Regulatory approach to Safety Culture

TM on Integration of Safety Culture into Regulatory Practices and the

Regulatory Decision Making Process

IAEA, 6-8 October 2014

Tea Bilic Zabric

Nuclear Slovenia

Mine TRIGA

NPP Krško

Nuclear Facilities

Krško NPP

• Westinghouse PWR

• 2 loop

• 700 MWe

• Commercial operation

since 1983

• Ownership 50:50

Slovenia-Croatia

Nuclear and Radiatioan Facilities

• TRIGA research reactors

• Central Interim RW

Storage

• Former Uranium Mine

• Looking for LLIW

Repository

• >1000 sources of ionizing

radiation

Slovenia, the smallest nuclear country

We have everything the big country has …

… but we have to manage it with less resources!

Slovenian Nuclear Safety Administration

Regulatory oversight

Slovenian Nuclear Safety Administration

Tools for Oversight

• Safety Indicators

• Inspections

• Operating Experience Feedback

• Fuel Cycle and Outage Analysis

• Periodic Safety Review

• Management Meetings

• Integrated Safety Assessment

How to integrate oversight of safety culture in regulatory oversight

SNSA Safety Indicators

Inspections

• No resident inspectors at NPP, site in 100 km distance

• Yearly plan based on: – PSA (PRA) based contribution to the Core Damage Frequency

– Operating experience

– Observations in the previous years

– Unusual events

• Plan is prioritized based on safety significance

• Plan is adjusted during the year according to the needs

• Inspections assist licensing of modifications

• Inspectors pay special attention to safety culture issues

SNSA Risk Based Regulatory Oversight

SNSA Risk Based Regulatory Oversight

Operating Experience Feedback

• In addition to the NPP SNSA has own OEF system

• Screening of incoming information from different sources

• Selecting interesting cases

• Deeper analysis

• Discussion with the NPP

• Implementation of lessons learned

• Lessons related to safety culture

Fuel Cycle and Outage Analysis

• Krško NPP has 18 months fuel cycles

• Refueling outages are most demanding periods from the nuclear safety point of view

• Inspections are on site continuously

• Additional help provided by TSOs

• After the refueling the SNSA’s Analyses is prepared as a basis for the Fuel Cycle Acton Plan

• Special attention is given to Safety Culture during outage activities

SNSA Fuel Cycle and Outage Analysis

OU

TA

GE

Inspection of maintenance activities

Inspection of modifications

Inspection of tests

Formation of SNSA review team

Preparation of review plan

Draft of Outage analysis report

NPP's Outage plan

Co-ordination with NPP and TSOs

Daily meetings and drafting of report

Finalization of the report with the Action plan

Revision of the report with the Action plan

Implementation of the Action plan

Transfer of not fully implemented actions into new cycle

Archiving

+15 d

+30 d

During fuel cycle

-30 d

-30 d

-60 d

-6 m

SNSA TSOs

TSO's report

SNSA

SNSA

SNSA

NPP

SNSA

SNSA

Comments of TSOs and NPP

SNSA

Periodic Safety Review

• Every 10 years nuclear facility must perform a through safety review including: – Design Basis

– Condition of SSC

– Procedures

– Emergency preparedness

– Human Performance

– Safety Culture

– etc

• Action plan for improvements

• PSR is a condition for continued operation

Management meetings

• Meeting of top managers of the NPP and the SNSA twice a year

• Open discussion about problems, challenges and plans

• Good opportunity for better understanding

• Safety culture is issue of discussion

• Safety culture of all participants can be assessed during the meetings...

Integrated Safety Assessment

Technology is easy part...

...challenging is Safety Culture!

Are the operators trustworthy?

Understanding Safety Culture…

...is feeling the spirit inside the organization

understand how it works,

what drives it

It requires permanent and open communication, mutual respect and mutual trust!

The Licensee is responsible for safety!

• Let them have the responsibility!

• Regulator do not make decisions for licensee but – Observe

– Inspect

– Comment

– Advise

– Evaluate

– Challenge their views

• Regulator communicate with the licensee very openly!

SNSA Integrated Assessment System

NPP

Inspections

Rumors

Licensing of

Changes

SNSA Management Meeting (daily)

Feeling about the

Climate in the NPP

Third Party

News

BAD

Reporting Management

meetings

Safety Indicators

Outages

OEF Analyses

SNSA Integrated Assessment System

The basic goal is to detect potential deteriorations

long before any measured evidence could be found and long before any Technical Specification

violations!

If SNSA notice possibility for improvements

• First communicate on technical level to „sell the idea“

• If not accepted: increase informal pressure - meeting with the management

• Only after that follows the order!

Safety Culture in regulations

• The investor or facility operator of a radiation or nuclear facility shall promote a strong safety culture

• Licensee has to monitor Safety Culture

• An extraordinary safety review is ordered in the case:

… – if the safety culture deteriorates to a degree where radiation

or nuclear safety may be threatened;

• Scope of the PSR:

… – Safety Culture

Where are we now?

• Recently discuss results of the safety culture assessment in the NPP

• Continuous assessment of the safety culture in the regulatory body

• Continuous improvement of the safety culture, both regulators and licensee