1 Purpose and scope

1.1 This procedure outlines the format and content to be adopted for the production of the Health & Safety Executive Nuclear Installations Inspectorate’s (HSE/NII) quarterly reports. These reports are provided to local community groups for sites regulated by HSE/NII (see Table 1 for listing). It also covers the distribution of the reports internally and externally to HSE/NII, including placement on the HSE website. Additionally, some guidance is provided to NII inspectors attending the meetings.

2 Background

2.1 The local community groups meet to discuss site matters in relation to the local populace. These groups have no basis in statutes. However, as part of the HSE/NII commitment to make information about inspection and regulatory activities relating to sites that it regulates available to the public, periodically (usually quarterly) reports are produced for distribution to these groups. NII Site Inspectors usually attend the group meetings, as observers to respond to questions from group members and to provide clarification arising from information contained in their reports. There are currently 3 types of local community group, these are: - Site Stakeholder Group (SSG), Local Community Liaison Council (LCLC) and Local Liaison Committee (LLC). The different terminology is mainly historical, and in many cases related to site ownership. There are also some constitutional differences between committees, in chairmanship, meeting venue and frequency, for instance.

2.2 DBERR (formerly DTI) made recommendations about how local community groups should function, and licensee’s arrangements are expected to reflect these.

3 Responsibilities and procedure

Production of the quarterly report

3.1 The Nominated NII Site Inspector or other site inspectors, as locally agreed with the Unit Superintending Inspector (SI), should normally compile the report in draft form after the end of each quarter but no later than 6 weeks from the end of the quarter to which the report relates.

3.2 To promote consistency of approach, the Site Inspector drafting the report should follow the guidance on format and content set out in Appendix A.

3.3 The draft report should be presented by the Site Inspector to the Inspection Unit SI for review.

3.4 The Inspection Unit Superintending Inspector (SI) should review and comment on the draft to the site inspector and when content agree the report with them. The SI with assistance from the Admin Team should aim to have an agreed report available within 8 weeks of the end of the reporting quarter.

3.5 The Site Inspector should email the finalised report to their relevant Divisional administration support account.

Distribution of the report

3.6 The relevant Divisional Admin Team is responsible for prompt distribution of the report to the relevant licensed site and internally within HSE; to facilitate this they should:-

• Finalise the report on the EDRM system (unless already done by the inspector).
• Produce a uniquely numbered covering letter in the nominated Site Inspector’s name (See Appendix B for text of covering letter to be used).
• For the Welsh sites, Trawsfynnd and Wylfa, arrange for the report to be translated into Welsh, through FOD Cardiff.
• Send a covering letter with report attached to site, and/or email them, if agreed with the site.
• Distribute the report by email to the internal HSE distribution list (see Appendix C).
• Monitor 6 weeks after the end of the quarter the status of each report to assist the SI in the timely production of the reports. (see Table 1 for full listing of sites and their local community groups)

Please see flowchart regarding distribution of SSG/LCLC/LLC reports.

3.7 HSE’s intention is to have the report available on its website no later than 10 weeks from the end of the reporting quarter, except in the case of Welsh sites where the aim is 12 weeks.

3.8 The ND Communications and Stakeholder Engagement and International (CASEI) team work with the Communications Delivery Service (CDS) team to publish the reports on the HSE website.

Attendance at local community group meetings

3.9 NII states in the Foreword to the report that its Site Inspectors usually attend the meetings. Attendance by NII inspectors is in the capacity of observer. Inspectors are expected to respond to any questions arising from the NII quarterly reports.

3.10 The points set out below are for guidance purposes for NII attendees:-

1. NII attendees are observers only and therefore should not participate in the general discussions. They should intervene if the meeting would otherwise be misled on matters of health and safety.
2. To emphasise NII’s role as an independent regulator serving the public, inspectors should wear HSE identification and not licensee provided passes. They should sit in an unobtrusive position; not with the licensees’ representatives if possible.
3. At the agenda item for the HSE/NII report, inspectors should introduce themselves and invite any questions or points of clarification on the previously circulated report. Inspectors should not routinely give formal presentations.
4. From time to time it may be appropriate to give a brief insight into the role of the NII in relation to site matters and the legal duty for licensees to comply with the licence conditions when conducting its business.

