ML20205F091
| ML20205F091 | |
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| Issue date: | 02/02/1999 |
| From: | NRC |
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'ev Comparison of U.S. Reactor Regulation Programs with that of France, Japan and the United Kingdom 0
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Table of Content Pace l
- 1. '
Study Conclu sions................................................... 1 II.
Backg rou n d........................................................ 1 111.
N RC Regulatory Framework............................................ 2 IV.
Comparisons of the U.S. Regulatory Framework with those of France, Japan and United Kingdom.....................
..................... 2 V.
Individual Program Comparisons........................................ 9 VI.
R e sou rce Com parison s.............................................
25 Vll.
Tim D. Martin & Associates Study...................................... 26 l
Attachments:
- 1. Tim D. Martin & Associates Chart
- 2., Memo from Jackson to Trav(rs dated 11/24/98
- 3. U.S. NRC Program Description
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- 4. Memos to France, Japan, and United Kingdom dated 12/4/98 l
- 5. ' Response from France
- 6. Response from Japan
- 7. Response from United Kingdom
O t
1.
Study Conclusions Aggregate comparisons of the resources for reactor regulatory programs of the U.S., France, Japan, and the UK, as done by Tim D. Martin & Associates (TDM) are not meaningful because they do not compare like programs. Many of the specific regulatory programs conducted by the U.S. are not conducted in a substantive or formal way by some of the other countries (i.e.,
Enforcement, mvestigation, License Renewal, Adjudication, Legal Advice. Operational Experience Evaluation). Other programs are conducted in a substantially different way because of different infrastructure differences or regulatory approaches (i.e., Licensing, inspection, Performance Assessment, Research, incident Response, High Level Waste Management).
Infrastructure differences are generally outside NRC control. These include the degree of standardization of reactor designs, private vs. public sector licensees, the number of licensees and legal structures. These differences alone could easily account for the differences in resource levels allocated to various programs.
The regulatory approach used by the NRC for a given program also affects resource expenditures and is generally more within our control but is shaped largely by expectations from the U.S. public, the Congress, past U.S. operational exparience and Commission policy. This would include such considerations as the degree of independent verification required for licensee activities and the degree of public participation in regulatory activities. The scope and nature of NRC regulations and programs has also been driven by past operational experiences, such as the TMl accident. Nonetheless, the NRC currently is reassessing its reactor reguiatcry approach and processes in all major programs -- Inspection, Licensing, Performance Assessment, Enforcement, and Regulations.
Given the above, comparison of U.S. reactor regulatory programs in the aggregate or by program with that of France, Japan, and UK does not appear meaningful.
Notwithstanding the above, the Tim D. Martin & Associates analysis omitted resources expended by other countries for functions performed by the NRC. Typically, these functions
. (e.g., research and technical assistance) are provided by other than the primary regulatory body. This made the NRC program appear disproportionately large.
II.
Background
in the context of the July 30,1998 hearing, before the Senate Subcommittee on Clean Air, Wetlands, Private Property and Nuclear Safety, the NRC resources devoted to nuclear safety oversight were compared with those of other countries. The basis for the comparisons was data collected by Tim D. Martin & Associates. Attachment 1 is a chart prepared by Tim D.
Martin & Associates whici, vas used in discussions with the Senate staff. The source of the information for other countries appears to have been a 1997 OECD Nuclear Energy Agency report, Status Report on Reaulatory Insoection Philosophy. Inspection Oraanization and insoection Practices. The chart indicates that "...NRC is larger than other nuclear regulators--
more analysis should be performed to understand why."
On November 24,1998, Chairman Jackson directed the Executive Director for Operations (EDO) to conduct additional study in this area to enab e the Commission to provide the Congress with a more informed response (Attachment 2). The study was to include:
1
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i A description of the program elements of the NRC regulatory framework.
A comparison of this lramework to the nuclear regulatory frameworks of France, Japan j
l and the UK.
An analysis of the overall usefulness of such studies, including the vulnerabilities present in making comparisons of organizations with differing infrastructures, legal bases, oversight responsibilities, and industry characteristics.
A comparison of the NRC study with the Tim D. Martin & Associates report.
Ill.
NRC Reaulatory Framework i
The first step was to define the NRC regulatory programs in a manner that would facilitate comparison to other countries with differing structures. The program descriptions and resource
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information (Attachment 3) were comprised primarily of FY 1999 data from the Budget j
Estimates for Fiscal Year 2000 for the Nuclear Reactor Safety Arena (Green Book, NUREG-1100, Volume 15). On December 4,1998, the EDO sent letters to counterparts in France, Japan and the UK (Attachment 4) requesting information that would be the bases for the comparative analysis. The letters included a description of the U.S. NRC regulatory structure and programs with associated FTE information.
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I The staff then prepared comparisons of the NRC programs with the other three countries based on existing available information and specific responses from the counterparts (Attachments 5, 6,7). Subsequently, the counterparts reviewed a draft of this report and provided clarifications which have been incorporated. The results of that staff's analysis follow.
IV.
Comparisons of the U.S. Regulatory Framework with those of France. Japan and United Kinado_m U.S. NRC:
A comparison of the resource and prcgam differences between the NRC and the nuclear safety regulators in France, UK, and Japan must consider a number of f actors. One of these is fundamenta! differences in the culture / philosophy of nuclear power regulation. For example, 1
l From the inception of the commercial nuclear power program in the United States, Congress and the public have called for a more comprehensive regulatory safety regime than those that edst in other countries. As a result, the NRC program has evolved to a more detailed, prescriptive regulatory approach.
The United Str.tes has a long standing culture of public paiticipation in govemment decisionmaking that is not typical in other countries. Thus, the NRC, in contrast to its foreign counterparts, has regulatory processes which provide substantial opportunity for public participation. The NRC devotes significant resources to matters such as licensing l
adjudications, solicitation and evaluation of public comments on proposed regulatory l
actions, maintaining publicly available documents, and conducting business in a public forum.
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e in some of these countries, the nuclear safety regulator traditionally has had a more cooperative relationship with their regulated communities. This in turn has resulted in less oversight and the need for fewer and far less prescriptive regulatory requirements.
The NRC regulates many more reactor designs than its counterparts of these countries.
Standardized plants, such as those in France, can be regulated morn efficiently.
In addition, the NRC is subject to numerous government-wide statutory obligations unrelated to nuclear regulation that require substantial resources to implement. These statutes include (but are not limited to) the:
Administrative Procedure Act Freedom of Information Act Paperwork Reduction Act Government in the Sunshine Act Federal Advisory Committee Act France:
The description below is of the French regulatory system now extant; however, the French Government is currently considering a full-scale reorganization, including creating a five-
- n. ember commission to lead its regulatory activities.
