MDEP STC Self Assessment Report

Multinational Design Evaluation Programme
Self Assessment 2012

Date: 4 March 2013
Validity: until next update or archiving
Version 3

MDEP STCSELF ASSESSMENTREPORT
Related to: MDEP Steering Technical Committee

SELF ASSESSMENT REPORTMDEP STC Self Assessment Report

MDEP SELF ASSESSMENT REPORT 2012

MDEP SELF ASSESSMENT REPORTEXECUTIVE SUMMARY

A self assessment of the Multinational Design Evaluation Program was initiated in late 2011 to takestock of the MDEP programme of work, what has been accomplished to date and what has yet to beaccomplished, as well as assess if MDEP activities are enhancing safety of new reactor design reviews andharmonisation. Data was collected from both MDEP members (90 surveys were completed) and external
stakeholders (15 organisations provided input). Input was requested in the areas of goals andachievements of the programme, communications, scope, membership and participation. Feedback from
MDEP members and external stakeholders was generally very positive. The respondents found MDEP to
be a unique and useful forum to connect with experts from other regulators. Most respondents also
believe that MDEP has been successful in achieving most of the goals set out in the terms of reference.
However, there are areas that continue to be a challenge to harmonisation, such as differing regulatory
practices among the member countries. The self assessment found that the format and processes of the
programme are effective and there is not a desire for significant changes in the way the programme isimplemented.
An overall theme that arose from the self-assessment is that MDEP is transitioning from a small
group of regulators who co-operate internally, to a more inclusive organisation that has more interfaces
and co-operative arrangements with other organisations. The observations from the internal and external
stakeholders indicate that these interfaces with external organisations should be expanded to make
MDEP more effective. For example, the conclusions suggest that MDEP is very effective in encouraging
co-operation and harmonisation among the standards development organisation, and provides useful
input to IAEA standard development.
The self assessment identified several actions to improve communications, and make MDEP
activities more effective including:•

Develop an agreed upon definition of convergence to be used for MDEP activities, in the form ofa revision to the Terms of Reference;•

Modify the MDEP Terms of Reference to remove the objective of improving public
understanding and acceptance of safety goals;•

Develop a communication plan that identifies stakeholders and specific communication
products;•

Open at least a part of the MDEP library to non-MDEP representatives and invite non-MDEP
organisations to attend issue-specific working group meetings as appropriate;•

Enhance interactions with its IAEA counterparts to identify areas in which MDEP can provide
useful input to IAEA safety standards under development;

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Identify completion strategies (including final products, recommendations to SDOs or otherorganisations for follow-up activity) in the issue-specific working group Programme Plans;•Continue the activities of the design-specific working groups at least through the construction
oversight phase;•

Address advanced reactor issues, through an STC Subcommittee or Working Group that would
explore the issues of most interest to the MDEP member countries;•

Act quickly to approve the formation of new design-specific working groups (consistent with theexisting Rule of Three for forming design specific working groups);•

Support increasing MDEP membership consistent with the existing guidance, and encourage
participation in MDEP by any national regulators who are considering designs under MDEP
review.

1. BackgroundPurpose:A self-assessment of MDEP was proposed at the September 2011 meeting of the MDEP Steering
Technical Committee (STC). The self assessment was intended to take stock of the MDEP programme ofwork, accomplishments to date and future accomplishments, as well as to assess if MDEP activities areenhancing safety of new reactor design reviews and harmonisation. The self assessment was intended to
identify lessons learned as well as impediments to harmonisation of regulatory requirements andpractices among the MDEP members.
Process:
The STC utilised several inputs to provide insights in to the self assessment including the experience
gained in the pilot project and over the last 4 years of MDEP operation in its current structure. Since
March 2008 when the MDEP was approved in its current form, the Policy Group (PG) has met 6 times; theSTC has met 19 times, the EPR Working Group (EPRWG) 11 times; the AP1000 Working Group(AP1000WG) 6 times, the mechanical Codes and Standards Working Group (CSWG) 11 times, the Vendor
Inspection co-operation Working Group (VICWG) 10 times, and the Digital Instrumentation and Control
Working Group (DICWG) 14 times. It should be noted that other meetings such as design-specificsubgroups meetings and STC subcommittee meetings have also been held. In all, some several thousand
person-hours have been invested in MDEP activities. The experience gained and the lessons learned from
MDEP activities that contributed to this self assessment have been documented in the record summaries
and conference proceedings documents that are contained in the MDEP library and available on the
MDEP public website. Another tool used by the STC were surveys and questions soliciting input frominternal and external stakeholders in order to get a comprehensive picture.
With respect to the internal self assessment survey, the MDEP STC Chair and other STC members,
with input from the NEA, produced a questionnaire for the purpose of requesting pointed feedback fromthose who know the MDEP best – the people who participate in MDEP meetings from the 10 (at thattime) member countries, the IAEA, and the NEA. Proposed survey questions were forwarded to all STC
members and, as a result of feedback from several members of the STC, some questions were modified
and some questions were added to the survey. The survey was then sent to MDEP participants from the
STC, and all working groups. Policy Group members and other senior managers in the participating
agencies who are involved in MDEP activities took part as desired. In addition, the IAEA representatives
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who take part in issue-specific subgroups were also invited to take part, as well as some of the NEA MDEP
technical secretariat.
In all, approximately 90 persons took the survey. Every MDEP member country was represented in
the survey responses. The IAEA and the NEA also provided responses to the survey.
With respect to the role of the respondents, the most frequently represented group was the EPRWG
and its subgroups at 35 respondents. All of the other working groups had significant responses, as well. It
is notable that all STC members responded (including members of the two STC subcommittees) as well as
4 Policy Group members. Seven persons who identified themselves as MDEP member regulator
management who do not normally attend MDEP meetings also responded.
The goal of the internal self assessment survey was to receive open and frank input from MDEP
participants with the purpose of evaluating if the MDEP activities are meeting the goals of eachparticipant and regulatory body, and to identify improvements that can be made and/or adjustments infuture activities of the MDEP. This was a blind survey with no recording of names or email addresses
although country and working group/committee affiliations were requested. Answers were asanonymous as possible.
A separate survey was distributed to the external stakeholders -- organisations that had interfacedwith MDEP working groups in the past, or had participated in the MDEP conference in September 2011.
This survey consisted of 10 open-ended questions, rather than multiple choice questions. The questions
addressed the role of MDEP, the usefulness of MDEP products, the effectiveness of communications, andwhen MDEP activities should be transferred to other organisations. Surveys were sent to 35
organisations. Fifteen responses were received.
The STC analysed the responses and made 15 specific recommendations to the PolicyGroup at its meeting in May 2012. The Policy Group endorsed the recommendations with minor
modifications. A summary of the findings and actions taken are listed in Section 3 of this report.
2. Analysis of the internal and external survey responses
2.1. Goals and achievements
Internal stakeholders were asked how they thought that their activities helped reach the MDEP goals
and objectives, expected outcomes, and challenges facing the Working Groups.
The MDEP Terms of Reference (ToR) defines the MDEP goals and objectives as (1) enhancing
multilateral co-operation within existing regulatory frameworks, (2) facilitating multinational convergenceof codes, standards and safety goals, (3) facilitating licensing of new reactors, (4) encouraging safer
reactor designs, (5) enhancing co-operation between regulators on design reviews, (6) improving public
understanding of safety, and (7) encouraging global standardisation. The internal survey’s participants
were asked how they thought that their activities helped reach these goals. The respondents generally
agreed that MDEP activities were meeting all of these goals except the goal of improving public
understanding of safety.

