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NUCLEAR REGULATIONS (6) (Current status)
SELECTED LAWS RELATED TO THE SUJB ACTIVITIES 1.
No.18/1997 on Peaceful Utilization of Nuclear
Energy and Ionizing Radiation, 2. No.2/1969
on the Duties of Ministries and Other
Central Authorities, 3. No.71/1967 on
Administrative Proceedings, 4. No.50/1976 on
Land Planning and Construction
Regulations (the Construction Act), 5.
No.552/1991 on State Inspection and
Monitoring, 6. No.111/1994 on Road Transport.
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NUCLEAR REGULATIONS (7) (Current status)

• January 1997 - new Act No. 18/1997 Coll., on
  Peaceful Utilization of Nuclear Energy and
  Ionizing Radiation
• ( Atomic Act )
• The Act entrusted execution of the state
  administration and state supervision over
  peaceful utilization of nuclear energy and
  ionizing radiation to the SÚJB and newly
  established the province of its authority.The Act
  was developed with the objective to re-codify
  peaceful utilization of nuclear energy and
  ionizing radiation and to cover more adequately
  such issues as radioactive waste management,
  liability for nuclear damage and emergency
  planning .

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NUCLEAR REGULATIONS (8) (Current status)

• Examples of issues determined by the Atomic Act
• - condition of peaceful use of nuclear energy
  and ionising radiation, conditions of performance
  of activities related to nuclear energy
  utilization and activities resulting in
  radiation exposures,
• - requirements for ensuring civil liability in
  case of a nuclear damage,
• - conditions for ensuring safe disposal of
  radioactive waste,
• - requirements related to the state
  administration and supervision over nuclear
  energy utilization, over activities resulting in
  radiation exposure and over nuclear items

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NUCLEAR REGULATIONS (9) (Current status)

• - The Atomic Act transferred into the Czech
  legal system the Vienna Convention on Civil
  liability for Nuclear Damage and Joint Protocol
  related to the Application of the Vienna and
  Paris Conventions, to which the Czech Republic
  had acceded. The gap in the legal system, which
  had been discouraging foreign organizations to be
  active on the market within the Czech nuclear
  program, was adequately closed.
• - The Atomic Act authorizes the SÚJB to issue
  Act related regulations.

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NUCLEAR REGULATIONS (10) (Current status)

• Examples of Atomic Act related regulations
• - Transportation and Shipment of Specified
  Nuclear Materials and Specified Radionuclide
  Sources,
• - Physical Protection of Nuclear Materials and
  Nuclear Facilities and their Classification,
• - Radiation Protection Requirements,
• - Quality Assurance,
• - Criteria for Siting of Nuclear Facilities,
• - Nuclear Safety and Radiation Protection
  Assurance during Commissioning and Operation of
  nuclear Facilities,
• - Nuclear Safety Assurance in the Process of
  Nuclear Installations Designing, Licensing and
  Construction

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DUTIES OF SÚJB (1)

• Examples of duties and responsibilities of
  the SÚJB
• - to carry out State supervision over nuclear
  safety, nuclear items, physical protection,
  radiation protection and emergency preparedness
  on the premises of nuclear installations or
  workplaces with an ionizing radiation source,
• - to issue licenses to perform practices
  governed by the Act and to issue type-approvals
  for packaging assemblies for transport and
  storage of nuclear materials and radionuclide
  source
  

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DUTIES OF SÚJB (2)

• - to monitor, assess and regulate the radiation
  exposure of individuals (professionals and
  public),
• - to issue authorizations for selected personnel
  to perform safety related activities,
• - to approve documentation, programmes, Limits
  and Conditions, concepts of physical protection,
  emergency rules and on-site emergency plans and
  their modifications,

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DUTIES OF SÚJB (3)

• - to establish emergency planning zones and to
  define areas of workplace with an ionizing
  radiation source
• (controlled areas),
• - to carry out the State system of accounting
  and control of nuclear materials,
• - to approve the classification of nuclear
  installations or their components and nuclear
  materials into appropriate physical protection
  categories,
• - to inspect the adherence to the Atomic Act,

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DUTIES OF SÚJB (4)

• - to monitor results in safety related RD area
  and follow modern trends of practices, and in
  this respect to coordinate research activities,
• - to provide information to municipalities and
  District Authorities concerning radioactive waste
  management within their territory of
  administration,
• - to provide the public with adequate
  information concerning the results of SUJB
  activities, unless they are subject to the State,
  professional or commercial secrecy, and once a
  year to publish a report on SUJB activities and
  submit it to the Government of the Czech Republic
  and to the public

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RIGHTS OF SÚJB (1)

• For the execution of the State supervision over
  peaceful utilization of nuclear energy and
  ionizing radiation the Atomic Act gives the right
  to the SÚJB to perform inspection activities.
• The Atomic Act, together with the Act on State
  Inspection and Monitoring, provides sufficient
  instruments to the SUJB to supervise and enforce
  the fulfillment of all relevant requirements for
  nuclear safety and radiation protection.

