KELPO2 Developing licensing and qualification of nuclear facilities, phase 2 … · 2020-02-28 · Report 2(36) 14 January 2020 NE-38 Summary Operators in the nuclear sector have

Report

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14 January 2020 NE-38

KELPO2 – Developing licensing and qualification of nuclear facilities, phase 2 Report

Prepared by: Maria Palo, AFRY

Translated from Finnish by:

Lingoneer Oy

Note:

Due to the cross-organisational nature of the project, the normal inspection and approval markings are

not presented herein. The report has been prepared in cooperation with persons who worked with the

KELPO2 Project, and content has been contributed by the person specified as the document creator as

well as other people. The contents of the published report have been reviewed and approved by the

steering group.

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Summary Operators in the nuclear sector have noticed that licensing and qualification processes and

operating practices considered laborious set challenges to projects related to modernisation

and repair of ageing equipment. The supplier network is dwindling and there is less interest in

supplying equipment to nuclear facilities. At present, the considerable quality developments

occurring in other fields of industry over the past decades are not sufficiently taken advantage

of in the nuclear sector.

The competitiveness of nuclear power in a changing operating environment shall be ensured.

The prerequisites for implementing repairs and modernisations relevant in terms of safety and

accessibility shall be ensured. A comprehensive supplier network and availability of high-qual-

ity equipment are necessary to ensure the operational prerequisites and overall safety of the

nuclear sector.

The licence holders’ joint KELPO Project was launched in 2018 to respond to the aforemen-

tioned challenges. In the second phase of the project in 2019, the work mainly focused on

developing the pilot projects and cooperation between licence holders. Discussions with equip-

ment suppliers have also taken place, and international cooperation and information exchange

has occurred particularly at the EU level.

The project introduces changes to procedures and operating methods particularly in relation

to equipment procurements in lower safety classes. With the suggested new procedures, the

aim is to improve overall safety and safeguard the operating conditions of nuclear power in a

changing operating environment. By harmonising procedures in the nuclear sector, enabling

the use of standard equipment particularly in the mechanical discipline and developing pro-

curement and quality assurance processes to become more fit for purpose and clear to equip-

ment suppliers in particular, the changes necessary for the future of the nuclear sector can be

enabled.

In terms of equipment procurements in lower safety classes, particularly in the mechanical

discipline, the aim is to take a new approach where equipment procurement is based on high-

quality standard equipment widely available on the market. The aim is to streamline proce-

dures related to equipment procurements and their quality assurance as well as to modify

supplier assessment and approval procedures so that standard equipment could be used more

widely and the quality of the end product could be better assured using the supplier’s estab-

lished and tested processes.

The cooperation between licence holders is developed, focusing on information sharing, com-

mon activities and joint procedures, documents and templates. To implement the cooperation

on a practical level, there is a proposal to create a shared Digital Platform for licence holders,

which includes databases, procedures, documents and templates to support equipment pro-

curements.

In the pilot projects launched in 2019, new procedures specific to different fields of technology

have been suggested and tested and the joint procedures and documentation of licence holders

have also been partially reviewed. The pilot projects continue in 2020, and their results shall

be presented in more detail in separate final reports.

The development work continues with the KELPO3 project in 2020, with particular focus on

developing and implementing the cooperation between licence holders on a practical level.

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Contents

Summary ............................................................................................................................ 2

Contents ............................................................................................................................. 3

Annexes ............................................................................................................................. 5

Abbreviations and definitions ................................................................................................. 5

1 Introduction .................................................................................................................. 7

2 KELPO Project ............................................................................................................... 8

2.1 Description and goals ............................................................................................ 8

2.2 KELPO, phase 1 .................................................................................................... 9

2.3 KELPO, phase 2 (KELPO2) ..................................................................................... 9

3 Other development work related to the topic ................................................................... 10

4 Purpose of the development work .................................................................................. 11

4.1 Safety and reliability ........................................................................................... 11

4.2 Work allocated based on safety significance ........................................................... 12

4.3 Harmonised operating methods ............................................................................ 12

4.4 Use of standard equipment .................................................................................. 12

4.5 Streamlined and appropriate procurement and quality assurance procedures ............. 13

4.5.1 New procurement model ........................................................................ 13

4.5.2 Roles and duties of the parties ................................................................ 15

4.5.3 Approval of suppliers ............................................................................. 16

4.5.4 Approval of product families and products ................................................ 17

4.5.5 Clarity at the supplier interface ............................................................... 18

5 Cooperation between licence holders .............................................................................. 19

5.1 Background and purpose ..................................................................................... 19

5.2 Implementation of the cooperation ....................................................................... 20

5.3 Content, development and maintenance of the joint Digital Platform ......................... 20

5.3.1 Shared procedures ................................................................................ 21

5.3.2 Shared documents approved for use ........................................................ 21

5.3.3 Templates ............................................................................................ 22

5.3.4 Databases ............................................................................................ 22

5.4 Benefits of cooperation ........................................................................................ 22

5.5 Success factors .................................................................................................. 23

5.6 Complying with competition legislation .................................................................. 23

6 Pilot projects ............................................................................................................... 24

6.1 Pilot projects in general ....................................................................................... 24

6.2 KELPO pilot, mechanical ...................................................................................... 24

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6.2.1 Description ........................................................................................... 24

6.2.2 Key changes compared with the current procedure .................................... 25

6.2.3 Documentation and its harmonisation ...................................................... 25

6.2.4 The estimated impact of the new procedures ............................................ 27

6.2.5 Follow-up measures ............................................................................... 27

6.3 KELPO pilot, electrical ......................................................................................... 28

6.3.1 Description ........................................................................................... 28

6.3.2 Key changes compared with the current procedure .................................... 28

6.3.3 Documentation and its harmonisation ...................................................... 29

6.3.4 The estimated impact of the new procedures ............................................ 30

6.3.5 Follow-up measures ............................................................................... 30

6.4 KELPO pilot, I&C ................................................................................................. 31

7 Summary and further development ................................................................................ 32

7.1 KELPO2 results ................................................................................................... 32

7.1.1 Changes to YVL Guides and other regulations ........................................... 32

7.1.2 Changes in licence holders’ own procedures .............................................. 33

7.2 Further work – KELPO3 ....................................................................................... 33

References ........................................................................................................................ 36

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Annexes 1. Appendix 1 – Example of a procurement process supported by the shared Digital Platform

of the licence holders

Abbreviations and definitions

AIO Authorised inspection organisation

EN European Standard

EYT No nuclear safety classification

FSAR Final Safety Analysis Report

IEC International Electrotechnical Commission

LH Licence holder/applicant

PED Pressure Equipment Directive

SC Safety Class

SIL Safety Integrity Level

STUK Radiation and Nuclear Safety Authority

YVL Regulatory Guides on nuclear safety and security (published by STUK)

Authorised inspection organisation

Authorised inspection organisation shall refer to an independent inspection organisation

approved by the Radiation and Nuclear Safety Authority under Section 60 a of the Nuclear

Energy Act to carry out inspections of the pressure equipment, steel and concrete struc-

tures and mechanical equipment of nuclear facilities in the capacity of an agency perform-

ing public administrative duties.

Digital Platform

A digital cooperation platform for licence holders, used to store and maintain shared data

and materials such as templates, procedures, documents and databases.

FINAS

FINAS is the national accreditation body of Finland. FINAS accredits, or certifies, labora-

tories, certification bodies, inspection organisations, organisers of reference measure-

ments and verifiers of environment and emissions trading.

Graded approach

A principle according to which safety requirements and measures must be commensurate

with and allocated to the level of risk and safety significance.

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Licence holder

Licence holder shall refer to the holder of a licence entitling to the use of nuclear energy.

In this report, licence holder also refers to licence applicant, where applicable.

Licensing and qualification

Procedures for having a system or product approved for use at the nuclear facility.

Low-energy

In safety class 2, ‘low-energy’ refers to equipment with a design pressure of up to 20

bar(g) and a design temperature of up to 120 °C and to which the design, dimensioning

and quality-control requirements of corresponding equipment from safety class 3 can be

applied without causing a risk of the equipment losing operability.

Serially-manufactured equipment

Serially-manufactured equipment is designed, manufactured and tested in accordance

with the manufacturer’s requirements. Typically, the equipment is manufactured in large

batches, and comprehensive user experiences of its various applications are available.

The structure, dimensions and materials of the equipment and the methods and quality

of manufacture does not essentially differ within or across manufacturing batches.

Safety Integrity Level

Safety Integrity Level refers to specifying the integrity of the control functions related to

the safety of the electronic control system in accordance with standard IEC 61508 through

calculating the probability of failures.

The Safety Integrity Level determines the reliability of the safety function. In order to

become SIL-classified, the equipment must pass tests compliant with the standard IEC

61508, wherein level 1 has the lowest-level demands and level 4 has the highest. If the

system implements several safety functions, the level is determined according to the most

demanding safety function.

Standard equipment

Equipment whose manufacture, inspection, testing and documentation are based on com-

monly known standards and procedures, which are also used in other fields of industry

and normally used by the manufacturer.

Standard equipment may be order-based products dimensioned and manufactured to or-

der based on the client’s requirements, or it may be off-the-shelf.

General component requirement specification

The general component requirement specification refers to a document that includes the

component-specific general design and quality control requirements (for mechanical

equipment) set by the licence holder. In component procurement, the requirements set

out in this document shall be supplemented by requirements specific to the service place.