Leaislation Nuclear installations are basically regulated by the Decree of December 11,1963, amended by three more recent decrees. In particular, its Article 11 defines the role of inspectors. The autho:ities primarily involved in licensing procedures are the Minister for Industry and the Minister for the Environment (with the consent of the Minister of Health requested). The regulatory organizations are Directorate for the Safety of Nuclear Installations (DSIN), Nuclear Steam Supply System Control Bureau (BCCN), and the nuclear divisions of Regional Directorate for Industry, Research and the Environment (DRlRE). DSIN reports to the Ministry of Industry and the Ministry of Environment. There are also two technical support organizations: the Institute for Protection and Nuclear Safety (IPSN) and the Office for Protection Against lonizing Radiatirn (OPRI), which belongs to the Ministry of Health. Also, the Atomic Energy Administration (CEA, does nuclear safety research anc' development work.
DSIN can sign a number of regulatory documents on behalf of the Ministers, except reactor individual licenses which are granted by decrees or arretes: those can only be signed by the Prime Minister or Ministers respectively.
Oraanization DSIN, considered the regulatory counterpart to NRC, has about 210 professional staff, including 70 regionalinspectors, and an annual budget of approximately $100 million. As in the U.S., the majority of DSIN'c funding is recovered from regulatory fees. 210 professional Staff are for DSIN, BCCN and nuc! car divisions of DRIREs; amon" them,125 are DSIN and BCCN inspectors.
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0 DSIN's responsibilities are:
drafting and monitoring the app!ication of the general technical regulations; implementing licensing procedures; organizing and implementing surveillance et the plants by inspectors; j
emergency response in case of an incident or accident; providing the general public and the media with information on nuclear safety
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problems; contributing to the activities of international organizations and promoting bilateral relations with the regulatory bodies of other countries.
DSIN also follows nuclear safety research and development work undertaken by organizations j
under the Ministry of Industry, particularly the Commissariat a l'Energie Atomique (CEA) and the utility Electricite de France (EdF). DSIN's work is also directly supplemented by IPSN, the Regional Directorates for Industry, Research and the Environment (DRIRE); and the BCCN. In fact, BCCN, nuclear divisions of DRlREs and !PSN carry our their work upon DSIN's request.
Only 8 DRIREs (among 22) have a nuclear division; within these DRIREs, only the nuclear division works for DSIN. The rest are responsible for tasks which have nothing to do with nuclear safety.
At the locallevel, the DRIREs implement their tasks of nuclear plant surveillance, which include:
inspection; approval and monitoring of power plants outage programmes; after an annual outage, DSIN would authorize the plant start up, based on DRIRE advice; processing of waiver requests (with regards to the general operating rules); only non generic waivers are processed by DRIREs, generic waivers are processed by DSIN; the waiver is always granted by DSIN; processing of declared incidents; incidents having generic aspects are subsequently processed by DSIN; l
supervision of pressure vessel regulation (and associated processing of waiver j
requests);
J supervision of regulations for registered installations (on environmental grounds);
labor regulation supervision; relations with local authorities (prefects, mayors, etc.).
Both the DSIN and DRIREs get technical support from IPSN. There are no resident inspectors, and only limited capability of regionalinspection offices. Ongoing inspection is less than in the l
U.S., but every ten years in-depth safety evaluations are performed for each facility, which are not required in the U.S. DSIN/DRlRE do not regulate radiation safety or safeguards.
IPSN, which is part of the Atomic Energy Administration (CEA), and whose Chairman is the Director of DSIN, has a budget of $260 million and an independent staff of 1270 among which 350 FTE carry out safety analyses, and provides technical safety assessment advice to DSIN and the DRIREs. Most of the remaining 920 staff at IPSN are involved in carrying out reactor safety research to develop and maintain the nuclear infrastructure and to provide consultation to the regulator. IPSN research does not only cover reactor safety, but also radiation safety or criticality safety. Moreover, among the 920 staff, a number provide technical assessment advice to DSIN for transport safety issues as well as to the regulators for safeguards, physical protection and for defense facilities respectively.
Radiation protection is the responsibility of the Office for the Protection Against lonizing Radiation (OPRI), which is under the supervision cf the Labor and Health Ministry, has a staff of 4
I tr 180 and an annual budget of $13.4 million. The regulator for radiation protection is the Health ministry; OPRI provides it with technical advice.
MLhat is reaulated f-In France there is one national utility (Electricite de France), which operates the 58 licensed commercial power reactors. DSIN also licenses the Commissariat a l'Energie Atomique (which i
operates the Phenix fast breeder reactor) and the vendors Cogema, Framatome and Andra. In fact, Cogema and Andra are operators of fuel cycle (enrichment, fabrication, reprocessing) and
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waste disposal facilities respectively. All are "public or para-public entities" where tha government is represented on their boards and oversight is provided by the same ministry to which DSIN reports. I act, DSIN equally reports to two Ministries (Environment and Industry) and in cases where the m 'isters disagree, the Prime Minister makes the final decision. In addition to the fuel cycle activities which are licensed (e.g., enrichment, fuel fabricatior.,
reprocessing, and vitrification plants, as well as low-level waste storage facilities), there are 58 licensed commercial power reactors of only three standard designs. Currently one site has been identified for use as a possible high-level waste (HLW) underground research laboratory and a second site is being sought.
l Differences The major differences are (a) multiple organizations in France contribute to the regulatory effort; (b) there are fewer reactors (58 in France versus 103 in the U.S.); (c) in France there is only one electric utility / licensee; only one nuclear steam supply system designer; and only one architect-engineer; (d) there are three basic designs; (e) there are no resident inspectors; and (f) the primary regulator does not regulate radiation safety or safeguards. Furthermore, the research program is broader than the research being conducted by NRC. In particular, IPSN supports expensive test programs whicn are providing valuable information to address reactor safety issues.
Japan:
Leaislation Japan's Atomic Energy Basic Law (No. 186,1955) established the framework for its nuclear activities. Subsequent legislation also added to the organizations that make up its parallel, double check regulatory system that includes a public hearing process.
In addition, regulatory bodies license on the basis of.the Law of Nuclear Source Materials, Nuclear Fuel Materials and Reactors (RNNR Law and the Electric Utilities Industry Law). The Electric Utilities Industry Law stipulates the penalties for the utilities, if a violation against the law is committed by a licensee, they are fined. In the RNNR Law, there are also penalties of which fuel manufacturers or research institutes shall be fined if they treat nuclear fuel without permission or disperse fuel materials outside.
