Office for Nuclear Regulation

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1 ONR GUIDE FLEXIBLE PERMISSIONING INCLUDING THE USE OF DERIVED POWERS Document Type: ONR Nuclear Safety Permissioning Guide Unique Document ID and Revision No: NS-PER-GD-001 Revision 0 Date Issued: April 2013 Review Date: April 2016 Approved by: Andy Lindley Director, Civil Nuclear Reactor Programme Record reference: Trim Folder (2013/149261) Revision commentary: New document issued in response to an IRRS self-assessment finding (A4.5), where a gap was identified in this area. TABLE OF CONTENTS 1. INTRODUCTION PURPOSE AND SCOPE STATUS OF DERIVED POWERS GENERAL GUIDANCE FOR INSPECTORS.. 4 Flexible Permissioning using Derived Powers Flexible Permissioning through enhanced implementation monitoring and control 5. GUIDANCE FOR INSPECTORS ON ASPECTS OF LICENSEES ARRANGEMENTS FOR FLEXIBLE PERMISSIONING MANAGEMENT OF FLEXIBLE PERMISSIONING WITHIN ONR 8 7. DEFINITIONS REFERENCES Crown copyright. If you wish to reuse this information visit for details. You may reuse this information (excluding logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view the licence visit write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or psi@nationalarchives.gsi.gov.uk. Some images and illustrations may not be owned by the Crown so cannot be reproduced without permission of the copyright owner. Enquiries should be sent to copyright@hse.gsi.gov.uk. NS-PER-GD-001 Revision 0 Page 1 of 10

2 1. INTRODUCTION 1.1 The site licence and attached licence conditions (LCs) provide the principal legal basis for regulation by ONR of nuclear safety on licensed sites. The LCs include various powers which are used by inspectors in ONR with delegated authority, to control specific activities proposed by the licensee for the licensed site. These are known as primary powers. The primary powers are the means provided for ONR to control specific aspects of the licensees arrangements for managing their facilities and site activities safely. The primary powers exist in addition to the direct powers in the Nuclear Installations Act (NIA) 1965 and the Health & Safety at Work Act 1974 (HSWA). Using primary powers to control activities on a licensed site is an example of permissioning within a licensing regime. 1.2 There are cases where it is not considered proportionate to use primary powers to effect regulatory control, but nevertheless it remains desirable in the interests of safety that ONR maintains a degree of control and oversight of a licensee s activities or proposals. In these cases appropriate regulatory control and oversight may be achieved through a process termed flexible permissioning. However, when considering if it is appropriate to exercise regulatory control using a primary power or an alternative approach, persons having delegated authority for making such decisions should be consulted. 1.3 There are two approaches to flexible permissioning: (a) The use of powers derived from a licensee s arrangements to permission activities on a licensed site, by persons with delegated authority issuing licence instruments (LIs). For example, a derived power LI may be issued by ONR to agree to the licensee implementing a particular proposal, undertaking an activity, or progressing from one stage of a project to the next. The powers used by ONR in these circumstances are called derived powers because they derive from the arrangements made by the licensee to comply with the LCs. (b) Enhanced implementation monitoring and control, to ensure by sampling that activities and projects are being carried out safely, in accordance with the licensee s arrangements under the LCs, and any additional relevant legal requirements. The facility to employ enhanced implementation monitoring and control will enable, among other things, regulatory oversight of the implementation of activities either permissioned under a primary or derived power, or having a safety classification that does not require formal permissioning using an LI to implement the proposal. However in the latter cases, the option to intervene under primary or derived powers remains available to ONR. Where enhanced implementation monitoring and control is adopted to maintain regulatory oversight of a licensee s proposal, the approach is considered to be part of routine site inspection activity for the site. 1.4 The use of derived powers is predicated on licensees defining appropriate powers within their LC compliance arrangements allowing ONR to exercise regulatory control by permissioning selected licensee s activities. The activities most likely to require permissioning by exercise of these powers are those deemed to be of greater safety significance. In addition, LC compliance arrangements must also include provision for responding to intervention by site inspectors as part of enhanced implementation monitoring and control of for example: modifications to existing plant; changes to design of plant under construction; and, changes to organisational structure, as deemed appropriate. Site inspectors may elect to carry out enhanced implementation monitoring and control of an activity on the licensed site as a part of normal inspection sampling, to confirm that the licensee is complying with the extant arrangements to control implementation of an agreed change. The licensee s arrangements should provide for such interventions by ONR, including how interactions between the Site or Project Inspector and the licensee, in relation to the change, will be conducted. NS-PER-GD-001 Revision 0 Page 2 of 10

