Category Archives: Infrastructure and methodologies for the. justification of nuclear power programmes

The means to enact responsibilities and enhance leadership effectiveness

5.1.2 Organisational factors

Operators in all regulatory environments must establish organisations within which the personnel have effective leadership and the knowledge, skills and attitudes required to manage nuclear assets.

The operator must establish programmes, processes and procedures through which the knowledge and skills of the workforce are effectively deployed. These must be applied to all phases of design, site selection, construction, commissioning, operation and maintenance of the plants. Ultimately, decommissioning activities will also require similar consideration.

The levels of resource and the competencies required will be determined by the strategy adopted for the implementation of the responsibilities assigned to them in the licence conditions. In many cases work will be out­sourced and this will have an impact on the resource levels required by the operating organisation, but the responsibility for the enactment of the nuclear site licence will always remain with the licensee, so the ability to specify what work is required and to assess the adequacy of the work under­taken must be retained and maintained by the licensee.

The regulatory function: development of a regulatory pyramid

The regulatory pyramid is the structure that represents the hierarchy of the regulatory system (Fig. 4.1). The regulations and guides are based on and suit the legal system of the State concerned and establish the principles, requirements and associated criteria for safety upon which the regulatory judgements, decisions and actions are based. The legislative and govern­mental mechanisms ensure that such regulations are developed and approved in accordance with appropriate time scales.

image002

The regulatory pyramid is composed of laws and decrees, regulations, regulatory requirements, safety goals and criteria, safety guides and indus­trial standards. In the development of the regulatory pyramid it is always necessary to take into account the fact that the licensee or operator has the prime responsibility for safety during all phases of the nuclear power plant’s life: ensuring safety in the siting, design, construction, commissioning,

operation and decommissioning phases until the operator is released from the regulatory control of the plant. Therefore, it is important that the regula­tor clearly states that compliance with the conditions, regulations or require­ments imposed by the regulatory body does not relieve the operator of its prime responsibility for safety. The licensee needs to demonstrate to the satisfaction of the regulatory body that this responsibility has been and will continue to be discharged.

Requirements for new nuclear power plants

To deal with requirements for new nuclear power plants, two main docu­ments should be referred to: IAEA (2007b), Milestones in the Development of a National Infrastructure for Nuclear Power, NG-G-3.1, and IAEA (2008a), Nuclear Safety Infrastructure for a National Nuclear Power Programme Supported by the IAEA Fundamental Safety Principles, INSAG-22.

2.4.1 Preliminary phase

At the level of a country and upon the decision of the government, the first preliminary phase is to prepare the manpower necessary for carrying the programme, a phase that will evolve with time over periods as long as 10 years, and to ratify all international conventions necessary to meet the necessary levels of safety, security and safeguards.

Manpower development, in addition to nuclear engineering achieved through education, theoretical training and on-the-job training, if necessary in foreign countries, should follow a very long schedule to be able to man the required structure to be put in place. Such a structure is composed of the energy producer, the regulatory body, research laboratories and techni­cal support organizations. It is recommended to man the top levels of the structure with nationals having the power of decision and well-established responsibilities. One should not forget to prepare the manpower necessary for the maintenance of the installations.

A national structure should be set for managing the whole programme. This includes the government support ministries with a clear definition of roles and responsibilities, and the availability of financial and human resources.

The international legal framework comprises the international legal framework for nuclear safety, the international legal framework for nuclear security, and the international nuclear security initiatives.

For safety there are the Convention on Nuclear Safety (IAEA, 1994), the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management (IAEA, 1997), the Convention on Early Notification of a Nuclear Accident and the Convention on Assistance in the Case of a Nuclear Accident or Radiological Emergency (IAEA, 1986a, 1986b) complemented by bilateral agreements between neighbouring countries, Regulations for the Safe Transport of Radioactive Materials (IAEA, 2009c), the Code of Conduct on the Safety and Security of Radioactive Sources (IAEA, 2004) and the Code of Conduct on the Safety of Research Reactors (IAEA, 2006a). The references for developing and implementing nuclear laws are IAEA (2003c), Nuclear Law Handbook, and the newer IAEA (2010a), Nuclear Law Handbook — Implementing Legislation.

It is necessary to implement at all stages of the life of the installation the 10 fundamental principles that sustain safety as developed in IAEA (2006b), Safety Standards Series, Fundamental Safety Principles, SF-1:

Principle 1: Responsibility for safety.

