Convention on nuclear safety - HSE

hse.gov.uk

Convention on nuclear safety - HSE

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 3 rd CNS meeting – Vienna 2005 1


CONVENTION ON NUCLEAR SAFETY

Presented

By

Dr Mike Weightman

HM Chief Inspector of Nuclear

Installations,

Health & Safety Executive

UK presentation to 3 rd CNS meeting – Vienna 2005 2


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

UK presentation to 3 rd CNS meeting – Vienna 2005 3


PRESENTATION STRUCTURE

1. Overview of the UK industry covered by the CNS

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

3. New Factors - Since the 2 nd Review Meeting

4. Recent Events - Since the 3 rd Report

5. Response to Questions on the UK Report

6. Areas of Challenge & Good Practice

7. Future Plans to Enhance Safety

8. Concluding Remarks

UK presentation to 3 rd CNS meeting – Vienna 2005 4


Style of UK National Report

• Identified the UK practices, legal requirements and

standards that relate to the Articles of the ong>Conventionong>

• 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.

UK presentation to 3 rd CNS meeting – Vienna 2005 5


1. Overview of the UK Industry

Covered by the CNS

UK presentation to 3 rd CNS meeting – Vienna 2005 6


HISTORY OF UK NUCLEAR POWER

1945 to 2005

UK presentation to 3 rd CNS meeting – Vienna 2005 7


First

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

reactor

at Windscale

goes critical

1950

UK presentation to 3 rd CNS meeting – Vienna 2005 8


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

1953

Government

Decision to build a

commercial nuclear

power station

UK presentation to 3 rd CNS meeting – Vienna 2005 9


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

HM Queen

opens Calder

Hall

1 st commercial

nuclear power

station

1956

UK presentation to 3 rd CNS meeting – Vienna 2005 10


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

1962 -First of the civil

Magnox power stations

starts operation at

Berkeley

UK presentation to 3 rd CNS meeting – Vienna 2005 11


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

1962 –66. 14 Steel pressures

Vessel Magnox Reactors

UK presentation to 3 rd CNS meeting – Vienna 2005 12


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 3 rd CNS meeting – Vienna 2005 13


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

1976 -First Commercial AGRs

start operation at Hinkley

Point and Hunterston

UK presentation to 3 rd CNS meeting – Vienna 2005 14


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

1988 – Torness and Heysham 2

Operational

Completes programme of 14

AGR Units

Capacity 9GW

UK presentation to 3 rd CNS meeting – Vienna 2005 15


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

1995- PWR at Sizewell B

operational

Capacity 1.1 GW

Completes UK NPP Programme

UK presentation to 3 rd CNS meeting – Vienna 2005 16


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

1996

British Energy

privatised with

AGR & Sizewell B.

Magnox stations

stay in public

ownership

UK presentation to 3 rd CNS meeting – Vienna 2005 17


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

2005

Nuclear Industry

restructuring

Formation of the

Nuclear

Decommissioning

Authority

UK presentation to 3 rd CNS meeting – Vienna 2005 18


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

ong>Conventionong>:

– Fuel Manufacture and reprocessing

– Research facilities

– Decommissioning Reactors

– Military Installations

• How is the industry regulated and safety assured?

UK presentation to 3 rd CNS meeting – Vienna 2005 19


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

fire. One of

the air-cooled reactors

released radioactivity

after a fuel fire.

1957

UK presentation to 3 rd CNS meeting – Vienna 2005 20


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

UK presentation to 3 rd CNS meeting – Vienna 2005 21


Nuclear Site Licensing

Nuclear

Installations

Act

• Established the

Licensing system

for Nuclear

Installations

• Set out insurance

requirements

UK presentation to 3 rd CNS meeting – Vienna 2005 22


Nuclear Site Licensing

Nuclear Site

Licence

Licences issued to the

corporate body that is the

user of the site.

Licensing system applies

throughout the lifetime of

a nuclear site including

installation,

commissioning,

operation and

decommissioning.

UK presentation to 3 rd CNS meeting – Vienna 2005 23


Nuclear Site Licensing

Nuclear Site

Licence

Regulatory control

exercised through 36

standard conditions

attached to the licence.

