1. IAEA International Atomic Energy Agency

2. IAEA Outline Learning objectives Introduction Authorization Inspection Enforcement 2 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

3. IAEA Learning objectives After finishing this lecture the trainee will: Get understanding about the contents to be reviewed in the scope of the IRRS Modules 5, 7 and 8 Understand that the review should address authorizations in different stages of the nuclear facility like nuclear power plants. Understands that as authorizations, review and assessment and inspections are interconnected, their respective review during IRRS also need coordination. Understand the concept of graded approach in authorization, inspection and enforcement. 3 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

4. IAEA Learning objectives After finishing this lecture the trainee will: Understand the generic and specific requirements related to authorization and inspection for specific types of facilities. Understand how to review different types of inspections. Understand how to review the inspection programme of the regulatory body. Understand how to review the enforcement policy. 4 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

5. IAEA Introduction This Training Lecture covers three IRRS Modules: This Training Lecture covers three IRRS Modules: Module 5: Authorization Module 5: Authorization Module 7: Inspection Module 7: Inspection Module 8: Enforcement Module 8: Enforcement

6. IAEA Complexity of these IRRS modules Complexity of the review depends on complexity of the nuclear programme in the country Each module has its core part (left) and subchapters depending on types of activities or facilities (right) Nuclear power plants are so reviewed together with the general process reviews

7. IAEA Hints about the following slides There is a line under the title with the GSR Par 1 Requirement number looking like this: GSR Part 1, Requirement 7; In 2006-2011 referenced 11 times. This is the number of references to that Requirement by IRRS missions to nuclear countries between 2006 and 2011. Indicates the practical importance of that Requirement. Recommendation of Experienced Reviewers Give particular attention to: Those slides list the most important issues, that have been recognized as such by experienced IRRS reviewers during a series of Consultancies in 2012. Some slides have the following title: 7 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

8. IAEA Review Methods – short reminder Review Methods are explained in detail in Training Lecture 5 – Methodology of review Summary: Three basic methods to acquire sufficient information for an objective review are: A review of written material. Interviews with personnel and other officials. Direct observation of regula- tory body activities in the office and at facilities.

9. IAEA 9 Review is assisted by Report Template Training Lecture 7 – Report writing As presented in Training Lecture 7 – Report writing the Standard Mission report Template gives guidance and assistance in the interviews and in writing the report

10. IAEA IRRS Module 5: Authorization 10 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

11. IAEA Authorization Authorization by the regulatory body shall be a prerequisite for all facilities and activities. The applicant shall be required to submit an adequate demonstration of safety. GSR Part 1, Requirements 23 & 24 In 2006-2011 referenced 12 & 67 times respectively. 11

12. IAEA Types of authorizations Different types for different stages: site evaluation, design, construction, commissioning, operation, shutdown, decommissioning... Authorizations for different activities: operation, maintenance, engineering activities...

13. IAEA Authorization process License amendment, renewal, revocation Independent verification of the safety assessment and traceability of decisions Requirements reflecting graded approach Clear criteria, requirements, safety objectives and independent assessment

14. IAEA Recommendation of Experienced Reviewers Give particular attention to: Coordinate with Modules 3 & 4: Clearly defined roles of stakeholders (government, regulatory body, other regulators...) Competence available to regulatory body Interfaces with others involved in licensing [The license applicant, advisory boards, Technical Support Organizations (rules applied to avoid conflict of interest), public, etc.] 14 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

15. IAEA Facilities and activities For each facility or activity check the situation with respect to standards mentioned on following pages For NPPs the scope of the review is usually quite standard and similar in different countries. For other facilities the scope of the review could be very broad and different from each other. 15

16. IAEA Authorization of nuclear power plants Standards: SSR-2/1 Design, SSR-2/2 Commissioning and Operation, NS-R-3 Site Evaluation, SSG-12 Licensing Process Recommendation of Experienced Reviewers Give particular attention to: Application for authorization Definition of the safety case Documentation of the licensing basis Ageing management 16

17. IAEA Authorization of research reactors Standards: NS-R-4, CoC Research Reactors, NS-R-3, SSG-12 Recommendation of Experienced Reviewers Give particular attention to: Ageing management Safety committees, lines of authority and communications Influence on DBA by experiments and experimental devices Role of the reactor manager Licensing of personnel 17 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body For titles and description of standards see IRRS Training Lecture No. 2!