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1 Introduction The development need for the licensing and qualification of nuclear facilities has been widely

recognised in Finland and abroad, and the development work is active and ongoing. By devel-

oping the procedures to make them more appropriate, we can better facilitate modifications at

the plants and lower the threshold for equipment suppliers and manufacturers to participate

in nuclear projects and thereby improve the overall safety of the plants as well as ensure a

comprehensive supplier network.

At present, undertaking modification works that improve the overall safety and operability of

the plants is considered difficult, expensive and laborious. The operating procedures, seen as

heavy, complicate the maintenance and modernisation of ageing equipment and systems, and

do not sufficiently support the implementation of safety-improving actions using modern, reli-

able and commonly available technology. The deviations from manufacturers’ normal practices

and processes due to the special requirements in the nuclear sector also lead to difficulties. In

the nuclear sector, it must be possible to also leverage quality developments achieved in other

fields of industry over the previous decades, which improve the usability and reliability of

standard equipment. In lower safety classes, it would make sense to use high-quality and

reliable, serially-manufactured standard equipment, based on commonly known industrial

standards and used in other fields of industry, which has been manufactured, inspected, tested

and documented in accordance with the equipment manufacturer’s normal procedures.

Operating methods in the nuclear sector need to be reformed to ensure the future of the sector.

New operating methods introduce needs for changes to regulatory requirements and legislation

as well. Changes are necessary in order to ensure a comprehensive supplier network and the

availability of high-quality products and equipment to nuclear facilities going forward. Some

equipment suppliers and -manufacturers have been unwilling to participate in nuclear facility

projects, and some suppliers have decided to withdraw from deliveries to the nuclear sector

altogether. The factor underlying these decisions is that the suppliers and manufacturers find

deliveries in the nuclear sector complicated and financially risky.

Facilitating modifications and modernisations, utilising high-quality equipment and the best

technology as well as ensuring a comprehensive supplier network are all vital for ensuring the

operational feasibility of the nuclear sector and guaranteeing the overall safety of nuclear fa-

cilities in a changing operating environment. The change is unavoidable from the climate per-

spective as well, since all emission-free energy production must contribute to mitigating cli-

mate change.

In order to respond to the challenges and development needs described above, we have

launched the KELPO Project. Its purpose is to develop licensing and qualification procedures

and common operating practices in the nuclear sector, particularly in the lower safety classes.

The KELPO2 Project described in this report follows the first phase of the KELPO Project, im-

plemented in 2018, which examined the development of the licensing and qualification of nu-

clear facilities particularly from the point of view of mechanical components in lower safety

classes [1].

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2 KELPO Project

2.1 Description and goals

The KELPO Project is a collective project of power companies, jointly launched and imple-

mented by licence holders/applicant Fortum, TVO and Fennovoima. STUK also participates in

the project in an observer capacity, contributes to discussions and pilot projects and supports

project work in other respects, too. Observations and suggestions related to the KELPO Project

also play a major role in developing STUK’s own activities.

The goal of the KELPO Project is to

• bring the Graded Approach principle into action and ensure its implementation

• enable the use of high-quality standard equipment in component procurements in the

lower safety classes of nuclear facilities

• ensuring a comprehensive supplier network and good availability of high-quality equip-

ment

• enhance cooperation between licence holders and standardise operating practices (first

in Finland but, later, more widely in the Nordic countries and Europe).

The project aims to develop nuclear facility licensing and qualification processes and proce-

dures as well as related requirements in lower safety classes (particularly in safety class 3) so

that the nuclear sector as a client would not differ from other safety-critical fields of industry,

such as chemical industry, as far as equipment suppliers and manufacturers are concerned.

The goal is to continue engaging the current equipment suppliers in nuclear projects and enlist

new and capable suppliers. The purpose is to ensure that the best suppliers are involved in

nuclear projects in order to secure the availability of modern, highest-quality equipment in the

nuclear sector as well.

The goal of the project is to attain the following benefits through the change proposals related

to requirements and operating practices:

• enabling the use of standard equipment in safety-classified locations, particularly in

safety class 3

• attracting the best equipment suppliers to participate in nuclear projects

• ensuring a comprehensive supplier network and good availability of high-quality equip-

ment

• streamlining the procurement process and shortening equipment delivery times

• enabling a modern, high-quality equipment base for nuclear facilities and improving the

availability of spare parts

• ensuring the smooth and profitable implementation of modification and modernisation

projects

• enabling the completion of modification and repair projects on time and according to the

schedule

• ensuring the appropriate use of resources and allocating them to areas where the overall

safety of nuclear power can be influenced the most

• ensuring the profitable use of nuclear power going forward.

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Developing and enhancing the overall safety of nuclear power is a joint interest of all parties

and a reason why cooperation is needed to reach the goals. Ensuring the profitable use of

nuclear power in the future is particularly important from a climate perspective.

2.2 KELPO, phase 1

The first phase of the KELPO Project was completed in 2018, and a report on the results was

published in January 2019 [1]. The purpose of the project was to develop the licensing and

qualification processes of nuclear facility systems and equipment in lower safety classes while

proposing more appropriate processes and concrete improvements to operating practices and

ensuring further safety developments. At the equipment level, the first phase focused partic-

ularly on procedures and operating methods related to the licensing and qualification of me-

chanical equipment.

2.3 KELPO, phase 2 (KELPO2)

The purpose of the second phase, KELPO2 Project, was to ensure the continuity and progress

of the development work begun in 2018 and expand cooperation and information sharing to

the EU level. Another goal of the project was to provide a common denominator and channel

for information exchange for development projects undertaken by various parties.

In the second phase, equipment-level reviews have been expanded to cover electrical and I&C

equipment, whereas the first phase mainly focused on mechanical components.

The goals set for the KELPO2 Project include:

• specifying and compiling change suggestions resulting from the development work and

concerning legislation and YVL Guides

• specifying and compiling the needs for changes in the companies’ own practices ob-

served during the development work

• determining guidelines and alternative implementation methods and creating prerequi-

sites for decision-making concerning cooperation with licence holders

• expanding the partner network to the EU level and to national operators in other coun-

tries.

This report presents the needs for changes and development proposals in so far as they are

available at the moment of writing. It should be noted that the needs and proposals for changes

shall be specified further as the cooperation continues in 2020.

Areas of the KELPO2 Project are provided in the figure below (Figure 1).

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Figure 1. Areas of the KELPO2 Project.

In the KELPO2 Project, a separate working group assembled from members of the steering

group has been working on developing the cooperation between licence holders and on poten-

tial methods to implement the cooperation. This area will be discussed in chapter 5.

Pilot projects are independent sub-projects jointly implemented by the power companies and

STUK. Project groups and responsible persons and organisations have been specifically desig-

nated for the pilot projects. Pilot projects shall be discussed in more detail in chapter 6.

Discussions with equipment suppliers and manufacturers have also taken place during the

KELPO2 Project. The purpose of these discussions was to seek supplier views on requirements

and operating methods in the nuclear sector as well as their development needs; another goal

was to better understand the procedures used in equipment procurements in other demanding

fields of industry. The aim is to take into account the needs for changes highlighted during the

conversations in this report, in the proposed needs for changes and in the new operating pro-

cedures as a whole.

One sub-area of the project is international cooperation particularly at the EU level. During the

KELPO2 Project, there have been active discussions with parties such as nuclear power oper-

ators in Sweden, France and the Czech Republic. The purpose of the discussions was to survey

what kind of experiences and operating practices other countries have had, explore partnership

opportunities and ensure a parallel approach to development work between the countries.

Information on development work under way in Finland has been actively shared throughout

the project, and participants have attended various international seminars and other events

where the KELPO Project has been introduced.

3 Other development work related to the topic Relating to the topic of the KELPO Project, several development projects are ongoing or have

already been implemented elsewhere. The most important of them is described in this section.

European operators in the nuclear sector work together to ensure a comprehensive supplier

network and guarantee the availability of high-quality equipment. FORATOM, a European or-

ganisation which represents the stakeholders of the nuclear industry, facilitates this work and

has assembled a separate working group to cover the topic. The working group suggests

measures to enable the continuous development of safety and secure a comprehensive, high-

quality supplier network. A related report shall be published in early 2020.

KELPO2

Coopera

tion

betw

een lic

ence

hold

ers

Supplier

inte

rface

and d

iscussio

ns

Pilot

pro

jects

EU

-level coopera

tion

-

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At the EU level, there is an ongoing project titled Modernisation & Optimisation of European

Nuclear Supply Chain, which deals with the same topic as the KELPO Project. Nuclear operators

from several EU countries are participating in the project.

There is a separate development project under way in Sweden, which deals with several topics

similar to the KELPO Project [2]. The development project in Sweden focuses on the following

issues, for example:

• valve procurement according to the API standards used in the oil refining industry

• renewal of the PAKT documents presenting the joint requirements of the Swedish nu-

clear sector

• procurement of programmable I&C equipment according to the standard IEC 61508.

STUK is also developing its operations. STUK’s strategic goal is to ensure risk-informed, com-

mensurate supervision that targets areas where supervision is deemed to have the most influ-

ence. In the VALKE project, the goal is to develop operations so that supervision can be applied

to more safety-critical matters, and the capacity and responsibility of the licence holder can be

taken into account when selecting supervision methods and adjusting the scope of supervision.

Another aim is to modify the regulations concerning the use of nuclear energy so that such

changes in supervision processes can be enabled. According to STUK’s new strategy, the indi-

vidual role of licence holders shall also be highlighted, and safety cannot be achieved through

supervision but as a result of the good work of a responsible operator. The KELPO Project

development work also supports STUK’s goals [3] in accordance with STUK’s new strategy.

