USNRC IRRS TRAINING Lecture18 Reviewing Regulations and Guides

Outline Learning Objectives Introduction IRRS review of regulations and guides Relevant safety standards Development of regulations and guides Review of regulations and guides Promotion of regulations and guides Contents of regulations and guides Recommendations of experienced reviewers USNRC IRRS Training - Reviewing Regulations and Guides

Learning objectives After finishing this lecture the trainee will: be aware of the two-level approach of reviewing regulations and guides; get an understanding of the contents to be reviewed in the scope of IRRS Module 9; know that the approach and the process for developing regulations and guides depend on the nature of the text (regulation or guide) and the type of facility or activity. USNRC IRRS Training - Reviewing Regulations and Guides

Introduction (1) Regulatory Functions: Authorization (Licensing) Review and Assessment Inspection and Enforcement Development, Review and Promotion of Regulations and Guides (GSR Part 1) USNRC IRRS Training - Reviewing Regulations and Guides

Introduction (2) Safety = protection of people and the environment against radiation risks, and the safety of facilities and activities that give rise to radiation risks = safety of nuclear installations + radiation safety + safety of radioactive waste management + safety in the transport of radioactive material (SF-1) Regulations and Guides must cover these four elements: safety of nuclear installations, radiation safety, safety of radioactive waste management and safety in the transport of radioactive material. USNRC IRRS Training - Reviewing Regulations and Guides

Introduction (3) Regulations establish requirements with which all operators must comply (mandatory, not facility or company specific) USNRC IRRS Training - Reviewing Regulations and Guides

Introduction (4) Guides give advice on how to comply with regulations (not mandatory, not facility or company specific) USNRC IRRS Training - Reviewing Regulations and Guides

IRRS review of regulations and guides First level: review of the development process (GSR Part 1, Requirements 32 – 34) – part of the core modules Second level: review of the contents of regulations and guides (compliance with the relevant IAEA safety standards) USNRC IRRS Training - Reviewing Regulations and Guides

IRRS review of regulations and guides (2) The two-level approach is reflected in the format and template of the mission report: Generic issues (level 1) Thematic issues (level 2), as appropriate: Nuclear Power Plants Research Reactors Fuel Cycle Facilities Radioactive Waste Management Facilities Radiation Sources Facilities Decommissioning Activities USNRC IRRS Training - Reviewing Regulations and Guides

Relevant Safety Standards Process of developing regulations and guides in GSR Part 1, Governmental, legal and regulatory framework for safety GS-G-1.4, Documentation used in regulating nuclear facilities Content of regulations in nuclear safety, radiation safety, transport safety and waste safety requirements relevant to the activities and facilities reviewed USNRC IRRS Training - Reviewing Regulations and Guides

First Level - Development of Regulations and Guides (1) GSR Part 1, Requirement 32 2006-2013: referenced 46 times. The regulatory body shall establish or adopt regulations and guides to specify the principles, requirements and associated criteria for safety upon which its regulatory judgments, decisions and actions are based. USNRC IRRS Training - Reviewing Regulations and Guides

First Level - Development of Regulations and Guides (2) Regulations and guides shall suit the legal system of the State and the nature and extent of the facilities and activities to be regulated, in accordance with a graded approach. the hierarchy of regulatory texts should be described the coverage of regulatory texts should be demonstrated the application of the graded approach should be explained the choice between a performance based approach and a prescriptive approach should be explained USNRC IRRS Training - Reviewing Regulations and Guides

First Level - Development of Regulations and Guides (3) The process shall involve consultation with interested parties. the process should be described for the different types of regulations and guides, and the different elements of safety the interested parties should be identified for the different elements of safety In some countries the general public is one the interested parties. USNRC IRRS Training - Reviewing Regulations and Guides

Example (1) USNRC IRRS Training - Reviewing Regulations and Guides

Example (2) USNRC IRRS Training - Reviewing Regulations and Guides

First Level - Review of Regulations and Guides (1) GSR Part 1, Requirement 33 2006-2013: referenced 22 times Regulations and guides shall be reviewed and revised as necessary to keep them up to date, with due consideration taken of relevant international safety standards and technical standards and of relevant experience gained. USNRC IRRS Training - Reviewing Regulations and Guides

