effective interaction between stakeholders to ensure

Effective interaction between stakeholders

to ensure highest level of nuclear safety

AFCONE Workshop

Jean-René JUBIN | Senior Nuclear Safety Officer

Division of Nuclear Installation Safety

Department of Nuclear Safety & Security

Content

1. IAEA Safety Standards

2. Establishing a safety infrastructure

3. National Nuclear Safety System

4. Transparency and openness

5. GSG-6

6. Conclusion

2021ARCONE 2


2021ARCONE 3

Responsibility

for safety


2021ARCONE 4

Role of

government

Leadership

and

management

for safety

Justification

of facilities

and activities

Optimization

of protection

Limitation

of risks to

individuals

Protection of

present and

future

generations

Protective

actions to

reduce existing

or unregulated

radiation risks

Prevention

(and mitigation)

of accidents

Emergency

Preparedness

and Response

To protect peopleand the environmentfrom harmful effectsof ionizing radiation.

Responsibility

for safety


2021ARCONE 5

Role of

government

Leadership

and

management

for safety

Justification

of facilities

and activities

Optimization

of protection

Limitation

of risks to

individuals

Protection of

present and

future

generations

Protective

actions to

reduce existing

or unregulated

radiation risks

Prevention

(and mitigation)

of accidents

Emergency

Preparedness

and Response

To protect peopleand the environmentfrom harmful effectsof ionizing radiation.

An effective legal and governmental framework for

safety (…) must be established and sustained

3.10. The RegulatoryBody must:• Set up appropriate means of

informing parties in the vicinity,

the public and other interested

parties, and the information

media about the safety aspects

(including health and

environmental aspects) of

facilities and activities and about

regulatory processes

• Consult parties in the vicinity,

the public and other interested

parties, as appropriate, in an

open and inclusive process


2021ARCONE 6

Req. 5: Interaction with interested parties

Senior management shall ensure thatappropriate interactionwith interestedparties takes place.

Req. 36: Communication and consultation with interested parties

The regulatory body shall promote theestablishment of appropriate means ofinforming and consulting interested partiesand the public about the possible radiationrisks associated with facilities and activities,and about the processes and decisions ofthe regulatory body.

2. Establishing a Safety Infrastructure

Main phases in the lifetime of an NPP

A Nuclear Safety Infrastructure is defined as “the set of institutional, organizational and technical elements and conditions established in a State to

provide a sound foundation for ensuring a sustainable high level of nuclear safety” [INSAG-22]

2021ARCONE 7

decisio

n

Bid

s / C

on

tract

com

missio

nin

g


• Road map: Role of the main entities throughout the

establishment of the Infrastructure for safety

2021ARCONE 8

Phase 1 Phase 2 Phase 3

Bids or

Contract

Ready to make a knowledgeable

commitment to a nuclear programme

M2M1

Ready to commission and

operate the first NPP

M3

Implementation of the Operating Organization

Implementation of the Regulatory Body

Role of the Government


2021ARCONE 9

Safety guide SSG-16 Establishing the Safety Infrastructure for a Nuclear

Power Programme constitutes a “Road-map” to apply the entire suite of

IAEA Safety Standards progressively during the early phases of the

implementation of a nuclear power programme.

Highlight the importance

of public acceptance for

the implementation of a

NPP programme which

can be gain through

transparent and open

communication and

dialogue


Phased approach of the safety infrastructure development:

Deliverables expected from the regulatory Body

2021ARCONE 10

Phase 1 Phase 2

Contract

Application for construction license

First concrete

Pre

para

tion o

f safe

ty docum

enta

tion

Assessm

ent b

y the

regula

tory b

ody

Constru

ctio

n

Esta

blish

ing

the b

asic

regula

tory

fra

mew

ork

Site

pre

para

tion

Fuel Delivery

Issuance of theconstruction licence

Phase 3

1~3 years 3~7 years 7~10 years

Initial site

survey

Environmental impact

assessment

Ready to commission

and operate the first NPP

NP

P O

pe

ratin

g L

ice

nse

Co

mm

issio

nin

g P

erm

it

Issu

an

ce

of S

ite P

erm

it

Issuance of

safety Requirements

needed for bid

specification

Issuance of

the Nuclear Law

Ready to make a decision on whether

or not to introduce nuclear power

Bids / Contract


Phase 1

Decision

Phase 2 Phase 3

commissioning

Phase 2

• Keeping informing the

interested parties about the

safety implications and issues

on implementation of NPP

programme, including the

expected health and

environmental impacts

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Phase 1

• Communication on risks and

benefits of nuclear power to

facilitate stakeholders’

