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CONVENTION ON NUCLEAR SAFETY

The United Kingdom of

Great Britain and

Northern Ireland

NATIONAL REPORT

PRESENTATION

For the

Third Review Meeting

11-22 April 2005, Vienna

UK presentation to 3rd CNS meeting – Vienna 2005 1

CONVENTION ON NUCLEAR SAFETY

Presented

By

Dr Mike Weightman

HM Chief Inspector of Nuclear

Installations,

Health & Safety Executive


PARTICIPATING ORGANISATIONS

• UK Department of Trade

and Industry (Lead Dept)

• Health and Safety

Executive

• BNFL/Magnox Electric

• British Energy

• Environment Agency

• Scottish Environmental

Protection Agency


PRESENTATION STRUCTURE

1. Overview of the UK industry covered by the CNS

2. UK’s Follow-up to Actions from the 2nd Review Meeting

3. New Factors - Since the 2nd Review Meeting

4. Recent Events - Since the 3rd Report

5. Response to Questions on the UK Report

6. Areas of Challenge & Good Practice

7. Future Plans to Enhance Safety

8. Concluding Remarks


Style of UK National Report

• Identified the UK practices, legal requirements and

standards that relate to the Articles of the Convention

• Addressed these in the report

• Compared UK practices and standards with IAEA

requirements

• Not suggesting that all countries should do this

• But may provide a guide for future peer reviewers.


1. Overview of the UK Industry

Covered by the CNS


HISTORY OF UK NUCLEAR POWER

1945 to 2005


1940----1950----1960----1970----1980-----1990-----2000-First reactor

at Windscale

goes critical

1950


1940----1950----1960----1970----1980-----1990-----2000-

1953

Government

Decision to build a

commercial nuclear

power station


1940----1950----1960----1970----1980-----1990-----2000-

1956

HM QueenHM Queen

opens Calderopens Calder

HallHall

11stst commercialcommercial

nuclear powernuclear power

stationstation


1940----1950----1960----1970----1980-----1990-----2000-

1962 -First of the civil

Magnox power stations

starts operation at

Berkeley


1940----1950----1960----1970----1980-----1990-----2000-

1962 –66. 14 Steel pressures

Vessel Magnox Reactors


1940----1950----1960----1970----1980-----1990-----2000-

1968 -1971

4 concrete pressure

Vessel magnox reactors at

Oldbury and Wylfa completes

the Magnox programme

Design Capacity – 6 GW UK presentation to 3rd CNS meeting – Vienna 2005 13

1940----1950----1960----1970----1980-----1990-----2000-

1976 -First Commercial AGRs

start operation at Hinkley

Point and Hunterston


1940----1950----1960----1970----1980-----1990-----2000-

1988

Operational

Completes programme of 14

AGR Units

Capacity 9GW

– Torness and Heysham 2


1940----1950----1960----1970----1980-----1990-----2000-

1995- PWR at Sizewell B

operational

Capacity 1.1 GW

Completes UK NPP Programme


1940----1950----1960----1970----1980-----1990-----2000-

1996

British Energy

privatised with

AGR & Sizewell B.

Magnox stations

stay in public

ownership


1940----1950----1960----1970----1980-----1990-----2000-

2005

Nuclear Industry

restructuring

Formation of the

Nuclear

Decommissioning

Authority


History Implications

• Covered by the CNS, UK has:

– Range of Different Reactor types

– Range of reactor ages (1956 – 1995)

• In addition UK has installations not covered by this

Convention:

– Fuel Manufacture and reprocessing

– Research facilities

– Decommissioning Reactors

– Military Installations

• How is the industry regulated and safety assured?



1940----1950----1960----1970----1980-----1990-----2000-Windscale fire. One of

the air-cooled reactors

released radioactivity

after a fuel fire.

1957

History Implication – Law and

Regulation

• Windscale fire highlighted the potential safety,

environmental and social impact of a nuclear

accident

• Government recognised that the then existing law

and regulations were not adequate

• Parliament enacted the Nuclear Installation

• Act 1959

• This set up Regulatory Authority – NII

• Later (1974) HSE formed, included NII


Nuclear Site Licensing

Nuclear

Installations

Act

• Established the

Licensing system

for Nuclear

Installations

• Set out insurance

requirements



Licences issued to the

corporate body that is the

user of the site.Nuclear Site

Licence

Licensing system applies

throughout the lifetime of

a nuclear site including

installation,

commissioning,

operation and

decommissioning.



