When will NII grant a Nuclear Site Licence?

The NI Act states that "...no person shall use any site for installing … [a nuclear reactor or any other prescribed nuclear installation] unless a licence to do so has been granted…". This means that a nuclear site licence must be granted to a developer by HSE before they may undertake construction work which could, if inadequately conceived or executed, affect nuclear safety when the plant is operating. Based on this, HSE defines the point beyond which a licence is required as the placement of the first structural concrete for buildings with nuclear safety significance. Consequently, it may be permissible for a developer to undertake excavation of building foundations and placement of the blinding layer before a nuclear site licence is granted.

The power companies interested in developing new nuclear power stations have identified a number of potential sites around the country.  For any particular site the developer’s site licence application must show that there are no geological or other conditions present that could affect the safety of the proposed nuclear power plant.  To establish whether the ground conditions are suitable or not, potential licensees will need to carry out preliminary site investigation work, usually in the form of geological mapping, boreholes and shallow trenches.  Of necessity this work must be carried out before a site licence application is made. The site investigation work itself does not require a licence or approval from the HSE and does not imply that the site will ultimately be licensable for nuclear development.  If the results of the site investigation were to show that the site was unsuitable, (the IAEA Guide NS-G-3.6 and the NII SAPs give some guidance on the sort of ground conditions that would preclude development), then no application is likely to be made or if an application were to be made it could be rejected by HSE.  Developers may also decide to make a start on enabling works such as initial ground works, access roads and temporary buildings and inasmuch as these do not affect nuclear safety they can proceed prior to a nuclear site licence being granted subject to planning authority agreement.

HSE is also prepared to consider granting a nuclear site licence at an earlier stage, should this be sought by a prospective licensee.

HSE would expect a number of factors to have been adequately addressed to enable us to grant a licence. These are set out in Table 1 below.

Progression through stages of construction and commissioning may be controlled through hold points specified under the nuclear site licence conditions.

Table 1: Essential Precursors for licensing
Site identification Nuclear site licences are granted on a site-specific basis, and define the boundary of the licensed area by reference to a plan incorporated into the licence.  Consequently a nuclear site licence cannot be issued until the licence applicant can provide a suitable plan of the site (albeit that the detail of the plan may be modified or refined up to the point at which the licence is granted)
National Nuclear Policy Statement A demonstration of conformity with UK Government siting policies. It would not be prudent for HSE to grant a licence for a nuclear power station site if that site was not on the list attached to the Government’s National Nuclear Policy Statement.
Security of tenure HSE requires a licensee to have full rights of access to and control of the site so that it can satisfy the demands placed on it by NIA65 and the licence.  If the applicant does not own some or all of the identified site it will need a suitable long lease (or leases) or similar evidence of appropriate security of tenure.[*   ‘The licensing of nuclear installations’  -  para 2.23]
Prescribed
activities
The type of plant to be installed must be defined in the licence application as licences for, eg,  nuclear power stations, traditionally include at part 2 of Schedule 1 an explicit description of the reactor type for which the site is being licensed.
Generic Design Assessment & the Pre-Construction Safety Report If the proposed development is for a new nuclear power station, and it has been submitted for Generic Design Assessment, then the design used on the site must have progressed sufficiently far through the GDA process for there to be reasonable confidence that a Design Acceptance Confirmation (DAC) is likely.  However, it is not necessary to wait until this process has been exhausted and the DAC has been issued, to grant a licence.  For similar reasons it is considered that a fully-developed Pre- Construction Safety report is not required as a precursor to licensing.  This position is reinforced in IAEA Standard GS-G-4.1  -  Format and Content of a Safety Analysis Report
Generic Siting Envelope HSE expects designs submitted for Generic Design Assessment to be suitable for typical UK sites. To this end, HSE will expect the licence applicant to demonstrate that the characteristics of the site for which the licence is sought are within the generic siting envelope for that design or justify a departure.[ *  See Appendix A of ‘Nuclear Power Station Generic Design Assessment – Guidance to Requesting Parties’. ]
Organisational Capability HSE requires the licence applicant to submit a safety management prospectus showing that it has an adequate management structure, safety management arrangements, resources and competencies to discharge the obligations associated with operating a nuclear site.  HSE expects the prospectus to show how the licence applicant proposes to develop its organisational capability to remain in control of activities on its site, understand the nuclear safety and security implications of its activities and how to control them, and be an "intelligent customer" for any work it commissions externally.
Conceptual Security Plan OCNS will expect significant progress in developing the conceptual security plan to have been made prior to site licensing.
Mandatory Consultation NIA65 s.3(1A) requires HSE to consult the appropriate Environment Agency prior to granting a nuclear site licence.
Adequate Licence Condition Compliance Arrangements Before granting a licence HSE would need to be satisfied that the prospective operator had developed, and possessed the capability to implement, adequate licence condition compliance arrangements for the construction phase of the site. 

Blinding layer; A layer of (typically) unreinforced concrete placed on top of soil or rock at the foundation level to seal it against degradation, prevent soil intrusion into the foundations and to act as a working platform for future construction.