A Guide to Nuclear Regulation in the UK 2016 Update

A guide to Nuclear Regulation in the UK 2016 update

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Contents

03 Introduction 05 The UK nuclear industry 12 Safety of the nuclear industry 24 Security of the civil nuclear estate 26 Emergency planning and preparedness 28 Transport of radioactive materials 29 International activities 32 Nuclear safeguards 33 List of abbreviations 34 Further reading

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Introduction

The The Office for Nuclear Regulation In performing our interventions we are (ONR) independently regulates safety required to comply with the Regulators’ and security at 37 licensed nuclear sites Code, which requires regulatory frameworks in the UK. These include the existing to support business through innovation fleet of operating reactors, fuel cycle with the aim of breaking down barriers and facilities, waste management and boosting UK productivity. In addition, the decommissioning sites and the defence Government requires that UK regulatory nuclear sector. In addition, we regulate frameworks support innovation, emerging the design and construction of new technologies and the digital economy. nuclear facilities and the transport of We adopt a modern enabling regulatory nuclear and radioactive materials and approach to all aspects of our regulation, work with the international inspectorates with the aim being to achieve longer-term to ensure that safeguards obligations strategic safety and security delivery. for the UK are met. We co-operate with Our approach involves working with international regulators on safety and licensees and duty holders, and other security issues of common concern, relevant stakeholders, to seek effective including associated research. delivery against clear and prioritised The responsibility for delivering a safe safety and security outcomes. We are and secure nuclear industry rests with clear with licensees and duty-holders the nuclear industry itself. Our role, that our independence in regulatory captured in our mission statement, is to decision making is not compromised and provide efficient and effective regulation we continue to hold them to account in of the nuclear industry, holding it to accordance with our mission. account on behalf of the public. We use This guide describes our regulatory activity a wide range of regulatory tools to and explains how we carry out our work in influence positively those we regulate, a clear and straightforward manner. It puts and to encourage the achievement of the regulation of the nuclear industry into sustained excellence and continuous context showing that despite its hazards, improvement in safety and security all the activities we regulate are performed performance across the nuclear sector. in a safe and secure manner. As ONR acts on behalf of the public, it is vital that we regulate with rigour, diligence and with an appropriate level of assurance that our work is targeted and proportionate to the hazards and risks presented by the industry at the right Richard Savage quality and cost. Chief Nuclear Inspector

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Regulated nuclear sites in the UK Regulated Nuclear Sites in Great Britain

• Dounreay Dounreay Site Restoration Ltd Clyde Naval Base MoD • • Vulcan Naval Reactor Hunterston B EDF Energy • Test Establishment Hunterston A Magnox Ltd • MoD Chapelcross Magnox Ltd • • Rosyth Rosyth Royal Dockyard Lillyhall Studsvik UK • • Torness EDF Energy Sellafield, including • Windscale and Calderhall • Hartlepool EDF Energy Moorside NuGen • • Manufacturing site, Derby Rolls Royce Marine Power Low Level Waste • Repository Ltd • Neptunetest reactor, Derby Rolls Royce Marine Power Barrow BAE Systems • • Harwell Magnox Ltd Heysham I and II EDF Energy • • Amersham GE Healthcare Preston Springfields Fuels Ltd • • Burghfield AWE Wylfa Magnox Ltd • • Aldermaston Wylfa Newydd Horizon • AWE Capenhurst URENCO • • Sizewell C EDF Energy Trawsfynydd Magnox Ltd • • Sizewell B Berkeley Magnox Ltd • EDF Energy Oldbury Magnox Ltd • • Sizewell A Oldbury B Horizon • Magnox Ltd Cardiff GE Healthcare • • Bradwell B EDF Energy Hinkley Point C NNB GenCo • • Bradwell Hinkley Point B EDF Energy • Magnox Ltd Hinkley Point A Magnox Ltd • • Consort reactor, Winfrith Magnox Ltd • Ascot Imperial College Devonport Naval Base MoD • • Dungeness A Devonport • Magnox Ltd Devonport Royal Dockyard • Dungeness B EDF Energy

Defence site Research reactor Partly operational/decommissioning Magnox reactor Advanced gas cooled Decommissioning reactor (AGR) Chemical plants and Identified by DECC as other facilities Proposed nuclear potential new build sites power station Pressurised water reactor (PWR)

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The UK nuclear industry

Nuclear power has been produced Today, the UK’s nuclear activity consists of: commercially since the 1950s and grew generating electricity through power- out of the policy need for a UK nuclear producing nuclear reactors; deterrent. At Windscale in Cumbria, two reactors were built to produce plutonium non-power-producing nuclear for defence purposes. These were then facilities, e.g. producing and followed at the adjacent Calder Hall site by reprocessing nuclear fuel; four energy producing reactors designed decommissioning of nuclear power to supply electricity. This saw the UK host reactors and other facilities; the world’s first commercial nuclear power station in 1956. new nuclear build; and defence facilities (licensed and non-licensed sites).

Table 1: UK operating (power producing) reactors

Power Station Owner Operator Reactor Electrical First Power Type Output Generation per Unit (MW)

Dungeness B (two EDF Energy EDF Energy Nuclear AGR 520 1983 reactors) Generation Ltd (NGL)

Hartlepool (two reactors) EDF Energy EDF Energy Nuclear AGR 595 1983 Generation Ltd (NGL)

Heysham 1 (two reactors) EDF Energy EDF Energy Nuclear AGR 585 1983 Generation Ltd (NGL)

Heysham 2 (two reactors) EDF Energy EDF Energy Nuclear AGR 615 1988 Generation Ltd (NGL)

Hunterston B (two EDF Energy EDF Energy Nuclear AGR 430 1976 reactors) Generation Ltd (NGL)

Hinkley B (two reactors) EDF Energy EDF Energy Nuclear AGR 430 1976 Generation Ltd (NGL)

Torness (two reactors) EDF Energy EDF Energy Nuclear AGR 600 1988 Generation Ltd (NGL)

Sizewell B (single reactor) EDF Energy EDF Energy Nuclear PWR 1188 1995 Generation Ltd (NGL)

This table does not include the reactor sites that are no longer operating

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Power-producing nuclear reactors

There are eight operating power stations, producing electricity for the national grid with three different types of reactors (refer to Table 1).

