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«Managing Regulatory Body Competence IAEA SAFETY STANDARDS AND RELATED PUBLICATIONS IAEA SAFETY STANDARDS Under the terms of Article III of its ...»

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Most tasks require at least a working level knowledge of specific policies and procedures. Structured self-study can help the trainee acquire an appropriate level of knowledge. The same standards and controls that apply to formal classroom training (i.e. learning objectives, lesson plans and standards for successful course completion) are implemented for self-study and OJT activities, which are more focused, structured and sequenced to increase their effectiveness. Self-study activities are most effective if they precede and tie directly to a subsequent formal course or OJT activity (i.e. the participant reads and studies the document, then has an opportunity to discuss and to apply it).

A structured self-study guide is developed for each document for which a detailed knowledge or working level knowledge is desired. Each self-study guide may include the objectives, specific actions required by the participant, requirements for management involvement and oversight, review questions and measurable standards for acceptable completion of each activity. Related guides would be combined into a module that would link to a formal course and is required as a prerequisite for attending the following course. This can integrate and sequence learning activities so that each subsequent activity builds and expands on the previous activities.

IV.5. COACHING AND MENTORING

Some regulatory bodies appoint mentors, particularly with new staff.

Mentors are experienced members of staff, not necessarily from the same department as the person being mentored, who help to explain the culture and values of the organization and give advice about the informal aspects of the organization.

Coaching is generally carried out by line managers, and feedback needs to focus on easily identifiable issues and encompass specific characteristics of behaviour as described by Quadrant 4 of the competences. Effective managers coach in two ways: the directive coaching approach, where problem solving is shared; and the reflective approach, where the manager and the staff member together seek to understand joint experiences. Respect is vital to effective coaching — managers are able to influence the behaviour of others favourably if they are highly respected. Coaching and personal performance review processes are complementary because they comprise dialogue between the staff member and the line manager.

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V.1. BACKGROUND IAEA Safety Standards Series No. GSR Part 1 addresses the issues of competences of the regulatory body by requiring that a “process shall be established to develop and maintain the necessary competence and skills of staff of the regulatory body, as an element of knowledge management” (para. 4.13 of Ref. [1]).

IAEA Safety Standards Series No. SSG-16 [6] provides guidance in the form of actions to be implemented by a State embarking on a nuclear power programme to establish an appropriate infrastructure for safety. It states that a considerable period of time is needed to acquire the necessary competences and a strong safety culture before operating an NPP. While prime responsibility for safety must rest with the operating organization, the regulatory body has the responsibility of providing oversight of the overall programme and of authorizing its implementation through a stepwise licensing process.

Figure 3, taken from IAEA Safety Standards Series No. SSG-16 [6], shows some typical steps in the development of a nuclear power programme that are

divided in three major phases:

(a) Phase 1 is ‘Safety infrastructure before deciding to launch a nuclear power programme’ (average duration 1–3 years).

(b) Phase 2 is ‘Safety infrastructure preparatory work for construction of an NPP after a policy decision has been taken’ (average duration 3–7 years).

(c) Phase 3 is ‘Safety infrastructure during implementation of the first NPP’ (average duration 7–10 years).

To implement these steps, actions are needed from one or several organizations involved in the nuclear power programme. For example, the initial site survey in Phase 1 is a step that has to be conducted at the very beginning of the programme by the government or by the future operating organization (if it has already been identified). The purpose is to consider potential sites based on existing data. This is not the site evaluation process that will take place later, probably in Phase 2, and that will require approval by the regulatory body.

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Another example is the need to have the requirements necessary to support the bid specification issued in Phase 2. This is a regulatory body responsibility for developing or adopting regulations against which the bid responses will be assessed.

A major challenge that the regulatory body will face at the beginning of Phase 3 is the regulatory review and assessment of the application for the NPP construction. In general, this is done through the review of a preliminary safety analysis report (PSAR) and other safety related documents, such as a probabilistic safety assessment (PSA). This activity requires competences in a broad range of technical areas that need several years to be developed. It is likely that the regulatory body at this stage will not have all the required competences, and a strategy must be put in place to ensure that the review will be performed effectively by a competent technical team. This strategy can include recruiting staff with the required competences from other organizations that may be from inside or outside the State, contracting external support organizations to assist in the review process or developing its own competences through a training programme. The proper mix of these options needs to be chosen depending on the size and level of maturity of the organization. Section V.4 elaborates on the strategy to be adopted.





