Handbook for Regulatory Inspectors of Nuclear Power Plants

Regulatory inspections of nuclear facilities and activities generally consist of a predefined programme of planned inspections and reactive inspections which are both announced and unannounced to ensure that the inspectors obtain a clear understanding of the overall operation of the Nuclear Power Plant. The purpose is to provide independent assurance that the operator is in compliance with regulatory and license requirements and conditions.

This Techdoc is a rather strange accumulation of advice on the inspection process.

GSG-13 identifies four basic methods for obtaining information during an inspection: Monitoring and Direct Observation; Discussions and Interviews; Document Evaluation; and Independent Tests and Measurements. These are expanded on in Section 2.3.2 listing suitable things to inspect in each style and giving hints about how to make the inspection more successful.

Inspections generally should follow a plan – perform – evaluate – report process, which is expanded upon in Section 3, which looks at the phases, and further in Section 4, which looks at how inspections are undertaken. This includes recommending that an inspector be armed with: note book, clipboard, drawings/diagrams; voice recorder; portable computers, tablets; laser pointer; camera; radiation meters; pyrometer/thermal imaging device; and Inspection mirror, providing the site rules allow them.

Section 4.3.1 is an extraordinarily detailed section about some of the components of a nuclear plant (gauges, valves, motors, pumps, pipe supports etc. which seems to be more general plant familiarisation than inspection material. Some nice diagrams are included.

A potentially useful annex gives tables of questions to ask during and after a tour of the plant.

This Techdoc makes an interesting read and could be useful to a reasonably novice inspector as a self-teaching aid and to a more experienced one as a refresher. However, I cannot help thinking that mature national regulators will already have their own material that fits this purpose. For example in the UK the ONR has its extensive set of technical assessment guides (TAGs).

https://www-pub.iaea.org/books/iaeabooks/12194/Lessons-Learned-from-the-Deferred-Dismantling-of-Nuclear-Facilities

This document discusses the requirements to manage sites entering the Care and Maintenance stage of decommissioning (sometimes called deferred dismantling in IAEA documents and SAFESTOR in the USA) where most of the quick wins in terms of cleaning out components have been achieved and the sites waits for several decades for radiological decay to reduce dose rates to more manageable levels before final dismantling of the reactor core and buildings in completed. It is estimated that about 50% of the nuclear facilities that have been shut down are in safe store and that learning from these sites is increasing. This document was written to allow the benefits of that experience to be shared. It was drafted and reviewed by consultants managed by the IAEA

The document discusses the length of time a site may wait before dismantling based on the half-lives of the isotopes giving most of the dose on the one hand and the deterioration of the structures and containment on the other. It concludes that 15 – 20 years is often a sensible duration provided that there is a suitable waste repository for the final waste arisings.

Section 2 of the document talks about the facilities that are required in safestore, the options to repurpose existing buildings during safestore and the removal of unnecessary buildings. It provides reports of experiences and photographs. Several of the examples are based on the experience of Magnox, which as an ex-employee, pleases me.

Section 3 is about the preparations for safestore. This includes the recording of the hazard inventory and a hazard management plan (remove it or make it safe for the duration of safe store), clean up and deplanting, decontamination, drainage and protection.

In a section on firefighting it states that the risk of fire can be reduced by removing as much of the combustible material and as many ignition sources as practical in the preparations for Care and Maintenance phase. However, it states that a firefighting plan is still required and should be developed and agreed with the local fire fighters and the regulators.

Where external firefighters are the first responders familiarisation training, fire plans, exercising and testing are recommended. For unmanned sites there is a need for automatic alarms that reach the firefighters and the site’s management and access arrangements for the local firefighters. These firefighters must have the appropriate security training and classification to enter the site unescorted.

Security measures are required to keep people off the site to avoid vandalism, damage and theft and also to reduce damage by vermin.

The continuing need for environmental monitoring of radionuclides is discussed in Section 6.6. This is likely to be a regulatory requirement but at a lower level that when the site was operating. It is suggested that it would be sensible to taper off monitoring after a period of about five years by which time a workable baseline understanding of the site would have been achieved. There is a warning that new release pathways may be revealed in time.

The interesting bit of this document for me is the section on emergency planning.

