ONR’s statutory determination of the off-site emergency planning and public information areas for Barrow in accordance with the requirements of the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) regulations 9 and 16

Project Assessment Report ONR-COP-PAR-14-006 Revision 0 10 12 2014

© Office for Nuclear Regulation, 2014 If you wish to reuse this information visit www.onr.org.uk/copyright.htm for details. Published 12/14

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EXECUTIVE SUMMARY

ONR’s statutory determination of the off-site emergency planning and public information areas for Barrow in accordance with the requirements of the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) regulations 9 and 16

This Office for Nuclear Regulation (ONR) Project Assessment Report (PAR) describes and explains the basis for ONR’s re-determination of the Radiation (Emergency Preparedness and Public Information) Regulations (REPPIR) off-site emergency planning area and the area within which prior information is to be distributed around the Barrow GB nuclear site and nuclear warship site. The determination of a REPPIR off-site emergency planning area defines the area around a site within which, in the opinion of ONR, any member of the public is likely to be affected by a reasonably foreseeable radiation emergency (as defined in REPPIR), and constitutes an important component of the UK’s overall emergency response framework. In relation to this area, the local authority is required to prepare an adequate off-site emergency plan with the purpose of minimising, so far as is reasonably practicable, radiation exposures to those likely to be affected by such an emergency. This plan will detail the potential need to implement appropriate countermeasures within all or part of this area. REPPIR requires operators to undertake hazard identifications and risk evaluations (HIRE) in relation to work with ionising radiations (including where there are material changes to such work) as specified in REPPIR. These HIREs must identify all hazards on the sites with the potential to cause a radiation accident, and evaluate the nature and magnitude of the risks to employees and other persons (e.g. those who live or work nearby) arising from those hazards. REPPIR also requires operators to assess their HIRE and to send a Report of Assessment (RoA) to ONR either prior to commencement of the work with ionising radiation, following any relevant material change in this work, or at least within three years from the last assessment. REPPIR also makes provision for ONR to request additional information. In practice, it is usual for the HIRE information itself to be requested to inform ONR’s determinations. ONR has historically used the term detailed emergency planning zone (DEPZ) to refer to the area it defined under REPPIR regulation 9 as requiring an off-site emergency plan. (The term is still used this way in some ONR guidance.) As the term is not used within REPPIR itself (although referred to in the related guidance), and to ensure legal clarity and avoid misunderstanding amongst stakeholders, this report refers to the ‘REPPIR off-site emergency planning area’ and the ‘REPPIR prior information area’ under regulations 9 and 16 respectively rather than to ‘detailed emergency planning zone’ or ‘DEPZ’. The off-site local authority emergency planning area around the Barrow sites, as provided for in REPPIR regulations 9(1) and 16(1), was first determined in 2002 - a short while after REPPIR came into force in 2001. The current area is represented by overlapping circular areas of radius 2 km around the two sites and is based on the radiological hazards assessed for a routine operational berth. This re-determination has been undertaken in response to REPPIR submissions to ONR by BAE Systems Marine Limited in relation to the GB nuclear site (Wet Dock Quay) and by the Ministry of Defence (MOD) for the nuclear warship site ( Basin). In these submissions, the dutyholders highlight the differences in the hazards associated with activities at the Barrow sites compared to a routine submarine operational berth. This leads to a reduction in the size of the technical area associated with the reference accident, specifically for the Barrow sites, compared to routine submarine operational berths. This re-determination has been undertaken in accordance with ONR’s regulatory processes, guidance associated with REPPIR itself, and the relevant ONR Technical Assessment Guide (TAG). In conducting the re-determination of the REPPIR off-site emergency planning area

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for Barrow, ONR has applied its’ recently published determination principles and associated guidance for the determination of such areas. These principles recognise the learning that has emerged from global events such as occurred at Fukushima and the need to review the scope of off-site emergency planning. They also reflect ONR’s insistence on and commitment to high standards of nuclear safety and security at nuclear installations, and its continual efforts to seek improvements to standards and to the consistency and transparency of its decision-making. ONR’s determination process requires that: (i) Technical assessments be undertaken, by ONR, of BAE Systems Marine Ltd and the MOD’s Hazard Identification and Risk Evaluations (HIREs) and Reports of Assessment (RoAs) for the respective sites. These have been completed and are reported separately. These technical assessments conclude that areas of radius of 690 m around the reference accident locations at the Wet Dock Quay and Ramsden Dock Basin should be used as the foundation for defining the extent of the need for local authority off-site emergency planning under regulation 9 of REPPIR. (ii) In accordance with the relevant ONR Technical Assessment Guide, ONR also gives appropriate consideration to practical and strategic factors relating to the planning and potential implementation of an off-site emergency plan, and other pragmatic factors appropriate to secure confidence as regards protection of the public. This aspect of the process includes dialogue with the relevant local authority (as the dutyholder within REPPIR to prepare the off-site plan), and considers, amongst other factors, local demographic and geographical considerations. ONR’s determination is therefore informed by a range of practical and common-sense factors which have the effect of defining a more practical area (from an emergency planning perspective) than that in (i) above. ONR’s principles emphasise the importance of ensuring that an appropriate balance is achieved between the assessment of technical submissions provided by the operator, and other practical and strategic considerations judged necessary in the interests of public safety. As a consequence, the ultimate determination of the REPPIR off-site emergency planning area represents ONR’s best regulatory judgement, and is not formed solely on the basis of technical considerations or criteria. The outcome of ONR’s review of the technical submissions made by operators, taking into account the relevant practical and strategic considerations relating specifically to Barrow, is that both the REPPIR off-site emergency planning area and the REPPIR prior information area for the Barrow sites will be re-defined to be the enhanced single area shown within the red line on the map contained in appendix C to this report. This area is geographically approximately twice the size but has a smaller population than the area previously defined. The change to the planning area (to include the whole of ) does not mean that ONR has identified a greater risk for those living near the site. On the contrary, ONR is satisfied that the overall risk from the two sites has been conservatively estimated. The changes therefore reflect an improved assessment of the risks specific to activities at the Barrow site; factors which ONR judges to be relevant in securing confidence as regards protection of the public during a reasonably foreseeable radiation emergency; the learning that has emerged from global events such as occurred at Fukushima; and the need to review the scope of off-site emergency planning.

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The key recommendations are: • That ONR write to County Council, BAE Systems Ltd (WDQ) and the MOD (RDB) to advise that the REPPIR off-site emergency planning area has been determined as the area within the red line on the map at appendix C.

• That ONR write to Cumbria County Council confirming the need to update, as required, its off-site emergency plan to adequately cover the area defined in recommendation 1.

• That ONR write to BAESM (WDQ) and MOD (RDB) confirming the requirement to ensure the appropriate provision of prior information to the public within the area referred to in recommendation 1. This information should also be copied to Cumbria County Council.

• ONR should notify the Defence Safety Nuclear Regulator (DNSR) of the revised REPPIR off-site emergency planning areas.

