Main Requirements on Different Stages of the Licensing

Main Requirements on Different Stages of the Licensing Process for New Nuclear Facilities Module 4. 6 Construction Geoff Vaughan University of Central Lancashire, UK Drafting School, Vienna, December 2012 Module 4. 6 1

IAEA Guidance Currently there is no IAEA Safety Guide on Construction DS 441 is in preparation and comments from Member States are being progressed No version of this is available on the website but DPP 441 is available Drafting School, Vienna, December 2012 Module 4. 6 2

Sources of Information The following slides are based on: • DPP 441 • As a member of the drafting group I have a version of DS 441 with MS comments • NPP Design Requirements Drafting School, Vienna, December 2012 Module 4. 6 3

IAEA Safety Standards Specific Safety Requirements Safety of Nuclear Power Plants: Design SSR-2/1 Drafting School, Vienna, December 2012 Module 4. 5/1 4

SSR 2/1 has only one requirement relevant to construction Requirement 11: Provision for construction Items important to safety for a nuclear power plant shall be designed so that they can be manufactured, constructed, assembled, installed and erected in accordance with established processes that ensure the achievement of the design specifications and the required level of safety. In the provision for construction and operation, due account shall be taken of relevant experience that has been gained in the construction of other similar plants and their associated structures, systems and components. Where best practices from other relevant industries are adopted, such practices shall be shown to be appropriate to the specific nuclear application. Drafting School, Vienna, December 2012 Module 4. 5/1 5

DPP 441 Construction for Nuclear Installations - 1 In the “Background”, DPP 441 notes that: “The status of safety and quality of newly built nuclear installations … has been a global concern, as relevant parties involved in nuclear construction processes may lack experience or resources…” “guidance is needed … [on] … the technical processes and … management systems … to ensure that the nuclear installation is constructed in accordance with the approved design … is particularly important in today’s environment of global supply chains. “ Drafting School, Vienna, December 2012 Module 4. 6 6

DPP 441 Construction for Nuclear Installations - 2 “Recent construction experience has emphasized the importance of the management and supervision of contractors (incl. subcontractors and vendors) and also the issues related to risk management, safety culture, leadership, oversight and management for the design process, experience feedback and handling of non-conformances during construction” Drafting School, Vienna, December 2012 Module 4. 6 7

DPP 441 Construction for Nuclear Installations - 3 Several other IAEA Safety standards are noted as supplying requirements and/or guidance relevant to construction: NS-R-1, NS-R-4 and NS-R-5 require that systems, structures and components (SSCs) be constructed such that their quality and reliability are commensurate with their safety significance (for NPP, RR and FCF respectively). Management system requirements and guidance are provided by : GS-R-3, “The Management System for Facilities and Activities”, GS-G-3. 5, “The Management System for Nuclear Installations”, and GS-G-3. 1, “Application of the Management Systems for Facilities and Activities”. Drafting School, Vienna, December 2012 Module 4. 6 8

DPP 441 Construction for Nuclear Installations - 4 Proposed Contents 1. INTRODUCTION 2. PREREQUISITES FOR THE CONSTRUCTION OF NUCLEAR INSTALLATION 3. THE GENERAL CONSIDERATIONS 4. CONSTRUCTION MANAGEMENT PROGRAMMES FOR STRUCTURES, SYSTEMS AND COMPONENTS REFERENCES GLOSSARY Drafting School, Vienna, December 2012 Module 4. 6 9

DS 441 Construction for Nuclear Installations - 1 Likely Contents 1 Introduction 2 General Considerations 3 Regulatory Oversight of Construction Activities 4 Management System for the Construction of Nuclear Installations 5 Management of Construction Activities References Drafting School, Vienna, December 2012 Module 4. 6 10

The main aim during construction of both the licensee/operator and the regulator is to ensure : the built installation is the as-designed installation or any design changes or additional design features are properly assessed and where necessary given regulatory approval Hence any regulations or guides must be written to ensure that these aims are achieved Drafting School, Vienna, December 2012 Module 4. 6 11

Specific issues covered in DS 441 (draft) include: Safety Culture Construction Management Control of Design Information Transfer of responsibility Control and Supervision of Contractors Manufacturing and Assembling Procurement specifications Cleanliness, preservation, storage of equipment and materials § On-site manufacturing, installation and construction processes § § § § Drafting School, Vienna, December 2012 Module 4. 6 12

Consideration should be given as to what features should be covered in Regulations and Guides , both for the licensee and the regulatory body This should include what work is allowed, and how it will be monitored, before formal construction permit is issued The necessary contacts with other regulatory agencies and their formalisation, should also be considered in such documents Drafting School, Vienna, December 2012 Module 4. 6 13

In overview, Regulations and Guides should cover: The safety case needed before a permit to begin construction can be granted The oversight requirements that the licensee must implement, if a contractor is employed to construct the installation, so as to maintain its responsibility for safety The activities of the regulatory body in review, assessment and inspection both before granting the permit and during the construction activity Drafting School, Vienna, December 2012 Module 4. 6 14

Some points from SSG-12: 1 Before granting an authorization or a licence for the construction of a nuclear installation, the regulatory body should review, assess and inspect: (a)The management system of the applicant or licensee and vendors, as necessary; (b) The site evaluation; (c) The design features important to safety and security; (d) Documentation relating to demonstration of compliance of the selected design with safety objectives and criteria, including validated results from experiments and research programmes; (e) Organizational and financial arrangements for decommissioning and for management of radioactive waste and spent fuel. Drafting School, Vienna, December 2012 Module 4. 6 15

Some points from SSG-12: 2 The licensee should exercise control over the manufacture of structures, systems and components important to safety, and this process should be reviewed, assessed and inspected, as appropriate, by the regulatory body. While controlling such manufacturers under its management system, the licensee should also control subcontractors, suppliers and vendors under its management system. Particular issues arise if part of the supply chain is in other States. The regulatory body should then ensure that there are legally binding arrangements in place allowing the necessary access to documents and to the premises of all organizations; alternatively, such arrangements may be made part of a licence condition, for instance. If a regulatory body intends to visit premises in another State, the visiting regulatory body should inform the regulatory body of the State in which the premises are located Drafting School, Vienna, December 2012 Module 4. 6 16

Some points from SSG-12: 3 The licence to allow construction to begin will be based on a specified design, which may or may not be complete. It is also almost certain that some changes will have to be made during construction Planned deviations from the approved design should be fully analysed in relation to the original design intentions and submitted to the regulatory body for assessment and approval. Drafting School, Vienna, December 2012 Module 4. 6 17

Some points from SSG-12: 4 During construction the regulatory body should have a programme of inspections. These should include “hold points” or “witness points” at particular stages in construction as there are features which would difficult, if not impossible to change or modify at a later stage Consideration should be given to the changes in safety and security requirements when the first nuclear material is brought onto site Drafting School, Vienna, December 2012 Module 4. 6 18

Some points from SSG-12: 5 These include: • radiation protection • emergency preparedness, and • a decommissioning plan, including a waste management plan to demonstrate that sufficient funds to decommission the nuclear installation will be available at the end of operation. A legal framework should be in place to secure decommissioning funds and to protect them from being depleted for other purposes. Drafting School, Vienna, December 2012 Module 4. 6 19

Regulatory Requirements Consideration should be given to the extent of documentation needed to provide guidance to the applicant/licensee and to the regulatory body staff in carrying out work associated with the licensing process Drafting School, Vienna, December 2012 Module 4. 5/1 20