18. IAEA Authorization of fuel cycle facilities Standards: NS-R-5, NS-R-3, SSG-12, SSG-5, SSG-6, SSG-7, SSG-15 Describe specific authorization requirements for facilities available in the host country. FCF’s: processing, refining, conversion, enrichment, fabrication of UOX and MOX fuel, SF storage, SF reprocessing, fuel cycle research and development installations 18 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

19. IAEA IRRS Module 7 Inspection 19

20. IAEA Inspections The regulatory body shall carry out inspections of facilities and activities. Inspections shall verify that the authorized party is in compliance with the regulatory requirements and with the conditions specified in the authorization GSR Part 1, Requirement 27 ; In 2006-2011 referenced 31 times. 20 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

21. IAEA Types of inspections There shall be programmed inspections and reactive inspections; both announced and unannounced. Regulatory Body should develop and implement a programme of inspections. Inspections shall cover all areas of responsibility of the regulatory body GSR Part 1, Requirement 28; In 2006-2011 referenced 3 times. 21 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

22. IAEA Graded approach Inspections of facilities and activities shall be commensurate with the radiation risks associated – graded approach. GSR Part 1, Requirement 29; In 2006-2011 referenced 31 times. 22 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

23. IAEA Inspection methods (reviews, interviews, walk downs, observation of activities) Reporting the results Planning of inspections Use of third party for the inspection (TSO, inspection organizations, consultants) Joint inspections with other regulators, sharing of inspection results with other regulators Interfaces with authorization, review and assessment and enforcement 23 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body Recommendation of Experienced Reviewers Give particular attention to:

24. IAEA Follow up and closure of corrective actions Manpower available, qualification and training of inspectors Resident/site inspectors Authority of inspectors Use of inspection feedback in the regulatory process 24 Recommendation of Experienced Reviewers Give particular attention to:

25. IAEA Base the review on the following standards NPPs: GS-G-1.3 Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body Research Reactors: NS-R-4 Safety of Research Reactors Fuel Cycle Facilities: NS-R-5, SSG-5, SSG-6, SSG-7, SSG-15 Waste Management Facilities: GSR Part 5, SSR-5, WS-G-2.5, WS-G-2.6, WS-G-2.7, WS-G-6.1, SSG-1, SSG-14, SSG-15, GS-G-3.4 Inspection of facilities 25 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

26. IAEA Inspection of facilities cont. Base the review on the following standards Radiation Sources Facilities: GS-G-1.5, RS-G-1.10 Decommissioning Activities: WS-R-5, WS-G-2.1, WS-G-2.4, WS-G-5.2 26 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

27. IAEA IRRS Module 8 Enforcement 27

28. IAEA Enforcement Policy The regulatory body shall establish and implement an enforcement policy for responding to non- compliance by authorized parties In the event that risks are identified, the regulatory body shall require corrective actions to be taken. GSR Part 1, Requirements 30 & 31; In 2006-2011 referenced 8 & 24 times, resp. 28

29. IAEA Enforcement Policy Criteria for corrective actions, should be established. Enforcement actions may include recorded verbal or written notification, written warnings, penalties and revocation of the authorization. Prosecution may follow in cases where the authorized party does not cooperate 29 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body

30. IAEA Graded approach Enforcement tools and powers clearly defined in the legislation From enforcement to prosecution Safety culture aspects Possibility for the licensee to appeal Interface with authorizations, review and assessment and inspections 30 Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body Recommendation of Experienced Reviewers Give particular attention to:

31. IAEA Transparency and openness Guidance, criteria and examples for different enforcement tools Training of inspectors on the enforcement 31 Recommendation of Experienced Reviewers Give particular attention to:

32. IAEA Summary (1) When reviewing Authorization focus should be on: Checking that authorization is a prerequisite for any nuclear safety related activity Different types of authorizations Authorization process Facility related authorizations

33. IAEA Summary (2) When reviewing Inspection focus should be on: Verification that authorized party is in compliance with regulatory requirements Different types of inspections Graded approach Facility related inspections

34. IAEA Summary (3) When reviewing Enforcement focus should be on: checking, that enforcement is in place to respond to non-compliances Clear criteria for enforcement Graded approach

35. IAEA THANK YOU FOR YOUR ATTENTION 35 Photo: V. Friedrich Basic IRRS Training - Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body 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

36. IAEA Discussion Why is authorization so important, so emphasised in all international standards? Couldn't we simply trust the users to perform their radiation activities or use their nuclear facilities without the licence? Compare the pro’s and con’s of a formal, direct, written request of the inspector in case of incompliance with an open discussion with the licensee looking for the optimum solutions of the recognised weaknesses? Explain an example of graded approach related to inspection activities. What is a better goal for the inspector: as many enforcement actions as possible or as few enforcement as possible? Basic IRRS Training – Reviewing Authorization, Inspection and Enforcement Functions of the Regulatory Body36