The IRRS completed its third mission on 9 October 2013
In addition to reviewing the findings from 2006 and 2009, the mission assessed the nuclear safety themes that were not within the scope of the previous missions including:
- waste management
- decommissioning
- radioactive sources
- radiation protection and lessons from Fukushima.
Reviewing these final modules ensured that ONR has received a full scope mission. The IRRS reviewers also assessed compliance with IAEA's relevant standards and guides, overarching themes included: independence; funding/resource; resilience; competence and integration.
Mission team
- Team leader - Bill Borchardt (USA)
- Deputy team leader - Ingemar Lund (Sweden)
- Team coordinator - Adriana Nicic (IAEA - NSNI)
- Deputy team coordinator - Gerrad Bruno (IAEA - NSRW)
- Modules 1 and 3 - Legal and role of the regulator - David Skeen (USA)
- Module 4 - Management system - Phillip Webster (CAN)
- Modules 5 - 8 - Licensing, Assessment, Inspection and enforcement - Ferenc Adorian (HUN)
- Module 10 - Emergency preparedness and response - Karol Janko (SLR)
- Module 11 - Occupational radiation protection, Control of discharges and environmental monitoring - Pascal Guillaud (FRA), Gerrad Breas (NET)
- Modules 5-9 - non-nuclear power plantsm, Radiation sources, Waste and decommissioning - Rusiana Tripailo (UKR), Peter Lietava (CZR), Luis Jova Sed (CUB), Kaisa-Leena Hutri (FIN)
- Fukushima module - Ivan Lux (IAEA)
- Administrative assistant - Martin Ubani (IAEA)
The mission involved an introductory meeting, with high level presentations given to the IRRS team by IAEA, DWP, DECC and ONR. The rest of the mission consisted of information and evidence gathering by holding interviews with ONR technical staff, observation of inspection activities at licensed sites, and interviews with UK nuclear and radiation safety stakeholders.
In the final report from the 2013 mission, the IAEA team commends:
- the systematic way in which ONR has taken into account the 2006 and 2009 recommendations and suggestions
- the significant progress and improvements made in many areas, such as how ONR engages with licensees, assesses emergency preparedness and response capability, and ONR's regulatory guidance
This has meant that 31 out of the 32 recommendations and suggestions made in 2009 were fully addressed and therefore considered as closed which is a strong follow up position. The Report also explicitly highlights six areas in which the IAEA consider that ONR delivers Good Practice. The review team identified 25 new findings (13 recommendations and 12 suggestions) relating to two main themes:
- responsibilities and Functions of ONR (including organisational capability, communications and training)
- supervision of non-nuclear power plant facilities (including regulation of radioactive sources, radioactive waste streams and decommissioning)
ONR has accepted these as an opportunity to further enhance the regulatory framework and processes, and a detailed ONR programme of work is underway to address them. The IAEA has accepted a proposal from ONR to review progress against the 2013 findings, later in 2014 in order to help further reinforce stakeholder confidence.
The next full scope IRRS mission for the UK is anticipated in 2019 to meet expectations set out in the European Union Nuclear Safety Directive.
Summary table of 2013 mission findings
Good practices
- GPFF1 - Systematic engagement with prospective licensees in the area of Organisational Capability.
- GPFF2 - The elaboration and application of ONR guidelines on a Graded Approach and the regulatory assessment principles.
- GPFF3 - The use of comparative emergency capability maps in the area of Emergency Planning and Response.
- GPFF4 - Access to a large range of Radiation Protection information on the HSE website for Employers and workers.
- GPFF5 - The establishment of a working group to exchange views between Regulators and potential operators on the GDF.
- GPFF6 - The use of a Radwaste Management case for waste streams.
Suggestions
- SF2 * - ONR should institute a programme for the reconstitution of an advisory committee on nuclear safety.
- SFF1 - ONR should ensure sufficient resources are available for effective regulatory oversight of the GDF project.
- SFF2 - ONR should consider developing a timetable for a fully integrated ONR.
- SFF3 - ONR should publish its revised Comms Strategy when it is completed.
- SFF4 - ONR should develop a process to administer refresher training for re-Warranted inspectors.
- SFF5 - ONR should continue to assess whether it has the necessary human resources to fulfil its statutory obligations.
- SFF6 - ONR should review its training programme to include the full range of duties regarding radioactive sources.
- SFF7 - ONR is encouraged to promote the establishment of a means of informing and consulting (parties and the public) about GDF facilities and activities and associated radiation risks and regulatory processes and decisions.
- SFF8 - A high-level timeline should be prepared to affirm Senior Management's determination to complete the preparation of the ONR Management System (MS)
- SFF9 - The ONR MS should to be updated to show that one of its purposes is to promote and support a strong safety culture.
- SFF10 - ONR should complete its first full review of the standard Licence Conditions.
- SFF11 - ONR should review its training programme to include the full range of duties regarding radioactive sources.
- SFF12 - ONR (in collaboration with other relevant regulatory authorities) should consider a coordinated approach to regulating RAW disposal facilities.
Recommendations
- RFF1 - The ONR Management System should be completed and fully implemented as quickly as possible.
- RFF2 - HSE and ONR should ensure that the allocation of responsibilities is documented when employees are engaged in work involving radiation sources that are not under their employer's control.
- RFF3 - HSE and ONR should ensure that the regulatory framework contains specific requirements addressing: eye lens dose limits; occupational exposure of persons under 16; maintenance of employee training records working with ionising radiation in the non-nuclear sector.
- RFF4 - HSE and ONR should define and ensure the implementation of arrangements concerning worker dose assessment in supervised areas.
- RFF5 - The UK government should ensure that the operational limits and conditions are based upon the latest GSR Part 3 international standard.
- RFF6 - The interaction between ONR and other Regulatory bodies should be agreed to and better documented for implementation of effective cooperation.
- RFF7 - The UK government should continue to implement policy and develop (as necessary) strategies specifying steps and responsibilities fro all UK Radwaste streams.
- RFF8 - Regulatory authorities should review their GRA (Guidance on Requirements for Authorisation) to consider a need for passive institutional control of the site of a near surface disposal facility.
- RFF9 - ONR should develop further assessment capabilities to be able to review the whole safety case and assessment of Radwaste management facilities.
- RFF10 - ONR should review the criteria in the use of the Enforcement Management Model to ensure regulatory requirement compliance for Radwaste management facilities.
- RFF11 - ONR should review the implementation of the present legal arrangements and ensure that all organisations involved in decommissioning activities and Radwaste management are held accountable for their responsibilities and that their activities are coordinated.
- RFF12 - The ONR should review its approach to authorising decommissioning plans.
- RFF13 - The ONR should review and update decommissioning guidance to ensure that safety requirements will be in accordance with the latest international safety requirements in this field.