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LIST OF ABBREVIATIONS USE D

ABP Association of British

BAESM BAE Systems Marine CCA Civil Contingencies Act (2004) CCC Cumbria County Council DEPZ Detailed Emergency Planning Zone (Ref: REPPIR regulation 9(1)) DNSR Defence Safety Nuclear Regulator EURATOM European Atomic Energy Committee FSA Food Standards Agency HIRE Hazard Identification and Risk Evaluation HSE The Health and Safety Executive IAEA The International Atomic Energy Agency MCA Maritime and Coastguard Agency MHWM Mean High Water Mark MLWM Mean Low Water Mark

MOD Ministry of Defence NRPB National Radiological Protection Board (which became Public Health on 1 April 2013) ONR Office for Nuclear Regulation PAR Project Assessment Report PAZ Precautionary Action Zone (IAEA terminology) PHE Public Health England RDB Ramsden Dock Basin REPPIR Radiation (Emergency Preparedness and Public Information) Regulations 2001 RoA Report of Assessment SAPs Safety Assessment Principles TAG (ONR) Technical Assessment Guide UPZ Urgent (protective action) Planning Zone (IAEA terminology) WDQ Wet Dock Quay

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TABLE OF CONTENTS

1. REGULATORY CONTEXT …………………………………………………………………...... 1 2. INTRODUCTION ……………………………………………………………………...... ….…1 2.1 Background ……………………………………………………………….……….…1 2.2 Scope ………………………………………………………………………….…...…2 2.3 Methodology ………………………..………………………………………….…….3 3 ASSESSMENT STRATEGY ……………………………………...…………………….………4 3.1 Basis of assessment ……………..………………………………………….…...…5 3.2 Standards and Criteria ……………………………………………………….…...... 5 4 ASSESSMENT OF TECHNICAL SUBMISSIONS ………………………..…………….…….6 4.1 BAE Systems Marine Ltd RoA/HIRE (Wet Dock Quay)………………….………6 4.2 MOD RoA/HIRE (Ramsden Dock Basin)…………………………………..………6 4.3 ONR Technical Assessment (WDQ and RDB)……………………………..……..7 5 ASSESSMENT OF PRACTICAL AND STRATEGIC CONSIDERATIONS .....…………..…8 6 CONCLUSIONS AND RECOMMENDATIONS ……………………………….……....…...... 19 6.1 Conclusions ………………………………………………………………………….20 6.2 Recommendations ………………………………………………………………….21 7 REFERENCES …………………………………………………..………………………………22

Appendix A: Maps ………………………………………………………………………………..24 Map 1: Map of Barrow REPPIR off-site emergency planning areas: 2002 - 2014 Map 2: Map of the Peninsula (10 km radial distance from the WDQ) Map 3: BAE Systems Submarine Solutions Shipyard at Barrow-in-Furness Showing licensed site and transit route to the RDB Map 4: Boundary of . Map 5: Potential Barrow off-site emergency planning area and population areas extending to 2 km and 3 km

Appendix B: Demographic data for the area around Barrow-in-Furness …………………28

Appendix C: ONR determination of the REPPIR off-site emergency planning area and the REPPIR prior information area around the Barrow GB nuclear site and nuclear warship site ……………………………………………………..…………………………………………..30

Office for Nuclear Regulation

1 REGULATORY CONTEXT

This report sets out the outcome and justification for the determination of the revised Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) off-site emergency planning and prior information areas for the Barrow GB nuclear site and nuclear warship site, in accordance with the requirements of REPPIR regulations 9(1) and 16(1) respectively (reference 1).

2 INTRODUCTION

2.1 Background The UK nuclear regulatory framework requires that every licensee must demonstrate to the regulator that it fully understands the hazards and risks associated with its operations and controls them appropriately. The regulator challenges the safety and security of the design and operation of nuclear plant to ensure that licensees’ provisions are robust, and that any risks are reduced so far as is reasonably practicable. Barrow BAE Systems Marine Ltd (BAESM) constructs, tests and commissions nuclear powered under contract from the Ministry of Defence (MOD) at the Barrow GB nuclear site. The actual operation of the nuclear reactor, at this location, takes place only for a short period of time at the end of each submarine build (i.e. it is an occasional operation only). The submarines are subsequently prepared for sea at the Ramsden Dock Basin (RDB), which is a nuclear warship site. The operator of this latter site is the MOD. The RDB is a holding berth, and submarines are intended to spend a limited number of days (or perhaps hours given favourable weather and tidal conditions) at this location prior to their transit to sea. In relation to emergency planning, REPPIR requires operators, in this case BAESM (Wet Dock Quay, WDQ) and MOD (RDB), to undertake hazard identification and risk evaluation (HIRE) of all hazards arising from their work with the potential to cause a radiation accident on their respective sites. The assessment must be sufficient to demonstrate that all such hazards have been identified and the nature and magnitude of the risks to employees and other persons arising from those hazards have been evaluated. REPPIR also requires that operators submit a report of the assessment (RoA) of this hazard identification and risk evaluation to the Office for Nuclear Regulation (ONR) prior to commencement of the work, following any material change, and at least every 3 years. At Barrow, ONR regulates the BAESM site which, under the Energy Act, includes the regulation of nuclear and conventional safety. For REPPIR submissions, the Defence Nuclear Safety Regulator (DNSR) provides support to the ONR. However, under the Energy Act, ONR is solely responsible for making REPPIR determinations on GB nuclear sites and nuclear warship sites. Where it is reasonably foreseeable that a radiation emergency (as defined in REPPIR) might arise, REPPIR requires ONR to define areas within which, in its opinion, persons (including any member of the public) are likely to be affected by such emergencies. This then defines the area for which local authorities are required to prepare an adequate off-site emergency plan (regulation 9(1)) and for which operators are required to provide specified prior information (regulation 16(1)) without it having to be requested. The off-site emergency plan, in cases where one is required, should include countermeasures and other protection measures as are relevant, reasonably practicable, and proportionate to the radiological risk in the event of a reasonably foreseeable radiation emergency. NB. ONR has historically used the term ‘detailed emergency planning zone’ (DEPZ) to refer to the area it defined under REPPIR regulation 9 as requiring an off-site emergency plan. (The term is still used this way in some ONR guidance.) As the term is not used within REPPIR itself (although referred to in the related guidance), and to ensure legal clarity and avoid misunderstanding amongst stakeholders, this report

Page 1 of 30 refers to the ‘REPPIR off-site emergency planning area’ and the ‘REPPIR prior information area’ under regulations 9 and 16 respectively rather than to ‘detailed emergency planning zone’ or ‘DEPZ’. ONR is of the opinion that the extent of areas for local authority off-site planning and for the provision of prior information by the operator should be the same. This is a reflection of the factors considered by ONR for determination of these areas are the same. As a consequence, and for simplicity, where the term ‘REPPIR off-site emergency planning area’ is used in this report, it should be assumed to refer equally to the off-site emergency planning and prior information areas. Following the determination by ONR, the local authority is required to prepare an adequate off-site emergency plan. In so doing, the local authority has a legal obligation to consult a range of persons (including the operators, the Emergency Services, the relevant health authority, and such other persons, bodies and authorities and members of the public as it considers appropriate). This plan must then be reviewed and, where necessary, revised at least every three years, with an equivalent requirement to test the plan. The local authority off-site emergency planning and prior information area around the Barrow sites, as provided for in REPPIR regulations 9(1) and 16(1), was first determined in 2002 - a short while after REPPIR came into force in 2001. This area was represented by circular areas around the two sites with a radius of 2 km (appendix A, map 1). This report sets out ONRs considerations in determining revised REPPIR off-site emergency planning and prior information areas for the Barrow sites. It takes due account of the findings of the BAESM and MOD RoAs/HIREs and of ONR’s principles and guidance.

