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Authorization and Inspection of Nuclear Installation in Korea Sukho Lee Director, International Nuclear Safety School

Authorization and Inspection of Nuclear Installation in Korea

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Authorization and Inspection of Nuclear Installation in Korea

Sukho Lee Director, International Nuclear Safety School

2

Contents

I. Authorization II. Review and Assessment Process III. Licensing Review IV. Inspection Process

First in Regulation and Safety Technology, KINS

I. Authorization

3

Activities of Licensing and Operation

• Two Step Licensing Process

Construction Permit (CP) Phase

Apply for Early Site Approval (ESA)

Operating License (OL) Phase Commercial Operation

Review & Grant ESA

Apply for CP

Review PSAR & Issue CP

Apply for Pre-Operational Inspections (POIs)

Construction, Performance

Apply for OL

Review FSAR & Issue OL

Fuel Load

Conduct POIs

Start-up

Commercial Operation

Start-up Tests

Reload & Apply for Periodic Inspections (PIs)

Conduct PIs

Operating Organization

Regulatory Body

4

Authorization process in Korea

• Specific review process for construction permit and inspection process for construction stage

Operator

Apply for Construction Permit

Commence Construction Work

Apply for Pre - operational Inspections

NSSC

Request Safety Review for Construction Permit

Issue Construction Permit

Request Pre - operational Inspections

KINS

Conduct Safety Review

Submit Safety Review Report

Conduct Pre - operational Inspections

( KINS ) request additional information , ( KHNP ) submit information

( KINS ) conduct inspections , ( KHNP ) corrective actions and submit implementation results

Authorization process in Korea

• Specific review process for operating stage

Applicant

Apply for Operating License

Load Fuel

Start - up Test

NSSC

Request Safety Review for Operating License

Issue Operating License

Confirm Pre - operational Inspection Results

KINS

Conduct Safety Review

Submit Safety Review Report

Submit Pre - operational Inspection Report ( start - up test )

Conduct Pre - operational Inspections

Submit Pre - operational Inspection Report ( construction , performance )

Commence Commercial Operation

First in Regulation and Safety Technology, KINS

II. Review and Assessment Process

7

Review & Assessment Process

To confirm the compliance with regulatory requirements and associated acceptance criteria Use Standard Review Guideline/Procedure

R&A Guidelines • Safety Review Guidelines for PWR • Safety Review Guidelines for Periodic Safety Review of PWR • Safety Review Guidelines for Periodic Safety Review of PHWR • Safety Review Guidelines for Continued Operation of PWR • Safety Review Guidelines for Continued Operation of PHWR

R&A Procedures • Licensing Review Procedure • License Amendment Review Procedure • Periodic Safety Review Procedure • Topical Report Review Procedure

8

Basis for Review & Assessment

Regulation on Technical Standards for Nuclear Reactor Facilities Regulation prescribes the specific requirements pursuant to Articles 12

(Standards for Permits) and 22 (Standards for Licenses) of the AEA

Industry codes and standards endorsed through NSSC Specific requirements for the design, manufacturing, operation, testing,

etc.

KINS Review Guidelines also provide specific guidance For major issues, the key review items are selected and their adequacy

is verified through independent confirmatory audit calculations ECCS and Safety/Accident Analysis, PSA and Sever Accident , etc.

9

Scheduling and Planning Process of Permit and Notification of Review Plan Specified in the Article 21-2 & 3 of Enforcement Decree to AEA Regulatory process for CP or OL should be completed within 24 months. Process within 15 months for the following cases - Capacity, Reactor type, and Design Specifications of the Major Components are

identical to those for which a CP or OL has already been issued

- Identical design to the approved standard design

Review plan be notified in advance to enhance the predictability of licensing - Operating experience, Design changes, Application of the latest technical criteria,

First of a kind design issue, and Issues of significant public concern, etc.

Following periods shall not be counted in the process timing: periods required to supplement or correct the documents

other periods additionally required for excusable reasons - to conduct an experiment in order to verify safety

- period during which the inspection cannot be performed 10

Implementation of R &A All of areas considering up-to-dated Experiences &

other Factors : • Proven provisions or Qualification

EQ, Software Quality of Safety-critical I&C Systems • Consideration of competence and skills and others

Technical Capability for Operation , Human Factor • Incorporating on the latest experience

Cyber Security for Digital I&C Systems • Independent confirmatory audit calculation

Uncertainty and Sensitivity Analysis, Code V & V in Safety Analysis

• On-site verification through regulatory inspection Electric System Design, ECCS Sump Strainer, etc.

