SISC Integrated System for NPPs SupervisionSpanish Reactor Oversight

“ SISC ” Integrated System for NPP´s Supervision-Spanish Reactor Oversight Process Teresa Labarta, Olvido Guzmán, (CSN) Beatriz Gómez-Argüello (TECNATOM) 2006 ISOE INTERNATIONAL SYMPOSIUM, ESSEN

CSN INTRODUCTION In November 2000 a joint committee (RB-licensees) was set up to work jointly on the improvement of the efficiency of the regulatory process, the objectives being: üTo compile the ongoing activities developed by the CSN and the nuclear sector focused on this item. üTo select a few representative countries (including those that are design suppliers of Spanish NPP) and analyse their regulatory framework. üTo analyse the proposal issued by NEA and IAEA. üTo identify actions to be developed in order to improve the regulatory process, attending to their scope and priority. SISC- WG concluded recommending the adoption of a less prescriptive process, addressed to the surveillance process, based on performance and risk significance

CSN INTRODUCTION ROP had started in USA in a consistent and effcient manner USA Tecnology dominant in Spanish NPP The WG recommended the adoption in Spain of a simmilar system, introducing necessary adaptations to our national context SISC 2006 Pilot phase 01/2007 Official phase SISC-

CSN INTRODUCTION SISC program is an Integrated System for Spanish NPP´s Supervision, as result of the adaptation of the “Reactor Oversight Process” from NRC (EEUU) SISC is intended to fulfil the following four goals : üTo maintain safety by establishing a regulatory oversight framework that provides assurance that plants continue to be operated safely by plant operators. üTo enhance public confidence in the CSN´s regulatory program by increasing the predictability, consistency, objectivity and transparency of the oversight process. üTo improve the effectiveness, efficiency, and realism of the oversight process by focusing both agency resources and utility resources on those issues with the most safety-significance SISC- üTo reduce unnecessary regulatory burden as the process becomes more efficient and effective.

CSN INTRODUCTION SISC structure: Three Strategic performance Areas: Reactor Safety, Radiation Safety and Safeguards. Seven Cornerstones of Safety: üInitiating Events üMitigating Systems üBarrier Integrity üEmergency Preparedness üPublic Radiation Safety üOccupational Radiation Safety üPhysical Protection SISC Three Cross-Cutting Areas: Human performance, Safety Conscious Work Environment and Corrective Action Program SISC-

CSN SISC- DESCRIPTION

CSN SISC STRUCTURE SISC process is structured in the following steps: 1. NPPs Surveillance- By Performance Indicators and CSN Inspections. 2. Inspection Results Assesment- Evaluation of Indicators and Inspection Findings according to its safety importance and its risk impact. 3. Regulatory Actions- That will depend on the assessment results. SISC- 4. Communication to the Public- Public information of the SISC program results.

CSN SISC STRUCTURE 1) Information gathering by CSN From two sources: -Performance Indicators (PIs). Reported by the licensee quarterly. -Inspections. Findings resulting from CSN's inspection program. SISC-

CSN SISC STRUCTURE 2) Evaluation of the information gathered Checking of the indicator values submitted by licensee and determine the safety significance of inspection findings through the Significance Determination Process. (SDP), assigning a specific colour to each of them. SISC-

CSN SISC STRUCTURE 3) Regulatory actions- CSN response The PIs and inspection findings are used as assessment inputs to the Action Matrix. The first level of the Action Matrix corresponds to the Licensee Response column. The next four columns correspond to four levels of regulatory response increasing (including orders for plant shutdown) as plant performance declines. SISC-

CSN SISC STRUCTURE 4) Information/Communication One of the main objectives of SISC program is to provide objective and clear information to the licensee and public about the NPPs performance. The results of the Inspection Findings and Performance Indicators will be public. SISC- It is still pending the definition of the different levels of information for utilities, stakeholders and public in general.