Nuclear Site

Licence

Regulatory control

exercised through 36

standard conditions

attached to the licence.

Licence conditions are

goal setting

Can be regarded as

regulations


2. UK’s Response to Actions from the

2nd Review meeting: Follow-up


Follow-up to the 2nd Review Meeting

Several items identified during the 2nd review

meeting are relevant to UK, main ones:

• Make appropriate measures to ensure operational safety until closure.– Resources have been and continue to be available to ensure

operational safety until closure and beyond. Licence condition 36 is used to ensure that adequate resources are maintained.

• Development of new, or changes in legislative and regulatory frameworks– Covered in Articles 7 & 9 in National Report and later in this

presentation



• How regulatory bodies obtain adequate expertise without conflict of interest, if they do not have TSO’s of their own. – Most of the expertise to regulate nuclear safety is available

to the regulator through its own staff or others in HSE. However, the regulator has an extramural support budget and framework agreements with some independent outside bodies when specialist advice and/or additional resources are needed.

• Independence and administrative position of the Regulatory Body – How the UK achieves independence of its nuclear safety

regulatory body is described under Articles 7 & 8



• The use of probabilistic safety assessment and

different performance indicators,

– The use of PSA in the UK is discussed under Article 14. The

use of indicators is discussed later in this presentation

• International co-operation among regulatory bodies

– The HSE has several active bilateral agreements. HSE

participated in EC sponsored assistance programmes. It

also participates in the work of the IAEA, OECD (NEA),

WENRA, etc. Discussed under Article 8



• Maintenance & enhancement of competence of

regulatory bodies – covered under Article 8

• Implementation of quality management systems in

regulatory bodies

– The Business Management System

– Benchmark against other regulators

– The use of the EFQM model and programme

• Content of safety review processes for plant life

extension and conclusions of the review(s)

– Article 6 provides provides information on the UK’s safety

review processes (PSRs).


Follow-up from the 2nd Review

Meeting

• In the present changing energy market, it is important

that utility managers as well as regulatory bodies

understand the potential effects on safety of severe

financial constraints

– This issue is well understood in the UK as nuclear utilities

have been operating in a deregulated electricity market for

several years. Licence Condition 36 is used to ensure that

licensees maintain adequate resources to ensure safety


3. New Factors Since the 2nd Meeting


New Factors

• Creation of the Nuclear Decommissioning

Agency

• Restructuring of BNFL

• Relicensing of Several Magnox Sites


New Factors

Creation of the NDA:

– UK Regulator heavily involved in its development

– Created 1 April 2005

– New Owner of all the Magnox sites

– Funds decommissioning

– Licensee operates or decommissions reactors under a contract from NDA

– Contracts based on detailed life cycle base lines and near term work plans

– Intended to lead to faster, cheaper, safer decommissioning with due regard to security and environment


New Factors

Restructuring of BNFL:

– Response to NDA requirements

– Regulated under Licence Condition 36

– Required transfer of staff between various bodies and formation of new entities

– Completed to programme by joint project involving assessment of cases and inspection


New Factors

Relicensing of several Magnox sites:

– Required to enable BNFL restructuring & facilitate

competition for running the sites

– Relicensed BNFL sites to Magnox Electric

– Relicensed only after regulator convinced of capability of

new operator to run sites safely


4. Recent Events Since Issuing the

UK’s 3rd Report


Recent Events at UK’s NPPs

Since the CNS report was published three significant events have been identified related to the operating safety case for the UK’s NPPs:

– Further degradation of the graphite moderator

– Integrity of Boiler closure units

– Consequences of Rare Turbine Failure Events at Heysham & Hartlypool



Further Degradation of Graphite Moderator (1):

– Oldbury graphite weight loss as a result of neutron induced

oxidation in the circuit gas

– Detailed analysis of the predicted rate and consequences for

structural integrity of the core graphite structure

– Case made after further in core inspections and out of core

analysis of graphite samples

– Continuing programme of inspection, sampling and analysis



Further Degradation of Graphite Moderator (2):

– Inspections revealed enhanced cracking of graphite bricks in

core at Hartlypool

– Extra stresses from irradiation induced anisotropic growth

– Outside earlier safety case prediction and could give rise to

coolant bypass and control rod entry difficulties

– Required further inspections to establish overall position of

cores and further analysis to develop valid safety case with

enhanced future monitoring and inspection regimes



Boiler closure units:

