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Oversight of Licensees’ Human & Organizational Factors in Bulgaria

This technical meeting in Vienna, Austria discussed the regulatory oversight of human and organizational factors in Bulgaria's nuclear facilities. Topics covered included license validity, decommissioning, and regulatory frameworks.

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Oversight of Licensees’ Human & Organizational Factors in Bulgaria

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  1. Oversight of Licensees’ Human & Organizational Factorsin Bulgaria Technical Meeting on Regulatory Oversight of Human and Organizational Factors 14–18 December 2015 Vienna, Austria Hristo Botsoev Nuclear Regulatory Agency

  2. Nuclear Facilities • Kozloduy NPP • Unit 5 (WWER 1000/320) – Licence valid until 2017 (design lifetime) • Unit 6 (WWER 1000/320) – Licence valid until 2019 (design lifetime 2021) • WSFSF – Licence renewed until 2024 • DSFSF – Commissioning permit issued November 2011 • Submitted Application for Operational Licence - February 2015 • Undergoing is assessment of documentation • Kozloduy NPP – New build • Site selection permit issued (3 years) - August 2013 • Site approval application submitted - July 2015 Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  3. Nuclear Facilities State Enterprise RAW Management • SD Decommissioning Kozloduy : Units 1 and 2 (WWER 440): - Licences for Decommissioning issued in November 2014 (10 years) Units 3 and 4 (WWER 440): - Licences for RAW Management Facilities valid until February 2018 - Application for Decommissioning License Submitted in April 2015 • SD RAW town of Kozloduy – Licence renewed until 2025 • SD PR RAW town of Novi Han – Licence valid until 2019 • SD NDF RAW: – Design permit issued May 2012 (3 years) – Application for Site Selection Order and Design Approval Order submitted in August 2015 Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  4. Regulatory body • NRA is the national regulatory authority in the field of the safe use of nuclear energy and ionising radiation, the safety of radioactive waste management and the safety of spent fuel management • NRA assists the chairman in the implementation of his authorities. The chairman of the Agency is an independent specialised body of the executive power • One general department and four departments, divided into general administration and specialized administration • NRA performs its activity through the work of 114 officers, including the Chairman and two deputies • The total number of occupied staff positions –98 as at 31 November 2015 (Inspectors ~ 60%) Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  5. Regulatory body Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  6. Regulatory framework • Act of the Safety Use of Nuclear Energy • Regulations • Regulation on ensuring the safety of nuclear power plants • Regulation on the conditions and the procedure for notification of the NRA about events in nuclear facilities and sites with SIR • Regulation on the terms and procedure for obtaining of vocational qualification and on the procedure for issuing of licenses for specialized training and of individual licenses for use of nuclear power • Safety guides • Guide on management system for facilities and activities • Guide on periodic safety review for NPPs • Guide on safe operation of NPPs • Internal rules • Procedure for inspections in nuclear facilities • Procedure for assessment and analyses of nuclear facilities • Instruction for regulatory oversight of safety culture in licensees’ organizations • Instruction for the activities of the working group on event analyses Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  7. Current regulatory requirements Regulation on ensuring the safety of nuclear power plants • The design shall provide for technical means aimed at precluding human errors or limiting their consequences • Layout of instrumentation and control devices and the way of presenting the information shall be such that the operating staff at the MCR be able to clearly and quickly identify plant status and behaviour, adherence to the operational limits and conditions, identification and diagnosis of the safety system automatic actuation and operation • Control systems for normal operation shall ensure the most favourable conditions to the operating personnel to take the correct decisions for plant management Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  8. Current regulatory requirements • Safety systems shall operate so that any initiated actuation shall lead to complete fulfilment of the safety functions. Recovery of the safety systems in initial state shall require successive actions of the operating personnel • Control safety systems shall be designed to lock the switch-off capability of the operating personnel for at least 30 minutes after an automatic actuation • Possibilities for wrong operation of the control safety systems shall be minimized. Design of the remote control of the safety systems shall ensure that at least two logically connected operator actions (two switches, buttons, etc.) are needed for their actuation. Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  9. Current regulatory requirements • The operating organization shall establish an organizational structure justified for safe and reliable operation. Changes to the organizational structure, which might be significant for safety, shall be justified in advance • Personnel shall be provided with the necessary resources and conditions to carry out work in a safe manner • The operating personnel shall operate the NPP in accordance with written operating instructions and procedures, developed on the basis of the design and technical documentation, the limits and conditions for operation and the results of plant commissioning • The personnel actions prescribed in the instructions shall lead to recovering the plant state to normal operation, or to achieving a safe extended shutdown under accident conditions • At least two operators shall be available at the MCR during plant operation, who have a formal authorization (certificate) issued by the Chairman of the NRA Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  10. Current regulatory requirements Regulation on the conditions and the procedure for notification of the NRA about eventsin nuclear facilities • The analysis of events associated with the human factor shall contain the causes and circumstances for the occurring problems of human behaviour, contributing to the event development • Areas of human errors and other problems in human behaviour, which may be related to procedures, training, communications, human-machine