Main Requirements on Different Stages of the

Licensing Process for New Nuclear Facilities

Module 4.7
Commissioning
Geoff Vaughan
University of Central Lancashire, UK

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 IAEA Guidance
The following slides are based on:

• NPP Commissioning and Operation

Requirements

• The version of DS 446 approved by the

Commission on Safety Standards (CSS)

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 Commissioning
Commissioning is the process of ensuring that:
• the as-built design meets the operational safety
characteristics expected in the pre-Construction Safety
Case;
• the operational and management procedures required
to ensure that the plant stays within the defined limits
and conditions for safe operation are in place; and
• any necessary maintenance, inspection and test
activities are implemented.

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 Commissioning stages
• Commissioning can be divided into two main
stages: non-nuclear testing
• (before the introduction of nuclear or certain
types of radioactive material) referred to as
“non-active commissioning” and
• nuclear testing (after the introduction of
nuclear or certain types of radioactive
• material) referred to as “active commissioning”

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From Construction to Operation

At the start of commissioning, all procedures and

processes should be in draft
At the end of commissioning all procedures and
processes should have been validated

Commissioning overlaps with construction as much of

“inactive commissioning” is verifying construction
“Active commissioning” is essentially low power
operation
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 And finally to operation
Just as the as-built design may be a modification of
the initial design, so the as-commissioned
installation may not be the as-built design as
further modifications may be required during
commissioning
Hence the Pre-Operation Safety Case may be a
further iteration of the Pre-Construction Safety
Case.
(NB this will also apply to the USNRC COL process)
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 IAEA Safety Standards
Specific Safety Requirements

Safety of Nuclear Power Plants:

Commissioning and Operation

SSR-2/2

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Commissioning is to effectively the first stage of operation
and many of the requirements in SSR 2/2 are applicable to
the Commissioning stage as well as the operational stage

THE MANAGEMENT AND ORGANIZATIONAL STRUCTURE OF

THE OPERATING ORGANIZATION

Requirement 1: Responsibilities of the operating

organization
Requirement 2: Management system
Requirement 3: Structure and functions of the operating
organization
Requirement 4: Staffing of the operating organization
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MANAGEMENT OF OPERATIONAL SAFETY

Requirement 5: Safety policy

Requirement 6: Operational limits and conditions
Requirement 7: Qualification and training of personnel
Requirement 8: Performance of safety related activities
Requirement 9: Monitoring and review of safety performance
Requirement 10: Control of plant configuration
Requirement 11: Management of modifications
Requirement 12: Periodic safety review
Requirement 13: Equipment qualification
Requirement 14: Ageing management
Requirement 15: Records and reports
Requirement 16: Programme for long term operation
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 OPERATIONAL SAFETY PROGRAMMES

Requirement 17: Consideration of objectives of nuclear

security in safety programmes
Requirement 18: Emergency preparedness
Requirement 19: Accident management programme
Requirement 20: Radiation protection
Requirement 21: Management of radioactive waste
Requirement 22: Fire safety
Requirement 23: Non-radiation related safety
Requirement 24: Feedback of operating experience

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 PLANT COMMISSIONING - 1
Requirement 25: Commissioning programme
The operating organization shall ensure that a commissioning
programme for the plant is established and implemented.

The commissioning programme for the plant shall cover the full range of plant
conditions required in the design and the safety case.

The results shall be used to demonstrate that the behaviour of the plant as
built is in compliance with the design assumptions and the licence conditions.

Special attention shall be paid to ensuring that no commissioning tests are

performed that might place the plant in an unanalysed condition.

Commissioning stages, test objectives and acceptance criteria shall be specified

in such a way that the programme is auditable.
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 PLANT COMMISSIONING - 2
The commissioning programme provides the means of identifying hold points
in the commissioning process.

The commissioning programme shall be divided into stages and proceeding to

the next stage is dependent on the review of the test results.

Resulting from the review succeeding stages may be modified due to the test
results, because some tests had not been undertaken, or not completed.

The results for some stages may be subject to approval by the regulatory body
before commissioning can proceed to the next stage.

The programme shall include all the tests necessary to demonstrate that the
as-built plant meets the requirements of the safety analysis report, satisfies
the design intent and, consequently, that the plant can be safely operated.

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 PLANT COMMISSIONING - 3

Operating and maintenance procedures shall be validated, with

the participation of future operating personnel.

Suitably qualified operations personnel shall be directly involved

in commissioning to ensure preparation for the operation.

Reference data on structures, systems and components shall be

retained for ensuring the safety of the plant and safety reviews.

All the functions and procedures of the operating organization

shall be performed, verified and validated during commissioning.

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 PLANT COMMISSIONING - 4
Initial fuel loading shall not be authorized until all relevant
pre-operational tests have been performed and the results have
been accepted by the operating organization and the regulatory
body.

Reactor criticality and initial power increase shall not be

authorized until all necessary tests have been performed and
the results have been accepted by the operating organization
and the regulatory body, as appropriate.