Orcanization Nuclear regulatory functions are performed by at least five agencies in Japan, with approximately 450 professional full-time equivalent staff (MITI:200, STA:40, NUPEC:70;
.JAPEIC:120, NUSTEC:20) with a cumulative budget of $396 million. The expenses of personnel, traveling, research and others in the Ministry of International Trade and Industry 5
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(MITI) and the Science and Technology Agency (STA) are paid for by national revenues. There is a small amount of income generated from license and inspection fees.
l Preparing for the next century, the Prime Minister called for 6 retorm programs including reorganization of Japan's government agencies in 1997. That reorganization, including that of l
the nuclear safety regulatory bodies, is ongoing today.
l (A) MITIis responsible for regulation, licensing and inspection of operating commercial nuclear power plants. MITI's Agency of National Resources and Energy (ANRE) carries out the Ministry's mandate, including safety examination, safety policy planning, administration and regulation of commercial nuclear power plants with a professional staff of 200; and advisory committee members of 107. MITI grants all reactor licenses (construction and operation).
They are supported by the Nuclear Power Engineering Corporation (NUPEC) which, with 70 professional staff, carries out safety analysis and the Japan Power Engineering and Inspection Corporation (JAPEIC), with 120 professional staff, which performs pre-service inspections of nuclear power plants to assure high reliability and safety (including welding inspection). MITI has regional offices and a resident senior specialist for NPP systems.
(B) STA, an aGministrative body attached to the Prime Minister's office, is responsible for regulating research reactors, reactors under development, materials safety, all fuel cycle facilities including facilities dealing with radioisotopes (except for those used in medical applications), and radioactive waste disposal. STA's Nuclear Safety Bureau (NSB), is responsible for the regulation of research and power reacters under development, overall radiation monitoring, emergency measures, safety reviews of reactors and nuclear fuel f scilities, radioisotopes and radiation-generating devices; safeguards and nuclear materials.
The NSB is supported by the Nuclear Safety Technology Center (NUSTEC) with 20 professional staff. The Nuclear Safety Commission (NSC) has five Commissioners, and provides advice on policy matters concerning regulations for ensuring safety of nuclear energy (fuel cycle and advanced reactors). As part of the double check system of safety regulation, NSC has the authority to reexamine the nuclear-related safety administration of MITI and STA.
The NSC is not a decision-making body.
(C) The Ministry of Transportation regulates the transportation of nuclear fuel and radioactive waste, and has jurisdiction over the regulation and inspe,ction of reactors used for naval propulsion.
What is reculated The Japanese nuclear regulators license ten utilities with 53 licensed commercial nuclear power facilities (with one reactor under construction and four planned). The Japanese govemment also regulates a complete fucl cycle, including 2 enrichment plants,6 fuel fabrication f acilities,2 reprocessing plants, and 4 low-level waste facilities. Japan also has an active fast breeder reactor program.
Differences in Japan there is a double check regulatory system. Their regulatory system is less prescriptive than that of the United States, with government regulatory institutions working closely with licensees to reso!ve problems. In the aftermath of two nuclear incidents in 1995 and 1997 the i
I government acknowledged the need for greater transparency and better public communication, and has been workmg to implement these policies. Furthermore, research activities carried out 6
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by JAERI and NUPEC are broader than the NRC research program. Both organizations support expensive test programs which are instrumental in providing information to resolve complex technical issues. Finally, the Japanese regulatory program has no resident inspectors in the way that the NRC has.
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United Kingdom:
Leaislation The main legislation governing the safety, and enforcement of safety, of nuclear installations is the Nuclear installations Act as amended, together with the Health and Safety at Work, etc., Act i
of 1974 and the Ionizing Radiations Regulations of 1985. Under the Nuclear Installations Act J
l no site may be used for the purpose of constructing, commissioning, or operating any nuclear j
installation unless a license has been granted by the Health and Safety Executive's (HSE)
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Nuclear Installations Inspectorate (Nil).
Each nuclear site license has conditions attached which have the force of law and which pla;e either absolute requirements or require the making of adequate arrangements and compliance j
with those arrangements. A fundamental feature of one condition is the requirement for the licensee to demonstrate the safety of the proposed operation in a document known as the
" safety case," prior to the start of that operation. Breach of any law, regulation or license condition is a criminal offense and the offender may be prosecuted in the UK courts of law.
Inspectors appointed by the HSE also have the power to stop unsafe acts or to require improvements to be made within a given time. These powers are carefully set out so as to not take away the absolute responsibility of the licensee for safety on the licensed site. The Nil does not license individual operators at the nuclear installation. However, there is a specific license condition which requires persons who control or supervise operations which may affect safety to be duly authorized. Actions of Nil are subject to internal review processes and in extreme cases can be subject to review by the UK courts of law (Judicial Review of process only). In the UK there is no appeal against regulatory decisions.
i The Government sets the general policy for siting of nuclear installations, managing radioactive l
waste and decommissioning but Nil develops the detailed policy in relation to nuclear licensed sites. Nil implements these detailed policies through the granting of site licenses and its i
powers under the site license conditions. HSE sets policy in respect of work radiation exposure which is enforced by Nll on licensed nuclear installations and by other parts of HSE for other industrial and medical uses of radioactive material. Nil also enforces other safety and health regulations in relation to non-nuclear hazards at licensed sites.
Oraanization Under the Nuclear Installations Act, HSE recovers most of the running costs of Nil, together with the costs of any research thought necessary from licensees.
(A) The Health and Safety Executive (HSE) is a distinct statutory body of three people which advises and assists the Health and Safety Commission (HSC), and has day to day responsibility for enforcing health and safety legislation. The mandate of the HSE and HSC together is to protect the health, safety and welfare of employees, and to safeguard others, principally the public, who may be exposed to risks from industrial activity. The Executive delegates responsibility for regulation of nuclear safety to its Nuclear Installations Inspe6% e t
(Nil).
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(B) Nll is responsible for granting nuclear site licences and enforcing compliance with the safety conditions attached to these, together with other health and safety legislation. A single licence will cover all activities on a nuclear site from construction through operation into decommissioning. The transitions between these stages are controlled by regulatory powers, such as Directions, Consents and Agreements. Tue total number of staff currently employed by Nil in regulating the UK's nuclear facilities is 237 but this is under review and is like to increase.
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This comprises 144 inspectors,2 scientists, and 91 administrative stslf. The ' inspector'
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category includes staff employed on site inspection, project and assessment activities. Nll also places contracts with external technical organizations for analyses and research. Technical work directly supporting regulatory issues is funded through a Nuclear Support Studies budget, which is about 2.5 million pounds (USD $4 million) per year. This translates into about 36 staff years of effort. Various contractors are used, including AEA Technology, National Nuclear Corporation, and others. A research effort of approximately 100-140 FTE is jointly funded by HSE and the Industry Management Committee and cannot be directly compared to U.S.
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research.
