May 7, 1998

Mr. John Holmes, Esq.
Principal Private Secretary to the Prime Minister
10 Downing Street
London SW1A 2AA
United Kingdom

Dear Mr. Holmes:

I am writing on behalf of the International Nuclear Regulators Association (INRA) concerning preparations for the May Economic Summit in Birmingham. This letter addresses the important issue of nuclear safety, which I understand will be discussed by G-7/8 Foreign Ministers in a separate session preceding the Summit itself.

INRA has taken note of statements on nuclear safety in the Moscow Energy Conference Communique (paragraphs 18-20). As an organization whose members are responsible for regulating nuclear power reactors, we are pleased that the importance of nuclear safety was recognized at the Moscow meeting. The existence of competent, independent and efficient safety oversight is in our opinion a fundamental prerequisite for the health and success of any national nuclear power program, particularly in view of the ongoing trend towards electricity market deregulation. However, we believe regulatory issues should have received more specific attention. We hope, given the importance of maintaining high nuclear safety standards in our countries and the need to encourage other countries with less well developed safety standards, the issue of nuclear regulation can be given a higher priority in discussions at the Foreign Ministers meeting and in preparing the final document for the 1998 Summit.

Our Association has a keen interest in both nuclear safety and regulatory issues, given the fact that INRA’s members comprise the highest nuclear safety officials in countries operating a substantial majority of the world’s civil power reactors. As a result of discussions at the past two meetings of INRA, we have developed a short paper which may be useful in deliberations on nuclear safety. The paper outlines some essential considerations we believe must receive the most serious attention, especially during a period when competitive pressures in an evolving electricity sector are likely to generate pressures to reduce resources needed to maintain the highest levels of safety (enclosed).

In addition, we have been considering the issue of how to move from assistance to cooperation in nuclear safety between donor and recipient countries. INRA is in the process of developing a set of fundamental elements of nuclear safety regulation which might aid in that transition. We expect to complete these elements soon.

In this light, we will be working with our colleagues within our respective governments and as a body to have nuclear safety remain on the agenda as an issue which merits continued attention at the highest political levels. If INRA can be of assistance to you in your important efforts regarding nuclear safety, please do not hesitate to contact me.

Sincerely,

Shirley Ann Jackson

Enclosure: As stated

STATEMENT OF THE INTERNATIONAL NUCLEAR REGULATORS ASSOCIATION

All countries which have made a national decision to utilize nuclear technology for energy production must ensure that nuclear safety receives the highest priority. This is particularly important during a period of increasing competition in the energy sectors of many countries.

Different countries will have different energy strategies in which nuclear energy may play a role. Development of a sound nuclear power program requires that basic infrastructure and institutional elements be present from the outset. It is fundamental that a national nuclear program must be developed within the context of an overall energy policy that places a proper focus on public health and worker and environmental protection, for all methods of energy production, including nuclear power.

Significant transformations are now underway in the economic and organizational aspects in most of the world’s electric utility sector, including those which are mature and those which are only now emerging. These transformations include restructuring, privatization, and in some aspects but not all, deregulation of the electricity market intensifying competition and cost reduction.

Elements common to all these evolving situations include increased competition in the electric power industry, placing an increased emphasis on reducing costs. Special attention needs to be given to areas where cost concerns could affect nuclear safety; these include:

- safety margin in design;

- maintenance;

- training;

- safety improvements;

- safety-related research;

- decommissioning funds; and

- loss of key staff.

The following key elements of nuclear safety should be present in every national nuclear power program:

• A national commitment to safety as the fundamental requirement for a nuclear program.

• Basic industrial, technological, and human resource infrastructure should be developed as part of the fundamental basis of nuclear safety.

• An unambiguous recognition that the prime responsibility for the safety of a nuclear installation rests with the holder of the license, while a strong and competent regulatory body shall ensure that each such license holder meets its responsibility. A key aspect of this is a focus on operational safety and the establishment, by the operator, of a system of effective safety assessment and management.

• A legislative and regulatory framework governing the safety of nuclear installations providing for national safety requirements and regulations, undergirded by a robust and coherent licensing regime to guarantee the incorporation of safety into the design, construction, operation, and maintenance of nuclear facilities. This licensing regime also assures the training and competence of nuclear operators. The process should be open and publicly accountable.

• A system of regulatory inspection and assessment, including independent safety analysis by the regulator, to ascertain compliance with terms of licenses, with concomitant enforcement of regulations, including suspension, modification or revocation.

• The regulatory body should implement the legislative and regulatory framework and have adequate authority, competence, and financial and human resources; there should also be an effective separation between the functions of the regulatory body and those bodies concerned with the promotion or utilization of nuclear energy.

• Due to intensifying competition in the electric power industry, regulatory organizations should give increased attention to:

- review of existing licensing requirements;

- enhanced cooperation in safety-related research;

- broader cooperation among regulatory organizations;

- more active monitoring of contractor and subcontractor activity;

- quality of licensee safety management; and

- adequacy of operators’ human resources, including training.

• Finally, increased attention to self-assessment by the regulators themselves, including maintenance and enhancement of the technical, personnel and financial resource capabilities necessary to assure safety in a changing industrial environment should be emphasized.

An important opportunity to assess the degree to which countries utilizing nuclear power are meeting these fundamentals will be the peer review meeting of parties at the International Convention on Nuclear Safety (CNS) which will be convened in April of 1999 in Vienna.

National reports under the Convention are to be submitted in September of this year. The potential significance of the CNS peer review for enhancing global safety is enormous. However, for the meeting to be successful, all parties to the Convention must show the maximum degree of transparency, seriousness, and technical competence in preparing their national reports and participating in the peer review.

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