Licence conditions are

goal setting

Can be regarded as

regulations

UK presentation to 3 rd CNS meeting – Vienna 2005 24


2. UK’s Response to Actions from the

2 nd Review meeting: Follow-up

UK presentation to 3 rd CNS meeting – Vienna 2005 25


Follow-up to the 2 nd Review Meeting

Several items identified during the 2 nd 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

UK presentation to 3 rd CNS meeting – Vienna 2005 26


Follow-up to the 2 nd Review Meeting

• 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

UK presentation to 3 rd CNS meeting – Vienna 2005 27


Follow-up to the 2 nd Review Meeting

• 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

UK presentation to 3 rd CNS meeting – Vienna 2005 28


Follow-up to the 2 nd Review Meeting

• 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).

UK presentation to 3 rd CNS meeting – Vienna 2005 29


Follow-up from the 2 nd 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

UK presentation to 3 rd CNS meeting – Vienna 2005 30


3. New Factors Since the 2 nd Meeting

UK presentation to 3 rd CNS meeting – Vienna 2005 31


New Factors

• Creation of the Nuclear Decommissioning

Agency

• Restructuring of BNFL

• Relicensing of Several Magnox Sites

UK presentation to 3 rd CNS meeting – Vienna 2005 32


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

UK presentation to 3 rd CNS meeting – Vienna 2005 33


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

UK presentation to 3 rd CNS meeting – Vienna 2005 34


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

UK presentation to 3 rd CNS meeting – Vienna 2005 35


4. Recent Events Since Issuing the

UK’s 3 rd Report

UK presentation to 3 rd CNS meeting – Vienna 2005 36


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

UK presentation to 3 rd CNS meeting – Vienna 2005 37


Recent Events at UK’s NPPs

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

UK presentation to 3 rd CNS meeting – Vienna 2005 38


Recent Events at UK’s NPPs

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

UK presentation to 3 rd CNS meeting – Vienna 2005 39


Recent Events at UK’s NPPs

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

UK presentation to 3 rd CNS meeting – Vienna 2005 40


Recent Events at UK’s NPPs

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

UK presentation to 3 rd CNS meeting – Vienna 2005 41


5. Response to Questions on the UK

Report

UK presentation to 3 rd CNS meeting – Vienna 2005 42


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.

UK presentation to 3 rd CNS meeting – Vienna 2005 43


Analysis of Questions Received

Number of Questions

20

18

16

14

12

10

8

6

4

2

0

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

Article Number

UK presentation to 3 rd CNS meeting – Vienna 2005 44


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)

UK presentation to 3 rd CNS meeting – Vienna 2005 45


Response to Questions

General

Questions

20 Questions received

UK presentation to 3 rd CNS meeting – Vienna 2005 46


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

UK presentation to 3 rd CNS meeting – Vienna 2005 47


Existing Nuclear Installations

Article 6

12 Questions Received

UK presentation to 3 rd CNS meeting – Vienna 2005 48


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)

UK presentation to 3 rd CNS meeting – Vienna 2005 49


Article 6 – Existing Installations

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).

UK presentation to 3 rd CNS meeting – Vienna 2005 50


Article 6 – Existing Installations

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.

UK presentation to 3 rd CNS meeting – Vienna 2005 51


Article 6 – Existing Installations

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

UK presentation to 3 rd CNS meeting – Vienna 2005 52


Article 6 – Existing Installations

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

UK presentation to 3 rd CNS meeting – Vienna 2005 53


Article 6 – Existing Installations

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.

UK presentation to 3 rd CNS meeting – Vienna 2005 54


Legislative and Regulatory

Framework

Article 7

11 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 55


Article 7 - Legislative and Regulatory

Key areas of questioning:

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)

UK presentation to 3 rd CNS meeting – Vienna 2005 56


Q1- Updating of the UK Laws

Regulatory Pyramid

Summary

HEALTH AND

SAFETY AT WORK

ACT

(Passed by parliament)

NUCLEAR INSTALLATIONS ACT

(Passed by parliament)

SITE LICENCE AND LICENCE CONDITIONS

(Prepared by NII- compliance mandatory)

ARRANGEMENTS MADE UNDER LICENCE CONDITIONS

(Prepared by Licensee – compliance mandatory)

Safety Assessment

Principles and Assessment Guides

(NII)

UK presentation to 3 rd CNS meeting – Vienna 2005 57


Article 7 - Legislative and Regulatory

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

UK presentation to 3 rd CNS meeting – Vienna 2005 58


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 3 rd CNS meeting – Vienna 2005 59


Article 7 - Legislative and Regulatory

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.