• Issue arose from inspection of main PV tendons

• Issue was the integrity of prestressing components around

boiler penetrations through the concrete pressure vessels

• Problem initiated by water leaks in the pressure vessel cooling

system

• Resolved by application of a multi-leg safety argument involving

– Structural integrity analysis

– Inspection

– Monitoring



Consequences of rare Turbine Failure Events:

• Safety case issues arose from further consideration of possible loss of coolant events reflecting on earlier cast iron pipework problems

• Particular consequence of the design of the Heysham 1 and Hartlepool reactors – position of condenser near turbine and segregation not full height between turbine hall and reactor building

• Rare turbine failure, flooding with pool fire and flows to heat up reactor pressure vessel and various safety components

• Regulatory action to ensure all 4 reactors needed regulatory approval to restart

• Two pronged approach taken – detailed analysis to support revised safety case and building of wall to provide adequate segregation


5. Response to Questions on the UK

Report


Analysis of Questions Received

• UK received 169 Questions from 22 countries

• For each Article I will :

– Summarise the main themes of the questions

asked

– Provide brief answers

– Address in detail some of the major topics

identified by the questions to supplement the

information in the UK National Report.


Analysis of Questions ReceivedN

um

ber

of Q

uestions

20

18

16

14

12

10

8

6

4

2

0G 6 7 8 9 10 11 12 13 14 15 16 17 18 19

Article Number


Analysis of Questions Received

• Breakdown of questions is broadly similar to

other countries with NPP

• Main areas of interest are:

–Assessment and verification of safety (Art 14)

–Operations (Art 19)

–Legal and regulatory body (Arts 7 and 8)


Response to Questions

General

Questions

20 Questions received


Response to Questions - General

• Covered a wide range of topics:

–Structure of UK report (already discussed)

–UK Nuclear Decommissioning Authority (NDA)

– UK energy policy – consequences of closure of

NPPs

–Resources of the Regulatory Body

–Upgrading Reactors (PSRs)

• These topics are addressed under the

appropriate article in this presentation


Existing Nuclear Installations

Article 6

12 Questions Received


Article 6 – Existing Installations

Key areas of questioning:

1. Status of NPP built to earlier standards

• Benefits of Periodic Safety Reviews

• Some specific technical issues on Magnox Reactors

• PSRs as an integral part of the Regulatory process

2. Knowledge retention post decommissioning.

(covered under Article 19)



Q1- Status of NPP built to earlier standards

• Periodic Safety Reviews are the key process

• The objectives of the PSRs are:

– To confirm adequacy of the current NPP safety case;

– To compare against current standards and implement any

reasonably practicable improvements.

– To identify any ageing process that may limit the life of the

plant in the next 10 years

– To revalidate the safety case until the next PSR, (subject to

the outcome of routine monitoring by the licensee and

regulation by NII).



Q1.1 - Benefits of PSRs:

• Outcome will give both licensee and regulator confidence that (subject to normal regulation) the plant is adequately safe for 10 years.

• Provides a vehicle for public reassurance on continued nuclear safety

• Identifies reasonable plant upgrading.



Periodic Safety Reviews

Q1.2 – Specific Technical Issues for Magnox Reactors

• Early PSRs identified need for major upgrading such

as:

– Diverse shutdown systems

– Additional post-trip cooling

– Seismic upgrading

– I&C upgrading

– additional review/monitoring/inspection of specific items



Periodic Safety Reviews

• The later PSRs (e.g. Wylfa) identified the need for such items as:

–Vibration monitoring on Gas Circulators

– Structural integrity studies on Concrete Pressure vessel penetrations

–Additional seismic studies (core support)

– Development of a natural circulation cooling safety case

– Inclusion of Human Factors in PSA



Q1.3 - PSRs as part of the Regulatory Process:

• The Site licence Conditions require PSRs to be

carried out

• Continued operation of an NPP depends on the

satisfactory outcome of a PSR.

• PSRs do not replace routine day-to-day regulation.

They are an additional stand back review.


