5.1.3 Preconstruction activities

The decision to construct a nuclear power station involves the commitment of huge resources, so it is not one that can be taken without careful consideration. The decision-making process must be rigorous and comprehensive.

Initially the decision-making process involves an appraisal of the socio­economic circumstances, to determine if new generating capacity is required and to determine if a nuclear power station is an acceptable option to satisfy such a need.

If the politics and the demand for new generation are favourable the next phase will involve a decision to commit finance. The financial appraisal must include consideration for the choice of site, the design options, the funding options available and the electricity market model in which the plant will operate. These tasks will require specific knowledge and experience, which must be established in the operating organisation several years before build commences.

In addition the operating organisation must recognise and cater for the demands of the regulatory process associated with new build and acquisi­tions. These can be very lengthy and resource demanding, so they require a strategy and a fully resourced plan for dealing with them in order to optimise the timescales and costs involved.

The decision to build must also take into account the availability of a suitable infrastructure to manufacture, build and operate the plant. For many years the manufacturing sector was dormant due to a lack of orders.

Many of the major manufacturers survived on the basis of manufacturing replacement parts, design upgrades and service activities. Clearly such activ­ities resulted in a reduction of staff and a loss of competencies, which have had to be renewed in a very short timescale.

The nuclear renaissance has come with a rapid surge in demand for plant and equipment, so manufacturing capacity is further stretched to capacity. Similarly, universities and other educational institutions that provided train­ing for nuclear industry workers closed down courses and reassigned staff to other educational programmes (see Chapter 6).

The current approach to licensing of nuclear plants seeks to establish generically approved designs. However, each site chosen for construction must be assessed to determine if it can satisfy generic design requirements and to assess the environmental impact of that design on the site, through all phases of construction, commissioning and operation. These studies and the generic design characteristics will form the basis for the decision to grant licences and the conditions associated with the licences. The execution of such studies will require specialist skills.

The preconstruction activities are costly and resource intensive, as well as being quite lengthy in nature. It can be concluded from this brief descrip­tion of the decision-making process that the prospective operator must commit significant resources and commence the construction of the operat­ing organisation well before the decision to build is taken.

On a case-by-case basis, it may be beneficial to accept the use of technical standards of the vendor State or of a State having oversight experience with a reactor of the type selected. It is also useful to learn from the earlier independent analysis and safety assessments of this technology performed in other States. Furthermore, other regulatory bodies can give insights into the levels of quality achieved by key manufacturers and other suppliers, and this allows for better focusing of the auditing and evaluation of these orga­nizations. In adapting safety standards or regulations of other States, the regulatory body should make its regulations compatible with its own national legal and regulatory framework, include appropriate requirements specific to national conditions such as special site characteristics and electri­cal grid conditions, promptly evaluate amendments made to the reference regulations or standards, and issue amendments to its own regulations as appropriate.

Once the vendor has been chosen through the bid evaluation process, the regulatory body should consider cooperation with the regulatory bodies of those States in which the same vendor has supplied similar plants, and especially of the State of the vendor, if possible. The possible benefits of information based on the experience of other States are clear and this could influence the tentatively planned regulatory approach.

A common option chosen in the past for regulation by States into which a first nuclear power plant was being imported was to use the regulations and standards of the supplier State. This had the advantage that the supplier knew in detail which requirements it had to meet, and it was easier for the regulatory body because it knew that such a plant was licensed in the sup­plier State. However, this approach has a significant disadvantage. The regu­latory system of the importing State should be properly considered in the approach of the regulations adopted. If the State subsequently purchases a plant from a supplier with a different regulatory approach or a different licensing system, or if a major back-fitting programme is implemented, the two systems would have to be reconciled. The regulatory body should have a clear understanding of the basis for the regulations so that subsequent regulatory actions or changes can be fully and knowledgeably evaluated (IAEA, 2011a).