2.2 Scope This assessment sets out the basis for, and conclusions of, the re-determination of the REPPIR off-site emergency planning and prior information area relating to the Barrow sites. This has been undertaken in accordance with HSE’s guidance on REPPIR (reference 1) and the relevant ONR supporting Technical Assessment Guide (TAG) (reference 2), which incorporates ONR’s recently revised principles for determination of REPPIR areas, and related guidance. ONR’s revised principles recognise the learning that has emerged from global events such as occurred at Fukushima and the need to review the scope of off-site emergency planning. They also reflect ONR’s insistence on, and commitment to, high standards of nuclear safety and security at nuclear installations, and its continual efforts to seek improvements to standards and to the consistency and transparency of its decision-making. Where this report refers to ‘Barrow’, it relates to the area adjacent to and containing both the BAESM GB nuclear site and the MOD operated nuclear warship site, unless otherwise indicated. In REPPIR regulation 2(1), “premises” is defined such that .’…where a radioactive substance forms an integral part of a vessel and is used in connection with the operation of that vessel, it includes that vessel when it is at fixed point moorings or alongside berths, save that such vessel shall be deemed to be separate premises only where such moorings or berths do not form part of a licensed site or part of premises under the control of the Secretary of State for Defence.’ REPPIR guidance (paragraph 44, reference 1) clarifies that vessels that are powered by nuclear reactors are to be treated as separate premises when at fixed point moorings such as buoys or alongside berths, unless they are moored at a nuclear licensed site or MOD- controlled premises in which case they are part of those premises ONR was informed that, apart from the WDQ and RDB, there were no other fixed point moorings for vessels powered by nuclear reactors at Barrow (reference 3). In addition, under REPPIR regulation 2(1) “transport” means ‘.transferring or conveying a radioactive substance through any public place otherwise than –

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(i) by rail, road, inland waterway, sea or air; or (ii) by means of a pipeline or similar means’ Thus, REPPIR applies to transport operations through any public place other than by standard transport modes or pipelines (REPPIR guidance paragraph 64). In consequence, although submarine movements within the dock system, along the channels and at sea include areas with public access, these movements are addressed under other legislation (e.g. Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (reference 4) and are outside the scope of this REPPIR determination. For the purposes of determining the REPPIR off-site emergency planning area, ONR is of the opinion that it would be neither appropriate nor proportionate to include, within the REPPIR off-site emergency planning area, the extent of potential long-term health protection recovery measures associated with the restriction of food. The provisions for the implementation of food restrictions are contained in the Food and Environment Protection Act 1985 (FEPA) and are determined and enforced by the Food Standards Agency (FSA). As these provisions are addressed by separate legislation, may be exercised in a broad range of circumstances (i.e. not restricted to a radiological event), and are subject to existing planned implementation arrangements made by the FSA, this is viewed as being independent of the local authority off-site emergency plan under REPPIR.

2.3 Methodology ONR’s process for determining a REPPIR off-site emergency planning area requires that it: A. Conduct an initial technical assessment of the information provided by the operators in the Barrow HIREs and RoAs; and B. Establish and consider any other relevant practical and strategic factors (e.g. relating to the planning and practical implementation of measures to restrict public exposure so far as is reasonably practicable (e.g. countermeasures) for those persons who are likely to be affected by a radiation emergency etc). Step A: requires ONR to assess the operator’s determination of whether it does, or does not, have legal duties under REPPIR and, if so, to identify and characterise the likelihood, nature and magnitude of the radiation related risks that may result from a reasonably foreseeable radiation emergency. ONR assesses the content and findings of the operators’ HIREs and RoAs and considers the likely extent of the area within which the dose criteria contained within Schedule 1 of REPPIR may be met or exceeded. This indicates the minimum distance for consideration in Stage B, and is usually presented in operators’ HIRE reports as a circle with a specified radius centred at the source of a potential release. Whilst Stage B applies additional factors to the ONR determination, and whilst the determined REPPIR off-site emergency planning area need not be circular, it cannot be smaller than that arising from the technical assessment under Stage A. Step B: requires the consideration of a range of pragmatic, demographic, geographical and practical factors, and includes dialogue with the relevant local authority. The nature of the relevant practical and strategic factors considered is set out in detail in the relevant ONR Technical Assessment Guide (reference 2). ONR’s principles relating to practical and strategic considerations (reference 2) emphasise that, in the undertaking of the determination, it is important to ensure that a sensible balance is achieved between the assessment of the technical report provided by the licensee and such additional practical and strategic considerations that, in ONR’s opinion, are judged necessary in the interests of confidence in public safety. As a consequence, the extent of the REPPIR off-site emergency planning area represents a regulatory judgement of the significance of all of these factors, and is made on a case-by-case basis. The factors that ONR’s principles and associated guidance indicate should be considered are summarised as follows: • local geographic, demographic and practical implementation factors; Office for Nuclear Regulation page 3 of 30

• avoidance of bisection of local communities where sensible to do so; • inclusion of immediately adjacent groups of vulnerable people; • the credibility and confidence in the extent of REPPIR off-site emergency planning area for the purposes of public protection; • consideration of the implications of the extent of the REPPIR off-site emergency planning area in the context of an effective emergency response (e.g. dilution of resources, potential dis-benefits associated with immediate/urgent countermeasures); • international good practices; and • other relevant site specific factors of which ONR may be aware. The purpose of the ONR determination is to define the area for which the local authority must prepare off-site emergency plans (under REPPIR, for the purpose of securing, so far as is reasonably practicable, the restriction of exposure to ionising radiation and the health and safety of persons who may be affected by a reasonably foreseeable emergency) and across which the operator must provide prior information to the public without their having to request it. For single facility sites, the area is based on the most significant reasonably foreseeable event (referred to in reference 2 as the ‘reference accident’, and described as an event which is less than likely but realistically possible) such as possible plant and equipment failures, breakdown of administrative arrangements, and potential unauthorised behaviour of employees or the public. For events that are judged to be beyond reasonably foreseeable (e.g. extremely low frequency but potentially higher consequence events), the guidance associated with REPPIR notes, as a good practice, that local authorities should be capable of extending their emergency response beyond the REPPIR off-site emergency planning area should it be necessary to do so. However, as such extended zones are not statutorily required under REPPIR, such arrangements are not considered further in this determination. The most commonly referenced off ‐site countermeasures available in the early stages of a nuclear emergency in order to reduce radiation doses to members of the public are sheltering, evacuation and, in the case of operating nuclear power reactors, the administration of iodine prophylaxis (potassium iodate tablets). In determining a REPPIR off-site emergency planning area, ONR acknowledges that the implementation of countermeasures can, in some circumstances, convey a risk to individuals to whom they are applied. For example, in relation to the countermeasures taken following the Fukushima accident in Japan in March 2011, Koichi Tanigawa et al. report in the Lancet journal on the loss of life that occurred as a result of the implementation of evacuation (reference 5). As, within a REPPIR off-site emergency planning area, the local authority may expect some countermeasures to be applied immediately or urgently across at least a part of the area, it is important that the area within which they may be applied in this manner is not excessive in order to ensure that overall risks to those affected are reduced so far as is reasonably practicable.