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The ranking from highest to lowest of the MDEP activities that are meeting these goals andobjectives (survey participants agree or strongly agree that the activity is meeting this goal):1.

Enhancing multilateral co-operation within existing regulatory frameworks (95%);

2.

Enhancing co-operation between regulators on design reviews (89%);

3.

Facilitating licensing of new reactors (81%);4.

Encouraging safer reactor designs (80%);

5.-6. Facilitating multinational convergence, and encouraging global standardisation ( 75%);
7.

Improving public understanding of safety (31%).

The survey participants also were asked if they agreed that the results of their work were helping tomeet the expected outcomes as listed in the MDEP ToRs which include (1) increased knowledge transfer
through the exchange of information between regulators, (2) identify similarities and differences inregulatory practices, (3) move towards convergence on regulatory positions and understand whereconvergence may not be practical, (4) increased stakeholders understanding of regulatory practices, (5)enhanced ability for regulators to co-operate in reactor designs reviews, (6) enhanced ability for
regulators to co-operate in vendor inspections, (7) provide useful input to upgrade IAEA safety standards,and (8) provide useful input to Standards Development Organisations (SDO).
In general, the survey respondents agreed or strongly agreed that the results of the MDEP in theseareas are meeting the expected outcomes. The first two expected outcomes of increasing knowledgetransfer among regulators and identifying similarities and differences in regulatory practices are almost at
100% agreement. Agreement falls off with the issues of increasing stakeholders understanding of
regulatory practices (63%), providing useful input to SDO (62%), and providing useful input to upgrade
IAEA safety standards (54%).
The ranking from highest to lowest of those MDEP activities that are meeting these expected
outcomes is (% that agreed or strongly agreed):1.

Identify similarities and differences in regulatory practices (100%);

2.

Increased knowledge transfer through the exchange of information between regulators (99%);

3.

Move toward convergence on common regulatory positions, etc. (85%);4.

Enhanced ability of regulators to co-operate in reactor designs reviews (81%);5.

Enhanced ability of regulators to co-operate in vendor inspections (73%);

6.

Increased stakeholders understanding of regulatory practices (63%);

7.

Provides useful input to SDO (62%);

8.

Provides useful input to upgrade IAEA safety standards (54%).

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The survey participants were also asked about some of the biggest challenges to meeting the goals,
objectives, and expected outcomes as described in the ToRs. The ranking from highest to lowest of those
who agreed or strongly agreed that these are impediments to successfully meeting MDEP goals:
1.

Differing regulatory practices (90%);2.

Differences in quality assurance requirements (76%);3.

Differences in safety classification (73%);

4.

Pace of work/pressure to meet expected completion dates (65%);5.

Lack of agreement among working group members (59%);

6.

Insufficient direction from the STC/PG (38%).

