Slovak Regulatory oversight of HOF Viktor Szab Viktor
Slovak Regulatory oversight of HOF Viktor Szabó (Viktor. Szabo@ujd. gov. sk) Pavol Matkovčík (Pavol. Matkovcik@ujd. gov. sk) Inspectors of Nuclear Safety Department of Safety Evaluation and Inspection Activities Technical Meeting on Regulatory Oversight of Human and Organization Factors (HOF), IAEA, Vienna 14. -18. 12. 2015
SCOPE • • Mission of UJD Status of Nuclear Power Programme Status of Regulatory Framework Regulatory Requirements Inspection and Procedures Oversight of HOF Challenges
Mission § Supervision § Regulatory Framework § Nuclear Safety § Nuclear Security § Emergency Preparedness § § Assessment docs. Evaluation of events Sanction & Violation International Affairs § Atomic Act § Regulations § Technical Norms § § Authorization Verification Public Information Safeguards
Nuclear Facilities (1)
Nuclear Facilities (2) Nuclear Installations Type Start up (Shut down) Operator NPP A-1 Bohunice HWGCR 1972, (1977) JAVYS. a. s. NPP V-1 Bohunice WWER 440/230 1978, 1980 (2006, 2009) JAVYS. a. s. . NPP V-2 Bohunice WWER 440/213 1984, 1985 SE a. s. -Enel NPP Mochovce 1, 2 WWER 440/213 1998, 1999 SE a. s. -Enel NPP Mochovce 3, 4 WWER 440/213 2016? , 2018? SE a. s. -Enel Technologies of RAW Treatment and Conditioning from 1977 JAVYS a. s. Interim Spent Fuel Storage wet, pool 1987 JAVYS a. s. RAW Repository near surface 1999 JAVYS a. s. Technology for Treatment of LRW 2007 JAVYS a. s.
Status of Nuclear Power Programme in Slovakia (1) Second decommissioning phase of Bohunice V-1 started since January 2015 – Re-trained (case - changing of job position) more than 90% staff of AH – Change the activity from first phase to second phase of decommission Preparing for the commissioning of Mochovce unit 3, 4 – – – Working with re-training (case - changing of job position) New full scope simulator of MO 3, 4 Verification of CR personnel was starting on 4/2015
Status of Nuclear Power Programme in Slovakia (2) Operation of Bohunice V-2 and Mochovce 1, 2 : • • Modernization and upgrade of FSS of EBO & EMO. New Info and training center in Mochovce. Decentralization of management for training on sites. Refreshing of training programmes of competent personnel based on SAT by new software Vision.
Status of Regulatory framework (1) Project about preparation of new atomic act and its regulations: • Planned valid version – 1. 1. 2017 • Planned presentation for parliament – 1. 6. 2016 • Planned presentation for Government - 1. 4. 2016 • Preparation of draft version – Frist meeting for project team 10. -14. 11. 2014 – Last meeting planned for days 1. -5. 02. 2016 – Approving by leaders approx. . March 2016
Status of Regulatory framework (2)
Exist Regulatory requirements: (1) The quality management system of a authorization applicant and a authorization holder must be created, maintained and continually improved in accordance with requirements of UJD, and their documentation describe: a) an internal management system for ensuring quality, b) implementation of quality management system policy including safety policy and professional personnel training c) monitoring of adherence to nuclear safety.
Exist Regulatory requirements: (2) • The authorization holder shall determine all job position in which work activities are performed with an impact on nuclear safety, and other job positions with a direct impact on nuclear safety along with a description of work activities in the quality system documentation including their required number. • The required number of work positions, their competences and their sufficiency result are regularly verified on the basis of an analysis system, which is properly documented.
Exist Regulatory requirements: (3) • The authorization holder is obliged to entrust with performance of work activities only persons fulfilling the conditions stated under Atomic Act, • Licensed employees are employees of the authorization holders performing work activities having direct impact on the nuclear safety, shall have master’s degree obtained in the Slovak Republic or in the Member States, completed the professional training, are medically fit and mentally competent, whose special professional competence was verified by an examining board established by the Authority and the Authority issued them a license of special professional competence.
