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 EdF 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 to2013/4 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