1 The licensees are responsible for the safety of their operations, and must develop their own nuclear safety standards. They must then demonstrate to Nil that these reduce the risk to staff j
and members of the public to as low a level as reasonably practicable, as required by the Health and Safety at Work, etc., Act 1974. Nil assesses these submissions against its published Safety Assessment Principles, which represent its own standards.
(C) The Health and Safety Commission (HSC) is a statutory body responsible for advising the Government on most industrial health and safety matters, including nuclear safety. It consists of a Chairman and nina members and is supported by a small staff of five.
What is reaulated Nil regulates nuclear power stations, nuclear fuel cycle facilities, radioactive waste management plants, nuclear research facilities including research reactors, the refueling of the UK's nuclear subrnarines and the atomic weapons sites at Aldermaston and Burghfield.
There are 35 operating power reactors in the UK including one civilian PWR at Sizewell,14 Advanced Gas Cooled Reactors (AGRs) of varicus designs and 20 gas cooled Magnox Reactors. The Magnox reactors include steel and prestressed concrete pressure vessel designs. The PWR and AGRs are privately owned by British Energy. The 20 Magnox reactors are owned by BNFL which is a state owned corporation. The fuel cycle plants at Sellafield, Springfields and Capenhurst are also owned by BNFL. Sellafield not only reprocesses fuel for the Magnox and AGR programmers, but also reprocesses fuel from Japan and other countries.
Several facilities are undergoing decommissioning including the prototype fast breeder reactors at Downreay, a Steam Generating Heavy Water Reactor, the Windscale Advanced Gas Cooled 1
Reactor, several material best reactois, two defense related plutonium producing piles and six commercial Msgnox reactors.
Differences in the UK the regulatory body oversees fewer reactor plants. Approximately half of the licensed sites are privately owned and half are public entities although the majority of licensees are now in the private sector. Regulatory responsibilities are not as broad or encompassing as in the U.S. for a single organization. Technical analyses and research are funded via licensing fees and a levy respectively. Finally, the responsible regulatory body, the Nil, is not required to hold a hearing before issuing a license. The Director of the Nuclear Safety Directorate has indicated that they will be increasing the staff in the Directorate from 237 to 290. Finally, the UK does not have resident inspectors on-site in the way the NRC has.
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V.
Individual Program Comparisons Comparison of U.S. Reactor Regulation Programs with those of France. Japan, and the UK Program: Reacter Licensing Country Oraanization Proaram Differences France
- 1. Directorate for
- 1. In France there are laws or regulations governing nuclear power the Safety of and safe operation. These regulations, prepared by DSIN, are Nuclear
" umbrella" or overall regulations describing objectives or goals to Installations be met. The process in France is less formal whereby DSIN writes (DSIN) letters to the one licensee (EdF) requesting evidence that a j
particular part of the regulction is being met.
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The DSlN regulatory approach is much less prescriptive than that of the NRC; it does not systematically issue regulatory guides, NUREGs and the numerous other publications issued by NRC'.
There are no equivalent processes for 2.206 or 10 CFR 50.59.
The licensee has to demonstrate that the provisions he takes meet the safety objectives set forth in the general regulations.
DSIN does not have responsibility for regulating financial assurance. Operators are not licensed by DSIN; this is done by the licensee with DSIN maintaining cognizance.
DSIN does not regulate radiation safety (or protection). This is the responsibility of the Radiation Protection Bureau of the Ministry of Health with the technical support of OPRI. OPRI has 200 FTE devoted to reactors, other nuclear facilities and medical applications.
DSIN is not involved in Safeguards (Material Accounting and Physical Protection). This is the responsibility of HFD (Defense Senior Civil Servant). DSIN is in charge of processing the applications for discharge permits.
- 2. Institute for
- 2. Detailed technical support including all safety assessmeni.s Protection and required by DSIN.
Nuclear Safety (IPSN)
'The process that NRC follows, before issuing a Regulatory Guide or Rule, involving consultation, review and comment is much longer and move complicated (with 45 licensees and legal aspects to be addressed) than the letters sent by DSIN to its single licensee.
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l' Program: Reactor Licensing
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Proaram Differences Country Oraanization
- 1. Regulations are enforced by several administrative bodies. MITI Japan
- 1. Ministry of Int'l Trade &
has the overall responsibility and ANRE implements these Industry (MITI) regulations. Much of the work is guided by the deliberations of Agency of advisory committees. For example, there are advisory committees Natural on Basic Design, Detailed Designed Operations Management and Resources &
Comprehensive Preventive Maintenance. Advises on policies Energy (ANRE, relating to the safety of nuclear installations. Operators are not MITI) licensed, however, persons responsible for operation are required to have defined qualifications.
- 2. Nuclear
- 1. NSC consists of 5 members with meetings of subcommittees (250 Safety cart time members) held as necessary.
Commission (NSC)
- 3. STA is responsible for safety regulations for R&D and research
- 3. Science &
reactors. Implementation of the regulations overseen by the Technology Nuclear Safety bureau of the STA.
Agency (STA)
- 4. Nuclear Power
- 4. NUPEC performs safety analysis in support of the licensca Eng. Corp authority (MITl/ANRE) (70 FTE).
(NUPEC)
UK
- 1. Nuclear
- 1. Methods of operation are much less prescriptive than those of Installations NRC. UK licensees, when applying for a new site license or Inspectorate consent to build new plant, submit a report which is called the (Nil)
" Safety Case" which includes technical justification and license compliance demonstration. This is reviewed by Nil and a license or Consent granted when Nil is satisfied. In certain circumstances it may be necessary to hold a public inquiry before the license or Consent is issued, as was the case with Sizewell B, UK's only PWR. (40 FTE)
Operators are not licensed.
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Program: License Renewal I
Country Organization Program Differences France
- 1. Directorate for
- 1. In France a license is granted with no duration limit and thus there the Safety of is no license renewal process. Every 10 years a safety review is Nuclear performed (but this is not connected to renewal of a license).
Installations l
(DSIN)
There is a special regulation for the Pressure Vessel. BCCN performs a pressure test of the primary circuit before it goes into service, after 1 year of operation and then every ten years (during
- BCCN (Nuclear Steam Supply long outages).
System Control Bureau)
Japan
- 1. MITl/ANRE
- 1. There is no license renewal system in Japan. Once the license is issued there is no time limit on the license.
UK
- 1. Nuclear
- 1. Periodic safety reviews (PSRs) are required every 10 years. Once Installations the license is issued there is no license renewal process (7 FTE Inspectorate devoted to PSRs).
(Nil)
Program: Reactor inspection Country Organization Program Differences France
- 1. Directorate for
- 1. There are no resident inspectors. Inspections consist of one day the Safety of visit to a plant by 2 or 3 persons; 2 from DSIN/DRIRE and 1 from Nuclear IPSN. These inspections generally focus on conformity with the Installations regulations / requirements.
