HSE Nuclear Safety Research Strategy 2005

Introduction

The UK nuclear safety research programme operates within a national legal and policy context.

• The Health and Safety at Work etc. Act 1974 places a duty on HSE to make arrangements for carrying out research and also to encourage research by others.
• The Nuclear Installations Act 1965 (as amended by the Atomic Energy Act 1989) states that HSE may recover from the licensees expenses incurred in connection with the carrying out of research into nuclear safety at the direction of HSC.
• One of the UK government's Science and Innovation priorities is to promote the development and deployment of safe and sustainable energy technology.

The Department of Trade and Industry has given guidelines for the management of the HSC Coordinated Programme of Nuclear Safety Research that are considered below.

In addition to this there are international requirements from the International Atomic Energy Agency and good practice recommendations from the OECD Nuclear Energy Agency that are considered below.

DTI Guidelines

In 1990, DTI transferred the management of the nuclear safety research programme to the HSC, with corresponding Guidelines. The objectives were given as:

1. Primary Objectives

i) To ensure that adequate and balanced programmes of nuclear safety research continue to be carried out, based on a view of the issues likely to emerge both in the short and long term.
ii) To ensure that, as far as reasonably practicable, the potential contribution which such research can make to securing higher standards of nuclear safety is maximised.
iii) To ensure that the results of any such research having implications for nuclear safety are disseminated as appropriate.

2. Supporting Objectives

i) To take account of the desirability of maintaining a sufficient range of independent capability to ensure the attainment of the primary objectives.
ii) To ensure that proper account is taken of the advantages of international collaboration in furthering the primary objectives.

The DTI guidelines are high level and are compatible with the NSD objectives below. They are mainly about the conduct of the programme.

International standards and good practice

The International Atomic Energy Agency is the international nuclear safety standards organisation, and their requirements documents include research.

GS-R-1 on legal and government infrastructure states:

• Nuclear safety legislation shall set up a means whereby research and development work is undertaken in important areas of safety
• The regulator may initiate, coordinate and monitor safety related R&D work in support of its regulatory functions
• Government shall ensure that appropriate R&D programmes for radioactive waste disposal are implemented, in particular for long term safety.

NSR-1 on design of nuclear power plants states:

• Where an unproven design or feature is introduced or where there is a departure from an established engineering practice, safety shall be demonstrated to be adequate by appropriate supporting research programmes, or by examination of operational experience from other relevant applications.
• The design shall take due account of relevant operational experience that has been gained in operating plants and of the results of relevant research programmes.
• The basis for the safety assessment shall be data derived from the safety analysis, previous operating experience, results of supporting research and proven engineering practice.
• On the basis of operational experience, relevant safety analysis and results from safety research, design activities for addressing severe accidents shall take into account.

There are relevant reports by the IAEA International Nuclear Safety Advisory Group (INSAG), which have the status of good practice recommendations.

• INSAG-12 'Basic safety principles for NPPs' gives a principle 'Organisations concerned ensure that the operating experience and the results of safety research relevant to safety are exchanged, reviewed and analysed, and that the lessons are learnt and acted on.'
• INSAG-16 'Maintaining knowledge, training and infrastructure for R&D in nuclear safety' expands on the consequences of this principle in a declining industry.

The OECD Nuclear Energy Agency has issued a series of reports and collective statements on nuclear safety research, which also have the status of good practice recommendations. These cover:

• Capabilities and expertise in support of efficient and effective regulation of nuclear power plants
• Assuring future nuclear competencies
• Major facilities and programmes at risk
• Role of research in a regulatory context
• Regulator and industry cooperation: challenges and opportunities.

Some of this guidance is mainly relevant to PWRs, but some of it is more general.

Relationship to the Nuclear Safety Division (NSD) Strategic Plan 2003-2006

The Programme is integrated into NSD's overall activities and supports a number of NSD's strategic goals. NSD's Strategic Plan 2003-2006 defines NSD's mission as:

"to secure effective control of health, safety and radioactive waste management at nuclear sites for the protection of the public and workers and to further public confidence in the nuclear regulatory system by being open about what we do."

NSD undertakes five Key Business Activities to fulfil this mission. Four of the KBAs are: Assessment; Inspection and Enforcement; Licensing; and Standards and Advice. The fifth KBA, Research, is defined as:

"the activity of identifying, commissioning and promulgating the results of research into nuclear safety issues so that licensees and NII have the scientific and engineering knowledge to make judgements about the adequacy of safety measures."

