Presentation on theme: "Regulatory project management"— Presentation transcript:
1Regulatory project management VN/RA/01 Task 1&2 WorkshopHanoi, October 2012ConfidentialIlari AroRef. to Kirsi Alm-LytzSTUK
2Outline Regulatory oversight projects Procedures developed at STUKTypical oversight projectsExamples of regulatory project management in new build projectsOL3 - STUK’s role and organisation in licensing stepsSummary of STUK’s competences and resources needed for OL3 project oversightPreparation for regulatory oversight of upcoming new build projectsPVM/NN
3Regulatory oversight projects Regulatory oversight is defined in the legislation and regulationsNew plant projects and plant modifications are initiated by the licensees-> STUK can’t decide whether the regulatory work should be done or not but choice can be made whether the oversight work is performed as projects or within line organisation
4Projects office at STUK/NRR (Department of Nuclear Reactor Regulation) Projects office (PMO) founded in 2002 for the oversight of the OL3 licensingCo-ordinates the regulatory oversight in new NPP licensing process, in NPP operating license renewals and in some larger plant modificationsDevelops the project management procedures for oversight projectsSupports the project managers in project planning and prepares quarterly collective report on projects’ progressProvides resident inspectors for new NPPs under construction
5Development of the project management procedures at STUK/NRR After foundation of Projects unit in 2002 also other oversight works have been co-ordinated as projectsThe detailed guidance for the regulatory project management was finalised in 2010STUK/NRR project model is based on generic project management practices, references e.g.,A guide to the project management body of knowledge (PMBOK guide), ANSI/PMIABC project model, Finnish Project Institute
6STUK/NRR project model Portfolio managementG1G0PEProject ideaEvaluationphasePreparationphasePlanningphaseExecutionphaseClosingphaseProject managementInitiatingProject planningManagement and controlClosingProject executionMSMSEnd productof projectProject documentsProject meeting memosAssessment reportProject charterProject management planProgress reportsList of follow-up itemsPVM/NN
7Regulatory oversight projects Guidance for a single projectDecision of project start, G0 (criteria, project charter template)Project organisation (steering group, project manager, project group, resident inspectors)Project planning (project management plan templates)Project management and control (meeting practices, communication with licensee and other stakeholders, resource management, progress reporting and template)Closing project (closing meeting, assessment report and follow-up list templates)Documentation (record keeping)Project management in STUK/NRRProject classification (ABC model, classification principles and procedures in different classes)Project portfolio management (excel table used by PMO, quarterly project progress reports and portfolio reporting)Engagement in the department’s yearly planning process (resource planning)
8Typical oversight projects New build projectsOperating licence renewals and periodic safety reviewsExtensive plant modifications involvingseveral technical areashigh safety significancelong time schedules (several years)large resource need (several person-months of oversight work)
9Oversight projects of nuclear facilities new nuclear facilitiesFIN5 ( , oversight of OL3 licensing and construction)PAP ( , DiPs for new NPPs)VALVE ( , preparations for FIN6/7 CL appl. review)ONKALO (2005 ->, construction of research tunnels and final repository for spent fuel)operating licence renewals/ periodic safety reviewsKLUPA (Loviisa licence renewal, ended 2007)OLMATA (Olkiluoto periodic safety review, ended 2009)FLUPA (Research reactor licence renewal, ended 2012)large plant modificationsLARA (Loviisa I&C renewal, )LOKIT (Loviisa liquid waste solidification plant construction, )KOPLA (enlargement of Olkiluoto interim storage for spent fuel, )LAMO (modernisation of Loviisa refueling machine, >)DiGU (modernisation of Olkiluoto diesel generators, >)LoPolar (modernisation of Loviisa Polar crane, >)
10Estimated project progress (traffic lights) Project portfolioNameDescriptionClassOwnerManagerGroupScheduleProject phaseEstimated project progress (traffic lights)e.g. FIN5Olkiluoto 3 ...AN.N.N.N., …Project initiated– predicted endPlanning/Execution/Closing-Resources available-Use of resources comparedto the planned-deviations in the submitting scheduleof documents for review-deviations in the quality of submitteddocuments for reviewExcel table collecting information on different projectsIncludes also links to the project charter, project management plan and the latest progress reportProject managers report quarterly on the progress of their projectsOffice head of PMO updates the project portfolio and reports quarterly in the operative and management meetings on the progress of projects and possible resource problems