A notable result was that the top two responses thought to be an impediment “to a great extent”
were the differing regulatory practices (30%) and differences in safety classification (26%). No other
impediment reached over 9% in this category.
Survey participants were also asked what they did not like about MDEP, or what should be changed.
Some members noted that, although progress has been made in some areas, it is not clear that MDEP isany closer to its objective of harmonisation of regulatory requirements and practices.
External stakeholder feedback on the role of MDEP included:-

The primary task of MDEP is co-operation among regulators and it is working well;-

Technical exchanges have been useful to avoid divergence of conclusions in specific technicalareas;-

Harmonisation of regulatory requirements and practices is a prerequisite for co-operation;-

Harmonisation will work best if the member States agree on developing a new risk-informed andperformance based framework to replace the current largely deterministic framework;-

MDEP should not only develop common positions, but agree that the common positions will be
implemented in their national regulations;-

MDEP should not attempt to reach harmonisation through general wording that has to bereshaped/detailed when coming to the national level, or by enveloping requirements of all theparticipants;-

MDEP should provide guidance in similarities and differences in requirements and practices, aswell as proposals for harmonisation;-

MDEP’s role is to facilitate liaison between regulators and identify areas of convergence for use
by SDO;-MDEP is a program in which members can exchange experiences in reviewing the safety of newreactor designs, as well as exchanging information about the methodologies and processes ofreview;

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MDEP is a very effective platform for exchanging information on regulatory practices, partial andfull results of design evaluations, and challenges. Such exchanges are very important for small
and mid-size regulators with limited resources;-

MDEP should be a complementary organisation to the international organisations aimed atcreating generic standards and procedures (IAEA, EC, WENRA, OECD working groups, ICRP).
MDEP should be focused on more specific issues linked to specific types of reactor technologies;-

Industry should be involved in the convergence process for providing data input and making
proposals;-

The role of MDEP is to identify the differences in the different countries requirements, andunderstand the reasons. This is the basis of work on the harmonisation of safety standards;-

MDEP should focus on harmonisation of requirements and practices for specific reactor
technologies, rather than developing generic guidelines similar to IAEA standards.

Use of design-specific work and products
With regard to design reviews, internal respondents to the survey agreed that MDEP interactions areuseful in confirming findings that had previously been made (80%). The respondents stated that MDEP
interactions improved the safety focus of the design review (60%), helped identify previously
undiscovered safety issues (54%), expanded the scope of review (45%), or reduced resources needed toperform the review (15%). It is worth stressing the relatively low number regarding the opinion that
MDEP activities helped reduce the resources needed to perform the design reviews.
Also with regard to the design reviews, the responders overwhelmingly thought that sharing
advanced copies of review findings, requests for additional information and status of the design reviews
were being used by each country. Formulating design specific common positions also was viewed as
extremely positive. External participants, particularly industry, found the sharing of documents among
regulators to be useful.
MDEP issue-specific products
With respect to the use of MDEP products by the MDEP member regulators, the answers to thisquestion are very interesting in that for each of the products mentioned in the question, there are a very
high number of “NA” answers which leads one to believe that these responders are not very familiar withthe particular product. For example, it is highly likely that a DICWG member is not knowledgeable or notaffected by the work of the VICWG and is unlikely to use the Inspection Protocol document or the Vendor
Inspections results database. In addition, it is probably best to look at the percentages who answered at
the extremes of the possible answers – those that answered that either the MDEP product wouldn’t be
used at all or would be used to a great extent. When doing so, the answers reveal the following ranking of
the use of MDEP products by regulators:
1.

Digital I&C Common Positions (33% used to a great extent; 4% not at all used);2.

Participation in witnessed vendor inspections (23% to a great extent; 4 % not at all);

3. -4. Tie between table of upcoming vendor inspections (21% to a great extent; 4% not at all) andvendor inspection protocol document (21% to a great extent; 5% not at all);5.

Comparison of pressure boundary codes (20% to a great extent; 5% not at all);7

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6.

Vendor inspection results database (16% to a great extent; 7% not at all);7.

Position paper on safety goals (17% to a great extent; 11% not at all);8.

Comparison of quality assurance requirements (16% to a great extent; 8% not at all).

It should be noted that if you include the responses for products that will be used “somewhat” by
the regulators, the most used products are Comparison of QA requirements and the Position Paper on
Safety Goals. The next question about the expected benefits of future work provides a more complete
picture of these responses.
When comparing various future products (which are also consistent to some already existing MDEP
products – completed or ongoing) the rankings would be:
1.

Completing Digital I&C common positions (42% to a great extent; 26% to some extent);

2.

Providing suggestions to IEC/IEEE and IAEA to harmonise DI&C standards (41% to a great extent;
25% to some extent);

3.

Performing joint vendor inspections (27.5% to a great extent; 38% to some extent);

4.

Harmonising QA inspection procedures (QA requirements) (23% to a great extent; 44% to someextent);5.

Developing a process to use foreign codes and standards (22% to a great extent; 41% to someextent);6.

Helping SDO converge on specific parts of the codes (21% to a great extent; 39% to someextent);7.

Performing multinational vendor inspections (21% to a great extent; 45% to some extent);

8.

Comparing codes for Class 2 and 3 components (18% to a great extent; 42% to some extent).

From analysis of responses to these two questions, the most used and interesting generic issuerelated products to pursue in the future are clearly DI&C common positions with VICWG following(including QA requirements issues). It again should be noted that the CSWG work with respect to thesoon-to-be released code comparison work, etc., should move up with respect to usage by the regulators.
The majority of external stakeholders stated that they have not used MDEP products. In several
cases, particularly for non-MDEP regulators, they clarified that they had not used the products yet
because their country had only recently made a decision to pursue new build, or they had not decided ona technology yet. Industry responders were generally more likely to use MDEP products, and indicatedthat they found the common positions useful and potentially helpful to IAEA, SDO, and non-MDEP
regulators.
Input to IAEA draft standard reviews
Approximately 70% of MDEP member responders believe that MDEP discussions are helpful tomember reviews of IAEA draft standards (4% believed otherwise and 22% had no opinion).

