PH3.01/09 Technical assistance for improving the legal framework for nuclear safety and strengthening the capabilities of the PNRI and its TSO

The overall objective of the project is to develop and implement nuclear safety cooperation with the Philippines Nuclear Research Institute (PNRI), in order to enhance and strengthen the regulatory regime. The purpose of this project is to strengthen the capabilities, effectiveness and efficiency of the PNRI to fulfil its regulatory duties. The project activities do not decrease the responsibility of the PNRI to fully perform its independent regulatory safety assessment and respective regulatory decisions. Any project result is not intended to affect the responsibility of the PNRI in this respect and should not be referred to when decisions of the PNRI are grounded.

The specific objectives of this project are to enhance and strengthen certain aspects of the regulatory regime for nuclear safety in the Philippines in accordance with international obligations and internationally accepted criteria and practice. This will be achieved through cooperation with, and support of, the PNRI and its TSO in each of the following areas:

• Regulatory framework in Philippines,
• Regulatory processes for assessing nuclear safety and licensing of nuclear power plants,
• Deterministic and probabilistic safety assessment approach,
• Human resources development plan and training programme for PNRI and its TSO.

To address these topics, four technical tasks were foreseen:

• Task 1: Technical assistance for the enhancement of the regulatory framework in the Philippines;
• Task 2: Enhancement of the regulatory processes for assessing nuclear safety and licensing of nuclear power plants in the Philippines;
• Task 3: Strengthening the capabilities of the nuclear regulator in deterministic and probabilistic safety assessment;
• Task 4: Human resource development plan and training program for PNRI and its TSO.

 
Task 1 Technical assistance for the enhancement of the regulatory framework in the Philippines;
 
The transposition of the US-NRC 10 CFR 50 into the existing CPR Part 07 related to the licensing of nuclear installations was  the main regulatory document to develop in the task.

The issue of emergency preparedness and response was addressed in the CPR Part 07 and also the environmental and radiological impacts mentioned.
Addressed were:

• PNRI draft of “General considerations on the PNRI policy and strategy for safety and the global nuclear safety regime”
• “National policy statement by PNRI on nuclear safety in the Philippines” of November 2014;
• Identification of regulatory documents to be amended, replaced or developed (provisional);
• “Recommendations regarding the improvement of the legislation and regulation of Philippines”
• General regulations for NPPs (identified as a 1st set);
• Regulations for siting, design and construction (identified as a 2nd set);
• Regulations for emergency preparedness and response;
• Regulation for environmental and radiological impacts

A study visit of PNRI experts in Europe (STUK, BEL V, GRS and PNRI) was held.
As an outcome of the PNRI decisions, the documents were restructured into the new sets (CPR 7 - Licensing of nuclear installations) and (CPR 5 - Site evaluation for nuclear installations).
As far as nuclear installations are concerned (except those related to radioactive waste management), RISKAUDIT considers that the nuclear regulatory system of the Philippines will be complete when the last adjustments proposed (in particular taking into account the decommissioning of nuclear installations) and the development of guides will be performed.
 
Task 2 Enhancement of the regulatory processes for assessing nuclear safety and licensing of nuclear power plants in the Philippines;

The objective of this task was to support and give advice to the “Nuclear Regulatory Division” (NRD) of PNRI on regulatory processes for assessing nuclear safety and licensing of nuclear power plants.
Performed meetings and trainings were used to update the PNRI procedures and guides related to:

• the regulatory decision-making process for licensing a nuclear facility;
• the review and assessment process in all phases of installing and operating a nuclear installation;
• issuing, amending, suspending, revoking and terminating licenses;
• the steps to be taken in the preparation of an inspection, the conduct of inspections, and the preparation of inspection reports.

 
Task 3 : Strengthening the capabilities of the nuclear regulator in deterministic and probabilistic safety assessment

The transferred materials and references allow further self-study for improving PNRI experts’ knowledge on the site evaluation assessment; assessment and review of the NPP design for construction licensing and radiological environmental impact assessment. PNRI trainees have acquired the main knowledge and are prepared to apply it to their real work situations as for example provide their recommendations/feedbacks to the final draft of the PNRI regulations developed in Task 1. In addition, they got a clear understanding of the role and responsibilities of the regulatory authority as well as the need for establishing an effective communication with the public during both normal and emergency situations. Despite the just mentioned conclusion, it is recommended to continue PNRI personnel training as part of the Human Resources Development and Training Plan (HRDTP).
 