Magnox, First Generation Reactor Advanced Gas-cooled Reactors (AGR) The ten ‘first generation’ Magnox stations Seven stations owned and operated which started operation between 1956 by EDF Energy (eight if we include and 1971 were carbon dioxide gas- Heysham 1 and 2 as separate operating cooled graphite-moderated reactors reactors). These have two reactors using natural uranium fuel in a magnesium each and were commissioned between alloy cladding. The last reactor at Wylfa 1976 and 1988. They are ‘second stopped generating in December 2015. All generation’ nuclear reactors, which Magnox stations are owned by the Nuclear use enriched uranium oxide fuel in Decommissioning Authority (NDA) and stainless-steel cladding, allowing for operated under contract by Magnox Ltd. higher temperatures in the carbon They are in various stages of preperation dioxide coolant gas and more efficient for long term care and maintenance. electricity production.

Wylfa power station (courtesy of Magnox Ltd) Dungeness B power station (courtesy of EDF NGL

The UK’s nuclear power stations produce about 18% of the country’s electricity.

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Pressurised Water Reactor (PWR) One station owned and operated by EDF Energy. Located on the Suffolk coast, Sizewell B is the UK’s newest nuclear power station. It began operations in 1995 and uses enriched uranium oxide fuel, clad in zirconium alloy. PWRs are the world’s most common type of nuclear reactor. Between them, the UK’s nuclear power stations produce about 18% of the country’s electricity.

There are ten Magnox reactor stations now being decommissioned. These are: - Berkeley - Bradwell - Hinkley Point A Sizewell B power station (courtesy of EDF NGL) - Hunterston A - Sizewell A - Chapelcross - Dungeness A - Trawsfynydd - Oldbury - Wylfa

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Table 2: Non-power-producing nuclear facilities

Site Owner Operator Current activities Status

Dounreay, NDA Dounreay Site Originally used for research, development and Decommissioning Caithness Scotland Restoration Limited prototype operation of fast reactors, it is now of the reactors being decommissioned. The site still stores used and other plants is and unused nuclear fuel, together with liquid well advanced reprocessing liquors and other waste.

Winfrith, Dorset NDA Magnox Ltd Former nuclear power research and development Decommissioning site, housing laboratories and research/prototype reactors.

Harwell, Oxon United Magnox Ltd Former nuclear power research and development Decommissioning Kingdom site, housing laboratories and research reactors. Atomic The site still stores intermediate level radioactive Energy waste arising from its historic operations. Authority

Springfields, NDA Westinghouse Manufacture of fuels for AGRs and light water Operational and Preston Electric UK Limited reactors, manufacture of uranium hexafluoride, decommissioning/ processing of residues. demolition of redundant plants and buildings

Capenhurst Works, Urenco Ltd Urenco UK Plants producing enriched uranium for Operational and Chester international markets. The site stores depleted storage uranium hexafluoride. Part of site operated by a tenant on behalf of the NDA to provide the UK site for uranic materials storage.

Low Level Waste NDA LLW Repository Ltd UK’s national low level waste disposal site. Operational Repository, Cumbria

Metals Recycling Studsvik Studsvik UK Decontaminates and recycles metal waste as part Operational Facility, Cumbria UK of the UK’s low level waste strategy.

Imperial College Imperial Imperial College At the early stages of a decommissioning Decommissioning Consort Reactor, College programme. Berkshire

GE Healthcare GE GE Healthcare Manufacture of radiopharmaceutical products and Operational Limited, Amersham Healthcare waste storage. and Cardiff sites

Sellafield, Cumbria NDA Sellafield Ltd The largest nuclear site in Europe with possibly the Operational - world’s largest radioactive materials inventory in reprocessing one place. Operations centre around the nuclear plants and fuel cycle, with two spent fuel reprocessing plants decommissioning and a number of waste and effluent treatment plants and associated storage facilities. Many are at different stages of decommissioning. A key activity is moving radioactive materials from ageing legacy facilities to more robust modern facilities. The site also houses the decommissioning Calder Hall Magnox reactors.

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Non-power-producing nuclear facilities

There are a number of other nuclear facilities, which do not generate power but are dedicated instead to activities such as producing nuclear fuel, processing used nuclear fuel, and storing or treating radioactive material. Some of the sites are being decommissioned because they are no longer needed. Many of these sites are owned by the NDA and operated on the NDA’s behalf by contractors. ONR works with the NDA to optimise the safe decommissioning of its sites (see Table 2). Sellafield (courtesy of Sellafield Ltd)

Sellafield Sellafield is a large and complex nuclear UK’s oldest reactors) will be completed in fuel reprocessing site situated in Cumbria. 2020 while Advanced Gas cooled Reactor The site is owned by NDA and has a (AGR) fuel reprocessing will cease in workforce of around 10,000. Construction 2018. Significant quantities of radioactive of the site commenced around 1950 and wastes from past reprocessing activities it is the location where the spent nuclear are stored on the site in facilities that fuel from the UK’s civil nuclear reactors do not meet modern standards. These is stored and reprocessed. Reprocessing facilities pose unacceptable risks to the involves dissolving the nuclear fuel in public and workers and dealing with them concentrated acid. The resultant highly is a national priority. Reducing these risks active liquors are then turned into glass is consequently ONR’s main focus and (vitrified) for long term storage whilst the strenuous efforts are being put into the uranium and plutonium extracted from the recovery and treatment of these wastes; a fuel are stored for future use. It is planned process anticipated to take between two that reprocessing of Magnox fuel (from and three decades to complete.

