The interim report of the Nuclear Regulatory Taskforce makes interesting reading. Based on a wide-ranging review of nuclear industry stakeholders, the Taskforce found that the UK nuclear regulator has a good reputation for safeguarding nuclear safety in the UK, but on the downside, the regulatory system is perceived to be unnecessarily slow, inefficient, and costly.

The Taskforce identified “six areas where we see the greatest opportunities for a radical reset”.

As a long-time participant in this regulatory process, my overall impression is that this report makes some valid points. While I am not in position to comment on all the points raised, I can comment on some of the topics from the perspective of someone working on the assurance of control and instrumentation systems (C&I) used in civil nuclear plant.

My comments relate to:

• Risk management and proportionality
• Capacity, capability, culture
• International harmonisation

As this is an interim report, there is an opportunity to provide feedback for the Taskforce final report, so my concluding remarks include some thoughts on potential avenues for contributing to the Taskforce.

Risk management and proportionality

There is criticism that the ALARP (As Low As Reasonably Practicable) principle has been taken to an extreme in determining what level of risk is “Reasonably Practicable”. As noted in the report, the overall approach is risk averse and duty holders are reluctant to “push back” against the regulator. This can lead to more complex designs, potentially increasing costs and causing delays.

Deciding what is proportionate is not an easy job. While I have not seen any examples of pushback by duty holders, I have seen regulation working in a positive sense. For example, when a design was not accepted because it violated an established design principle (such as allowing a lower criticality system to modify the behaviour of a higher criticality one).

More generally, there is scope for gaining stakeholder consensus on proportionality “ground rules” in a less pressured (non-project) environment like UK C&I Nuclear industry Forum (CINIF). CINIF includes both duty holder and regulatory representatives and funds research on approaches to regulation and licensing (including risk-based approaches).

For example,  Adelard, part of NCC Group, is currently leading CINIF research projects on:

• A proportionate approach for assuring lower complexity, limited functionality, smart devices (like pressure sensors or flowmeters) used in safety-classified systems.
• The balance between production excellence evidence from a supplier against additional confidence building evidence from independent assessment.

CINIF could be a suitable forum for a broader stakeholder engagement on approaches to ALARP and proportionality.

Capacity, capability, culture

The scarcity of suitably qualified and experienced (SQUEP) staff is certainly an issue. The lack of new nuclear plant construction in previous decades has led to a decline in SQUEP staff. This is a niche area requiring an understanding of nuclear plant, safety engineering, safety culture, and the ability to make reasoned safety arguments. In recent years, this scarcity has been exacerbated by the need to license novel reactor designs (like SMTs and AMRs).

There is no quick fix for this, but it is important to make a start on developing a larger pool of experienced staff. The Adelard team is actively involved in doing this to handle the increasing demand for assessment services in the nuclear sector.

More generally, it is important to make efficient use of this scarce resource by avoiding duplication of effort. A national policy of sticking to a common fleet design (the strategy employed by France's nuclear sector) could make a big difference in reducing the regulatory burden, as safety assessments for the rest of the fleet would be limited to siting and environment concerns.

International harmonisation

Ideally, in a harmonised regulatory environment, a nuclear plant design only needs  to be accepted once before being deployed internationally. This would be beneficial from many viewpoints, such as a reduced cost for the duty holder, reduced project delay, and reduced burdens on individual regulators.

In practice, this does not happen. A harmonised approach requires mutual recognition of regulatory approaches, and as noted in [1], each regulatory system has its own approach, interpretation of international standards, and legal framework.

These differences were brought into sharp focus for me when I took part in two research projects for the US Nuclear Regulatory Commission (NRC). The NRC has a deterministic, compliance based approach to safety assurance (as defined in NUREGs), while the UK ONR uses a more probabilistic goal-based approach based on safety assessment principles (SAPs). There are also differences in the choice of standards and safety classification levels.  

It must be acknowledged that there is international collaboration to agree common approaches to regulation. For example, there is an agreed common position for licensing critical software [2]<, but some important nations are not involved (such as the USA and France). More generally, any common approach will be restricted to a subset where all regulators are in agreement. So compliance to an international common position would be insufficient for individual national regulators.

In summary, it will be difficult to “square the circle” with such disparate regulatory approaches. One possible workaround is mutual accreditation of regulatory regimes. This would acknowledge that there are differences, but agree that the alternative approaches are sufficiently rigorous to assure safety. This is, however, very unlikely to happen in the short term.

Concluding remarks

• In my view, the biggest win would be a mutual recognition of licensing decisions by another national regulator. But given the disparity of national approaches, this does not look achievable in the short or medium term.
• A more realistic short-term win would be a fleet-based based construction and licensing policy, where a complete series of stations are constructed to a common design that is only licensed once by the UK regulator. This is particularly important for SMRs where many units will be needed for the UK supply needs.
• The Interim Report called for stakeholder engagement in developing recommendations. Members of the UK CINIF consortium should be included in this process. CINIF also have the capability to undertake follow-on research on the recommendations made in the final version of the report.

References

[1]        Nuclear Regulatory Task Force: Interim report, April 2025, https://www.gov.uk/government/publications/nuclear-regulatory-taskforce

[2]        Licensing of safety critical software for nuclear reactors: Common position of international nuclear regulators and authorised technical support organisations, 2022 (Belgium, Germany, Canada, Spain, South Korea, China, United Kingdom, Sweden, Finland)