Licensee activities during design, construction, commissioning, operation and decommissioning

The differing roles of the operator and of the regulator with respect to safety need to be made clear. The IAEA’s Fundamental Safety Principles require that ‘the prime responsibility for safety must rest with the person or organization responsible for facilities and activities that give rise to radia­tion risk’ (IAEA, 2006c). That is, the licensee is responsible for safety, and the regulator is responsible for granting licenses and providing oversight of the operator’s activities with respect to safety. These responsibilities persist throughout the entire life cycle of an NPP and can span a period of several decades. The license specifically states that the licensee is responsible for the following:

• Establishing and maintaining the necessary competences

• Providing adequate training and information

• Establishing procedures and arrangements to maintain safety under all conditions

• Verifying appropriate design, and the adequate quality of facilities and activities and of their associated equipment

• Ensuring the safe control of all radioactive material that is used, pro­duced, stored or transported

• Ensuring the safe control of all radioactive waste that is generated.

On leadership and management for safety, Principle 3 of the Fundamental Safety Principles states that ‘Leadership in safety matters has to be demon­strated at the highest levels in an organization’. Therefore, the starting point for a licensee is senior management’s leadership of, and commitment to, safety through a clearly articulated safety vision that is communicated to every employee. Or, as the International Safety Group (INSAG) expresses it (INSAG, 2002):

Commitment to safety and to the strengthening of safety culture at the top of an organization is the first and vital ingredient in achieving excellent safety performance. This means that safety (and particularly nuclear safety) is put clearly and unequivocally in first place in requirements from the top of the organization, and there is absolute clarity about the organization’s safety philosophy.

The next step is to ensure that a safety culture, leadership and manage­ment systems and processes are all in place to ensure safety. These must be established early in the NPP project and certainly before the bidding process begins. For a new NPP operator, assistance from an experienced operator of a similarly designed NPP is likely to be essential for establishing these requirements. Once established, the licensee must communicate its safety policies on an ongoing basis to both staff and its suppliers. For example, bid specifications should clearly reflect the operator’s safety requirements. Also, the licensee should include formal presentations on the expected compliance of all stakeholders with the licensee’s safety vision, including contractors, suppliers, constructors, vendors and support groups.

The operator must also establish effective relationships with the regulator, even before the bid is specified. During the early stages of an NPP deploy­ment programme, there are many interfaces that need to be managed by the licensee, since the operator is at the centre of all the activities. The various interfaces typically include governments, regulators, the public, the media, the designer/vendor, construction companies, and manufacturers and suppliers. Notwithstanding this, the licensee and regulator must take the time to establish professional and comprehensive interactions to ensure that there is joint understanding of the licensing processes and requirements.