UK presentation to 3 rd CNS meeting – Vienna 2005 60


Regulatory Body

Article 8

14 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 61


Article 8 - Regulatory Body

Key areas of questioning:

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)

UK presentation to 3 rd CNS meeting – Vienna 2005 62


Article 8 - Regulatory Body

Q1 -Resources of the regulator (finance):

– NII agrees budget with HSE

HSE negotiates with sponsoring department

(DWP)

– Director NSD (HMCI) manages the NII budget.

UK presentation to 3 rd CNS meeting – Vienna 2005 63


Article 8 - Regulatory Body

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

UK presentation to 3 rd CNS meeting – Vienna 2005 64


Article 8 - Regulatory Body

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.

UK presentation to 3 rd CNS meeting – Vienna 2005 65


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

3%

By 2008 (from 2004)

reduction: fatal & Major injury

6% reduction: Ill-Health

9% reduction: days lost

By 2008 (from 2001)

5% reduction: nuclear precursors

45% reduction: hydrocarbon releases

15% reduction: onshore RIDDOR DOs

HSC STRATEGY TO 2010 AND BEYOND

Developing

closer

partnerships

Helping people

benefit from

effective H&S

management

Focussing on our

core business by

being clear about

priorities

Communicating

effectively

HSC/E 3 YEAR BUSINESS PLAN

UK presentation to 3 rd CNS meeting – Vienna 2005 66


PROGRAMME 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

Reduce Ill-

Health, Injury and

days lost

Control Major

Hazards

HSC/E 3 YEAR BUSINESS PLAN

FIT 3

Strategic

Delivery

Programme

Strategic Enabling

Programmes

Major Hazards

Strategic

Delivery

Programme

Business

Involvement

Programme

Worker

Involvement

Programme

LA/HSE

Partnership

Programme

Enforcement

Programme

Policy

Programme

Efficiency &

Productivity

Programme

Better

Regulation

Programme

UK presentation to 3

rd

CNS meeting – Vienna 2005

67


Major Hazard precursor targets set out in DWP PSA 5

Sector

Precursor indicator

Nuclear

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

safety

Offshore

Major and significant hydrocarbon releases

Onshore

(COMAH)

Relevant RIDDOR reportable dangerous occurrences (e.g. unintentional

explosions, failure of pressure systems)

Railways

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

Risk Index (SRI).

UK presentation to 3 rd CNS meeting – Vienna 2005 68


Responsibility of the Licence Holder

Article 9

5 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 69


Article 9 – Responsibility of the

licence holder.

Key areas of questioning:

1. Public liability insurance

2. General questions on licensing process and

interaction between the licensee and regulator

UK presentation to 3 rd CNS meeting – Vienna 2005 70


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

UK presentation to 3 rd CNS meeting – Vienna 2005 71


Article 9 – Responsibility of the licence holder.

Q2- Interaction between the licensee and regulator

Effectiveness

Vision

Mind Map/Culture

Systems/Structures

Patterns/Processes

Events/Plant/Operations

Strategic

(Proactive)

Process

(Reactive)

UK presentation to 3 rd CNS meeting – Vienna 2005 72


Article 9 – Responsibility of the licence holder

Q2- Interaction between the licensee and regulator

Public

Reassurance

Vision

Mind Map/Culture

Systems/Structures

Patterns/Processes

Events/Plant/Operations

Strategic

(Proactive)

Process

(Reactive)

UK presentation to 3 rd CNS meeting – Vienna 2005 73


Article 9 – Responsibility of the licence holder

Q2- Interaction between the licensee and regulator

Compliance &

Reality Check

Influence

----------­

Regulate

Vision

Mind Map/Culture

Systems/Structures

Patterns/Processes

Events/Plant/Operations

UK presentation to 3 rd CNS meeting – Vienna 2005 74


Priority to Safety

Article 10

13 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 75


Article 10 – Priority to Safety

Key areas of questioning:

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)

UK presentation to 3 rd CNS meeting – Vienna 2005 76


Article 10 – Priority to Safety

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

UK presentation to 3 rd CNS meeting – Vienna 2005 77


Article 10 – Priority to Safety

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):

UK presentation to 3 rd CNS meeting – Vienna 2005 78


Article 10 – Priority to Safety

Worst Best Mode

Rating Rating Rating

Licence Condition

1 Interpretation

2 Marking the Site Boundary

3 Restrictions on Dealing with the Site

4 Restrictions on Nuclear Matter

5 Consignment of Nuclear Matter

6 Docs, Records and Certs.

7 Incidents on the Site

8 Warning Notices

9 Instructions to Persons on Site

10 Training

11 Emergency Arrangements

12 DAPs and SQEPs *Ratings 1

Exemplar

13 Nuclear Safety Committee 2

Good Standard

14 Safety Documentation 3

Adequate]