3 ASSESSMENT STRATEGY The assessment strategy for the determination of the REPPIR off-site emergency planning area is summarised as follows:

3.1 Basis of assessment The REPPIR off-site emergency planning area must, as a minimum, include all of the area around the sites within which a person (including members of the public) could receive an effective dose in excess of 5 mSv in the year following a reasonably foreseeable radiation emergency (or other dose criteria defined in REPPIR schedule 1). [NB. Note that REPPIR requires that when operators assess the doses to members of the public, they must assess the potential doses from all exposure routes and, for this purpose, must disregard any health

Office for Nuclear Regulation page 4 of 30 protection measures that may be taken during the first 24 hours immediately following the event]. The current REPPIR off-site emergency planning area is based on two overlapping circles of radius 2 km centred on the WDQ and RDB. This off-site emergency planning area dates to 2002 and was derived using pessimistic assumptions (i.e. based on the radiological risk presented by a Representative Patrol Cycle for a Trafalgar Class submarine reactor core). In 2008, a revised approach was developed for the Representative Patrol Cycle of Vanguard, and later Astute Class submarines based on reference accident methodology. DNSR assessed this work and, using this information, ONR determined a revised circular REPPIR off-site emergency planning area of 1.5 km (reference 6). Notwithstanding the adoption of the generic 1.5 km REPPIR off-site emergency planning area for MOD operational berths, 2 km radius overlapping circles were retained locally for the WDQ (and the RDB). BAESM (WDQ) and MOD (RDB) have submitted their HIREs and RoAs, which form the basis of ‘Step A’ (see Section 2.3) of the assessment and determination described in this report. Although the Barrow site is comprised of the separate WDQ and RDB sites, this assessment relates to the determination of a single REPPIR off-site emergency planning area around the two adjacent sites as provided for in REPPIR. A single area serves to aid the practicality and integration of emergency preparedness and response.

3.2 Standards and Criteria 3.2.1 Acts, regulations and guidance The relevant standards and criteria considered within this assessment are those contained within the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) (reference 1) and its associated guidance. REPPIR is made under the Health and Safety at Work Act 1974 and implements the articles on intervention in cases of radiation emergencies contained in the European Council Directive 96/29/EURATOM - Basic Safety Standards for the Protection of the Health of Workers and Members of the Public against the Dangers from Ionising Radiation (reference 7). 3.2.2 Safety Assessment Principles ONR’s Safety Assessment Principles (SAPs) provide inspectors with a guiding framework for making consistent regulatory judgements on nuclear safety cases. Although the SAPs are not directly relevant to the assessment of REPPIR submissions, cognisance has been taken of SAP: AM.1 - Accident management and emergency preparedness (reference 8). 3.2.3 Technical Assessment Guides The SAP principles are supported by a suite of internal Technical Assessment Guides (TAGs), with the following TAG being applied in this assessment: • The technical assessment of REPPIR submissions and the determination of detailed emergency planning zones, ONR NS-TAST-GD-082 Revision 2 2013 (reference 2). This TAG incorporates ONR’s revised principles for determination of REPPIR off-site emergency planning areas. 3.2.4 National and International Standards and Guidance The following national guidance has also been considered and, where appropriate, has informed the conduct of this assessment: • A guide to the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (reference 1). ONR also notes the relevance of the following International Standards and Guidance: • IAEA Safety Standard Series – Preparedness and Response for a Nuclear or Radiological Emergency GS-R-2 (reference 9). • IAEA Safety Standards – Arrangements for Preparedness for a Nuclear or Radiological Emergency GS-G-2.1 (reference 10). Office for Nuclear Regulation page 5 of 30

4 ASSESSMENT OF TECHNICAL SUBMISSIONS BAESM (WDQ) and MOD (RDB) have submitted their hazard identification and risk evaluations (HIREs) and reports of assessment (RoAs) for their respective sites to ONR (references 11 to 13). ONR has subjected these submissions and supporting documentation to expert technical assessment and the conclusions are reported separately (reference 14). These conclusions are summarised as follows: 4.1 BAE Systems Marine Ltd RoA/HIRE (Wet Dock Quay) BAESM’s REPPIR submissions (references 11 and 12) are concerned only with the activities at the WDQ, but are underpinned by the site-independent generic assessment for Astute Class submarines (reference 15) referred to in section 3.1 above. The reference accident in the generic assessment is defined as a leak in the primary cooling circuit of the reactor, which cannot be isolated and is beyond the capacity of coolant make-up systems. This primary coolant leak, coupled with engineering and other failures, leads to damage to the fuel within the reactor, which, in turn, releases some radioactive material from the reactor. This is largely contained within the submarine, and hence the dose to a member of the public is dominated by gamma shine, although a small part of the release inventory may be released to the environment. This leads to a circular area of radius 0.9 km within which a person might receive a radiation exposure of 5 mSv or more. The BAESM HIRE identifies that the site-independent generic assessment reactor plant faults in an Astute class submarine core (reference 15) are based on a reactor core inventory (source term) resulting from a Representative Patrol Cycle for a typical operational vessel. This represents an irradiated core with a significant related fission product inventory. However, and in contrast, a newly installed reactor core at BAESM will be undergoing Power Range Testing; that is the core will be comparatively unirradiated (with a small fission product inventory). This means that the actual reactor cores present at BAESM will contain significantly fewer fission products than an Astute core at the end of a Representative Patrol Cycle. On that basis, the assumption in the HIRE is viewed as pessimistic (i.e. had the more realistic unirradiated core assumption been used, a smaller area than the 0.9 km radius circular area previously identified would be expected to result from the reference accident considered in the generic assessment). The dose resulting from a combination of the gamma shine and a small proportion of primary containment leakage associated with the reference accident was calculated by scaling the dose from the generic Astute assessment according to the decay heat level expected at the WDQ. BAESM have calculated a dose of 5 mSv from the combination of the gamma shine and aerial dose which may be accrued out to a distance of 690 m from the centre of any such event at WDQ. (Note BAEASM round the estimate to the nearest 100 m and hence advise a distance of 700 m from the centre of the event.)

4.2 MOD RoA/HIRE (Ramsden Dock Basin) Correspondingly to the BAESM RoA, the MOD RoA (reference 13) is concerned only with activities at the RDB. Essentially the same approach was adopted as in the BAESM RoA and HIRE, along with consideration of local hazards and a comparison with the Astute fault set, in order to determine a bounding fault which could be used as a reference accident. The reference accident is therefore the same as that described in section 4.1 above. ie. a 5 mSv contour at 690 m (rounded to 700 m) from the centre of the event at RDB.