Legislative and Regulatory

Framework

Article 7

11 Questions


Article 7 - Legislative and Regulatory

Framework


1. Updating of the UK Laws • Adequacy of the existing laws

• Status of guidance such as the Safety Assessment Principles

2. Plant upgrading • Legal basis for requiring plant upgrades

3. Resources and funding of the regulatory body (covered under article 8)


Regulatory Pyramid

Summary

HEALTH AND

SAFETY AT WORK

ACT

(Passed by parliament)

(Passed by parliament)

SITE LICENCE AND LICENCE CONDITIONS

ARRANGEMENTS MADE UNDER LICENCE CONDITIONS

Principles and Assessment Guides

(NII)

Q1- Updating of the UK Laws

NUCLEAR INSTALLATIONS ACT

(Prepared by NII- compliance mandatory)

(Prepared by Licensee – compliance mandatory)

Safety Assessment



Framework

Q1 - Updating UK Law – The basic laws are essentially unchanged but

• The licensing process gives flexibility

• The 36 licence conditions generally set goals but do not prescribe how the goals are to be achieved

• Some conditions require the licensee to make arrangements to achieve the goals

– Compliance with licence conditions and arrangements is mandatory; non compliance is a criminal offence

– The 36 conditions can be regarded as regulations

– Recently changed a licence condition to address an issue related to the NDA taking ownership of the licensed sites

– Reviewing licence conditions further and SAPs


Article 7 - Legislative and Regulatory Framework

Example of Licence Condition

Licence condition15. PERIODIC REVIEW

(1) The licensee shall make and implement adequate arrangements for the

periodic and systematic review and reassessment of safety cases.

(2) The licensee shall submit to the Executive for approval such part or parts of

the aforesaid arrangements as the Executive may specify.

(3) The licensee shall ensure that once approved no alteration or amendment is

made to the approved arrangements unless the Executive has approved such

alteration or amendment.

(4) The licensee shall, if so directed by the Executive, carry out a review and

reassessment of safety and submit a report of such review and reassessment to

the Executive at such intervals, within such a period and for such of the matters

or operations as may be specified in the direction. UK presentation to 3rd CNS meeting – Vienna 2005 59


Framework

Q2- Plant upgrading

• Arrangements for a PSR require comparison with

current standards

• Must evaluate any shortcomings and upgrade

where reasonably practicable

• Application of ALARP

• No absolute requirement for an old plant to meet

current standards.


Regulatory Body

Article 8

14 Questions


Article 8 - Regulatory Body


1. Regulator’s resources 1. Staffing and funding of the Regulator

2. Technical Support to the Regulator

2. Interface with other bodies 1. Delegated authority given to NII as part of Health and

Safety Executive.

2. Interface with other government bodies

3. Assessment standards (Articles 7 and 14)



Q1 -Resources of the regulator (finance):

– NII agrees budget with HSE

– HSE negotiates with sponsoring department

(DWP)

– Director NSD (HMCI) manages the NII budget.



Q1 -Resources of the regulator (staff):

– NII agrees staff complement and composition with

HSE

– NII has range of expertise but also has budget to

recruit external support (10% of total)

– Procedures exist to ensure independence of

external support

– System provides checks and balances



Q 2 - Interface with HSE and other departments

• Delegated authority from HSE to CI to grant licences &

set/change licence conditions

• In common with other government departments in UK, Public

Service Agreements (PSAs) set out objectives and targets

• This requirement passes from DWP to HSE to the individual

HSE directorates

• HSE/NII has a PSA target to secure a reduction in the number of

pre-cursor events to an accident.



STRATEGIC LINES OF SIGHT

Government objectives for Employment, Productivity, Health and Rehabilitation,

including Revitalising Health and Safety and Better Regulation

DWP’s PSA target 5 (of 10)

By 2008, to improve health and safety outcomes in Great Britain through

progressive improvement in the control of risks from the workplace

Developing

closer

partnerships

Helping people

benefit from

effective H&S

management

Focussing on our

core business by

being clear about

priorities

Communicating

effectively

reduction: fatal & Major injury

reduction: Ill-Health

By

HSC STRATEGY TO 2010 AND BEYOND

HSC/E 3 YEAR BUSINESS PLAN

By 2008 (from 2004)

3%

6%

9% reduction: days lost

2008 (from 2001)

5% reduction: nuclear precursors

45% reduction: hydrocarbon releases

15% reduction: onshore RIDDOR DOs

rd

PROGRAMME LINES OF SIGHT

67

Programmes

FIT 3

Strategic

Programme

Strategic

Programme

Business

Programme Programme

LA/HSE

Programme

Programme

Policy

Programme

Better

Programme

DWP’s PSA target 5

Hazards

HSC/E 3 YEAR BUSINESS PLAN

Productivity

ProgrammeUK presentation to 3 CNS meeting – Vienna 2005

Strategic Enabling

Government objectives for Employment, Productivity, Health and Rehabilitation, including

Revitalising Health and Safety and Better Regulation

Delivery

Major Hazards

Delivery

Involvement

Worker

Involvement Partnership

Enforcement

Regulation

(of 10)

By 2008, to improve health and safety outcomes in Great Britain through progressive improvement in the control of risks from the workplace

Reduce Ill-

Health, Injury and

days lost

Control Major

Efficiency &

Sector Precursor indicator

Nuclear safety

Offshore

(COMAH)

Relevant RIDDOR reportable dangerous (e.g. unintentional

explosions, failure of pressure systems)

Risk Index (SRI).