Principle 2: Role of government.

Principle 3: Leadership and management of safety.

Principle 4: Justification of facilities and activites.

Principle 5: Optimization of protection.

Principle 6: Limitation of risk to individuals.

Principle 7: Protection of present and future generations.

Principle 8: Prevention of accidents.

Principle 9: Emergency preparedness and response.

Principle 10: Protective actions to reduce existing or unregulated radiation.

These principles constitute the starting point of the review and revision of all safety standards series of the IAEA.

For security there are the Convention on the Physical Protection of Nuclear Material (IAEA, 1979), the Convention for the Suppression of Acts of Nuclear Terrorism (IAEA, 2005), the Convention for the Suppression of Unlawful Acts Against the Safety of Maritime Navigation (IMO, 1988) and UN Security Council Resolution 1540 which asks ‘States to prohibit non­State actors from acquiring such weapons through adoption of laws, enforce­ment measures, domestic controls’. In addition a certain number of initiatives need also to be implemented: the Nuclear Threat Initiative, the IAEA security plan, and the UN Global Counter-Terrorism Strategy.

The IAEA (2003c) Nuclear Law Handbook and the newer IAEA (2010a) Nuclear Law Handbook — Implementing Legislation cover all these inter­national aspects and give all necessary details for implementation.

For safeguards, the Non-Proliferation Treaty engages all state parties to implement export controls (not to transfer nuclear material and single-use equipment and material to non-nuclear weapons States except subject to Agency safeguards (Art. III.2)), technology transfers (to facilitate fullest possible exchange of equipment, materials and scientific and technological information for peaceful uses of nuclear energy (Art. IV.2)) and disarma­ment (to pursue negotiations on measures relating to cessation of the nuclear arms race and to nuclear disarmament, and on treaty on general and complete disarmament under international control (Art. VI)); the veri­fication process is in the hands of the IAEA via Comprehensive Safeguards Agreements. The structure and content of Agreements between the Agency and States, in connection with the Treaty on the Non-Proliferation of Nuclear Weapons INFCIRC/153 (Corr.), requires from countries the estab­lishment of a State system of accounting and control (SSAC), an informa­tion system for record keeping by operators, reporting inventories, imports, exports and production of nuclear materials, providing information on design of nuclear facilities and other locations where nuclear material is used, and giving access to facilities and other locations, involving facility design information verifications, inspections and cooperation with the Agency. Chapter 13 of the present book deals in more detail with the safe­guards regime.

Finally, the country should also sign one of the Conventions on Civil Liability for nuclear damage. Special arrangements have been adopted under both national laws and international legal instruments to deal with the problem of how to compensate persons for injuries and other damage that could result from nuclear incidents. Reference IAEA (2010a), Nuclear Law Handbook — Implementing Legislation, lists the following principles:

‘(a) A defined scope for the liability regime based on specific concepts, namely “nuclear installation”, “operator”, “nuclear incident” and “nuclear damage”

(b) Strict (no fault) liability imposed on the operator of a nuclear installation (also referred to as “absolute” liability)

(c) Exclusive liability of the operator (so-called legal channelling of liability onto one person — namely, the operator — to the exclusion of other persons)

(d) Exonerations of the operator from liability only in certain exhaustively enumerated circumstances (e. g. nuclear incidents directly due to warlike events, grave natural disasters of an exceptional character, conduct on the part of the person suffering the damage which amounts to gross negli­gence or intent to cause damage)

(e) Possibility of limiting the liability in amount

(f) Mandatory financial security of the operator to meet liability

(g) Limitation of liability in time

(h) Non-discrimination and equal treatment of victims

(i) Exclusive jurisdiction of a single competent court

(j) Obligation to recognize and enforce final judgements entered by the competent court in other contracting States without re-examination of the merits.’

These Conventions will also determine the responsibilities with the vendor and constructor of the plant.

The development of the national legal framework comes next. Again the reference IAEA (2010a), Nuclear Law Handbook — Implementing Legislation guides countries in developing their national nuclear legal framework.

The national nuclear law needs to be established and should meet all the obligations induced by the ratification process underlined above. It should also meet the constraints of the legislative system of the country. The defini­tion of the national nuclear law is the following: ‘Nuclear law is the body of special legal norms created to regulate the conduct of legal or natural persons engaged in activities related to fissionable materials and ionizing radiation’ (IAEA, 2010a).

