1. USNRC IRRS TRAINING Lecture18
Reviewing Regulations and Guides

2. 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

3. 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

4. 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

5. 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

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

7. 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

8. 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

9. 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

10. 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

11. First Level - Development of Regulations and Guides (1)
GSR Part 1, Requirement 32
: 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

12. 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

13. 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

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

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

16. First Level - Review of Regulations and Guides (1)
GSR Part 1, Requirement 33
: 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

17. 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

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

19. First Level - Promotion of Regulations and Guides
GSR Part 1, Requirement 34
: 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

20. Example
USNRC IRRS Training - Reviewing Regulations and Guides

21. 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

22. Example
USNRC IRRS Training - Reviewing Regulations and Guides

23. 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

24. 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

25. 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

26. 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

27. 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

28. 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

29. 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

30. 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

31. 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