Nuclear safety, security and safeguards
interfaces in operation: An EDF perspective
Andy Spurr, Managing Director, EDF Energy Nuclear Generation
12 June 2013, Westleigh, Preston
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The regulatory framework in which we operate
• As an operator of civil nuclear power stations, EDF Energy Nuclear
Generation (NG) has a number of regulators including:
Office for Nuclear Regulation – safety, security, safeguards and
transport
Environment Agency/Scottish Environmental Protection Agency
Health and Safety Executive – Field Operations Directorate
• There is a significant quantity of legislation including:
Health and Safety at Work etc Act 1974
Nuclear Installations Act 1965 (as amended)
Ionising Radiations Regulations 1999
Environmental Permitting Regulations 2010 (Radioactive Substances
Act 1993, Pollution Prevention & Control Act 1999, Water Resources Act
1991)
Radiation Emergency Preparedness and Public Information Regs 2001
2
Nuclear Industries Security Regulations 2003
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Aspects of the Nuclear Site Licence and its regulation
• Under UK Law a Nuclear Site Licence must be held by a Corporate Body
(a Company). Accountability is through the Nuclear Generation Board.
• The Nuclear Site Licence requires the company to set down “adequate
arrangements”. The company should comply with its own Licence
arrangements and a failure to do so is a breach of the Licence. The
company should “Self Regulate” to demonstrate it is self checking and
correcting.
• The Nuclear Regulator (ONR) approves certain aspects of the
arrangements and checks compliance with the arrangements and checks
the adequacy of self regulation.
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NG accountability model
• Station Directors are the
CEO EDF Energy
key people
• The rest support them –
not the other way round
Generation Board
(Licensed entity)
3 CNOs, CTO,
S&T, HR, Fin
Station
Director
Station
Director
Station
Director
Station
Director
Station
Director
Station
Director
A g e n t s o f t h e L i c e n s e e
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Station
Director
Station
Director
Governance, performance improvement and challenge model
NG Performance
Review with CEO
Delivery Teams
Safety and oversight, Operations performance,
Business performance, People, Risk & internal
controls, Engineering governance, Fleet
programmes, Lifetime
Programme
owners
Fleet managers
External regulation
review
Internal regulation
Industry peer
Internal controls
NG Executive
Team
Managing Director accountability
reviews
Chief Nuclear Officers & Executive
Team members
Peer groups
Line managers
Station Directors and Heads of
Function
Performance improvement and challenge
Accountability and challenge
Direction
Information
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Layers of Oversight: Organisational Defence in Depth
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•
Management accountability –
the line performance is crucial
•
In-process oversight –
self-assessments and reviews
•
Functional oversight –
who does it well and can help
•
Independent Internal oversight –
critical appraisal from outside the line
•
External oversight - independent
In-process oversight
7
•
We have several layers of organisational defence in depth which begins
with our employees who are all trained nuclear professionals.
•
Personal ownership is critical to the appropriate governance of our
business as we all have a responsibility to ensure that our rules,
regulations and processes are adhered to and are as robust as they can
be.
•
All staff need to be trained to be suitably qualified and experienced
persons to enable them to undertake their required roles in support of
nuclear safety and operational excellence. We ensure this through
application of the systematic approach to training
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Line management accountability
•Normal routes for individuals and line managers to raise resource, workload,
priority and resource issues include:
- accountability and succession management meetings
- Appraisals, team briefs
- task observations, peer to peer coaching
- Condition reports.
•If necessary, there are also escalation routes available to individuals and line
managers, these include:
- Human Resources
- Trade Union/Safety and Regulation Division representatives
- Safecall – independent, confidential reporting line.
•In addition, the nuclear safety culture survey (2 yearly) and employee
engagement surveys (annually) provide opportunities for individuals and line
managers to raise issues related to organisational effectiveness.
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Functional oversight
•
Fleet managers and process owners monitor and review progress in their
areas. They also report progress and raise resource, backlogs, priorities and
work issues to their respective Delivery Teams.
•
The Delivery Teams review monthly progress updates from the process
owners and provide challenge on annual deep dives undertaken by fleet
managers
•
The Delivery Teams also review and provide challenge on the annual selfassessments undertaken by process owners as part of our Internal Controls
process.
•
The NG Executive Team, in addition to the Delivery Team review meetings
and the accountability scorecard meetings, also reviews reports from across
the business on resources, work, risks, priorities, succession, etc.
•
Relevant reports are then presented to the Licensee Board and Group Board
who provide oversight and challenge.
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Independent internal oversight
•
•
•
•
•
10
In addition to the accountability and in-process arrangements described,
independent oversight is also provided:
Safety and Regulation Division via an independent line undertakes
surveillances and inspections across a wide variety of areas, including on
management resilience.