Observations and development suggestions related to the KELPO Project are an important

source in this development work.

In 2017, STUK also commissioned a preliminary study “Ydinlaitosten luvitusmallien kehit-

täminen (Luvike)” (Development of the licensing models of nuclear facilities) and followed up

with interviews of Finnish technology companies (Luvike2), where the need for licensing and

qualification development work was clearly recognised. [4][5]

STUK is currently updating the YVL Guides. The updated YVL Guides and their drafts already

contain several improvements with regard to the goals of the KELPO Project. The guide updates

are expected to be completed in early 2020.

4 Purpose of the development work

4.1 Safety and reliability

The purpose of the development work is to create appropriate conditions for continuous im-

provements in nuclear safety as the operating environment changes. The suggested new meth-

ods highlight overall safety and focus on implementing the Graded Approach principle in prac-

tice.

The suggested new procedures take advantage of the quality development occurring in other

fields of industry. Stricter requirements on quality and accessibility have led to the result that

equipment manufactured in accordance with common industrial standards also fulfils the re-

quirement level of the nuclear sector in lower safety classes. By utilising standard equipment,

a comprehensive and high-quality supplier network and the availability of the best components

and spare parts can be ensured. This creates prerequisites for implementing modification and

modernisation projects which are relevant in terms of safety and accessibility.

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4.2 Work allocated based on safety significance

Through streamlining equipment-level operating practices in lower safety classes and devel-

oping procedures, resources can be freed up for work that is more relevant for overall safety.

Currently, both the licence holder and authority expend plenty of resources on work with equip-

ment in lower safety classes in relation to the safety significance of such equipment. It is

important in terms of the plant’s overall safety that careful preparations are made for the

failure of any single piece of safety-classified equipment. Safety design shall be realised

through several consecutive, independent and redundant structures and systems. The redun-

dancy, diversity and separation principles are also applied in design to ensure the operability

of the safety functions in the event of a failure. Systems are designed such as to ensure that

the failure of any single piece of equipment cannot result in the loss of a safety function.

Through developing operations and procedures with the Graded Approach principle, practical

work by both the licence holder and authority can be applied to areas where safety can be

influenced the most.

4.3 Harmonised operating methods

A future goal is to establish more harmonised procedures and operating methods between

licence holders, from the perspective of equipment suppliers and the authorities. This will

streamline operations and reduce overlapping work done by both the licence holder and the

authority.

At this point, the goal is to harmonise operating practices between Finnish licence holders, but

in future, such opportunities should be explored at the international level as well, particularly

with regard to Sweden. During the project, the discussions revealed that harmonised proce-

dures at the European level are not considered possible in near future because the operating

environments in different countries are very unlike each other.

4.4 Use of standard equipment

In nuclear projects, the goal is to enable the use of standard equipment in lower safety classes

so that these locations may use equipment whose manufacture, inspection, testing and docu-

mentation are based on commonly known standards and procedures used in other fields of

industry and normally used by the manufacturer. By using standard equipment, plants have

access to modern and high-quality equipment, and spare parts are also widely available. This

contributes to the development of safety. It should be noted that standard equipment may

involve made-to-order products that are customised to the client’s requirements order-specif-

ically, or it may be involve off-the-shelf products readily available from the manufacturer or

supplier.

It is important to note that there are differences between different fields of technology. With

regard to the current situation of mechanical equipment, standard equipment as such is barely

used in safety-classified locations. With regard to electrical and I&C equipment, the equipment

itself, even in safety class 2, is typically based on common industrial standards. Because of

this, enabling and increasing the use of standard equipment applies largely to mechanical

equipment. However, with regard to electrical and I&C equipment, there often are nuclear

power-specific requirements related to their manufacturer, documentation etc., and the ap-

propriateness of these requirements should be re-evaluated. When qualification feels labori-

ous, this easily leads to the use of old, already qualified equipment types instead of modern

standard equipment at the plants. In addition, the number of suppliers of such equipment is

diminishing.

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Figure 2 displays in green the area where the standard equipment is supposed to be used: A

majority of the equipment in safety class 3 and a part of the equipment in safety class 2 are

such that standard equipment should be able to be used as it is. With EYT equipment, standard

equipment can already be used in light of the current regulations. However, it has been noted

that this is currently not happening in practice, and the current operating procedures of licence

holders in particular should be developed in terms of EYT equipment as well, although the

regulations as such would enable the use of standard equipment. Of course, there will be

further need for nuclear power-specific procedures and standards in higher safety classes and

certain applications.

Figure 2. Displays the application area of standard equipment (in green in the figure).

A majority of nuclear power plant equipment belongs to lower safety classes, and a majority

of modification and repair projects therefore concern equipment in lower safety classes. Thus,

considerable benefits can be gained by developing procedures in this area.

There are no attempts to dissolve the boundary between safety class 3 and EYT through the

use of standard equipment as it is in safety-classified locations, too. EYT equipment and equip-

ment in safety class 3 still have different levels of safety significance. Furthermore, system-

level differences between SC3 and EYT shall be retained. Nowadays, standard equipment as

such is sufficiently high-quality to be used in safety-classified locations as well, particularly in

SC3. Based on experience, it looks like the serial manufacturing, large production volumes and

comprehensive user experiences of standard equipment, and the continuous improvements

and elimination of deficiencies enabled by these factors, lead to higher-quality and more ac-

cessible final products in comparison with individual, customised products produced in small

batches. Best quality is usually achieved when the manufacturer operates according to its

established processes and operating practices.

4.5 Streamlined and appropriate procurement and quality assurance pro-

cedures

4.5.1 New procurement model

In future, the aim is to assume a new way of thinking in relation to equipment procurements

in lower safety classes (mostly SC3- and certain SC2 equipment). This shift in mindset applies

particularly to mechanical equipment. Instead of customising the manufacture of the equip-

ment according to procurement-specific requirements, a standard piece of equipment,

SC1

- ASME

- AFCEN

- KTA

- ...

SC3

- ASME, AFCEN, KTA, ...

EYT

(non-nu-

clear)

SC2

- ASME

- AFCEN

- KTA

- ...

Industrial standards



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demonstrated as suitable for the location by the licence holder, is procured in accordance with

the supplier’s normal processes and methods. Figure 3 describes this change in mindset.

Figure 3. Change of the procurement model, mechanical components in particular.

Along with the new procurement model, equipment widely available on the market is used and

demonstrated to meet the location-specific requirements. The general requirements concern-

ing equipment design, quality management and control, materials, manufacture and documen-

tation are specified in connection with the enquiry/order in the general component requirement

specification, which is prepared so that it complies with the requirements applied to other fields

of industry. The general component requirement specification is drawn up to apply to all licence

holders and to a certain equipment group (it is, therefore, not specific to a procurement or

device). STUK approves the general component requirement specifications. Location-specific

requirements, such as design pressure, - temperature, nozzle size, electrical power, etc. are

specified in a data sheet supplied with the general component requirement specification.

The licence holder’s role is highlighted in the new procurement model. In some cases, the

location involves additional nuclear sector requirements which standard products, normally

delivered to other fields of industry, may not necessarily fulfil, or their fulfilment has not yet

been proved. It will be up to the licence holder to prove the fulfilment of these requirements

through analyses or tests. As a rule, this should not be considered the responsibility of equip-

ment suppliers since it may easily lead to a lower number of suppliers. In the current procure-

ment model, these additional requirements are part of the requirement specification delivered

to the supplier. In the new procurement model, these nuclear power-specific requirements are

processed as a separate package of requirements. It shall be assessed on a case-by-case basis

whether additional measures regarding the supplier’s manufacturing process or standard prod-

uct are required. Any additional nuclear industry requirements applicable to the product are

typically related to the following topics:

• Seismic requirements

• Material requirements derived from radiation resistance

• Requirements derived from decontaminability

From requirements to a customised product

CURRENT

From a standard product to conformity

KELPO

GENERAL REQUIREMENTS

Requirements of the equipment location

GENERAL REQUIREMENTS (based on standards)

Requirements of the equipment location

STANDARD

PRODUCT

CUSTOMISED

PRODUCT

The customised product is

made according to re-

quirements

Suitability of the standard - product is demonstrated

Any additional requirements of the nuclear sector are pro-

cessed separately

Any additional requirements of the nuclear sector in the

requirements

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• Material requirements for surfaces in contact with primary coolants, such as cobalt con-

centration requirements.

If the location is associated with additional nuclear industry requirements, a separate plan shall

be drawn up to take them into consideration. This plan covers all additional measures required

in addition to the delivery of the standard equipment. In particular, one should assess whether

the additional requirements will cause any further measures related to the manufacture or

qualification of the equipment.

With regard to the additional qualification of the equipment, the starting point is that the nec-

essary additional measures are carried out by the licence holder itself or by utilising the joint

qualification processes of the licence holders. Additional qualification procedures are required

from equipment suppliers only for highly compelling reasons. Regarding the manufacture of

the equipment, the aim is to minimise the number of additional measures because they usually

concern the supplier. In these cases, the options include disrupting the normal supplier process

or ordering the equipment from a supplier that, as a rule, manufactures equipment according

to the applicable nuclear industry standard.

The application of the principles of the new procurement model shall be reviewed when pro-

curing electrical and I&C equipment, highlighting the role of the licence holder. However, it

should be noted that electrical and I&C equipment already mainly consists of standard equip-

ment based on normal manufacturer procedures. Therefore, the change is not as significant as

with mechanical equipment.

