"Safety Case Management for Nuclear, Defence and Energy."
Scottish Universities Environmental Research Centre Case Study
Scottish Universities Environmental Research CentreSage Safety was involved in the de-licensing of a site where there had been a nuclear reactor licensed by the NII.
Sage Safety helped the client to assemble the safety justification that demonstrated that the site represented no risk to the public, the workforce or the environment. This was done as compactly as possible, an approach that had the full support of the regulator. The site was delicensed and was able to be developed without restriction.Professor Roger Scott writes: -'Sage Safety were engaged by SUERC to assist with the preparation of arather complicated and unusual de-licensing application in respect of thesite of a decommissioned research reactor. The difficulties weresuccessfully addressed and a case was produced in a prompt and highlyprofessional manner at reasonable cost.'
Decommissioning and delicensing the 300Kw research reactor
Sage Safety fully researched and costed a decommissioning method in conjunction with a major building contractor, intended to offer a minimum cost approach, making use of existing staff. A Turnkey contract was eventually awarded elsewhere.
Sage Safety was subsequently contracted to produce the delicensing safety case. Initially this was a straightforward document, satisfying the requirements of the Regulator, but kept to a minimum size, backed by a level of technical annexes, with further detailed survey results and archived records available below these.
The delicensing became complicated when, to satisfy the "no risk" criteria, it was stated by the Regulator's legal experts that no radioactive sources could be present on site at the time of delicensing. This would have stopped much of the ongoing work of the Establishment, and it was decided to approach the delicensing in two stages, firstly by varying the site boundary to exclude the site of the now demolished reactor from the licensed site. The second stage would delicense the remainder of the site in phases.
This dual approach was essential so that the cleared reactor site, by now demonstrated clear of all radioactivity associated with the past operations, could be dealt with before all experienced staff who had worked on the reactor had left or retired.
The final solution, now being assessed by the Regulator, was to vary the boundary to reduce the licensed site to one room, the radioactive sources' store, effectively delicensing the rest of the site. All remaining sources would be placed in the store for a short period of days only, embracing the change from being licensed under the Nuclear Installations Act, to being regulated under the Radioactive Substances Act. Then all sources would be moved onto the regulated site to their places of normal use. The store would be surveyed and being found clean the site would be delicensed, the store brought back into the regulated site and the sources not in current use returned.
Sage Safety were involved throughout this process, keeping closely in touch with the Regulators. Throughout the process, the aim was to retain the simplicity of the documentation, to demonstrate that the site presented no risk to the environment, public or workers.