The plan states that NSD seeks to be open and transparent to all the individuals and representative organisations who have a direct interest in our activities, or are likely to be affected by them (e.g. licensees, the public, contractors etc) about how it undertakes each of these KBAs.

NSD has seven strategic goals (SGs):

1. prevention of major nuclear accidents,
2. reduction of waste hazards,
3. protection from ionising radiation,
4. to promote the maintenance of essential nuclear infrastructure in Great Britain.
5. to further public confidence in the UK nuclear regulatory system by providing information to our stakeholders, seeking their views and responding to them as appropriate.
6. to ensure that NSD moves towards being a world class nuclear safety regulator.
7. to promote the improvement of international nuclear safety through the development and harmonisation of nuclear safety standards across the world.

By contrast, the HSE non-nuclear Science and Innovation programme is not considered to be key business activity, but is justified in terms of supporting specific business needs. The nuclear safety research programme is different because HSE has been given a UK responsibility as described above. However research is not done as an end in itself, but in support of other requirements.

Regulatory Objectives

There are a number of regulatory objectives supporting the above strategic goals. These objectives were identified in the 2002-3 review of the research arrangements and were presented to the Nuclear Safety Advisory Committee Sub Committee on Research. They have since been developed further to be consistent with NSD's Strategic Plan.

Objectives relevant to both the regulator and the licensees are:

• To encourage and facilitate research to maintain and improve standards of nuclear safety where it is reasonably practical and timely to be implemented at UK licensed sites. (This supports SGs 1-3)
• To inform both the licensee and NSD about safety issues which are expected to arise and to respond to those which emerge unexpectedly. (This supports SGs 1-3.)
• To maintain the technical expertise of both the licensee and the regulator. (The support programme is also available to maintain the regulator's expertise.)
• To benefit from data and information produced by others.
• To secure an infrastructure of research capability (in the UK or overseas) which is essential to the safe operation of nuclear power systems at UK licensed sites or which provides NSD with access to sources of independent technical advice. (This supports SG4: maintenance of essential nuclear safety infrastructure,)

Specific to each licensee is:

• To ensure that independent research exists where needed to confirm/corroborate the findings of a licensee made in safety submissions and underpin existing safety cases by increasing the validation of and confidence in the methods used.

Generic regulatory objectives are:

• To cater for the interests of stakeholders by making research arrangements and activities sufficiently open. (This supports SG5: furthering public confidence in the regulator by openness.)
• To undertake research to support improvements in the way NSD regulates (This supports SG6: regulatory excellence.)
• To demonstrate to the public and our other key stakeholders that we are well informed on, and learn from, international nuclear safety development. (This supports SG7: improvement of international nuclear safety.)

Objectives to which safety research can contribute, but are not primary objectives of the programme, are:

• To contribute to national work to maintain nuclear skills in the UK (as required by the human resources requirement in the Nuclear Safety Convention, and supporting SG4 on infrastructure)
• To ensure that licensees have suitable staff to manage safety effectively now and in the future. (This supports Licence Condition 12 and SG4)

In terms of Licence Conditions, the research programme supports:

• LC 12 on Suitably Qualified and Experienced Persons (as a secondary objective, noted in the above paragraph)
• LC 14 on Arrangements for safety documentation
• LC 15 on Arrangements for Periodic Safety Review.

Relationship to Policy

Much attention has been devoted recently to the use of Government research to support policy, in connection with the drive to evidence based policy, leading to Guidelines 2000 published by the Office of Science and Technology. However the nuclear safety research programme is primarily aimed at the technical basis supporting regulation. Part of the programme informs aspects of operational policy. HSE's responsibility for the programme is a policy decision by DTI. The programme may address issues related to policy, such as: those issues which are of particular public concern (e.g. leukaemia clusters), studies of enforcement strategies, development of regulatory performance indicators, emergency planning, impact evaluations (there is a future intention to do these, and the results should affect policy), and the possibility of studies of new reactor designs if required.

Regulatory Challenges

Continued safety of ageing plant

Ageing plant (ageing effects, life time extension, replacement, refurbishment) is a continuing (and continually increasing until closure) challenge. It is likely that the existing number of issues/projects concerning gas cooled reactor plant life management issues will be maintained or even increased. For example, ageing of graphite with associated problems for the integrity of the core structure and safety during refuelling operations is likely to continue to provide a challenge in the future.