3 1.5 This document provides general guidance to inspectors on the role of flexible permissioning in regulating nuclear safety on a licensed site, what arrangements should be made to allow flexible permissioning to work effectively, and how the arrangements may be used in the interests of safety. 2. PURPOSE AND SCOPE 2.1 This guidance is intended to promote a consistent approach to flexible permissioning, including identifying which proposals made by a licensee should be considered for permissioning using derived powers, to provide a proportionate level of regulatory control of selected activities. It also describes other means for conducting enhanced implementation monitoring and control that may be carried out, to confirm that changes on the site are made in accordance with the licensee s extant arrangements. In all cases, decisions about whether permissioning will be achieved using a primary or a derived power, or whether enhanced implementation monitoring and control will be employed, must be made by a person with delegated authority to act in that regard (Ref. 1), and as defined within the ONR management system. 2.2 This guidance complements other permissioning documents, such as the ONR instruction titled Preparation and issue of Licence Instruments (Ref. 2). It describes not only an approach for exercising derived powers, but also provisions for carrying out enhanced implementation monitoring and control of changes as an additional option where this is deemed appropriate. This latter approach could include compiling records of formal meetings, regulatory letters, and any other forms of communication generated during site inspection covering implementation of the change. What is flexible permissioning? 2.3 Flexible permissioning has been employed extensively in ONR to control certain activities at nuclear installations, particularly by using derived powers in order to control construction, commissioning, plant modifications and decommissioning activities under arrangements made under LCs and 35. ONR has established processes to exercise control principally through the use of derived powers set out within the licensees LC compliance arrangements, and endorsed by ONR as a suitable means of implementing regulatory control over selected licensees activities on the site. An example of the use of flexible permissioning is in the identification and release of stages within a project, referred to as hold-points, to ensure regulatory acceptance of progression from one stage to the next, through the use of derived powers to issue a derived powers LI. 2.4 Alternatively, a site inspector may choose to exercise enhanced implementation monitoring and control of a project or activity where use of LIs is not deemed proportionate, and in this case the inspector may use other means to control hold-points agreed as part of the activity. The means available should be described within the licensee s arrangements, and agreed with the licensee according to the circumstances of each case. 2.5 ONR continues to have the option to use the primary powers conferred by the LCs or HSWA, should flexible permissioning arrangements not provide an appropriate level of control and irrespective of whether those arrangements are in place. 2.6 The use of flexible permissioning does not replace or limit the use of primary powers to achieve control of the activities of licensees when appropriate, nor does it affect the powers that ONR inspectors have under the HSWA or NIA In addition, it is not anticipated that ONR would agree a derived power in the form of a Consent, Approval or Direction, without reference to the HSE Legal Advisory Team in the Treasury Solicitor s Department. NS-PER-GD-001 Revision 0 Page 3 of 10

4 3. STATUS OF DERIVED POWERS NOT PROTECTIVELY MARKED 3.1 The licensee is required to make and implement arrangements under many of the standard licence conditions. The arrangements may provide mechanisms through which ONR may permission activities. The provision of authority to act in relation to a licensee s proposed activity, which is included in the licensees arrangements, is known collectively as derived powers. For example, a licensee may include in their arrangements made under LC22 a provision requiring them to seek ONR s Agreement before proceeding with certain activities. When ONR exercises a derived power it is exercising a power conferred by the licensee s arrangements, made under a particular licence condition. Usually, exercising a derived power to permission an activity is evidenced by issuing a LI. 3.2 Derived powers have no formal statutory basis. They are working level administrative arrangements which are put in place by a licensee as part of its LC compliance arrangements and agreed between them and ONR in the interests of safety. Derived powers are not primary powers, as primary powers are conferred by the LCs themselves. The inclusion, or use, of derived powers in LC compliance arrangements does not prevent the ONR using primary powers provided to it by the LCs, or other powers conferred by HSWA or the NIA 1965, should it be considered necessary. 4. GENERAL GUIDANCE FOR INSPECTORS 4.1 Flexible permissioning arrangements allow ONR to: (a) use derived powers and issue a licence instrument to permission or agree to activities on a licensed site which may affect nuclear safety (see section below); or (b) where it is not appropriate to exercise a primary or derived power, put in place other arrangements, agreed with the licensee, to enable site inspectors to maintain enhanced implementation monitoring and control of particular activities, including locally agreed hold-points and their release. 