Petteri Tiippana: We are using all the people in our department [nuclear reactor regulation] for the Olkiluoto 3 work, but of course not full-time. Mostly just the 12-person project group works full-time on OL3. The annual workload for OL3 has been about 30 man-years per year since 2004; we are spending more than half of our oversight resources on OL3.

The department now has 107 staff; in 2001 we were about 60. We have been hiring people almost every year, mostly for OL3, but also to prepare for retirement. In the next few years 10-15 very experienced people will be retiring. We are trying to prepare in advance for that.

Q. How are you working to retain their knowledge?

We have a knowledge management project ongoing, and with that we are trying to transfer knowledge from experienced staff to newcomers. An example of where we are using this approach is in the renewal of our regulatory guidelines. We started this in 2006, and our aim is to finish by the end of 2011. Updating the regulatory guidelines is carried out here in the department; it is led and mostly done by the experienced staff. We are now trying to include new people in the working groups so that they can learn firsthand from the experts, which helps them to better understand the requirements and the justifications; it is very useful…

Q. What is involved in regulatory control of construction?

What we are doing now is reviewing and approving the detailed designs of systems, structures and components. This is mostly complete for OL3, although there are portions of detailed design that still need to be reviewed and approved. We are also assessing and evaluating the performance of the licencee (TVO) and the vendor (Areva) and its subcontractors with our inspections. There are inspections on site, and at manufacturing sites, where we are evaluating the performance of project stakeholders and making sure that they are doing what they need to do to make sure that the components (for example pressure equipment or electrical motors) or structure, fulfills the requirements. These inspections are a big portion of our work during construction…

Q. Why is it important to go beyond the workpiece and audit the company processes?

You want to be proactive, to make sure that the working processes are adequate so that the final product will meet your expectations. In many cases if the working processes are not adequate, the product will not be either…

Q. It must have been a big learning curve, with so little reactor experience recently?

That is a question we get a lot. We still have people here at STUK – the Director General, my predecessor (the department director), and experts – who were here when the currently operating reactors were built. So we had and still have a very good situation with regards to construction knowledge and experience, and we have of course been able to use that experience on the OL3 project.

I think the reason our management selected young people, like me, to work on the project was to get people trained, educated and experienced on licensing and construction…The timing of the OL3 project, starting in early 2002, was good from that point of view. Had it started now, we would not be in such a good position.

Q. What lessons have you been learning from OL3?

There are many lessons being learned. One thing we did well before OL3 started was to update our safety regulations. Where the licencee and Areva maybe failed was in their familiarity with the updated regulations i.e. what the safety requirements mean for the design in detail; how the regulator works; what design information the regulator expects; what manufacturing documents are required, and in what phase of the project; how will documents be reviewed and approved. With the next project we want to be sure that the licencee and vendor are familiar with the regulatory requirements and regulatory system in Finland, because it affects the project implementation.

Another lesson is that the licencee and vendors’ know-how is a key issue. Especially the top management’s nuclear experience and knowledge, it has to be there. They need to know how a nuclear project is managed, what kind of people are needed in different phases, how you find them, how the contractors are to be managed, what things are specific to nuclear in comparison to other industries, and how that is taken into account in the project. In general, the knowledge and experience of key persons in all technical areas of the project is very important.

One lesson everyone has learned at OL3 is that it is not easy to build a first-of-a-kind reactor. It is a challenge, especially after a long delay in construction in Europe. It is important to have the design completed as much as possible before the construction starts, and have the engineering resources available, subcontractors trained and educated for the project so that it can go smoothly when it starts.

For new projects if they start [in Finland], there will be more emphasis on the management processes, organisational and safety culture issues early in the project…

Q. What do you mean by safety culture?

There is no big difference between construction and operation of nuclear power plants from a safety culture point of view. First of all you need to have a clear emphasis on safety and quality over cost and schedule. Management needs to convey this message clearly to everyone working on the construction project. That is the first thing.