Economic environment

• In recent years the principal influences within the nuclear sector have been organisational change and deregulation of the electricity market. The industry's response to these has included downsizing and contractorisation which is threatening the expertise and knowledge of the licensed corporate bodies and discouraging the teaching of nuclear skills and technology.
• As the topics mature technically, licensees are becoming more reluctant to fund nuclear safety research. This raises concerns with respect to their ability to maintain the necessary knowledge to anticipate or address emerging nuclear safety issues.
• Human and organisational factors remain topics of concern, as organisations continue to evolve. The wider HSE policy is to increase the attention to this area.
• The licensees are aware of the potential commercial benefit of research results but have no mechanism in place to profit from this, creating a potential obstacle to trading research.
• Related to economics there is increasing pressure from government to demonstrate the improvements produced by regulation by developing indicators that are amenable to target setting.

Nuclear clean-up

• NII's mission is to secure effective control of health, safety and radioactive waste management at nuclear sites.
• There are increasing pressures for furnishing both licensees and regulator with the knowledge and expertise to:
  • develop appropriate strategies for regulating and managing the post-operation phase of plant life; and
  • apply acceptable standards of safety to decommissioning and long-term management of wastes,
• The government has established the Nuclear Decommissioning Authority to oversee the industry's management of radioactive wastes. Decommissioning and Waste management issues and the associated organisational issues are becoming more important.
• The British Nuclear Group have announced a business plan that defines the closure programme for their older steel vessel gas cooled reactors and provides the lifetimes for their concrete vessel plants provided the economics remain sound. This has started to have an impact upon the scale and nature of the research needed, and to an increase in the waste management and decommissioning research.
• The use by the UK nuclear industry of financial discounting for future costs has had serious implications in terms of preferred decommissioning options. This can encourage operators to delay all possible spend as the cost of funding in future will, with the use of any significant discount rate, be lower. The result is an argument for delaying research.

Capability maintenance

• A major challenge is the retention of manpower, facilities and capability, inside and outside of the industry. The HSC Programme addresses a subset of these requirements.
• The Magnox closure programme has the effect of decreasing the research related to continued operation that would support the research capability.
• With no immediate intention to build new nuclear power plant in the UK, generic research from this source has come to an end. The government Energy White Paper postponed any decision on new build, but proposed to keep the nuclear option open.
• The reactor safety cases are mature and in many technical areas new research is stimulated only when a Periodic Safety Review is being carried out for a station.
• The UK has only one, relatively new, civil Pressurised Water Reactor (PWR) (Sizewell B). Research spend upon PWR issues has decreased as residual start up issues have been addressed. Even so, it is necessary to maintain a level of research capability. The primary function of this capability will increasingly be to access PWR knowledge and know-how around the world. The challenge will be to establish this core capability against a background of an anticipated reduction in the number of new issues arising.
• The unique UK technology is a continuing challenge. The maintenance of Magnox and Advanced Gas-cooled Reactors (AGR) capability is of prime importance to the UK. Such capability is unavailable elsewhere in the world and the scope for international collaboration associated specifically with gas reactors is limited.
• The restructuring of the British Nuclear Group and the setting up of Nuclear Science and Technology Services as a separate company Nexia Solutions raise potential concerns about capability maintenance.

Research Strategy

The DTI Guidelines, NSD Strategic Goals and the above regulatory objectives all include:

• safety and capability maintenance as objectives of the research projects,
• dissemination, transparency and collaboration as objectives of the research processes.

Issues may be cleared by:

• establishing a program of basic research,
• collating information from existing facilities or by analysing existing data/information.

The programme addresses these objectives by the following types of activity.

Research of direct safety benefit

This is important for the continued safety of ageing plant. There are two strands:

• Achieving safety - The results of research which can have a direct safety benefit, for example by modifying plant design or operations (both of which can reduce risk or be used to help justify continued operation), is more readily amenable to cost benefit arguments.
• Demonstrating safety - Research is also carried out which reduces uncertainties in or increases confidence in an existing safety argument by improvements to or identification of limits of methodologies or data. Although it may have no direct impact on the plant or plant operations this confirmatory/corroborative research is still important.

Exploration of emerging safety issues

Anticipatory research helps the industry and NSD to respond to emerging safety issues and also maintains and improves the collective knowledge base. The regulator will in general be more inclined to sponsor long-term anticipatory research than will the industry, particularly in the current economic climate. However blue skies fundamental research is the responsibility of the Research Councils, not the regulator. EPSRC has recently increased its funding for nuclear energy related research, with projects addressing 'Keeping the Nuclear Option Open' as part of the 'Towards a Sustainable Energy Economy' programme.