4.2 As flexible permissioning includes exercising derived powers, the application of flexible permissioning arrangements to permit activities is with the agreement of the licensee and at the discretion of ONR. Both ONR and the Licensee must be content with the derived powers included in the licensee s LC compliance arrangements, and the arrangements made by the licensee to manage and respond to interventions made by ONR as part of the agreed process. 4.3 The main advantage in the use of derived powers to permission activities is that they may be applied to a wide range of selected activities and provide more flexible regulatory control, which is in addition to the primary powers provided by the LC. The issue of a LI to exercise a derived power is captured by the ONR processes for regulatory transparency, because PARs and other reports produced to justify their issue are accessible on the ONR website, and derived powers LIs are included in the list of instruments published in the site inspectors quarterly reports for local site stakeholder groups. 4.4 A licensee s LC compliance arrangements, for modifications or other changes for example, will provide for the classification of modifications, experiments or change proposals according to their safety significance. The arrangements should include a requirement for the provision of adequate documentation to justify the safety of the proposed modification, experiment, or other change, and for its submission to ONR where appropriate. Generally these arrangements should require the licensee to submit the highest safety classification (or category) change proposals to NS-PER-GD-001 Revision 0 Page 4 of 10

5 ONR for permissioning prior to implementation. On receipt of a licensee s letter requesting permissioning of a change proposal, ONR will assess whether use of flexible permissioning is appropriate. Where this is the case permissioning of the proposal will be through a derived powers LI, issued under the arrangements made under the licence condition and sent to the licensee. The above approach may also be adopted for the most significant changes made under other LCs, for example LCs 20 and Some licensees may also include in their arrangements the opportunity for ONR to exercise derived powers in connection with changes and modifications of lower safety significance, and ONR may decide to intervene using these derived powers should it be considered necessary. The exercise of derived powers in these cases will also require a LI to be issued. However, in most cases, licensees are permitted to proceed with lower classification proposals under their extant arrangements, without specific intervention by the ONR under these derived powers. 4.6 In the cases where a derived (or primary) power LI is issued for a lower safety category proposal, a Site or Project inspector may still determine that the proposal should also be subject to enhanced implementation monitoring and control to ensure that the licensee s arrangements are controlling implementation of a proposal in the interests of safety. In these circumstances, flexible permissioning is used to exercise closer regulatory control of implementation of the change on the licensed site. 4.7 Where a derived (or primary) power LI is not used, to control lower safety category proposals, flexible permissioning allows enhanced implementation monitoring and control to be used to ensure that the implementation of the proposal complies with their extant arrangements made in the interests of safety. 4.8 Enhanced implementation monitoring and control may be exercised in a variety of ways, including: routine regulatory interventions; agreement of hold-points; hold-points being amended, deleted or released; arrangement of meetings to review progress; and, agreement of criteria to demonstrate that the implementation process is complete. This approach may be applied to all stages of operations, including: new build projects; modifications; and, decommissioning activities. The approach may be used where a primary or derived powers LI has been issued to initially permission a proposal, or where it is considered that a change proposal not requiring a LI is selected for additional regulatory oversight during its implementation. 4.9 Regulatory monitoring and control of the implementation of a change-proposal may include the identification of hold-points, which define stages in a project beyond which an activity will not proceed until released by ONR using appropriate means. Three examples of a regulatory holdpoint are as follows:- Regulatory hold-points instituted by use of primary powers where ONR has Specified, Notified or Directed the licensee not to continue with an activity, and to seek ONR Agreement or Consent before proceeding past the hold-point. The hold-point may be released by the use of a primary powers LI. Regulatory hold-points, which are established using derived powers, set out in the licensees arrangements, and which may then be released through the use of a derived powers LI. Regulatory hold-points which are put in place as part of the site inspectors enhanced implementation monitoring and control measures by agreement with the licensee, in compliance with their extant arrangements, and in accordance with ONR delegated authorities. These holdpoints may be released by letters, records of meetings or other suitable means of recording that ONR is content for the activity to proceed under the arrangements for local control. NS-PER-GD-001 Revision 0 Page 5 of 10