engagement in decision making

for possible NPP programme

• Transparent and inclusive

process to consult the public

and others

Bids / Contract


Phase 1 Phase 2 Phase 3

commissioning

• Seeking to establish and maintain

confidence and trust

• Continuing explaining risks and benefits of

the introduction of NPP

• Communicating about licensing process,

safety requirements and regulatory

oversight

• Ensuring a transparent approach on safety

issues with interested parties, regarding

any problems and difficulties during

construction and commissioning

2021ARCONE 12

Bids and/or Contract

INSAG-27: Model of

national nuclear system

3. Robust National Nuclear Safety System

2021ARCONE 13


Fukushima Daiichi

Accident (March 2011)

14

• Earthquake magnitude 9

followed by Tsunami

• Total station blackout (SBO)

• 3 unit damaged

• Release of radioactive

material in environment

• About 150 000 people were

evacuated in

total, 40 km

evacuation zone

2021ARCONE

15

Fukushima Daiichi Accident

Strong belief that NPP were sufficiently robust to withstand external events of low probability and high consequences: tendency not to challenge the level of safety and to introduce promptly safety improvements

Lack of transparency: Concern about worrying the public jeopardized the decision making on safety and emergency preparedness and impacted the licensee’s own perception of these risks

Stakeholders did not fully act as challengers against complacency or lack of vigilance of the operator and regulator

“The root causes identified… as being cultural and institutional” (Nuclear Accident Independent Investigation

Commission of the National Diet of Japan)

2021ARCONE


INSAG-27: Model of national nuclear system

Covers parties having in interest in nuclear (sub-systems) who can or should influence

the achievement of safety

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Framework to be established by the Government, each sub-system

– should have the authority and responsibility to fulfil its clear and distinct roles

– should links together in a way that each sub-system reinforces the others

Legal framework covering:

› Obligations of nuclear industry

› Responsibilities of regulatory body

› Measures (e.g., freedom of information) to ensure the openness and transparency that enables stakeholders to be effective


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• Leaders (nuclear industry, regulatory body) should foster a

strong, vibrant safety culture. Cultures are interconnected:

– The way regulatory duties are discharged impacts licensees ’ safety

culture

– The way licensees respond to the regulatory body reflects its culture

and impacts the regulator body’s culture

• Effective communication within and between the various

sub-systems

– Enables to develop safety awareness among sub-systems thereby

promoting safety culture

• Each sub-system is independent but open and transparent

to the others

4. Transparency and Openness

Why the concepts of transparency and openness are important for safety

• Accountability– Transparency and openness promote accountability, a key contributor to

safety culture

– Accountability enhances confidence of interested parties in the nuclear system, and increases confidence that their views will be properly taken into account by the regulatory body

• Credibility and legitimacyTransparent and open communication and consultation

– Reinforces an awareness of the role and responsibilities and how duties are discharged, in seeking to maintain and continuously improve safety

– Helps to demonstrate and reinforce the distinction between the regulatory body and those organizations concerned with public acceptance of nuclear energy, including industry

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4. Transparency and Openness

• Quality in the performance of activities and regulatory

functions

– Participation in the regulatory decision can influence or even challenge the

regulatory body and information it used

– Knowledge of interested parties (e.g., Residents on local environment, and

social factors), can inform how issues are framed

– Allow the regulatory body (and others) to better understand and better

consider interested parties’ concerns as it performs its regulatory functions

• IndependenceA high level of transparency and openness

– allows the regulatory body to demonstrate its independence

– contributes to ensuring its freedom from undue influences that might

adversely affect safety

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Communication and consultation with interested

parties by the regulatory body

5. GSG-6

IAEA safety standards address

• Government responsibility

• Regulatory body overall

responsibility

• Information

• Documentation

• Confidential of information

• Consultation

• Authorized party duties

But Requirements & Guidance

• Scattered between several

standards

• Insufficient to provide Member

States with clear and

comprehensive guidelines to

develop a strategy relevant to

transparency, openness and

interested parties’ involvement in

regulatory activities

2021ARCONE 21

Decision taken in 2012 to establish

a guide on Communication

5. GSG-6

Communication and Consultation with Interested Parties

by the Regulatory Body

– General guidance and recommendations for regulatory bodies

concerning communication and consultation

– 5 sections• INTRODUCTION: background, objective, scope and structure

• Overarching recommendations

• Provisions of the REGULATORY FRAMEWORK

• IMPLEMENTATION BY THE REGULATORY BODY: Leadership, process, relevant

provisions to develop and implement a communications strategy

• METHODS OF effective COMMUNICATION AND CONSULTATION

– Examples (Strategy, Plan)