11

Records and Maintenance of Results

Recording the Results of Review and Assessment (R &A) KINS reports the review and assessment results in accordance with the

relevant Rules for Entrusted Regulatory Activities

KINS writes review reports for each licensing activity - CP, OL, amendment approval, or report of minor change

Maintaining and utilizing the Results of R &A KINS maintains and controls various records of the licensing activities

documents readily available for the reviewers MIDAS (Management of Information and Data Access System) was

developed using BPM(Business Process Management) concept

persistent accumulation, sharing, and application of regulatory experiences and knowledge resources become possible

information of the previous reviews can be searched and utilized

12

Feedback of Regulatory Information

Various Level of Meetings with Licensee NSSC/KINS maintains open communication channel with the applicant

Briefing sessions, questions and responses, licensing issue meetings, etc.

Industry opinions are collected and factored into decision making process

- Consultative group composed of the experts

- High level and working level talks, and - Technical group meeting and so on.

High Level and Working-Level Talks between Nuclear Safety Related Institutions

Annual meeting between the high level of management of KINS and KHNP

13

First in Regulation and Safety Technology, KINS

III. Licensing Review

14

Licensing Review

Category Construction Operation

Licensing Review

Construction Permit

Operating License

Continued Operation After

Design Life Approval of

Standard Design Amendment of Permit or License

Approval of Topical Report

Other Safety Review

Implementation of Severe Accident Policy

Periodic Safety Review

15

Licensing Reviews

• Objectives – How to maintain and improve the safety level – How to prepare for emergency situations

• Special Attentions – Feedback of domestic and other countries’ operating

experience – Application of new regulatory requirements – Incorporation of the improved design features – Safety features against severe accidents – Quality Assurance Program

16

Review for Early Site Approval (ESA)

• Purpose of ESA – To allow the applicant to do the limited scope works

such as the concrete construction for the site’s land adjustment before CP.

• Documents submitted for ESA Review – Application for the early site approval – Site investigation report – Radiation environmental report (RER)

17

Review for Early Site Approval (ESA) (Cont’d)

• Review Areas – Appropriateness of the candidate site for the

construction of NPP against the risk of natural disaster such as the earthquake and flood and artificial accidents caused by the surrounding industry and military facilities,

– Properness of the basic engineering foundation and excavation method for the nuclear plant construction, and

– Properness of the basic considerations to restrict the radioactive exposure level of neighbors when the radioactive accident occurs.

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Review for Construction Permit (CP)

• Documents submitted for CP – Radiation Environmental Report (RER)

• includes the radioactive impact on the environment by new NPPs, and a plan to monitor the radioactive release from the operating nuclear power plants

– Preliminary Safety Analysis Report (PSAR) • includes all the safety aspects such as basic design information,

functional requirements, and preliminary safety analyses – Quality Assurance Plan (QAP) for construction

• includes the full details of QA system applied to the nuclear plant’s design and construction process and organizations important to the overall quality activities

– Description on the technical capability for nuclear plant installation

19

Review for Construction Permit (CP)

• Safety Analysis Report (SAR) – Role of the SAR

• The primary basis for the review and assessment of the nuclear safety aspects of the proposed facility,

• An important part of the basis for licensing and the safe operation of the facility.

– Requirements on SAR • The SAR should contain accurate and sufficiently precise

information on design and its operation of the facility. • The SAR should be made in such a way that the regulatory body

will be able to evaluate independently the safety of the plant. • The SAR should be controlled in accordance with a quality

assurance program.

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Review for Construction Permit (CP)

• Contents of the SAR of Power Reactors

Chap. 1 Introduction and General Description of Plant Chap. 2 Site Characteristics Chap. 3 Design of Structures, Components, Equipment and Systems Chap. 4 Reactor Chap. 5 Reactor Coolant System Chap. 6 Engineering Safety Features Chap. 7 Instrumentation and Controls Chap. 8 Electric Power Chap. 9 Auxiliary Systems Chap. 10 Steam and Power Conversion System Chap. 11 Radioactive Waste Management Chap. 12 Radiation Protection Chap. 13 Conduct of Operations Chap. 14 Initial Test Program Chap. 15 Accident Analysis Chap. 16 Technical Specifications Chap. 17 Quality Assurance Chap. 18 Human Factor Engineering Chap. 19 Severe Accidents and Risk Evaluation

21

Review for Construction Permit (CP) (Cont’d)

• Docket Review – To assure that the documents submitted by the

applicant contain all necessary details required by Atomic Energy Act and subordinate regulations.