The management and organization of plant operations should be such as to ensure a high level of performance and safety in operations. Operation of the power plant is performed by monitoring and controlling the plant systems in accordance with relevant rules, operating procedures, established operational limits and conditions and administrative procedures. Shift per­sonnel need to be authorized or licensed, both at the beginning of operation and also at regular intervals (every year, for instance). Such authorization or licensing has to be approved by the regulator. The reference IAEA (2000), Safety Standards Series, Safety Requirements for a Nuclear Power Plant Operation, NS-R-2, explains all the recommendations for the safe operation of a nuclear power plant.

The plant organization should clearly define the roles and responsibilities of all plant staff: the operations manager has the overall responsibility for establishing and implementing the operations programme and has the responsibility for the day-to-day running of the operations. The resources, both human and financial, need to be sufficient for all operating functions. Control room operators have to be licensed and to know all procedures and be regularly trained appropriately.

The plant organization has to fix as its first priority ‘safety first’ for all personnel. This means enforcing a good safety culture. Adequate training needs to be given on safety culture.

Special procedures have to be organized for maintenance, refuelling, shutdown activities, regular testing and outage activities.

The plant needs to promote plans for human resources training, retrain­ing and authorization/licensing of operators. For a lifetime of 60 years for the plant, personnel needs should be anticipated for compensating for retirement and for new specialities that will be required, such as for decommissioning.

Operating experience and feedback is essential for ensuring the safety of the plant. It requires investigating all events which could or did affect the plant operational safety. The analysis should be shared with the regulatory body and with all the plant operators worldwide. The IAEA document IAEA (2008b), Improving the International System for Operating Experience Feedback, INSAG-23, and the Incident Reporting System of the IAEA/ NEA demonstrate the necessity of exchanging information on events which occurred worldwide.

As the plant life goes, plant ageing management has to be put in place. It is recommended that a periodic safety review process is carried out every 10 years to provide reassurance that the licensing basis is still valid, taking into account cumulative ageing effects, obsolescence of equipment or mate­rials, modifications implemented during the plant life, lessons from world­wide operating experience, results of advanced research and changes in international safety standards. The IAEA (2009b) Safety Standards Series document Ageing Management for Nuclear Power Plants, NS-G-2.12, gives all requirements for dealing with ageing.

Transportation of radioactive materials in safe and secure conditions will be prepared in the country and internationally as need be. Transportation may be by road, rail, sea or air. More information can be found in IAEA (2009c), Safety Standards Series, Regulations for the Safe Transport of Radioactive Material, TS-R-1; IAEA (2007a), Considerations to Launch a Nuclear Power Programme; and IAEA (2008c), Nuclear Security Series Guidelines, Security in the Transport of Radioactive Material, no. 9.

Security should be enforced to protect all radioactive material from diversion or terrorism as required by the relevant ratified conventions. All relevant information can be found in IAEA (2008c), Nuclear Security Series Guidelines, Security in the Transport of Radioactive Material, no. 9.

A very detailed and structured documentation programme needs to capture all operational data that may be of use for the decommissioning plan. From the beginning of the life of the installation, a decommissioning plan has to be approved by the regulatory body and to be updated regularly. At the end of the lifetime, the final plan has to be approved before stopping the installation and starting to unload the used fuel. Financial provisions should be accumulated throughout the life of the plant and kept at the level necessary for the decommissioning operations. These should include the used fuel management and the waste management resulting from the decommissioning phase.

The enforcement action may involve warnings or directives or orders; these apply in general for deviations from or violations of regulatory require­ments, or unsatisfactory safety conditions. In each case, the regulator explains the basis for each violation, deviation or unsatisfactory situation and specifies a period of time for taking corrective action. The regulator can also include technical measures such as reductions in power, pressure, temperature or other parameters, including, if necessary, temporary shut­down of the facility or administrative compensatory measures.

Modification, suspension or revocation of the authorization

In the event of repetition or serious non-compliance or safety consequences, the regulatory body modifies, suspends or revokes the licence, depending on the nature and severity of the conditions at the plant.

