FIRST SEMI-ANNUAL REPORT 2010

Chairman's Preface

It is with great satisfaction that I transmit a full report of the first meeting of the International Advisory Board of the United Arab Emirates Nuclear Power Program. The initiative of the government of the UAE has been welcomed by the world as timely and farsighted. The pursuit of the program entails a great responsibility forall involved, notably regarding safety, security and transparency. I and all the other members of the International Advisory Board feel honored to share in some of that responsibility. We expect to be fully and continuously informed and will do our best to offer advice based on our professional experience and contribute to a safe and successful implementation of the program.

Safety

The International Advisory Board endorsedthe UAE's effort to make nuclear safety thehighest priority

The International Advisory Board (IAB) views safety as a top priority in the development of the UAE nuclear energy program. Board members were heartened to find that the UAE government has thoroughly reviewed the safety requirements needed for embarking on its peaceful civil nuclear energy program. As a first step, the government issued a white paper entitled “The Policy of the United Arab Emirates on the Evaluation and Potential Development of Peaceful Nuclear Energy”, which focused on nuclear safety as an indispensible element in the development of the UAE nuclear sector. Subsequently, the UAE government initiated steps to establish a competent, independent regulatory authority to develop and enforce comprehensive safety regulations and standards to govern planning, design, construction, operation & maintenance, management and decommissioning of nuclear facilities, as well as the use, handling and storage of nuclear fissile, fertile and radioactive materials. Under this emerging regulatory environment the UAE government's goal appears to be to hold nuclear operations within its borders to the highest international standards for nuclear safety and security. This presumes that both the regulator and operators understand their responsibilities for nuclear safety, with the regulator providing safety regulation and guidance and the operator implementing the necessary programs to ensure that the plants operate well within that safety guidance. Looking beyond the borders of the UAE, the government has entered into a range of international instruments and agreements related to nuclear safety.

The Federal Authority for Nuclear Regulation (FANR) was established by Federal Law No.6 of September 2009. Under this legislation, FANR was established as an independent regulatory authority in charge of the task of developing and enforcing binding safety standards and regulations intended to achieve the highest standards of nuclear safety, nuclear security and radiation protection on par with those adopted in the countries with best records in these areas

In briefings by FANR to the IAB, the former outlines its core objectives and responsibilities (see below)

FANR Objectives

Reduce any harmful impact of the use of nuclear technology and ionizing radiation on human life, health and living conditions of both present and future generations, the environment and property,
Keep worker and public exposure to ionizing radiation to a level which is as low as reasonably achievable and
Prevent any diversion of nuclear or radioactive materials and nuclear technology for non-peaceful purposes.

FANR has a responsibility to develop regulations covering all of the following areas:

Selection of a site for the construction of a nuclear facility,
Preparation of a site for the construction of a nuclear facility,
Design of a nuclear facility,
Construction of a nuclear facility,
Commissioning of a nuclear facility,
Operation and maintenance of a nuclear facility,
Closure or a change in the closure date of any nuclear facility,
Decommissioning of a nuclear facility,
Modifications having significance to safety of the management system and organizational arrangements or the systems, structures, and components of any nuclear facility,
Possession, use, manufacture and handling of any regulated material or part of any regulated material in the State,
Import or export of any regulated material into or from the State, subject to any consents required pursuant to the provisions of Law No. 13 of 2007,
Transportation of any regulated material within the State,
Introduction or removal of any regulated material to or from any nuclear facility,
Storage of any regulated material within the State,
Disposal of any regulated material within the State and
Emergency preparedness relating to any nuclear facility. Under the UAE nuclear law, each licensee is responsible for taking all steps necessary to reduce the risk of any nuclear related accident to a level that is as low as reasonably achievable.

Subsequent to issuing regulation, FANR will also have the responsibility to assess the capability of applicants and to issue licenses to those seeking to engage in a regulated activity. Finally, FANR will continue to oversee the performance of license holders through a system of ongoing inspections to ensure that they continuously meet the requirements described in their licenses and applicable regulations and laws.