Major Hazard precursor targets set out in DWP PSA 5

Reports made to HSE by licence holders which indicate a challenge to nuclear

Major and significant hydrocarbon releases

Onshore occurrences

Railways Precursors that can lead to a catastrophic event - as valued within the Rail Safety


Responsibility of the Licence Holder

Article 9

5 Questions


Article 9 – Responsibility of the

licence holder.


1. Public liability insurance

2. General questions on licensing process and

interaction between the licensee and regulator


Article 9 – Responsibility of the

licence holder.

Q1- Public liability insurance:

• This is fixed by statute under section 19 of the

Nuclear Installations Act

• The Act does not cover wider environmental

damage and liability for this would be determined

by the courts


Article 9 – Responsibility of the licence holder.

Q2- Interaction between the licensee and regulator

Vision

Effectiveness Mind Map/Culture

Systems/Structures

Patterns/Processes

Events/Plant/Operations

Strategic

(Proactive)

Process

(Reactive)


Article 9 – Responsibility of the licence holder


Vision

Public

Reassurance

Mind Map/Culture

Systems/Structures

Patterns/Processes


Strategic

(Proactive)

Process

(Reactive)


Article 9 – Responsibility of the licence holder


Compliance &

Reality Check

Influence

----------

Regulate

Vision

Mind Map/Culture

Systems/Structures

Patterns/Processes



Priority to Safety

Article 10

13 Questions


Article 10 – Priority to Safety


1. Safety Indicators (also in other articles)

2. Licensees internal safety management• Nuclear Safety Committees

3. Contractorisation of Safety related topics

4. Regulatory decision making (covered under article 14)



Q1 - Safety Indicators

• Have used a variety of indicators in past but recognised need to

develop better ones and ones which all parties agree on

• Pilot exercise in 2004/5 with British Energy on reporting of

indicators.

• 26 indicators identified based on:

– IAEA Safety Performance Indicator framework

– British Energy’s own Key Performance Indicators

– SPIs from other organisation



Q1 - Safety Indicators • Examples of Indicators are:

– Nuclear Reportable events

– Unplanned trips

– Number of Breaches of Tech Specs

– Number of open safety related defects

– HSE’s Public Service Agreement Indicator (see Article 8)

• Work to be extended to Magnox Reactors

Also have developed NII inspection and assessment monitoring and feedback system (IES):



1

2

3

4

5

6

7

8

9

10

11

12 1

13 2

14 3

15 4

16 5

17 6

18

19

20 '

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

.


Worst Best Mode

Rating Rating Rating

Licence Condition

Interpretation

Marking the Site Boundary

Restrictions on Dealing with the Site

Restrictions on Nuclear Matter

Consignment of Nuclear Matter

Docs, Records and Certs.

Incidents on the Site

Warning Notices

Instructions to Persons on Site

Training

Emergency Arrangements

DAPs and SQEPs *Ratings Exemplar

Nuclear Safety Committee Good Standard

Safety Documentation Adequate]

Periodic Review Below Standard

Site Plans, Designs and Specs. Significantly Below Standard

Quality Assurance Unacceptable

Radiological Protection

Construction and Installation * The Ratings have been taken from Annex 2 of the BMS document

Mods. To Plant Under Construction INS/003 entitled ' Production of Visit Reports

Commisssioning

Mods. Or Experiments on Plant

Operating Rules

Operating Instructions

Operating Records

Control And Supervision of Ops.

Safety Mechs, Devices and Circuits

Exam, Insp, Maint and Testing

Duty to carry out Tests, Insp etc.

