ENSI undergoes rigorous scrutiny

ENSI wants to keep its work in line with the highest quality standards. For this reason, the organisation has agreed to undergo a thorough investigative review by a group of experts from the International Atomic Energy Agency (IAEA) between 21 November and 2 December 2011. This is already the second time that the Swiss regulatory body has been scrutinised, and there are also similar reviews for the operators.

Safety is a process, so it must be constantly analysed and – wherever necessary and appropriate – improved, as ENSI Director Hans Wanner has already written. Reviews of authorities and operators by international teams of experts are a key element of this process.

It is important for every regulatory authority and every operator of nuclear plants to take a regular look at themselves in the mirror. This process prevents a blinkered attitude and it may help new ideas to blossom.

The IAEA’s most important review mission for authorities

International reviews are mainly conducted by the Vienna-based IAEA (the International Atomic Energy Agency) and WANO (the World Association of Nuclear Operators). The IAEA reviews authorities as well as operators, whereas WANO focuses on reviewing operators.

The IRRS – or Integrated Regulatory Review Service – is probably the IAEA’s most important review mission for authorities at present. It lasts two weeks, and is conducted by ten to twenty international experts, depending on the areas supervised by the authority under review.

About three years after a mission, what is known as a follow-up mission takes place; this examines the implementation of the opportunities for improvement that were recommended during the mission as such. The international experts are recruited from different countries, and attention is paid to ensure that all cultures (regions of the globe) are represented as far as is possible.

Switzerland was the first European country to undergo a review

As long ago as December 1998, the HSK (or DSN, ENSI’s predecessor organisation) was reviewed by an IRRS mission (known at the time as IRRT, or International Regulatory Review Team). The follow-up mission took place in January 2003. At that time, Switzerland was the first western European country to undergo an international review of this sort. Since then, however, IRRS missions have been conducted in most countries with nuclear plants.

Looking back, former ENSI Director Ulrich Schmocker rates the 1998 mission as very valuable: “This review was something new for us, and we were able to learn a great deal from it. We received important suggestions on improving our supervision concept. Especially in the area of inspection, we learned quite a lot from the IRRT at the time.”

It is now the international practice for missions of this sort to take place about once every ten years. This has actually been stipulated as a requirement within the EU, i.e. the regulatory bodies of the EU countries have to be visited by an IRRS mission every ten years. Switzerland will also adopt this frequency. In this way, ENSI complies with the requirement stipulated in Article 2, paragraph 3 of the ENSI Ordinance, that it should arrange for itself to be reviewed by the IAEA at regular intervals.

Open and honest answers

For the authority under review, the self-assessment is probably the most important task of all. To quote ENSI Director Hans Wanner’s assessment of the imminent mission: “It enables us to realise for ourselves how far our regulatory framework and the supervisory practice that we implement meet the IAEA’s requirements, and where any shortcomings might be present.” Openness and honesty, he adds, are the decisive factors in order to maximise the benefit gained from the IRRS mission.

“It is of little help to conceal shortcomings from the international experts. But conversely, it is helpful for us to point out our own potential deficits, to single out improvement potentials for ourselves, and to obtain the experts’ opinions on them,” Wanner continues. The discussions during an IRRS mission must be conducted in an atmosphere of openness. Experience to date shows that this is the case in most countries, but unfortunately not in all of them. “This can often be explained – but not justified – by specific cultural traits,” he notes.

It goes without saying that the experts cannot carry out a detailed examination of all aspects of the supervisory practice and the regulations in just two weeks; instead, they have to form an opinion on the basis of written documents and observations. The frankness of the information supplied by the authority under review helps to shape this opinion.

Broad-based review

The IAEA’s vision for the IRRS missions is described as “Effective and sustainable regulatory bodies that apply the IAEA safety standards, and share regulatory experiences, knowledge and lessons learned among regulators”. [1] The idea is to implement globally harmonised safety requirements and to ensure ongoing dialogue among the regulatory authorities across all borders and cultures. This is why an IRRS mission focuses on reviewing the implementation of the IAEA safety requirements and recommendations as set forth in the IAEA’s publications (Guides).

The key requirements regarding the regulations, infrastructure and structure of a nuclear regulatory authority are stated in the IAEA’s publication entitled “GSR Part 1“. These requirements provide the foundation for the review by the experts. The review determines the extent to which a country’s regulatory framework takes account of the IAEA requirements and of how far these requirements are implemented in practice at the nuclear plants. For a country such as Switzerland, the following are examples of subject areas that are reviewed in detail:

• Government’s responsibility and remit for the safety of nuclear plants
• Responsibility of the regulatory authority
• Management system of the regulatory authority
• Licensing procedure
• Expert reporting activities
• Inspection system
• Implementation of requirements
• Guidelines
• Emergency preparedness
• Radiation protection, including monitoring of surrounding areas
• Disposal of radioactive waste
• Transport of radioactive substances

In addition, there is frequent discussion of issues such as openness and transparency towards the outside world, cooperation with other authorities, the long-term operation of nuclear power plants and (since 11 March 2011) specific consequences arising from the accident at Fukushima. The subject area covers all aspects of the remit to be carried out by ENSI, together with tasks that must be accomplished by the government and other Swiss authorities in the nuclear sector.

Extensive questionnaire

In preparation for a mission of this sort, the authority under review must compile extensive documentation; in particular, a special questionnaire with about 2000 individual questions on the issues listed above must be completed as part of what is known as a self-assessment. This means a major expenditure of time for the authority (as much as several person-years of work).

The mission proper consists mainly of discussions between the international experts and the authority in order to arrive at a precise understanding of how the authority operates in practice. For this purpose, the experts also observe the authority’s day-to-day work, hold discussions with supervised parties and representatives of other authorities, take part in inspections and observe an emergency exercise.

Based on the written information, the observations and the discussions, the experts draw up the final report, issue recommendations and put forward suggestions for improvements; however, they may also designate particularly innovative procedures as “good practices”, which are then made known to other authorities as well.

The aim of this procedure is to achieve an objective that is stated in the IAEA’s vision: authorities which implement the international safety requirements and adopt a constantly questioning approach in order to continue improving nuclear safety.

ENSI employees have also reviewed other authorities in the past

Aided by the experience they gained from the first mission and thanks to the international recognition accorded to ENSI’s activities, ENSI employees have repeatedly participated as experts in IRRS missions to other countries. They have also been – and still are – appointed as team leaders. The experience gathered during IRRS missions as well as the exchange of experiences are, in turn, incorporated into ENSI’s own work.

ENSI experts who take part in IRRS missions can contribute their own experience, and can work towards the improvement of activities by authorities in other countries. For example, the management system that was developed by ENSI and is implemented in everyday practice is repeatedly commended as a model for other authorities. Conversely, ENSI has benefited from other authorities and (for instance) has adopted the introduction of so-called “plant inspectors” from the UK.

As well as its direct activities related to the missions, ENSI also benefits from the international network that is built up as a result of the missions. If specific questions arise, this makes it easier to contact other authorities in order to discuss specialist topics. One know who the experts are. ENSI is regularly asked to consider questions of this sort, and the organisation is glad to provide information from its own perspective. The IAEA vision – the exchange of experience, knowledge and new findings – is bearing fruit in this area.

Results are in the public domain

The results of the review are made public by the IAEA at the end of the mission because it is important that they are disclosed transparently to all interested parties.

Following the disaster at Fukushima, international reviews of authorities and operators will become even more important, as will the design of plants to withstand external impacts (among other aspects). The European stress test is a move in this precise direction, and it is likely to serve as an international model.