• Time Period for CP Review – 15 months for the reactors that have similar type and

size in design to the previously licensed ones, – Otherwise, 24 months

22

Review for Construction Permit (CP)

• Focus of CP Review – To ensure that the technical standards for the location,

structure, facility, and performance of NPP are met. • Review Areas

– All technical areas addressed in RER, PSAR, and QAP – Details in KINS’ Safety Review Guides (SRG)

• developed based on Standard Review Plan (SRP) of USNRC,

• provide not only the regulatory requirements but also review procedures to keep the consistence in the review results.

• Legal and Technical Requirements – Refer to “Legal System of Nuclear Safety Regulation”

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Review for Construction Permit (CP) (Cont’d)

• Issuance of CP – Based on review results from KINS and the NSC

recommendations, NSSC would issue the Construction Permit.

• Amendment of Construction Permit – If the applicant wants to modify the contents of

approved documents, the applicant must submit the supplement with reason of modification and other related documents to get approval from the NSSC

– The review process of the supplement is the same as the original.

24

Review for Operating License (OL)

• Documents submitted for OL – Final Safety Analysis Report (FSAR) – Technical Specifications for Operation (TS) – Quality assurance plan (QAP) for operation – Radiation Environmental Report (modified contents in the

documents submitted at the construction permit) – Radiation Emergency Plan – Description on the technical capability for the reactor operation – Description on nuclear fuel loading plan – Description of the technical background and verification method

to be for the Emergency Operating Procedure

25

Review for Operating License (OL)

• Docket Review – To assure that the documents submitted by the

applicant contain all necessary details required by Atomic Energy Act and subordinate regulations.

• Time Period for OL Review – 15 months for the reactors that have similar type and

size in design to the previously licensed ones, – Otherwise, 24 months

26

Review for Operating License (OL)

• Focus of OL Review – To confirm that the final design of nuclear reactor

described in the final safety analysis report meet the applicable standards, and

– To ensure that the completed nuclear reactor can be operated as expected throughout the design life.

• Review Areas – Basically same as CP review (focus on revised areas) – Additional review on EOP, TS, etc.

• Legal and Technical Requirements – Same as CP review

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Review for Operating License (OL) (Cont’d)

• Issuance of OL – Based on review and pre-operational inspection results

from KINS and the NSC recommendations, NSSC would issue the Operating License.

• Amendment of Operating License – If the applicant wants to modify the contents of

approved documents, the applicant must submit the supplement with reason of modification and other related documents to get approval from the NSSC

– The review process of the supplement is the same as the original.

28

First in Regulation and Safety Technology, KINS

IV. Inspection Process

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Regulatory Inspection – Type /All Stages

Type Stage Construction Decommissioning

Planned

Pre-operational Inspection

Confirm and

Check-up

Quality Assurance (QA) Inspection

Special Inspection (Ad Hoc) (Safety Issues, Safety Culture, etc.)

Daily Inspection by Resident Office (including Unannounced Inspection)

Reactive Special Inspection (Incident) (Incident Response & Investigation, etc.)

Operation Continued Operation

Periodic Inspection

Atomic Energy Act Article 16 & 23-2 (Inspection)

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Regulatory Inspections

Pre-operational Inspection To confirm the adequacy of materials, components, systems and structures, as well as construction related activities, processes, procedures and personnel competence Performed in compliance with safety assessment results and Safety Analysis Reports, and in reference to the project milestones

Quality Assurance Inspection To confirm the quality achievement of organizations involved in the design, manufacturing, construction, and operation of facilities To verify the effectiveness of QA Program (QAP) and the appropriateness of applicant’s QA activities Performed in reference to the QAP approved by the regulatory body, in a programmatic manner, annually planned for each organization

31

Regulatory Inspections

32

Internal Guidelines Inspections are performed to confirm compliance with regulatory

requirements and the conditions/commitments set out in the authorization and/or safety review & assessment process using internal guidance in the form of the inspection guidelines/ procedures 1. Pre-operational Inspection: ① KINS/GI-N02, Pre-operational [Facility] Inspection Guidelines for PWR ② KINS/GI-N03, Pre-operational [Performance] Inspection Guidelines for PWR ③ Pre-operational Inspection Procedure for Nuclear Power Reactor and