(DSIN)
When an inspector finds what he thinks is a safety issue the Head DRIRE of DRIRE sends a letter requesting corrective actions to the plant (Regional manager. If a generic issue is identified, DSIN would require Directorate for generic corrective actions to the licensee.
- Industry, Research and the Environment) 2 DRIREs are not part of DSIN but their nuclear divisions work for DSIN.
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l Inspection activities in France are indeed as described above. However, note "l
that the number given~in the table at part VI (resource comparisons) does not refer to that description; it relates to broader activities which are similar to those of US inspectors. Part of these activities, especially assessment, are performed by IPSN, about 45 FTE.
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Program: Reactor inspection i
Country Organization Program Differences J: pan
- 1. Ministry of
- 1. Performs pre-service inspection, welding inspection and periodic International (annual) inspection. These inspections generally focus on Trade and conformity with regulations. There are no resident inspectors.' The industry (MITI) number of inspectors and inspection days is very much less than carried out by the NRC.
- 2. Japan Power
- 2. As an appointed inspection institution, JAPEIC performs
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Engineering &
inspections of reactor welds. MITI audits the JAPEIC inspection inspection Corp.
results.
(JAPEIC) l
- 3. Science and Technology
- 3. Performs pre-service inspection, welding inspection and periodic Agency (STA)
(annual) inspection. These inspections generally focus on conformity with regulations. There are no resident inspectors.
- 4. Nuclear Safety Technology
- 4. As an appointed inspection institution, NUSTEC performs welding Center inspections of reactor welds. STA audits the NUSTEC inspection (NUSTEC) results.
UK
- 1. Nuclear
- 1. There are no resident inspectors but each licensed site has a Installations Nominated Site Inspector who spends at least 30% of their time on inspectorate site. The number of inspection days is very much less than carried (Nil) out by the NRC. Each inspection is generally of shorter duration than in the U.S. (31 FTE)
Program: Reactor Performance Assessment i
Country Organization Program Differences 1
France No formal program. Performance Assessment is part of the monitoring activity and cannot be distinguished from licensing l
activities.
l Japan No formal program. Performance Assessment is part of the inspection activities.
UK No formal program. Performance Assessment is part of the inspection activities.
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t Program: Reactor incident Response Country Organization Program Differences I
France
- 1. Directorate for
- 1. Prefect (local representative of the government) and plant the Safety of management are responsible for operations in an emergency Nuclear situation. DSIN serves an advisory role. Early notification of highly l
Installations significant incidents by telephone to DSIN triggers automatic l
(DSIN) notification of staff and inspectors. Emergency center at the Ministry of Industry headed by director of DSIN. Other incidents l
notified by licensee via Telex and an incident report within two 4
months. Significant incidents may result in inspection of plant.
Seven exercises per year are carried out to test the emergency management system. (One reactor site therefore has an emergency exercise every three years.)
- 2. Technical safety director of IPSN heads technical team to support
- 2. Institute for and develop DSIN advice. DSIN and IPSN personnel do not go to Protection and the site.
Nuclear Safety (IPSN)
- 3. Regional
- 3. Immediate response to reactor site and to Prefecture. Potassium Directorates for iodide tablets pre-positioned locally.
- Industry, Research and the Environment (DRIREs)'
Japan
- 1. Ministry of Int'l
- 1. Prompt notification of MITI and local governments by licensee.
Trade &
MITI has senior specialist at each site who report incidents. MITI Industry (MITI) maintains a NPP Operation Monitoring System similar to the NRC Operations Center.
- 2. Advisory
- 2. Although mostly longer term follow up of events, these committees committees on could also be involved during a ongoing event.
Nuclear Power Generation
- 3. Nuclear Safety
- 3. Several subcommittees of the Council on Reactor Safety Commission Examination of NSC focus on incident response measures.
(NSC)
- 4. Nuclear Power
- 4. Provide technical review in support of incident evaluation (INES).
Eng. Corp l
(NUPEC) l 13
Program: Reactor incident Response Country Organization Program Differences UK
- 1. Nuclear
- 1. Licensees are required by the license, expected to make installations arrangements for notification, recording, investigation, and Inspectorate reporting of abnormal occurrences on the site. Licensee expected j
(Nll) to review all occurrences at his own and similar plants with a view j
to preventing future occurrences. Senior inspector makes judgement on nature of initial response. Nll initiates emergency arrangements and sends inspectors to site.
Program: Reactor Operational Experience Evaluation Country Organization Program Differences France
- 1. Directorate for
- 1. Is part of monitoring the application of the general technical the Safety of regulations and cannot be distinguished from lict nsing. Often Nuclear request licensee to provide evaluations of events or conditions Installations discovered at facilities and to propose corrective actions. Request (DSIN)
IPSN to assess the information provided by the licensee.
Since French reactors are standardized, reactor operational experience evaluations are considered generically applicable to all reactors. Also, since all reactors are run by the same utility, the licensee develops generic modifications. (*NRC evaluations must i
consider the impact on scores of different designs.) Only significant operational events are reported in writing to DSIN - less significant events are collected in database which French regulators would I
periodically review. The licensee must provide evaluations of J
significant events or conditions discovered at f acilities and propose corrective actions; based on the advice of IPSN, DSIN may require further actions to be taken and sets the deadlines for implementation at the reactors concerned.
(
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- 2. Institute for
- 2. Reviews operating experience but only events of higher safety f
significance are reported. The lessor events are not reported but Protection and l
Nuclear Safety are simply entered into a database. French regulators would (IPSN) periodically review those events. Also program similar to Accident i
I Sequence Precursor program looks at fewer events. Performance indicators are maintained by the licensee.
- 3. Regional
- 3. Reviews written reports for proper safety classification. DRIRE Directorates for with support from IPSN conducts a small number (2-5) of reactive l
j
- Industry, inspections each year to investigate events. Inspection information l
Research and is not publicly available.
the Environme" (DRIREs) 14
Program: Reactor Operational Experience Evaluation Country Organization Program Differences Japan
- 1. Ministry of Int'l
- 1. Overall responsibility for oversight of operational experience Trade &
evaluation of commercial power reactors in Nuclear Power Safety Industry (MITI)
Administration (NPSA) Division of MITI. NPSA publishes annual report similar to U.S. performance indicators. NPSA also picks investigation topics for NUPEC (below) to analyze in more detail.
{
No Accident Sequence Precursor program. NPSA also solicits the
)
review of the Nuclear Power Plant Operations Management Subcommittee on matters relating to abnorrnal events and operations management.
l
- 2. Nuclear Power
- 2. NUPEC is a contractor outside government similar in part to the Eng. Corp Institute for Nuclear Power Operations (INPO) in U.S. Develops (NUPEC) the safety information data base as directed by NPSA.