6 Flexible Permissioning using Derived Powers 4.10 Agreements and Acknowledgements are the most frequently used of the derived powers LIs, but all of the types of derived power are set out below Licensees arrangements generally differ, and the derived powers conferred under them may also differ between licensees. However, it is not anticipated that ONR would agree a derived power in the form of a Consent, Approval or Direction, without reference to the HSE Legal Advisory Team in the Treasury Solicitor s Department. All derived powers require a LI to be issued, and can only be exercised by a person with the necessary delegated authority within ONR Types of derived power: Agreement - may be used, for example, to enable the ONR by licence instrument to Agree to a safety case submission or the commencement of an on-site activity. Acknowledgement - may be used for example, to enable the ONR by licence instrument to Acknowledge receipt of a safety submission. ONR may indicate in the Acknowledgement that, either: (a) ONR acknowledges the licensee s proposal to implement a specified change (and so by implication the licensee can proceed); or (b) notifies that ONR intends to assess the licensee s proposal in the interests of safety. In the latter case the licensee s arrangements must require that the on-site activity does not commence until ONR indicates that it is content with the proposal. This will be done by issuing a further LI or other letter, confirming a satisfactory outcome from an assessment of the proposal. Specification - may be used, for example, to enable the ONR by licence instrument to Specify a Safety Case, for its Acknowledgement or its Agreement, or identify other regulatory hold-points within a proposal. If regulatory hold-points are specified, ONR must agree the release criteria for a hold-point, and the method of release of the hold-point. This power could be used, for example, if the safety significance or categorisation of the licensee s proposal did not require seeking ONR permission before proceeding with the project, but that in any event ONR considers that the matter is of such potential safety significance that intervention is justified. Notification - may be used for example, to enable the ONR by licence instrument to Notify the licensee that ONR has received a safety case submission with the option of indicating that either: (a) ONR intends to take no formal action on the proposal and that by implication the licensee may proceed, or (b) ONR intends to assess the licensee s proposal in the interests of safety. In the latter case the licensee s arrangements must require that the onsite activity does not commence until ONR indicates that it is content. This may be by ONR issuing a further LI or other letter confirming a satisfactory outcome from our assessment. In addition the licensee s arrangements may provide for the ONR to notify the licensee under the arrangements of a need to take action or provide information in relation to matters affecting safety on the site Flexible permissioning by a derived powers LI may be employed for example, to Acknowledge a safety case submitted to ONR, or to agree to release of a hold-point for an activity on a licensed site where the hold-point has been specified under derived powers. The route for clearance of safety cases and hold-points controlled using derived powers should be clearly defined and agreed by a person in ONR with the necessary delegated authority, prior to the activity/proposal being commenced. This should also include identification of the deliverables to be submitted to ONR to support releasing the hold-point. The derived powers LIs themselves must be issued by a person with the necessary delegated authority (Ref: 1). NS-PER-GD-001 Revision 0 Page 6 of 10

7 4.14 The ONR management instruction (Ref 2), contains standard templates agreed by the Legal Advisory Team in Treasury Solicitors office (TSoL) for the types of derived powers LIs most frequently employed by ONR, and referred to in paragraph The derived powers covered by the templates include specifications, agreements and acknowledgements under licensees arrangements made under LC 19(1), 20(1), 21(1), 22(1) and 35(1). The list of all derived powers LIs for which standard templates are available for use is contained in the Annex to INS/001. The list of persons who may exercise those powers is set out in the ONR Delegated Authorities document. Under the current ONR arrangements, where it is intended to issue an LI in exercising a derived power not covered by a standard template, advice must be sought on the draft LI from the Legal Advisory Team in TSol before it is issued If the licensee does not comply with the requirements of decisions made under flexible permissioning, the ONR will need to consider, as a first step, whether action should be taken under the primary powers to ensure compliance with the licence condition. It may also be possible, that ONR should consider taking other enforcement action in proportion to the safety significance of the non-compliance. Flexible Permissioning through enhanced implementation monitoring and control 4.16 Where it is not considered proportionate to the nature and magnitude of the risk or hazard for ONR to exercise derived (or primary) powers then enhanced implementation monitoring and control may be appropriate to provide regulatory oversight of a proposed change. For example, in cases where the licensee s extant arrangements permit implementation of proposals of lower safety