I have written the letter below to the recently appointed chief Nuclear Inspector, Mark Foy, at the Office for Nuclear Regulation. I am publishing it because I genuinely believe in transparency:
Mark
I've just speed read hundreds of pages the joint regulators released today on the GDA for the Hitachi-GE ABWR.
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www.gov.uk
Detailed assessment of Hitachi-GE’s UK Advanced Boiling Water Reactor: updated and final series of assessment reports.
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Out of these hundreds of pages, I could find only two paragraphs that mention nuclear security issues.
5.17 Nuclear Security (Ref. 47)
http://www.onr.org.uk/new-reactors/uk-abwr/reports/uk-abwr-gda-dac-assessment.pdf
In addition to nuclear safety, ONR is responsible for the regulation of civil nuclear security.
Consequently, and complementary to the nuclear safety specialist assessments summarised elsewhere in this section of the report, ONR has examined Hitachi-GE’s conceptual security arrangements for the UK ABWR.
In particular, ONR specialist nuclear security inspectors considered:
The adequacy (and outputs) of Hitachi-GE’s process for categorisation of nuclear and other radioactive material against theft or sabotage (to provide a proportionate and risk informed basis for its conceptual security plan);
The adequacy (and outputs) of Hitachi-GE’s process for identification and categorisation of critical assets (including Computer Based Systems Important to Safety) and vital areas (VA);
The adequacy and proportionality of the physical protection of identified assets, and demonstration of defence in depth to meet ‘National Objectives, Requirements and Model Standards for the Protective Security of Civil Licensed Nuclear Sites, Other Nuclear Premises and Nuclear Material in Transit’ (NORMS); and
Evidence that safety requirements had been considered when developing security arrangements.
ONR notes that, at a later stage, the future licensee will need to develop site specific arrangements that are compatible with ONR’s Security Assessment Principles (Ref. 51), which has recently replaced NORMS.
ONR is satisfied that Hitachi-GE has satisfactorily conducted a comprehensive VA identification analysis (using a UK design basis threat), and has generated a well-defined list of areas requiring protection.
To prevent unauthorised access to such facilities, Hitachi-GE has adopted ‘defence-in depth’, through which, a series of sequential barriers and access controls ensure that only those personnel with appropriate authorisation can gain access to relevant areas.
As a consequence, ONR is satisfied that the claims, arguments and evidence presented in the Conceptual Security Arrangements are such that, from a nuclear security perspective, the design is suitable for construction in GB.
Could you provide me with this ONR document, and draw my attention to any other references to security assessment in the GDA suite of documents that I may have overlooked. I find the imbalance between one part of the ONR mission, ie safety, to which hundreds of pages are devoted, and security, meriting barely two paragraphs, extraordinary.
Is there any coherent explanation for this. I know Hitachi declined to publish a single word on security. Could you inform me what is the total number of pages their secret security documentation comprises?
http://www.onr.org.uk/new-reactors/uk-abwr/reports/uk-abwr-gda-dac-assessment.pdf
In addition to nuclear safety, ONR is responsible for the regulation of civil nuclear security.
Consequently, and complementary to the nuclear safety specialist assessments summarised elsewhere in this section of the report, ONR has examined Hitachi-GE’s conceptual security arrangements for the UK ABWR.
In particular, ONR specialist nuclear security inspectors considered:
The adequacy (and outputs) of Hitachi-GE’s process for categorisation of nuclear and other radioactive material against theft or sabotage (to provide a proportionate and risk informed basis for its conceptual security plan);
The adequacy (and outputs) of Hitachi-GE’s process for identification and categorisation of critical assets (including Computer Based Systems Important to Safety) and vital areas (VA);
The adequacy and proportionality of the physical protection of identified assets, and demonstration of defence in depth to meet ‘National Objectives, Requirements and Model Standards for the Protective Security of Civil Licensed Nuclear Sites, Other Nuclear Premises and Nuclear Material in Transit’ (NORMS); and
Evidence that safety requirements had been considered when developing security arrangements.
ONR notes that, at a later stage, the future licensee will need to develop site specific arrangements that are compatible with ONR’s Security Assessment Principles (Ref. 51), which has recently replaced NORMS.
ONR is satisfied that Hitachi-GE has satisfactorily conducted a comprehensive VA identification analysis (using a UK design basis threat), and has generated a well-defined list of areas requiring protection.
To prevent unauthorised access to such facilities, Hitachi-GE has adopted ‘defence-in depth’, through which, a series of sequential barriers and access controls ensure that only those personnel with appropriate authorisation can gain access to relevant areas.
As a consequence, ONR is satisfied that the claims, arguments and evidence presented in the Conceptual Security Arrangements are such that, from a nuclear security perspective, the design is suitable for construction in GB.
The Design Acceptance Confirmation (DAC) document makes a single reference to an ONR document.
| Step 4 Assessment Report – Security, UK ABWR GDA - ONR-NR-AR-17-026, 2017/98310 |
Could you provide me with this ONR document, and draw my attention to any other references to security assessment in the GDA suite of documents that I may have overlooked. I find the imbalance between one part of the ONR mission, ie safety, to which hundreds of pages are devoted, and security, meriting barely two paragraphs, extraordinary.
Is there any coherent explanation for this. I know Hitachi declined to publish a single word on security. Could you inform me what is the total number of pages their secret security documentation comprises?
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