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Defence facilities

Nuclear licensed sites Nuclear non-licensed sites There are seven licensed nuclear sites Several naval sites undertake nuclear- which are operated in support of the related activities but are exempt from MoD’s Defence Nuclear Programme. aspects of ONR regulation as they are These sites provide and maintain the under the control of the Crown (MoD). On warheads for the UK’s nuclear deterrent, these sites, nuclear and radiation safety is and support for the UK fleet of nuclear regulated jointly by the Defence Nuclear powered submarines, including: Safety Regulator (DSNR) and ONR. ONR is also the enforcing authority for submarine reactor fuel manufacture, conventional safety regulation within these including a test reactor; sites. submarine construction and ONR regulates these sites through commissioning; the Health and Safety at Work etc Act submarine maintenance, refuelling and 1974 (HSWA), the Ionising Radiations decommissioning. Regulations (IRR99) and the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR). These sites are HM naval bases at Devonport and Clyde (comprising the Faslane and Coulport sites), the Vulcan Naval Reactor Test Establishment at Dounreay and, 5 Basin at Devonport.In addition, there are a number of submarine operational berths around the UK, including Southampton, Portsmouth, Portland and Clyde where ONR enforces IRRs and REPPIR only. HMS Astute (courtesy of BAE Systems)

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Table 3: Nuclear defence licensed sites

Site Owner Operator Current activities

Atomic Weapons MoD AWE plc Manufactures and maintains the Establishment, warheads for the UK’s submarine Aldermaston, Berkshire launched nuclear deterrent.

Atomic Weapons MoD AWE plc Manufactures, maintains and Establishment, decommissions the warheads for the Burghfield, Berkshire UK’s submarine launched nuclear deterrent.

Rolls Royce Marine Rolls-Royce Rolls Royce Carries out the manufacture of nuclear Power Operations plc Marine Power fuel for submarine reactors. They also Limited, Derby, Operations operate a low energy naval research Derbyshire (two sites) Limited reactor. These are separate licensed sites with a single operator.

Devonshire Dock BAE Systems BAE Systems Carries out submarine construction and Complex, Barrow in Maritime - Marine Limited commissioning activities. Currently the Furness, Cumbria Submarines Astute Class hunter killer submarines are being built there for the Royal Navy.

Devonport Royal Babcock Devonport Carries out the maintenance and Dockyard Limited, International Royal refuelling of the Royal Navy’s Plymouth, Devon Group Dockyard submarines. Plant and site Limited modifications are currently being progressed that will enable future defuelling activities to be carried out on redundant hunter killer submarines.

Rosyth Royal Dockyard Babcock Rosyth Royal Most of the nuclear related facilities Limited, Fife International Dockyard have been decommissioned, leaving Group Limited only a small inventory of radioactive waste. Defuelled submarines are stored at Rosyth off the licensed site, but are occasionally brought onto the licensed site for work to be carried out.

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Safety of the nuclear industry

Hazards of radiation and the risks from exposure

Communicating the difference between below gives an indication of some of the what constitutes a hazard, as opposed to risks we face in everyday life. These can something which represents a risk, is a be contrasted with the risk of dying as a challenge that ONR faces when providing result of a nuclear accident, which in the reassurance to a wide variety of groups, UK is about 1 in 100 million per year. including communities living in the vicinity The harm to people’s health from radiation of nuclear sites, the wider public and depends on the amount of radiation government. being given off by the substance per The terms ‘hazard’ and ‘risk’ are often used second and how energetic that radiation interchangeably in everyday vocabulary. is. An important property of a radioactive Common definitions when discussing substance is that the rate of radiation workplace health and safety are that: emitted will diminish naturally over time. This is measured by its half-life – the time a hazard is any thing that has the it takes for a radioactive substance to potential to cause harm; and reduce its radioactivity by half. This can risk is the likelihood of the hazard range from seconds to millions of years arising, combined with the effect of depending on the particular substance. the hazard. There are various ways in which radioactive The primary hazards associated with substances can affect the body, for the nuclear industry arise from radiation example by direct exposure to the given off by radioactive materials. The radiation or, by internal exposure due to risk represents the likelihood that people ingestion or inhalation of the substance, or are exposed to that radiation. Table 4 by entering the bloodstream via wounds.

Table 4: Annual risk of death for various causes averaged over the entire population (taken from Annex 4 of HSE’s Reducing risks, protecting people)

Cause of death Annual risk

Cancer 1 in 387

Injury and poisoning 1 in 3 137

All types of accidents and all other external causes 1 in 4 064

All forms of road accident 1 in 16 800

Lung cancer caused by radon in dwellings 1 in 29 000

Gas incident (fire, explosion or carbon monoxide poisoning) 1 in 1 510 000

Lightning 1 in 18 700 000

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Some ingested or inhaled substances Latent harm manifests itself as an will be excreted and exposure is less as increased risk of various types of cancer, a result. The degree of harm depends some of which may lead to death, or on the combination of these factors and, possible genetic defects. These latent although highly complex, the International effects may not become apparent for Commission on Radiation Protection many years after exposure and may not provides recognised models for measuring materialise at all. exposure and assessing harm. Estimates of the likelihood of latent Potential harm to an individual is normally effects are based on the assumption considered to be either direct or latent. that the increase in cancer risk is directly Direct harm usually affects those who proportionate to the increase in exposure receive a very large dose of radiation, for to radiation, no matter how small that example workers in close proximity to a increase may be. Such risks arise from nuclear accident or those exposed to a both naturally occurring as well as man- highly radioactive source. Effects may made sources of radiation. include vomiting, damage to the skin Nuclear emergency planning is based and internal organs and, at high enough on the prevention of direct effects and exposures, death. limitation of the risk of latent effects.