11Example – Olkiluoto 3, resources for licensing and regulatory oversight
12OL3 Project generally 1/2 OL3 is the first EPR being constructed OL3 is a turn key projectOwner and operator (Licensee) is TVOConstructed by Consortium of Areva and SiemensProject is progressing but is more than five years behind the original schedulePhotos: TVO
13OL3 Project generally 2/2Main civil construction activities finished at the siteCurrent issuesInstallation activities ongoingDesign of instrumentation and control system (independence, testing, qualification)Operating licence application expected during 2013Schedule for Commercial operation under elaboration
14OL3, CL phase - organization, competences and resources 1/4 STUK started preparations for regulatory oversight of OL3 project in 2002 after DIPEstablishment of aproject office and project group to plan and coordinate workproject plan for the oversight (steps, goals, resources, risks, reporting)Discussions withthe utility on the project schedule, content of documents for construction licenceTechnical Support Organisations to establish analysis capabilities needed for independent comparison analysesRegulators with recent licensing and construction experienceRegulators and TSO’s with knowledge on EPR designInspection Organisations possibly needed in the projectResource planningto plan the work of subprojects (technical disciplines)to find out possible expertise gaps.PVM/NN
15OL3, CL phase - organization, competences and resources 2/4 Conclusions of the planning wereSTUK mainly had a core competences to review technical issues presented in PSAR and other documents of CL applicationon the other hand, resources to oversee existing plants was too small - recruiting was necessary.Technical support of TSOs was neededfor new features like airplane crashes, severe accidents (melt retention in core catcher), digital I&C and primary system materials and componentsto perform independent assessments and analyses of design to support STUK’s decision making.co-operation with French regulatory body (ASN) to share experiences of EPR design.PVM/NN
17OL3, CL phase - organization, competences and resources 4/4 OL 3 technical support areas in CL phasePVM/NN
18OL3, construction - STUK objectives 1/2 Review and approval of detailed design documentation for systems, structures and components (SSCs)Before start of construction or manufacturingOversight of and inspections on manufacturing and construction to verify QA and QC activities of manufacturer, vendor and licenseeResident inspectors on site (complemented with staff from HQ)Regular visits at the component manufacturing sitesAssessment of licensee´s performance to verify the adequacy of project management, safety assessment, QA/QC programmes, etc.Quality of the submitted regulatory documentationInspections within the construction inspection programmeResident inspectors at siteAssessment of the performance of the parties responsible for design, construction and manufacturingparticipation as an observer in audits, inspection visits, manufacturing and construction oversight, meetingsPVM/NN
19OL3, construction - STUK objectives 2/2 Inspections during construction can be divided to two categoriesInspections during construction on structures and componentsTo verify QA and QC results and activities of manufacturer, vendor and licensee - product conformityDefined in regulatory guidesInspection organizations used in lower safety classesInspections on licensee’s performance within the Construction Inspection ProgramTo verify the adequacy of project management, safety assessment, QA/QC programmes, etc. - performance conformityPVM/NN
20OL3, Construction phase - organisation, competences and resources Oversight during construction needssame core competences than during CL phase but alsomuch new know-how (e.g. materials, concreting, welding, QA/QC inspections to manufacturers, site supervision...) and human resources when the amount of work is much larger.STUK has continued recruiting as well as using of TSOs and IOstechnical experts recruited from expert organisations, utilities or from “conventional” industry - background from nuclear side not necessarily needed in all tasksIOs are “extension” of STUK - they take STUK’s role as a regulator in lower safety classes.TSOs participate more in STUK’s reviews than make independent analyses.PVM/NN