Related Facilities

2. Quality Assurance Inspection: ① KINS/GI-N013, Quality Assurance Inspection Guidelines for Construction

and Operation of Nuclear Power Utilization Facility ② Quality Assurance Inspection Procedure for Construction and Operation of

Nuclear Reactor Utilization Facilities

③ Quality Assurance Inspection Procedure for Production of Major Components for Nuclear Reactor Facilities 33

Internal Guidelines

3. Periodic Inspection: ① KINS/GI-N01, Periodic Inspection Guidelines for Nuclear Power Reactor

and Related Facilities

② Periodic Inspection Procedure for Nuclear Power Reactor and Related Facilities

4. Daily Inspection: ① Daily Inspection Guidelines for Nuclear Reactor and Related Facilities

(NSSC-MSM-002) • Guideline for Daily Inspection of Plant under Operation • Guideline for Daily Inspection of Plant under Construction

• Guidelines for Planned Inspections • Guidelines for Preparing Annual Inspection Report of Resident Office at

Plant.

34

First in Regulation and Safety Technology, KINS

II. Pre-operational Inspection during Construction & Commissioning

35

Pre-operational Inspection Items

Structure inspection begins at the early stage of the site construction at the time when the foundation excavation is on the way (specified in NSSC Notice No. 2010-26 for 11 facilities)

Installation inspection begins when the installations, welding, non-destructive test and pressure test are ready (52 items)

Cold functional test inspection is implemented whether components and systems are properly installed and ready to operate in a cold condition (77 items)

After the integrity of the primary and the secondary system are confirmed, hot functional tests at a temperature of normal operating condition (23 items).

When the OL is granted, the operator can proceed to load fuel into the reactor and continue for core physics and power ascension tests (33 items).

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Pre-operational Inspection Milestone Facilities of the safety related functions and important to safety.

Safety functions are defined in NSSC Notice No. 2009-37: Ensuring the integrity of the reactor coolant pressure boundary Safe shutdown of reactor and maintaining shutdown conditions Functions that prevent or mitigate situations that can exceed offsite radiation exposure dose limits

Example : Milestone of Shin-Kori Unit 3 (APR1400)

* CFT: Cold Functional Test, CHT: Cold Hydrostatic Test, HFT: Hot Functional Test

2008 2009 2010 2011 2012 2013

Structure

Installation

CFT

CHT & HFT

Start-up Test

CP SIT/ILRT RV Install

OL

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Quality Assurance Inspection To verify whether the Quality Assurance Program Description

approved by the regulatory body is appropriately implemented (Articles 31 and 43 of Enforcement Decree) Technical Requirements

QA Inspection of Vendors (Vendor Inspection)

QA Inspection of Licensee (Licensee Inspection)

Technical requirements Regulations on Technical Standards, Article 68-Organization to

Article 85-Audit

CNSC Notification ST.Reactor.026: KEPIC/QAP

Licensee QA Program Description: SRG Ch.17

Contractor QA Program Description: SAR Ch.17

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First in Regulation and Safety Technology, KINS

III. Periodic Inspection during Operation & Refueling Outage

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Periodic Inspection Items

Inspect on both performance of plant facilities (about 57items) and operational capability (5 items)

Since 2005, inspection of the secondary system such as power conversion system has been transferred from MOCIE to NSSC.

Examples of performance inspection Core physics test ECCS test S/G ECT RCS flow rate test Containment isolation system test etc.

Examples of operational capabilities Organization, qualification and training, human factor, EOP,

and operating experience (OE)

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Daily Inspection Procedures • Checking and reporting of status of construction and operation of nuclear power

plants.

• Witnessed inspection of reactors and major facilities related to nuclear materials.

• Verifying safety management and corrective action at the nuclear power plant sites.

• Support of site inspection tasks by KINS at nuclear power plants

• Review and action of reports of changes in minor matters (Regular report to Responsible Manager, Daily business log, Notification of inspection finding slip and keep control log)

Inspection Findings and Report • Inspection finding to NSSC resident office (through PM)

• NSSC orders the licensee to take corrective measures according to the inspection finding treatment method

• Following considerable discussion with the licensees on the items, inspection finding or recommendation tables are issued as per NSSC Notice No.2009-37

• Issuance of an inspection finding requires the signatures of both the regulatory inspector and the licensee of the licensee, and necessary measures are required to be taken by a certain date.

Preparation for Inspections and Performance procedure

41

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