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2.2. Communications
Regarding communications within MDEP, a large majority of the respondents found communication
between working groups, the STC and the PG to be effective. The internal survey respondents
overwhelmingly found the listed information resources useful with the highest usefulness from email
exchanges with other MDEP members and meetings. The results of the survey are:-Meetings (99% at least somewhat useful with 61% stating very useful);-

Email exchanges with members (98% at least somewhat useful with 61% very useful);-

MDEP website (83% at least somewhat useful with 30% very useful);-

MDEP library (81% at least somewhat useful with 41% very useful);-

MDEP annual report (81% at least somewhat useful with 28% very useful);-

MDEP conference (75% at least somewhat useful with 27% very useful).

A majority found the guidance from the PG, STC and other working groups to be useful. The resultsof the survey are as follows:-

Guidance and input from the STC (96% at least somewhat useful with 44% very useful);-

Guidance and input from the PG (88% at least somewhat useful with 31% very useful);-

Guidance and input from other working groups (87% at least somewhat useful with 20% very
useful).

Suggestions on improving communications
The internal responders provided some feedback about better ways to communicate information
about MDEP to other organisations including:-

Look for opportunities to make presentations at other international meetings;-

Produce an MDEP Newsletter periodically;-

Present program plans and status of work at significant industry meetings;-

Give more formality to MDEP products and allow for a more formal public comment and review
process;-

Invite other organisations to specific meetings as observers;-

Expand MDEP membership;-

Formulate and carry out a communications strategy;-

Some consistent recommendations for improving the MDEP library include (1) ensuring that allpresentations for meetings are placed in the library in a timely manner, (2) reorganising of thelibrary to enhance obtaining information, (3) addressing the Final versus Working areas of thelibrary.

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Suggestions from external stakeholders:-

The external stakeholders noted that they use the MDEP website to obtain information, andsuggested that improvements be made in the layout and structure. Some suggested a more
active channel of information to external stakeholders, such as regular newsletters, orannouncement when new information is posted. Some would like more information on thewebsite. For example, more detailed reports or drafts of issues that MDEP is working on;-External stakeholders expressed an interest in having access to parts, or all, of the MDEP library;-

The annual report is widely read;-

The MDEP conference is well attended but there is too little detail. The conference is not a
substitute for technical meetings and workshops;-

Some responders noted that they received information on MDEP activities through CNRA/CSNI
working groups. Therefore, it is important that MDEP continue to interact with CNRA working
groups, especially WGRNR.

Interactions with other stakeholders
The most frequent external interactions by MDEP working groups and the STC are with the IAEA
representatives, followed by vendors such as AREVA and Westinghouse. This is followed by interactions
with licensees such as EDF, TVO, etc, and interactions with non-MDEP regulators (mostly on a less thanyearly basis). It was perceived by the respondents that many MDEP groups do not interact with thefollowing organisations at all – CNRA/WGRNR, CSNI, WENRA, Mechanical SDOs, and Industry
organisations such as the World Nuclear Association. The responses reveal that some MDEP members do
indeed meet with some of these external stakeholders at least occasionally and we do know that the
CNRA/WGRNR and the STC interact very frequently and that the U.K., Finland, and France are also
members of WENRA and maintain contact with their counterparts. In addition the CSWG maintains veryfrequent contact with the mechanical SDO and WNA/CORDEL as does the DICWG with IEEE and IEC(although it has recently been noted that IEEE has NOT been attending DICWG meetings as they had in
the past – this statement was made several times in the comment section of these questions). The
VICWG initiated contacts with the SDO (including ISO) and WNA in 2012. Also, we know that CNRA andCSNI invite MDEP to give an update at each of their bi-annual meetings which is usually carried out by an
MDEP member or the NEA technical secretariat. The CNRA/WGIP got close relationships with the VICWG
in 2012 (VICWG members attended the WGIP workshop in Switzerland).
The key message from the responses to this question is MDEP should look for ways to reach out tothese external stakeholders and to find opportunities to interact with them about MDEP activities.
With respect to rating the perceived effectiveness and usefulness of interactions with external
stakeholders, interactions with the IAEA (84% rating of at least “somewhat effective and useful”), reactor
vendors (91%), and new reactor licensees/applicants (88%) are by far the highest. Others include NonMDEP regulators (56%), Mechanical SDO (55%), CNRA/WGRNR and CSNI (54%), WENRA (50%), Industry
organisations such as WNA (49% ), and other Industry organisations such as NEI, etc. (39%). It should be
noted that the ratings of interaction with little or no benefit are highest with non-MDEP regulators.
It is clear from review of the responses that MDEP participants find a lot of benefit and efficacy ininteractions with the IAEA, and the reactor vendors and licensees in the design-specific working groups.
83% of the respondents felt that the process of developing common positions has at least been
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somewhat helpful in facilitating useful communications with industry representatives. An example ofhelpful communications with industry was given in the EPRWG work on containment sump issues andcommunications with the vendor/licensees.
It is certain from the work of the DICWG and CSWG that interactions with their respective electricaland mechanical SDO is invaluable in carrying out their work and soon the VICWG will start interactingwith the mechanical SDO on QA issues – although the importance of communicating with theseorganisations may be masked somewhat by the results of this survey response. In their responses to thesurvey, the SDO and industry expressed a desire for more and earlier interactions with MDEP.
It is also clear that future interactions should be explored with all of the external stakeholders but it
does appear that with respect to the benefits of completing MDEP work, the MDEP participants are notconvinced that interactions with non-MDEP regulators will help them accomplish that. This does notmean that further outreach to them should not be undertaken as this would help achieve the goal ofincreasing stakeholder understanding of MDEP activities. Note that in their responses to the survey, thenon-MDEP regulators indicated a desire for more information and meetings beyond the MDEP
conference.
Industry and SDO desire more and earlier interactions. Industry would like to have greater
involvement in WG activities, including participating in meetings and the drafting process of MDEP
position papers.
2.3. MDEP scope and topics
Most of the WG members believe that their working group should continue as long as enoughmembers are interested in interacting (51%), or at least until the current Programme Plan (2012-2013)activities are completed (24%). The remaining expressed no opinion.
Future of issue-specific working groups
Most MDEP members think that issue-specific work should eventually be transferred to anotherorganisation such as CNRA or the IAEA. However, when that should happen was not clear (the majority of
those who answered yes to transferring the issues agreed that a transfer should happen after the current(2012/2013) Programme Plan is completed. There were a significant number that answered that the work
should not be transferred. Note that about half of the respondents chose the “NA” option. The results
were as follows:-