Exist Regulatory requirements: (4) Training system includes: • The employees recruitments procedure, • The employees selection procedure, • Description of the methodology used in professional based on a systematic approach, which proceeds logically, from the identification of competencies, through the development and implementation of professional training programmes including the respective teaching aids subsequent evaluation of this professional training. • Professional records, competencies and responsibilities in connection with the professional training.
The Challenge WHO? WHAT? Change WHY? BY? HOW? BASED?
Exist Regulatory requirements: (5) Modification (Change) at nuclear installation important to nuclear safety during the construction, commissioning, operation, decommissioning, closure of repository and/or after the closure of repository, which can be carried out only after obtaining previous permission or approval by the Authority and, in special cases, also after obtaining position by the EC shall mean modifications: – of classified equipment which perform safety function or through which their safety function/related characteristics undergo changes, – of documentation reviewed or approved by the Authority, – which results in changes of limits and conditions
Exist Regulatory requirements: (6) • Definitions (pursuant § 2 to letter w) of Atomic Act) „Modification at nuclear installation during its construction, commissioning, operation, decommissioning, closure of repository and/or after the closure of repository, subject to preceding notification and review by the Authority and, shall mean modifications not mentioned under letter u), which however, if implemented, may impact the nuclear safety. • Authority issued – Regulation of the NRA SR of No. 52/2006 on professional competency (updated by Regulation No. 34/2012), – Regulation of the NRA SR of No. 431/2011 on quality management system,
Exist Regulatory requirements: (6) Based on Regulation of the NRA SR of No. 431/2011 on quality management system • Quality management system documentation shall contain: a) quality policy and quality targets, b) quality manual, c) the organizational structure and its description, d) documented regulations, programs, procedures and records, e) requirements for ensuring nuclear facility safety, f) nuclear facility quality requirements, g) categorization of selected facilities into safety classes or a list of selected facilities, h) quality assurance requirements for selected facilities, i) quality requirements for selected facilities
Exist Regulatory requirements: (7) Based on Regulation of the NRA SR No. 431/2011 on quality management system REQUIREMENTS FOR DOCUMENTATION OF IMS A quality policy including a safety policy expressing the written commitment of the permit applicant’s management and permit holder’s management to achieve and maintain, a high level of nuclear safety as a priority, A professional training policy expressing the commitment of the permit applicant’s management and permit holder’s management to ensure, the required number of professionally competent employees and specially professionally competent employees as a priority, A description of organisational structure including binding definition of responsibilities of specific job positions for an exactly determined area of nuclear safety,
Exist Regulatory requirements: (8) Based on Regulation of the NRA SR of No. 431/2011 / cont’ A description of the binding procedure and specification of responsibility for staffing of functional positions with direct influence on nuclear safety and with influence on nuclear safety with nuclear facility employees. The requirements for maintenance of employee competences so that during the performance of job activities, they will pay the highest attention to ensuring a high level of safety culture. The requirements for qualification of employees performing checks and tests of specified structures, installations or processes, their independence, and requirements for the level of such checks and tests.
Exist Regulatory requirements: (9) Based on Regulation of the NRA SR No. 52/2006 on professional competency, The authorization holder shall determine all job position in which work activities are performed with an impact on nuclear safety, and other job positions with a direct impact on nuclear safety along with a description of work activities in the quality system documentation. The authorization holder shall define the conditions for appointment, change of appointment and sequence in appointment to specific job positions for licensed personnel.