- 3. Nuclear Safety
- 3. NSC is a specialized subcommittee (Deliberation Committee on Comraission Analysis and Evaluation of Accident and Failure in Nuclear (NSC) installations) within NSC deal with operational experience.
4
- 4. Science and
- 4. Nuclear Safety Bureau of STA evaluates reactors during the Technology research and development stage.
Agency (STA) i l
UK Nuclear Reactor operational experience evaluation is seen as primarily a installations responsibility of the licensee. Nll operational experience evaluation l
Inspectorate (Nil) activities are viewed as an integral part of the inspection activities with l
limited support from its Central Strategy Unit. However, resource in this area is to be increased.
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h' Program: Reactor Technical Training Country Organization Program Differences l
France DSIN, IPSN, and IPSN and one third of DSIN and DRlRE staff are recruited from high l
DRlRE level engineers within the Commissariat a l'Energie Atomique (CEA).
l These personnel already have extensive practical experience in nuclear issues. Other DSIN and DRIRE staff, including managers, are qualified civil servants. Allinspectors and some headquarters
)
personnel recelve simulator training. The government does not j
maintain in-house simulators. Combined level of effort devoted to I
training per employee within DSIN, IPSN, and DRlRE is similar to the NRC.
Japan Ministry of Int'l Inspectors are university degreed engineers with two years of on the Trade & Industry job training. There are several training courses for inspectors and (MITI) regulatory staff, including mock-up simulator training. Refresher training is provided. The government does not mwntain in-house simulators.
UK Nuclear Inspectors are all technically and professionally qualified. They installations typically hold professional engineer status and have suitable inspectorate (Nil) experience 10 an appropriate field. Internal tra;ning programs cover legal and other activities to ensure that an inspector is competent to inspect and enforce legislation. Few of the staff receive simulator training. The government does not maintain in-house simulators.
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Program: Enforcement i
Country Organization Program Differences France The process :n France is not as formal as in the U.S. as the regulation does not provide for direct enforcement sanctions. Citations can be made through the courts, but this is not a current practice. While j
DSIN does not impose enforcement sanctions,if plant safety is questioned, the Director can request the operator to shut down at once.
Japan MITI Various governmental organizations in Japan have enforcement authority. For example, the Minister of MITI appears to have the authority under their Reactor Regulation Law, and their Electricity Utilities Industry Law to conduct " examinations" and enforce the requirements of these laws. Japan has an enforcement program, however, Japan's legal system, general philosophy regarding regulation, and relationship betweer' the regulator and the regulated entity are different than the U.S. MITI uses a different process for resolving problems than the NRC's process of issuing enforcement actions frequently.
UK Nuclear UK has an enforcement program, however, its legal system, general Installations philosophy regarding regulation, and relationship between the Inspectorate (Nil) regulator and the regulated entity are different than the U.S.
Approximately half of the licensed sites are owned by public entities.
The majority of discrepancies identified by Nil are addressed at the individual inspector and plant operator level without the need for formal documentation or regulator issued enforcement action. However, more significant discrepancies are dealt with through formal enforcement action.
]
Program: Reactor Investigations Country Organization Program Differences France No formal program.
Japan Ministry of Int'l No formal program.
Trade & Industry (MITI)
UK No formal program.
17
Program: Reactor Legal Advice Country Organization Program Differences France in contrast to the NRC, Frar.ce's nuclear safety regulator devotes very limited resources to the provision of legal advice relating to nuclear reactor safety, licensing, and environmentalimpacts. To the best of
)
our understanding, the relative lack of need for legal resources stems from France's adoption of broad, generally non-prescriptive regulations. Legal advice, when needed, is given by a separate
" Commission" of experts, the Interministerial Commission for Basic nuclear Installations, which is not part of the DSIN.
Japan MITI and STA have their own legal advice staff. They not only perform legal advice on nuclear regulatory matters but also other matters concerning MITI and STA responsibilities.
UK in contrast to the NRC, the UK's nuclear safety regulator devotes very limited resources to the provision of legal advice relating to nuclear reactor safety, licensing, and environmental impacts. To the best of our understanding, the relative lack of need for legal resources stom:
from the U.K.'s adoption of broad, generally non-prescriptive regulations.
Program: Reactor Adjudication Country Organization Program Differences France In contrast to the NRC, France's nuclear safety regulator does not have a public adjudicatory or hearing process for the licensing of its nuclear power plants. However, this process includes a public inquir/
performed by the Prefect after DSIN gives a positive advice on the files submitted by the applicant.
Japan MITI and STA have a public adjudicatory or hearing process for the licensing of its nuclear power plants.
UK in contrast to the NRC, the UK's nuclear safety regulator does not have a public adjudicatory or hearing process for the licensing of its nuclear power plants.
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Program: Reactor and Plant Performance Research Reactor Materials and Component Behavior Research Country Grganization.
Program Differences France Institute for Resources:
i Protection and Nuclear Safety In FY1997 IPSN's budget was FF 1,489.4 Million - $298M. IPSN has (IPSN) approximately 1270 FTEs, among which 350 FTEs perform safety assessments for DSIN. Many of the remaining IPSN staff (920 FTE) perform research functions similar to those carried out by RES.
However, unlike NRC, IPSN is supporting expensive test programs such as the Phebus program on fission product release and transport, the Cabri program on high burnup fuel, and the BETHSY thermal-j hydraulic test program, etc.
Maior Differences from NRC/RES:
In France there is a single standard reactor design of the pressurized water reactor type with dry containment. In a simple term, this enables the French to conduct research activities for that design which results in substantial saving of resources. For example, the analysis tools that are being developed to assess plant performance under normal, and accident conditions (e.g., fuel behavior, thermal-hydraulics, severe accidents, etc.) are designed to handle that standard design.
Furthermore, both the industry and the regulator fund and share selected research results and fund and use the same analytical tools that are developed by IPSN. While there are several drawbacks to such reliance on the same analytical tools by the industry and the regulator, there is significant reduction in resources as compared to developing independent aralysis tools.
By contrast, the USA has several different reactor designs (e.g.,
pressurized and boiling water reactors) different types of steam generators (e.g., U-tubes, Once Through), several type of containment designs (e.g., dry, sub-atmospheric, ice condenser, pressure suppression Mark'l,11, and lil) with several balance of plants designs.
The research needs and the technical bases to support each of these different designs are unique. Hence our research activities must encompass all these different design variations. For example, the NRC analytical tools must be developed and assessed using data that are applicable to all types of reactor designs. This places additional i
burden on RES to uevelop data for PWRs and BWRs.