CSWG: Do not transfer (12%), Transfer (Total: 37%, 10% in the near future; 16% after current PP,
11% at some later time); 45% NA;-

DICWG: Do not transfer (20%), Transfer (Total: 37%, 9% in the near future, 14% after the current
PP, 14% at some later time); 50% NA;-

VICWG: Do not transfer (24%), Transfer (Total: 29%, 3% in the near future, 14% after the current
PP, 14% at some later time); 51% NA.

External stakeholders suggested that the generic efforts should be completed after Common
Positions are published, or after clearing an issue.

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Future of design-specific working groups
When asked about the future role of design-specific working groups, it was clear that the working
groups should continue their work on the EPR and AP1000. A majority (56%) of MDEP members answeredthat the design-specific working groups should continue at least until all members have completed thedesign review. A large number also believed that the working group should continue throughout theconstruction oversight phase (28%), or after plant operation begins (19%). 11% believed that the design
specific working group should be discontinued when fewer than 3 MDEP members are still performing
the review. 33% answered the “No Opinion” option.
Some noteworthy individual comments include:-

Working groups should be maintained but with a reduced number of meetings, stressing theimportance of the personal connections made and the rapidity at which information can beobtained from other regulators;-

MDEP should cover operational issues as well;-

Disbanding or transferring a design-specific working group should be done on a case-by-casebasis since reactor design reviews are in different phases but the rule of three MDEP members
should apply;-

Technical specifications and operating instructions need to be reviewed during site licensing
phases so there are advantages of MDEP operations continuing into licensing;-If a subgroup or group is concluded, a report about lessons learnt, etc., should be produced;-

Some expressed a lack of clarity of the future of EPRWG and AP1000WG when the design
evaluation processes are complete in the U.S.A. and the U.K.;-

It would be useful to keep the design-specific working groups active through site licensing.

While this question was not specifically asked of the external stakeholders, an industry respondersuggested that MDEP has a role to play throughout the life of a fleet of plants, since the majority ofaccident risk comes from operation. Backfits that are found necessary as a result of new knowledge or
operating experience should be considered by MDEP and common positions taken such that designs do
not diverge throughout the life of the plants.
Both the internal and external surveys indicate that there is a benefit to maintaining some sort of cooperative arrangements after one or more WG members completes its design review.
Since the self assessment indicates general agreement on the high-level MDEP goals of increased
regulatory co-operation and harmonisation of requirements and practices, the question of the future of
the design-specific working groups (after certification, combined license or operating license) can beaddressed by considering the type and level of activity that would be appropriate to continue to support
those goals. The members of the working group could maintain general communications and regulatory
contacts relevant to:-

Project status;-

Construction inspections (using the MDEP library);-

Construction experience (supporting the WGRNR database);

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Vendor inspections (relevant to AP1000).

These could be accomplished through periodic conference calls (including video conferencing wherepractical) and regular e-mail exchanges. The typical current practice of three working group meetingseach year during the active design review stage would not be necessary or appropriate.
In addition, the working group could be called into action when circumstances called for increased
activity. For example, to support the goal of harmonisation and standardisation, the working group could
begin to co-operating actively when regulators begin addressing situations that could affect the plantdesign such as:- Design changes (e.g. from Periodic Safety Reviews or utility requests);-

New requirements/ practices/ policies;-

Plant corrective actions (addressing construction or operating experience).

Inclusion of Fukushima-related activities
Currently the issue of Fukushima and potential lessons learnt is being discussed at every STC
meeting to ensure that all MDEP members understand the actions being taken by the other MDEP
regulators. When asked about the best way to deal with the Fukushima lessons learnt issue, mostmembers preferred to keep the current process. The results were as follows (a respondent could choose
more than one answer):
1.

Discussed in STC meeting as they are now (46%);2.

Dealt with in design-specific working group as they are now (40%);

3.

Explore possible formation of a Fukushima working group (33%);

4.

No opinion (22%).