Dividing of UJD SR staff § Public Servants, administrative employees, driver, IT and economists § § Civil Servants §Professional Personnel (are not Inspectors) lawyers, international connection, public relations and IT admin. § §Inspectors of Nuclear Safety for: § site inspectors (EBO, EMO 1 2, MO 3 4, VYZ) § assessment of nuclear safety (Periodic, PSA, DSA) § assessment of components and systems § building activities § radioactive materials § safety guards § physical protection § radioactive waste § decommissioning § emergency planning § quality assurance § training and qualification § inspection of aerial activities near Nuclear Fields § safety culture
Inspection Guides & Procedures • Internal Guides for inspection of NRA SR • S 310 004: 12 Directive on inspection activities NRA SR defines routine, special and team inspection – P 320 013: 08 The inspection procedure - Monitoring the performance of the NI construction and design changes to equipment with impact on nuclear safety. – P 320 014: 08 The inspection procedure - Control systems for quality assurance – P 220 001: 08 The inspection procedure for checking the qualifications and training of authorization holders personnel
Inspection Guides & Procedures • Internal guides of RB for Inspection a) b) c) d) e) Types of inspection (planned-unplanned, routine, periodic, team, special) Annual Inspection plan (Approved by leaders, prepared by inspectors) Range and scope of inspection (programmes, leaders, material) Communication rules (official letters – protocols, reports) Categories of findings are identified by the code – effects from documentation is everywhere a) b) c) d) e) f) g) h) i) ES Status of the Equipment ET Testing of the Equipment OP Operation Documentation QA Quality Assurance TP Training of Personnel EP Emergency Preparedness NS Nuclear Safety PS Physical protection GP Good Practices
Inspection Guides & Procedures • Internal guides of RB for Inspection Categories of findings based on importance: a) Failure of design projects, incidents b) Deviation of project, unplanned activities c) Mistakes or Misunderstanding 3 2 1 • Internal guides of RB for Verification of selected personnel • Internal guides of RB for Verification of inspectors • Internal guides of RB for Verification of lectors (trainers)
Oversight of HF and OF : • TP Training of Personnel – Deficiencies in training of staff (OF) • Failure in organization of training (OF) • Failure in Planning of training (OF- SC) • Wrong organizational changing (OF) – Deficiencies in compliance with qualification requirements (OF) • Working without permitting (OF) • Lack of competencies (HF) • Pass of one part of training (HF) – Errors and mistakes of staff (HF) • Use the wrong procedures or tools (HF) • Time pressure (OF) • Workload (OF)
Oversight of HF and OF (2): • TP Training of Personnel – Deficiencies in documentation for staff training (OF) • Failure in preparation of documentation (OF –HF) • Missing appropriate grants of activities (OF) – Deficiencies in the technical infrastructure of specialized equipment • Annual test is not complete (OF-SC) • Lack of full-scope ability (OF-SC) – Failure to operational discipline (HF) • Inappropriate training or maintaining of competence (HF) • Failure etic codes (HF) – Weaknesses in personnel safety culture • Interrupt internal orders (HF) • Wrong social – work culture on work place (OC-SC) – Others
Oversight of HOF in IMS : § § § information gathering on systematic way; sources (periodical report, inspections on wide range); methods (document review, observation, interviews, investigation); planning: focus for time management, areas and attributes. monitoring and direct observation (such as of working practices and equipment, discussions and interviews with personnel of the authorization holder (mapping of staff behaviour) verification of procedures, records and documentation Control tests and measurements Non-compliance assurance Inadequate records and evidence Inconsistent adherence to deadlines and schedules
Oversight of HOF in IMS : § § § information gathering on systematic way; sources (periodical report, inspections on wide range); methods (document review, observation, interviews, investigation); planning: focus for time management, areas and attributes. monitoring and direct observation (such as of working practices and equipment, discussions and interviews with personnel of the authorization holder (mapping of staff behaviour) verification of procedures, records and documentation Control tests and measurements Non-compliance assurance Inadequate records and evidence Inconsistent adherence to deadlines and schedules
Oversight/Monitoring of HOF in IMS : Managing staff are examples models in compliance with the standards, requirements and expectations for the human factor reliability program. Basic error prevention tools: • job-site review, • questioning attitude, • self-checking, • procedure use and adherence, • three-way communication, • phonetic alphabet, • pre-job briefing. Supplementary error prevention tools: • peer checking, • independent verification, • place keeping, • turnover, • flagging, • post-job review.
Challenges: • Preparation of new Atomic act and regulations – Describing of contractors training and their controlling, – More deep requirements for decreasing of human and organization factors, – Status of nuclear knowledge management, – More requirements for on-site training, mainly for full time instructors, – More details about modernization and maintain of FSS, – Detailed description of the job position, – and many else.
Thank you for your attention
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