The primary hazards associated with the nuclear industry arise from radiation given off by radioactive materials.

Sellafield (courtesy of Sellafield Ltd) The risk represents the likelihood that people are exposed to that radiation, combined with the effect of the radiation.

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Measuring exposure

For nuclear power station reactors, the The unit of radiation exposure is the main hazard derives from the large amount sievert (Sv). One Sv represents a large of radioactivity in the fuel which has been dose and in an adult equates to increased created by nuclear fission. To ensure that chance of getting cancer of about 1 in 20 this radioactivity is not released, nuclear (for comparison, the normal chance of power stations employ the barriers of dying from cancer is about 1 in 4). Most controlling, cooling and containment. exposures will be measured in millisieverts (mSv) which is one thousandth of a sievert. Controlling nuclear and chemical reactions to limit the release of The annual legal limits for normal radiation energy will prevent the degradation exposure from nuclear facilities are of the containment and escape of 20 mSv for radiation workers on plants, radioactive material. and 1 mSv for members of the public who may be exposed by discharges and Cooling the radioactive material, if it is direct radiation from the facility. The legal heat-generating, ensures that excessive requirement to take all necessary steps to temperatures do not occur which may restrict exposures, so far as is reasonably degrade the containment and lead to practicable exposure means that radiation the escape of radioactive material. workers in the UK are exposed, on Containment of the radiation or average in a year, to around 1 mSv. This radioactive material is done by is in addition to the average 2.7 mSv shielding with concrete walls, which per year we all incur from our normal stop or absorb radiation, and with activities. Exposure to natural radiation robust vessels, cells and flasks to stop varies around the country depending on radioactive material escaping. the local geology. Some areas, such as Cornwall with its high amounts of naturally In non-power-generating nuclear facilities, radioactive granite, give rise to annual some of the most significant hazards background exposures around four times arises from heat-generating radioactive the average (i.e.10 mSv). We also incur materials in facilities dealing with used increased cosmic radiation doses when nuclear fuel. Here, cooling will be a key we fly, as well as radiation doses when we feature and where there is the potential eat certain naturally radioactive foods, or for release of radioactivity, there is always when we are exposed to certain medical the need to ensure containment. procedures such as X-rays. The annual legal limits for normal radiation exposure from nuclear power plants are 20 mSv for radiation workers on plants, and 1 mSv for members of the public.

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Ensuring safety

The safety of a nuclear facility depends The internationally accepted approach on controlling the risk of exposure to for nuclear safety is to use the concept radiation from both routine operational of ‘defence in depth’. This is an approach activities and from potential accidents. which puts in place layers of protective On site, ONR regulates both of these systems which, in the event of an aspects, while various environment accident, will contain and delay the regulators (in England, Wales and release of radiation and so limit the risk Scotland) regulate permitted discharges of of harm. Defence in depth is embedded radioactive materials into the environment. in ONR’s Safety Assessment Principles A number of factors combine to ensure (SAPs) which are used to judge the the safety of a nuclear site: adequacy of licensees’ safety cases. a robust design with appropriate limits The aim is to ensure that: and conditions for operation; faults do not occur; a rigorous operating regime with peer if faults do occur they are controlled; and checking, self-assessment, training accreditation and internal oversight; if the protection fails, systems are in place to mitigate the consequences. an experienced regulatory group within the licensee’s organisation; Conservative design, good operating practice and proper maintenance and external peer review of the licensee testing should minimise the likelihood of from organisations such as the World faults. Nevertheless, the design of nuclear Association of Nuclear Operators facilities must be shown to be capable of (WANO) and the International Atomic tolerating a wide range of possible faults. Energy Agency (IAEA) The principle of ‘defence in depth’ oversight by a strong independent also requires licensees to analyse fault external regulator (ONR) staffed by sequences leading to severe accidents in highly trained, qualified professionals order to identify any additional equipment undertaking site inspection and that may be needed and to ensure that technical assessment work. As well as realistic guidance on the actions to be a rigorous internal assurance process, taken is available. ONR is also subject to international peer review by the IAEA. The worldwide consensus strategy for nuclear safety is to use a ‘defence in depth’ approach.

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Safety legislation

The legal framework for the nuclear A key principle of the UK’s approach is industry is based around the Health and that nuclear licensees are required to Safety at Work etc. Act 1974 (HSWA), build, operate and decommission nuclear the Energy Act 2013 and the Nuclear sites in a way that ensures that risks are Installations Act 1965. kept as low as reasonably practicable. This is referred to as the ALARP principle HSWA places duties on all employers, and requires licensees to demonstrate that including those in the nuclear industry, they have done everything ‘reasonably to look after the health and safety of practicable’ to reduce risks. This requires both their employees and the public. them to balance the level of risk posed However, because of the particular by their activities against the measures hazards associated with the nuclear needed to control that risk in terms of industry, including the potential for money, time or trouble. However, they do accidents to cause widespread harm not have to take action if those measures and social disruption, further legislation would be grossly disproportionate to the is also in place, specifically the Nuclear level of risk averted. Installations Act 1965. Additionally, there are provisions for nuclear regulations to be Ensuring overall safety made under the Energy Act 2013, as well as specific regulations under HSWA such In addition to nuclear safety ONR is also as the Ionising Radiations Regulations responsible for regulating non-nuclear, 1999 (IRR99) and Radiation (Emergency or conventional, health and safety Preparedness and Public Information) on nuclear licensed sites. The aim of Regulations 2001 (REPPIR). regulation is to ensure that the site has reduced risks to employees and The legal framework other persons so far as is reasonably practicable. This includes fire safety. for the nuclear industry is based around the Health and Safety at Work etc. Act 1974, the Energy Act 2013 and the Nuclear Installations Act 1965. Torness power station (courtesy of EDF Energy)