Other noteworthy comments include that the Fukushima issues are being handled by otherregulatory groups such as CNRA and this issue should be left to others; issue should be left to designspecific working groups; perhaps have a dedicated subgroup in each design-specific working group.
In general, external participants agreed with the current approach taken by MDEP, to focus
Fukushima discussions in the design-specific working groups.
External stakeholders expressed a variety of views on MDEP’s role in addressing Fukushima lessons
learned including:-Industry responders stated that MDEP should ensure unification of regulatory views as to thereflection of post-Fukushima safety improvement requirements on new reactor designs. It
should identify, review and understand the reasons for different backfit solutions chosen bydifferent countries. While the IAEA and NEA provide high level guidance, MDEP should address
Fukushima-related issues for new reactors for practical use in licensing considerations, andprovide early dialogue with the industry;-

The MDEP design-specific working groups provide a unique forum for ensuring that there areconsistent conclusions coming from the different regulators at the end of the stress test
evaluations or equivalent processes in other countries;

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Others thought that many other groups are already working on Fukushima issues and it is not
the role of MDEP to participate in post-Fukushima activities;-

MDEP could facilitate an international process of assessments for specific reactor designs basedon knowledge gained from Fukushima;-

MDEP should extend the WENRA initiative on safety goals for new reactors to countries outsideof Europe.

Potential new work
Among the internal responses, there was significant interest in addressing all of the new issues listed
in the survey within MDEP. The exact manner in which to undertake this work was not clear although thehighest responses favored new issue-specific working groups. The results of the survey show thefollowing order of support for new issues (note that about half of the respondents chose the “No
Opinion” option and, if the percentages were normalised the results would double but still remain in thesame order):1.

Passive safety Systems (Yes address in some way: 49%, as a working group; 28%; No do notaddress: 6%);

2.

Severe accidents (Yes: 44%, working group: 26%; No: 7%);

3.

Human machine interface (Yes: 41%, working group: 24%; No: 3%);

4.

Startup testing (Yes: 40%, working group: 26%; No: 9%);5.

Construction Inspection Practices (Yes: 40%, working group: 19%; No: 5%);

6.

PSA methodology (Yes: 39%, working group: 20%; No: 8%);7.

Fire Protection (Yes: 38%, working group: 20%; No: 8%);

8.

Design Basis Accident methodology (Yes: 36%, working group: 18%; No: 13%);

9.

Accident/Event categorisation (Yes: 36%, working group: 20%; No: 11%);

10.

Initial operation: (Yes: 32%, working group: 22%; No: 14%).

The issues that are of clear interest to members of design-specific working groups, such as startup
testing and initial operation have relatively high numbers recommending working groups. This may be
explained by the fact that the 6 countries involved in the design-specific working groups probably
answered in the affirmative whereas the other 4 countries did not. If this is true, an option would be forthe design-specific working groups to take these issues on within their work.
Industry believes that MDEP should address some basic issues of tomorrow’s nuclear safetyarchitecture including: design change management, the role of vendors, emergency response, and therole of probabilistic safety goals.
New design-specific working groups
Regarding potential new work on specific designs, of those who gave an opinion, there was interest
expressed in addressing all of the new designs within MDEP. However, this interest, in raw numbers, wasless than that expressed for the generic issues. Also there were differing levels of support based onwhether one would actually participate in such a new design-specific working group. The results of the14

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survey show the following order of support for new design-specific working groups (note that about 60%of the respondents chose the “No Opinion” option and, if the percentages were normalised the resulting
percentages would increase in all areas):
1.

ATMEA1 (Support new working group: 32%, would participate: 15%; No support: 10%);

2.

APR1400 (Support: 28%, participate: 15%; No: 10%);3.

APWR (Support: 28%, participate: 12%; No: 9%);4.

mPOWER (Support: 28%, participate: 18%; No: 11%);

5.

AES 2006 (Support: 24%, participate: 6%; No: 14%);

6.

ABWR (Support: 24%, participate: 13%; No: 13%);7.

ESBWR (Support: 22%, participate: 9%; No: 14%).

Inclusion of advanced reactor review activities in MDEP
A majority of the MDEP members agreed that MDEP should address advanced reactor topics. The
majority believed advanced reactors should be addressed by design-specific working groups when thecriteria are met (30%) or in design-specific working groups for reactor types (such as HTGRs, LMRs, etc.)(11%). The next largest group believes that MDEP should address these issues in issue-specific working
groups for topics applicable to all advanced reactors (20%), while 17% think that MDEP should only focus
on large light-water reactors. The rest expressed no opinion.
The members believed that small modular reactor issues should be addressed in issue-specificworking groups when enough countries agree to co-operate on such issues (34%). A smaller number
thought these issues should be addressed only in design-specific working groups for specific designs andwhen they meet the MDEP criteria for design specific working group formation (27%). Again, 16%
believed that MDEP should only focus on large light water reactors.
2.4. Membership and participation
The internal survey responses indicate that 60% of respondents find the current number ofmembers in MDEP is appropriate; 24% stated that MDEP would benefit from allowing additional
regulatory authorities to attend working group meetings as observers; 23% stated that MDEP would
benefit from additional members; and 7% stated the MDEP would function more effectively with fewer
members. One consistent recommendation was that all MDEP members should actively participate in theworking groups in which they are members.
The internal responders stressed the need for all regulators to participate especially those building
new reactors and the need to coordinate activities with CNRA to ensure no duplication of effort.
There was a suggestion from a non-MDEP regulator that regulators from countries embarking on a
nuclear power program to participate in some MDEP activities as observers.
Industry urged MDEP to accept increasing its membership to the regulators of countries embarking
on new build as participation of these countries will enhance co-operation and will contribute toconvergence of the licensing processes.

