Anne Lauvergeon’s recent lecture at the Royal Academy of Engineering included a 'call for a more streamlined approach to nuclear new-build safety regulation in Europe, labelling the need to meet different criteria in 27 separate licensing regimes an “exhausting exercise”'. She said: “It seems to be a national affirmation of authority. It would be easier for them to establish common rules.” Even if Europe adopted a common set of rules, this is still a regional matter in what is now a global industry'.
The current situation presents difficulties for the regulator as well as the builder. For example, NUREG/CR-6947 'Human Factors Considerations with Respect to Emerging Technology in Nuclear Power Plants' includes the following:
"The “Plant Design and Construction” topic is a relatively new consideration. With the rapid advance of technology, a more focused approach to this aspect of the design process, especially in minimizing human errors that impact aspects such as software design and plant construction, may be warranted. Our results also have implications for the NRC’s current HFE-related regulations and design review guidance documents. There are at least three aspects of the current guidance that should be evaluated further:
First, the wording of the regulations and guidance often reflects LWR technology. However, non-light water reactors are viable candidates for near-term deployment, as well as longer-term Generation IV designs. Thus, changes will be needed to address non-LWR designs.
Second, the regulations and guidance reflect current concepts of operation used in today's plants. For example, the current definition of crew member roles and responsibilities reflect the staffing approaches used in older, less automated plants. Another example is that safety monitoring reflects current approaches and LWR technology, such as in the safety parameter display system requirements. Some new plants may employ new concepts of operation and implement new technologies that may not fit the current review criteria.
- Third, the HFE review process and its guidance may have to be modified to accommodate new design and evaluation approaches, such as the use of human performance modeling for HSI evaluation in place of data collected from actual operations crews. The current review guidance is based on a systems engineering process that itself is changing as new design and evaluation methods and tools become available."
Some of these difficulties may originate in the relatively isolated nature of the nuclear sector. Looking to what has become mainstream in other sectors may provide part of the way ahead. Using mainstream fashionable career-enhancing tools and methods helps to attract the 'A' team (to be seen most dramatically in software, where projects with outdated languages struggle to attract talent). Making greater use of Systems Engineering would help to meet the challenges of new designs.
The Case-Argument-Evidence diagram above hopefully conveys the logic. Process standards are based on ISO/IEC 15504:2004 Information technology – Process assessment. They support Process Improvement and Capability Evaluation. A process is not a mechanical thing. Jim Moore defined it as 'a collection of responsibilities', which emphasises the two important aspects; an owner and an outcome.
The relevant standards are:
[ISO 31000:2009 Risk management – Principles and guidelines. This is not a process standard but offers the ability to trade a wide range of risks and opportunities]
ISO/IEC 15288:2002 ‘System engineering – system lifecycle processes’ This is perhaps the key standard.
ISO TS 18152 ‘Ergonomics of human-system interaction – Specification for the process assessment of human-system issues'
ISO/IEC 12207:2008 'Systems and software engineering – Software life cycle processes'
ISO/IEC 20000 'Information technology – Service management'
ISO/IEC 15504 Part 10: Safety extension
The standards would need tailoring, and technical supporting material for the nuclear sector.
The nuclear renaissance poses a challenge and an opportunity. Moving to (mainstream) process standards would be difficult, but the alternatives do sound worse.
Update, in response to off-line questions and comments:
Are process standards really the mainstream? Yes. If you were to take the experience from the CMM and SPiCE communities it is massively bigger than the alternatives.
Quoting the defence sector isn't a recommendation as they can mess things up. Well, they don't get everything wrong, either.
Is HFI / HSI inherently reductionist? To be the subject of a later post, when I have read 'The Closed World', but I think the philosophical answer is yes, alas.
Are these standards just a minimum? No. Process assessment scales range from 'not at all' to 'Optimised'.
Do these standards have enough scope? Yes, for the process part of triangulating with performance and product characteristics.
Is there an umbrella HFE/HFI standard that will provide a comprehensive, integrated process? Coming. ISO 26800 Ergonomics - General approach, principles and concepts
How do we address the full use of operating experience? To be the subject of a separate post on the Argenta-Europ blog. Not a solved problem.