In regard to different national practices, authority may be administered at either a national or local (federal) level depending on the laws of the country concerned. There are differences in approach reflecting differences in local legislation (EUR 16801 EN, ISSN 1018-5, 1996; Table 8.2). In the UK, the licensing process for power plant lies with a single licensing authority, the NII. However, in Germany for example, regulatory responsibilities lie with the Ministries of the Federal States. In addition, the licensing of different sectors of the nuclear industry may be administered across several organisations.

There are significant differences across countries on how regulatory technical support is acquired. Few authorities have sufficient in-house technical capability to meet all their requirements within their own organisation. Certain authorities require work to be contracted out to other organisations. In some countries, technical support organisations

Table 8.2. Differences in regulatory frameworks and approach



Administration of authority

National or local

Regulatory regime

Prescriptive or otherwise

Technical support procurement

Maintenance of government-funded TSOs vs. services purchased from commercial companies

Licensing and safety culture

Open or closed

Utility/regulator relationship

Collaborative vs. formal approach

Conduct of research

Focus on current operational or more future needs

EUR 20055 EN (2001).

(TSOs) are supported within the countries’ national safety framework. This is the case, e. g. in Germany and France. In other countries, the regulator may call on various contractors; (usually privately owned or commercial companies) to supply his technical need for the particular work required. This has implications on how an adequate level of technical resource is maintained and indeed on the number of personnel available. There are also substantial differences in the levels of resource (both licensing and technical) available within regulatory authorities.

In the past, the approach to nuclear regulation has varied between national governments and their political persuasions. For example, in the countries operating Russian-designed plant under the former Soviet regime, the safety culture was very different from that of the West. The differences of approach are now much less marked as all these countries move towards common licensing approaches.

There has been a major global influence of US practices in many countries. This is because US-designed plants are in operation in many countries around the world. It has also been a common principle from many regulators that NPPs should be licensable in their country of origin.

In addition, there has been considerable influence from IAEA principles, (Govaerts, 1996; IAEA Safety Standard Series, 2000), which have promoted the safety culture and co-operation between regulator and operator. These cover commonly accepted principles such as operator responsibility for operation and quality assurance principles agreed between regulator and operator, etc.

As a general rule, the investment in nuclear safety has far exceeded that which has been devoted to other industrial operations. As a consequence, the safety standards in the nuclear industry are as high or higher than those existing in many other industries.

Clearly, the licensing of future plants may require some adjustments of regulatory approach. For example, an application for the licensing of a Generation IV system would introduce new safety issues associated with new technology. The further the new system had advanced from existing technology, the greater the regulatory adjustment that would be required.

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