4.3 ONR technical assessment (WDQ and RDB) ONR’s technical assessment of the BAESM RoA/HIRE took cognisance of the assessment and acceptance of the site-independent generic Astute HIRE by the Defence Nuclear Safety Regulator (DNSR). ONR reviewed the BAESM and MOD reports, focusing mainly on the BAESM HIRE as it underpins the other documents. The aim of the ONR technical review was Office for Nuclear Regulation page 6 of 30 to assess how well the BAESM and MOD submissions met the requirements of REPPIR, mainly with respect to the representation of a reasonably foreseeable radiation emergency and the calculation of the distance from the relevant locations at WDQ and RDB to the 5 mSv contour. ONR’s specialist technical inspector concluded (reference 14) that both the BAESM RoA and HIRE for the WDQ, and the MOD combined RoA/HIRE for the RDB, adequately met the requirements of REPPIR with respect to the representation of a reasonably foreseeable radiation emergency, and the calculation of the distance from the relevant locations at WDQ and RDB to the 5 mSv contour. In both cases, a value of 690 m (note BAESM round to 700 m) has been used as the distance from the centre of the reasonably foreseeable radiation emergency to the 5 mSv contour. ONR’s specialist technical inspector agreed that this distance was justified by appropriate technical analysis. However, this distance is informed solely by the technical assessment and does not consider the application of strategic and practical factors (which ONR undertakes in section 5).

4.4 Conclusions of technical assessments ONR is satisfied that the reactor core at the WDQ and RDB will contain significantly fewer fission products than an Astute Class submarine core at the end of a Representative Patrol Cycle. Thus the hazards, and hence risks, presented at Barrow are reduced compared to those that may be associated with an operational submarine in a MOD operational berth. In consequence, a smaller circular area than the previously identified 0.9 km radius (for an operational Astute Class submarine) would be expected to result for the reference accident. ONR therefore considers it is reasonable to account for the site specific activities at Barrow (i.e. it is not an operational berth at which submarine reactor cores with significant fission product inventories may be berthed), in deriving the technical area associated with the REPPIR off-site emergency planning area. This is reflected in ONRs technical assessment with the distance to the 5 mSv contour reduced to 690 m (from 0.9 km). Based on ONR’s technical assessment report, which was informed by DNSR’s acceptance of the generic Astute HIRE, ONR concludes that both the BAESM RoA and HIRE for the WDQ, and the MOD combined RoA/HIRE for the RDB meet the requirements of REPPIR with respect to: • the representation of a reasonably foreseeable radiation emergency; and • the calculation of the distance from the relevant locations at WDQ and RDB to the 5 mSv contour. In both cases, a value of 690 m is calculated as the distance from the centre of the reasonably foreseeable radiation emergency to the 5 mSv contour.

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Conclusion 1 : ONR is satisfied through examination of the technical submissions made by BAESM and the MOD that the reactor core at the WDQ and RDB will contain significantly fewer fission products than an Astute core at the end of a representative patrol cycle. It is therefore reasonable to account for the reduction in hazards and risks presented at Barrow compared to a MOD operational berth. For both the WDQ and the RDB, a value of 690 m is accepted as the distance from the centre of the reasonably foreseeable radiation emergency to the 5 mSv contour.

5 ASSESSMENT OF PRACTICAL AND STRATEGIC CONSIDERATIONS FOR THE DETERMINATION OF THE BARROW REPPIR OFF-SITE EMERGENCY PLANNING AREA AND THE REPPIR PRIOR INFORMATION AREA

The purpose of the REPPIR off-site emergency planning area is to define the area for which the local authority must prepare an off-site emergency plan. This plan must be adequate to restrict exposures to the public, so far as is reasonably practicable, in the event of a reasonably foreseeable radiation emergency. The ONR assessment report (reference 14) of the licensee’s and the MOD’s submissions to ONR (references 11 to 13) concluded that the REPPIR off-site emergency planning area should extend at least to a radial distance of 690m from the respective locations of the reference accident releases for the WDQ and RDB. These distances represent the areas within which the technical assessments indicate that persons may be exposed to 5 mSv or more in the 12 months following a reasonably foreseeable radiation emergency (assuming that any health protection measures taken in the first 24 hours are disregarded). At the request of ONR, BAESM provided additional information (reference 16) to confirm that the assumptions used in the dose estimates, which underpin the RoA/HIREs (WDQ and RDB), accord with the requirements of REPPIR. In particular, ONR sought assurance that the effective dose estimates considered all dose routes, were integrated over a period of one year following the postulated radiation emergency, bound equivalent doses, and no allowance was made for health protection measures within the first 24 hours. The assessor was satisfied with the BAESM response, and hence the validity of the estimate of 690 m to the 5 mSv effective dose contour. In accordance with ONR’s technical assessment guidance and the principles incorporated therein (reference 2), ONR must also give consideration to the practicality (in an emergency planning sense) and pragmatism of the REPPIR off-site emergency planning area by considering a number of factors considered to be relevant in securing confidence regarding the effectiveness of the plans to deliver protection of the public. In the course of considering these factors, ONR has engaged in dialogue with Cumbria County Council, which is the duty holder under REPPIR for the off-site emergency plan for Barrow. The significance of these factors is discussed below.

5.1 Local Geographic, Demographic and Practical Implementation Factors ONR Technical Assessment Guide (TAG) (reference 2) indicates that “The relevant local authority is consulted on the basis that it has significant ‘local’ knowledge and has the responsibility for development and, in the highly unlikely event that it is ever necessary, implementation of the off-site emergency plan. (Note: The local authority also has the legal duty to undertake consultation in