4.5.2 Roles and duties of the parties

Based on the discussions during the project, it was noted that, at present, the roles of the

various operators and, particularly, STUK’s major role in assessing equipment conformity do

not meet the expectations set to the licence holder or equipment supplier in terms of taking

responsibility and handling the supervision of the supply chain. Currently, licence holders are

undertaking work that should be done by equipment suppliers and manufacturers, while STUK

handles work that should be carried out by the licence holder. The tasks of the parties overlap

partially. Internationally, the situation in Finland is exceptional, because the authorities par-

ticipate to a significant degree in the supervision and inspection of equipment in lower safety

classes as well. This should not, as a rule, be necessary for equipment in lower safety classes.

In future, the role and responsibility of the licence holder should be highlighted more with

regard to successful equipment procurements that meet the requirements. Procedures and

roles shall be developed to correspond with the modern operating environment, as presented

by Figure 4:

• STUK

o Shall ensure that the licence holder has the appropriate procedures in place to

ensure the high-quality and appropriate implementation of procurements.

o Shall monitor the licence holder’s capacity, processes and their implementa-

tion.

o Shall have the opportunity to participate in supplier assessments and inspec-

tions to ensure that the licence holder carries out its tasks appropriately

(please note: STUK’s role does not cover performing its own inspections of

equipment in lower safety classes, but only ensuring that the activities of the

licence holder are appropriate).

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• Licence holder

o Shall have processes and methods in place to ensure that the equipment sup-

pliers and manufacturers are able to perform their duties.

o Shall realise procurements in accordance with its own procedures.

o Shall ensure that the equipment supplier has the necessary processes and

measures in place and that the equipment supplier acts in accordance with

them.

o Shall supervise the equipment supplier to the extent necessary to ensure qual-

ity assurance.

• Equipment supplier

o Shall have processes and measures in place as part of the quality system to

ensure the high-quality and appropriate operations of the entire supply chain.

o Shall see to the implementation of processes and measures and appropriate

quality assurance and supervision measures.

o Its task is to supervise its subcontractors and ensure their quality and ability

to deliver.

Figure 4. Roles and duties of the parties in equipment procurements.

From STUK’s point of view, it is important to place trust in the activities of licence holders. If

power companies are considered to have good and functional processes to guide their activi-

ties, STUK’s role could be more focused on supervising and observing the activities of licence

holders.

4.5.3 Approval of suppliers

When approving suppliers, the focus should shift more towards concrete areas that impact the

quality of the final product. When assessing, auditing and approving equipment suppliers, it is

essential to focus on their ability to deliver and produce quality as well as the factors affecting

the quality of the final product. Particular attention shall be paid to the supplier’s quality control

and assurance processes and their implementation. If the delivery involves a particular

STUK

Monitors the licence holder’s capacity, processes and

their implementation

.

Licence holder Implements procurements and their supervision in ac-

cordance with its procedures

Equipment supplier Manufacture, quality assurance and control according to

the quality system, processes and procedures

Subcontractors Operate in accordance with their own procedures agreed

with the equipment supplier

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requirement that differs from the supplier’s normal activity (such as in relation to earthquakes),

particular attention shall be paid to factors affected by this requirement.

Suppliers who deliver high-quality, reliable standard equipment accordant with their normal

operations and used in other demanding fields of industry shall not, as a rule, be required to

have nuclear power-specific quality control systems, separate quality plans or processes or

measures related to safety culture. The best result can be achieved when the supplier focuses

on its own area of expertise and acts in accordance with its established operating practices.

Procedures and requirements related to safety culture have been created for licence holders

and suppliers of nuclear power-specific equipment (such as primary circuit components) be-

longing to higher safety classes, and they shall not be required from equipment suppliers op-

erating in lower safety classes. The licence holder’s task is to ensure that the equipment sup-

pliers have operating practices in place that ensure a high-quality end product suitable for its

purpose of use.

When procuring standard equipment, the future supplier approval process shall be similar to

what is used in other fields of industry. The situation is different if the equipment is specific to

the nuclear sector and its requirements are not fulfilled by the standard equipment. In that

case, requirements more specific to the nuclear sector shall apply to the supplier and its ap-

proval.

A future goal is to approve the supplier as well as its specific standard product family to be

used within the defined scope. When the supplier’s delivery capacity has been ensured along

with the fact that the supplier’s normal processes result in high-quality end products, it shall

not be necessary to monitor individual equipment deliveries as extensively as now.

4.5.4 Approval of product families and products

In the current procurement procedure, a product is customised according to the requirements,

and qualification is based on demonstrating the conformity of the finished product. In the new

procurement procedure, equipment qualification is based on two parts:

1. Qualification of the family of products (standard equipment)

2. Qualification specific to the procurement or location.

Qualification of a family of products indicates that the standard product or a family of products

resulting from the supplier’s normal manufacturing process meets the general requirements

set for the equipment. In the new procedure, the qualification of a product family is carried

out in one go, and it can be performed jointly for all licence holders. Typically, the qualification

of a product family is done during the first equipment procurement applicable to the product

family in question. Afterwards, the product is qualified for the relevant location. After the first

equipment procurement concerning the product family in question, the only thing that needs

to be done during future procurements is to qualify the equipment based on procurement/lo-

cation, which shall determine the procured equipment’s suitability for the location. Location-

specific qualification is based on the supplier’s normal documentation during manufacture and

the documentation of the test results of the finished equipment. Figure 5 illustrates the two

phases of qualification in accordance with the new procedure. The principle can be applied to

all fields of technology.

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Figure 5. The two phases of qualification in the new procedure in comparison with the current

procedure.

4.5.5 Clarity at the supplier interface

From the point of view of equipment suppliers, procurements and related requirements shall

be clear and the nuclear sector shall not stand out from other demanding fields of industry

(such as chemical industry) as a client unless this is duly justified in higher safety classes, for

example. The production processes and practices of equipment suppliers are based on the

requirements of major client groups and have been refined into a more efficient form. Deviating

from established processes and practices shall cause difficulties, may diminish the quality of

the final product and endanger other forms of production, and suppliers do not gladly take part

in this.

The requirements shall be clearly presented during procurements. Discussions with suppliers

during the project clearly revealed that there is a need to streamline and unify procurement

documentation and requirements as well as their mode of presentation in the nuclear sector.

Licence holders themselves shall identify and process equipment-related requirements (such

as the YVL requirements) and clearly present them to the supplier so that the supplier only

receives the requirements relevant to the delivery, presented in a clear format. In the best

case, the procurement documentation delivered to the supplier does not include any references

to the YVL Guides or other documents specific to the nuclear sector which are not already

known to the supplier. It is the licence holder’s duty to process these requirements so that

they are clear to the supplier.

APPROVAL

Supplier

Product/product family

General equipment

requirements

Individual product

Equipment-

specific requirements

LH - 1

LH - 2

LH - 3 LH - X

LH - X

LH - 1

LH - 2

LH - 3

LH - 1

LH - 2

LH - 3

LH - 1

LH - 2

LH - 3

CURRENT PROCEDURE NEW PROCEDURE

Co

mm

on

(1)

Pro

cure

men

t-sp

ecif

ic

-

Spec

ific

to

licen

ce

ho

lder

-

Pro

cure

men

t-

spec

ific

(2)

-

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5 Cooperation between licence holders

5.1 Background and purpose

Currently, licence holders make procurements and undertake equipment licensing and qualifi-

cation each in their own distinct ways. During the KELPO Project, this became clear from dis-

cussions between licence holders as well as discussions with the authorities and equipment

suppliers. Over the years, companies have developed their own practices and model documen-

tation. There are differences not only between licence holders but also within companies: dif-

ferent projects undertaken in the same company may involve mutually non-conformant prac-

tices, requirements and documents.

The current practice, where each licence holder makes acquisitions and handles the related

documentation, supplier approvals and licensing and qualification documentation separately

leads to overlapping work by the licence holders, and equipment suppliers are provided with

different requirements even though the application of the equipment would be the same. Fur-

thermore, documents may differ greatly from one another. By increasing cooperation between

licence holders, we could leverage the best practices, reduce overlapping work, streamline

operating methods, facilitate modernisation and repair projects and streamline procurements.

The separate practices are visible to the authorities through, e.g., mutually non-conformant

regulatory documentation concerning equipment procurements which is also different in scope.

There are also differences in the requirement level. It would facilitate the work of the authori-

ties if the documentation was more consistent and, where applicable, even identical. If the

procedures and measures were more consistent and better known in advance, STUK’s opera-

tions would also run smoother and it would be possible to reduce regulatory oversight to some

extent.

Equipment suppliers see non-conformant and separate operating practices as inconsistent re-

quirements that are difficult to predict, not only between companies but between different

projects of the same company as well. Furthermore, equipment suppliers feel that procurement

documentation and its mode of presentation is often unclear and difficult to understand. During

the discussions, equipment suppliers hoped that the requirement basis and procurement doc-

umentation between nuclear sector operators could be harmonised.

To harmonise the operations, documentation, procedures and requirements of licence holders,

cooperation shall be increased and provided with a clear and functional framework. Each li-

cence holder and individual project shall have easy and streamlined access to joint procedures,

shared documentation and document templates as well as to information about commonly

approved suppliers and service providers. The companies shall commit to creating and using

these factors as well. In this way, overlapping work by licence holders can be avoided and

prerequisites can be created for harmonised operations with the authorities as well as suppli-

ers. Consistent operations and documentation also facilitate authority work and streamline the

sector’s operating practices as regards suppliers.