Briefings provided by the senior management of the Emirates Nuclear Energy Corporation (ENEC) to IAB members also demonstrated that, when establishing the Emirates Nuclear Energy Corporation (ENEC) in December 20, 2009, the UAE government clearly sought to make the development of a safety culture an essential element of the new organization. The government expects the ENEC management and every employee to understand that the success of the UAE nuclear program, as well as its own success, will hinge upon the establishment of the highest safety conditions on the technical and behavioral sides. Quality assurance programs will be built upon proven engineering practices in the selection, design, construction and operation of future nuclear power plants. The ENEC management is also expected to demonstrate its safety minded attitude in its decisions and actions and seek to promote an appropriate safety culture through the development of a safety conscious work environment and open communications. The promotion of an advanced safety culture starts from the first steps towards planning, design and construction, aiming to create an environment that encourages reporting of safety concerns and a questioning attitude as part of a continually improving high quality corrective action program to address any concerns or shortcomings. The IAB found strong evidence that ENEC's requirements and the criteria utilized in its 2009 bidding process, demonstrated that safety was considered as a key factor in the award of the prime contract for the construction of the UAE's first nuclear power plant. It was important to ENEC's decision to purchase the APR-1400 reactor type given that the design provides safety and seismic robustness. Similarly, and as a result of the operational components of its prime contract, ENEC gave significant consideration to the Korean consortium's consistent high performance with regard to reliability and safety. In an effort to ensure its long term sustainability, ENEC included obligations in its prime contract regarding the establishment of a robust capacity building program.

The UAE government has also signaled its commitment to fulfill its safety obligations through entry into numerous international agreements related to nuclear safety. These include the Convention on Early Notification of a Nuclear Accident (1987), the Convention on Assistance in the Case of a Nuclear Accident or Radiological Emergency (1987), the Convention on Nuclear Safety (2009) and the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management (2009).

Safety assessment

The International Advisory Board endorsed the UAE's efforts to make nuclear safety the highest priority in the establishment of FANR and ENEC, including a clear division in the roles and responsibilities of these two entities. With regard to FANR, the IAB found strong evidence of commitment to regulatory independence and competence, including legal provisions designed to insulate regulatory decision makers from outside pressure and to provide the regulatory organization with independent source of funding. In relation to ENEC, the IAB found a serious commitment to the establishment of a strong safety culture as well as indications that the ENEC management fully understands both the importance and the complexity of this undertaking. The IAB supports both FANR's and ENEC's efforts to benchmark themselves against the best regulatory and operator regimes in the world, including their plans to establish cooperative arrangements with other international nuclear regulators and operators. FANR cooperation with its Korean counterpart, Korea Institute of Nuclear Safety (KINS), and ENEC cooperation with the Korean operating organization, Korea Hydro & Nuclear Power Co. Ltd (KHNP) would be of first priority, given the familiarity of the Korean organizations with the design of the APR-1400 and its operation.

The IAB acknowledged and fully supports the UAE program's commitment to work closely with the IAEA as well as the openness of the UAE entities to cooperate with other international nuclear bodies such as Institute of Nuclear Power Operations (INPO) and World Association of Nuclear Operators (WANO). The IAB appreciated the considerable efforts undertaken by both FANR and ENEC, to appoint leaders and experts with appropriate capability and experience, and to deliver a program that meets international safety standards. The IAB was also encouraged by the development of induction training programs for all new ENEC staff that feature a heavy emphasis on nuclear safety.

Safety Recommendations

While the IAB found strong evidence that the UAE entities had given deep consideration to safety related issues involved in the procurement and construction of future nuclear facilities, there was a concern that the same level of consideration had not yet been given to safety related issues involved in commissioning, operation and maintenance of those facilities. Therefore, the IAB recommended that greater resources be dedicated to operational safety, including specialized training courses and secondment for future operating staff to learn from operating units in other countries. Active participation of the ENEC operating staff in the commissioning tests of the first APR-1400 type units being built in Korea, Shin Kori 3 and 4, would be most valuable for gaining hands-on experience
In keeping with the UAE program's openness to international cooperation, the IAB recommended that the UAE nuclear regulators and operators establish formal peer review programs with their counterparts in other countries.
Given the recent establishment of the UAE nuclear industry, the IAB recommended that FANR and ENEC adopt an iterative procedure for filing of design documents and safety analysis that are attached to the license application for the construction of the UAE's first nuclear power plant. (e.g. provision of technical documentation as soon as mature drafts are available to allow for a more comprehensive, and unhurried review and assessment).
With regard to FANR, the IAB noted the important role of the organization's Board of Management, which was invested with ultimate decision making authority from the regulatory perspective. In light of that importance, the IAB recommended that participation on the Board of Management become a full-time position and that, until such time as the UAE industry produces sufficient numbers of experienced personnel, additional training be provided to increase the capabilities and skills of members of the FANR Board of Management.
The IAB also recommended that FANR evaluate the concept of utilizing quantitative versus qualitative safety goals and of introducing safety performance indicators (PI).
The IAB also recommended that ENEC develop further in-house engineering capabilities specifically aimed at continually improving and enhancing the level of safety.