The tests of the commissioning programme shall be successfully

completed as a necessary condition for authorization for normal
operation of the plant to be commenced.
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 PLANT OPERATIONS
Requirement 26: Operating procedures
Requirement 27: Operation control rooms and
control equipment
Requirement 28: Material conditions and housekeeping
Requirement 30: Core management and fuel handling

MAINTENANCE, TESTING,
SURVEILLANCE AND INSPECTION
Requirement 31: Maintenance, testing, surveillance and
inspection programmes
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 IAEA Safety Standards
Specific Safety Guide

Commissioning for
Nuclear Power Plants

DS 446 (draft approved by CSS)

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 DS 446 - 1
THE COMMISSIONING PROCESS

• OBJECTIVES OF COMMISSIONING
• THE COMMISSIONING PROGRAMME
• STAGES OF COMMISSIONING
• EXECUTION OF THE COMMISSIONING
PROGRAMME
• ROLE OF THE REGULATORY BODY
• ROLE OF THE OPERATING ORGANIZATION

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 DS 446 - 2
ORGANIZATION AND MANAGEMENT OF COMMISSIONING

• MANAGEMENT SYSTEM FOR COMMISSIONING

• ORGANIZATIONAL ARRANGEMENTS FOR COMMISSIONING
• FUNCTIONS AND RESPONSIBILITIES IN COMMISSIONING
• INTERFACES IN COMMISSIONING
• TRANSFER OF SYSTEMS AND HANDOVER OF THE PLANT IN COMMISSIONING
• RESOURCES FOR COMMISSIONING
• QUALIFICATION AND TRAINING FOR COMMISSIONING
• MEASUREMENT, ASSESSMENT AND IMPROVEMENT
• MAINTENANCE DURING COMMISSIONING
• ARRANGEMENTS FOR EMERGENCY PREPAREDNESS AND RESPONSE IN
COMMISSIONING
• MANAGEMENT OF UNEXPECTED EVENTS IN COMMISSIONING
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 DS 446 - 3
IMPLEMENTATION OF THE COMMISSIONING PROGRAMME

• COMMISSIONING TESTS
• PREPARATION FOR TESTING
• PREREQUISITES FOR TESTINGTESTING STAGES AND SEQUENCES
• REVIEW, EVALUATION AND REPORTING OF TEST RESULTS
• HANDLING OF DEVIATIONS DURING COMMISSIONING

DOCUMENTATION ON COMMISSIONING

• ARRANGEMENTS FOR COMMISSIONING DOCUMENTATION

• SCOPE AND STRUCTURE OF COMMISSIONING DOCUMENTATION

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 DS 446 - 4
Appendix
FUEL LOADING

• PREREQUISITES FOR FUEL LOADING

• TEST CONDITIONS AND PROCEDURES

Annex
LISTING OF TYPICAL COMMISSIONING TESTS

• INTRODUCTIONPREREQUISITES FOR PRE-OPERATIONAL TESTS

• PRE-OPERATIONAL TESTSFUEL LOADING, INITIAL CRITICALITY AND LOW
POWER TESTS
• POWER TESTS
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Consideration should be given as to what features
should be covered in Regulations and Guides ,
both for the licensee and the regulatory body

This should include what work is allowed, and

how it will be monitored, before formal
construction permit is issued

The necessary contacts with other regulatory

agencies and their formalisation, should also be
considered in such documents
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In overview, Regulations and Guides should cover:

The safety case needed before a permit to begin

construction can be granted

The oversight requirements that the licensee must

implement, if a contractor is employed to construct the
installation, so as to maintain its responsibility for safety

The activities of the regulatory body in review,

assessment and inspection both before granting the
permit and during the construction activity
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 Some points from SSG-12: 4
• The licensee or applicant should establish and justify plans and
• programmes for commissioning the nuclear installation. The
regulatory body
• should conduct reviews, assessments and inspections to determine
whether:
• (a) The commissioning test programme is complete and contains a set
of well
• defined operational limits, test acceptance criteria, conditions and
• procedures;
• (b) The commissioning tests can be safely conducted as proposed by
the
• licensee or applicant and their justification is appropriate.

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 Some points from SSG-12: 4
• There are several steps in the commissioning process for which the
• regulatory body may require the licensee to obtain prior approval and at which
• regulatory decisions may be made. The regulatory body should consider
• introducing such hold points at key steps in the commissioning programme
• relating to safety; for example, where it wishes to witness particular tests. In
• particular, the introduction of nuclear or certain types of radioactive material
• into the nuclear installation marks a significant step in the commissioning
• procedure and is often considered the point at which the main regulatory
• decisions are made.

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 Some points from SSG-12: 4
• Before authorizing significant steps such as the introduction of
nuclear or
• certain types of radioactive material, fuel loading, initial
criticality or power
• raising, the regulatory body should complete the review,
assessment and
• inspection of:
• (a) The status of the nuclear installation:
• (b) Management aspects:
• (c) Operational provisions:
• More details are in Paragraph
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 Some points from SSG-12: 4
• If there are deviations from design
• parameters, they should be analysed by the
licensee and reported to the regulatory
• body, which should carry out the necessary
review and assessment and may
• approve the proposed manner of dealing with
the deviations, as appropriate

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 Some points from SSG-12: 4
• The results of commissioning tests should be subject to:
• (a) Self-assessment and internal audits of the licensee. Appropriate
actions and
• measures should be taken whenever deviations from design parameters
are
• identified. These should be analysed by the licensee and reported to the
• regulatory body.
• (b) Review, assessment and inspection by the regulatory body. The aim
of these
• regulatory controls is to assess whether the test results are adequate for
• confirming the adequacy of all safety related features of the nuclear
• installation.

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 Regulatory Requirements

Consideration should be given to the extent

of documentation needed to provide
guidance to the applicant/licensee and to
the regulatory body staff in carrying out
work associated with the licensing process

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