First Level - Review of Regulations and Guides (2) When revising regulations and guides technological advances, research and development work, operational lessons learned and institutional knowledge are valuable USNRC IRRS Training - Reviewing Regulations and Guides

Example (1) USNRC IRRS Training - Reviewing Regulations and Guides

First Level - Promotion of Regulations and Guides GSR Part 1, Requirement 34 2006-2013: referenced 4 times The regulatory body shall notify interested parties and the public of the principles and associated criteria for safety established in its regulations and guides, and shall make its regulations and guides available. USNRC IRRS Training - Reviewing Regulations and Guides

Example USNRC IRRS Training - Reviewing Regulations and Guides

Second Level - Contents of Regulations and Guides (1) Purpose: to review the compliance with the relevant IAEA Safety Standards mapping of IAEA Requirements to national regulations should be available for reviewers (to be included in the ARM) Mapping = table of concordance (different levels of details) USNRC IRRS Training - Reviewing Regulations and Guides

Example USNRC IRRS Training - Reviewing Regulations and Guides

Second Level - Contents of Regulations and Guides (2) General safety requirements relevant to the contens of the R&Gs: GSR Part 4: Safety assessment for facilities and activities GS-R-3: The management system for facilities and activities USNRC IRRS Training - Reviewing Regulations and Guides

Second Level - Contents of Regulations and Guides (3) Relevant specific nuclear safety requirements: SSR-2/1: Safety of nuclear power plants: design SSR-2/2: Safety of nuclear power plants: commissioning and operation NS-R-3: Site evaluation for nuclear installations NS-R-4: Safety of research reactors NS-R-5: Safety of nuclear fuel cycle facilities USNRC IRRS Training - Reviewing Regulations and Guides

Hierarchy and coverage of regulations and guides Recommendation of Experienced Reviewers Give particular attention to: Hierarchy and coverage of regulations and guides Process of developing and issuing regulations and guides roles and responsibilities related to establishing regulations and guides inputs used for the regulations and guides and their updating (IAEA requirements, operating experience feedback, results of research and science…) stakeholder involvement in the process USNRC IRRS Training - Reviewing Regulations and Guides

Review and update of regulations and guides Recommendation of Experienced Reviewers Give particular attention to: Review and update of regulations and guides periodicity of the review of regulations and guides effectiveness of the process transparency of the updating process Mapping of IAEA requirements to national requirements IAEA requirements in the legally binding regulations assurance of complete coverage USNRC IRRS Training - Reviewing Regulations and Guides

Recommendation of Experienced Reviewers Give particular attention to: Implementation of the new regulations to existing or new NPP’s, activities and facilities process for implementation new regulations and guides backfitting strategy (including timeline) for implementing new regulations for existing facilities and activities USNRC IRRS Training - Reviewing Regulations and Guides

Recommendation of Experienced Reviewers Give particular attention to: The following basic material should be made available to the reviewer during the mission (if not, the reviewer should ask for it): process description for developing, updating and issuing regulations and guides mapping of IAEA requirements to national requirements USNRC IRRS Training - Reviewing Regulations and Guides

Summary Regulations and guides form the framework of the regulatory activities They are assumed to be based on IAEA safety standards The reviewer evaluates the extent to which the national regulations implement the relevant IAEA Requirements IRRS mission review may have two levels: First: development, review and promotion (core) Second: contents for specific activities and facilities (optional) USNRC IRRS Training - Reviewing Regulations and Guides

THANK YOU FOR YOUR ATTENTION This activity is conducted by the IAEA, with funding by the European Union. The views expressed in this presentation do not necessarily reflect the views of the European Commission Photo: V. Friedrich USNRC IRRS Training - Reviewing Regulations and Guides

Discussion Involvement of stakeholders and general public (different for regulations and for guides) Management of interfaces with other regulations Prescriptive versus performance based approach USNRC IRRS Training - Reviewing Regulations and Guides