The government should include public participation in the preliminary steps: the support of opinion support is essential for carrying out a nuclear programme. Regular information meetings could be envisaged, especially at the various steps described in the next paragraphs.

The compliance function: verification and oversight during construction and operation

The regulatory body oversees the compliance with regulations, regulatory requirements and the conditions specified in the licence through review and assessment and regulatory inspection. This review and assessment of infor­mation is performed prior to granting a licence and during the lifetime of the nuclear power plant. There are several types of review: pre-licensing review, review of the design or of operational changes at the plant, review of the application of the operational experience, review of the ageing of the plant, and review of licence extension or long-term operation beyond the licensing basis.

The independent review and assessment and the regulatory inspections are not separate and distinct processes. The safety verification and oversight is an integrated and interactive process that involves both the independent review and assessment processes and the regulatory inspections; from the results of both of these activities, conclusions can be drawn and therefore regulatory decisions taken. Coordination between review and assessment activities and inspection activities is a key element to ensure a systematic approach.

The results and decisions from the oversight are necessary to take appro­priate regulatory actions for safety, including enforcement action when necessary. The results of reviews and assessments should be provided as feedback information for the regulatory process.

The review and assessment activities and inspection activities are the major functions carried out by the regulatory body. Therefore it is necessary to consider the human and financial resources and regulatory competences required to perform these activities.

A crucial aspect is to provide the licensee with a comprehensive under­standing of national safety requirements, or references to international or other countries’ requirements clearly specified as part of the licensing and regulatory framework in the early stages of the project. Vendor, licensee and regulator need to have a clear understanding of the licensing, regula­tory, and inspection practices in the State where the plant is designed and in the State where the plant will be constructed.

Regulatory requirements and practices in nuclear power programmes

G. CARUSO, International Atomic Energy Agency

(IAEA), Austria

Abstract: Technology, people and organizations are the main contributors to safety and need to be considered properly in the regulatory framework in order to provide effective independent regulation of nuclear installations. The regulatory oversight includes the development and application of regulatory functions. The outcome of these functions provides the basis for determining the independent decision making on safety. The regulatory requirements, criteria and regulations that make up the selected regulatory approach are the basis for regulation and need to be properly integrated in the regulatory pyramid in accordance with the licensing process and with national arrangements.

Key words: licensing process, regulatory requirements, regulatory inspections, regulatory enforcement, regulatory oversight.

4.1 Introduction

Individual States establish the national policy for safety by means of differ­ent instruments, statutes and laws. The nuclear regulator is empowered to regulate and control nuclear activity; the regulator implements national policy by means of a regulatory programme and verifies compliance with national regulations. In general, the regulatory body develops strategies and promulgates regulations in the course of implementation of these national laws and policies.

The regulatory framework, as a major part of the national safety infra­structure, is considered in the national policy, taking into account all bodies and organizations involved and their assigned responsibilities. Building a

This chapter is the copyright of the International Atomic Energy Agency (IAEA) and is reproduced by the Publisher with the IAEA’s permission. Any further use or reproduction of the chapter, in whole or in part, requires the permission of the IAEA. The chapter has been written by a staff member of the IAEA in his personal capacity and not on behalf of the IAEA or the Director General of the IAEA. The views expressed in the chapter are not necessarily those of the IAEA and that the IAEA disclaims all liability in connection with the chapter and any use made thereof.

94

national safety infrastructure for nuclear power is a complex and multidis­ciplinary activity and can take over 10 years to complete.

In general, the policy for safety includes aspects such as general safety principles to protect both people and the environment, international legally binding and non-legally binding instruments, the regulatory system, the different governmental offices and organizations involved in nuclear safety, human resources and national safety research. These aspects are strongly dependent on national arrangements, the legal system, and current and future national considerations. The International Nuclear Safety Group (INSAG) has promoted a global safety regimen based on the IAEA Safety Standards and safety related Conventions (INSAG, 2007).

The fundamental objective with regard to nuclear safety is to protect people and the environment from the harmful effects of ionizing radiation. A comprehensive safety framework needs to be developed by the State, taking into account the Fundamental Safety Principles of the International Atomic Energy Agency (IAEA, 2006a) which represent the international consensus. Laws, ordinances and decrees are promulgated taking into con­sideration national policies, the current social and economic situation in the State and other specific circumstances that can influence the develop­ment of nuclear power. Normally, it is recommended to review and revise existing provisions to follow as close as possible the Fundamental Safety Principles.