Top

Security

The UAE government supports and complies with numerous international nuclear security related agreements

The UAE has already taken several steps with respect to nuclear security. As previously discussed, the government established FANR to plan and implement a program of nuclear regulation in the area of nuclear security including the physical protection of nuclear facilities and the use, storage and transport of radioactive and nuclear materials. The government also supported the creation of a dedicated group within the already existing Critical National Infrastructure Authority (CNIA) with primary responsibility for the implementation of nuclear security. Together these two entities developed a preliminary Integrated Security Master Plan that reflected the UAE's emerging security related regulatory requirements as well as the IAEA Nuclear Security Guidelines. For example, some components of the preliminary Integrated Security Master Plan included performance background investigations and the issuance of security clearances to individuals working in sensitive roles within the nuclear sector to ensure the reliability of operational personnel. Other components included the establishment of large exclusionary and non-development zones around the proposed sites for future nuclear power plants, as well as the development of internal access controls to protect sensitive areas within any future nuclear facility and the development of a design basis threat following rigorous assessment of potential threats against nuclear facilities established in the UAE. Additionally, the UAE government supports and complies with numerous international nuclear security related agreements including the UN Security Council Resolution 1540, the UN Security Council Resolution 1373 and the International Convention for the Suppression of Acts of Nuclear Terrorism.

Security Assessment

The IAB found that government entities were engaged in serious efforts to establish plans in the areas of nuclear security, including the physical protection of nuclear materials and installations and the use, storage and transport of radioactive and nuclear materials. The IAB endorsed the government approach in developing the Integrated Nuclear Security Master Plan, promoted by the IAEA.

Security Recommendations

While acknowledging the benefits of coordination between FANR and CNIA, the IAB found that boundaries and responsibilities between the two organizations were not consistently defined. As such the IAB recommended that appropriate steps be taken to militate against the risks of gaps or overlaps in responsibility.
The IAB recommended that the government integrate new security measures into the design of nuclear power plants to protect against threats including impact by a large commercial aircraft.
The IAB noted the importance of enhancing the import/export regime within the UAE and recommended that resources be directed at this effort on a priority basis.
The security issue of nuclear power plants is gaining more attention these days due to the increasing security issues by non-conventional asymmetric threats to the society. The IAB recommended a due-diligence effort in pursuing enhanced security measures to protect nuclear facilities.

Top

NON-PROLIFERATION

The UAE government has been active beyond its own national nuclear program to support global non-proliferation efforts

The UAE's peaceful nuclear energy program is living up to its international commitment to non-proliferation: inter alia through renouncing any intention to develop domestic enrichment and reprocessing capability and obtaining its fuel from reliable and responsible international suppliers. Furthermore, the UAE government has been active beyond its own national nuclear program to support global non-proliferation efforts and to enhance confidence in the international cooperation in peaceful use of nuclear power. For this purpose, the UAE government has contributed to the establishment of an international nuclear fuel bank, which would help ensure the supply of nuclear fuel and thus eliminate the need for domestic uranium enrichment capabilities.

The UAE government understands that the concept of physical protection is a fundamental national responsibility, and is committed to fully adhering and complying with its obligations under international non-proliferation agreements. In that vein, FANR has been charged with developing a robust State System for Accounting and Control (SSAC) of nuclear material. The UAE government is also working closely with the IAEA to put in place the agreement between the UAE and the IAEA for the Application of Safeguards in Connection with the Treaty on the Non-proliferation of Nuclear Weapons consistent with the UAE obligations under the Additional Protocol to this safeguards agreement.