Fines

Fines are applied in general at the corporate level, and are imposed or recommended by the regulatory body. The administering of fines to indi­viduals by the regulatory system is strongly discouraged in general, but may also occur. Fines on the organization rather than on individuals are preferable.

An essential element of the national policy and strategy for safety is to ensure the necessary professional training to maintain the competence of sufficient suitably qualified and experienced staff.

The building of competence is required for all parties with responsibili­ties for safety, including licensees, the regulatory body and organizations providing services or expert advice on matters relating to safety. Competence is necessary in the context of the regulatory framework for safety, and can be achieved by such means as technical training, learning through academic institutions and other learning centres, and research and development work.

The State should make adequate arrangements for the regulatory body and its support organizations to build and maintain expertise in the disci­plines necessary for discharging the regulatory body’s responsibilities in relation to safety. In cases where the training programmes available in the State are insufficient, arrangements for training should be made with other States or with international organizations. The development of the neces­sary competences for the regulatory control of nuclear power plants is facilitated by the establishment of, or participation in, centres where research and development work and practical applications are carried out in key areas for safety.

The regulatory body has to have appropriately qualified and competent staff. A human resources plan should be developed that states the number of staff necessary and the essential knowledge, skills and abilities for them to perform all the necessary regulatory functions. The human resources plan for the regulatory body covers recruitment, staff rotation and the processes to be used to obtain staff with appropriate competence and skills, and also includes a strategy to compensate for the departure of qualified staff. To develop and maintain the necessary competence and skills it is necessary to establish a process for knowledge management. This process includes the development of a specific training programme on the basis of an analysis of the required competence and skills. The training programme in general covers principles, concepts and technological aspects, as well as the proce­dures followed by the regulatory body for assessing applications for licens­ing, for inspecting and for enforcing the regulatory requirements in a nuclear power plant.

The construction project strategy to be adopted by an operating organisa­tion will depend on its circumstances. It must be recognised, however, that even with a turnkey contract, considerable resources will be required to ensure due diligence in the acquisition and construction phase.

For the commissioning phase the operating organisation must be suffi­ciently developed to acquire the knowledge and experience to be gained from commissioning activities and to be in a position to assume full respon­sibility for operation on completion of the contract.

In some countries the nuclear site licensing process has been developed to allow a general licence for construction and commissioning. There are, however, hold points in such licences that require the operator to meet conditions with regard to the competencies that must be established before, for example, nuclear fuel is delivered to the site or fuel is loaded into the reactor. Business plans and project plans must reflect these requirements.

Licensing issues are covered in Chapter 20 and commissioning in Chapter 22.

134 Infrastructure and methodologies for justification of NPPs

A licence is a legal document issued by the regulatory body granting authorization to perform specified activities related to a nuclear power plant to a licensee who has the responsibility for safety. Chapter 20 develops nuclear power plant licensing and regulatory body and licensee related activities.

4.1.6 Development of the licensing process

The licensing process involves the granting of authorizations during all stages of the lifetime of the nuclear power plant: siting, design, construction, commissioning, operation, decommissioning and, finally, release of the site from regulatory control. This step-wise process needs to be transparent, predictable and clear, and should be in accordance with the national legal and governmental framework.

The regulator specifies the regulations, requirements and conditions for safety that are necessary during each step of the process. Compliance with these regulations, requirements and conditions is demonstrated by the licensee to the regulator, who reviews and assesses safety using clearly defined procedures. Detailed information (format and content) is specified in a time frame by the regulator in order to evaluate safety at each stage of the licensing process. The information also has to be updated regularly by the licensee, as indicated in licence conditions or regulations. The regula­tory body may also need to repeat or reaffirm its assessment in order to support its decisions. The regulatory body makes decisions on the amend­ment, renewal, suspension or revocation of a licence based on actions such as inspections, reviews and assessments, and feedback from operational performance.