The document (Section 7.5) states that “emergency planning and preparedness (EPP) is necessary for a safe enclosure as it contains large amounts of radioactive materials due to structures, systems or components activation and contamination in various parts of the facility”.

As the risks of the facility reduce the operator should review and rewrite emergency plans to ensure that they remain fit for purpose. Off-site measuring equipment can be reduced but is still required and must be maintained. I assume this is referring to off-site radiation detection. In my experience this is sensibly reduced to perimeter monitoring equipment because of the small releases feasible from such structures do not give a sufficient signal very far downwind.

The document admits that it might be difficult to get the local authorities to agree on the need to maintain and test emergency plans for a site in safestore and suggest that the need to be able to deal with protestors and intruders might be one selling point.

There are sections on the management and regulation of sites, the costing of decommissioning activities (including an introduction to a system called the International Structure for Decommissioning Costing).

Section 12 and several of the annexes of the report give outlines and experiences of decommissioning projects around the world including Magnox’s lead and learn process which has been used to ensure that learning is shared between the different sites and that the process becomes more effective and cheaper with each subsequent site.

This publication does not represent in-depth guidance on care and maintenance of decommissioning nuclear sites. It provides a high level review of the aims of care and maintenance and some of the key considerations. Several examples are discussed. As such it makes interesting reading and may be useful as an introduction to the field for those in operating facilities that are coming to the end of their design life.

A Methodology for Establishing a National Strategy for Education and Training in Radiation, Transport and Waste Safety. IAEA Safety Report Series No. 93.

This document discusses how a country developing its nuclear capabilities should consider the needs for education and training to deliver a sufficient number of competent people in each discipline required giving the range of facilities and activities in the country. It recognises the potential need for various levels and fields of qualification including qualified expert, radiation protection officer, operator, health professional.

The guidance is stated as “describing good practices [which] represents expert opinion but does not constitute recommendations made on the basis of a consensus of Member States”.

It recommends a fairly standard training needs analysis methodology consisting of an assessment phase, a design phase, a develop and implement phase and an evaluation phase. As is usual these are arranged in a cycle to ensure the provision reacts to changes in needs and progress.

The assessment phase looks at the range of facilities in the country and the education and training requirements specified in the legal and regulatory framework, plus any requirements associated with professional qualifications.

The design phase lists the range of courses and their capacity required to meet the national needs and considers who is able to provide the training (including foreign expertise for those in the early phases of development). This can include existing universities and training colleges, national facilities and private providers.

The consideration of formal qualifications, overseen by suitable organisations, and experience leading to recognition by professional bodies is required to ensure proof of adequate knowledge and experience for some roles. This process will identify career routes and pipelines providing the required personnel.

The IAEA’s EduTA methodology is also mentioned as a way of focussing peer review on the nation’s educational and training system.

The meeting of the identified training needs may require capability development or the purchase of capability from other countries. Shortfalls in capability should be analysed and managed. Train the trainer (TTT) is mentioned as a powerful technique to develop capability.

The development and implementation of the programme requires that every identified education and training need should be matched with an appropriate methodology, such as attendance at a structured course, on the job training or distance learning and that opportunities to undertake such training are provided. These training services should be carefully specified and designed and delivered by suitable qualified and experience people.

The IAEA suggests that “the development and implementation of a national strategy for education and training will require government support and the long term commitment of all relevant stakeholders (e.g. regulatory body, governmental and other authorities and organizations in the field of radiation protection and safety, education and training providers, professional organizations). In this respect, the establishment of a high level steering committee of stakeholders will greatly facilitate the development of a policy document that outlines the rationales for the national strategy for education and training in radiation, transport and waste safety. The same committee could also oversee the development and implementation of the national strategy”. In fact, in countries with mature industries this organisation may not be needed. Legal requirements for professional qualifications for some roles, regulatory expectations of the training and experience of personnel and commercial drivers for a safe and competent workforce can achieve the same ends. Issues of supply and demand of skilled workers may occur if significant changes in the structure of the industry occur such as extensive new build programmes or decommissioning activities start.

Evaluation consists of continuous evaluation – the comparison of progress against programme, and long term evaluation of the overall efficiency and effectiveness of delivering the needs of the nuclear industry.

The remainder of the document is taken up with appendices giving examples.

It shows how the nation’s needs can be assessed by listing the facilities that use nuclear knowledge and assessing their needs for qualified people.

