Rosyth Royal Dockyard Limited report - Q1 2009

Local liaison committee report quarterly report for 1 January 2009 to 31 March 2009

Inspections
Routine Matters
Non Routine Matters
Regulatory Activity

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 Rosyth Local Liaison committee (LLC) and covers activities associated with the regulation of nuclear safety at Rosyth Royal Dockyard (RRD). These reports are distributed quarterly and are also available on HSE's web site at http://www.hse.gov.uk/nuclear/llc/index.htm.

Site Inspectors of HM Nuclear Installations Inspectorate usually attend LLC meetings and will respond to questions raised there or subsequently by members of the LLC.

Inspections

This report summarises the inspection and regulatory activities associated with the Rosyth Royal Dockyard (RRD) licensed site. The focus for the Rosyth Licenced Site is the safe and timely decommissioning of redundant nuclear facilities and safe disposal of wastes from the site, leading to delicencing. This is being progressed initially through what is known as the RD83 project.

The NII site Inspector visited the site on 3 February 2009.

Inspectors from HSE's Field Operations Directorate visited the site on 3 February 2009.

Routine Matters

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

the conditions attached by HSE/NII to the Nuclear Site Licence;
The Health and Safety at Work etc Act (HSWA) 1974 and
Regulations made under the HSWA for example the Ionising Radiations Regulations1999 (IRR99) and the Management of Health and Safety at Work Regulations 1999 (MHSW99)

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 site licence in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation.

As reported in previous reports, HSE/NII's continue to monitor that the site decommissioning has satisfactorily removed radioactive material from the site in the RD83 decommissioning programme. HPA, HSE/NII's contractor continues to report that all the samples taken demonstrate the decommissioning process has removed ground radioactivity and that the site decommissioning records are comprehensive.

The Site Inspector attended the Rosyth Regulatory Information Forum on 3 February 2009. This is a meeting established with the Licensee to provide a forum between RRD, the Nuclear Installations Inspectorate (HSE/NII), SEPA, the Defence Nuclear Safety Regulator (DNSR), and the Ministry of Defence (MoD).

The meeting noted that the site decommissioning is progressing to plan. The meeting also discussed the MoD and RRD progress on establishing a programme for disposal of the radioactive Ion Exchange resin held on site and the subsequent decommissioning and delicencing of the Active Waste Accumulation Facility (AWAF). MoD indicated that it was likely that the site programme would form part of a programme that included removal of the laid up submarines, seven of which are berthed at the site.

HSE-NII continues to press for early resolution for disposal of the radioactive material held in the AWAF.

Radwaste disposals were generally satisfactory although there continues to be a delay in the disposal of thermocouples at Sellafield.

Two inspectors from HSE's Field Operations Directorate visited the site with the Site inspector to gain familiarity with the site's operations and to inspect conventional (non-nuclear) safety in the AWAF.

It is HSE/NII policy that where improvements were considered necessary, satisfactory commitments to address the issues are made by or are sought from the (licensee/operator), and progress monitored by the site inspector(s) during future visits. Where necessary, formal regulatory enforcement action will be taken to ensure that appropriate remedial measures are implemented to reasonably practicable timescales.

Non-routine Matters

Licensees are required to have arrangements to respond to non-routine matters and events. NII Inspectors judge the adequacy of the licensee's/operator's response including actions taken to implement any necessary improvements.

There were no non routine matters this quarter.

Regulatory Activity

Under Health and Safety legislation HSE/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 require 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.

No Licence Instruments were issued during the quarter.

Changes to HSE's nuclear directorate

In early 2008 the Government initiated a review into the UK's nuclear safety regulatory regime, led by Dr Tim Stone. The recommendations and the UK's Government response were published at the end of January 2009. One of the major recommendations is the decision by Government to establish the Health and Safety Executive's (HSE) Nuclear Directorate (ND) as a Statutory Corporation under the auspices of the HSE.

The creation of this new, autonomous body, (which will continue to incorporate the Office for Civil Nuclear Security and the UK Safeguards Office) will facilitate a more sustainable approach to regulating nuclear safety and security within a rapidly changing global nuclear environment and recruitment of high calibre of staff within a hardening market place for highly specialised skills.

The restructuring will not change the substance or standards of regulation or compromise the independence of the nuclear regulatory body, and will not affect the decisions it takes or the international obligations the Government requires it to meet.

Enabling work continues for the initial scoping and planning of the work-streams and programmes necessary for the Statutory Corporation to come into being from April 2010. This project has required the temporary enhancement of ND's senior management capability in order to deliver existing regulatory work and to create the Statutory Corporation.