Vulcan Naval Reactor Test Establishment (NRTE), at Dounreay

Site Stakeholder Group 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 Dounreay Stakeholders Group (DSG) and covers activities associated with the regulation of nuclear safety at the Vulcan Naval Reactor Test Establishment (NRTE). 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 DSG meetings and will respond to questions raised there or subsequently by members of the DSG.

Inspections

The majority of sites inspected by HM Nuclear Installations Inspectorate (NII) a part of the Health and Safety Executive are licensed by HSE/NII under the Nuclear Installations Act 1965 (as amended). Vulcan NRTE is not a licensed site although it operates under Authorisation from the Ministry of Defence (MoD) Defence Nuclear Safety Regulator (DNSR). The site is adjacent to the Dounreay Licensed Site and is regulated by HSE/NII through other legislation as noted below. This report summarises the inspection and regulatory activities associated with Vulcan NRTE which are coordinated with inspections by DNSR. The focus for Vulcan NRTE is safe and timely testing of submarine reactor performance to enable continued safe operation of the UK's nuclear submarine fleet.

The Nuclear Installations Inspectorate Site Inspector made inspection visits to the sites on the following dates during the quarter: -

17 to 19 March 2009.

Routine matters

With limited resources, HSE-NII necessarily employs a sampling regime in its regulation of sites that is proportionate to the risks, and which is targeted primarily on those activities with the highest risks or where the hazards are least well controlled.

Inspections on site are undertaken are taken as part of monitoring compliance with:

The Health and Safety at Work etc Act (HSWA) 1974 and
Regulations made under the HSWA for example the Ionising Radiations Regulations1999 (IRR99), the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) and the Management of Health and Safety at Work Regulations 1999 (MHSW99)

This entails monitoring operator'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 operators are required to make and implement adequate arrangements in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation. In this period all inspections of Vulcan NRTE were undertaken jointly with DNSR and covered:

Emergency arrangements under REPPIR
Control of radiation exposure under IRR99

The Site Inspector also met with the Site Safety Representatives and attended the Dounreay Stakeholder's Group.

A joint inspection was carried out with DNSR (supported by Serco RSD) of the site's emergency arrangements. This covered:

The content, features and extent of the emergency plans, including the arrangements for their periodic review and update.
The basis of the arrangements, including assessment and categorisation of threats, intervention and alerting criteria, the extent of consultation and liaison with external bodies, including assurance of capability.
The emergency response organisation, authorities and responsibilities, including the facilities, equipment and instrumentation and interfaces with external organisations.
Instructions to personnel and training, for both internal and external organisations.
Exercise arrangements, including follow-up and incorporation of lessons learned. The inspection included attending a planning meeting for the forthcoming Lonestar 09 Emergency Exercise.

The emergency arrangements were found to be comprehensive and well-established and no significant issues were raised during the inspection. The inspection team did recommend that the document summarising the overall arrangements should be reviewed before Lonestar 09. The arrangements are likely to need to be further reviewed following Vulcan's REPPIR submission later in 2009.

In general the arrangements made and implemented by Vulcan NRTE in response to IRR99 were deemed to be adequate for the regulation inspected. Where improvements were considered necessary, these were brought to the attention of Vulcan NRTE during the inspection and the Site Inspector will monitor progress 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

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

There are no items of particular note during the current reporting period.

Regulatory Activity

Under Health and Safety legislation HSE/NII Site Inspectors, and other HSE Inspectors, may issue enforcement (Crown) notices to secure improvements to safety.

No enforcement (Crown) notices 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.