Not protectively marked AS/LOB Rev 01 1 Nuclear safety, security and safeguards interfaces in operation: An EDF perspective Andy Spurr, Managing Director, EDF Energy Nuclear Generation 12 June 2013, Westleigh, Preston

Not protectively marked AS/LOB Rev 01 2 The regulatory framework in which we operate As an operator of civil nuclear power stations, EDF Energy Nuclear Generation (NG) has a number of regulators including:  Office for Nuclear Regulation – safety, security, safeguards and transport  Environment Agency/Scottish Environmental Protection Agency  Health and Safety Executive – Field Operations Directorate There is a significant quantity of legislation including:  Health and Safety at Work etc Act 1974  Nuclear Installations Act 1965 (as amended)  Ionising Radiations Regulations 1999  Environmental Permitting Regulations 2010 (Radioactive Substances Act 1993, Pollution Prevention & Control Act 1999, Water Resources Act 1991)  Radiation Emergency Preparedness and Public Information Regs 2001  Nuclear Industries Security Regulations 2003

Not protectively marked AS/LOB Rev 01 3 Aspects of the Nuclear Site Licence and its regulation Under UK Law a Nuclear Site Licence must be held by a Corporate Body (a Company). Accountability is through the Nuclear Generation Board. The Nuclear Site Licence requires the company to set down “adequate arrangements”. The company should comply with its own Licence arrangements and a failure to do so is a breach of the Licence. The company should “Self Regulate” to demonstrate it is self checking and correcting. The Nuclear Regulator (ONR) approves certain aspects of the arrangements and checks compliance with the arrangements and checks the adequacy of self regulation.

Not protectively marked AS/LOB Rev 01 4 NG accountability model CEO EDF Energy Station Director Generation Board (Licensed entity) 3 CNOs, CTO, S&T, HR, Fin Generation Board (Licensed entity) 3 CNOs, CTO, S&T, HR, Fin Station Director Station Directors are the key people The rest support them – not the other way round A g e n t s o f t h e L i c e n s e e

Not protectively marked AS/LOB Rev 01 5 Governance, performance improvement and challenge model Direction Information External regulation Industry peer review Internal regulation Internal controls Peer groups NG Performance Review with CEO NG Executive Team Delivery Teams Safety and oversight, Operations performance, Business performance, People, Risk & internal controls, Engineering governance, Fleet programmes, Lifetime Delivery Teams Safety and oversight, Operations performance, Business performance, People, Risk & internal controls, Engineering governance, Fleet programmes, Lifetime Fleet managers Programme owners Line managers Managing Director accountability reviews Chief Nuclear Officers & Executive Team members Station Directors and Heads of Function Performance improvement and challengeAccountability and challenge

Not protectively marked AS/LOB Rev 01 6 Layers of Oversight: Organisational Defence in Depth Management accountability – the line performance is crucial In-process oversight – self-assessments and reviews Functional oversight – who does it well and can help Independent Internal oversight – critical appraisal from outside the line External oversight - independent

Not protectively marked AS/LOB Rev 01 7 In-process oversight We have several layers of organisational defence in depth which begins with our employees who are all trained nuclear professionals. Personal ownership is critical to the appropriate governance of our business as we all have a responsibility to ensure that our rules, regulations and processes are adhered to and are as robust as they can be. All staff need to be trained to be suitably qualified and experienced persons to enable them to undertake their required roles in support of nuclear safety and operational excellence. We ensure this through application of the systematic approach to training

Not protectively marked AS/LOB Rev 01 8 Line management accountability Normal routes for individuals and line managers to raise resource, workload, priority and resource issues include: -accountability and succession management meetings -Appraisals, team briefs -task observations, peer to peer coaching -Condition reports. If necessary, there are also escalation routes available to individuals and line managers, these include: -Human Resources -Trade Union/Safety and Regulation Division representatives -Safecall – independent, confidential reporting line. In addition, the nuclear safety culture survey (2 yearly) and employee engagement surveys (annually) provide opportunities for individuals and line managers to raise issues related to organisational effectiveness.

Not protectively marked AS/LOB Rev 01 9 Functional oversight Fleet managers and process owners monitor and review progress in their areas. They also report progress and raise resource, backlogs, priorities and work issues to their respective Delivery Teams. The Delivery Teams review monthly progress updates from the process owners and provide challenge on annual deep dives undertaken by fleet managers The Delivery Teams also review and provide challenge on the annual self- assessments undertaken by process owners as part of our Internal Controls process. The NG Executive Team, in addition to the Delivery Team review meetings and the accountability scorecard meetings, also reviews reports from across the business on resources, work, risks, priorities, succession, etc. Relevant reports are then presented to the Licensee Board and Group Board who provide oversight and challenge.

Not protectively marked AS/LOB Rev Independent internal oversight In addition to the accountability and in-process arrangements described, independent oversight is also provided: Safety and Regulation Division via an independent line undertakes surveillances and inspections across a wide variety of areas, including on management resilience. The Safety and Technical Director has a by-pass route if necessary Quality Department undertakes audits of all process areas EDF Energy internal audit function also provide independent internal oversight and report findings to the line, the executive, and the licensee board on a regular basis, with escalation routes available if necessary.

Not protectively marked AS/LOB Rev Independent external oversight Regulators – through formal inspections and interactions – real process, real impact (e.g. start-up after outages) The Nuclear Safety Committee comprises Station Directors, senior managers from the central support functions and includes a number of respected external independent members. The Training Standards and Accreditation Board includes respected external independence and oversight to challenge NG’s training and development arrangements The EDF Group Inspector General for Nuclear Safety and Radiation Protection undertakes an independent oversight role of NG performance on behalf of EDF SA. Third party independent audit of efficacy of our arrangements and their implementation is undertaken by Lloyds Register Quality Assurance (LRQA) Industry peer reviews are undertaken through the World Association of Nuclear Operators (WANO) and through frequent benchmarking.

Not protectively marked AS/LOB Rev Safety performance results

Operational performance results

Not protectively marked AS/LOB Rev Correlation between safety and commercial performance UCLF = Unplanned capability loss factor Good

Not protectively marked AS/LOB Rev Common goal for regulators and operators Nuclear safety is our overriding priority

Not protectively marked AS/LOB Rev Opportunities Regulators to develop an ‘onion model’ to improve integration and consistency of approach Extend the use of the Regulatory Nuclear Interface Protocol to all regulators who interact with the operators – measure the effectiveness and learn lessons Hold relationship workshops with other regulators/operators and between different regulators/key Government departments – share and widen perspectives.

Not protectively marked AS/LOB Rev Challenges Is the current regulatory framework pushing operators away from maximising safety through minimising risk? We need a shared understanding of ‘where risk comes from’.