Case Studies

Nuclear regulation

by Mark Rowe

The July to September 2019 print issues of Professional Security magazine feature the new build power station Hinkley Point C (pictured), the first new nuclear power station in the UK for a generation. One of the themes is regulation, by the the Office for Nuclear Regulation.

ONR is the UK’s independent nuclear regulator of nuclear safety, security (including cyber security and information governance) and conventional health and safety at licensed nuclear sites in Britain; from Dounreay on the coast of northern Scotland to Devonport naval base and Dungeness in the south. This includes operating reactors, fuel cycle facilities, waste management and decommissioning sites, as well as licensed defence sites (except for security which remains within Ministry of Defence’s remit), plus the regulation of new nuclear facilities. Nuclear does not only mean energy generation; ONR looks into shipment of radioactive material for use in medical treatment, industrial radiography, and research.

Like other regulators, according to its 2018-19 annual report, it seeks to be ‘proportionate, targeted and balanced’, so that what merits the most ‘attention level’ gets attention. Most attention goes to Sellafield in west Cumbria – not, the report says, ‘a reflection of the site’s safety and security performance or its level of compliance’ with the relevant law, but because of the trickiness of the de-commissioning of an ageing, by nuclear industry standards, site; a ‘high-hazard legacy’, as the report puts it. On the security side, the ONR has ‘assessed the adequacy of security plans and carried out investigations and enforcement considered necessary to promote, achieve and sustain compliance with the law’. Like other regulators, such as the CAA covering airspace, the ONR has moved to what it calls an ‘outcome-focussed regulatory assessment framework – SyAPs’. That does mean the ONR does fewer planned civil nuclear security inspections – the total of 773 compliance inspections in 2018-19 was about a quarter fewer than the year before. In 2017 it decided to ‘pause’ the inspection of non-nuclear radioactive materials transport.

To leave the document for a moment, the aim is to avoid doing things for the sake of it that might not actually help safety or security, and which come at a cost – given that near all the ONR budget comes from the nuclear industry. As the annual report put it: “SyAPs has benefits for industry, allowing duty-holders to make informed decisions about how to protect their nuclear material, facilities and information, thereby increasing the responsibility and accountability of the duty-holder.” The document admits that the time for duty-holders to produce SyAPs-aligned security plans, and for the regulator to assess them, was longer than originally forecast; and the project delivery date was put back to December 2020.

Cyber, the ONR admits, is a priority, because of ‘ a rapidly changing threat environment’; like related utilities, formerly offline OT (operational technology) is being networked, which brings benefits, but also introduces the threat of hacking. And yet what the report termed ‘resource challenges common across this field in the UK resulted in recruitment targets not being met’.

The 100pc armed Civil Nuclear Constabulary (CNC) is overseen by the Civil Nuclear Police Authority. The CNC was due to have a ‘firearms training centre of excellence’ at Sellafield, delivered in August 2018; however, according to the CNPA annual report, due to construction delays this will now be fully delivered in 2019-20.

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