– Use of terms: Communication, plan, transparency and openness

2021ARCONE 22

5. GSG-6

2. OVERARCHING RECOMMENDATIONS• INDEPENDENCE

– In any interaction with interested parties, no undue influence

• TRANSPARENCY AND OPENNESS– Information proactively available and Promotion of an active participation

• EARNING TRUST– Perception: Demonstration that the regulatory body is independent, competent,

objective, reliable, transparent, responsive…

• KEY PROVISIONS– Resource, processes for information and consultation

• AVAILABILITY OF INFORMATION– Appropriate access to information, Sensitive information not to be disclosed on legal

basis

2021ARCONE 23

“The regulatory body is responsible for

the regulatory oversight of safety and

should not be biased for or against the

use of nuclear or radiation technologies”

5. GSG-6

3. REGULATORY FRAMEWORK• IDENTIFICATION OF MEANS AND (LEGAL) PROVISIONS

• REQUIREMENTS PLACED ON THE LICENSEES (REGULATIONS,

LICENSE CONDITIONS, OTHERS)

– to inform and, when appropriate, consult interested parties about the

possible radiation risks associated with facility or activities, including the

results from the safety assessment

– to make available to relevant interested parties, through their representatives

where appropriate, decisions with regard to measures for protection and

safety

• SPECIFIC CARE TO RESTRICTED-ACCESS INFORMATION FOR

LEGAL REASONS

2021ARCONE 24

5. GSG-6

4. IMPLEMENTATION BY REGULATORY BODY • LEADERSHIP, STRATEGY, CLEAR RESPONSIBILITIES

• MANAGEMENT SYSTEM PROVISIONS AND COMPETENCE

– Processes in place, External supports, importance of information and

knowledge management

• INTERESTED PARTIES– Public, News and social media… Staff

• COMMUNICATION AND CONSULTATION

PROCESS

– To clearly understand who is the regulatory

body and its characteristics

To know the legal and regulatory provisions,

including on information-access restriction

2021ARCONE 25

5. GSG-6

5. COMMUNICATION AND CONSULTATION

METHODS • INFORMATION

– How to deliver information (format, tools, channels…)

• GENERAL PROVISIONS FOR (EFFECTIVE) PARTICIPATION– Clarity, step-by-step, timing, experts

• DIALOGUE (to increase the effectiveness of communication )

• CONSULTATION

– When, stages…

• COLLABORATION

– May be necessary with some parties for exploring potential solutions

2021ARCONE 26

6. Conclusion

Communication and consultation, effective interaction

with Stakeholders are important for Safety, to have a

strong national nuclear safety system

Effective communication within and between: Regulatory

Bodies; Governmental organizations; Industry; and Others

– Both licensees and regulatory bodies have to effectively

communicate and interact with the other stakeholders

– Based on a deep-rooted value of openness and transparency

2021ARCONE 27

6. Conclusion

Communication and consultation are strategic

instruments that support regulatory body (and others)

in performing their functions,

• Enabling the regulatory body to:– make informed decisions

– develop the awareness of safety amongst interested parties, thereby

promoting safety culture

• Regular communication and consultation with interested

parties contribute to more effective communication in a

possible nuclear or radiological emergency

2021ARCONE 28

6. Conclusion

Importance of transparency and openness as

highlighted in SSG-16– Dedicated Actions on Communication in Transparency and

Openness Safety Element

– Communication is a never-ending activity and should be based on

clear objectives, strategy based on transparency and openness

approach, plan implementation and monitoring

– Communication are critical for societal acceptance therefore the

long-term sustainability of a nuclear power programme

– Communication should be transparent and open to support trust in

nuclear power programme, particularly in Regulator and Operator• Benefits and risks of a nuclear power, licensing process, safety requirements,

regulatory activities, events

2021ARCONE 29

Thank you!

effective interaction between stakeholders to ensure

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