22Oversight OL3 - mechanical engineering and manufacturing technology Core competences for mechanical engineering, red colour indicates remarkable increase of resourcesNuclear fuel and control rodsMechanical equipmentNuclear power plant pressure vesselsStrength analysisManufacturing technologyMaterial technology and ageingNDIAgeing managementAssessment of QMSUtilization of PRA in inspectionsMaintenanceAssessment of inspection organisations.PVM/NN
23Oversight OL3 - reactor and safety systems Core competences for reactor and safety systemsSafety Principles and Design Basis of NPPDeterministic safety analysisNPP Technology and system design, thermal hydraulicsReactor technology and physics, criticality safetyNuclear fuel technologyContainment functionsI&C functionsSevere accidentsTechnical specificationsEmergency responseOperational safetyPVM/NN
24Oversight OL3 - radiation protection Core competences for radiation protectionRadiation protection - dose controlRadiation protection - dose calculationsRadioactive release (normal operation)Emergency preparedness and rescue services at NPPDispersion of radioactive releases in accidents – source termMeteorology - dispersion of radioactive releasesMonitoring environment of NPPResearch reactorsNuclear waste management.PVM/NN
25Oversight OL3 - risk analysis Core competences for risk analysisPRA in risk informed regulationFire protectionMeteorological and environmental risksSeismic risksPRA-methods (level 1 and 2)PRA software (user skills and development)Operation, MaintenanceReliability of human performanceTheoretical basis of risk analysis.PVM/NN
26Oversight OL3 - electrical and automation systems Core competences for electrical and automation systemsElectrical systems and componentsEmbedded automation of electrical componentsProtection automationAccident instrumentation and accident management systemsSoftware based automation systemsQA & QC, verification and validationOperational automationControl roomAgeing of I&C components.PVM/NN
28Oversight OL3 - project office Core competences for project officeHandling of license applicationsRegulatory control of plant projectsProject managementManagement systems / QA & QA, safety culture issuesModification projectsInterfaces between technical areasSafety analysisPRAOversight at site during construction (resident inspectors).PVM/NN
32YVL 1.1: Construction Inspection Programme The purpose of STUK’s Construction Inspection Programme is to verify that the operations of the construction licensee ensure high-quality construction and implementation in accordance with the approved designs while complying with the regulations and official decisions concerned. In particular, the Construction Inspection Programme assesses and controls the following issues:the licensee’s general operations with a view to constructing the facilitydetailed procedures in the various fields of technology implemented for constructing the facilitydealing with safety matters and consideration of safety in management proceduresthe licensee’s expertise and use of expertisequality management and quality control.
33Construction Inspection Programme The Construction Inspection Programme is divided into two main levels: the upper level assesses the licensee’s main operations, such as project management and resources management, project control, dealing with safety issues and project quality management.The next level, known as the operation level, assesses, e.g., project quality assurance, training of the operating personnel, inspection procedures, utilization of the PSA, document management, radiation safety, and structure and component-specific inspections in the various fields of technology. Furthermore, the emergency response arrangements during construction, physical protection, fire protection and nuclear waste treatment are included in the Construction Inspection Programme within the scope STUK considers necessary.In addition to the above-mentioned inspections, of which the licensee is informed in advance, STUK carries out inspections without prior notice at its discretion.
34Inspections and regulatory control required by YVL Guides STUK controls the construction project, quality management of the construction and the licensee’s safety work with the aid of inspections at its discretion. The inspections pertain, e.g., to the following issues:project management and controlorganization; training, competence and adequacy of the personneldealing with safety mattersimplementation of quality management as a whole and in the different sectorscontrol exercised by the licensee concerning the implementation of quality management by the licensee itself, the facility contractor and their subcontractors.
