‘The Stakes Are High’Concerns Over UK Nuclear Security Inspections
Use of outdated security documents has escalated concerns about a ‘poor organisational culture’ in the nuclear regulator, reports Wil Crisp
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The UK’s nuclear regulator is using out-of-date security documents as part of its inspections in the civil nuclear sector amid the ongoing energy crisis, raising concerns about oversight standards in the industry.
It is believed that dozens of inspections have been carried out this year without appropriate documents regarding nuclear cyber security and physical security available for inspectors to use.
A total of nine nuclear security “technical inspection guides” currently being used by the Office for Nuclear Regulation (ONR) were due to be reviewed and replaced in January 2022.
As of 29 August 2022, no review process has been completed and the out-of-date guides are still being used, according to analysis of the documents by the investigative journalism organisation Point Source.
The out-of-date security guides being used by the ONR cover a wide range of topics including physical protection systems, cyber security, policing, supply chain security, and emergency response preparations.
The use of the outdated documents by the regulator comes amid a global energy crisis that has sent UK household energy bills skyrocketing due to a global squeeze on the supply of oil and gas.
Amid the ongoing crisis, the Government has pointed to nuclear power as a reliable way of partially insulating the UK from higher global oil and gas prices – with Boris Johnson reportedly set to approve funding for the new ‘Sizewell C’ nuclear power station in Suffolk before he leaves office.
However, there are increasing concerns about the reliability and capacity of nuclear facilities in the UK due to the age of the existing nuclear fleet and a shortage of skilled workers in the industry.
The ONR did not reveal to Byline Times how many inspections had been conducted so far this year using outdated security documentation or how quickly it expects to update the documentation and distribute it amongst its inspectors.
Dr Paul Dorfman, chair of the Nuclear Consulting Group and a former secretary of the Government’s committee examining radiation risks of internal emitters, said the use of the outdated documents related to cyber security and supply chain security in the nuclear sector were of particular concern.
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“Cyber security is a field where the risks change very rapidly and if a cyber attack successfully targets a nuclear facility the consequences could potentially be dire,” he said. “It is absolutely key that these documents are as up-to-date as possible.
“All civil nuclear facilities are officially understood as uniquely risky places, especially in the context of Ukraine and potential cyber attacks. It’s critical that ONR inspectors are issued with relevant and up-to-date documents given the current global security situation.”
Concerns about a potential Russian cyber attack targeting European nuclear facilities has been elevated since Deputy Chairman of the Security Council of Russia, Dmitry Medvedev, issued a veiled threat to Ukraine’s Western allies on 12 August.
“Let’s not forget that the European Union also has nuclear power plants,” he said. “And accidents can happen there, too.”
David Blackburn, chair of Nuclear Free Local Authorities – a coalition of local authorities in the UK and Ireland – said the use of out-of-date security documents by the ONR is “extremely concerning”.
“Wherever nuclear power is being generated, public safety must always be at the forefront of the minds of all those in the industry and current best practice must always be followed,” he told Byline Times. “With nuclear, the stakes are high and the consequences could be severe if standards are allowed to slip.”
‘A Culture of Deregulation’
The latest concerns about the standards maintained in inspections come three years after an internal review was highly critical of the ONR’s “poor organisational culture” in relation to the use of out-of-date documents during nuclear inspections.
In 2019, two-thirds of ONR inspectors were found to be using outdated versions of the regulator’s ‘safety assessment principles’ (SAPs), according to a report released in response to a Freedom of Information request.
The safety assessment principles are used to make regulatory decisions during the nuclear facility inspection.
“A sample group of 15 inspectors were consulted and 10 were found to be holding an outdated reference copy of the SAPs and the inspectors were not aware that the SAPs had been updated since 2014,” the 2019 report found.
At the time, there had been eight revisions to the document and hundreds of individual changes had been made since 2014.