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1 Program: Reactor and Plant Performance Research l
Reactor Materials and Component Behavior Research Country Organization Program Difference France Institute for IPSN is the only Organization within CEA in charge of developing NPP l
(Continued)
Protection and safety technology. Other organizations, e.g., DSIN relies on IPSN for l
Nuclear Safety both code development and performing plant analysis. By contrast, in (IPSN) selected areas, the NRC maintains similar disciplines within its staff or through contractors.
Nuclear Reactor IPSN is not the only organization, even within CEA, in charge of Directorate (DRN) i developing NPP safety techriology. The Nuclear Reactor Direction DRN of CEA also has programs in this area: these programs are developed for EDF and/or Framatome and/or (in some cases for IPSN). DRN has approximately 1500 FTE of which about half (750) are devoted to reactor technology and safety research. We assume l
about half of these (300-400) are devoted to safety research similar to that conducted by NRC.
Besides, EDF and/or Framatome can develop their own codes or use l
codes from foreign organizations: an example is for severe accidents l
where EDF uses the American code MAAP while IPSN developed its own code, ASTEC.
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20
Program: Reactor and Plant Performance Research Reactor Materials and Component Behavior Research Country Organization Program Differences J: pan
- 1. Japan Atomic
- 1. Resources:
Energy Research In 1996, JAERI had 1,149 FTEs and V120 billion.
Institute It is difficult to deduce from the information we had the exact number (JAERI).
of FTEs directly involved in reactor safety research. It is estimated Several based on interaction with JAERI that 350-400 FTEs are involved in departments at reactor safety research which is similar to that conducted by RES, JAERI are This figure does not include the supporting staff at NSC/STA.
involved directly or indirectly in Maior Differences from NRC/RES:
nuclear safety research.
JAERI is involved in a much broader research than that being
{
conducted by RES. For example, JAERI supports large experimental programs, e.g., the ROSA thermal-hydraulic test facility which was used by NRC to run confirmatory test programs for the AP600, and the Nuclear Safety Research Reactor, which is being used to generate data on high burnup fuels. JAERI, however, does not develop reactor safety codes similar to those being developed by the NRC for thermal-hydraulics, severe accidents, and fuel behavior codes. One major difference between JAERI and RES is that some of their activities are being performed for promoting and developing nuclear technology. In addition to the items below, JAERI conducts research on fuen cycle safety research (e.g., burn-up credit for spent fuel storage and transport), and environmental safety research (e.g., radioactive waste management).
Finally, JAERI does not develop analytical tools similar to ones being developed by the NRC to assess plant performance under normal and accident conditions.
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l Program: Reactor and Plant Performance Research Reactor Materials and Component Behavior Research i
Country Organization Program. Differences Japan
- 2. Nuclear Power
- 2. Resources:
l Endearing Corporation in FY 1996, NUPEC had 346 FTEs and V28.4 Billion.
(NUPEC)
Supported by MITI. It is responsible of performing engineering tests for NPP components for demonstrating of reliability & safety of NPP.
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Maior Differences from NRC/RES:
NUPEC focuses on testing the safety and reliability of nuclear power i
generation equipment, safety analysis for nuclear power plants, and improving the nuclear power technology. As sucn, its mission is i
I similar to the Office of Research mission, however, they are I
supporting very expensive test programs nationally and internationally (e.g., Phebus, Sandia containment model). Direct comparisons, however, are difficult, since some of the responsibilities of NUPEC include promoting nuclear energy.
UK
- 1. Nuclear
- 1. Resources:
Installations inspectorate FY 97 Budget - $16M and 6 FTEs and 26 contractors employees.
l (Nil) l Research into generic nuclear reactor safety issues is managed by an Industry Management Committee (IMC), which comprises l
representatives of the nuclear Licensees and Nil. The safety issues i
are identified by Nil and placed on a Nuclear Research Index, and l
Technical Working Groups (TWGs) under the IMC consider proposals for resolving these and oversee progress with contracts. The industry usually arranges and funds the contracts to resolve the technical issues itself, and the contractors report back to Nil through the TWGs.
In some cases, however, Nil considers it more appropriate to place contracts itself, and then recovers the costs through a levy on the industry. The combined spent on IMC and levy-funded research is about 10 million pounds (USD$ 16 million) per year. Once again, a number of contractors are involved. Nll commissions research to assist regulatory decisions for these using its Nuclear Support Studies budget.
Maior Eifferences:
Most research is performed by industry Nil supports few projects and relies heavily on international e
collaborations
- Uses NRC-Developed safety analysis codes t
22 e
p Program: High Level Radioactive Waste Management Country Organization Program Differences France DSIN France is considering three options for safe management and disposal of high-level waste (HLW):
- deep geologic disposal,
-long-terrn surface storage, and
- chemical separation and transmutation.
France practices commercial reprocessing of spent fuel; the principal I
waste form is vitrified HLW, although some spent fuel may be directly disposed.
France has recently identified the Muese clay site as a research laboratory for geologic disposal. They are planning to identify a t
second research site in a granite formation; a granite sits which had been under consideration in the Vienne Department has been rejec9d as unsuitable.
The French Parliament is scheduled to make a decision on the future course of the French program, based on the outcome of these l
l research activities, in 2006.
)
Japan Science and The regulatory authority for HLW management in Japan is the Nuclear Technology Safety Bureau, within the Science and Technology Agency.
Agency / Nuclear l
Safety Bureau Japan practices reprocessing of commercial spent nuclear fuel and is considering deep geologic dispoeal of vitrified HLW, and separation
{
and transmutation of long-lived radionuclides, prior to geologic disposal of the residual waste.
A long period of research and development is planned to select and I
demonstrate the safety of the disposal technology, Japan plans to store HLW for 30 to 50 years. Regulations for safe management and l
disposal of HLW are still being developed.
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Program: High Level Radioactive Waste Management Country Organization Program Differences UK
- 1. Nuclear The regulatory authority for HLW management at nuclear licensed installations sites is the Nuclear installation inspectorate.
Inspectorate (Nll)
The UK practices reprocessing of spent nuclear fuel, so that the waste form is primarily vitrified HLW. However, privatization of the nuclear
- 2. Department of power industry in the UK has led to the consideration of direct disposal Environment of spent nuclear fuel.
Transport and the Regions The policy reiating to the long term environmentalimpacts of HLW (DETR) disposal the responsibility of DETR.
The UK current policy for HLW is to store it for a minimum of 50 years.
The government is currently considering what future national policy should be, and a Committee of the House of Lords visited the NRC in May 1998 for briefings on the U.S. laws, policies and regulations for radioactive waste disposal, to assist in formulating national policies and legislation in this area.
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VI.
