Health and Safety Executive

Introduction

The Health and Safety Executive (HSE) regulates the nuclear industry through its Nuclear Directorate (ND), which includes the Nuclear Installations Inspectorate (NII). The ND’s primary goal is to ensure that those it regulates have no major nuclear accidents. It is responsible for the UK safety regulation of nuclear power stations, nuclear chemical plants, decommissioning, defence nuclear facilities, nuclear safety research and strategy and since April 2007 for civil nuclear operational security and safeguards matters.

Generic Design Assessment

The nuclear regulators – the Health and Safety Executive (HSE) and Environment Agency – have been carrying out a new process called 'Generic Design Assessment' (GDA), which looks at the safety, security and environmental implications of new reactor designs before an application is made to build that design at a particular site. In March 2008, the initial assessment of four nuclear power station designs was completed. No shortfalls in any of the four designs were found. A series of reports on each design were published.

The next stage was going to be a prioritisation process to select a maximum of three reactor designs to proceed to the next stage of the assessment, but Atomic Energy of Canada Ltd announced in April 2008 that it was pulling its ACR-1000 design out of the process to focus on its home market.

On 12 June 2008, HSE and the Environment Agency announced that they were starting the next, more detailed stage of the GDA process - referred to by HSE as Step 3 - for the remaining three designs.

Then in September 2008 General Electric's nuclear venture with Hitachi Ltd. asked the HSE to temporarily halt the process of assessing its so-called Economic Simplified Boiling Water Reactor so that it could focus its efforts on getting U.S. approval instead.

This left only the Toshiba-Westinghouse AP1000 design and the Areva-Siemens European Pressurised Water Reactor (EPR) in the assessment process. The GDA process is supposed to take around 3.5 years from start to finish, taking us up to around the spring of 2011. At the end of the process the regulators will make statements setting out their conclusions about the acceptability of the designs.

Staff Shortages

There are worries about the Government’s failure to recruit a sufficient number of nuclear inspectors both to cope with the NII’s existing workload, and to carry out the Generic Design Assessment. Assurances were given to Dai Davies MP by energy minister Malcolm Wicks that progress in recruiting staff was being made, but the Chancellor, Alistair Darling, told the TUC in September that, despite his reluctance to pay more to public-sector workers, he may well have to throw cash at nuclear inspectors because too few people are applying.

The HSE is battling to recruit up to 50 more nuclear inspectors. Its nuclear arm has some 160 inspectors but needs another 30 to bring it up to full complement to meet the workload on existing nuclear sites and a further 20 inspectors for the GDA. There are concerns that the shortage of inspectors could threaten the Government’s timetable for new reactors.

According to the National Metals Technology Centre, the timely completion of the facilitative actions, which the Government is carrying out to support new reactor building, is threatened by a shortage of skilled inspectors and engineers engaged in the GDA process (within the NII), such that delays in the completion of this process and the possible knock-on effects of delays in the planning and licensing processes would affect confidence throughout the supply chain.

The GDA is identified as a significant bottleneck in the UK’s nuclear new build process. Without the process coming to fruition, no building can take place.

The Environment Agency said in a letter to the Government, at the start of Step 3 of the GDA process, that its preliminary assessment of the submissions to the GDA from the so-called ‘Requesting Parties’ (RPs) identified significant areas where they did not contain the necessary information to allow a determination of whether the designs would use best available techniques (BAT) to meet high environmental standards. However, all the RPs have committed to provide the necessary information by the end of 2008.

Mike Weigthman, the Chief Inspector of Nuclear Installations told the Government, “that there is a significant resource shortfall against that planned to be in place at the start of Step 3”. He said the NII’s original estimate of the amount of time and cost that would be required to complete the Generic Design Assessment (GDA) process was subject to:-

• the reactor designs being complete; • the Requesting Parties providing adequate documentation in a timely manner; • good interactions with Requesting Parties; • taking benefit from overseas regulator assessments; and • sufficient resources being available in NII.

But there have been difficulties in all these areas. He said while the nuclear regulators remain determined to complete the GDA process as close to the original programme as possible, there is a risk of this not being achieved. “Therefore, at this stage we cannot commit to a firm completion date.”

Regulatory Review

In June 2008 when the then Business Secretary, John Hutton, announced the establishment of the Office for Nuclear Development, Tim Stone, the Business Secretary’s senior adviser also described the findings, so far, of a review of the NII he is carrying out. The review, which is expected to be completed in Autumn 2008, will make recommendations about what might be done to enhance NII's ability to deliver as the nuclear industry expands. This is the main way the Government hopes to keep the GDA process on time.