Task 4 Human resource development plan and training program for PNRI and its TSO.

The objective of Task 4 was to support and give advice to the section “Nuclear Regulatory Division” (NRD) of PNRI on developing its Human Resources Development and Training Plan (HRDTP).
Discussing future duties and tasks of NRD, the following areas of expertise were identified:

• Siting criteria and siting evaluation
• Radioactive waste management and disposal, relevant for radioactive waste from both nuclear power plants and medical and industrial application
• Emergency preparedness (in extension to radioactive sources from medical and industrial applications)
• Capacity building for NPP regulation for the design review phase

Discussing the systematic approach to training, described in the IAEA Safety Reports Series No. 79, NRD has made the decision to use the IAEA-SARCoN-Methodology and the IAEA-SARCoN-Tool for conducting a competence gap analysis.
The HRDTP, the main deliverable of Task 4, was elaborated and structured in two independent parts dedicated respectively to the “Human Resources Development Plan” (Part I) and “NRD Training Programme” (Part II).

Part I of the HRDP starts with the task analysis for NRD in terms of current and future jobs. On the basis of this analysis the human resources planning for NRD has been developed with reference to current and future tasks. A gap analysis for NRD has been performed and inserted into the document.
It is foreseen that in future the results of the initial gap analysis using the SARCoN-Tool will be used in developing individual training programmes for NRD staff. The gaps will be prioritised according to their importance to the regulatory functions and to current and future tasks.
For the current tasks, NRD staff having gaps in technical disciplines concerning radiation protection, assessment of public exposure due to intakes of radionuclides, radiation physics including shielding, and medical physics, should acquire the needed competences by either of the following modes:

• internal or external classroom training,
• distance learning/e-learning,
• or structured self-study.

The same modes of training for the future tasks will be applied to acquire the needed competences in nuclear safety for siting, design, decommissioning and waste management of nuclear facilities & activities, safety analysis report, reactor physics, safety assessment methodology, site evaluation.
On the other hand, for the gaps in skills, e.g. the ability to produce assessment reports, emphasising the findings relevant to safety of a facility or activity and the ability to make judgments regarding the safety of a facility or activity and to assess the regulatory significance of inspection findings, the ability to review and assess application relevant to siting of NPP, safety of NPP design, EIA for NPP, technical aspects of the safety case, ability to develop regulations on Site Evaluations or Site Criteria for NPP, licensing of NPP, safety of NPP design, radioactive waste management & final repositories, coaching and mentoring or on-the-job training are appropriate.
The skills of NRD staff will be enhanced through the experience gained.

Furthermore, in order to fulfill the objectives of the HRDTP commitment at managerial level, financial resources and human resources management shall be guaranteed.
The NRD Training Programme prepared in Part II of the HRDTP document consists of identifying its scope and duration, staff groups for training, NRD training needs, existing training options, effectiveness indicators and trainings and databases. Training needs of NRD staff are identified based on the initial results of a gap analysis using the IAEA-SARCoN-Tool. The results will be analyzed vis-à-vis the current and future tasks. In order to fill in the needed competences, all of the identified gaps will be ranked by subject areas and prioritized according to the need. The individual staff with higher gap in a subject area will be prioritized accordingly. The TNA Committee will consult the training availability from among those listed in the above Sections or from other training providers or assistance from national and international organizations.

Other modes of training, like coaching or mentoring will be allocated in consultation with subject matter experts from the regulatory body. Structured and well defined trainings for each NRD staff member and job position will be developed in consultation with the supervisors.
The HRD plan will serve as the guide in order to realize the training programme. Close monitoring by supervisors is encouraged and should diligently be implemented so that the competency on radiation and nuclear safety of NRD staff is sustained and enhanced.
The HRDTP, the main deliverable of Task 4, has been successfully completed.