Health and Safety
Executive / Commission
Research:
Nuclear Safety
In the research domain, HSE has concentrated on reactor safety research, because of the history of the transfer of responsibility from the Department of Energy (under the DTI Guidelines, listed below), and because of the relative hazard of the respective plants.
In 2002 HSE undertook a review of the research programme, largely aimed at altering the research system to reflect the changing industry. It was agreed that the reactor licensee joint Industry Management Committee would be phased out (subject to successful new arrangements being established), HSE would continue to produce the Nuclear Research Index (NRI), and the reactor operators would produce Research Schedules giving their research that addressed the NRI issues and their other safety research activities.
The research review also addressed HSE's oversight of the safety research of other licensees. Hitherto, HSE had only assured HSC that the reactor safety research programme was balanced and adequate. HSC confirmed in October 2002 that HSE's oversight did indeed extend in principle to all licensees, subject to the availability of resources. All licensees have a duty to carry out appropriate safety research, and HSE has a duty to satisfy itself and assure HSC of the balance and adequacy of this research. The resources allocated depend on the relative hazards of the operations, and the contribution that research can make to safety in each case, on a basis of proportionality and consistency. The new arrangements developed with the reactor licensees were taken as an example of good practice, to be adapted to other licensees. The preference is for voluntary arrangements, in order to get the benefit of the licensee's input to the research and their acceptance of the results to facilitate implementation, and to make the best use of NII's resources.
The former Memorandum Of Arrangements stated in paragraph 2.3 that
'the HSC Co-ordinated Programme excludes nuclear safety research commissioned by HSE's Nuclear Installations Inspectorate (NII) to enable it to take specific licensing decisions both today and in the future (covered by separate arrangements)'.
Thus the research arrangements do not cover research work in support of specific plant safety cases as these would be dealt with through the normal licensing process. (HSE would use its support programme for such work.) Similarly, concerns about application of British Nuclear Group's Safety Management Systems for example, would be addressed by a regulatory route rather than through the research route.
Standard HSE procurement procedures and policies are followed for projects commissioned by HSE.
The reactor programme covers the following:
Although HSE participates in the US DOE Generation IV International Forum, in the absence of any declarations by licensees of intent for new build, the scope of the nuclear safety research programme does not include new reactor designs.
The main driver for the HSC reactor safety research programme is HSE's Nuclear Research Index (NRI). The NRI, which is produced annually, is a compilation of generic nuclear safety issues generated by HSE as a result of its knowledge gained in regulating nuclear reactor sites and its broader dealings with other organisations, both nationally and internationally. The index provides a basis for:
It is necessary to ensure adequacy and balance within a technical area, between technical areas, and between different reactor types.
The NRI consists of two individual documents. (The strategy is now a separate document that covers all relevant licensees.)
The arrangements for implementing the reactor research programme require both HSE and the major nuclear generating licensees to commission research programmes to address safety issues identified by HSE in its Nuclear Research Index (NRI). The reactor safety research programme is drawn up following a dialogue based on the NRI with the reactor licensees. New arrangements for delivering the programme were introduced for 2003-2004, with the licensees making transparent to HSE their proposed research programme in a Nuclear Research Schedule. The reactor licensees also make transparent to HSE their reactor safety research that is not in response to NRI issues, in order to facilitate HSE's judgement on the balance and adequacy of the programme.
The majority of the programme is commissioned by the licensees. By voluntary agreement, HSE only commissions research:
Both the licensees and NSD research coordinators have written detailed guidance for their staff on the detailed operation of the arrangements. The NSD guidance is part of NSD's Business Management System.
HSE publishes on the HSE website the NRI, the levy programme, the list of levy reports, and the open advisory committee (NuSAC SCR) papers that deal with the total programme proposals, its execution and evaluation.
The term 'Chemical Plants' was adopted under the previous Nuclear Chemical Plant Research Index research arrangements to describe BNFL Licensed Sites without an operating nuclear reactor (as power generating research was covered under the separate IMC arrangements). In practise, these 'chemical plant' arrangements exclusively addressed Sellafield issues, as Sellafield is the predominant non-reactor Licensed site. In developing new Sellafield arrangements, an overview of relevance to other non-reactor Licensed sites in the BNFL Group has been maintained. Both research and development are included. Both health as well as safety issues are considered. HSE's interests include areas such as application of established methodologies and skills management of safety assessors which are outside the scope of these research arrangements. The Sellafield Licensee would not expect to address such issues in the Research Schedule, but would address these through other appropriate routes e.g. the Safety Case Review Forum.
In 2002 Sellafield agreed that the degree of transparency of Sellafield's research to HSE would be increased. HSE proposes a strategy for each technical area indicating priority areas of interest for potential research. The purpose of the strategy is to identify those generic nuclear safety research issues that HSE considers are either specific, or of particular importance, to chemical plant. The strategy should address three main areas:
This mirrors the reactor NRI approach, but at a less detailed level. HSE
will publish the technical area strategies on the HSE website.
The Sellafield Licensee looks to agree the strategies as being suitable
and clear bases for dialogue and exchange. In response to the issues raised
in these strategies, Sellafield produces a research schedule, analogous
to that for the reactor research, describing how the specified issues are
addressed (whether by research or otherwise).
This targeted approach has been agreed as being most effective, as Sellafield's
research in this area is known to be extensive and it would be inefficient
and impractical for Sellafield to attempt to describe all the work which
it carries out, as well as being resource intensive for HSE staff.
Whereas HSE will endeavour to use the jointly agreed voluntary arrangements
to address its research concerns, it reserves the right to commission its
own research and to recover the charges from the Sellafield Licensee through
a Levy. The circumstances when this is likely to happen are when HSE and
the Sellafield Licensee fail to agree on how an issue should be resolved,
where HSE wish to commission research to inform itself where independence
from Sellafield is seen to be important and where HSE may wish to directly
fund research with its own independent team or to undertake research through
an international agreement which requires the participation of the regulator.
These examples should not be considered as exclusive of any other reasons
which may arise but which cannot be foreseen at this time.
In the topic areas described in the strategies, HSE is interested in understanding
Sellafield's use of research results and having the opportunity to discuss
them before they are presented in a safety case. This includes feedback
of operational experience, validation of methods, and the work needed to
determine how to apply new or existing research results, or to address new
applications.
HSE's nuclear research unit has written guidance on the format and content
of the technical area strategies, and stressed the importance of stating
the nature of regulatory issues and how research could potentially be relevant
to address these. The responsibility for responding to these issues (by
research or otherwise) and the detailed specification and management of
any research remains the clear responsibility of the Licensee.
The objectives given in the HSE nuclear safety research strategy were originally developed for reactor safety research, and need to be slightly modified for chemical plant arrangements.
In recent years, UKAEA has given HSE an annual presentation on their technology programme. It has been agreed that UKAEA's Corporate Technology Plan will form a suitable vehicle for UKAEA to make their safety research transparent to HSE. This document will be available to HSE in 2005.
The arrangements described here for the British Nuclear Group and UKAEA are appropriate for their current position as owner-operator of licensed sites. However, the creation of NDA will fundamentally change the position, with the NDA being the source of funding for site licensees, and with contracts between the NDA and the site licensees/operators having to address the need for, and importance of, research. In the current context, the issues arising from this change include:
HSE is involved in discussion with NDA and the licensees about the future arrangements for safety and waste management research under NDA. NDA has set up an advisory Research Board, including DTI, HSE, DEFRA, EA, SEPA and other interested government departments as members.