35Buildings and concrete and steel structures STUK controls the design, manufacture and installation of the buildings and concrete and steel structures important to safety. The control includespre-inspection of structuresinspections at the construction site concerning the readiness to begin workinspections concerning manufactureconstruction inspections of steel structurescommissioning inspections.The safety class of structures is taken into account when determining the scope of control and setting the requirements. The requirements for and control of concrete and steel structures have been described in Guides YVL 4.1 and YVL 4.2. Fire protection at nuclear facilities is discussed in Guide YVL 4.3.Only organizations and persons in their employ that have been granted approval by STUK are allowed to carry out inspections and expert duties subject to licence relating to concrete and steel structures. Guides YVL 1.3 and YVL 4.1 deal with these duties and the approval procedures.
36ComponentsSTUK controls the design, manufacture and installation of pressure equipment and other mechanical components of nuclear facilities. The control includesinspection of the construction plans for componentsapproval of the manufacturers and testing organizationsinspections concerning manufactureconstruction inspectionsinstallation inspectionscommissioning inspections.The safety class of components is taken into account when determining the scope of control and setting the requirements. On the licensee’s application, STUK may approve a separate testing organization to carry out specified control duties. The requirements for and control of mechanical components have been described in Guides YVL 1.3, YVL 1.14 and YVL 1.15 and in YVL Guides of series 3 and 5. Guide YVL 3.0 describes the principles of pressure equipment control. Guide YVL 3.4 presents the requirements for the approval of manufacturers. Guide YVL 1.3 deals with the duties and the approval procedure for inspection and testing duties subject to licence relating to mechanical components.
37ComponentsSTUK controls the design, manufacture and installation of electrical and instrumentation and control equipment of nuclear facilities. The control includes review of the suitability assessment, inspections concerning manufacture and installation to be conducted at STUK’s discretion, and commissioning inspections.The safety significance of the component concerned is taken into account when determining the scope of control and setting the requirements. The requirements for and control of electrical and instrumentation and control equipment have been described in Guides YVL 5.2 and YVL 5.5. Guides YVL 7.9 and YVL 7.10 give the requirements for radiation protection of nuclear facility workers and monitoring of occupational exposure. Other requirements and control concerning the radiation protection and environmental monitoring of a nuclear facility are discussed in guides of the YVL 7 Guide series.
38Nuclear fuelIn accordance with Sections 114 and 115 of the Nuclear Energy Decree, STUK controls that the nuclear fuel is designed, manufactured, transported, stored, handled and used in compliance with the valid regulations.The nuclear fuel licensing procedure and STUK’s regulatory control measures for nuclear power plants have been described in Guide YVL 6.1.Guides YVL 6.2, YVL 6.3, YVL 6.4, YVL 6.5, YVL 6.7 and YVL 6.8 give the requirements for the design, manufacture, transport, handling, storage and use of nuclear fuel.
39Preparations for operation; organization and training In accordance with Section 119 of the Nuclear Energy Decree, STUK controls that the organization operating the facility is appropriate and adequate and that the persons involved in the use of nuclear energy meet the competence requirements and that they are given proper training.Development and training of the operating organization shall begin early enough during the construction of the nuclear power plant (YVL 2.5).When reviewing the administrative rules and organization manual referred to in Section 4.2 above, STUK assesses the appropriateness and adequacy of the licence applicant’s organization and the qualifications required.In accordance with Section 128 of the Nuclear Energy Decree, the operator of the facility systems in the main control room of a nuclear facility shall have STUK’s approval for this job. The requirements for the nuclear power plant operator licensing and the training of personnel have been defined in Guides YVL 1.6 and YVL 1.7.
40Pre-operational testing The purpose of the pre-operational testing of a nuclear facility is to demonstrate that the facility has been constructed and operates as designed. The testing consists of the following stages:system performance testsfuel loading and pre-criticality tests of the reactor systemsmaking the reactor critical and low-power testspower tests.STUK controls the testing of a nuclear facility by reviewing the general testing plans and programmes, by watching the tests at the nuclear facility and by reviewing the documents of test results.The operation of a nuclear power plant is considered to begin when the loading of nuclear fuel into the reactor begins. The reactor loading requires that the Government has granted an operating licence and that STUK has approved the application concerning fuel loading and the reports on the reactor and fuel behaviour in the first operating cycle.