It is expected that the regulatory body will be adequately staffed and operational before the commissioning process starts, at the end of Phase 3. At that time, all internal processes and procedures, as well as technical and managerial competences required to oversee the future reactor operation, need to be in place.

The resources, both human and financial, and time required to build a competent regulatory body should not be underestimated.

In an embarking State, the application of the competence model needs to be done in conjunction with human resource planning. The organizational structure and staff numbers (head count) must be determined by senior managers using their (managerial) judgement and taking into account the scope of responsibility of the regulatory body, the legal arrangements in place, the regulatory approach adopted, the analysis of competences required and the availability of external technical support, among other things. Guidance on workforce planning in Phases 1, 2 and 3 is available in IAEA Nuclear Energy Series No. NG-T-3.10, Workforce Planning for New Nuclear Power Programmes [9]. Examples of the scope of responsibility of regulatory bodies related to authorization process may be found in the Report of the Survey on the Review of New Reactor Applications [10].

This appendix relies on the quadrant model of competences introduced in Section 3 of this Safety Report. In addition, it elaborates on the competence model for embarking States and suggests a sequential approach for the development of a regulatory body consistent with the actions presented in IAEA Safety Standards Series No. SSG-16 [6].

V.2. CONSIDERATIONS TO APPLY THE COMPETENCE MODEL TO EMBARKING STATES

This section gives an overview of challenges and issues that might arise during the development phases. It is expected that a regulatory body of an embarking State will have all competences described in the competence model at the time of the NPP commissioning. However, these competences do not need to be developed all at the same time. For example, competences required to establish the regulatory framework or those required for the site assessment need to be established before those related to inspection or to operation. Based on these competences, senior management can apply judgement to determine the number of experts and time frame to recruit and train or to pursue external support.

V.2.1. Quadrant 1: Competences related to legal, regulatory and organizational basis These competence areas are described in Section 3.1.1. The following is a collection of some considerations based on experience from embarking States.

V.2.1.1. Legal basis The staff recruited by the regulatory body need to have a clear understanding of the responsibilities, scope of activities and power limitations of the regulatory body as stated in the nuclear law. The legal framework varies from State to State, and acquiring competences in this field through an appropriate training programme is essential to all staff of the regulatory body, independent of their previous background and experience.

At the very early phase of the nuclear power programme (most probably just after the decision has been taken), the State will become party to international legal instruments such as a comprehensive safeguards agreement and additional protocol, the Convention or Nuclear Safety, and the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management. It is important that the staff of the regulatory body have an overall understanding of those legal instruments and their obligations, since it will be in the frontline to respond to the State obligations.

Another element to be considered is the bilateral agreements that the State or the regulatory body will establish with States with mature nuclear power programmes. These arrangements create opportunities by receiving training support or by the exchange of experts to increase rapidly the competences of the embarking State. Of particular importance in this context is a bilateral agreement with a State that has licensed a similar facility (if the technology had already been defined). Information on the existence and scope of those agreements needs to be provided to the staff.

V.2.1.2. Regulatory policies and approaches

The staff responsible for establishing those policies and approaches (i.e. the senior management of the organization) have to develop a clear understanding of the functions and responsibilities of a regulatory body as stated in IAEA Safety Standards Series No. GSR Part 1 [1] and to be exposed to similar policies developed by other regulatory bodies.

Policies being developed need to state long term goals of the regulatory body, its main mission, core values and regulatory approach to achieve the goals for licensing, and human resource development, among others.

V.2.1.3. Regulations and regulatory guides

The regulatory body of an embarking State needs to understand the nature and scope of the IAEA Safety Standards, since they may be used as a basis for its own regulations. The IAEA Safety Standards are technologically neutral, allowing for an open bid process. However, for the detailed assessment that needs to be conducted in Phase 3, the embarking State may decide to complement the IAEA Safety Standards by a set of more prescriptive regulations. Those could be, for example, the regulations from a State that has licensed a similar facility. In this case, a good understanding of these regulations is also necessary.

V.2.1.4. Management system

The regulatory body needs to develop competent staff to effectively put in place a management system (see Ref. [2]). This would include, among other aspects, the ability to define a structure and hierarchy of documents as well as the approval process, generate documents under the management system and communicate its content to all the staff of the regulatory body.

V.2.2. Quadrant 2: Technical disciplines competences These competence areas are described in Section 3.1.2. The following is a collection of some considerations based on experience from embarking States.



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