The 2019 report was highly critical of the ONR’s organisational culture in relation to the use of out-of-date documents during nuclear inspections. “Staff members indicated that, having raised their concerns once, they had been unwilling to repeatedly press management for remedial action,” it stated. “It is believed that this reticence may reflect the poor organisational culture prevalent at that time. It was very disappointing that staff concerns were not acted upon.”
The report made several recommendations including recommending that the ONR “identify and implement procedures to maintain robust document control of all such documents in future”.
It also recommended that “a broader and more comprehensive review of other published documents should be considered urgently and used to inform the basis of a proper version control system”.
The ONR did not reveal to Byline Times whether these recommendations had been implemented. But it said that no laws had been broken by using out-of-date documents during inspections and that the continued use of the documents was not a sign of declining standards.
“It is not correct to say we are failing to follow proper processes during inspections,” a spokesperson told this newspaper. “We continue to hold the industry to account against the high standards of safety and security required under UK law.
“The documents in question are internal guidance that we also publish on our website and, irrespective of the internal review date, their status is checked every two months against relevant good practice, international standards or guidance, and current legislation.”
But for Tom Burke, chairman and founding director of the climate change research company E3G, the current failings at the ONR are part of a broader pattern under the current Government.
“What I think we are seeing here is a culture of deregulation,” he said. “The regulators know that there will be no price to pay for relaxing standards. We have a Government that knows that it can’t publicly say that it wants to ‘weaken regulators’ because the public like strong regulators.
“What it does is deregulation by stealth – by simply weakening the ability of regulators to actually carry out their job. This is bad when you find it in relation to the Environment Agency and regulating sewage, but failures to regulate the nuclear industry properly are much more dangerous.”
Burke believes there is a problem with regulatory capture, with the ONR increasingly becoming co-opted to serve the interests of companies in the nuclear sector.
“If the Government wants regulation to work, it needs to put critical and authoritative voices on the boards of the agencies – and it doesn’t do that,” he added. “It packs the boards of agencies with its cronies.”
Dorfman agrees that there is a problem with the regulator failing to maintain an appropriate distance from the companies it is charged with regulating.
“It is a poacher-turned-gamekeeper situation because the ONR is largely made up of a group of former industry figures,” he said. “It is likely that both the security crisis and the energy crisis will both become worse over coming months… The Government and industry are potentially putting significant pressure on the ONR to relax standards with regard to regulation.”
Dorfman said that the ONR needs to provide greater transparency to reassure the public that it is doing its job properly.
Thin on the Ground
In May, it was revealed that the number of reported security issues at the UK’s civil nuclear facilities had hit its highest level in at least 12 years, amid a decline in the number of inspections.
Experts said that the higher number of security issues and the lower inspection numbers raised concerns about the regulator’s capacity to cope with planned expansion in the sector.
Over the past five years, industry figures have repeatedly spoken out about the difficulty of recruiting staff with nuclear expertise.
An annual report published by the ONR in 2018 said: “Despite the increase in numbers, the loss of experienced regulatory staff is creating a thinning of our overall regulatory capability.”
Since then, the ONR has launched several schemes to bolster its workforce with appropriately skilled individuals.
Across the UK’s nuclear sector as a whole, there continues to be significant concerns about a shortage of skilled workers.
The Nuclear Industry Association – the trade body for the civil nuclear industry in the UK – said in January that “the sector must recruit to replace an ageing workforce if it is to avoid future workforce shortages”.
In a survey conducted by the Engineering Construction Industry Training Board, 24 companies active in the British nuclear sector said it was hard to fill vacancies due to lack of suitably qualified candidates.
In April, Boris Johnson said that nuclear power was “coming home” when he unveiled plans for eight new reactors in the UK. He has set a target of 25% of electricity coming from nuclear. That means increasing capacity from 7GW to 24GW by 2050, a process that will be overseen by a new body, Great British Nuclear.
To achieve this goal, it seems that a number of significant obstacles will have to be navigated.