NUCLEAR SAFETY GUIDELINE

Background

The Board of Directors of Iberdrola Generación Nuclear, S.A.U. (the "Company”), as the owner and organization responsible for the operation of nuclear power plants for the generation of electric power, recognises the importance of nuclear safety. Understood in its broadest sense, it is a premise and essential element for ensuring the protection of people, the environment, the facilities and their long-term operation, as well as for safeguarding the global viability of the nuclear industry.

Essential to protect people, the environment and facilities

The Company is aware that an advanced level of safety can only be obtained within the framework of an efficient, harmonic global management model improved on an ongoing basis and in this respect it endeavours to assume its responsibility, convinced that an optimal level of nuclear safety within the context of excellent integrated management will also benefit the Company, the citizens, the environment and the nuclear industry as a whole, and will enable thecorporate sustainability goalsto be achieved.

After 50 years, the generation of electric power using nuclear power plants has accumulated over 14,000 reactor-years of experience, and thanks to this expertise it has been possible to reach a high degree of international consensus on the essential principles, attributes and criteria for ensuring adequate nuclear safety in the short, medium and long term. The original principles of defence in depth, embodied in the concepts of multiple safety barriers, redundancy and diversity, have been ratified and perfected over the last decades and have resulted in multiple attributes and criteria which are enforceable at all levels and throughout the life cycle of nuclear projects. Initially, emphasis was placed on the technological aspects, later on the aspects related to the human factor and lately on the organisational and safety culture aspects.

The above must meet the international obligations in this area through active involvement in the programmes and activities of the World Association of Nuclear Operators (WANO) and compliance with internationally accepted ethical principles and current regulations, including the Convention on Nuclear Safety, the applicable regulations of the International Atomic Energy Agency (IAEA safety fundamentals, requirements and standards), the recommendations of the International Nuclear Safety Group (INSAG) and European Union regulations.

The Company has always been very aware of the importance of the human and organisational factor and of the need to develop a corporate culture at all levels. Consequently, from the outset it has ensured the development of the highest level of standards in nuclear safety. A high degree of quality in corporate management results in a vigorous safety culture at all organisational levels, which implies the guarantee of the integrity of the multiple barriers of the 'defence in depth' framework.

Aware of its responsibility to the citizens, the environment, its employees, shareholders and suppliers and other stakeholders, and to the global nuclear industry, both existing and under development, the Company will endeavour to achieve excellent managementin the safety of its facilities and the radiological protection of workers and the public.

  • Scope of the guideline

    These commitments are undertaken and driven through this Guideline so that all the individuals, bodies and levels of the organisation integrate, ensure and promote nuclear safety in their activities.

  • Guideline consistency and formulation

    This Nuclear Safety Guideline is consistent with the Iberdrola Group's Policies and materialises in the following basic principles for action:

    • Pay due attention to nuclear safety matters owing to their importance, with absolute priority.
    • Comply at all times with the terms and conditions of the official authorisations and all requirements imposed by regulations, in order to attain more demanding levels through self-regulation.
    • Establish an organisation with adequate design, capacity, functions, responsibilities, qualifications, expectations and resources for implementing this Guideline.
    • Ensure that the original design of the facilities and their updating meets the accepted standards, agrees with current design and licensing specifications, and maintains adequate control of the facility's configuration, of the safety margins and of the principles of 'defence in depth'.
    • Encourage the involvement and the commitment to nuclear safety of all individuals at all levels through their individual responsibility, exemplary conduct, teamwork, qualification and ongoing training, within a work environment that creates a favourable atmosphere for reporting deficiencies or opportunities for improvement and fosters swift resolution of incidents, fostering the highest levels of safety culture.
    • Implement, as part of the integrated management system, processes, internal rules and supervision systems that contribute to attain the desired conduct in favour of nuclear safety, and assess the processes, rules and systems in order to achieve ongoing improvement. Stagnation and complacency are considered to lead to declining performance in the area of safety; however, self-criticism and organisational learning are vital elements for improving safety.
    • Measure the results in the area of safety through a system of indicators based on best international practices, providing the resources needed to achieve demanding goals related to those indicators, and oversee the application of this Guideline through the body responsible for independent internal nuclear supervision.
    • Follow previously approved operating procedures inspired by the principles of prevention, surveillance and mitigation, oversee strict compliance with those principles and develop a dynamic of ongoing improvement through the feedback of usage experience, in both normal operation conditions and in emergencies.
    • Use advanced analytic tools for assessing and improving safety, such as probabilistic safety analyses, risk monitors and other risk-informed applications.
    • Establish a “prudent operational decisions” system that guarantees that the matters that are important for nuclear safety are treated with rigour, prudence, diligence and by competent individuals or bodies, with the involvement of those which can add value to the decision-making process, paying special attention to emerging issues of a multidisciplinary nature.
    • Make the most of own and third-party operating experience for preventing incidents through the establishment of an efficient process for exchanging experiences and for analysing causes, and participate actively in the industry's international bodies through an exercise of peer comparison and evaluation, promoting a healthy emulation of the best.
    • Extend nuclear safety management to the suppliers of goods and services through contractual clauses, quality assurance audits, certifications, training, operating procedures, supervision and teamwork at the facilities.
    • Disseminate relevant and truthful information on the activities carried out and promote communication and dialogue with the various stakeholders.
    • Cooperate with the competent authorities in the exercise of their supervision, regulation and public information functions, as guarantors of international commitments in countries where the facilities are located, and contribute to the improvement and optimisation of the regulatory framework.
    • Maintain a long-term vision of nuclear safety through research, development and innovation, with participation and promotion in international forums and in organisations devoted to safety knowledge and improvement.
    • Apply this Guideline as one of the criteria for selecting technologies in the case of new nuclear power plant projects.
  • Complementary considerations