Appendix A – Format and content of SSG/LCLC/LLC reports

Format and content of SSG/LCLC/LLC reports

This appendix provides guidance for those inspectors involved in producing the above reports. It sometimes specifies the use of standard format and content to promote a consistent approach across all sites.

General guidance for inspectors:

A1 The purpose of the quarterly report is to give an indication, to the public, of the NII's activities and interests on the licensed/regulated site during the period of the report. It should not seek to justify, excuse or otherwise account for any actions taken by the licensee and neither should it cover ground that is more properly the domain of the licensee. The licensee also submits reports to the local committee and these contain the information the licensee wishes to present.

A2 The report should be confined, as far as is possible, to statements about NII activities in relation to the site (which includes regulatory action) and should be based on statements of fact supported by evidence as appropriate. It should not include subjective matters, for example thoughts, opinions or beliefs. Readers may infer NII views from the action we took in each case; eg issued a licence instrument or a formal enforcement notice.

A3 The style is important to the purpose of the report and should be suited to the intended reader i.e. the layperson not the scientist or engineer. It should be written in clear English, be factual, informative and avoid jargon and unexplained abbreviations.

A4 The report should not include information that may pre-empt or compromise any investigation or associated enforcement action. However, a preliminary statement may be made in relation to incidents where an investigation is in hand.

A5 The Site Inspector should not necessarily need to consult the licensee on the content of the draft report as this is NII’s independent report. Regulatory independence must be maintained. However, when in the inspector’s opinion it is necessary to consult the licensee it should only be on matters of factual accuracy. It might be necessary to withhold information in the interests of security, and inspectors should obtain appropriate advice where necessary.

A6 The report may cover more than one site/power station or more than one licensee/employer, e.g. where the regulation of MoD naval base activities is covered, as well as the regulation of the licensee.

A7 Where significant security considerations apply at a site, e.g. Aldermaston, Sellafield etc. building identifiers, numbers and descriptions should not be used in the text. The preference should be to use generalised descriptions of the facility.

A8 The reports are Crown Copyright and as such licensees and local committees should be informed, where necessary, to provide a link to the HSE website rather than copy the reports onto their own websites.

A9 For the report format an NII house-style is available and should be followed, this allows easier publishing on the HSE website. The format set out below represents the house-style (e.g. no paragraph numbering, Font Arial 11).

Standard front page format

 

HM Nuclear Installations Inspectorate

Name of Licensee and Licensed Site (s)

LCLC/LLC/SSG (Written in full)

Quarterly report for (day/month/year to day/month/year)

Foreword

This report is issued as part of the Health and Safety Executive's commitment to make information about inspection and regulatory activities relating to the above site available to the public. It is for distribution to members of the (Name of Committee i.e. SSG, LCLC or LLC) and covers activities associated with the regulation of safety at (Name of Licensed Site). These reports are distributed quarterly and are also available on the HSE’s web site at http://www.hse.gov.uk/nuclear/llc/index.htm. Site inspectors of HM Nuclear Installations Inspectorate usually attend (SSG/LCLC/LLC) meetings and will respond to questions raised there by members of the (SSG/LCLC/LLC). Any other person wishing to enquire about matters covered by this report may contact the HSE’s Nuclear Directorate on 0151-951-3484/3290.

Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS

Report content and format

The report should be in 4 sections as outlined below. The text in brackets contains general guidance to be used in drafting the report. Standard text is also specified (in bold) and this should be included in every report. For a report that covers more than one site then an appropriate listing or table should be used to distinguish between the sites.