It provides example syllabi for courses for RPO in nuclear medicine.

It provides an appendix giving an overview of actions for establishing a National strategy for education and training in radiation, transport and waste safety. This provides a table detailing how 20 actions, distributed across 7 organisations in 5 phases leads to the outcome “The national education and training programme continues to be effective and up to date”.

I do wonder if the world really needs IAEA Safety Report Series 93. It is a fine piece of work but of limited imagination and limited application.

BEIS has issued a Ministerial Statement to both houses of Parliament (Commons and Lords) with regard to policy in the light of leaving euratom. It proposes a twofold approach of (1) “negotiations with the European Commission to seek a close association with Euratom and to include Euratom in any implementation period negotiated as part of our wider exit discussions”; and (2) “to put in place all the necessary measures to ensure that the UK could operate as an independent and responsible nuclear state from day one.”

It might do well to read a recent publication from IAEA Knowledge Loss Risk Management in Nuclear Organisations. This sees challenges resulting from an aging workforce, an industry that runs plant for several decades with different skill sets being required for design, build, operate and decommission stages leading to changing workforce and management. The long duration of nuclear projects also results in issues of technology obsolescence and the need for the introduction of new skills such as cyber security. In the UK we can add the risks posed by the free market “policy” that is resulting in a series of very different prototypes being built or proposed.

This is an issue that should concern BEIS because, of course, the average tenure of a civil servant in a particular influential post is very short compared to the nuclear project duration. They need to ensure that they maintain the knowledge, skills and systems to understand what the NDA, operators, ONR, the environment agencies have been tasked to do and how well or badly they are doing it.

The IAEA document seeks to increase awareness among nuclear organisation managers of the need for a strategic approach and actions plans to identify and manage the risks of individual and organisational knowledge loss.

The IAEA projections show the number of nuclear reactors operating in the world rising, with most of the growth in countries that already have a nuclear industry. Within this picture reactors are retiring and will take experienced resource to decommission them. An even greater cause of need for new recruits is expected to be the loss of skilled and experienced workers to retirement, internal transfer or promotion, or resignation. One scenario for the USA shows 19,000 new positions and 63,000 new hires by 2030.

The IAEA propose a Strategic Workforce Planning system that is composed of a cycle of Workforce Analytics, Workforce development, Execution and Metrics and Business Unit Planning.

They call for a “Coherent intervention by governments, industry, universities and R&D organisations” to provide a feed line of skilled and competent workers.

In the UK the NDA fund R&D in the area of nuclear decommissioning to meet its obligations under the Energy Act “to promote and, where necessary, carry out research in relation to its primary function of decommissioning” and “to ensure that there is a skilled workforce available to undertake the work of decommissioning” (NDA University and Research Strategy). Various universities offer nuclear power material to undergraduates and postgraduates (For example: Manchester, Bristol, Leeds, and Cambridge). These have different levels of direct links to the industry and it is not entirely clear that the situation can be called a “strategy” or described as “coherent” but it does (presumably) provide a feed of skilled (but not experienced) youngsters for the industry.

Figure 1 Knowledge devlopment from IAEA NG-T-6.11

Figure 1 shows the IAEA view of the relationship between workforce planning and knowledge management. Those new to the industry are likely to spend some working, learning and training before becoming independent competent workers and then some further time before achieving recognition as an expert in their field. The art of knowledge transfer management is to ensure that, where an expert leaves for any reason while their skills are still needed, a suitable replacement is ready to take the post.

On the industry side, workforce planning is required Site Licence Conditions 12 and 36 (below). This leads to systems which identify key skills, suitably qualified and experienced personnel and succession management.

The IAEA recommend a knowledge management team and define a list of participating roles and stakeholders for a typical nuclear power plant and the team’s main functions. It then outlines an Organisational Competence Loss Risk Assessment methodology. Among other tools this suggest a risk matrix which lists the skills requirements in each area and maps who, within the organisation, has those skills. This leads to the identification of those areas at risk of knowledge loss and the development of an Action Plan to restore the situation.

Another tool assesses the skills and knowledge of any employee nearing retirement, promotion or otherwise likely to leave their current post and initiates an Action Plan if appropriate.

The remainder of the document provides tools, forms, guidance and case studies.