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Internal operations
About 70 percent (%) of the MDEP member responders attended every meeting or almost every
meeting. The majority of the rest attended about half of the meetings.
A vast majority (86%) of respondents agree that the frequency of meetings is appropriate. Only
about 4% thought that the group should meet more frequently and 5% thought it should meet lessfrequently.
By far the biggest impediment for MDEP participants to attend MDEP meetings and carry out MDEPrelated functions is “other regulatory work of higher priority” (83% responded that this issue affects theirability to attend meetings and do MDEP work either “somewhat” or “to a great extent”). Other similarly
rated issues in this area are (1) limited agency resources (50%), (2) inconvenient location of meetings(40%), (3) inconvenient timing of meetings (32%), and (4) lack of relevance of topic regulatory work(20%).
Some noteworthy comments on this issue are that sometimes obtaining a visa to attend meetings inFrance is a lengthy process and has affected the ability to participate in MDEP meetings. There was arecommendation to rotate meeting locations to different countries. Also, one responder added thatbudgetary restrictions impede attendance. One member noted that travelling to Paris for every meeting(or almost every meeting), especially the issue-specific working groups, puts too much of a travel burden
on those members outside of Europe.
To some extent it was expressed that, due to visa and budgetary issues with travel, always having
meetings in Paris was inconvenient (although this was not a majority of respondents – 10% stated thatthe meeting location affects their ability to attend meetings “to a great extent”, 30% “somewhat”, and60% “not at all”). There was a recommendation to rotate meeting locations to different countries.
Approximately 88% of the respondents were at least somewhat familiar with their Working Group’s
Programme Plan (PP) with 62% being very familiar with the PP. About 80% of the respondents thoughtthat the PP was at least somewhat useful with 54% thinking that it was very useful.
Feedback about the NEA support as the technical secretariat was generally positive with regard totimeliness and quality of support for meetings and communications and the quality of facilities provided
in Paris. There was a recommendation that NEA should assist with resources (funds) for members toattend.
3. Assessment and recommendations
Several tools were used to assess the status of the MDEP activities including: the results from thesurveys discussed above, the experience of the working groups which consists of thousands of personhours spent on MDEP activities, and the knowledge of the Policy Group’s expectations.
Feedback from MDEP members about the most effective aspects of the MDEP was generally very
positive. The respondents mentioned many times that MDEP is a unique and useful forum to connect
with experts from other regulators. Communication paths have been well established as a result of MDEP
activities and it has become quick and easy to communicate with colleagues from other countries whenissues arise. In addition, the atmosphere of MDEP meetings has facilitated meaningful exchanges among
participants.
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The following are some common general observations from the self assessment, and actions taken
by MDEP to address them:a) Co-operation on design reviews
Both internal and external stakeholders believe that the most effective aspect of MDEP is the
co-operation and exchange of information it facilitates for design reviews. The benefits of cooperating on design reviews were confirmed by the survey, especially in confirming eachregulator’s findings and revealing issues that may not have been identified by another regulator.
The respondents agreed that MDEP interactions increased the safety focus of the reviews.
Action: The STC will continue to oversee the work of the design-specific working groups toassure continued co-operation on a broad range of technical topics.
b) Products of the issue-specific working groups
The self assessment found that all of the current and projected products of the issue specificworking groups are being or will be used by a majority of the MDEP members. MDEP products
are used more often by MDEP members and the industry, but not widely used by non-MDEP
regulators
Actions:c)-

The current working groups will continue with their proposed programme of work andcomplete the products under development.

-

The STC will identify opportunities and facilitate communications with other regulators,
through other international organisations, to make them aware of MDEP products andwill follow an MDEP Communications Plan that addresses these issues.

Convergence of regulatory requirements
The results of the self assessment indicate that the objective of convergence, as stated in the
MDEP ToR, is not clear and is not consistently understood by internal and external stakeholders.
The ToR states that MDEP should focus on convergence of regulatory practices that will develop
into convergence of regulatory requirements. However, absent a commitment that the MDEP
regulators will implement common positions into their national regulations and practices,convergence will be difficult to achieve.
Action: The MDEP Terms of Reference will be revised to clarify the definition of convergence.

d) Improving public understanding of safety
The terms of reference states that an objective of MDEP is to “further public understanding andacceptance of safety goals on an international basis” and an expected outcome is to “increase
stakeholders understanding of regulatory practices on an international basis.” However, theprogramme has taken no specific actions towards this goal. As a result, a majority of members
stated in the self-assessment that MDEP is not meeting this objective. While communicatingwith the public about its activities should be part of MDEP’s programme of work, influencing
public opinion is not a primary objective of the programme.
Action: The wording in the current ToRs will be revised to better reflect what is being done in
MDEP. Specifically, the wording of “acceptance” of safety goals will be removed.