Inspections

(In this section provide details of inspections in the form of dates the site inspector(s) or any other HSE/NII inspector has spent on site in the format below as an example)

[Standard text]The Nuclear Installations Inspectorate (NII) Site Inspector(s) made inspections/did not visit (Name of Site) on the following dates during the quarter: -

Site/Station Name

d, d, d etc mmm yyyy
d, d, d etc mmm yyyy
d, d, d etc mmm yyyy

(An option here would be to mention any visits made by other HSE inspectors and the dates of such inspections)

Routine matters

[Standard text in bold below should begin this section]

Inspections at site:Inspections are undertaken at site as part of the process for monitoring compliance with:

(i) the conditions attached by HSE/NII to the nuclear site licence;

(ii) the Health and Safety at Work etc Act (HSWA) 1974 and

(iii) regulations made under the HSWA for example the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999.

This entails monitoring licensee’s actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and any other matters which may affect safety. The licensees/operators are required to make and implement adequate arrangements under the conditions attached to the licence in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation. In this period routine inspections of (site/station) covered:

(Do not quote licence conditions numbers and titles, use general descriptors from the list below to reflect the general inspection areas covered

• Examination, Maintenance, Inspection and Testing.
• Management of operations including control and supervision.
• Staff training, qualifications and experience.
• Modifications to plant, equipment and safety cases.
• Plant construction and/or commissioning.
• Emergency preparedness.
• Incidents on the site.
• Radiological protection.
• Radioactive waste management.
• Decommissioning.
• Organisational Changes.
• Periodic safety review.
• Quality Assurance and records.
• Industrial safety.
• Meeting Safety Reps.

Continue with the standard text given in the paragraph below. This text is intended as a general statement covering routine regulatory business )

[Standard text] In general the arrangements made and implemented by (the site/stations) in response to safety requirements were deemed to be adequate in the areas inspected. However, where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from the (licensee/operator), and the site inspector(s) will monitor progress during future visits. Where necessary, formal regulatory enforcement action will be taken to ensure that appropriate remedial measures are implemented to reasonably practicable timescales.

(Examples of topics to include in the rest of the Routine Matters section are:

1. Annual Safety Review, Outage and start-up meetings.
2. Emergency exercises and review meetings.
3. Significant / topical plant matters (including modifications).
4. Significant / topical safety management matters.
5. Significant / topical compliance matters.
6. Matters related to generic issues that are being pursued with all licensed sites such as waste management, decommissioning, licensee management initiatives etc.
7. Follow-up work related to previous difficulties.)

Non-routine matters

(This section will mainly cover significant incidents on site, the level of detail here will vary, depending on circumstances, but any statutorily reportable radiological events or ministerial reportable events should be covered, as should any events at INES 1 or above. The Inspector should be prepared to respond to queries about incidents on the site; in many cases it will be sufficient to say that an incident is being dealt with in accordance with the licensee's arrangements, which are deemed to be adequate, but say that NII is monitoring the situation or investigating separately where the circumstances surrounding the event merit this response. This is also the section where the background to any formal enforcement actions is described, and a cross-reference to Section 4 should be made.)

[Standard text below should begin this section]

Licensees are required to have arrangements to respond to non-routine matters and events. NII inspectors judge the adequacy of the licensee’s/operators response including actions taken to implement any necessary improvements. (Then either of following statements) Matters of particular note considered during the current period include the following. (OR) There are no items of particular note during the current reporting period.

(Examples of other matters to be covered here include: -

1. Details of any significant radiological issues.
2. Outcomes of team inspections or other special inspections e.g. joint inspections with other regulators.
3. Significant organisational or legal changes affecting site activities.)

Regulatory activity

(This section is to give brief details of licence instruments or formal enforcement notices that have been issued in the quarter. For a report that covers more than one site then an appropriate listing or table should be used to distinguish between the sites.)

