March 2014

1. 14.Conduct, reporting and follow up of inspection processes associated with construction, installation and commissioning of SSCsPeter Uhrik Design, conduct, reporting and follow-up of inspection programmesrelated to reactor structures, systems and components important to safety March 2014

2. The Session Objectives • To explain the purpose of inspection reports. • To list typical items that create content of inspection reports. • To mention several aspects of distribution and publication of inspection reports. • To mention several general rules and recommendations regarding the writing of inspection reports. • To show several examples of common mistakes in the writing of inspection reports.

3. Content of the presentation • Introduction • Purpose of inspection reports • Content of inspection reports • Distribution and use of inspection reports • Publication of inspection findings • Practical recommendations • Examples

4. Conduct of inspection The inspections are conducted according to approved inspection manuals or program's. There are 25 inspection manuals and they cover areas of: • Emergency preparedness • Safeguards • Hydraulic tests • Testing of electric equipment • Test after construction, modification • Fresh and spent fuel storage • Special aircraft activity • License holders • Implementation safety measures • Fresh and spent fuel transport • Inspection after outages • SSCs with relevance to nuclear safety • Operation • Surveillance • Maintenance • Technical specifications • I & C calibration • Decommissioning and radwaste • Releases • Fire protection • Design modifications • Physical protection • Commissioning • Training and qualifications • Quality assurance

5. Implementation of the inspection programme Licensee is notified in advance by an official letter from UJD /planned inspection/. • date for inspection • names of the leader of the inspection team • names of inspectors /senior, junior/ • area to be inspected • notification that the areas may be extended • number of inspection manual or programme for inspection Site inspector is usually a member of the team.

6. Inspection programme For the inspections not covered with manuals, detailed inspection programme is prepared in advance. Detailed inspection programme includes following information: • Inspection objectives • Place of inspection • Deadlines for inspection preparation and conduct • Documents required to be prepared for inspection by utility • Inspection team • Instructions for inspection conduct • Inspection procedure, criteria, verification • Preliminary deadline for protocol The inspection programme is approved by the chief inspector.

7. Output form the inspection • The content, form and process of approval of an inspection report vary among different countries, but it is generally recognized that from every regulatory inspection a written report should be prepared. • Report from every inspection is prepared - minutes/protocol.

8. Purpose of inspection reports • record the results of all inspection activities relating to safety or of regulatory significance; • document and record an assessment of the operator’s activities in relation to safety; • record discussions held with facility staff, plant management and other concerned persons; • provide a basis for notifying the operator of the findings of the inspection and of any non-compliance with regulatory requirements, and to provide a record of any enforcement actions taken;

9. Purpose of inspection reports • record any findings or conclusions reached by inspectors • record any recommendations by inspectors for future actions by the operator or the regulatory body and to record progress on recommendations from previous inspections; • inform other members of the regulatory body; • contribute to maintaining an institutional memory

10. Content of inspection reports • identification of the facility inspected, the purpose and date of the inspection and the inspectors’ names; • the methods used in the inspection (interviews, observations, review of documents); • reference to applicable requirements; • criteria used in the assessment; • details of facility areas, activities, documents, processes, systems or components which have been inspected, assessed or reviewed; • a record of actual or potential problems relating to safety;

11. Content of inspection reports • a record of the results of any checks for compliance with the terms and conditions of the authorization for the facility and applicable national regulations; • a record of any deficiency or violation found in regulatory inspections, including a record of which requirements or regulations have been contravened; • a record of any regulatory action taken by inspectors and any consequent action taken by the operator in the period covered by the report; • a record of discussions held with the facility’s staff, the operator’s managers and other persons, including a record of discussions with facility managers about points of concern;

12. Content of inspection reports • a record of the findings or conclusions of the inspectors, including corrective or enforcement actions that should be taken; • a record of recommendations made by inspectors for future action, such as a need to advise other inspectors or operators about particular problems, proposals for further inspections or proposals for enforcement actions.