There are several types of licences: for specific time periods, for specific stages in the lifetime of the plant or for an unlimited time period. In order to grant a licence, it is necessary for a regulatory decision-making process to be in place. Political decisions are completely separate from technical decisions. These decisions are considered in a logical order, particularly when several governmental bodies are involved in the process; in this case, a licensing committee is recommended in order to integrate each govern­mental body into the licensing process in a timely manner. Separate hold points are specified for certain steps in the design, manufacturing, construc­tion and commissioning processes, in order to allow verification of the results of work and to assess the preparedness to carry out the subsequent activities. The competence of licensee individuals having responsibilities for safety is verified by the regulatory body.

The early involvement of the public, in order to get public input regarding safety concerns, needs to be considered in good time by the regulator, in particular with regard to safety issues that relate to design safety require­ments and the specified site conditions. Licence conditions are additional specific obligations for safety that the regulatory body considers it is neces­sary for the licensee to meet. In general, the conditions are incorporated into a general licence, to supplement general requirements or to make them more precise. They may include safety-related aspects affecting any stage of the plant’s lifecycle: site evaluation, design, construction, commissioning,

operation and decommissioning of the nuclear installation and its subse­quent release from regulatory control. In general the licence conditions concern the establishment of technical limits and thresholds, specifying procedures and modes of operation, administrative matters, inspection and enforcement, and plant response to abnormal circumstances.

The licensing process should be transparent to the public, and a licence is published and made available to the public — taking into account security — sensitive and commercial proprietary information. Public participation in the licensing process gives interested parties an opportunity to present their views during certain steps of the licensing process.

There are two aspects that the regulatory body considers early in the licensing process: (a) approval of sites, and (b) certification of standardized plant designs. International cooperation also helps to facilitate the licensing process. Initially a pre-licensing stage could be adopted for an early regula­tory review and approval of the proposed design safety requirements for the nuclear power plant as well as the review of the key features of the new design, to identify safety issues that would require modifications, develop­ment, or additional analysis to achieve regulatory approval of the design. During the pre-licensing process and when a particular plant design is being considered, it is necessary to provide regulatory approval of the licensee organization and site-specific aspects that may have an impact on safety in the design stage; issues that need to be adequately addressed in order to achieve regulatory approval of the site and organization should be identified.

In the combined licensing process an applicant can apply for a single licence to construct, commission and operate a nuclear installation and allow the plant to begin operation. The combined licence model requires a significant amount of regulatory resources and has only a small number of hold points, e. g. fuel loading, power increase or other technical issues.

A safety analysis report (SAR) is included in each application for a licence for a nuclear power plant. The SAR is intended to describe the facility, present the design bases and the limits on plant operation, and provide a safety analysis of the plant’s structures, systems and components and of the plant as a whole. The licensing process for nuclear installations is described in an IAEA specific safety guide (IAEA, 2010b).

As described above, a decommissioning plan has to be established and maintained throughout the plant’s lifetime and accepted by the regulatory body of the country. Adequate funds should be available. This gives the authorization for final shutdown and the first operation is then to unload the used fuel. The IAEA (2006c) Safety Standards Series document, Requirements for Decommissioning of Facilities Using Radioactive Material, WS-R-5, gives the precise ways of dealing with decommissioning.

The regulator has the responsibility for establishing the various criteria for the safety and environment of the decommissioning phase, for perform­ing regular inspections and for checking the handling of the produced wastes. It also has to produce criteria which have to be met for the end state allowing the release of the site from regulatory control; when this is not feasible the site has to continue to be controlled and adequate measures shall be taken.

Internationally the recommended strategy for dismantling of a nuclear plant is immediate dismantling. But some factors may induce delays (for example, availability of waste disposal and long-term repository, funds and competent personnel availability). In any case, the facility must at all times demonstrate its safety.

An organization for the management and implementation of decommis­sioning shall be established as part of the operating organization or dele­gated to contractors but the responsibility still lies with the operating organization. It is important at this stage to remember the Fundamental Safety Principle 1 on Safety Responsibility (see Section 2.4.1).