The aim of the cooperation is to carry out smoother and more efficient modernisation, modifi-

cation and repair projects as well as more streamlined procurements. Through the cooperation,

procedures and requirements can be harmonised for all licence holders and, thereby, clear and

predictable operating methods and requirements can be established for suppliers. To imple-

ment the cooperation in practice, a joint Digital Platform has been planned during the KELPO2

project. Its implementation method and operation are described in more detail in the next

chapter.

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5.2 Implementation of the cooperation

The aim is to implement the cooperation through a Digital Platform shared by the licence

holders. It is used to store and maintain shared documents, such as templates, procedures

and joint component requirement specifications as well as to maintain a shared database of

approved suppliers and product families along with service providers and qualified equipment.

It is important that the documentation is stored and maintained specifically in a digital envi-

ronment where everyone has access to the latest, similar versions and the documentation is

consistent across all companies. In other words, there should be no individual versions of the

documents, specific to each licence holder, in their own systems.

The licence holders’ joint Digital Platform includes shared databases, procedures, documents

and templates that support the procurements. Licence holders carry out the procurements

independently but, where applicable, using uniform procedures and documents supported by

the Digital Platform, as illustrated by Figure 6.

Figure 6. Procurement supported by the Digital Platform.

As an example, Appendix 1 describes how the Digital Platform supports the licence holder’s

procurement process throughout its different stages.

5.3 Content, development and maintenance of the joint Digital Platform

The licence holders’ joint Digital Platform includes databases, procedures, documents and tem-

plates supporting equipment procurements, as illustrated by Figure 7. At this point, the joint

platform is planned to include:

• joint procedures (such as the approval of suppliers and products/product families)

• shared documents approved for use (such as general component requirement specifica-

tions with a summary of justifications)

• shared templates (such as tendering documentation, data sheets, installation construc-

tion plans and summaries of justifications, suitability assessments etc.)

• a database on approved suppliers/service providers and products/product families

• a database on equipment qualified by licence holders

Digital Platform

(e.g. approved suppliers and

product families)

NEED

Licence holder’s

procurement

process

Supplier

3

Supplier

4 Supplier

N

Supplier

M

Supplier

2

Supplier

1

LICENCE HOLDER

(Commercial affairs) JOINT DIGITAL PLATFORM

(Common technical affairs)

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• documentation, reports, minutes etc. related to approvals and qualifications

Figure 7. Content of the licence holders’ shared Digital Platform and its interface with the licence holder.

The Digital Platform shall provide the opportunity to comment on and register any deficiencies

observed in the documentation to ensure that the necessary measures can be taken in a co-

ordinated manner. Good practices for maintaining, reviewing and updating documentation shall

be in place to ensure that the documentation is up-to-date and to prevent any unwanted de-

velopments over time.

It is important to note that the intention is not to import the licence holders’ current procedures

or documents to the Digital Platform; instead, new ones, shared by the licence holders, shall

be created. Of course, the existing documentation and information shall be utilised in the de-

velopment work where possible.

5.3.1 Shared procedures

The intention is to create shared procedures for licence holders, particularly with regard to

procurements and supplier approvals. At this point, shared procedures that have been identi-

fied include:

• the approval of a supplier/product family

• the procurement and qualification process with the procedures introduced in the KELPO

Project.

5.3.2 Shared documents approved for use

Documents shared by the licence holders that are in accordance with the KELPO approach –

the necessary approvals to use them are applied for from STUK. Documents shared by licence

holders include, for example, general component requirement specifications and their sum-

maries of justification.

The procedures developed during the KELPO Project do not entirely meet the current YVL re-

quirements, but their starting point is to achieve at least an equivalent level of safety. If there

are deviations from the content requirements specified in the documents’ YVL Guides, the

JOINT DIGITAL PLATFORM

Approved suppliers/in-spection bodies

& Approved products/

product families Documents approved for use

(e.g. the common KELPO equipment requirements and their summaries of

justifications)

Products qualified by licence holders

Shared templates (e.g. data sheets, installation construc-tion plan + summary of justifications,

suitability assessments)

Common KELPO procedures

(e.g. approval of suppliers, approval of product/product family)

LICENCE HOLDER

Equipment qualified for

a location

(LH 1, 2, 3)

Licence holder’s pro-

curement process

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necessary deviations shall be applied for from STUK, with the justification of reaching the

desired safety level through alternative measures.

5.3.3 Templates

Another goal is to create shared templates to help harmonise documentation between licence

holders. Such templates have been designed for items such as data sheets, installation con-

struction plans and their summaries of justifications as well as suitability assessments.

5.3.4 Databases

The Digital Platform includes databases on approved suppliers and product families. Licence

holders approve suppliers and product families jointly, to secure the supply of certain products.

It is also important to provide information on the delivery scope the supplier has been approved

for and information on which of the supplier’s products and units are covered by the approval.

Information on equipment qualified by licence holders shall also be imported to the Digital

Platform database. In certain locations in particular, information on which suppliers are able

to deliver certain products is valuable to licence holders. By sharing information on qualified

equipment, work that has already been completed once can be put to further use.

5.4 Benefits of cooperation

The following benefits have been identified that can be achieved through the planned cooper-

ation between licence holders:

• a streamlined joint platform and collaborative methods

• avoiding overlapping work and taking advantage of work that has already been com-

pleted (also with regard to the authorities)

• the growth in the number of potential suppliers when the requirements and procedures

become more streamlined

• improved availability of equipment and spare parts and ensuring the availability of the

best equipment

• cost benefits as a result of reduced overlapping work and a larger number of potential

suppliers

• smoother procurements (predictability, sticking to the schedule and budget) and clarity

to suppliers

• shortening procurement and storage times

• shortening time spent on modification and repair projects and facilitating their timely

implementation

• better and more even quality of documentation and consistent scope

• avoiding excessive specifications through commonly determined requirements and tem-

plates

• focusing technical expertise on shared documentation – no focus on individuals, and the

result does not depend on the creator as heavily

• lighter and more streamlined authority work through harmonised procedures and docu-

mentation

• harmonisation of requirements and, in the long term, equipment between plants

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• improvement of overall safety – resources can be freed up for more safety-relevant

work. In addition, all of these benefits will contribute to safety improvements.

5.5 Success factors

The following important areas have been identified in terms of successfully developing and

implementing cooperation between licence holders:

• understanding the need and reasons for change and the benefits of cooperation across

all organisational levels, among all participants

• licence holders’ commitment to development work and change across all organisational

levels

• ensuring the resources needed for development work

• engagement and commitment to cooperation and change of persons involved in practical

qualification and procurement work

• clear and transparent communication about development work in licence holder organ-

isations

• employees have the chance to be heard and influence the development work

• open review of requirements related to quality management and quality systems by all

parties

• open and active cooperation between licence holders and between licence holders and

authorities

• authority openness to change and understanding the reasons for the change.

The deployment of the Digital Platform and shared documentation shall be carried out without

compromising the daily work and operations of the licence holders’ facilities.

5.6 Complying with competition legislation

It is very important to clarify and take into account any restrictions set by competition legisla-

tion when procurement-related documentation and information is shared between companies.

The content of the Digital Platform and shared documents and procedures shall be carefully

limited so that no breaches of competition legislation occur as a result. On the other hand, the

specific goal of the cooperation is to ensure a comprehensive supplier network and attract new

suppliers to projects in the nuclear sector, thereby increasing competition instead of limiting

it. Taking into account this aspect, the planned cooperation should be acceptable, even desir-

able, from the point of view of competition legislation.

During the development work, matters concerning competition legislation shall be reviewed as

follows:

• before the final approval of the project plan related to the next phase (KELPO3, 2020)

• once the detailed specification of the Digital Platform has been completed

• before deploying the Digital Platform.

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6 Pilot projects

6.1 Pilot projects in general

The KELPO Project proposes new procedures which can facilitate the use of standard/serially-

manufactured equipment in nuclear facilities and safety-classified applications as well as

streamline the implementation of modification and modernisation projects. Pilot projects shall

be implemented in order to test the proposed new procedures and identify their strengths,

weaknesses and change needs as well as the necessary changes in legislation, requirements

and procedures. The procedures proposed in the pilot projects shall be tested in practice and

the necessary deviations shall be applied for from STUK so that the pilot projects can be run

according to the suggested new proposals and equipment procurements can be carried out

accordingly.

Three pilot projects were launched in the KELPO2 phase: mechanical, electrical and I&C pilots.

When this report was being prepared, the pilot projects were still ongoing, meaning that only

intermediate results are available at this point. The results shall be specified as the pilot pro-

ceeds, and individual final reports shall be prepared for each pilot project, presenting its results

and proposed changes to regulations and procedures.

The project groups of the pilots are attended by all power companies and STUK. Depending on

the pilot, equipment procurements are carried out by either TVO or Fortum, which is also

responsible for leading the pilot project in question.

Pilot projects are an important source of information when developing STUK’s activities and

regulations.

Further processing of experiences and change proposals related to pilot projects, translating

the changes into practice and expanding the use of the procedures generally and in other

equipment groups shall be ensured. This shall be taken into consideration as part of the KELPO3

project.

6.2 KELPO pilot, mechanical

6.2.1 Description

TVO is responsible for the mechanical pilot project. The project is a direct continuation of the

first phase of the KELPO Project launched in 2018, which proposed a new procedure for ac-

quiring serially-manufactured mechanical components and ensuring their conformity. This sug-

gested procedure shall be tested in practice in the mechanical pilot project.