Training and development

The operating organisation is responsible for ensuring that it is resourced with personnel who have the necessary knowledge and skills to perform the tasks assigned to them and for ensuring that those competencies are maintained throughout the lifecycle of the plant. This is achieved through induction or initial training at the time of recruitment and through continu­ing training during the period of employment.

Key to effective training is an objective analysis of training needs, facilities, equipment and suitably qualified trainers for the delivery of train­ing, together with a process for the continued evaluation of training effectiveness.

In recognition of these requirements the US utilities have employed a systematic approach (SAT) to the development and delivery of technical training. This approach has contributed greatly to the enhancement of pro­fessionalism in the workforces and to performance improvements in the US NPPs.

In support of the US utilities, the National Nuclear Training Academy has established a set of objectives and criteria that describe the attributes of organisations with effective training programmes. In summary these are:

1. Training is used as a strategic tool to provide highly skilled and knowl­edgeable personnel for safe operation and to support performance improvement.

2. Management is committed to and accountable for developing and sus­taining training programmes that meet NPP needs.

3. Initial training programmes use a systematic approach to the identifica­tion, design and delivery of training.

4. Continuing training uses a systematic approach to refresh and improve the knowledge and effectiveness of the workforce.

5. Training is conducted and uses methods and settings that are conducive to effective training. Effectiveness of training is confirmed through evaluation.

6. Evaluation methods are employed to systematically assess the effective­ness of training and to identify areas for improvement.

Each of these principles is outlined in the US National Academy for Nuclear Training standard ACAD 02-001. In that standard each of the principles or objectives is supported with a set of supporting criteria. Utility training programmes are periodically assessed against these criteria by NTA evalu­ators and those deemed to satisfy the criteria have their programmes accredited by an independent board of assessors. The practice has been adopted in UK and South African utilities.

Laws and decrees

The regulatory pyramid is established within the legal framework, using laws and decrees to establish, adopt, promote or amend regulations and guides. All regulations of the regulatory system have to be in compliance with the State legal system. In fulfilling its statutory obligations, the regula­tory body establishes, promotes or adopts regulations and guides upon which its regulatory actions are based.

4.1.3 Regulations

The main purpose of regulations is to establish requirements with which all licensees must comply. In order to carry out the regulatory functions it is necessary to create a consistent and comprehensive set of regulations with adequate coverage commensurate with the associated radiation risks. The regulatory body notifies all interested parties and the public of the princi­ples and associated criteria for safety established in its regulations and guides, and makes the regulations and guides readily available.

The development of regulations involves consultation with all interested parties and also takes into account internationally agreed standards, such as the IAEA Safety Standards, and the feedback of relevant experience from national or international organizations.

In several cases it is necessary to clearly identify by the regulatory body the reference and criteria to be used for assessing compliance with the regulations. The criteria for compliance need to be understood by the licen­see from the beginning in order that it can carry out its activities correctly.

The production of regulations is included in the regulatory body’s man­agement system together with the process for establishing, revising and revoking regulations and guides. This process is established in accordance with the national legal system. The periodic review of regulations is also specified; changes need to be discussed with interested parties as appropri­ate but it must keep in mind that frequent changes in regulations can affect the stability or predictability of the regulatory system if the changes are not properly justified from a safety perspective.

4.1.4 Regulatory requirements

The regulations provide a framework for more detailed requirements or conditions that will be issued by the regulatory body during its activities. Requirements are also incorporated into licences as specific conditions or requirements as well as into individual authorizations or applications for licences within the licensing process. The regulatory body issues require­ments when necessary to improve safety. Requirements are also necessary to improve safety considering the day-to-day regulatory oversight.