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RIGHTS OF SÚJB (2)

• Examples of inspection instruments
• inspection instruments include among others the
  right to
• - enter at any time facilities, installations,
  operation areas, territories and other workplaces
  of inspected persons where activities related to
  nuclear energy utilization or practices resulting
  in exposure are being carried out,
• - check the compliance with requirements and
  conditions relate to nuclear safety, radiation
  protection, PP or SGs and make measurements or
  take samples at the premises of inspected
  persons,

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RIGHTS OF SÚJB (3)

• ( inspections instruments )
• - demand evidence of fulfillment of all safety
  relevant obligations,
• - verify professional competence and special
  professional competence,
• - participate in investigations of events
  important for nuclear safety, radiation
  protection, physical protection and emergency
  preparedness, including unauthorized handling of
  nuclear items or ionizing radiation sources,

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RIGHTS OF SÚJB (4)

• Examples of enforcement instruments
• enforcement instruments include the rights of
  any inspector to
• - require the inspected person to undertake
  remedial measures within a set of time,
• - bind the inspected person to perform
  technical inspections, review or tests necessary
  for verification of nuclear safety,
• - withdraw the special professional competence
  authorization ( control room staff licencies ),
• - propose a penalty ( fine ) be imposed

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RIGHTS OF SÚJB (5)

• Examples of Penalties (Fines)
• For a violance of a legal obligation determined
  in the Atomic Act , the SÚJB imposes penalties,
  up to the amount of
• - CZK 100 million to those who violate the
  prohibition of nuclear energy utilization for
  other than peaceful purposes,
• - CZK 10 million to a licensee, violating the
  prohibition of an import of radioactive wastes,
• - CZK 200 thousands to employees of an inspected
  person for a distortion or hiding facts important
  for the inspection performance.

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RIGHTS OF SÚJB (6)

• ( Enforcement instruments )
• - The SÚJB is authorized in case there is a
  danger of delay or a occurrence of undesirable
  situations with an impact on nuclear safety,
  radiation protection, physical protection or
  emergency preparedness, to issue a provisional
  measure imposing on the inspected person the
  obligation to reduce the power output or suspend
  operation of the nuclear installation, to
  prohibit the handling of nuclear items, ionizing
  radiation sources or radioactive waste , or to
  impose on the inspected person the obligation to
  suffer that this handling is performed by another
  person on the expenses of the inspected person.

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MATERIAL AND HUMAN RESOURCES OF THE SÚJB - 1998

• staff 149 (2/3 are nuclear and rad.protection
  inspectors)
• budget 180 million Czech Crowns (6 million US
  )
• National Radiation Protection Institute
• Independent Advisory groups of experts for
  - nuclear safety
  
  - radiation protection
• Activity of Advisory groups is not regulated
  by the law,
• they undoubtedly became a significant
  advisory body for
• important issues of nuclear safety and
  radiation protection.

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MATERIAL AND HUMAN RESOURCES (cont.)
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SUJB - 1999ORGANISATIONAL STRUCTURE
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SUJB - 1999ORGANISATIONAL STRUCTURE (cont.)
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SUJB - 1999ORGANISATIONAL STRUCTURE (cont.)
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SUJB - 1999ORGANISATIONAL STRUCTURE (cont.)
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SÚJB INSPECTION ACTIVITIES (1)

• Three different types of inspection activities
• - routine inspections
  -
  planned specialized inspections
  - ad-hoc inspections
  as a response to certain inadvertent
• situations
• Routine inspections
• cover at nuclear power plant all regular
  activities of the licensee especially with
  respect to the observance of Limits and
  Conditions. These inspections are planned and
  carried out as regular daily observations by SÚJB
  site inspectors . These inspection activities are
  documented monthly in protocols.

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SÚJB INSPECTION ACTIVITIES (2)

• Planned specialized inspections
• - performed in accordance with SÚJB inspection
  plan (prepared for 6 month period)
• - inspection plan is based on
  - results
  of inspections performed during past period
• - operational schedule of Dukovany NPP
• - results of independent safety review
• - conclusions of the SÚJB evaluation effort
• - Usually carried by a team, composed of
  inspectors from
• the headquarters in Prague together with
  site inspectors of
• corresponding NPP.