The object selected for the pilot project is TVO’s valve replacement process, where 16 valves

in total shall be replaced in the shut-down reactor cooling system. The replaceable valves are

manually operated sluice, ball and poppet valves. The valve safety class is 3 and nominal sizes

are DN200/DN250. The system design temperature is 300 °C and the design pressure is 100

bar. The valves belong to class II of the Pressure Equipment Directive (PED).

The valves selected as targets of the pilot are manually operated, so this pilot project shall not

review any procedures, requirements and documents related to the actuators.

The aim is to install the valves procured in the pilot project to the plant during the annual

outage in May-June 2020.

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STUK is currently updating the YVL Guides. There is a draft of the YVL Guide E.8 concerning

valves, which already aims to facilitate the use of serially-manufactured equipment in compar-

ison with the currently valid YVL Guide [6]. The pilot has compared the proposed new proce-

dure tot this new draft of Guide YVL E.8 and its requirements [7].

6.2.2 Key changes compared with the current procedure

The goal of the pilot is to create and test a practice where the plan and manufacturing inspec-

tions conducted by AIO shall be replaced by quality requirements applicable to the manufac-

turer, manufacture and product of PED’s various module combinations so that the product can

receive a CE marking.

The goal is to utilise the supplier’s normal valve manufacturing process. According to the KELPO

Project’s view, this is the best way to achieve the best result in terms of technology and fi-

nance. According to the project, the best quality of the final product can be ensured when the

manufacturer operates according to its normal, refined operating methods, just like in the case

of valve deliveries in other demanding fields of industry. This shall not be disturbed, and the

normal manufacturing process shall not be interrupted with deviating inspections.

According to the licence holders’ opinion, the quality level ensured by the equipment suppliers’

normal, tested process meets the quality level required from equipment in safety class 3 as it

is, if the supplier is required to

• have a certified quality system

• comply with the PED requirements

• have a CE marking

• comply with equipment standards in design, manufacture and quality control.

The above requirements are considered self-evident by good suppliers.

Contrary to the current practice, a shared general component requirement specification for

licence holders is used in the pilot, and it is supplemented with location-specific requirements.

The mechanical pilot project includes deviations that have been initially identified in compari-

son with the YVL E.8 Guide draft. It was noted during the discussions that there are differences

of opinion between licence holders and STUK as to which ones of these are actual deviations.

According to STUK’s opinion, there are barely any deviations, but the identified deviations are

mostly matters of interpretation. Because of this subjectivity to interpretation, and because

the piloting process still deviates significantly from the procedure accordant with the current

practice and interpretations, these items subject to interpretation have been recorded as de-

viations.

6.2.3 Documentation and its harmonisation

Documentation to be prepared during the pilot project is under way and shall, therefore, not

be presented in this report. Documents created during the pilot project shall be presented in

the final report of the pilot project. This section describes the documentation prepared during

the project.

6.2.3.1 A general component requirement specification with appendices and a summary of justifica-

tions

The key task of the pilot project is to create a general component requirement specification for

licence holders and have it approved by STUK, concerning serially-manufactured valves in

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safety class 3 (SC3) and valves in safety class 2, classified as low-energy (SC2C). The general

component requirement specification applies to all licence holders, meaning that the require-

ments are the same regardless of the licence holder. In the procurement phase, the general

component requirement specification shall be supplemented with plant- and location-specific

requirements. In addition to the actual component requirement specification, it includes a data

sheet and quality control requirements provided as appendices.

Requirements set by the YVL Guides were not included as the basis for preparing the general

component requirement specification. Instead, the starting point was that procedures required

and used in other safety-critical fields of industry, which have been tried and tested, are suf-

ficient for nuclear facility valves in the specified location. In the general component require-

ment specification, requirements set by the YVL Guides can be met by utilising the tested

manufacturing processes of serially-manufactured valves made using a standard procedure.

In practice, this means that harmonised EU standard requirements shall be complied with in

the design, manufacture, inspection and testing of the valves. The plan and manufacture in-

spections by AIO shall be replaced with quality requirements set for the manufacturer, manu-

facturing and product through PED’s various module combinations.

Regarding nuclear power-specific requirements, it was decided that the general component

requirement specification should include acceptably certified quality systems required from the

manufacturer. Approved certification shall refer to the certification of a quality system based

on auditing in which the accreditation of the certification body has been done against the

requirements of standard EN ISO/IEC 17021 and the accreditation is covered by the Multilat-

eral Agreements (MLA) or Mutual Recognition Arrangements (MRA) entered into by FINAS. In

addition, the manufacturer performing the welding of valve pressure-retaining welds shall be

certified in accordance with the standard SFS-EN ISO 3834-2. These requirements were es-

tablished as such that can be met by good manufacturers without exceptions. Furthermore, it

was established that these requirements may possibly increase product quality without harmful

effects on the procurement and manufacture process while guiding users to choose a reliable,

high-quality manufacturer.

In the current procedures, general component requirement specifications are not yet in use.

The YVL requirement applicable to them is relatively new, and general component requirement

specifications are under development by licence holders while discussions about the subject

are going on with STUK. However, the work is well under way, and each licence holder has

approached the matter in their own way to some extent. Because of this, the structure, content

and scope of the general component requirement specifications currently under way beyond

the KELPO Project differ quite a lot between licence holders. In the mechanical pilot project,

the work on a shared, general component requirement specification was begun from scratch.

No document structure corresponding with the current concept of any licence holder was taken

as the starting point.

In the pilot project, the goal is to create a general component requirement specification whose

scope and content is such that it is well suited to be sent to the equipment supplier and does

not include any irrelevant information from the supplier’s point of view. Documentation to be

submitted to the supplier only includes those YVL Guide requirements relevant to the delivery

in question, without any general references to YVL Guides.

A summary of justifications has been prepared for the general component requirement speci-

fication, the purpose of which is to justify and describe to STUK how an operating practice

deviating from the current procedures and requirements and the general component require-

ment specification lead to equally good, or even better, results in terms of safety than

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procedures compliant with the YVL Guides. General component requirement specifications pre-

pared in later stages of the KELPO Project also need to be supported by a corresponding sum-

mary of justifications.

Once the general component requirement specifications of licence holders are shared by all

parties, it is possible to save resources and time related to preparing and maintaining these

specifications. Furthermore, related STUK inspection work is reduced and inspections can more

frequently cover equipment with more safety relevance. STUK has expressed the wish that

licence holders should aim to create shared component requirement specifications instead of

separate ones. Shared documents are more practical from the equipment supplier’s point of

view as well, in comparison with non-conformant documents specific to each licence holder.

Equipment suppliers have also proposed that nuclear sector operators should harmonise their

requirements and their mode of presentation, which was highlighted in discussions with the

equipment suppliers.

6.2.3.2 Other documentation created in the pilot project

During the pilot project, items such as documents related to the inspection and approval of

delivered valves and an installation construction plan with a summary of justifications shall be

prepared. The structure and content of these documents shall become more specific as the

project moves forward.

6.2.3.3 Procurement procedures

Harmonisation of the procurement procedures has not been reviewed in closer detail in this

pilot project. Supplier auditing shall be conducted jointly by licence holders so that all licence

holders are present and the supplier receives the joint approval of all licence holders in the

pilot.

6.2.4 The estimated impact of the new procedures

Based on the data accumulated so far, delivery times of valves acquired in accordance with

the pilot procedure are slightly shorter than in the case of products acquired using procedures

specific to the nuclear sector. The price level of the equipment is also lower, as expected.

However, delivery times and the price level of regular products used in other fields of industry

and in the conventional sector have not been achieved yet. It is possible that suppliers are

careful when they come across a client from the nuclear sector, allowing for more latitude in

scheduling and pricing due to the sector. When the new procedures are included in normal

operations in future and it can be demonstrated that nuclear deliveries in lower safety classes

do not significantly differ from deliveries in other fields of industry, we can expect that this

nuclear “extra” shall be eliminated or at least reduced.

6.2.5 Follow-up measures

The preparation and approval of the general component requirement specifications and related

documents is almost done, and the final approval from STUK is expected in early 2020.

Valve procurement is in progress, and the licence holders shall audit suppliers together. During

the delivery, the valves shall be inspected and approved in accordance with the KELPO proce-

dure, wherein they are approved for use in applications designed for nuclear plant operation.

These procedures are described in more detail in the summary of justifications of the general

component requirement specification.

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The aim is to install the valves during the next annual outage in May-June 2020. Afterwards,

the pilot project can be considered completed as a whole. Experiences and results related to

the pilot project shall be compiled in a final report.

Further processing of the experiences and change proposals related to the pilot project, imple-

menting the changes in practice and expanding the use of the procedure generally and in other

equipment groups shall be ensured. One possible way to proceed would be to apply for a

“continuous deviation” for the applied procedure from STUK after the pilot project, so that the

procedure and the common, general component requirement specification that was created

could be introduced generally. If the deviations observed by licence holders/holder during the

pilot project are largely regarded by the authorities as subject to interpretation and the pilot’s

component requirement specification could continue to be used without a separate deviation

application, this should be clearly recorded in the updated YVL Guide or, alternatively, in a

separate STUK decision. In the current guide draft, the chapter discussing requirements for

serially-manufactured valves still refers to terms such as construction plan and construction

inspection, which strongly steer users towards measures used in the old procedure.

6.3 KELPO pilot, electrical

6.3.1 Description

Fortum is responsible for the electrical pilot. Batteries in safety class 2 were selected as the

object of the pilot. An easy-to-use and simple equipment type was purposefully selected for

the pilot in order to test the qualification process. Together with all the power companies, the

aim is to create qualification documentation on batteries that would be as harmonised as pos-

sible and easily accessible to Fortum, TVO and Fennovoima. The goal is to qualify the batteries

in safety classes 2 and 3 for Fortum in 2020.