Site selection

The life of a nuclear power plant starts with the selection of the site. This study is necessary prior to the bidding process. The reference IAEA (2003a), Safety Standards Series, Site Evaluation for Nuclear Installations. Safety Requirements, NS-R-3, gives all details for proceeding to site evaluation:

‘The main objective in site evaluation for nuclear installations in terms of nuclear safety is to protect the public and the environment from the radiologi­cal consequences of radioactive releases due to accidents. Releases due to normal operation should also be considered. In the evaluation of the suitability of a site for a nuclear installation, the following aspects shall be considered:

(a) The effects of external events occurring in the region of the particular site (these events could be of natural origin or human induced). Site charac­teristics that may affect the safety of the nuclear installation shall be investigated and assessed. Characteristics of the natural environment in the region that may be affected by potential radiological impacts in opera­tional states and accident conditions shall be investigated. All these char­acteristics shall be observed and monitored throughout the lifetime of the installation.

(b) The characteristics of the site and its environment that could influence the transfer to persons and the environment of radioactive material that has been released.

(c) The population density and population distribution and other character­istics of the external zone in so far as they may affect the possibility of implementing emergency measures and the need to evaluate the risks to individuals and the population.’

If the site evaluation for the three aspects cited indicates that the site is unacceptable and the deficiencies cannot be compensated for by means of design features, measures for site protection or administrative procedures, the site shall be deemed unsuitable.

Proposed sites for nuclear installations shall be examined with regard to the frequency and severity of external natural and human-induced events and phenomena that could affect the safety of the installation. In addition to providing the technical basis for the safety analysis report to be submit­ted to the nuclear regulatory body, the technical information obtained for use in complying with these safety requirements will also be useful in fulfill­ing the requirements for the environmental impact assessment for radio­logical hazards. Site selection is discussed in more detail in Chapter 18 of the present book.

In addition, one should not forget to examine the electrical grid potential to receive the electricity production from the plant and make sure of its adequacy or plan the necessary modifications. This is discussed in more detail in reference IAEA (2007b), Milestones in the Development of a National Infrastructure for Nuclear Power, NG-G-3.1.

Independent review and assessment

The review of the compliance with safety principles, goals and criteria, using the information provided by the licensee, is a critical task. This information needs to be accurate and should be sufficient to demonstrate the safety of the nuclear power plant considering, among other factors, the site interac­tion with the plant, the operational limits, test acceptance criteria for com­missioning, all safety-related features of the design, safety of the operational modes and plant states, and decommissioning aspects.

All plant states (normal operation, anticipated operational occurrences and accident conditions) have to comply with the regulations and safety criteria. Therefore it is essential that the regulatory body defines and makes available to the operator the regulations and criteria and the basis for com­pliance that are to be applied during reviews and on which its judgements and decisions are based.

The regulatory programme for review and assessment includes all stages of the development of the nuclear power plant — from initial selection of the site, through design, construction, commissioning and operation, and including decommissioning until the plant is released from regulatory control. The review also covers deterministic and probabilistic safety analy­sis as needed to verify safety. A set of conservative deterministic rules and requirements for the design and operation of the plant or for the planning and conduct of activities is prepared for anticipated operational occur­rences and postulated accident conditions. The probabilistic safety analysis determines all safety-significant contributors and evaluates the safety balance of the plant. One of the outputs is to verify the probabilistic safety criteria, if they have been defined. Probabilistic approaches provide insights into the reliability of the plant systems, interactions and weaknesses in the design, the application of defence in depth, and risks that it may not be possible to derive from a deterministic analysis.

The regulatory body specifies the time frame for submission of all neces­sary documentation, indicating the period of time that is considered neces­sary for the review and assessment process; this facilitates the process and minimizes delays in granting the license or any other authorization. Usually, the licensee needs to carry out additional work to complete the information for demonstration of safety. In such cases it is very beneficial to monitor the progress of documents by the operator and the progress of the review and assessment process taking into account a tentative schedule agreed by the operator and the regulatory body.

The safety analysis performed by the licensee and the results of regula­tory review and assessment are major relevant inputs to define the regula­tory inspection programme.

In the pre-licensing stage, it is necessary to arrange an early regulatory review and approval of the proposed design safety requirements, for the plant selected and the review of the key features of the design to identify safety issues that would require modifications, development, or additional analysis in order to achieve an initial regulatory approval.

Basic characteristics of regulatory organizations

There are several basic characteristics of regulatory organizations reflecting the nature of their regulatory activities. The two most relevant characteris­tics, which also distinguish their regulatory functions, are:

• regulatory independence

• interfaces with other regulators and coordination.