Resource Comparisons Aggregate resource comparisons do not consider the number and types of programs that are executed by different countries. Even comparisons of resources at the program level may not be meaningful given the differences in such factors as: infrastructure differences and regulatory approach.
The following table compares FTE information where available by program and an FTE to reactor ratio.
Resource Comparisons FTE and Ratio Comparisons Reactor Proaram M
France Japan
.UE Comments Licensing 475 240 310' 40 Differences are not substantial between (FTE/ Reactor)
(4.6)
(4.00)
(5.8)
(1.1)
U.S., France & Japan and likely attributable to difference in standardization, number of licensees and regulatory relationship with licensee.
Also, other countries do not license plant operators.
License 55 NA NA NA' NA Renewal Inspection 634 103 UNK' 31
- 1. No Resident inspectors in France, (FTE/ Reactor)
(6.2)
(1.7)
(0.9)
Japan, or the UK.
- 2. U.S. sets higher threshold for i
independent verification by inspection.
- 3. Does not include radiation s fety or safeguards for France.
2 UNK' 10 Given lack of formal assessment Performance 62 UNK Assessment
(.6)
(.3) programs, comparisons not meaningful.
(FTE/ Reactor)
Incident 33 17 UNK' 7
French regulators play less of a
Response
leadership role. Great Britain sends inspector to site.
1 Op. Exp. Eval.
49 UNK UNK' 1
No formal programs. Comparisons not l
meaningful.
1
' Includes MITI (200), STA (40) and NUPEC (70). 240 is the total number of MITI and STA staff engaged on these programs, and it is difficuit to give breakdown by L
f-prograrr.
l 2Part of Licensing 25
7-f Resource Coniparisons l
FTE and Ratio Comparisons Reactor Procram kl4 France Japan UK Comments j
Technical 39 10 UNK' 3
Ratios are very close.
Training
(.02).
(.03)
(.02) 1 (FTE/ Employee)
Enforcement 19 NA UNK' 2
NA Investigations 33 NA UNK' NA NA i
l Legal Advice 19 NA UNK' 1
NA Adjudication 9
NA UNK' NA NA Research 349 650-750' 626-676' 130-140 The diversity of reactor standardization 5
(FTE/ Reactor)
(3.4)
(11.2-(11.8-(2.9-4.0) and different research strategies make j
12.9) 12.71) comparisons not meaningful. France and Japan have a broader research programs than the United States.
Totals 1776 1t220-936-986 195-235 1120 Operating 103 58 53 35 Reactors Vll.
Tim D. Martin & Associates Study This study concludes that broad comparisons of regulatory programs among countries is not meaningful. However,if such comparisons are atternpted, they should differentiate the constituent elements so as to compare like programs.
The resources that were used by Tim D. Martin & Associates (TDM) for comparing ratios of regulatory staff per power reactor appear to be based on discussions TDM had with the International Atomic Energy Agency (IAEA) who had provided TDM with available data from a 1997 study conducted by the Nuclear Energy Agency. The data we collected from our The estimated number of staff in ISPN devoted to reactor safety research activities is about 350 FTE and CEA/DRN has approximately 750 FTE devoted to reactor technology and safety research. Of these approximately % (300-400) are assumed to be involved in " safety" research.
' includes effort by JAERI and NUPEC.
5This includes the combined time spent by the Industry Management Committee and HSE's levy funded research and therefore cannot be directly compared.
26
F 1
9 counterparts is not consistent with these estimates. It also appears that the analysis did not account for resources expended by organizations other than the primary nuclear regulator.
Some of these omissions and differences in programs are explained below.
Franc.e: The French regulatory authority is DSIN with BCCN and the nuclear divisions of DRIREs. IPSN is a technical support organization with 1270 staff among which 350 provide technical support to DSIN. Of the remaining 920 it is estimated that 350 do research reactor research work. However, the research programs in France are broader than of those in the NRC and include extensive test programs. CEA/DRN also conducts thermal-hydraulics, reactor physics and fuel studies (300-400 FTE). In total, DSIN, ISPN and CEA/DRN are estimated to expend approximately 1020 to 1120 FTE for reactor reputatory activities. However, further detailed analysis would be required to determine the dnferences between the scope and depth of individual programs and research activities between NRC and the (French) Nuclear Regulatoy Authority.
The TDM study reported approximately 350 professional staff for 60 power reactors in France.
DSIN does not regulate radiation safety or safeguards, does not license the reactor operators and does not have a resident inspector program.
Japan: The TDM study reported approximately 400 professional staff for 53 power reactors in Japan (MITi & STA). However, MITI & STA staff are estimated at 240 FTE and technical regulatory support work is performed by NUPEC (70 staff), JAPEIC (120 staff) and NUSTEC (20 staff). Also, research work is estimated to be between 626-676 FTE. Much of this work would be done by the NRC's Office of Research and NRR Technical staff. Factoring in these support staff who do work for MITI & STA would bring Japan's professional staff equivalent to 936-986. However, further study would be required to determine the differences between NRC and MITI & STA for staffing individual programs and research and technical support activities.
United Kinadom: The TDM study reported appro>umately 145 professional staff for 35 power reactors and 6 commercial gas cooled reactors. This does not account for approximately $4M l
in contractor support (36 FTE) and research estimated to be at a level of 100-140 FTE. There are a number of differences between Nil and NRC. A major difference is that in the UK all the operating nuclear power stations are owned by only two companies and this has enabled Nil to i
operate a goal setting regulatory regime rather than the prescriptive system operated by NRC.
Nil does not have a Resident Inspector Program. Nll also regulates large fuel cycle, nuclear weapons production and nuclear submarine refueling facilities.
Summary: The data used in the TDM study does not account for all research and technical support functions conducted in France, Japan and the UK. While the nature of these functions may vary from country to country, they cannot be ignored if comparisons are to be made. The following chart shows how the ratios can be affected if %e functions are included. Even these ratios cannot be meaningfully compared, however, because the functions performed are different, and the nature and type of technical contractor support needs further analysis.
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f Ratlos after Adjustment l
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United France Japan United Kingdom States I
TDMA/NEA report (FTE) 1700 350 400 145 Revised Estimate 1776 1020-1120 936-986 195-235 i
Number of Reactors 103 58 53 35 TDMA Ratio 16.5 6.0 7.6 4.1 Revised Ratio 17.2 17.6-19.3 17.7-18.6 5.6-6.7 Attachments:
- 1. Tim D. Martin & Associates Chart
- 2. Memo from Jackson to Travers dated 11/24/98
- 3. U.S. NRC Program Description
- 4. Memos to France, Japan, and United Kingdom dated 12/4/98
- 5. Response from France
- 6. Response from Japan
- 7. Response from United Kingdom i
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