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How ONR regulates nuclear safety

Although ONR regulates nuclear sites and implement ‘adequate arrangements’ in the UK, the legal responsibility for for compliance with the licence condition, ensuring nuclear safety rests with as well as some more prescriptive the dutyholder. The Government is requirements. Adequacy, in this context, responsible for establishing nuclear policy means ONR’s evidence-based judgement through a legislative regulatory framework. that the licensee’s arrangements for the It does not set regulatory standards or management of nuclear safety meet the make regulatory decisions. These matters high standards expected of the nuclear are the responsibility of ONR. industry in both the UK and internationally. The UK generally operates a goal-setting A combination of ONR’s assessment and regime rather than the more prescriptive, inspection functions allows ONR to judge standards-based regimes applied in some whether licensees are operating with other countries. This means that ONR sets risks reduced to as low as reasonably out its broad regulatory requirements, and practicable. it is for licensees to determine and justify how best to achieve them. This approach allows an operator to be innovative and to achieve the required high levels of nuclear safety by adopting practices that meet its particular circumstances. It also encourages continuous improvement and the adoption of relevant good practices. ONR has attached 36 conditions to each nuclear site licence within which the licensees are required to operate, Table 5 lists these licence conditions. These set requirements for the licensee to make

The UK generally operates a goal- setting, regime rather than the more prescriptive, standards-based regimes applied in some other countries.

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In coming to a judgement on whether An important part of ONR’s safety an acceptable level of safety is being assurance is its monitoring of the achieved, a significant body of information performance of the licensee’s internal is typically considered, for example: regulator or internal assurance function, which can provide useful information safety cases; and help inform the development of site reports on the licensees’ periodic inspection plans and assessments. reviews of safety; Assessment is the process ONR applies results of on-site compliance to reach an independent and informed inspections, including joint inspections judgement on the adequacy of a nuclear with the licensees’ own regulatory safety case and underpins our application compliance teams; of the regulatory regime. For any operation that may affect safety, licensees are annual reviews of safety at each required to produce an adequate safety site, and information from start-up case to demonstrate the safety of that meetings at the end of each reactor operation. The overriding regulatory statutory outage; requirement is that the safety case shows the findings from investigations of that the licensee has reduced risks to as incidents and events; low as reasonably practicable. insights and intelligence gained from ONR’s assessment resources are the licensees’ senior management and organised around a number of internal regulator; and specialist technical disciplines, such as structural integrity, fault studies, the annual demonstration of electrical engineering and human factors. emergency exercises at each site. Assessors, who are appointed as nuclear inspectors, are recruited on the basis of their high technical qualifications A combination of ONR’s and extensive experience in nuclear assessment and inspection or other high-hazard industries. In reaching decisions on the adequacy of functions allows ONR to a licensee’s safety case, assessors will judge whether licensees use ONR’s Safety Assessment Principles as guidance. They may also visit sites are operating with risks to check the veracity of what is said in reduced to as low as the safety cases and to resolve technical issues with the licensee’s staff. In order reasonably practicable. to ensure that regulatory assessment

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Table 5: Licence conditions

1 Interpretation 20 Modification to design of plant under construction 2 Marking of the site boundary 21 Commissioning 3 Control of property transactions 22 Modification or experiment on existing 4 Restrictions on nuclear matter on the site plant

5 Consignment of nuclear matter 23 Operating rules

6 Documents, records, authorities and 24 Operating instructions certificates 25 Operational records 7 Incidents on the site 26 Control and supervision of operations 8 Warning notices 27 Safety mechanisms, devices and circuits 9 Instructions to persons on the site 28 Examination, inspection, maintenance and 10 Training testing

11 Emergency arrangements 29 Duty to carry out tests, inspections and 12 Duly authorised and other suitably examinations qualified and experienced persons 30 Periodic shutdown

13 Nuclear safety committee 31 Shutdown of specified operations

14 Safety documentation 32 Accumulation of radioactive waste

15 Periodic review 33 Disposal of radioactive waste

16 Site plans, designs and specifications 34 Leakage and escape of radioactive 17 Management systems material and radioactive waste

18 Radiological protection 35 Decommissioning

19 Construction or installation of new plant 36 Organisational capability

An important part of ONR’s safety assurance is its monitoring of the performance of the licensee’s internal regulator.