4.2.1 Regulatory independence

The fundamental element of a regulatory organization is the establishment of effective regulatory independence. The reason for this independence is to ensure that independent regulatory decisions can be made and regula­tory enforcement actions taken without pressure from outside interests that may conflict with safety. The independence to take regulatory decisions affords credibility to the regulatory body in the view of the general public; the regulatory body must be seen to be independent of the organization that it regulates as well as independent of governmental organizations and industry groups that promote nuclear technologies.

The importance of regulatory independence is affirmed in the Convention on Nuclear Safety. Article 8.2 of the Convention requires: ‘. . . an effective separation between the functions of the regulatory body and those of any other body or organization concerned with the promotion or utilization of nuclear energy’ (IAEA, 1994). However, this condition is necessary but not sufficient to obtain effective independence to regulate safety. There are internationally recognized elements that need to be considered, i. e. political, legislative, financial, competence, public information and international col­laboration elements; these will be discussed in more detail below. A regula­tory body cannot be absolutely independent of other parts of government: it must function within a national system of laws and budgets, just as other governmental bodies and private organizations must do. Nevertheless, for the regulatory body to have credibility and effectiveness, it should have effective independence in order to be able to make the necessary decisions in respect of protection of workers, the public and the environment. INSAG has addressed the importance of independence in regulatory decisions (INSAG, 2003).

1. Political elements. The political system needs to provide clear and effective separation of responsibilities and duties of the regulatory body and those of organizations promoting or developing nuclear technologies. The regulatory body should not be subject to political influence or pressure in taking decisions relating to safety. The regulatory body should, however, be accountable in respect of fulfilling its mission to protect people and the environment from undue radiation hazards. One way of ensuring this accountability is to establish a direct reporting line from the regulatory body to the highest levels of government. Where a regulatory body is part of an agency or organization that has responsibility for exploiting or pro­moting the development of nuclear technologies, there should be channels of reporting to a higher authority that has safety as one of its primary mis­sions and to which the regulatory body is clearly accountable when resolv­ing conflicts of interest that may arise. This accountability should not compromise the independence of the regulatory body in making specific decisions relating to safety with neutrality and objectivity.

2. Legislative elements. The functions and independence of the regulatory body with respect to safety should be defined in the legislative framework of the national regulatory system (i. e. in the laws or decrees relating to nuclear energy). The regulatory body should have the authority to adopt or to develop regulations relating to safety that give effect to laws enacted by the legislature. The regulatory body should also have the authority to take decisions, including decisions on enforcement actions. There should be a formal mechanism for appeal against regulatory decisions, with predefined conditions that must be met for an appeal to be considered.

3. Financial elements. The regulatory body needs adequate financial resources to discharge its assigned responsibilities. While it is recognized that the regulatory body is in principle subject to the same financial controls as the rest of government, the budget of the regulatory body should not be subject to review and approval by government agencies responsible for exploiting or promoting the development of nuclear technologies.

4. Competence elements. The regulatory body needs independent techni­cal expertise in the areas relevant to its responsibilities for safety. The management of the regulatory body should therefore have the responsibil­ity and authority to recruit staff with the skills and technical expertise it considers necessary to carry out the regulatory body’s functions. In addition, the regulatory body should maintain an awareness of developments in safety-related technology. In order to assist it in its decision making on regulatory matters, the regulatory body should have access to external technical expertise and advice that is independent of any funding or support from operators or from the nuclear industry; to obtain this advice the regu­latory body should have the authority to set up and fund independent advisory bodies to provide expert opinion and advice and to award con­tracts for research and development projects. In particular, an IAEA general safety guide (IAEA, 2002), suggests that the regulatory body should be able ‘to obtain such documents and opinions from private or public organiza­tions or persons as may be necessary and appropriate’.

5. Public information elements. One of the responsibilities of the regula­tory body should be to inform the public. An IAEA general safety require­ment (IAEA, 2010a) establishes that ‘The regulatory body shall have the authority to communicate independently its regulatory requirements, deci­sions and opinions and their basis to the public.’ The public will only have confidence in the safe use of nuclear technologies if regulatory processes are conducted and decisions are made openly. The governmental authorities should set up a system to allow independent experts and experts represent­ing major stakeholders (for example, the nuclear industry, the workforce and the public) to provide their views on safety and related issues. The experts’ findings should be made public.

6. International collaboration. The regulatory body needs the authority to liaise with the regulatory bodies of other countries and with international organizations to promote cooperation and the exchange of regulatory information.