HWR licensing practices in Romania

The current licensing practice for Cernavoda NPP is based on the provisions of the Law and of the regulations issued by CNCAN. The requirements specified in the Law and the regulations are rather general and therefore a number of mechanisms are in place to ensure effective management of the licensing process. The detailed regulatory requirements, as well as the assessment and inspection criteria used by CNCAN in the licensing process, are derived from a number of sources, such as:

• Romanian regulations;

• Limits and Conditions specified in the different licences;

• IAEA Safety Standards and Guides;

• ICRP recommendations;

• Regulatory documents developed by CNSC and US NRC;

• Applicable Standards and Codes (CSA, ANSI, ASME, IEEE, etc.);

• Safety related documentation produced by the licensee and approved or accepted by CNCAN (e.g. Safety Analysis Reports, Safety Design Guides, Design Manuals, reference documents, station instructions, operating manuals, technical basis documents, etc.).

Table 1. Phases features in the development of regulatory requirements for HWR in Romania Phase Phase

Period Phase Features

Phase 1 1967-1989

• Prescriptive approach for regulatory processes;

• Implementation of safety regulations based on IAEA safety guides and US NRC 10-CFR-50 regulations;

• Implementation of quality assurance regulations based on IAEA safety guides and Canadian similar regulations;

• ‘System by system’ approach for the licensing process of Cernavoda NPP;

• Significant conflict of interest: Regulatory Body and Utility belongs the same Governmental Organization (CSEN);

Phase 2 1990-2006

• Prescriptive approach for regulatory processes;

• Implementation of safety regulations based on IAEA safety guides, Canadian regulations, EU countries and the regulations and practices in place in the countries with HWR in operation;

• ‘Milestone’ approach for the licensing process of Cernavoda NPP;

• No conflict of interest between Regulatory Body and Utility;

Phase 3 2007-2015

• Implementation of EU countries experiences and practices for regulatory processes;

• Continuation of the implementation of safety regulations based on IAEA safety guides, Canadian regulations, EU countries and the regulations and practices in place in the countries with HWR in operation;

• ‘Milestone’ approach for the licensing process of Cernavoda NPP;

• No conflict of interest between Regulatory Body and Utility;

• Harmonisation process is in place within WENRA countries for the reactor regulations harmonisation;

• Licensing process for Cernavoda NPP, Units 3 & 4.

The regulatory pyramid used by CNCAN in the licensing process is presented in Fig. 1. Apart from the formally issued (published) regulations, the requirements established by CNCAN in the licensing process are imposed through regulatory letters. Requirements and dispositions are also stated in inspection reports. The licensing submissions include, as the main document, a safety analysis report having content in accordance with the specifications established by CNCAN for each stage of the licensing process. In addition to the safety analysis reports, various supporting documents are submitted by the applicants to demonstrate the safety of the nuclear installation and the fulfilment of all the relevant legislative and regulatory requirements.

The review process performed by CNCAN is documented by one of the following means: evaluation reports, regulatory letters, inspection reports, containing findings and dispositions, written minutes as result of the licensing meetings (common meetings between CNCAN staff and the representatives of the licence holder or applicant). If the review concludes that the applicant has met all requirements, a licence is issue by CNCAN for a limited period of time (usually 2 years). All the limits and conditions derived for each specific case are clearly stated in the licence, which includes sections devoted to quality management, emergency preparedness, radiation protection, reporting requirements, compliance with licensing basis documents, the hierarchy of documents of the licensee, etc.

FIG. 1. Regulatory pyramid used by CNCAN in the licensing process.

CNCAN requirements for the Level II Licensing Schedule for CNE Cernavoda Unit 1, can be summarized as follows:

• CNCAN Requirements for FSAR to be in Compliance with the Licensing Level 2 Schedule;

• Commissioning Phase A ‘Fuel Load’ Prerequisites;

• Commissioning Phase B ‘Criticality’ Prerequisites;

• Commissioning Phase C ‘Low to High Power Operation’ Prerequisites;

• Commissioning Phase D ‘Full Power Operation’ Prerequisites;

• Construction Completion Assurance List;

Regulatory requirements, criteria and conditions

Regulatory letters +

licensee’s documents previously approved by CNCAN (such as Safety Analysis Reports, Management Manuals, etc.) CNCAN dispositions and actions stated in the inspection

reports +

licensee’s procedures previously approved by CNCAN (such as reference documents, station instructions, etc.)

Regulations, Standards and Codes

Law

• Commissioning Completion Assurance List;

• General CNCAN Requirements for the Cernavoda NPP 1 Licensing Level 2 Schedule;

• Safety Compliance Assurance — Basic Requirements;

• Application Contents for Milestones:

• Receive, Store & Use Radioactive Sources;

• Receive & Store Heavy Water;

• Receive & Store Fuel;

• Load Heavy Water Into Moderator System;

• Commissioning Licence;

• Load Fuel;

• Load Heavy Water into PHT System;

• First Criticality;

• Power Increase from Low to High Power;

• On Power Refuelling Demonstration;

• Operating Licence.

The licensing documents explicitly depict the way in which the correspondence between Canadian and Romanian standard requirements must be assured. Meantime, the documents demonstrate that these approaches are not in contradiction. The licensing documents are expected to:

• ensure the completeness of FSAR as a license document;

• ensure the general compliance with the Romanian regulations;

• ensure the compatibility with the Canadian and Romanian operating practices;

• ensure an appropriate Regulatory/Utility interface during the licensing process.

In order to comply with legal requirements and strengthen the connection to reality in the field, and in conformance with the provisions of Law 111/1996, a procedure named: ‘Safety and Compliance Assurance procedure’ (SCA) had to be issued by the Utility. The SCA basic principles were as follows:

• SCA is to demonstrate compliance with the Romanian regulations during construction, commissioning and operation of the plant. SCA will be sent to CNCAN after finalizing the turnover (T/O) process for each system;

• SCA has to demonstrate that the safety requirements stated in the FSAR are actually met. The revision process should be developed simultaneously with the preparation of the Design Completion Assurance (DCA), Construction Compliance Assurance (CtCA) and/or CCA type documents. In this respect, a document called ‘Outstanding Issues List’ will be prepared for each system.

FIG. 2. Critical path to the Unit 2 commissioning milestones status, assessed by regulatory body and utility in the monthly licensing meetings.

5. Conclusions

The evolution of regulatory requirements for HWRs in Romania has a very positive trend. The CNCAN, as safety authority of Romania, established an appropriate strategy for the integration of Canadian regulatory experience and practices into the Romanian licensing process for Cernavoda NPP. The regulatory approach for the units 3 & 4 of the Cernavoda NPP will continue in the same manner as for the previous units 1 & 2. Future amendments to the licensing process will take into consideration compliance with the safety standards and guides, which are anticipated for 2014-2015 at the international level.

DEVELOPMENT OF RISK-INFORMED REGULATORY POSITIONS ON CANDU SAFETY