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relation to the off-site emergency plan as provided for under REPPIR regulation 9(12))” . The BAESM and MOD sites lie within the of Barrow, which is itself located within the southern edge of the town of Barrow-in-Furness. Barrow-in-Furness is situated at the south-western extremity of the Furness Peninsula (appendix A, map 2) and is bordered by Morecombe Bay to the south and the Duddon Estuary to the north. The west of the peninsula is separated from the by Walney Island. The Furness Peninsula is largely flat and rural with some urban areas. Along with tourism, farming is the Peninsula’s primary industry. Barrow-in-Furness, however, is an industrial town with manufacturing being the largest employment provider. Barrow-in-Furness is the largest settlement in the area with a total population (including Walney Island) of approximately 56,500. Other large settlements within 12 km from the BAESM licensed site include Dalton-in-Furness (population 8,000, approx 7 km north-east), Urswick (population 1,500, approx 10 km north-east) and Askam-in-Furness/ Ireleth (population 3,600 approx 12 km north). Nearby features of note include itinerant locations in the form of marine areas associated with the Barrow dock system, three caravan/campsites on Walney Island, and the Abbotswood, North Walney, South Walney, and Sandscale Haws nature reserves. Access to the is gained from the Irish Sea through the harbour along the tidal Walney Channel (appendix A, map 3). There are extensive sandbanks around much of the Peninsula’s coastline and the high ground north of Barrow climbs to between 150 and 300 metres above sea level. The meteorological conditions are typical for Cumbria with a prevailing wind from the west and above-average UK rainfall. Barrow is usually protected from wintry weather by its proximity to the Irish Sea, and the high ground to the north and east. The Barrow Dock System (appendix A, map 3) consists of the Devonshire, Buccleuch, Ramsden and Cavendish Docks. is situated to the north-east of Ramsden Dock and is connected to it by a sluice, which can be used to control water levels. The Dock System is owned and operated by Associated British Ports Holdings Ltd (ABP). The BAESM licensed site itself is located to the west of the port. The principal facilities within the licensed site are Wet Dock Quay, the Hall and the ship lift. BAESM is responsible for the construction and commissioning of nuclear powered submarines under contract from the MOD. The actual operation of the nuclear reactor only takes place once over a 2 month period at the end of each 2 to 3 year submarine build. The submarines are prepared for sea at Ramsden Dock, which is a nuclear warship site. This is operated by MOD. The Ramsden Dock Basin (RDB) is a holding berth, and submarines are intended to spend a very limited period (1-2 days, or perhaps only hours dependent on the weather and tidal conditions) at the RDB prior to their transit to sea. Currently, the Astute Class of submarine is in production on the site. The first and second of class completed their build and commissioning schedule, and left the site in November 2009 and September 2012 respectively. Subsequent vessels of the Astute Class are, at the time of writing of this document, under construction and at varying degrees of completeness. Cumbria County Council (CCC) has been consulted regarding potential local geographic, demographic and practical implementation factors, with the response received (reference 17 and 18) reflected in the appendices, and throughout this section of the report. ONR is also aware that (based on the consideration of the local geography, road network, centres of population and following consultation with BAESM, Barrow Borough Council, Public Health England (PHE) and the Director of Public Health) CCC issued a consultation document (“Off Site Emergency Plan – Proposed Changes to Detailed Emergency Planning Zone in September 2013” (reference 19)). CCC used the results of this consultation to help inform its response to ONR. ONR indicated its starting point of an initial area of radial distance of not less than 1 km from the relevant locations at WDQ and RDB, which would generate an area formed by two overlapping circles. In order to simplify the response arrangements and so improve the Office for Nuclear Regulation page 9 of 30 effectiveness of the off-site emergency response arrangements, CCC proposals for this area were combined into a single REPPIR off-site planning area. CCC also advised ONR (references 17 and 18) that in order to enhance delivery of effective emergency planning, it is of the view that the REPPIR off-site emergency planning area should be defined using a combination of physical features e.g. the course of the Furness/Cumbria Coast railway line and electoral ward boundaries. ONR accepts CCC’s advice.

Conclusion 2 : The REPPIR off-site emergency planning area boundary should be defined, so far as is sensible, by the use of physical, geographical and electoral ward boundaries (to assist Cumbria County Council in the preparation and implementation of off-site emergency plans).

ONR’s opinion is that the REPPIR off-site emergency plan needs to include adequate provision to control the access of maritime traffic during a radiation emergency. The option of using ward and physical boundaries also exists in defining the boundaries associated with the water areas i.e. the inland waterways, channels and, if needed, the seaward component. Since they are part of CCC’s existing off-site emergency plan, the organisations with responsibilities for co-ordinating the exclusion of maritime traffic during a radiation emergency were consulted. These organisations include ABP and the Maritime and Coastguard Agency (MCA). The ABP owns and operates the Barrow Dock System. ONR sought assurance on the geographic areas of responsibility and following consultation with ABP and MCA, CCC agreed with ONR that it would be more appropriate to utilise ABP jurisdiction lines as the limits of the channel boundaries rather than ward boundaries (reference 20). These ABP jurisdiction lines include the line across the Scarth channel to the north and from Rape Haw on Walney Island to Westfield Point to the south. Note that the actual limits of the southern ABP jurisdiction extend to the Piel Channel and Piel Harbour which forms the county boundary. The use of established ABP limits has the advantage of affording consistency with the Harbour Master’s jurisdiction (appendix A, map 4). In addition, in my opinion it would provide a more effective means of controlling maritime traffic than an earlier proposal to sub-divide the Walney, Piel and Scarf channels based on ward boundaries. The MCA is responsible for the sea areas beyond the jurisdiction of the ABP, in particular, the sea area to the west of Walney Island. However, this area is beyond 2 km from the WDQ and RDB, and so in my opinion, it would not be proportionate in this specific case to define a sea area as part of the REPPIR off-site emergency plan. In practice, the MCA advised that, for operational purposes that HM Coastguard, the UK maritime emergency service, will provide a response as necessary (reference 21). ONR is also aware that co-ordination with the MCA forms part of CCC’s current extendibility arrangements (reference 22). In addition, the MCA holds generic duties under the Civil Contingencies Act 2004 (CCA) (reference 23) and specific duties under various Merchant Shipping Acts, which would involve co-ordinating a response to an emergency that is on the seaward side of the shoreline boundary. ONR was made aware that the shoreline boundary is defined by national agreements between the Association of Chief Police Officers/ MCA and is based on the Mean High Water Mark (MHWM). If the incident is on the seaward side, co-ordination is undertaken by the MCA, whereas on the landward side, co-ordination is with the police. An earlier CCC proposal based on local authority ward boundaries included extension of the land based area to the Mean Low Water Mark (MLWM). This has the advantage that provision can be made to ‘warn/inform’ members of the public who may be using the beach/sea and so avoids potential ‘gaps’ in protection. Overall, ONR accepts that it is sensible to delineate the REPPIR emergency planning area based on the extent of the water boundaries along the channels using established ABP Office for Nuclear Regulation page 10 of 30 jurisdiction lines. However, to assure the protection of the itinerant population which may occupy the beaches, ONR considers that the extent of the emergency planning area along the shoreline boundary should, where sensible, be defined using electoral ward boundaries. This accords with conclusion 2, and in this specific case, where practicable, is equivalent to the MLWM. Note that the ABP jurisdiction lines use the MHWM.

Conclusion 3 : The extent of the REPPIR emergency planning area, as regards the watercourses, should be defined using a combination of established ABP jurisdiction lines across the Walney and Scarf channels, and where sensible, geographical and electoral ward boundaries.

5.2 Credibility and Confidence in the Extent of the REPPIR Off-Site Emergency Planning Area

ONR Technical Assessment Guide (TAG) (reference 2) indicates that: “Although REPPIR places the duty on the independent regulator to make an objective and unbiased regulatory determination of the extent of the REPPIR off-site emergency planning area (formerly DEPZ), ONR considers that, in the interests of confidence in public safety (noting the assumptions and estimations used to determine the 5 mSv contour), the DEPZ should be of sufficient extent so as to provide for a meaningful off-site emergency plan. It should, therefore, incorporate an appropriate degree of conservatism and pragmatism, and provide for a credible and effective response in the event of a reasonably foreseeable radiation emergency.” The results of ONR’s technical assessments of the RoAs submitted by the dutyholders confirm that the limit of the extent to which members of the public may be exposed to ‘5 mSv in the year following a reasonably foreseeable radiation emergency’ is a distance of 690 m from either the WDQ or the RDB berth. A best estimate of the current population provided by CCC indicates that there are approximately 1,904 inhabitants and 1,163 households within 700 m (i.e. 690 m rounded to the nearest 100 m) from the WDQ (reference 24). These data highlight the level of protection challenge associated with the population resident within the immediate area local to the GB nuclear site. In contrast, there are no households or residential populations within 700 m of the RDB (reference 24). ONR is mindful of the absence of a permanent population within 700 m of the RDB, but considers that the absence of a significant population to protect can be addressed, provided there is a unified, credible and effective plan to cover both sites. However, REPPIR states that the safety objective of the planning undertaken by local authorities with the REPPIR off-site emergency planning area is to ‘…secure, so far as is reasonably practicable, the restriction of exposure…’ to ‘…persons who may be affected…’ by a reasonably foreseeable radiation emergency, rather than simply to restrict public exposures in such an event to 5 mSv over the following year. ONR takes cognisance of the close proximity to the WDQ of the residents of Barrow-in-Furness and Walney Island and that, whilst UK licensees are undoubtedly conservative in their approach to nuclear safety, complex technical assessments of potential emergency situations such as this rely, inevitably, on a range of assumptions, judgements and estimates. ONR is satisfied that the REPPIR submissions made by the operators demonstrate that the hazards and risks associated with the Barrow sites are less than that of a generic MOD operational berth. Nonetheless, ONR is of the opinion that it is appropriate, where public safety is at stake, that it should act with reasonable conservatism in its own right, in the interests of securing the public safety objective of REPPIR.

