A Systematic Evidence Based Performance Approach to Regulation of Nuclear Sites in England and Wales - 20058
The Environment Agency for England has developed a systematic evidence-based approach to pursue our strategic environmental objectives for the regulation of nuclear sites. We use an annual evidence review process to ensure effective and efficient targeting of limited resources to achieve those objectives. Over the last 8 years, we have been developing and refining this approach to ensure risk-based and value driven regulation. The approach comprises nuclear site and nuclear sector review processes known as Site Environment Review (SER) and Nuclear Environment Review (NER). This approach complements our regulation of nuclear site permit holders under the Environmental Permitting Regulations (EPR). We deliver our regulation of nuclear sites in England and Wales alongside the Office for Nuclear Regulation. The SER process involves the lead regulator for each nuclear site assessing the permit holder's environmental performance across 14 themes, set within the context of the site's main activities and associated waste disposals. Our themes include environmental leadership, resources and climate change, radioactive waste management, facility management and decommissioning, groundwater, and environmental radiological protection. We use evidence from site inspections and working within our subject matter groups to grade current and predicted future environmental performance. We are particularly interested in sustainability and the application of Best Available Techniques (BAT) to prevent the creation, and minimise the disposal, of radioactive wastes. We use risk analysis (strengths, weaknesses, threats and opportunities) to examine performance against our strategic environmental objectives, which are set out, in our 5-year Nuclear Delivery Plan (NDP). The output supports the targeting of our resources at each nuclear site. We consult the relevant permit holders on the SER priorities and use their feedback to refine our plans. We expect all permit holders to take account of our priorities when considering their own programmes of work, objectives and plans. The NER process brings together what we learn and achieve through regulation across the sector. It provides input to planning priorities, supported by qualitative and semi-quantitative evidence. It covers the 28 nuclear sites in England and Wales and spans the same 14 environmental themes. During the process we collate, compile and summarise evidence from the SERs and other sources such as inspection reports and evidence from our other nuclear work programmes. The output is the NER annual report. This provides a snapshot of the status of the nuclear sector and gives insights to enable us to regulate more efficiently and effectively. It also takes account of cross-cutting issues and risks such as changes in international standards, domestic policy, regulatory framework, domestic standards and guidance, learning from experience such as incidents, events and good practice, and innovation, research and development. It provides graphics that illustrate the grading of environmental performance for the nuclear sector across the fourteen environmental themes. This analysis allows benchmarking of nuclear site's environmental performance and the visualisation provides a convenient comparison of performance across themes, sites, and over time. We use this intelligence to inform our investment in training and development of our staff, and our cross-cutting engagement on strategic issues with government, the Nuclear Decommissioning Authority (NDA) and other corporate organisations. Adopting this approach can provide benefits with organisational reputation, stakeholder participation and ensuring value from the public investment. This paper describes the history of the SER/NER process, a selection of outputs from the process and ideas for improvement. The paper will be of interest to other regulators and organisations across the world that are interested in supporting continuous improvement. (authors)