41Pre-operational testing To ensure that the nuclear facility complies with the regulations applied to it, STUK verifies, in accordance with Section 20 of the Nuclear Energy Act, before the fuel loading thatthe documents linked with operation of the facility, referred to in Section 36 of the Nuclear Energy Decree, are acceptable in all respectsthe instruction manuals concerning operation of the facility, including instructions for accidents and transients, are adequatethe organization operating the nuclear facility is appropriate and adequatethe persons involved in the use of nuclear energy meet the competence requirementsthe persons designated as responsible manager for the facility operation and as his/her deputy have received STUK’s approvalthere is a sufficient number of licensed operators at the facilityfor operation of the facility, persons who have received STUK’s approval have been appointed to see to the emergency response arrangements, physical protection and safeguards of nuclear materialsthe commissioning inspections of the facility systems, structures and components have been carried out with acceptable resultsthe results of system performance tests are acceptable insofar as it has been possible to perform the testing without the reactorpre-service inspections of the structures and components have been completedphysical protection and emergency response arrangements are sufficientthe necessary control to prevent the proliferation of nuclear weapons has been arranged appropriatelythe licensee of the nuclear facility has arranged indemnification regarding liability in the case of nuclear damage as prescribed.
42Pre-operational testing The reactor may be made critical and brought to a higher power level in accordance with the decisions taken by STUK.When the testing has finished, the holder of the operating licence shall assess the results of the testing as a whole. The testing results shall be used to assess, for instance, whether any changes in the Final Safety Analysis Report and in the operational limits and conditions are needed. On the basis of this assessment, the licensee shall make the necessary changes in the operational limits and conditions and in the Final Safety Analysis Report, and submit them to STUK for approval.Guide YVL 2.5 deals with regulatory control of the testing of nuclear power plants.
43Preparation for regulatory oversight of upcoming new build projects
44STUK’s preparation tasks for new projects (1/2) Collecting and analysing OL3 experience and lessons learnedCollecting OL3 experience by interviewing project key personsCollection, classification and analyse of OL3 lessons from different sourcesPresenting targets for construction licence review according to the new STUK YVL guidesInfluencing to licence applicants preparation activities and organisational preparednessPossible meetings with licence applicants and vendors concerning plant design, design maturity and siting
45STUK’s preparation tasks for new projects (2/2) Coordinate possible applications, e.g. for material manufacturing before granting the construction licenseAdvancing STUK’s oversight activitiesProducing specifications for project and requirement management toolsPlanning competence and personnel resources for new oversight projectsCooperate with national and international regulatory bodies and organisations
46Summary, project management Oversight of new build, licence renewals and plant modifications can be organised as projects, beneficial when includesseveral technical areashigh safety significancelong time schedules (several years)large amount of resources (several person-months)Generic project management models are applicable for also regulatory oversight projectsProject management processes: initiating, planning, executing, monitoring and control, and closingCost management is reduced to human resource managementGood planning of use of inspection resources is important but sometimes it is difficult to predict the submitted documents and their schedule-> licensing plan
47Lessons to be learned for New Build Regulator need to be well prepared for the project and licensing phasesregulations need to be up-to-date - requirements need to be managedlicensing steps, licensing documentation and regulatory hold points need to be commonly understood by project parties as well as project schedule and expectations to design completioncompetences and human resources for safety evaluations need to be evaluated and ensuredTSO support was indispensable for STUK. It was profitable to:use a limited number of experienced organisationsuse organisations that were familiar with design of the plant - but independent from vendorfocus on the new features.Co-operation with other regulators is a good possibility to benchmark requirements, findings and coverage of the review and inspection work.PVM/NN