Based upon extensive briefing to the IAB, it appeared that the UAE understands the important issues associated with establishing domestic radioactive waste disposal capabilities and is looking into developing a comprehensive waste management system that reflects the highest standards of international practice and excludes domestic reprocessing. While a final waste disposal strategy has not yet been completed, the UAE is considering various final waste disposal options, including deep geologic repository for the waste classes that need very long term isolation.

Non-proliferation assessment

The International Advisory Board welcomed the UAE government commitment to refrain from developing uranium enrichment and spent fuel reprocessing capabilities. The IAB endorsed the UAE decision, also set forth in the White Paper, to support, as it explores in the future various technology options, innovative reactors and full cycle technologies that exhibit enhanced proliferation resistance. This commitment strongly demonstrates the peaceful nature of the UAE nuclear program. The IAB also endorsed the government's deep commitment to fulfill its international safeguards obligations.

Non-proliferation recommendations

The IAB recommended that the government conduct full implementation of the signed agreements and Additional Protocol.
Applying monitoring and control on nuclear transfer among countries is an essential element of the global non-proliferation system. The IAB recommended that the government establish an adequate legislative framework for nuclear export and import control to ensure that transfer of nuclear materials, equipment and technology occurs in a proliferation resistant, secure, safe and environmentally responsible manner with proper inspection when needed.

Top

TRANSPARENCY

The IAB endorsed the UAE government's efforts to achieve and maintain operational transparency throughout the development of the nuclear program

As the UAE government began to appreciate the potential contribution that peaceful nuclear energy could make to meeting national energy requirements in a secure and environmentally responsible manner, it committed itself to the highest levels of transparency. Such an action was deemed necessary in order to gain domestic support and to assure the international community and international nuclear oversight bodies of the peaceful intention of the UAE nuclear program. This commitment was embodied in the UAE Nuclear White Paper, which was made available to the public from the very outset of the UAE program and which included a frank and direct discussion of the motivation behind the UAE's exploration of nuclear energy, as well as a description of the manner in which the UAE would implement any peaceful nuclear energy program.

Following the publication of the UAE Nuclear White Paper, the UAE government took several additional and tangible steps to achieve a high degree of transparency in its program. First, the government has directed all entities within the sector to cooperate closely with the IAEA in all aspects of the UAE nuclear program. Second, the government established FANR as a fully independent body, with its own long-term funding sources and significant protections for regulatory staff to ensure that they could face no adverse actions as a result of a regulatory decision. Third, ENEC's procurement process was designed to allow for joint venture arrangements with foreign investors, which would provide them, not only the opportunity to own equity in future UAE nuclear plants, but would also have a strong operator role. Such a structure would be necessary to provide those foreign partners unfettered access to information regarding the manner in which the plants were constructed and operated. Fourth, the government agreed on the Additional Protocol to its Comprehensive Safeguards Agreement with the IAEA. Finally, the UAE established the International Advisory Board, the entity developing and publishing this report to both review the status of the UAE nuclear energy program and to publish its findings to the public. Together, these steps ensure an unprecedented level of transparency, providing the world with an unobstructed window into the establishment and operation of the UAE's emerging nuclear sector.

Beyond making its White Paper accessible to the general public, the UAE government also undertook other steps to ensure effective public information and engagement on nuclear issues related to health, safety and the environment, including efforts to communicate the basis of its decisions and requirements related to its contemplated nuclear program. Such steps included nuclear awareness commercials designed to raise the public's understanding concerning the UAE nuclear program.

Transparency assessment

The IAB endorsed the UAE government's efforts to achieve and maintain operational transparency throughout the development of the nuclear program. The establishment of the International Advisory Board and the government's commitment to full transparency with the Board, as well as the decision to give the public access to the IABs' reports was recognized as a particularly forward-thinking step to assure transparency. The IAB also strongly supported the government's commitment to working closely with the IAEA. The IAB acknowledged the government's plans to provide educational information to the public regarding the rationale behind the introduction of nuclear power, as well as to inform the public regarding the planned siting of the first nuclear plants and the steps being taken to ensure compliance with national and international standards and conventions.