Periodic Shutdown

S/D of Specified Operations

Accumulation of Radwaste

Disposal of Radwaste

Leakage and Escape

Decommissioning

Control of Organisation Change

IRRs

Information Exchange

LCLC

Site Annual Review

Liaison with OGDs

Safety Reps

Conv Safety (inc. Fire Certificates)

Outage Intent/Start Up Meeting

Other Regs

Level 1 Ex/EPCC

Visits

EIAD

Worst Best Mode

Rating Rating Rating


Q2 - Licensees internal safety management

– Corporate Safety Department

– Safety Directors, Board Level

– Licensees have safety inspectors on site

– Nuclear safety Committee (LC13)

• Advises on nuclear safety issues

• External members (not HSE) but:

– Terms of Reference approved by HSE

– Minutes of meetings sent to HSE



Q3 - Contractorisation of Safety related topics

– No fundamental objection to appropriate use of contractors

but

• Licensee must retain responsibilities under law

• Sufficient staff with managerial and technical skill to understand

safety significance of contracted work

• Adequate day to day control & supervision of licensable

activities

– Licensees need to be an “intelligent customer” approach

• Infers continuation & development of corporate memory


Financial and Human Resource

Article 11

11 Questions


Article 11- Financial and Human

Resource


1. Nuclear Decommissioning Authority

2. Adequacy of Licensees’ Assets/finances

• Funding of safety

3. Contractorisation (covered under Article 10)



Resource

Q1 - Nuclear Decommissioning Authority (NDA)

– The NDA came into formal existence on 1 April 2005

– The work of the NDA regarding decommissioning and the

clean up of legacy waste is a matter for the Joint

Convention.

– However NDA will have operational responsibility for the

Magnox reactors.

– NDA will not be a licensee under the NII Act but certain

aspects of its activities will be subject to duties under the

licence conditions.



Resource

Q2- Adequacy of Licensees’ Assets/finance

– ALARP is the guiding principle on whether

a safety upgrade is necessary. This will include an

element of Cost Benefit Analysis.

– A licensees financial resources is not taken into

account when determining whether an upgrade

should be implemented.


Human Factors

Article 12

14 Questions


Article 12 – Human Factors


1. Safety Culture

• Evaluation methods

• Indicators

2. Use of Human Factors in Probabilistic safety

Analysis (PSA)



Q1- Safety Culture

– No specific indicators yet to assess safety culture

directly

– Evaluation of safety culture will be an integral part

of the pilot study on indicators (see Article 10)

– Licensees carrying out safety culture reviews as

part of the next round of PSRs

– Do not regulate safety culture but influence it



Q2- Use of Human Factors in Probabilistic

safety Analysis (PSA)

• Follows internationally agreed

methodologies:

– IAEA safety Series

– HEART methodology developed in UK

– NUREG


Quality Assurance

Article 13

7 Questions


Article 13-Quality Assurance


1. Auditing of Contractors

2. Quality of Regulatory Work

3. Use of IAEA Standards

4. QA of Safety Culture (see article 12)



Q1 - Auditing of Contractors

• The licensee is responsible for safety on the site.

• Activities of contractors are covered by the licensees’

arrangements made under the licence conditions.

• However NII may audit contractors activities as part

of inspecting licensee's compliance with the licence

• NII does not license or approve contractors.



Q2 - Quality of Regulatory Work

• Goals and KPIs set in Strategic and Annual plans, also goal (PSA target) agreed with HSE, cascaded into individual Performance Agreements

• Individuals’ and Managers’ performance regularly reviewed against Performance Agreements, plans and quality requirements

• System of escalating review of case for regulatory decision proportionate to impact of decision

• Internal regulatory review meetings on outcome of inspections and assessments – monitor against plan and amend as necessary.

• Two cross divisional management groups report to the Management Board

– ICG – Inspection Co-ordination Group

– CALM – Corporate Assessment liaison meeting.

• NII uses BMS to secure consistency & EFQM model to help secure

continuous improvement



Q3- Use of IAEA Standards

• HSE/NII and Utilities uses IAEA standards as

guidance.

• Current review of SAPs against IAEA standards

• IAEA guide 50-C-Q was used as the basis for Article

13 of the national report


Assessment and Verification of

Safety

Article 14

20 Questions


Article 14 – Assessment and

Verification of Safety

Key Areas of Questioning:

1. Probabilistic Safety Assessment

• Use in decision making

• Living PSAs

2. Risk informed Regulation

3. Public Information




Q1.1- PSA use in decision making

– No regulatory decision would be made on the basis of PSA

alone

– PSA used to identify the significance of a shortcomings

– NII Safety Assessment Principles provide scope for use of

ALARP

– SAPs recognise that old plant may not meet the same PSA

targets as new plant but risks have to be tolerable and

demonstrated to be ALARP


rd 98

of Safety

UK presentation to 3 CNS meeting – Vienna 2005

Article 14 – Assessment and Verification

Unacceptable Region

Risk cannot be justified

except in extraordinary

circumstances

Broadly Acceptable Region

The 'as low as reasonably practicable' or Tolerability Region

(Risk is undertaken only if a benefit is desired)