interface, management or supervision has to be identified • The analysis of operational experience shall identify the trends in staff behaviour and operation of the equipment Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  11. Current regulatory requirements Internal rules: • Procedure for inspection activities in nuclear facilities • defines the structure of the inspection program, incl. policy, main principles and requirements; planning, preparation, implementation, documenting, management of results • specifies the inspection areas and the themes of particular interest for each area – requirements on how to observe HOF as work environment, working conditions, management functions and training • Procedure for regulatory oversight of safety culture in nuclear installations • guidance on thecollection of information relevant to safety culture including on HOF Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  12. Regulatory oversight of HOF • Strategy for HOF oversight • The regulatory approach based on verification of regulatory requirements by means of inspections and review and assessment mainly • Oversight methods for HOF used by the RB • Preventive regulatory control - in the issuance of licenses and permits for activities under the ASUNE. The applicant for an authorization is required to submit to the Regulator a set of documents. The documents are reviewed to confirm the compliance with the requirements • Current regulatory control - to verify that the licensee is conducting its activities in compliance with the conditions of the authorization and its own established internal documents through inspections, as well as review and assessment of information periodically submitted by the licensee as specified in the authorizations’ conditions • Collecting information concerning HOF: • This is accomplished by monitoring and walk down of the facility; discussions and interviews with the personnel (but in more comprehensive way); review and assessment of safety documentation (PSR, SAR, reports, procedures, etc), as well as through the inspections and independent review of event analyses reports Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  13. Regulatory functions • Authorization process The review of HOF during authorization process should ensure that: • adequate system for personnel recruitment and selection is in place; recruitment methods are validated; adequate competence requirements exist; adequate training programs • an important aspect of the authorization activities for assessing the human performance of the personnel is the process of licensing of operating personnel and the management of the plant - individual licenses issued for performance of activities in nuclear facilities • assessment of changes in licensees organizational structure • assessment of modifications of SSCs and control room design modifications, with regard to the man-machine interface Technical Meeting on Regulatory Oversight f Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  14. Regulatory functions • Authorization process • planning and implementing activities related to surveillance programmes - work load and the established working conditions • planning, implementation and control of maintenance activities, with regard to the data from operating experience • effectiveness of the interaction between organizational units - operation and maintenance • clear allocation of staff responsibilities Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  15. Regulatory functions • Inspections • technical inspections including aspects of HOF: operating experience feedback; implemented modifications; maintenance activities • review of the human-machine interaction in order to: • determine the actual condition of the plant • is the plant project tolerant to human errors • define measures for ensuring reliable communication are appropriate • information provided to operators is in easily accessible and clear format • reactive inspections in response of unplanned, unexpected situation in nuclear facility, usually carried out to investigate abnormal operational events • personnel encouraging to acknowledge errors and seek help, when needed • operating procedures and practices (whether they are userfriendly), and error prevention techniques Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  16. Regulatory functions • Safety assessment and analyses • analysis of operational events related to human error, breached or non-fulfilled operating procedures, organizational issues (working group in NRA for independent review) • periodic analysis of the safety performance indicators, related to human factors • PSR (Safety factor 12: HF), SAR in relation to implemented modifications • Development of secondary legislation • establishing strong regulatory requirements on HOF Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  17. Challenges and lessons learned • Lack of systematic oversight process which integrates all aspects of HOF into the current inspection process • HOF requirements related mainly to preventing human errors or mitigation of their consequences, ergonomic aspects and organizational structure only • Revision of regulatory requirements • Technical focus of inspections, no adequate view on HOF aspects • Knowledge, skills, competence, HOF background (social and behavior sciences) – BNRA currently has no human factors expertise • Use of safety culture oversight procedure for collecting HOF findings • Training programme for current and new inspectors – HOF oversight elements will be included Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  18. Future plans • development of additional requirements and guidance on HOF • training – continuous process in order to improve the ability to identify relevant information during the normal inspection practice. Appropriate training approaches and innovation formats for educational purposes (videos, computer-based training) to be used as self-training and retraining. As a result all inspectors to acquire at least basic competence for assessing HOF • allocation of sufficient financial and human resources in HOF field – recruitment of HOF experts or additional training and qualification of the available experts • establishment of structured oversight process with integrated HOF aspects • experience exchange at international level through workshops, conferences and technical meetings Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

  19. Thank you for your patience! Technical Meeting on Regulatory Oversight of Human and Organizational Factors, 14–18 December 2015, Vienna, Austria

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