15 Periodic Review 4

Below Standard

16 Site Plans, Designs and Specs. 5

Significantly Below Standard

17 Quality Assurance 6

Unacceptable

18 Radiological Protection

19 Construction and Installation

20 Mods. To Plant Under Construction

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

INS/003 entitled ' Production of Visit Reports'

21 Commisssioning

22 Mods. Or Experiments on Plant

23 Operating Rules

24 Operating Instructions

25 Operating Records

26 Control And Supervision of Ops.

27 Safety Mechs, Devices and Circuits

28 Exam, Insp, Maint and Testing

29 Duty to carry out Tests, Insp etc.

30 Periodic Shutdown

31 S/D of Specified Operations

32 Accumulation of Radwaste

33 Disposal of Radwaste

34 Leakage and Escape

35 Decommissioning

36 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

UK presentation to 3 rd CNS meeting – Vienna 2005 79

Worst Best Mode

Rating Rating Rating


Article 10 – Priority to Safety

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

UK presentation to 3 rd CNS meeting – Vienna 2005 80


Article 10 – Priority to Safety

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

UK presentation to 3 rd CNS meeting – Vienna 2005 81


Financial and Human Resource

Article 11

11 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 82


Article 11- Financial and Human

Resource

Key areas of questioning:

1. Nuclear Decommissioning Authority

2. Adequacy of Licensees’ Assets/finances

• Funding of safety

3. Contractorisation (covered under Article 10)

UK presentation to 3 rd CNS meeting – Vienna 2005 83


Article 11- Financial and Human

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

ong>Conventionong>.

– 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.

UK presentation to 3 rd CNS meeting – Vienna 2005 84


Article 11- Financial and Human

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.

UK presentation to 3 rd CNS meeting – Vienna 2005 85


Human Factors

Article 12

14 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 86


Article 12 – Human Factors

Key areas of questioning:

1. Safety Culture

• Evaluation methods

• Indicators

2. Use of Human Factors in Probabilistic safety

Analysis (PSA)

UK presentation to 3 rd CNS meeting – Vienna 2005 87


Article 12 – Human Factors

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

UK presentation to 3 rd CNS meeting – Vienna 2005 88


Article 12 – Human Factors

Q2- Use of Human Factors in Probabilistic

safety Analysis (PSA)

• Follows internationally agreed

methodologies:

– IAEA safety Series

– HEART methodology developed in UK

– NUREG

UK presentation to 3 rd CNS meeting – Vienna 2005 89


Quality Assurance

Article 13

7 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 90


Article 13-Quality Assurance

Key areas of questioning:

1. Auditing of Contractors

2. Quality of Regulatory Work

3. Use of IAEA Standards

4. QA of Safety Culture (see article 12)

UK presentation to 3 rd CNS meeting – Vienna 2005 91


Article 13-Quality Assurance

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.

UK presentation to 3 rd CNS meeting – Vienna 2005 92


Article 13-Quality Assurance

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

UK presentation to 3 rd CNS meeting – Vienna 2005 93


Article 13-Quality Assurance

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

UK presentation to 3 rd CNS meeting – Vienna 2005 94


Assessment and Verification of

Safety

Article 14

20 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 95


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

UK presentation to 3 rd CNS meeting – Vienna 2005 96


Article 14 – Assessment and

Verification of Safety

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

UK presentation to 3 rd CNS meeting – Vienna 2005 97


Article 14 – Assessment and Verification

of Safety

Tolerability of Risk Diagram

Unacceptable Region

The 'as low as reasonably

practicable' or Tolerability

Region

(Risk is undertaken only

if a benefit is desired)

Broadly Acceptable Region

(No need for detailed working

to demonstrate that the risk

is as low as reasonably practicable)

Negligible Risk

Risk cannot be justified

except in extraordinary

circumstances

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

UK presentation to 3 CNS meeting – Vienna 2005

rd

98


Article 14 – Assessment and

Verification of Safety

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

UK presentation to 3 rd CNS meeting – Vienna 2005 99


Article 14 – Assessment and

Verification of Safety

Q2- Risk informed Regulation

• Risk information is an integral part of the

Integrated Enforcement Strategy (IES) used

by NII

UK presentation to 3 rd CNS meeting – Vienna 2005 100


Article 14 – Assessment and

Verification of Safety

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

UK presentation to 3 rd CNS meeting – Vienna 2005 101


Article 14 – Assessment and Verification

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.