Tolerability of Risk Diagram

Tolerable only if risk reduction

is not practicable or its cost

is grossly disproportionate

to the improvement gained

Tolerable if cost of reduction

would exceed the improvement

gained

Necessary to maintain

assurance that risk stays at

this level

Negligible Risk

(No need for detailed working

to demonstrate that the risk

is as low as reasonably practicable)



Q1.2 – Living PSAs

• Living PSAs are not a regulatory requirement in UK.

• Expect Licensees to follow best international practise.

• NPPs at Heysham 2 and Torness have on- line Risk

monitors




Q2- Risk informed Regulation

• Risk information is an integral part of the

Integrated Enforcement Strategy (IES) used

by NII




Integrated Enforcement Strategy

Object is to establish a process for determining

regulatory strategy actions related to Licensees’

nuclear safety performance which is :

• Consistent.

• Transparent

• Targeted

• Proportional



of Safety

Basic Principles of IES

The regulatory strategy needs to:

• Maximise Effectiveness of Regulatory Activities.

• Demonstrate Regulatory Compliance and check reality.

• Engender public reassurance and confidence in the regulatory system

• Based on systematic inspection of systems important to safety.


IES Generic Process Schematic

Set standards

and

expectations

Plan Gather

InformationActivity

Regulatory activities

Carry out analysis of data and

regulatory review

development processes

Inform planning,

recruitment and career



of Safety

Q3- Public Information

• On 1 January 2005 a Freedom of Information Act came into

force in UK

• HSE/NII Currently Publishes:

– Newsletter

– Results of major reviews, inspections, etc

– Press releases on major events

• Licensees have local liaison committee meetings

• HSE/NII has identified and meets with Stakeholders and is

looking at how to further develop its activities in this area


Radiation Protection

Article 15

7 Questions


Article 15 -Radiation Protection

Key Areas of questioning:

1. Basis for determining Dose Limits

2. Supervision of work involving radiation

3. Data on doses at specific sites



Q1 - Basis for determining Dose Limits

• Euratom Directive leads to:

– Ionising Radiation Regulations

• Advice from UK National Radiological

Protection Board (NRPB) and ICRP.



Q2 - Supervision of work involving radiation

• Employers must appoint Radiological Protection

Advisor (RPA) to advise on complying with the

Ionising Radiation Regulations (IRRs)

• Employers must appoint a Radiation Protection

Supervisor (RPS) to supervise compliance with

IRRs.

• NII inspects these arrangement and the

employers’ compliance with the rest of the IRRs



Q3 - Data on doses at specific sites, 2 Issues:

• Doses at Gas cooled reactor are lower than at Light Water Reactors.

– Gas circuits are clean due to low contamination of gas coolant circuit and ability to remove failed fuel on load.

• UK report on doses at Magnox sites excludes Calder Hall:

– Reason is Calder Hall is on the Sellafield reprocessing site and is included in the Sellafield data (CH is now shut down)


Emergency Preparedness

Article 16

11 Questions


Article 16 - Emergency

Preparedness


1. Determination of Emergency Planning

Zones

2. Lessons learned from Emergency Exercises

3. Public information (covered under Art 14)



Preparedness

Q1- Determination of Emergency Planning Zones

• Radiation(Emergency Preparedness and Public

information) Regulations implement EC directive 96/29

• Requires operators to assess where a reasonably

foreseeable accident could give rise to 5mSv to members

of public

• Reasonably foreseeable taken as an event within the fault

schedule with an initiating frequency greater than 10-5 per

year

• Must inform HSE and Local Authority of assessment



Preparedness

Q1- Determination of Emergency Planning

Zones ( continued)

• HSE will confirm size of the 5mSv zone

• Local Authority responsible for co-ordinating

within this zone – the Detailed Emergency

Planning Zone (DEPZ).

• DEPZ must be at least 1km.