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Regulatory intelligence

decisions are robust and consistent, Nuclear sites may experience unplanned assessment reports are peer reviewed events that can be described as internally and authorised by a senior anomalies, incidents or accidents inspector. depending on their severity. In general, the more significant the event the more Inspection is the structured gathering that could be learned from it. In order to of intelligence about nuclear licensees’ prevent the recurrence of incidents and safety and security performance, through accidents, ONR encourages licensees direct first-hand observation of plant, and others with legal duties on the site to procedures and work activities and the report events to ensure lessons are being questioning of staff on the site. Safety derived. This provides assurance that the inspection activities focus on checking dutyholder is taking steps to learn from licensee compliance with the nuclear site mistakes and helps ONR focus attention licence conditions and enforcing other in areas where further investigation or safety legislation for which ONR is the advice might be needed. This contributes statutory regulator. towards a culture of continuous ONR targets its attention on sites and improvement in the nuclear industry. facilities which hold the highest hazard The UK uses the International Nuclear and pose the greatest risk. Where an and Radiological Event Scale (INES) to operator’s safety standards fall short rate reported events. The INES scale is of what is required by law, ONR will a tool devised and maintained by the implement an enforcement response International Atomic Energy Agency (IAEA) which is proportionate to the degree of for use worldwide, to facilitate consistent shortfall. ONR generally seeks to bring communication and understanding about safety improvements through a between the technical community, persuasive and influencing approach, the media and the public of the safety but it will increase the severity of its significance of events associated with enforcement action as necessary, sources of radiation. including taking criminal prosecutions where appropriate.

ONR generally seeks to bring about safety improvements through a persuasive and influencing approach, but it will increase the severity of its enforcement action as necessary.

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In reporting events to ONR, nuclear sites The Fukushima accident in 2011 and provide an initial INES rating for the event. Chernobyl in 1986 were classified as ONR employs a nuclear safety inspector Level 7. In the UK there has only been one as the UK INES National Officer to verify event that was rated as a nuclear accident, the ratings given by the site. ie Level 4 or above; this was the Windscale fire in 1957, which was retrospectively Events are classified on the scale at seven classified as a Level 5 event. This event levels: was instrumental in the Government Levels 1-3 are in the incident category. setting up the Nuclear Installations Inspectorate, since incorporated into Levels 4-7 are in the accident category. ONR, to provide independent regulation of Events without safety significance are the civil nuclear power programme which classified as “Below Scale / Level 0”. was then being embarked upon.

The IAEA International Nuclear and Radiological Event Scale (INES)

7 Major accident

6 Serious accident Accident Accident with 5 wider consequences

Accident with 4 local consequences

3 Serious incident

Incident 2 Incident

1 Anomaly

Below scale / level 0 NO SAFETY SIGNIFICANCE

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Regulatory Assurance

In line with recognised good practice assure regulatory decisions and activities. and international guidelines, ONR has a The Directorate is divided in to five range of internal assurance mechanisms separate functions: to ensure the robustness of its processes, Regulatory Training ensures that decision-making and other activities. ONR’s people have the necessary skills The Regulatory Assurance Directorate and knowledge to perform their regulatory is independent from ONR’s operational duties. Beginning with effective and programmes and aims to secure the timely staff induction, and backed by a confidence of stakeholders including busy portfolio of both legal core training Government and the ONR Board and and specialist technical courses, the Executive. It is headed by the Director team delivers a professional capability of Regulatory Assurance who is also a development and refresher programme member of ONR’s senior executive team. to all ONR inspectors. The ONR Learning and Development team ensures that The Regulatory Assurance Directorate ONR embeds the ethos of a learning aims to complement the specialist organisation and promotes a consistent knowledge and experience of ONR approach to regulatory and technical inspectors and the management challenges. processes that are followed to routinely

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The Knowledge Management The Regulatory Research function function ensures that regulatory and ensures that ONR has continued access technical knowledge is passed on and to the latest independent scientific shared between ONR’s experienced and technical expertise, to support its regulators and newer inspectors. goal of being an exemplary regulator. Embedding effective knowledge The objectives of this research include management processes throughout the supporting independent regulatory organisation is recognised as vital in decision-making by helping ONR to test ensuring consistent, proportionate and claims made in safety cases, identifying robust regulatory decision-making. potential risks from new technologies, and securing access to scarce technical The Technical Standards function expertise. maintains ONR’s Safety Assessment Principles (SAPs), Technical Inspection Regulatory Assurance Review and Guides (TIGs) and Technical Assessment Oversight ensures that ONR follows Guides (TAGs) so that ONR inspectors appropriate standards, guidance and have up to date, relevant and consistent processes across the entire regulatory guidance to help regulate the nuclear body. The team carries out internal industry. To be fully transparent, the reviews, both planned and reactive, in SAPs, TIGs and TAGs standards are also addition to general oversight activities published to ensure that all stakeholders, across all of ONR’s operational including dutyholders in the industry, are programmes. The Review and Oversight fully aware of ONR’s expectations. team aims to highlight learning and continuous improvement opportunities throughout the organisation, and provides assurance reports to ONR’s Board, Executive Management Team, and the Government. ONR has a range of internal assurance mechanisms to ensure the robustness of its processes, decision-making and other activities

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Security of the civil nuclear estate

Security legislation

Effective security arrangements in the The Nuclear Industries Security nuclear industry are essential to prevent Regulations 2003 (as amended) (NISR) the theft of nuclear or other radioactive place significant obligations on the materials, the sabotage of nuclear operators of civil licensed nuclear sites facilities and to protect sensitive nuclear with regard to physical security measures information. ONR plays an important for facilities, nuclear material and the role in setting out requirements for security of Sensitive Nuclear Information nuclear security outcomes for the civil (SNI). NISR also covers the vetting of nuclear sector thereby enabling it to put permanent staff and contractors, the in place protective security measures movement of nuclear material by road commensurate with the threat. Doing this and rail within the UK and globally in UK- requires collaboration between a number flagged vessels. This legislation requires of national and international bodies. all civil nuclear operators to produce and implement robust Nuclear Site Security Plans (NSSP). Strict requirements exist for the reporting of security incidents, and developers of civil nuclear sites have obligations during the design and construction process. ONR regulates: civil licensed nuclear sites, each with an NSSP, as well as tenants at some of these sites who are required to maintain their own security plans;

(Courtesy of Civil Nuclear Police Authority)

Effective security arrangements in the nuclear industry are essential.