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SUJB INSPECTION ACTIVITIES (3)

• Ad-hoc inspections
• carried out to examine events and
  failures having impact on nuclear safety, as well
  as to clarify serious findings of the routine or
  planned inspections. Ad-hoc inspections are
  carried out by site inspectors or by inspectors
  from the headquarters in Prague as needed.
• Inspection outputs are
  - inspection
  protocols
  - inspection reports

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SUJB INSPECTION ACTIVITIES (4)

• - Inspection Protocol
  
  every inspection has to be documented by a
  protocol, which is an official document prepared
  by inspector and signed by both sides -
  representatives of inspected organization and
  attending inspectors. The protocol describes
  inspection in details (subject, programme,
  findings, required relevant remedies) and
  reflects results of observation
• - Inspection Report
• inspection report is an internal document of
  the SÚJB which provides additional detailed
  comments and explanations related to findings
  written down in protocol

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SÚJB INSPECTION ACTIVITIES (5)

• SÚJB inspection evaluation process
• There are two general levels of evaluation of
  inspection activities
  
  - Inspection Evaluation Board
  (Committee) level
  - SUJB Board of Managers level
• Inspection Evaluation Board
• - Board is group of SÚJB managers and
  specialist established to review and assess
  inspection activities
• - Board has regular meetings once a month
• - Board determines - necessity of immediate
  SUJB actions
• - changes in the Inspection plan
• - classification of particular
  inspection into Functional Areas

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LICENSING OF TEMELÍN NPP UPGRADES AND
BACKFITTINGS (1)

• Safety Analysis Reports related to the original
  design of Temelín NPP were prepared by the
  licensee and evaluated by the CSKAE in 80-ties.
• Decision on Temelín NPP design modifications made
  in early 90-ties
• Amendments of the original PSAR and relevant
  Topical Reports have been generated by the
  licensee ( format and contents as specified in
  the US NRC R.G.1.70) since 1993
• SÚJB safety evaluation process based on US NRC
  practice ( US NRC Standard Review Plan -
  NUREG-800 )

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LICENSING OF TEMELÍN NPP UPGRADES AND
BACKFITTINGS (2)

• SÚJB licensing team was established and
  formalized ( SÚJB staff experts, headed
  by a project manager) at the very beginning of
  the evaluation process.
• The team has been supported by experts from
  external research institutes, universities and
  technical - engineering organizations.
• Since the very beginning of the NPP Temelín
  design modification project, regular and
  effective communication has been establish
  between SÚJB and licensee.

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LICENSING OF TEMELÍN NPP UPGRADES AND
BACKFITTINGS (3)

• SÚJB has continuously been kept informed on the
  concept of design modifications (related Topical
  Reports submited, presentations given by
  suppliers followed by informal discussions on
  technical and regulatory aspects of the presented
  information).
• Topical Reports are not official licensing
  submittals, but are expected to become reference
  documents to FSAR.
• Drafts of relevant chapters of SAR have been
  submitted to SÚJB.
• SÚJB Requests for Additional information have
  been communicated to the designer via the
  licensee.

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LICENSING OF TEMELÍN NPP UPGRADES AND
BACKFITTINGS (4)

• Licensing database has been developed by the
  SÚJB staff (US NRC assistance program)
  - to specify and
  record all licensing issues
  - to record SÚJB evaluation of individual
  licensing issues
  
  - to keep track of the licensees
  response to individual SUJB requests
  
  - to get quickly a precise
  picture of the actual status of the process
  
  - to use database
  information in decision making with respect to
  resources allocation, planning future
  activities, etc.

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REGULATORY POSITION AND PRACTICES CONCERNING
REVIEW ACTIVITIES (1)

• Czech law and regulations must be unconditionally
  met
• Quality of safety related items has to be
  demonstrated (licensee must among others
  demonstrate the compatibility of components
  taking into account existing original materials,
  functionality of subsystems, synergy of all
  systems, etc...)
• SÚJB requested the deliverables to be licensable
  in the country of origin ( compliance with the
  country of origin regulatory requirements should
  be showen )

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REGULATORY POSITION AND PRACTICES CONCERNING
REVIEW ACTIVITIES (2)

• The possibility to adopt any set of industrial
  standards which would assure the fulfillment of
  legal requirements to protect public health and
  safety and regulatory detailed requirements
  (related for-example to the design) is opened by
  Czech legislative.
• SÚJB is engaged in activities related to the
  verification of the adequacy of codes used to
  perform calculations to assess properties of
  nuclear facilities.

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CONCLUSIONS

• The Czech regulatory activities are fully and
  adequately covered by legal instruments.
• The Czech nuclear safety and radiation protection
  legal framework and regulatory activities are
  fully in compliance with internationally
  recognized good practice and recommendations.