SISC DESCRIPTION CSN COMMUNICATION CSN RESPONSE • • ASSESMENT PROCESS (ACTION MATRIX) MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS SAFETY CORNERSTONES Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK –INFORMED BASELINE INSPECTIONS SISC- Ý ASSESMENT REPORTS AND INSPECTION PROGRAMS ENFORCEMENT SUPLEMENTAL INSPECTIONS PUBLIC MEETINGS PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES PERFORMANCE INDICATOR THRESHOLDS PERFORMANCE INDICATORS

SISC DESCRIPTION CSN COMMUNICATION CSN RESPONSE • • ASSESMENT PROCESS (ACTION MATRIX) MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS SAFETY CORNERSTONES Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK –INFORMED BASELINE INSPECTIONS SISC- Ý ASSESMENT REPORTS AND INSPECTION PROGRAMS ENFORCEMENT SUPLEMENTAL INSPECTIONS PUBLIC MEETINGS PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES PERFORMANCE INDICATOR THRESHOLDS PERFORMANCE INDICATORS

INDICATORS CSN A Performance Indicator is a quantitative and objective measure of a particular attribute of licensee performance that indicates how well a plant is performing when measured against established thresholds SISC- Licensees submit this data quarterly, and the CSN regularly performs verification inspections of their submittals

CSN INDICATORS ü There are 15 indicators corresponding to the safety cornerstones (10 for reactor Safety, 2 for Radiation Safety and 3 for Emergency), which are common to all Spanish NPPs. ü Risk-informed thresholds have been developed for both the PIs and inspection findings to establish performance bands. SISC-

CSN COLOUR CODE GREEN- It indicates performance within an expected performance level in which the related cornerstone objectives are met. WHITE- It indicates performance outside an expected range of nominal utility performance but related cornerstone objectives are still being met. YELLOW- It indicates related cornerstone objectives are being met, but with a minimal reduction in safety margin. RED- It indicates a significant reduction in safety margin in the area measured. SISC-

CSN SISC- THRESHOLD BANDS

CSN INDICATORS n OCCUPATIONAL RADIATION SAFETY INDICATOR “Occupational Exposure Control Effectiveness” This indicator monitors the control of access to and work activities within radiologically-significant areas of the plant and occurrences involving degradation or failure of radiation safety barriers that result in readily-identifiable unintended dose. ü Occurrences in Restricted Permanence areas - non conformance with the radiological protection manual requirements in these areas ü Occurrences in Prohibited Access areas - Idem ü Unintended Exposure occurrences - A single occurrence of degradation SISC or failure of one or more radiation safety barriers that results in unintended occupational exposure exceeding a effective dose of 1 m. Sv SISC-

CSN INDICATORS n PUBLIC RADIATION SAFETY INDICATOR “Radioactive Effluent Control” ü Non compliance with the monthly dose restriction (10 Sv)- If the radioactive effluent releases per month reach a effective dose for the critical population 10 SV. ü Uncontrolled Releases - Radioactive effluent release outside the plant producing doses exceeding 1 Sv, without applying any kind of control over the effluent. SISC-

SISC DESCRIPTION CSN COMMUNICATION CSN RESPONSE • • ASSESMENT PROCESS (ACTION MATRIX) MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS SAFETY CORNERSTONES Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK –INFORMED BASELINE INSPECTIONS SISC- Ý ASSESMENT REPORTS AND INSPECTION PROGRAMS ENFORCEMENT SUPLEMENTAL INSPECTIONS PUBLIC MEETINGS PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES PERFORMANCE INDICATOR THRESHOLDS PERFORMANCE INDICATORS

CSN INSPECTION PROCEDURES n Baseline Inspection Program: It is a risk-informed inspection which establishes the minimum inspection effort that all licensees would receive, regardless of their performance. It includes the areas not covered by the indicators and the verification of these indicators. n Inspections beyond the baseline will be performed at plants with performance below established thresholds, as assessed through information gained from performance indicators and CSN inspections. SISC- n Additional inspections may also be performed in response to a specific event or problem which may arise at a plant

CSN BASELINE INSPECTION PROGRAM Inspection Procedures-Occupational Radiation Safety cornerstone SISC- ü ü “Access control to controlled area” “ALARA organisation, managing and control” “Radiation protection instrumentation and equipment” “Radiation protection training” Inspection Procedures-Public Radiation Safety cornerstone ü “Treatment, monitoring and control of liquid and gaseous radioactive effluents” “Inspection of transport of radioactive materials in NPPs” “Inspection of clearance activities” “Environment monitoring program (PVRA)” “Radioactive waste control and management” ü ü

CSN SISC- INSPECTION RESULT PROCESS

CAP CSN Corrective Action Program (CAP) In this program licensee must introduce : n All Minor findings found by CSN inspectors- Findings of low significance which are only required to be documented and solved by the licensee through the CAP. n All problems or issues detected by the licensee with its corresponding correcting action (minimum required issues are described in a specific procedure approved by CSN) CSN inspects each CAP to check if the licensee has included all required issues and minor findings. SISC- Issues detected by licensee, registered and properly solved by himself will not count as finding by the CSN if it is of low importance (minor finding or Green).