6.3.2 Key changes compared with the current procedure

The aim is to propose changes to the current operating methods so that, instead of location-

specific qualification, the manufacturer’s entire battery product line could be qualified in one

go from now on. During equipment renewals, the licence holder selects and procures an ap-

propriately dimensioned set of batteries from an already qualified product line. Currently, the

qualification is carried out separately and location-specifically during each equipment renewal.

The new procedure would not involve an actual location-specific qualification procedure unless

the equipment dimensioning criteria change (that is, unless there are system-level changes

and deviations from the FSAR). The suitability of the selected equipment for the location would

be determined internally by the licence holder.

Previously, a similar procedure has been applied to processing cables and simple serially-man-

ufactured electrical components (relays, contactors, miniature circuit-breakers). In the pilot

project, a similar procedure could be applied to electrical motors as well as batteries under

review. This possibility was highlighted also during discussions with suppliers in the KELPO2

phase.

The electrical pilot also proposes changes to the delivery of equipment-level documentation to

STUK for processing. The goal of the proposal is to lighten the authority workload at the com-

ponent level and, on the other hand, highlight the licence holder’s own role. A preliminary

change proposal for the upper level is provided below (Table 1). The proposal is under way

and will be presented in more detail in the final report of the electrical pilot project. With the

proposal, changes are also proposed to the YVL Guide (YVL E.7) applied to electrical and I&C

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components [8]. These changes are presented in more detail in the pilot project documenta-

tion.

Table 1. A preliminary change proposal concerning the delivery of equipment-level documentation (suita-bility assessments) to STUK.

Current proce-

dure New proposal

SC2 For approval For information

SC3 For information Internal processing by the li-cence holder, no processing by STUK.

SC3 I&C system plat-forms

For information For information (no changes)

Deviations from YVL guides

For approval For approval (no changes)

6.3.3 Documentation and its harmonisation

6.3.3.1 Documents

The electrical pilot project explores the possibilities for harmonising documentation delivered

to equipment suppliers in the enquiry phase as well as authority documentation.

In the pilot project, proposals have been prepared concerning the structure of the suitability

assessment prepared during equipment renewals and the form submitted to the supplier in the

procurement phase. The licence holder records the existing technical requirements in the form,

and the equipment supplier supplements the information with equipment data. Comments from

equipment suppliers regarding the form have been requested as well, to ensure that their point

of view is also taken into account in the development of the documentation. The suitability

assessment and documents sent to the supplier could be consistent between licence holders

(shared templates), and this possibility shall be examined more closely during the pilot project.

Batteries are simple, standard equipment, and not much actual procurement documentation

is delivered to the equipment supplier in the procurement phase. In practice, the equipment is

acquired from importers. Therefore, there are very limited opportunities for harmonising pro-

curement documentation in the electrical pilot. Procurement documentation related to electric

equipment could, in future, be harmonised in terms of requirement specifications related to

the acquisition of electric motors. This need for harmonisation was also highlighted during

discussions with suppliers in the KELPO2 phase.

Suitability assessments of electrical and I&C equipment have been identified as a potential

target for harmonisation. In practice, the YVL Guides determine the content requirements of

suitability assessments, so it would make sense to harmonise their structure for all licence

holders. This way, documentation submitted to the authorities would be similar regardless of

the licence holder and the presentation methods perceived as the best could be used.

Review of the documentation harmonisation possibilities is still under way in the pilot project.

As the work proceeds, the scope and limits of harmonisation possibilities and licence holders’

opinions about the matter shall be specified. The final report of the pilot project shall provide

conclusions related to the harmonisation of the documents.

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6.3.3.2 Requirements

Shared and jointly presented requirements for licence holders could include quality require-

ments based on YVL Guides and standards. In terms of harmonising technical requirements,

possible limiting factors have been identified during the pilot project, such as environmental

conditions, technical design bases, accident conditions and differences in earthquake spectra.

However, it would be useful for licence holders to go through the technical design bases as

well and examine whether they could be harmonised. Minor differences in requirements shall

hardly prevent their harmonisation as long as the equipment meets the requirements of all

licence holders. Instead, too demanding accident conditions and earthquake spectra have been

noted to possibly lead to unnecessary over-dimensioning and elimination of certain equipment

types. Therefore, prudence is called for when harmonising them.

It should be noted that the structure and voltage of the electrical power systems of the Loviisa

and Olkiluoto plants deviate from each other. This results in limited opportunities for harmo-

nising requirements, and fully identical equipment is not suitable for Loviisa and Olkiluoto.

6.3.4 The estimated impact of the new procedures

Currently, electrical equipment involves mainly standard equipment. In particular, batteries

examined in the pilot project are normally acquired as standard equipment from the equipment

supplier, so the equipment itself or the proposed procurement changes in the pilot project shall

have little impact. The suggested changes will have little effect from the point of view of an

equipment supplier/manufacturer. Thus, equipment prices or delivery times are not expected

to change.

The suggested changes impact the license holder’s own work, and through the proposed

change, the workload related to preparing qualification documentation during equipment re-

newals would be reduced. Equipment can also be procured faster when there is no need to

await STUK’s decision, so equipment renewals could be carried out faster in this regard.

Changes also highlight the licence holder’s role and thereby clarify responsibilities. The pro-

posed changes lighten STUK’s workload at the component level, freeing up resources for more

safety-relevant work and supervising the licence holder’s activities and procedures.

6.3.5 Follow-up measures

In the next phase of the pilot project, the aim is to submit the qualification documentation of

the product line to STUK for processing. Once STUK has approved the operating procedure for

the pilot, equipment procurement can be started based on these procedures.

The experiences and change proposals related to the pilot project and their estimated impacts

on resource needs, schedule and costs shall be presented in a report to be prepared at the end

of the pilot project. The report shall also compile the needs for change observed and suggested

during the project and incorporate them into YVL Guides and existing operating practices (also

used internally by licence holders).

Developing and harmonising procedures is estimated to have a larger impact on electric mo-

tors, for example. In future, it would make sense to clarify whether licence holder require-

ments, operations and documentation can be harmonised in this regard. Equipment suppliers

have also expressed this wish.

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6.4 KELPO pilot, I&C

Fortum is responsible for the I&C pilot. The object selected for the pilot is a pressure transmit-

ter family commonly used in industrial manufacturing and manufactured according to industrial

standards and. The aim is to qualify this equipment in safety class 3. At the same time, means

to qualify simple programmable devices shall be examined. The aim is to perform the qualifi-

cation according to the “black box” method [9] in accordance with standard IEC 62138. A

qualification procedure based on the SIL classification, also used in other safety-critical fields

of industry, has been discussed during the pilot project [11]. Qualification based on the SIL

classification has, however, been found to be cumbersome and difficult to leverage particularly

in existing plants. In order to fully leverage the SIL classification and determine the reliability

of the electrical/I&C equipment, the entire measuring/control circuit shall be assessed from

the measuring device to the actuator. This sets additional challenges particularly for the oper-

ating plants OL1-2 and LO1-2, because the existing device circuits are likely not included in

the range of the available SIL service providers. It is also unclear what other analyses should

be carried out for the nuclear power plants.

The I&C pilot project explores the joint qualification of licence holders, i.e. the aim is to qualify

the pressure transmitter so that all licence holders can use it jointly, without having specific

knowledge of the equipment’s exact location of use. The project also explores whether the

documentation related to the pilot project could be harmonised between licence holders.

The qualification of I&C equipment that contains software and has been manufactured for in-

dustrial purposes for safety-classified locations in nuclear facilities has been identified as a

challenging area that requires further development. The availability of analogue devices is

diminishing further, their technology is considered outdated and even the simplest I&C and

electrical devices nowadays often contain simple, programmable technology. Over the years,

programmable devices have become more reliable and uniform in quality due to large produc-

tion quantities. The number of analogue devices, on the other hand, has reduced considerably,

and user experiences are no longer as widely available as before. Their manufacture is not

going to be continued. Modern programmable devices are considered more reliable than ana-

logue devices, and they should be able to be put to practical use in nuclear power plants as

well. However, it has proven difficult to qualify them because software-related information is

often not available that would be required to qualify them according to the current regulations.

Or, acquiring this information and demonstrating its appropriateness according to the current

regulations is highly laborious and often requires information from the original manufacturer.

Often, the software in the equipment cannot be opened and no documentation is available on

its programming process. Requirements and procedures for qualifying simple programmable

equipment should be developed to align with the modern equipment offering.

Work related to the I&C pilot was launched in October 2019, meaning that no results can be

presented at this point. However, the suggested changes are expected to facilitate and accel-

erate the performance of necessary repairs in operating facilities, reduce overlapping work

and, through the use of serially-manufactured equipment, bring about considerable cost sav-

ings. The suggested new procedures, requirement changes and operating methods and their

estimated impacts on equipment availability and the schedules, resource needs and costs of

change projects shall be presented in the final report of the I&C pilot.

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7 Summary and further development

7.1 KELPO2 results

In the second phase of the KELPO Project in 2019, the work mainly focused on developing pilot

projects and cooperation between licence holders. Discussions with equipment suppliers have

also taken place, and there has been international cooperation and information exchange par-

ticularly at the EU level.