classification without prior ONR permission, or do not confer derived powers of specification or notification etc. to ONR, local regulatory control of a proposal may be effected by the site inspector agreeing constraints with the licensee to be applied to the implementation process. This approach could also be applied to projects being implemented that have already been permissioned under primary or derived powers, where otherwise the licensee could proceed with implementation of the proposal without further ONR involvement A record of the oversight maintained by the site inspector as part of enhanced implementation monitoring and control, and may be evidenced by means which include: Letters (not being LIs), or other written communications. Release an agreed hold-point recorded in the minutes of a quorate regulatory interface meeting with appropriate Terms of Reference. Information recorded in a site or other report, which is approved for issue. 5. GUIDANCE FOR INSPECTORS ON ASPECTS OF LICENSEE S ARRANGEMENTS FOR FLEXIBLE PERMISSIONING 5.1 The following aspects should be noted on licensee s governance of flexible permissioning: The licensee s arrangements for managing flexible permissioning should be clearly described in documents, which are deemed suitable by ONR for the purpose of facilitating regulatory control using flexible permissioning. This should include the use of derived powers and allow for ONR to exercise enhanced implementation monitoring and control as deemed necessary. NS-PER-GD-001 Revision 0 Page 7 of 10

8 Technical regulatory interface meetings at the working level (e.g. Level 4) should convene regularly to clarify what must be delivered, and to demonstrate that the basis for proceeding with any project stages that have been agreed is met, including further permissioning under derived powers LIs as necessary, or otherwise releasing agreed hold-points. The format and content of deliverables should be clear. Frequently the most suitable deliverables are reports with an appropriate safety classification, which contains evidence of progress against specified objectives. For large or complex submissions, an ONR assessment period of some months may be needed, and in these cases permissioning using a derived powers LI may be appropriate. Consideration should be given to the Licensee s governance of deliverables. It may be helpful for these processes to be included in the summary document where, for example, it is submitted to a Nuclear Safety Committee (NSC) established under LC13(1), or other suitable body advising on safety. 5.2 Arrangements agreed between ONR and the licensee for derived powers to be included in the licensees arrangements for establishing and releasing hold-points by ONR, should include the following: - A procedure to enable the identification, the number and type of hold-points needed to ensure the safety of the project or activity, including the proposal of candidate hold-points by the licensee for ONR s consideration and agreement. Definition of the scope of each activity covered by a hold-point, and production of supporting evidence to ONR to enable release of each hold-point. The licensee should be responsible for producing the documents defining the activities and the evidence of clearance to be furnished to ONR. Identification of hold-points where permissioning requires the involvement of another regulator (e.g. DNSR, other HSE Directorates, and/or EA). A summary document describing the hold-points should be put in place for a specific project; it should include the manner of release of the hold-points. The summary document should cover the licensee s main activities, and be consistent with ONR permissioning methods, as necessary. 6. MANAGEMENT OF FLEXIBLE PERMISSIONING WITHIN ONR 6.1 Management of Interventions within ONR, is described in Management System instructions and guides (Refs: 3 & 4). Flexible permissioning is managed within the framework outlined in these documents, and is subject to scrutiny through Regulatory Review Meetings (RRM), Intervention Management Group (IMG) oversight and normal programme management consideration. Projects should therefore make optimum use of a combination of primary powers, derived powers and enhanced implementation monitoring and control, to provide appropriate regulatory oversight of matters potentially affecting safety on the site. Flexible permissioning may be used to provide regulatory control within a framework defined by the primary powers provided by the licence conditions. The use of primary powers should be Specified prior to commencement of the work programme, to indicate points which are deemed most significant for safety. The correct balance in using flexible permissioning and primary powers, will depend on specific circumstances and the licensee s extant arrangements, which will be the subject of consideration NS-PER-GD-001 Revision 0 Page 8 of 10