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As a consequence, ONR’s principles recognise that an off-site emergency planning area, which demands little by way of an emergency plan in practice, may not be capable of providing sufficient flexibility in the (albeit extremely unlikely) event that the technical assumptions, judgements or estimates made by licensees are challenged in practice. It is my judgement that this is a relevant consideration in the case of the WDQ because the site is within the town of Barrow-in-Furness and is also in close proximity to the significant population of Walney Island. The population of approximately 1,900 living within 700 m of WDQ represents a small proportion (< 5%) of the adjacent combined population of Barrow-in-Furness and Walney Island (approximately 56,500). In this context, restriction of the extent of the plan to this small area (and population) would not, in my opinion, be sufficient to provide for a credible and effective off-site emergency plan to secure protection of the public in the highly unlikely event that some of underlying risk estimates associated with a reasonably foreseeable radiation emergency at the WDQ transpired to be optimistic. In addition, parts of the eastern beaches of Walney Island are captured within a 700 m distance of either the WDQ or RDB. Walney Island holds a significant residential population of around 10,600 (reference 25). Given that road access is served by a single major road (via the Jubilee bridge) which passes within 400 m from the WDQ, CCC has expressed concerns relating to the effectiveness of the implementation of prompt countermeasures (in particular, the provision for stable iodine distribution and evacuation (references 17 and 18)). Notably, control of access and ingress to Walney Island would be afforded by inclusion in the off-site planning area. This would also serve to improve the effectiveness of PITs distribution. The vulnerability of the population of Walney to isolation was apparent from an ONR site visit (reference 26). The flooding on Walney Island during the January of 2014 also serves to highlight the potential for isolation (reference 27). A difficulty is that, in the unlikely event of evacuation of parts of Walney Island, this would inevitably require moving individuals closer to the source of the radiation emergency for a limited period because access to Walney Island is controlled by the Jubilee Bridge. This, therefore, merits careful planning and consideration in the interest of public safety. In my opinion, the potential isolation of the large residential population of Walney Island is an important consideration in defining the REPPIR off-site emergency planning area for Barrow. I am mindful of the CCC concerns and, on balance, consider it appropriate to include Walney Island as part of the REPPIR off-site emergency planning area in order to ensure that CCC is able to make effective provision for the implementation of the off-site emergency arrangements (e.g. stable iodine tablet distribution and the control of access/ ingress). ONR does emphasise that the inclusion of Walney Island is not based on any change in risk to the public. On the contrary, it reflects strategic considerations which are aimed at improving the effectiveness of the emergency arrangements and hence affording improved public protection to residents and visitors alike. To examine the extent of the area necessary to provide for a meaningful off-site planning area, I have considered the off-site emergency planning challenge that would be presented by the area proposed by CCC following their consultation with BAESM and other response organisations. This comprises 1 km radial area from the WDQ and RDB with extension to include Walney Island and areas of land based on ward boundaries, and the division of Barrow-in-Furness town by the route of the Furness/ Cumbria Coast railway line that runs from the south-east to the north-west corners of the town. This provides for a clear demarcation with respect to public communications and so limits the potential for confusion. CCC also advised that, in combination with the electoral ward boundaries, this area would afford efficient traffic management in the unlikely event of a radiation emergency (reference 17 and 18). Information, provided by the local authority (reference 18), on the population within the 1 km radius of the sites with extension (including the ward and Walney Island) indicates the following estimates (appendix B): - a permanent population of 24,785

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- transient populations associated with tourism and the nearby presence of the retail outlets (for example there are several retail outlets within 1 km of the WDQ and 3 camping/caravan sites on Walney Island); - 12,678 households and at least 1,623 commercial properties; - vulnerable groups within or close to this area (i.e. 7 care homes, 10 children centres, 14 schools, marine moorings with the occasional visit from cruise ships); and The demographic data indicates a significant increase in the population for a relatively small increase in distance from the original 700 m radial area discussed above, albeit the data includes the population of Walney. The data is indicative of a small area of high population density. I consider this provides a reasonable basis for a credible off-site emergency response plan. Therefore, it is my opinion that the REPPIR off-site emergency planning area should extend to at least 1 km from the WDQ (or RDB), should include a part of Barrow-in-Furness, and (given the potential for isolation of island occupants) the entirety of Walney Island. In practice, the distance defined by the course of the Furness/ Cumbria Coast railway and electoral ward boundaries varies between approximately 1.2 km and 2 km from the WDQ. It is noted that the northern boundary of the area within the town of Barrow-in-Furness could be effectively drawn a line across from the boundary of railway property to the coast and that this would exclude the fire station and the multi-agency control centre.

Conclusion 4 : Noting the proximity of Barrow-in-Furness and Walney Island, a REPPIR off-site emergency planning area of less than 1 km from the WDQ (and RDB) would not provide for a credible or effective plan to secure the protection of the public, or restriction of exposures so far as is reasonably practicable, in the event of a reasonably foreseeable radiation emergency. Consequently, the REPPIR off-site emergency planning area should extend to at least 1 km, include at least part of Barrow, and given the risk of isolation, the whole of Walney Island.