'Horizon scanning' is a stated aim of HSE Science and Innovation programme. The effect of the Nuclear Decommissioning Authority and the nuclear clean-up programme, and the declared government policy of 'Keeping the Nuclear Option Open' certainly have to be considered. Longer-term issues that may have an effect on nuclear safety research requirements include the needs of a possible waste repository and the possibility of new reactor designs (e.g. the Generation IV initiative)

Maintenance of Licensees' Essential Research Capability and NSD's access to Independent Technical Capability

Reduction in industry research programmes is a feature common to several mature industries, including petroleum, chemicals, coal and steel. The government Lambert report says that the breaking up (quasi-)monopolies has led to large companies closing their central research laboratories, and sometimes using universities more for research. NSD and the reactor licensees have agreed a proactive strategy for Essential Research Capability (ERC) support for those facilities or bodies of expertise which are considered essential for the continued safe operation of nuclear power plant. This involves an annual review to reassess continued necessity and current viability. In addition, the review ought to identify any new bodies which have, or could, become essential. Action may be required to sustain an ERC and it is important that the teams are provided with confidence for their longevity by suitable medium/long term funding assurances.

There is also a need for NSD to maintain access to an Independent Technical Capability (ITC) for specialist safety advice, and NSD has established a similar procedure to that adopted for ERC. Where the maintenance of an ITC is in doubt, the regulator may consider commissioning research contracts as one means of guaranteeing its continued existence.

Where research is used for capability maintenance, the work undertaken should, as far as possible, be research aimed at addressing safety issues in the NRI. Operational activities may be supported as appropriate.

Unless the current reduction foreseen in the UK nuclear power programme in the longer term is reversed, it is likely that the proportion of the programme used to proactively support essential technical research capabilities (and independence) will increase in the near future. Also, with current changes within the licensees themselves, the strategy itself needs to be kept under close review and alternatives considered where appropriate.

Intelligence gathering

Much potentially valuable nuclear research is undertaken outside the HSC Programme. It is important that the UK nuclear industry achieves access to this research where it is of relevance. Sources are:

• outside the UK
• non-nuclear UK industries.
• other parts of HSE and other regulatory agencies.

Access to this information can be achieved in a number of ways, e.g.

• participation in international agency committees,
• membership of research "clubs" where research is shared,
• membership of vendors Owners Groups and research organisations such as EPRI by the licensees, who may pass the information to the regulator in safety cases,
• sponsorship of and representation at meetings and seminars,
• through exchange agreements.

Partnership is one of the areas addressed by the European Foundation for Quality Management model used by HSE/NSD. With UK nuclear safety research likely to decrease, it is important to take advantage of such activities to obtain research information for the UK in a cost effective manner. The regulatory challenges are mainly shared with other countries, including the more recent ones such as economic liberalisation and the development of indicators, and sharing the experience of dealing with them is of mutual benefit.

Secondary advantages achieved through these contacts are to assist in the dissemination of UK research and to demonstrate that the regulator is well informed on international developments and moving towards being a world class nuclear safety regulator (benchmarking)

Socio-economic research

Socio-economic research is one means for the regulator to improve methods of regulation. Such research is often not specifically nuclear in nature, but related to risk perception, risk governance and methods of regulation in general. Therefore usually such research is left to HSE to take the lead, with appropriate NSD involvement for nuclear aspects. Socio-economic and policy related issues are not included in the reactor Nuclear Research Index.

References

HSC, 2005, Science Strategy 2005-2008
IAEA GS-R-1, 2000, Legal and government infrastructure:
IAEA NSR-1, 2000, Design of nuclear power plants:
IAEA INSAG-12, 1999, Basic safety principles for NPPs
IAEA INSAG-16, 2003, Maintaining knowledge, training and infrastructure for R&D in nuclear safety
OECD-NEA, 2004, Capabilities and expertise in support of efficient and effective regulation of nuclear power plants
OECD-NEA, 2001, Assuring future nuclear competencies
OECD-NEA, 2001, Major facilities and programmes at risk
OECD-NEA, 2001, Role of research in a regulatory context
OECD-NEA, 2003, Regulator and industry cooperation: challenges and opportunities