9 by ONR. This process may include advice from Treasury Solicitors and LAO, and discussions with licensees. 6.2 Where flexible permissioning is being used to control a project, any hold-points should be identified in advance, and recorded in an appropriate document by the licensee which is made available to ONR. The document should include all of the regulatory hold-points agreed with the licensee for the parts of the project or programme that are associated with activities which may affect safety. The document should summarise the basis for the interface between ONR, other regulators and stakeholders, and the licensee, and should be reviewed and revised as necessary to ensure the agreed approach provides an appropriate level of regulatory control for the duration of the project or programme. 6.3 Under these arrangements the transparency and management of the regulatory hold-points can be monitored through established regulatory interface meetings. The arrangements for implementing and releasing hold-points may, unless an LI is required, allow work to proceed with the basis for this being recorded at quorate regulatory interface meeting, supporting technical meeting, or a management meeting by agreement, and in accordance with delegated authorities. Where appropriate, adequate regulatory oversight may be provided through enhanced implementation monitoring and control measures by a warranted inspector. 6.4 Flexible permissioning arrangements may associate a hold-point with an activity, and with the evidence needed to support its release. Detailed discussion of the evidence supporting implementation (safety documentation, other information and arrangements made) takes place at the appropriate and defined regulatory interface meetings, which may then report the outcome to meetings at a higher level (a meeting hierarchy), where for example release of an agreed holdpoint may be considered, including regulatory interface meetings, if deemed appropriate. In all cases control of flexible permissioning must be in accordance with the delegated authorities, as set out in the ONR management system. 6.5 Where a hierarchy of meetings is not used (for example at lower hazard or decommissioning sites), the arrangements made in connection with enhanced implementation monitoring and control should define a suitable alternative means for controlling hold-points established as part of the activity or proposal. 6.6 Within ONR the IMG, or its programme equivalent, should ensure that activities managed using flexible permissioning provide the necessary level of regulatory control and deliver the planned interventions necessary to support ONR s strategies and plans for the particular sites being regulated. The IMG is responsible for advising on the use of flexible permissioning, suggesting resource allocation, and reviewing potential changes in programme milestones. Site and Project Inspectors are responsible for implementing the regulatory process, including the identification of hold-points, and preparation for the control of hold-points using derived powers LIs or alternative means, as necessary. 6.7 Where flexible permissioning is used to control a licensee s activities the decisions made to permit the implementation of a licensee s proposal must be recorded in accordance with ONR management processes. In the case of derived powers LIs, this will be in the form of a Project Assessment Report and issuing a LI. For alternative approaches, adopting enhanced implementation monitoring and control, the decision made by the inspector/onr should be recorded in appropriate documents, such as an Intervention Reports, Assessment Reports, File Memoranda etc. 6.8 The authority to exercise primary or derived powers needing a LI is currently restricted to ONR Superintending Inspectors, or grades above, in accordance with the delegation of authorities in ONR (Ref. 1). However, the Chief Nuclear Inspector may formally authorise, temporarily or permanently, such individuals or such appointments as are necessary to discharge ONR s NS-PER-GD-001 Revision 0 Page 9 of 10

10 functions given in the framework document, as amended (Ref. 5). All such further authorisations must be given in writing. 7. DEFINITIONS Regulatory Hold-Point. A regulatory hold-point is a stage in a project beyond which work may not proceed until cleared by the ONR. A regulatory hold-point may be cleared by LI using either primary or derived powers, by other means (such as a letter), or by agreement at a regulatory interface meeting, or by such means as are outlined within the Licensee s arrangements, where the hold-point is put in place as part of enhanced implementation monitoring and control. Intervention. An interaction by ONR Inspectors and other staff to influence licensees/dutyholders, industry representatives, partners and stakeholders to achieve an outcome to secure safety. This includes both planned and reactive interventions. Programme. A framework for achieving identified outcomes over the long term, consisting of activities and projects managed as a whole over a prolonged period by a programme management team. Project. A project is a distinct package of work controlled by a temporary organisation; a project team, set up to deliver the work within defined timescales, cost, quality, resource, scope and risk. Intervention Management Group (IMG). A generic term to cover various management groups (IPGs, RRMs etc) that exercise oversight over the development and delivery of the various intervention plans established under programmes and projects, and includes members with delegated authority within ONR. Nuclear safety. The achievement of proper operating conditions, prevention of accidents and mitigation of accident consequences, resulting in protection of workers and the general public from dangers arising from ionizing radiations from nuclear installations (Ref: 6). 8. REFERENCES Ref 1: Delegated Authorities BMM Annex 2 Issue 4. Ref 2: Preparation and Issue of Licence Instruments INS/001. Ref 3: Intervention Planning INS/008 Ref: 4: Guidance for Intervention Planning - G/INS/008. Ref 5: ONR Framework Document (As amended) November Ref 6: EC Directive on Nuclear Safety 2011 NS-PER-GD-001 Revision 0 Page 10 of 10