CSN SDP Significance Determination Process (SDP) - It helps CSN´s inspectors to determine the safety significance of inspection findings. Each SDP supports a cornerstone associated with the strategic performance areas. Objectives : ü To characterize the safety significance of inspection findings, SISC- using best available risk insights as appropriate ü To provide all stakeholders an objective and common framework for communicating the potential safety significance of inspection findings ü To provide a basis for timely assessment and/or enforcement actions associated with an inspection finding ü To provide inspectors with plant-specific risk information for use in risk-informing the inspection program

CSN SDP OCCUPATIONAL RP (1) NO ALARA Finding YES Is three year rolling average collective dose > 0. 8 man. Sv/year for PWR or > 2 man. Sv/year for BWR NO Verde Green YES Job Dose > 175 man. m. Sv NO Greater than 4 occurrences SISC YES SISC- Blanco White YES Blanco White NO Verde Green

CSN SDP OCCUPATIONAL RP (2) It is an Overexposure? NO It is a potential overexposure? NO Was the ability to asses dose compromised? YES Dose Equivalent exposure? YES DE>5 times the limit? NO Blanco White YES NO Effective Dose >5 times the limit? Amarillo Yellow Associated to a surface contamination ? YES Verde Green NO Amarillo Yellow NO YES Rojo Red Whole body exposure in a RED area ? SISC YES SISC- Amarillo Yellow NO Blanco White NO Verde Green

CSN SDP PUBLIC RP (1) RADIOACTIVE Efluentes Radiactivos EFFLUENTS? NO WHITE YES Impaired ability to assess doses YES Dañada capacidad de evaluar dosis Failed to assess doses NO NO Dose to the Public > 50 Sv NO GREEN YES Dose to the Public > 100 Sv NO WHITE YES SISC- NO Dose to the public > 1 m. SV Dosis público > 1 m. SV YELLOW YES RED

CSN SDP PUBLIC RP (2) NO Environmental Monitoring Vigilancia Ambiental Program (PVRA) NO YES Impaired ability to assess environmental impact NO GREEN YES Failed to assess environmental impact YES SISC- WHITE NO GREEN

SDP PUBLIC RP (3) CSN NO Solid Material potentially NO GREEN contaminated WHITE YES Impaired ability to characterise a potentially contaminated material YES NO Failed to assess the activity concentration of the material and total activity released NO Dose to the Public > 50 Sv NO GREEN YES Dose to the Public > 100 Sv NO WHITE YES SISC NO Dose to the Public > 1 m. Sv YELLOW YES SISC- RED R

SISC DESCRIPTION CSN COMMUNICATION CSN RESPONSE • • ASSESMENT PROCESS (ACTION MATRIX) MANAGEMENT CONFERENCES MONITOR LICENSEE ACTIONS CSN INSPECTIONS ADDITIONAL REGULATORY ACTIONS SAFETY CORNERSTONES Significance Evaluation SIGNIFICANCE DETERMINATION PROCESS (SDP) EVENT-RESPONSE INSPECTIONS GENERIC SAFETY INSPECTIONS RISK –INFORMED BASELINE INSPECTIONS SISC- Ý ASSESMENT REPORTS AND INSPECTION PROGRAMS ENFORCEMENT SUPLEMENTAL INSPECTIONS PUBLIC MEETINGS PERFORMANCE RESULTS IN ALL 7 SAFETY CORNERSTONES PERFORMANCE INDICATOR THRESHOLDS PERFORMANCE INDICATORS

CSN ACTION MATRIX – EVALUATION LEVELS Every Spanish NPP has a temporary position in this matrix, which reflects the licensee's safety performance. The first level of the Action Matrix corresponds to the Licensee Response column, for plants with all the indicators in green and with only green findings (if any). The next four columns correspond to four levels of Regulatory Response increasing as plant performance declines. These four levels determine the appropriate level of CSN response, including supplemental inspection and pertinent regulatory actions ranging from management meetings up to and including orders for plant shutdown SISC-

CSN SISC- ACTION MATRIX – MODEL