Decommissioning and dismantling involve:

• Radioactivity, which means protection of the workers and the environment

• Contamination, which induces use of chemicals and the necessity of containment.

Dismantling of an installation produces enormous quantities of wastes. The wastes generated must be disposed of or recycled when possible. The low — activity wastes can be disposed of in existing facilities that are usually avail­able in most countries. For the other kinds of wastes it is important to reduce the volume as much as possible by separating the non-radioactive ones. The radioactive part (intermediate and high level) should be packaged and stored safely while waiting for availability of appropriate repositories.

If waste is stored on the site, a revised or new, separate authorization, including requirements for decommissioning, shall be issued for the facility.

Transparency and openness represent the most important elements for earning public trust and building confidence in the nuclear regulatory system. A decision to launch a nuclear power programme requires a broad acceptance by all nuclear stakeholders that such a programme is justified through a clear decision-making process. Public opinions and comments need to be considered as an input to any process that is intended to lead to a decision on launching a nuclear power programme. INSAG has con­sidered stakeholder information and participation (INSAG, 2006).

In order to balance the need for information to be disseminated with the need to protect certain sensitive and classified information, the policy and criteria for protection of such information are established and clearly com­municated to all stakeholders.

In the licensing process of a nuclear power plant it is highly beneficial for the consistency of the process to secure public involvement as early as pos­sible, in order to obtain input from the public at the stage where all safety concerns can be adequately addressed and taken into account in the review process.

The regulatory body needs to establish and maintain effective communi­cation mechanisms for informing stakeholders, interested parties, govern­mental authorities and the public regarding possible radiation risks associated with facilities and activities, safety regulatory judgements and decisions and their basis, how the nuclear regulator is performing the func­tions necessary to assure safety, and information on nuclear accidents, inci­dents and abnormal occurrences. These communication mechanisms should also provide easy access to information on safety and should create oppor­tunities for all stakeholders to express their opinions. These communication mechanisms should also consider the make-up of audiences and their dif­ferent concerns, levels of knowledge and experience. It is necessary to clarify the role of the licensee from the beginning of the nuclear pro­gramme; i. e. that the licensee has as an obligation to inform the public about the possible radiation risks associated with the plant and this obligation needs to be specified in the regulations promulgated by the regulatory body or in the licence. In order to build a successful communication programme it is essential to consider communication in the regulatory budget planning and to involve dedicated personnel with technical expertise and a talent for this discipline.

The objective and functions of the regulatory body, its independence, its technical competence, the available human resources and its neutrality have to be disseminated and proactively communicated to all stakeholders, in particular to the public and interested parties.

While maintaining its independence, the regulatory body liaises with the licensee to achieve their common objectives and to discuss safety-related issues. Mutual understanding and respect achieved through frank, open relationships will provide constructive liaison on safety-related issues.

The international participation of the regulatory body — through legally binding and non-binding international instruments (e. g. Convention on Nuclear Safety), workshops, seminars and other meetings and effective bilateral agreements among regulators to share regulatory experiences on safety — contributes to increasing the credibility of the regulator. Participation and involvement in international peer reviews designed for regulators will also strengthen the regulatory effectiveness worldwide.

The regulatory control has to be stable and consistent with a formal process based on specified policies, principles and associated criteria; the process should follow specified procedures as established in the management system. Stability and consistency of regulatory control need to be ensured by preventing any subjectivity in the decision making of the individual staff members of the regulatory body. The regulatory decisions need to be justi­fied with the proper rationale to be traceable and supported. When carrying out its reviews, assessments and inspections, the regulatory body should inform the licensee of the objectives, principles and associated criteria for safety on which its requirements, judgements and decisions are based (IAEA, 2011a).

The regulatory body should always emphasize the continuous improve­ment of safety as a general objective. Changes in regulatory requirements are subject to careful scrutiny to evaluate the possible enhancements in safety that could be achieved. Any proposed changes in regulatory require­ments need to be based on informed judgements and there should also be the opportunity for consultation with the licensee.