Legislative and Regulatory Framework Colin Patchett United Kingdom

Legislative and Regulatory Framework Colin Patchett, United Kingdom

Contents • Regulatory Responsibilities • Health and Safety at Work Act 1974 • Ionising Radiation Regulations 1985 • Nuclear Installations Act 1965 • REPPIR 2001 • Nuclear Environmental Impact Regulations 1999

Contents (continued} • The Energy Act 2013 • Fire Safety • Security • Transport • Asbestos • International

First Generation UK Nuclear Sites

Nuclear Licensed Sites

Existing Sites and Proposed NPP

Changing Regulatory Responsibilities • Nuclear power reactor regulation and 1965 Nuclear Installations Act • BNFL Licensing • UKAEA Licensing • AWE Licensing

Health and Safety at Work Act 1974 Some key areas • Health and safety in the workplace in the UK • ALARP, As Low As is Reasonably Practicable • Collecting Evidence • Provision for enforcement, PN, IN etc

Ionising Radiation Regulations • Regulator at Nuclear Licensed sites • Use of Radiation in the workplace • Authorisation, Risk Assessment, Dose Limits, Plans, Designated Areas, Control of Radioactive substances etc • Interfaces with others enforcing IRRs

Nuclear Installations Act 1965 • Power to grant a nuclear site licence • CI can attach conditions • Regulatory controls • Third party Liability Insurance • Duration

Nuclear Installations Act 1965 • Appeals? • Regulatory costs • New Build Cost Recovery, Health and Safety Fees Regs 2012

Nuclear Installations Act • Generic Licence condition applicable to all sites • Originally 35 conditions • Licence condition 36 added in 2000 • Licence condition guidance

Radiation Emergency Preparedness and Public Information Regulations (REPPIR) 2001 • Emergency Planning, Public Information • HSE led • Consultation with stakeholders • Development of guidance • HSE/Nuclear Regulator interactions

Nuclear Reactors (Environmental Impact Assessment for Decommissioning) Regulations • Prior to starting decommissioning • Assessment on environmental impact • Regulator must consult, Environment Agencies, Nature Conservation, Local Authorities etc • No decommissioning work nuclear or non nuclear without CONSENT

Decomissioning • Nuclear Decommissioning Authority, 2004 • Deliver decommissioning and clean up in a cost effective way and where possible accelerate the programme to reduce the hazard • Approx £ 67 billion lifetime cost of clean up • Interfaces

The Energy Act 2013 • ONR Statutory Corporation • Board of Directors • Legal Responsibilities • Enforcement Responsibility

Personal Experience 1987 to 1999 • Management of Health and Safety at Work Regs 1992 • Fire Safety, Regulated by HSE • Interface with Fire Safety • Transport of Nuclear Materials • Interfaces, Emergencies

Personal Experiences 1987 to 1999 • Asbestos removal • Interfaces, risks, dealing with personal injuries during shutdown • Security • Environment Agency

Personal Experience 2000 to 2009 Emergency Planning, impact of 9/11 on REPPIR • Emergency Exercise, planning, objectives, • Follow up, reporting, review of process • Adequacy of REPPIR • National and Local Exercise planning

Personal Experience 2000 to 2009 REPPIR, challenges in developing Guidance • Definitions • Interface Licence Conditions • Interface with Assessment Principles • Emergency dose levels

Personal Experience 2000 to 2009 British Energy • Share sales, emergent safety issues • Ed. F purchase • Licensee Board • Financial standing

Personal Experience 2010 to 2013/4 • The Energy Act 2013 • ONR – Regulation, accountability • Transport regulation • Security regulation • Ionising Radiation

Personal Experience 2010 to 2013/4 • GDA New Designs • Engagement with overseas vendors/licensees • Corporate governance, UK law • Financial standing • Security, design and site

Personal Experience 2010 to 2013/4 Licensing Hinkley Point C • Site suitability • Safety Case, GDA • Management Prospectus • Site Licence conditions

Personal Experience 2010 to 2013/4 Licensing Hinkley Point C • Safety Committee • Consultation • Planning Consent • Other Authorisations

Personal Review 2010 to 2013/4 Licensing Hinkley Point C • Internal Review Process for a new Licence • Documentary evidence • Legal Advice • Review Panel