Transparency recommendations

Noting that, at the time of its first meeting, the proposed location of the UAE's first nuclear power plants had not been announced, the IAB recommended that ENEC develop a comprehensive public awareness program to target the population around the site of a nuclear power plant, including the general public, neighboring countries and international communities. The IAB suggested that the program should be based on prior research about the attitudes, opinions and level of knowledge of the intended audience and that it should describe the need for nuclear energy in terms of its economic feasibility, its contribution to energy independence and how it aligns with the nation's development goals. The public awareness program should also provide a clear understanding of the risks to health and safety and the means and actions taken to manage those risks.

Top

SUSTAINABILITY

The UAE government has committed to approach its peaceful nuclear energy program in a manner that best ensures long-term sustainability

The UAE government has committed to approach its peaceful nuclear energy program in a manner that best ensures long-term sustainability. In order to sustain the nuclear energy program, the UAE government recognizes that it must develop essential nuclear capabilities within the national labor force and particularly among the UAE citizens. To this end, the government has put into force several dedicated training and educational programs, including specialized scholarships and advancement opportunities to ensure that national talent will be capable of fully meeting future staffing requirements of the nuclear program. At the time of its first meeting the IAB learned that FANR and ENEC in association with Khalifa University of Science, Technology and Research (KUSTAR) had granted scholarships to 40 students to study nuclear-related disciplines in a number of distinguished universities in the United States, United Kingdom, France and the Republic of Korea.

The UAE government also understands that a comprehensive strategy for the initial sourcing of fresh fuel and ultimate disposition of spent fuel and other nuclear wastes must be developed to ensure the long term sustainability of the UAE's peaceful nuclear energy program. To meet UAE fuel requirements and assure a steady supply of fuel, the government is evaluating a number of options, including traditional market purchases from a diverse portfolio of suppliers, as well as more innovative concepts such as fuel leasing arrangements. The UAE will also be playing an important role in the proposed establishment of an international nuclear fuel bank. Although the nuclear fuel markets function well today and can be expected to do so in the foreseeable future, the nuclear fuel bank would provide a potential fall-back source for nuclear fuel services such as enrichment, processing or management that were temporarily unavailable through regular channels. On the back end of the fuel cycle, the government is still engaged in long term planning for the management of spent fuel and for the ultimate disposal of nuclear waste. As a necessary part of sustainable waste management, the government has called for the establishment of a dedicated decommissioning fund into which nuclear operators would be obligated to contribute and from which the government would draw funds to cover the long-term decommissioning of nuclear sites and the disposition of nuclear waste.

Sustainability assessment

The IAB found the UAE's focus on human resource development and fuel cycle strategy (including long term management of nuclear waste) to be well placed. Efforts in the area of developing national talent were welcomed and seen to be dynamic, if somewhat narrowly focused to reflect the program's intent to become self-sufficient in the operation of peaceful nuclear power plants. However, the IAB found long-term fuel cycle planning underdeveloped, even when acknowledging that no nuclear fuel is scheduled for loading into UAE plants until 2016, at the earliest. Finally, the IAB noted that work remains to be done in developing and implementing a nuclear liability regime that would encourage sustainable investment in the UAE's nuclear energy sector

Sustainability recommendations

The IAB recommended that the UAE government consider expanding the scope of its human resource development plans beyond the narrow requirements of construction, operation and maintenance of nuclear power plants to embrace research in technical sciences relevant for the nuclear safety. One aim of this research should be to develop in-depth understanding of key safety issues and a capability to independently assess safety of a nuclear power plant.
IAB recommended that the UAE program accelerate the development of an integrated fuel cycle strategy, including methods for securing long term fuel supplies, as well as arrangements for covering the costs of decommissioning of nuclear facilities and the management of spent fuel and other nuclear waste.
With regard to long-term fuel supplies, members of the IAB also recommended that the program explore potential alternatives that exhibit enhanced proliferation resistance to traditional uranium-oxide fuels.
The IAB recommended that work also be accelerated to develop and implement a nuclear liability regime consistent with existing standards embodied in multilateral liability arrangements such as the Vienna Convention on Nuclear Liability.

Top

NEXT PROPOSED TOPICS

Organizational Preparations for Licensing and Inspection;
UAE Preparations to Receive International Transfer of Nuclear Technology;
Site Selection and Risk Evaluation.

Top