The Safety and Technical Director has a by-pass route if necessary
Quality Department undertakes audits of all process areas
EDF Energy internal audit function also provide independent internal
oversight and report findings to the line, the executive, and the licensee
board on a regular basis, with escalation routes available if necessary.
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Independent external oversight
•
Regulators – through formal inspections and interactions – real process, real
impact (e.g. start-up after outages)
•
The Nuclear Safety Committee comprises Station Directors, senior managers
from the central support functions and includes a number of respected external
independent members.
The Training Standards and Accreditation Board includes respected external
independence and oversight to challenge NG’s training and development
arrangements
The EDF Group Inspector General for Nuclear Safety and Radiation Protection
undertakes an independent oversight role of NG performance on behalf of EDF
SA.
Third party independent audit of efficacy of our arrangements and their
implementation is undertaken by Lloyds Register Quality Assurance (LRQA)
Industry peer reviews are undertaken through the World Association
•
•
•
•
of Nuclear Operators (WANO) and through frequent benchmarking.
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Safety performance results
Nuclear Reportable Events
Nuclear Reportable Events
60
4
3
40
3
40
2
23
20
1
6
10
5
9
7
0
0
3
0
0
Jan2013
Feb2013
Mar2013
Apr2013
May2013
Jun2013
Jul2013
Aug2013
Sep2013
Oct2013
Nov2013
Dec2013
YTD
2005
2006
2007
2008
2009
2010
2011
2012
2013
(31.05.13)
Plan
Injuries Staff & Contractors
Lost Time Injury (staff +Contractors)
30
27
60
25
50
20
40
15
30
26
21
20
10
14
16
8
7
10
5
9
5
9
4
0
0
Jan2013
Feb2013
Mar2013
Apr2013
May2013
Jun2013
RWI-YTD
Jul2013
Aug2013
MTI-YTD
Sep2013
LTI - YTD
Oct2013
Nov2013
Dec2013
2005
YTD
2006
2007
2008
2009
2010
2011
2013
(31.05.13)
2
2
Plan
Environmental Events Tier 1
Environment al Event s (Tier 1)
4
40
3
30
21
2
2
20
18
14
16
11
7
10
1
1
0
0
Jan2013
Feb2013
Mar2013
Apr2013
M
ay-
Jun2013
Jul2013
Events
12
2012
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Aug2013
Sep2013
Plan
AS/LOB Rev 01
Oct2013
Nov2013
Dec2013
YTD
2005
2006
2007
2008
2009
2010
2011
2012 2013
(31.05.13)
Operational performance results
UCLF
Unplanned Capability Loss Factor (UCLF)
40.0
29.6
30.0
23.5
(% )
%
33.5
20%
18%
16%
14%
12%
10%
8%
6%
4%
2%
0%
18.1
20.0
15.9
14.8
12.8
11.4
10.0
Jan2013
Feb2013
Mar2013
Apr2013
May2013
Jun2013
Jul2013
Aug2013
Sep2013
Oct2013
Nov2013
Dec2013
9.3
0.0
2005
YTD
2006
2007
UCF
2008
2009
2010
2011
2012
2013
(April)
Unit Capability Factor (UCF)
100
100%
80
95%
73
67
90%
67
60
78
82
63
53
(%)
%
85%
73
72
80%
75%
40
70%
65%
20
60%
Jan2013
Feb2013
Mar2013
Apr2013
May2013
Jun2013
Jul2013
Aug2013
Sep2013
Oct2013
Nov2013
Dec2013
0
2005
YTD
2006
Automatic Trips
2007
2008
2009
2010
2011
2012
2013
(April)
Unplanned Automatic Trips
14
7
6
6
12
12
12
11
11
10
5
10
4
8
10
8
6
6
3
2
2
4
1
2
2
0
0
Jan2013
Feb2013
Mar2013
Apr2013
M
ay-
Jun2013
Jul2013
YTD
Aug2013
Plan
Sep2013
Oct2013
Nov2013
Dec2013
YTD
2005
2006
2007
2008
2009
2010
2011
2012
2013
(31.5.13)
Correlation between safety and commercial performance
Position in fleet
Good
Station rankings
8
7
6
5
4
3
2
1
0
A
B
C
D
Days since last event
UCLF = Unplanned capability loss factor
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E
F
UCLF
G
Trend
H
Common goal for regulators and operators
Nuclear safety is our overriding priority
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Opportunities
16
•
Regulators to develop an ‘onion model’ to improve integration and
consistency of approach
•
Extend the use of the Regulatory Nuclear Interface Protocol to all
regulators who interact with the operators – measure the effectiveness
and learn lessons
•
Hold relationship workshops with other regulators/operators and between
different regulators/key Government departments – share and widen
perspectives.
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Challenges
•
Is the current regulatory framework pushing operators away from
maximising safety through minimising risk? We need a shared
understanding of ‘where risk comes from’.
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