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MDEP SELF ASSESSMENT REPORT 2012e) Communications and interactions with external stakeholders
External stakeholders make use of the products currently available to get information on MDEP
activities, but would like more interaction and more active involvement in MDEP activities.
External stakeholders indicated that they would like to have access to more information
through the MDEP website, access to the MDEP library, and participation in meetings orworkshops.
Actions:f)-

MDEP will continue to produce an annual report and hold biennial MDEP conferences;-

MDEP will develop a Communication Plan that identifies stakeholders and specificcommunication products;-

The design-specific working groups will interact, as needed, with the appropriate
vendors and licensees/applicants;-

The issue-specific working groups will interact, as needed, with SDO and other industry
organisations. The STC will explore additional opportunities such as workshops withexternal stakeholders;-

NEA should explore ways to make more information available through the MDEP
website, and will consider active outreach to stakeholders when new information
becomes available;-

MDEP will explore various options for opening the MDEP Library to external
stakeholders with a focus on regulators from WGRNR first, taking care to protect
proprietary and sensitive information.

Communications within MDEP
A large majority of members have found the communications within MDEP to be effective andthe guidance and input from the STC, PG, and other working groups to be useful, although
improvements could be made to the MDEP public website and library.
Actions: MDEP will explore necessary changes to the MDEP Library to make it easier to use, andcontinue to encourage members to contribute information to the library.

g) Role of MDEP in the IAEA standard development
Most MDEP members believe that MDEP products provide useful input to upgrade the IAEA
safety standards, and that MDEP discussions are helpful to member reviews of IAEA draft
standards. MDEP should be a complementary organisation to the international organisations
aimed at creating generic standards and procedures such as the IAEA.
Action: MDEP will enhance cooperation with its IAEA counterparts to identify areas in which
MDEP can provide useful input to the IAEA safety standards under development. The STC Chair
met with IAEA representatives in June 2012 to better define the roles of MDEP and the IAEA.
h) Future of issue-specific working groups
Many MDEP members believe that the work of the issue-specific working groups should
eventually be transferred to another organisation such as CNRA, the IAEA, etc.

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Action: The MDEP working groups will identify end users of their products. The working groups
will identify completion strategies for the issue-specific working groups using currently
established procedures regarding starting or stopping working group activities. Guidance will be
included in the STC Guidance Document on Programme Plan formulations regarding
identification of end users of working group documents and to encourage early interactions
with these end users.
i)

Future of design-specific working groups
Both the internal and external responders believe that there is a benefit to maintaining some
type of co-operative arrangements after one or more WG members completes its design
review. Most members believe that the design specific working groups should continue at least
until all members have completed the design review, and a large number also believed that theworking group should continue throughout the construction oversight phase. This was
supported by industry responders.
Action: Guidance will be included in the STC Guidance Document on Programme Plan
formulations regarding the preference to continue design-specific working groups through theconstruction phase and to provide means to feedback back new design issues to the applicable
MDEP countries regardless of the status of construction or operation.

j)Inclusion of Fukushima-related activities
Most members endorse the current manner in which MDEP deals with Fukushima follow-up
actions, including continuing discussion in the STC and the design-specific working groups.
External participants believe that the MDEP design-specific working groups should ensuring that
there are consistent conclusions coming from the different regulators at the end of the stresstest evaluations or equivalent processes in other countries.
Actions:-

The STC will continue the current practice related to co-operation on Fukushima followup actions;-

The design-specific working groups will tackle Fukushima lessons learnt and report to
the STC.

k) Inclusion of advanced reactor review activities in MDEPMDEP is not currently undertaking activities as documented in the ToR involving the“implementation of MDEP products to facilitate licensing of new reactors, including those being
developed by the Generation IV International Forum,” with an emphasis on the latter part
regarding advanced reactor designs. A majority of the MDEP members agreed that MDEP
should address advanced reactor topics.
Action: MDEP will follow the currently established processes regarding starting new working
groups to address new designs (including advanced reactor and small and modular reactor
issues).

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MDEP SELF ASSESSMENT REPORT 2012l)Potential new work
The self assessment indicated that there was significant interest by MDEP members inaddressing new issues within MDEP. The two generic issues that ranked highest were Passive
Safety Systems and Severe Accidents. The highest support for working on new designs and forparticipating in a design-specific working group was expressed for the mPOWER, ATMEA1, andAPR1400 designs. A majority of the members responses indicated that MDEP should consider
addressing advanced and small modular reactor issues.
The STC observes that the EPR working group has been very effective. This appears to be partly
because international co-operation was started early in the evaluation process.
Action:-MDEP will continue to include a relatively small number of MDEP topics and keep themclosely connected to topics relevant to new reactor designs;-

MDEP will act quickly to approve the formation of new design specific working groups(consistent with the existing Rule of Three for forming design specific working groups).

m) Membership
The self assessment found that external stakeholders strongly favor allowing more members. In
addition, the MDEP members are generally supportive of opening membership, at various
levels, to more participants.
Action: The MDEP PG will support increasing MDEP membership consistent with the existingguidance, and encourage participation in MDEP by any national regulators who are considering
designs under MDEP review.
n) Participation
More active participation from All MDEP countries in MDEP activities would benefit MDEP
efforts to meet its goals and objectives.
Action: The Policy Group members were requested to provide encouragement and support totheir staffs to actively participate in relevant MDEP work.
o) Internal operations
The self assessment found that MDEP meeting frequency is appropriate, although resource andtime restraints make travelling for meetings difficult sometimes.
Action: To facilitate broader participation by each regulatory organisation, the STC will consider
holding one STC meeting per year in a different MDEP member country, and will consider on acase by case basis and in consultation with the NEA, holding working group meetings in otherlocations.

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