13. Distribution and use of inspection reports • Reports should be distributed according to established procedures in order to provide for the following: • a basis for future regulatory action; • a contribution to maintenance of the regulatory history of the facility • a basis for identifying major or generic issues which necessitate special inspections, changes to inspection plans or generic regulatory action; • information to regulatory staff responsible for review and assessment, for reporting incidents; for regulations and guides;

14. Distribution and use of inspection reports • a basis for periodic reviews of inspection findings, including trends and root causes; • information to regulatory staff responsible for the development of requirements for authorization or new regulations; • a means of sharing information with other site inspectors working at different locations; • a means of passing information to interested parties or governmental bodies; • self-assessment activities.

15. Publication of inspection findings • In order to inform the public of the safety of nuclear installations and of the effectiveness of the regulatory body, findings of inspections and regulatory decisions may be made publicly available. • The extent to which such information is made publicly available will depend on the legal provisions in the State concerned. • Be careful about sensitive information (security, personal data, proprietary information etc.)

16. Practical recommendations • Good inspection report : • what was find good • what was found wrong • what was found! • Strictly separate objective facts from personal judgment and conclusions of inspectors. • Be precise when referring to any document. • Every finding should always be related to a legal requirement.

17. Practical recommendations • Inspection report is always written also for persons that were not involved in the inspection. Hence, anyone who is reading it should be able to get a very clear picture about: • what was inspected • by whom • by what instruments • what was found out • were there any shortcomings • if yes, what and why are they shortcomings

18. Practical recommendations • Good to have pre-defined struture (template) and written procedure for writing, approval and distribution of inspection reports. • Help each other in reading the reports (is it understandable, clear and to the point...?) • Including regulatory orders for corrective measures in the inspection reports is country specific.

19. Example 1 • Avoid subjective and non-precise formulations: • Instead of: „The I&C specialist thinks the system was not installed correctly...“ • Write: „During the personal dialogue with the I&C specialist he stated that the system was not installed correctly...“

20. Example 2 • Write all necessary circumstances: • Instead of: „During the inspection it was discovered that the high-pressure ECCS valve is untighten.“ • Write: „On March 15th, 2009, during an announced walkdown in the room No. A201, at 9:30 a.m. in the presence of RB inspector and primary systems technician it was discovered, that there is a leak from valve XXX. The coolant was dropping on the floor... The whole situation was documented immediately by photographs by resident inspector.“

21. Example 3 • Be precise: • Instead of: „During the inspection all documents required by inspectors were shown and no insufficiencies were found.“ • Write: „Here is the list of documents that were required by inspectors and that were shown by the NPP:... These documents were checked and no insufficiencies were found.“

22. Practical recommendations • It is easy to be strict. • It is easy to be tolerant. • It is difficult to be fair!

23. Summary • There should be an official written and approved inspection report from every inspection performed by a RB • Inspections reports should be worked out according to an internal procedure • Format and content should be pre-defined. • Inspection report should be clear, understandable and objective.

24. Construction Observation – Real Examples Inspection Protocol No 419/2012 Subject: Inspection of anchoring of accumulator seismic stands of the group “C6” in Civil Structure 806/1-03, rooms No 1302, 1303, 1304 and of the group “C5” in Civil Structure 805/1-02 in rooms No 1374 and 1375 Findings …Installation of accumulators 3BTA11,12, including seismic stands, was commenced without the acceptable result of input inspection…

25. Construction Observation – Real Examples (cont’d| Findings …use of other type of anchors bolds… …used injection system HIT-RE 500/500/1 is not certified for the respective use and it is not an equal alternative of injection system HIT-HY 150 MAX.. …Non-compliance between the chemical anchor and the one actually installed …the work was started without internally approved technological procedure ResultReinstallation

26. Construction Observation - Real Examples Conformity check - Emergency water tank 3LAR13BB001 Findings … missing marking of weld joint at the bottom of the tank… … invalid qualification of welders according to applied standards… … insufficient traceability of base material… Result • process audit focused on traceability by supplier of the tank • additional chemical analysis of based material • partially performing new weld joint • qualification test of welder

27. That Was ….. Conduct, reporting and follow up of inspection processes associated with construction, installation and commissioning of SSCsPeter Uhrik Thank You for your attention: Questions? Design, conduct, reporting and follow-up of inspection programmes related to reactor structures, systems and components important to safety March 2014