• Must also develop a contingency zone for non-

reasonably foreseeable events



Preparedness

Q2 - Lessons learned from Emergency Exercises – Mechanisms: the Nuclear Emergency Planning

Liaison Group (NEPLG) brings together Organisations and Agencies with Offsite Emergency duties

– Chaired by DTI – meets twice per year

– Takes forward issues identified during exercises

– On-site issues arising from exercises taken forward by HSE/NII


Siting

Article 17

2 Questions


Article 17 - Siting

Key areas of Questioning:

1. Seismic evaluations for reactors built in

1960s

2. Severe Accident Analysis


Article 17 - Siting

Q1 - Seismic evaluations for reactors built in

1960s

• The evaluation of the seismic hazard, together with

other external hazards was one of the main reason

for initiating the PSR process.

• The PSRs identified many reasonable plant

upgrades that were implemented


Article 17 - Siting

Q2- Severe accident Analysis

• The analysis of Severe accidents is

addressed in NII Safety Assessment

Principles Numbers 28 - 31


Design

Article 18

4 Questions


Article 18 - Design


1. Guidance for designers and reviewers for

review of existing plant design

2. Use of Modern Standards on old plant

(addressed under Article 14)


Article 18 - Design

Q1 - Guidance for designers and reviewers for review of

existing plant design

• Licensees have “Nuclear Safety Principles”

• NII has “Safety Assessment Principles” (SAPs)

• The two are compatible but the licensees’ is more

detailed and its purpose is to guide the design of

plant and the preparation of safety cases

• Licensees will review their guidance as a

consequence of the revision of the NII SAPs


Operations

Article 19

19 Questions


Article 19 - Operations

Key areas of questioning :

1. Operational experience in PSRs

2. Specific plant based issues

3. Knowledge retention



Q1 - Operational experience in PSRs

• Operational Experience is now a significant part of the PSR process. It will comprise a review of: – Operational events and incidents

– Maintenance data

– Operator Actions

– Review of performance indicators

• Dose levels

• INES events

• Reportable incidents

• Review will also take note of events at other plants



Q2 - Specific plant based issues

• Graphite Moderator Degradation – Addressed earlier in this presentation

– Update in Q/A document

• AGR Gas Circulator impellor failures (cracking)– Essence of safety case is that impellor failure is a

comparatively frequent event

– Consequences are bounded by other parts of the safety case

– Update in Q/A document



Q3 Knowledge retention

• Currently skill shortage is not a problem

• But age profile indicates a future problem

• Government set agenda for action

• The Sector Skills Council progressing programme involving industry, government departments and universities.

• Some positive outcomes - new courses starting in Universities


6. Challenges & Good Practice


Challenges

The Challenge is Change: • Social/political/economic environment – reduced interest in

nuclear science & technology, FOI, deregulated electricity

markets, globalisation, need for greater public reassurance, etc

• Response of industry to these environmental pressures – contractorisation, reduced finances, need for greater return,

changes in the workforce

• Changes on the plant and its operation - with ageing

phenomena, spares supplies, supply chain, attitude of workforce

and education background, new management practices


Good Practices (1)

Against such challenges the following are

suggested as good practices in the context of the

UK social/political/economic environment:

• Increasingly both industry and the regulator moving towards

being much more learning organisations – able to respond

more rapidly to change, based on international good practices

and peer group reviews

• Flexible risk based goal setting regulatory regime that

demands high standards of safety from licensees


Good Practices (2)

• Licence Condition 36

• Maintenance of a highly competent Regulatory

Body buffeted against financial, resource and

political pressures by being part of a larger

regulatory organisation

• Striving for greater effectiveness through new ways

of working (e.g. IES)


7. Future Plans to Enhance Safety


Future Plans to Enhance Safety

• Industry & regulator aligned around striving for sustained and robust excellence delivering:– High standards of safety

– Targeted Investment in plant, people and processes

– Customer & Stakeholders focused

– Predictable electricity supplies

• Regulator seeking to maximise its effectiveness in improving standards of Health & Safety – Seeking simple compliance if not enough

– Use leverage models within IES to align, change relationships, determine regulatory strategy, look at human resourcing issues and competencies, etc


-----------

Enhancing effectiveness of regulator

Compliance & Regulate Reality Check

Effectiveness

Vision Public

InfluenceReassurance Mind Map/Culture

Systems/Structures

Patterns/Processes



8. Concluding Remarks


Conclusions

• UK meets all the main elements of the Convention

• UK learnt and moved on from 2nd Review Meeting

• UK derives considerable benefit from such

benchmarking:

¾ improving safety even further; and

¾ providing confidence to the public and others.

• UK seeking to improve further & be better able to

meet the challenges of a changing environment


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