The project introduces changes to procedures and operating methods particularly in relation

to equipment procurements in lower safety classes. With the suggested new procedures, the

aim is to improve overall safety and safeguard the operating conditions of nuclear power in a

changing operating environment. By harmonising procedures, enabling the use of high-quality

standard equipment particularly in the mechanical aspect and developing procurement and

quality assurance processes to become more streamlined and appropriate, we can enable the

changes necessary for the future of the nuclear sector. The suggested changes also support

STUK’s new strategy, highlighting the role and responsibility of the licence holder.

Developing and increasing cooperation between licence holders has proven to be extremely

important in terms of the future of the nuclear sector. The implementation methods, scope

and content of the future cooperation have been explored, and to ensure that the cooperation

takes place in practice, we are introducing a joint Digital Platform for licence holders. It con-

tains databases, procedures, documents and templates to support equipment procurements.

From discussions with equipment suppliers, we have obtained valuable insights on how oper-

ations in the nuclear sector should be developed so that it would attract the best experts in

the field.

Through international cooperation and information exchange, relations with other nuclear sec-

tor operators have been established in other European countries, and there is now more aware-

ness of the situations of other countries as well as their ongoing or planned development pro-

jects. The KELPO project has been introduced at several international events. It is not consid-

ered possible to harmonise international operating methods at a wider scale, but operating

methods in the nuclear sector should, where possible, also be harmonised at the EU level. This

is why it is important to continue international cooperation.

In the pilot projects, new procedures have been developed and tested, and possibilities for

harmonising operating methods and documentation across various fields of technology have

been examined. The pilot projects were launched at different points of time in 2019, and they

shall continue in 2020. The results of the pilot projects and the detailed change proposals

concerning YVL Guides, regulations and procedures shall be presented in the final reports spe-

cific to each pilot project.

7.1.1 Changes to YVL Guides and other regulations

The detailed change proposals to YVL Guides arise mainly as a result of pilot projects and shall

be introduced in the final reports of the pilot projects once the projects are completed. This

report presents some deviations and change proposals identified at this point and applicable

to YVL Guides, particularly with regard to the mechanical pilot project (see chapter 6.2).

Improvements concerning the use of standard equipment, included in the new YVL Guides and

their drafts, have been made in the ongoing YVL Guide renewal. At least in terms of the me-

chanical side of things, the pilot project has revealed that interpreting the requirements of the

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new guide draft is not unambiguous in all cases. The YVL Guide E.8 should, therefore, be

clarified in this regard. If the new suggested procedure is considered to meet the requirements

of the YVL Guide as such, the terms used in the YVL Guide need to be clarified because the

terms currently in use steer users towards applying measures used in the old procedure.

As a result of the changes in operating practices described in chapter 4.5.2 and 4.5.3 in par-

ticular, it is necessary to review the needs for change in the YVL Guide A.3 “Leadership and

management for safety” as well as the potential impacts of the changes on requirements pre-

sented in YVL Guides specific to fields of technology, in relation to equipment suppliers [10].

In this regard, there are plans to organise more detailed discussions between licence holders

and STUK.

There must be more specific agreements on submitting change proposals to STUK in a con-

trolled manner and implementing the changes in practice. If the necessary changes cannot be

imported to the YVL Guides in a timely fashion, appropriate measures shall be agreed on (such

as a separate decision) to incorporate the changes into practical work.

7.1.2 Changes in licence holders’ own procedures

Needs for change in the licence holders’ own procedures have been identified as a result of the

KELPO2 project work. The key change proposals in the licence holders’ procedures include:

• Dissemination of information and cooperation between licence holders particularly re-

garding technical issues with equipment procurements in lower safety classes.

• Harmonising procedures, measures and documentation particularly in relation to equip-

ment procurements, within a scope to be agreed separately.

• Highlighting the licence holder’s own role and responsibility in equipment procurements.

• Clarifying requirements in the procurement phase: the requirements set for the equip-

ment supplier shall be unequivocal, already processed by the licence holder and only

cover requirements that are essential for the delivery. References to, e.g., YVL Guides

shall be avoided and the requirements shall be written out instead.

• Transferring the responsibility for demonstrating that requirements specific to the nu-

clear industry (such as in relation to radiation and earthquakes) have been met mainly

to the licence holder (not the equipment supplier) when procuring standard equipment

in lower safety classes.

• Clarifying EYT equipment procurements and eliminating unnecessary nuclear sector re-

quirements from them.

These change proposals shall be supplemented with observations from pilot projects, to be

presented in the final reports of the pilots.

7.2 Further work – KELPO3

The development work will continue with the KELPO3 project in 2020. A preliminary project

plan has been created for the KELPO3 project phase, to be finalised in early 2020. The following

have been determined as the preliminary goals of the KELPO3 project:

• Establish a shared Digital Platform as a cooperation platform for licence holders and

commission it in phases during 2020.

• Harmonise procurement procedures between licence holders and obtain authority ap-

provals for the new procedures.

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• Create shared general component requirement specifications in phases, one equipment

group at a time and within a scope to be agreed, for mechanical equipment in lower

safety classes; apply for the necessary STUK approvals in order to use them in procure-

ments.

• Clarify possibilities for creating shared and consistent documents for all licence holders

with regard to electricity and I&C; begin their preparation.

• Complete the pilot projects launched in 2019 and compile the observed change and

development proposals for further action.

• Continue international cooperation and information exchange and clarify the capabilities

for harmonising operating practices and databases particularly with the Swedish nuclear

industry.

The development of the Digital Platform and cooperation between licence holders shall be con-

tinued in the KELPO3 project in 2020. The work is planned out in more detail in a separate

project plan. When developing cooperation, it is important to take into account the involvement

of the persons who will actually use the information and documentation. This is the best way

to achieve a result that works for the Digital Platform and its users.

During further development, it must be noted that this is about more than deploying a tool –

this requires a comprehensive change of operating practices and mindset. Communication and

engaging different parties to commit to the change across all organisational levels is crucial.

When developing cooperation between licence holders, opportunities for connecting licence

holders’ seismic spectra should also be explored in relation to the seismic qualification of the

equipment. The seismic spectrum of Hanhikivi differs slightly from other plant sites, and the

required seismic spectrum is always specific to the plant site, depending on the equipment’s

location in the building. Regardless, it could be possible to use joint seismic spectra in equip-

ment procurements that cover the requirements of various plant and equipment sites. How-

ever, it should be ensured that this does not lead to requirements so strict that a device might

be unnecessarily eliminated because of it or that an unnecessarily strict requirement would not

otherwise incur additional workload or costs. From a global perspective, Finland’s seismic re-

quirements are, as a rule, very modest, and equipment is often used in much more demanding

conditions in this respect. Common seismic spectra are used in equipment qualification in

countries such as Sweden.

In the development work related to the KELPO project, the starting point was to examine a

mostly mechanical field of technology, after which electrical and I&C technology were included

in the second phase of the review. A more comprehensive review of the development of elec-

trical and I&C technology procedures and documentation as a whole could be needed in future.

Discussions with suppliers should be continued and equipment suppliers should be informed

about the KELPO project. In order to ensure a comprehensive supplier network, it is important

that the development work and changes in the nuclear sector, along with the shift in mindset,

can be seen by the equipment suppliers.

It is highly important to develop nuclear sector procedures and operating methods to safeguard

the operating conditions of existing plants and ensure the future of nuclear power. A compre-

hensive and high-quality supplier network shall be ensured, procurements shall be streamlined

and conditions safeguarded to enable the implementation of modernisation, change and repair

projects relevant for safety and usability. It is important to continue development work to-

gether with STUK, licence holders and other operators so that all parties may provide their

own views on the development work and commit to the changes. Openness to change, an

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interactive atmosphere and cooperation are important for achieving common goals and ensur-

ing the operational feasibility and overall safety of the nuclear industry also in the future.

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References 1. KELPO – Development of the licensing and qualification processes for the systems and

equipment of nuclear facilities in Finland, Final Report, 2019.

2. The use of Commercial Grade Dedication in Sweden - presentation in Energiforsk seminar

on Industry standard components in nuclear I&C applications, Pär Lansåker, Vattenfall,

22/10/2019.

3. STUK’s strategy 2018–2022, https://www.stuk.fi/web/en/about-us/stuk-s-strategy-2018-

2022.

4. Ydinlaitosten luvitusmallien kehittäminen (Luvike), Esiselvitys (Development of the licens-

ing models of nuclear facilities, Preliminary Study). R. Rintamaa / Clenercon Oy, K.

Törrönen / EnergyWave Oy, 2017.

5. Ydinlaitosten valvonnan kehittäminen (Luvike2), suomalaisten teknologiayritysten

haastattelut (Development of supervision of nuclear facilities, interviews with Finnish tech-

nology companies), R. Rintamaa, K. Rintamaa / Clenercon Oy, K. Törrönen / EnergyWave

Oy, 2018.

6. Guide YVL E.8 Valves of a nuclear facility, 15/11/2013, STUK.

7. Guide YVL E.8 Valves of a nuclear facility, Draft 08/04/2019, STUK.

8. Guide YVL E.7 Electrical and instrumentation and control equipment of a nuclear facility,

15/03/2019, STUK.

9. SFS-EN IEC 62138:2019:en, Nuclear power plants - Instrumentation and control systems

important to safety - Software aspects for computer-based systems performing category

B or C functions, 15/10/2019.

10. Guide YVL A.3, Leadership and management for safety, 15/03/2019, STUK.

11. SFS-EN IEC 61508 Functional safety of electrical/electronic/programmable electronic

safety-related systems, 24.1.2011.

https://www.stuk.fi/web/en/about-us/stuk-s-strategy-2018-2022

https://www.stuk.fi/web/en/about-us/stuk-s-strategy-2018-2022