    Within the development of the Guideline are a series of complementary considerations that reflect a commitment to nuclear safety management and which are detailed through the following complementary basic action guidelines:

    • Implement a series of indicators based on international best practices and allocate the necessary resources for reaching goals defined annually, closely related with the most demanding objectives. Within the safety indicators established annually and periodically monitored by Iberdrola Generación Nuclear, we highlight unscheduled shutdowns, reportable events, safety evaluations and analyses, and exposure to radiation by both workers and the general public. The purposes of these indicators are: to minimise the probability of unscheduled stoppages and events, to perform safety evaluations and analyses to reduce risks to the extent possible, and to optimise exposure to radiation of both workers and the general public by implementing the ALARA (as low as reasonably achievable) principle. If any objective fails to be reached in a given year, tendencies and causes will be analysed, corrective actions established and affected indicators reviewed to redefine appropriate goals.
    • Optimise exposure to radiation of both workers and the general public by continuously implementing the ALARA principle. This principle may be defined as the process or method employed for improving, to the extent possible, the efficiency of the protection system, in accordance with limits and criteria established, given the best methods for using resources and reducing radiation-related risks as much as possible for both workers and the general public, taking into account socioeconomic factors. For Iberdrola Generación Nuclear, these criteria materialise through the ALARA programme, which entails:
      • Reducing as much as possible individual doses, number of persons exposed and probability of potential exposures, taking into account socioeconomic factors.
      • Optimising the mode, magnitude and duration of interventions so that the results obtained are the best possible.
    • Risk, understood as the probability of an event occurring in accordance with its consequences, is controlled, limited and minimized by fostering behaviour linked to a culture of safety and to the use of tools related with human factors, such as self-checks, three-way communications, on-site supervision, or independent verifications. These basic action lines are applied to safety, which Iberdrola Generación Nuclear manages in compliance with all applicable legislation, paying particular attention to EU regulations and, when possible, being even more demanding in the voluntary definition of additional criteria for action. This implies, for example, that the probabilistic safety analysis is not used merely for verifying compliance with standards, but rather, for improving, as much as reasonably possible, global results by identifying areas for improvement through advanced "risk-informed application" techniques. The development, maintenance and update of the probabilistic safety analysis are state-of-the-art.
    • Results obtained from the probabilistic safety analyses of different designs are taken into account as one of the important criteria for the selection of technologies for new facilities.
    • Safety, understood as the protection of the facility and the nuclear materials against malicious acts or usage other than that for which these are designed, is a key requirement of Iberdrola Generación Nuclear in the area of nuclear safety, wherefore it is managed in accordance with the same principles applied to the safety of reactors, maintaining the necessary confidentiality-related precautions. Given the above, our objective is not mere compliance with applicable legislation, but rather to aspire to Excellence by applying a continuous improvement cycle and the best international practices.