Vulcan Naval Reactor Test Establishment (NRTE), at Dounreay

Site Stakeholder Group Report

Quarterly Report for 1 April to 30 June 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:

16 to 18 June 2009

He was accompanied on this visit by the Superintending Inspector for Naval Nuclear Propulsion Plant regulation and a Radiation Protection Specialist Inspector.

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.

A joint NII-DNSR inspection team assessed the Lonestar 2009 emergency exercise on 17 June 2009. This was designed to test the on-site response to a reactor accident in the Shore Test Facility (STF) at Vulcan NRTE. Overall, the exercise demonstrated a strong capability of the Vulcan site to cope with a reactor accident and to protect both the workforce and the public. The assessing team considered that all the exercise objectives were fully met. There were, however, a number of learning points that will need to be addressed relating to briefing of intervention teams and notification of the incident to NII. These will be followed-up on a future site visit.

NII has received a revised Hazard Identification and Risk Evaluation under REPPIR covering operations on the Vulcan NRTE site. This suggests that the likelihood of a nuclear event involving the STF plant is less than in previous submissions and the site are seeking a reduction in the Detailed Emergency Planning Zone (DEPZ) around the site from 2km to 1.15km. This submission is currently being assessed, following which NII is required by REPPIR to make a determination of the appropriate size of DEPZ. This determination is expected to be issued towards the end of 2009. In the meantime, Highland Council has been advised that emergency response plans should continue to be based on the current DEPZ determination.

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.

Proposed changes to the status of 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.

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.

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