Office for Nuclear Regulation

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Rosyth, Inspection of LC32 Arrangements, Level 4 Meetings, LC11 Emergency Exercise Demonstration and Submarine Dismantling Project Regulatory Interface Meeting

Executive summary

Purpose of intervention

This inspection of RRDL’s licensed site at Rosyth was undertaken as part of a series of planned interventions made in accordance with the IIS Strategy and Plan.

Interventions Carried Out by ONR

The intervention consisted of an inspection of the licensee’s compliance with Licence Conditions 11 (Emergency Arrangements) and 32 (Accumulation of Radioactive Waste). 

The LC11 inspection undertaken utilised the relevant ONR Technical Inspection Guide which requires inspectors undertaking compliance inspections against LC11 to consider both the arrangements that are in place together with their associated implementation.  The intervention was undertaken by three ONR inspectors and involved the observation of the annual Level 1 Demonstration of the on-site emergency response arrangements.  The purpose was to evaluate the capability of licensee’s emergency arrangements and its emergency response personnel to deal effectively with emergencies with on-site or off-site consequences.

The LC32 Compliance inspection was undertaken by the ONR Site Inspector and ONR specialist inspector in Nuclear Liabilities Regulation, in accordance with the relevant ONR Technical Inspection Guide and involved examination of relevant licensee documentation, targeted discussions with relevant members of the licensee’s staff and inspection of the Active Waste Accumulation Facility.

Additional to the Licence Condition compliance inspections, I undertook a routine update of issues that had been raised at previous site inspections, conducted an inspection of Dock Number 2 and attended a Submarine Dismantling Project (SDP) Regulatory Interface Forum.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The LC11 Level 1 demonstration was based upon a loss of containment event occurring within the Active Waste Accumulation Facility, with 2 associated casualties.   I considered that the scenario provided a suitably challenging test of the emergency arrangements. ONR assessors were located in the Emergency Response Centre and at the simulated incident scene.  Whilst the exercise demonstrated adequate arrangements in many areas, the capability in relation to casualty recovery, communications and command and control at the incident scene was not fully demonstrated.  On this basis I have given an inspection rating of 4 (below standard) and a regulatory issue will be raised to address this shortfall. I will also write to site requesting that a partial re-demonstration of the site emergency arrangements, focusing on casualty recovery and procedures and protocols at the incident scene be undertaken and observed by ONR. Self-evaluation by the Rosyth Royal Dockyard Limited internal assessment team demonstrated good alignment with observations and assessment by the regulators.

The compliance arrangements for LC32 were found to be adequate on inspection and complied with the relevant ONR guidance. On this basis I have given an inspection rating of 3 (adequate) for this inspection.

The level 4 meeting reviewed progress against the existing issues on the ONR Issues database. On the basis of these discussions and evidence provided I am satisfied that adequate progress is being made on these issues.

In support of ongoing inspection of the adequacy of the licensee arrangements for the SDP project, I undertook an inspection of Dock Number 2.   Housekeeping standards during this inspection were good and there was evident progress against previously identified issues.  No further issues were raised.

The SDP Regulatory Interface Forum provided an opportunity for site and MoD representatives to provide an update to regulators in relation to the project.  No issues arose from these discussions.

Conclusion of Intervention

On the basis of the information provided and evidence obtained during this intervention, I concluded that the licensee has effective arrangements under Licence Conditions 32 (Accumulation of radioactive waste).

The LC11 Level 1 demonstration was not considered to provide a full demonstration of the emergency response capability on site. The licensee will be asked to undertake a partial repeat of the exercise focusing on casualty recovery and procedures and protocols at the incident scene.