On an individual level, construction workers have to understand that they are working on a nuclear power plant, and understand the safety significance of their work. Whether they are working on the concrete or steel or a component, somebody should be able to tell them what the component is, why it is there and why it is safety-significant. An understanding will promote personal responsibility to do the work correctly and according to procedures and criteria…

Q. Should subcontractors be approved by a regulator?

It depends on the subcontractor. We approve most safety-significant pressure equipment manufacturers (although not electrical and I&C) and their inspection and testing organisations. We are also reviewing and auditing the organisations that perform design on structures and components for electrical or I&C, but we are not approving them or giving them a licence.

Q. What is the separation of responsibility between TVO and Areva?

For regulator the answer is clear: TVO is responsible for everything. All the interactions we have are with TVO. However, it is a turnkey, fixed-price, fixed-schedule contract between TVO and Areva. With that, Areva is of course responsible to TVO to do everything according to the contract. We have had some cases that has shown that this type of contract is a little tricky from the ‘licencee is responsible for safety’ point of view. The licencee may find it a challenge to go in and influence the work, because if it interferes with progress, it can lead to deep discussions about who is responsible for the consequences. We have faced some challenges because we – of course – expect that licencee is in control of everything…We have examples where it has been difficult for the licencee and vendor to interfere on subcontractors’ work when the work is ongoing and they rather wait until the work is finished and reject the final outcome…

Q. How much contact have you had with ANS?

We have been sharing challenges and problems and have been able to learn from each other. In some cases I feel our cooperation with the French safety regulator is more effective than the cooperation between EDF, TVO and Areva. However, we could do better because there have been very similar issues with FLA3 concreting and steel liner welding as we had here.

Q. Despite the similarity of the projects, Flamanville-3 has had a lower profile than OL3; why is it running better?

The project of course is run differently. At FLA3 it is EDF, at OL3 it is Areva who is the project lead. The companies are different, and the projects are run differently. I am not able to compare the challenges or the problems [that FLA3 faces]. The two projects are at different phases. The OL3 design is a little bit further along than FLA3; construction is further than FLA3, component manufacturing is probably further than FLA3; when things are progressing challenges have been faced. Hopefully things will go more smoothly at FLA3…

Q. When will TVO apply for an operating licence?

The information I have is that it will submit an operating licence application at some point next year. We have said that a precondition for that is that the design is finished.

Q. What is the state of play with the reactor protection system (I&C) query; on your website you say that you were expecting information by the end of July?

We haven’t received the final documentation and description of the instrumentation and control systems architecture. It may be coming this fall… [He reported in early November to have received some, but not all, of the documentation]. The open issue has to do with ensuring the adequacy of the safety systems (those used to maintain control of the plant if it goes outside normal conditions), and their independence from control systems (those used to operate the plant under normal conditions). So, what we want is that these systems are independent to provide defence-in-depth in the design; this is the primary issue with I&C design at the moment.

Q. What about other design issues in the reactor?

I don’t know anything that is this big. This is the main issue in design…To my understanding we have more or less the same open issues not only in the UK and Finland, but also in France and the USA where the EPR is being licensed…

Q. What are your plans for your new role?

The biggest challenge for us is to manage our workload of operating reactors, OL3 and possible new reactor projects in Finland. We have to manage our available resources carefully and make sure we plan our work well so people are able to work effectively…

Another thing that I want to highlight is the licencee’s responsibility. In an ideal world the regulator would not be needed because the licencee is responsible for everything. Things should be managed by the licencee. Of course this is not an ideal world, and regulators are needed in risk-significant activities like the use of nuclear energy. We are focusing on the licencee’s responsibility and how they bear it.

Third, I would like to make our working processes more transparent and results more open to the public. One lesson we have learned is that new-build is very attractive to the public and the media…

Author Info:

Based on an interview with Petteri Tiippana carried out in September 2009 by Will Dalrymple, editor of NEI