[Standard Text should begin this section]

Under Health and Safety legislation NII Site Inspectors, and other HSE Inspectors, may issue formal documents to ensure compliance with regulatory requirements. Under nuclear site licence conditions HSE/NII issues regulatory documents, which either permission an activity or requires some form of action to be taken; these are collectively termed Licence Instruments (LI). In addition inspectors may issue enforcement notices to secure improvements to safety.

(X number or No) LI were issued to the licensee(s) during the quarter: -

(LI Number and date – A brief description of the LI in clear English.)

Optional: (Y number) of enforcement notices were issued during the reporting period:

(IN, PN Reference details and date served with reference back to a paragraph in the Non-Routine Matters section where details should be provided)

Appendix B

The Standard text below should be used in a covering letter to site with the HSE/NII report. In some cases agreements could be made with sites to email the report, if so use the text below in the body of the email message with the report attached as a Word document.

HSE letter headed paper

Dear Site Manager/Director

Licensed Site Name – NII Site Inspector’s Quarterly (SSG/LCLC/LLC) Report

Please find enclosed a copy of the NII site inspector’s quarterly report for the period (day/month/year to day/month/year).

I should be grateful if you would arrange for it to be copied and sent to all full members of the (Site Name and Committee) and to the site’s Safety Representatives.

In keeping with HSE practice, a copy of the report will be placed on the HSE web site, the address of which is provided in the report.

Yours sincerely

 

 

PP By Admin Support

[Inspectors Name]

HM Principal Inspector of Nuclear Installations

Appendix C – Distribution list for SSG/LCLC/LLC reports

The relevant divisional Admin Teams are responsible for distributing the quarterly reports to the following organisations/people both within and externally to HSE. Internal distribution will be by electronic means. If arrangements can be made with external recipients then distribution should also be by email attachments.

List of internal HSE recipients

1. CASEI team – (using the “ND” email account) for publication on the HSE website.  All emails to be marked SSG/LCLC/LLC for website publication.
2. ND Director’s Office (using Technical Assistant’s email account)
3. SI9 Nuclear Policy Group, Rose Court (only send Sellafield and Dounreay reports - using relevant policy personnel email accounts)

4. Press Office

   List of external recipients

5. Site Licensee (for distribution to all members of SSG/LCLC/LLC and the Site Safety Representatives)
6. Defence Nuclear Safety Regulator (CNNRP) (for MOD-related naval sites)

Appendix D – Distribution of SSG/LCLC/LLC reports

Table 1 – Licensed and other nuclear sites – Local community group designation

Licensed & other sites	Type of group
Division 1
Berkeley	SSG
Bradwell	SSG
Chapelcross	SSG
Dungeness A & B	SSG (Joint)
Hartlepool	LCLC
Heysham1 & 2 (single licensed site)	LCLC (Joint)
Hinkley Point A & B	SSG (Joint)
Hunterston A & B	SSG (Joint)
Oldbury	SSG
Sizewell A & B	SSG (Joint)
Torness	LCLC
Trawsfynydd	SSG
Wylfa	SSG
Division 2
Capenhurst (BNGSL)	LSG*
URENCO (Capenhurst)	LLC
Dounreay (includes Vulcan	SSG (Joint)
Harwell (incl. GE Healthcare buildings)	SSG (Joint)
GE Healthcare, Amersham	LLC
GE Healthcare, Cardiff	LLC
Sellafield (incl. Windscale, Calder Hall and LLW repository at Drigg	SSG (Joint)
Springfields	SSG
Winfrith	SSG
Imperial College, Research Reactor, Ascot	None presently convened
Division 3
AWE Aldermaston & Burghfield	LLC (Joint)
Clyde Naval Base (incl. Coulport & Faslane)	LLC
Devonport Royal Dockyard & HM Naval Base	LLC
Marconi Marine (VSEL) Barrow	LLC
Rolls-Royce Marine (incl. Neptune), Derby	LLC
Rosyth Royal Dockyard	LLC

* The BNG Capenhurst site, uniquely, has a Local Stakeholder Group.