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How ONR regulates nuclear security

one unlicensed nuclear site holding ONR’s regulation of nuclear security nuclear material; prioritises areas that involve the greatest hazard and present the greatest risk. As companies approved by ONR to with safety, security in the nuclear industry transport nuclear material within the is based on the principle of defence in depth UK and globally in UK-flagged vessels; where there are multiple layers of protection locations where SNI and technology is so that if one is breached, further barriers held – ONR regulates the security of SNI exist. Our enforcement of security legislation whether on or off nuclear licensed sites; is conducted in accordance with the same policies and procedures as those governing the vetting of permanent staff and the enforcement of safety legislation. ONR contractors involved with nuclear has the power and duty to compel plant materials or SNI. operators, carriers of nuclear material and ONR does not regulate the security of those holding sensitive information and radioactive sources held outside nuclear technology to make improvements to their licensed sites; these are regulated by the security arrangements, if necessary. environment agencies and supported by Currently, security regulation is police counter-terrorist security advisors. underpinned by ONR’s National Objectives, Security at nuclear premises operated Requirements and Model Standards primarily or exclusively by MoD or its (NORMS). This provides guidance on how contractors is also outside of ONR’s the industry can meet the duties placed on regulatory remit. it by security legislation and has moved the regulation of civil nuclear security towards ONR has the power a more goal-setting, outcome-based to compel plant approach, with onus on dutyholders to propose and justify security arrangements operators, carriers of that meet ONR’s defined security objectives. nuclear material and In 2017, the evolution of outcome focused security will continue as NORMS is replaced those holding sensitive by Security Assessment Principles (SyAPs) information and providing more mature guidance. technology to make A programme of planned and no-notice inspections (including in-depth multi- improvements to their disciplinary inspections) is carried out by security arrangements teams of security inspectors, to ensure compliance with the approved arrangements. if necessary. Regular site security exercises are also observed to assess the performance of security systems against a range of scenarios. Office for Nuclear Regulation page 25 of 36 A guide to Nuclear Regulation in the UK

Emergency planning and preparedness

Responding to an emergency

Although the design, operation and All nuclear operators and relevant local maintenance of nuclear installations authorities prepare, in consultation with makes the risk of accidents involving the emergency services and other bodies, the release of radiation extremely low, emergency plans for the protection of the regulations are in place to ensure there are public and their workforce in a nuclear adequate arrangements for responding emergency. These emergency plans to a nuclear or radiological emergency. are subject to regular tests under three These regulations are enforced by ONR. categories: The Department of Energy and Climate Level 1 exercises are held at each Change (DECC) is the Lead Government nuclear site generally once a year Department in the event of any emergency and concentrate primarily on the resulting from off-site radiological operator’s actions on and off the site. consequences from a licensed civil nuclear Level 2 exercises are usually held site in England and Wales. In Scotland, triennially and are aimed primarily the main national coordinating role would at demonstrating the adequacy of fall to the Scottish Government. DECC the arrangements made by the local has established national governance authority to deal with the off-site arrangements where representatives from aspects of the emergency. nuclear operators, police, fire service, local authority emergency planning officers, Level 3 exercises are held annually nuclear regulators and government to rehearse the wider involvement of departments and agencies come together central government. to consider measures required to respond to a nuclear emergency.

All nuclear operators and relevant local authorities prepare, in consultation with the emergency services and other bodies, emergency plans for the protection of the public.

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The police, working in conjunction with given to the level of risk presented by the other emergency services, expert bodies, site, local and practical considerations and local and national agencies, are relevant to the implementation of the responsible for coordinating response plan itself, and any other relevant factors effort locally. The lead government that ONR judges to be necessary in the department coordinates the response at interests of public safety. The off-site a national level, briefing ministers and the emergency planning area is based on UK’s international partners, and acting the effects of a reasonably foreseeable as the main source of information to the radiation emergency, and whilst not public and the media at national level. currently a statutory requirement, it is good practice that local authorities ONR works closely with Public Health consider the means by which the area England’s Centre for Radiation, Chemical might be extended in the highly unlikely and Environmental Hazards which event of a larger accident. provides guidance on public protection countermeasures. Such countermeasures include sheltering, evacuation and the taking of potassium iodate tablets to reduce the uptake of radiation to the public in the early stages of some types of nuclear emergency. ONR determines the size of the local authority off-site emergency planning area in accordance with the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR). In determining the size, consideration is Emergency exercise

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Transport of radioactive materials

ONR regulates the movement of all Although complex, this arrangement has radioactive material in Great Britain (with worked successfully for many years. the exception of some material related Significant incidents or accidents must to defence). This includes flasks carrying be reported to ONR so that they can be spent nuclear fuel from operating and investigated and appropriate lessons decommissioning nuclear reactors, radio- learnt and acted on. ONR implements an pharmaceuticals needed for hospitals, inspection and audit programme to judge and sealed radiocative sources needed, the extent to which the nuclear industry for instance in the construction industry, and other duty holders comply with or for the non-destructive testing of North transport regulatory requirements. ONR Sea oil rigs. also reviews the emergency arrangements The regulations for the transport of of consigners and carriers and ensure that radioactive materials are prescriptive these are appropriately tested. to meet international requirements that enable transport of packages across international borders. The UK regulations are based on those of the IAEA, which are applied internationally. ONR engages with UK industry and interested parties regarding proposed changes to the regulations, and represents the interests of the UK at the Transport Safety Standards Committee at the IAEA. The UK regulations also reference other international regulations for radioactive materials transported by land, sea and air. (Courtesy of IAEA)

The regulations for the transport of radioactive materials are prescriptive to meet international requirements that enable transport of packages across international borders.

