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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.

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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 29 April and 2 June 2009.

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Changes to HSE’s nuclear directorate

The Government has put forward proposals to change the status of HSE's Nuclear Directorate (ND) to that of a Statutory Corporation under the auspices of the HSE. This is intended to enable ND, as the independent nuclear regulator of safety and security, to better meet the challenges of a changing nuclear industry over the coming years. The changes are to provide the nuclear regulator with greater flexibility and increase the accountability, transparency and openness of nuclear regulation. The Government are proposing that the statutory changes needed to bring this about will be made by a Legislative Reform Order (LRO).

This builds on the outcome of the Government initiated review of the UK's nuclear regulatory regime, led by Dr Tim Stone. The Summary Recommendations and the Government’s response were published at the end of January 2009 (available on HSE’s website: http://www.hse.gov.uk/nuclear/stonereview.htm).

A public consultation, run by DWP and DECC, on the LRO was launched on June 30th for a 12 week period, which gives the opportunity for stakeholders to comment on the proposals.

For access to this consultation please see: http://decc.gov.uk/en/content/cms/consultations/hse_restruct/hse_restruct.aspx

These new arrangements 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.

Subject to the outcome of the consultation and Parliamentary approval, and if the Parliamentary timetable permits, the aim is to bring the new body into being during 2010.

An internal change programme is currently operating within ND to ensure that the ND is ready to operate as a statutory corporation from spring 2010.

This programme does not in anyway compromise the current regulatory activities of ND.

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Routine Matters

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

1. the conditions attached by HSE/NII to the Nuclear Site Licence;
2. The Health and Safety at Work etc Act (HSWA) 1974 and
3. 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 continues 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. It is expected that HPA’s final reports will be issued towards the end of 2009, enabling RRD to apply for and HSE-NII to grant a variation to the RRD site Licence leaving the AWAF and its surrounds as the only nuclear licensed area on the Rosyth site.

The Site Inspector attended the Rosyth Emergency Arrangements Demonstration Exercise planning group meeting on 29 April 2009. This group in formed to ensure that the annual demonstration exercise is planned to enable RRD to satisfactorily demonstrate its arrangements. It also allows the site to incorporate details in the planned exercise that allow external agencies to demonstrate matters relating their own response arrangements.

The Site Inspector attended the Rosyth Stakeholder Meeting on 2 June 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), Scottish Executive and the Ministry of Defence (MoD). Following this meeting, the Site Inspector attended a workshop to examine the options for disposing of resins stored on the site.

The Stakeholder 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). HSE-NII continued to press for an early resolution of the way forward for disposal of the radioactive material held in the AWAF.

During the workshop MoD presented input into a BPEO study on disposal options. HSE-NII said that the study appeared to duplicate a BPEO study that had been completed in 2008 and advised that the new study, if it was necessary, should build upon the 2008 study rather than repeat it. HSE-NII urged early production and implementation of a resin disposal plan that would enable delicencing of the Rosyth nuclear licensed site.

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.

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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.

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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.

RRD have submitted an application for Approval of revised Emergency Arrangements. It is expected that this application will result in the issue of a Licence Instrument in the coming quarter.

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