UK presentation to 3 rd CNS meeting – Vienna 2005 102


IES Generic Process Schematic

Regulatory activities

Set standards

and

expectations

Plan

Activity

Gather

Information

Carry out analysis of data and

regulatory review

Inform planning,

recruitment and career

development processes

UK presentation to 3 rd CNS meeting – Vienna 2005 103


Article 14 – Assessment and Verification

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

UK presentation to 3 rd CNS meeting – Vienna 2005 104


Radiation Protection

Article 15

7 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 105


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

UK presentation to 3 rd CNS meeting – Vienna 2005 106


Article 15 -Radiation Protection

Q1 - Basis for determining Dose Limits

• Euratom Directive leads to:

– Ionising Radiation Regulations

• Advice from UK National Radiological

Protection Board (NRPB) and ICRP.

UK presentation to 3 rd CNS meeting – Vienna 2005 107


Article 15 -Radiation Protection

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

UK presentation to 3 rd CNS meeting – Vienna 2005 108


Article 15 -Radiation Protection

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)

UK presentation to 3 rd CNS meeting – Vienna 2005 109


Emergency Preparedness

Article 16

11 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 110


Article 16 - Emergency

Preparedness

Key Areas of Questioning:

1. Determination of Emergency Planning

Zones

2. Lessons learned from Emergency Exercises

3. Public information (covered under Art 14)

UK presentation to 3 rd CNS meeting – Vienna 2005 111


Article 16 - Emergency

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

UK presentation to 3 rd CNS meeting – Vienna 2005 112


Article 16 - Emergency

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 nonreasonably

foreseeable events

UK presentation to 3 rd CNS meeting – Vienna 2005 113


Article 16 - Emergency

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

UK presentation to 3 rd CNS meeting – Vienna 2005 114


Siting

Article 17

2 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 115


Article 17 - Siting

Key areas of Questioning:

1. Seismic evaluations for reactors built in

1960s

2. Severe Accident Analysis

UK presentation to 3 rd CNS meeting – Vienna 2005 116


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

UK presentation to 3 rd CNS meeting – Vienna 2005 117


Article 17 - Siting

Q2- Severe accident Analysis

• The analysis of Severe accidents is

addressed in NII Safety Assessment

Principles Numbers 28 - 31

UK presentation to 3 rd CNS meeting – Vienna 2005 118


Design

Article 18

4 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 119


Article 18 - Design

Key Areas of Questioning:

1. Guidance for designers and reviewers for

review of existing plant design

2. Use of Modern Standards on old plant

(addressed under Article 14)

UK presentation to 3 rd CNS meeting – Vienna 2005 120


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

UK presentation to 3 rd CNS meeting – Vienna 2005 121


Operations

Article 19

19 Questions

UK presentation to 3 rd CNS meeting – Vienna 2005 122


Article 19 - Operations

Key areas of questioning :

1. Operational experience in PSRs

2. Specific plant based issues

3. Knowledge retention

UK presentation to 3 rd CNS meeting – Vienna 2005 123


Article 19 - Operations

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

UK presentation to 3 rd CNS meeting – Vienna 2005 124


Article 19 - Operations

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

UK presentation to 3 rd CNS meeting – Vienna 2005 125


Article 19 - Operations

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

UK presentation to 3 rd CNS meeting – Vienna 2005 126


6. Challenges & Good Practice

UK presentation to 3 rd CNS meeting – Vienna 2005 127


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

UK presentation to 3 rd CNS meeting – Vienna 2005 128


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

UK presentation to 3 rd CNS meeting – Vienna 2005 129


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)

UK presentation to 3 rd CNS meeting – Vienna 2005 130


7. Future Plans to Enhance Safety

UK presentation to 3 rd CNS meeting – Vienna 2005 131


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

UK presentation to 3 rd CNS meeting – Vienna 2005 132


Enhancing effectiveness of regulator

Effectiveness

Public

Reassurance

Compliance &

Reality Check

Influence

-----------

Regulate

Vision

Mind Map/Culture

Systems/Structures

Patterns/Processes

Events/Plant/Operations

UK presentation to 3 rd CNS meeting – Vienna 2005 133


8. Concluding Remarks

UK presentation to 3 rd CNS meeting – Vienna 2005 134


Conclusions

• UK meets all the main elements of the ong>Conventionong>

• UK learnt and moved on from 2 nd 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

UK presentation to 3 rd CNS meeting – Vienna 2005 135

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