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International Activities

ONR undertakes a broad range of European regulators, advises the international activities, working to ensure Commission on nuclear safety matters that international law and standards and works with other member states on are best placed to further safety and key European safety issues. security in the UK and to take advantage The UK is also signatory to two of opportunities to increase the quality international safety conventions; the and efficiency of our regulation through Convention on Nuclear Safety and the Joint international cooperation. Convention on the Safety of Spent Fuel At the European level a number of Management and the Safety of Radioactive European Commission Directives place Waste Management. ONR ensures that its requirements on the law ONR enforces practices align with the requirements of the and the wider regulatory framework- such conventions and takes part, every 3 years, as the independence of the regulator. in international peer review of the UK and ONR supports the Government on other contracting parties’ compliance the negotiation and implementation with these Conventions. With respect to of Directives. ONR is a member of the nuclear security the UK is signatory to the European Nuclear Safety Regulators Convention on the Physical Protection of Group (ENSREG) and alongside other Nuclear Material.

ONR meeting with Hitachi-GE, the British Embassy and the Nuclear Regulatory Authority (NRA), Japan’s nuclear safety regulatory body.

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In addition to the legal framework, missions to benchmark our regulatory ONR contributes to safety and security approach and facilitate continuous standards set by the International Atomic improvement. Energy Agency (IAEA) and safety reference International activities however are not levels agreed by the Western European limited to international law, standards Nuclear Regulators Association (WENRA). and guidelines. ONR undertakes a These standards directly inform ONR’s own range of bilateral and multilateral work standards and policies used in regulation. to progress safety and security in the The IAEA’s Integrated Regulatory Review UK. For example, ONR takes part in Service (IRRS) conducts reviews of the Multinational Design Evaluation national regulators’ policies and practices Programme (MDEP), which brings together against IAEA standards. In addition to regulators from countries undertaking being reviewed by the IRRS, most recently the assessment of new reactor designs in 2015, ONR provided experts to take to share learning and agree common part in reviews of other countries. Similarly positions. This work directly contributes the UK hosts and contributes experts to to the Generic Design Assessment work missions by the International Physical carried out by ONR. Protection Advisory Service (IPPAS), These activities, amongst others, are used concerning practices and arrangements by ONR to ensure that strategic objectives for nuclear security. The UK hosted an can be met through international IPPAS mission in 2011 and will receive a engagment, contributing to both UK and follow up mission in 2016. ONR uses these worldwide safety and security.

ONR meets its strategic international objectives through involvement in a wide variety of international activities.

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Nuclear safeguards

Nuclear safeguards are measures put The primary safeguards ‘regulators’ are in place to verify that countries comply the international safeguards inspectorates with their international obligations not to of the IAEA and the European use civil nuclear materials (plutonium, Commission (Euratom), not the ONR. uranium and thorium) for the manufacture This means ONR’s safeguards role differs of nuclear explosives. Since it is the from what it does in regulating nuclear country itself that is regarded as the safety, security and transport. ONR’s potential diverter of nuclear material, safeguards team works with the Euratom confidence about the absence of diversion and IAEA safeguards inspectorates and is provided by international (i.e. third UK organisations subject to safeguards party) verification. Such safeguards are requirements so that safeguards a cornerstone of the international non- obligations for the UK are met in a proliferation regime, and safeguards proportionate manner. ONR also fulfils obligations in the UK derive from: safeguards-related reporting obligations on behalf of the UK Government and the Euratom Treaty, which requires provides advice and support to DECC, European Commission application of who are responsible to Parliament for the safeguards to all civil nuclear material UK’s international safeguards obligations, in the European Union; and and elsewhere in Government on the safeguards agreement between safeguards implementation in the UK. the UK, the International Atomic Energy Agency (IAEA) and Euratom in connection with the Treaty on Nuclear safeguards are the Non-Proliferation of Nuclear Weapons (NPT), under which the IAEA measures put in place can choose to inspect civil nuclear to verify that countries material at any facility in the UK, and the additional protocol to that comply with their agreement. international obligations not to use nuclear materials (plutonium, uranium and thorium) for the manufacture of nuclear explosives.

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List of abbreviations

AGR Advanced gas-cooled reactor MoD Ministry of Defence ALARP As low as reasonably practicable mSv millisievert AWE Atomic Weapons Establishment NDA Nuclear Decommissioning CCSWG Centrifuge Collaboration Authority Security Working Group NEA Nuclear Energy Agency CNI Chief Nuclear Inspector NEPDC Nuclear Emergency Planning Delivery Committee DECC Department of Energy and NISR Nuclear Industries Security Climate Change Regulations 2003 DNSR Defence Nuclear Safety NORMS National Objectives, Regulator Requirements and Model EC European Commission Standards ENSRA European Nuclear Security NSSG Nuclear Safety and Security Regulator Association Group ENSREG European Nuclear Safety NSSP Nuclear Site Security Plan Regulator’s Group ONR Office for Nuclear Regulation EPA Emergency Planning Area PWR Pressurised water reactor GTRP Global Threat Reduction REPPIR Radiation (Emergency Programme Preparedness and Public HSE Health and Safety Executive Information) Regulations 2001 HSWA Health and Safety at Work etc. SAPs Safety Assessment Principle(s) Act 1974 SNI Sensitive Nuclear Information IAEA International Atomic Energy Sv Sievert Agency WANO World Association of Nuclear INES International Nuclear and Operators Radiological Event Scale WENRA Western European Nuclear IPPAS International Physical Protection Regulators Association Advisory Service IRR99 Ionising Radiations Regulations 1999 IRRS Integrated Regulatory Review Service

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