5.3 Avoidance of Bisection of Local Communities ONR Technical Assessment Guide (TAG) (reference 2) indicates that: “Whilst accepting that it may sometimes be unavoidable, ONR’s preference is to avoid the bisection of small settlements or communities, on the basis that any REPPIR off-site emergency planning area (formerly DEPZ) determination is based on some unavoidable assumptions and estimates, and is therefore not precise. Bisection of small communities has raised concerns in terms of public perception, and also has the potential to affect the effectiveness of implementation of countermeasures.” ONR is aware that the current REPPIR off-site emergency planning areas (defined by ONR in 2002 as a circular areas of radius 2 km centred on the WDQ and RDB) already presents the situation whereby Barrow-in-Furness and Walney Island are bisected. This is clearly shown in the maps included in the Cumbria Alert Radiation Emergency information leaflet (reference 28), and has the effect that, as things stand, neighbours may find themselves inside and outside of the emergency planning area respectively. ONR is aware of the potential for confusion and public concern, and that this may result in practical differences in the levels of emergency planning and related information provided to immediate neighbours. CCC has advised that the avoidance of the bisection of Barrow-in-Furness would simplify communications and improve the effectiveness of traffic management since fewer roads would be ‘severed’ (reference 17 and 18). However, such potential benefits must be balanced against the potential dis-benefits in terms of the size of the protection challenge, unnecessary dilution of emergency resources, and the effectiveness of the off-site emergency plan itself. To inform judgements on the implications of avoiding the bisection of Barrow-in-Furness, CCC provided the following best estimate demographic data for two 3 km bisecting circles centred Office for Nuclear Regulation page 13 of 30 on the WDQ and RDB, extended to include all of Walney Island (appendix A, map 5).These areas cover the majority of Barrow-in-Furness and the whole of Walney Island: - a permanent population of 48,677 - transient populations arising from tourism and the retail activities within Barrow-in- Furness and its environs . - 23,475 households and at least 2,002 commercial properties; and - vulnerable groups within or close to this area (i.e. 14 care homes, 19 children centres, 25 schools). This demographic data highlights the extent of the emergency protection challenge if such a large area were to be adopted, particularly were the dutyholder to implement urgent health protection measures uniformly across the area. Although REPPIR does not relate solely to urgent countermeasures, nor requires that countermeasures be applied uniformly, I am mindful of the scale of the challenge and the unnecessary dilution of emergency response resources. The risks associated with evacuation (including the stress of displacement, traffic accidents etc) should not be overlooked. CCC has advised that traffic management systems would be difficult to implement and impractical to control in a resource efficient manner (reference 18). CCC raised a question as to whether the availability of operational assets, such as fire, police, and transport depots, emergency control centre, media briefing centre, and district council emergency control centre, might be affected by inclusion in the off-site planning area. ONR does not consider assets to be affected simply because they are located within the off-site emergency planning area. This issue can be addressed to the satisfaction of the emergency responders through consultation in the development of the off-site plan by the local authority. Noting that the level of risk presented by a reasonably foreseeable radiation emergency does not necessitate planning to such distances, it would not be sensible, justifiable, or appropriate in terms of assuring the effectiveness of the emergency plan, for the area to extend to include the entirety of Barrow-in-Furness. It is also my opinion that the associated benefits of including the entirety of the Barrow-in-Furness community would be grossly outweighed by the dis-benefits in this particular case. As a consequence, it is my judgement that the extent of the REPPIR off-site emergency planning area on the Barrow-in-Furness side of the WDQ and RDB should be defined using a physical and electoral ward bounded area that does not include the whole of town of Barrow-in-Furness.

Conclusion 5 : The extent of the REPPIR off-site emergency planning area on the Barrow-in-Furness side of the WDQ and RDB, should be defined using a physical and electoral ward bounded area which does not include the whole of Barrow-in-Furness

5.4 Inclusion of Immediately Adjacent Vulnerable Groups ONR Technical Assessment Guide (TAG) (reference 2) indicates that: “ONR recognises that groups of vulnerable people (e.g. care homes, schools, camping and caravan sites, itinerant populations, etc) located close to the REPPIR off-site emergency planning area (formerly DEPZ) should be provided for in the same manner as those located within the zone.” (The definition of ‘vulnerable’ groups must be the definition adopted by the relevant local authority.) I have considered information provided by CCC relating to the communities in and around the WDQ and RDB at a number of distances for the sites in question. This information is summarised in appendix B and identifies potential vulnerable groups that are included within a selection of radial distances from the sites. (NB. Camping/caravan sites are identified as vulnerable groups on the basis that the important countermeasure of sheltering could be Office for Nuclear Regulation page 14 of 30 considerably less effective for those occupying a caravan when compared to the protection offered to those who are able to shelter in a more substantial and permanent structure.) Noting ‘Conclusion 4’ (that part of Barrow-in-Furness should be included within the re-defined REPPIR off-site emergency planning area), CCC has advised ONR (reference 29) that there are no additional vulnerable groups within a 100 m wide zone of the area determined in section 6.1 of this report.

Conclusion 6 : The adoption of a REPPIR off-site emergency planning area that includes part of Barrow based on a minimum 1 km distance from the WDQ and RDB and with extension to follow the boundary of the Furness/ Cumbria Coast railway property and adjacent ward boundaries on the Barrow side need no further modification to incorporate adjacent vulnerable groups.

5.5 International Good Practice ONR Technical Assessment Guide (TAG) (reference 2) indicates that. “ONR is of the view that its decisions should be informed by accepted international good practice.” Relevant international good practice relating to nuclear emergency planning, is contained in International Atomic Agency (IAEA) publications GS-R-2 and GS-G-2.1 (references 9 and 10). The guidance document (GS-G-2.1) is non-binding, and provides one of many potential benchmarks for comparison.

In these documents, the IAEA identifies categories of reactor power output and potential ‘threat’, and advocates the adoption of two types of emergency planning zones as follows:

i) ‘Precautionary Action Zone’ (PAZ) - for which arrangements shall be made with the goal of taking precautionary urgent protective action before or shortly after the release of radioactive material occurs, in order to substantially reduce the risk of severe deterministic effects. In relation to reactors, and in the absence of substantiated detailed safety analysis, the radius of this zone is suggested to be in the range of 0-5 km. [NB. Due to differences in the UK legal framework, and the assessment of reasonably foreseeable radiation emergencies on a case-by-case basis, this zone is not directly comparable with ONR’s determination of a REPPIR off-site emergency planning area]. ii) ‘Urgent protective action Planning Zone’ (UPZ) - for which arrangements shall be made for protective action to be taken promptly, in order to avert doses off the site in accordance with international standards. This is the practical limit of the radial distance within which to conduct monitoring and to implement appropriate urgent protective actions within a few hours. In relation to reactors and in the absence of substantiated detailed safety analysis, the radius of this zone is indicated to be in the range of 0.5-30 km. [NB. Again, due to differences in the UK legal framework, and the assessment of reasonably foreseeable radiation emergencies on a case-by-case basis, this zone is not directly comparable with ONR’s determination of a REPPIR off-site emergency planning area]. In the UK, the legal framework for local off-site emergency planning is set out in REPPIR and, although ONR’s principles broadly align with (and meet the spirit of IAEA guidance), the IAEA guidance specifically allows for an approach based on case-by-case assessment (as happens in the UK). In addition, there are a number of similarities and important differences between the UK legislative and IAEA regimes, which are summarised as follows: a) IAEA guidance document (GS-G-2.1) provides generic indicative radial distances around different categories of nuclear installations, but also states that ‘a different distance should be used when this is substantiated by a detailed safety analysis’. UK Office for Nuclear Regulation page 15 of 30

legislation, REPPIR, requires the off-site emergency planning area to be based on a robust site specific technical identification and evaluation of the hazards and risks presented by each individual site and, as such, these indicative generic distances are not applied in the UK (although they do provide a comparator, albeit of limited value). b) IAEA guidance is based on consideration of extreme accidents, whereas the UK legal framework, as set out in REPPIR, requires detailed planning areas to be based on reasonably foreseeable events (more frequent but less severe events). c) IAEA guidance is based on restricting severe deterministic doses (i.e. relatively high doses accrued over a shorter period), whereas REPPIR is based on restricting doses, so far as is reasonably practicable, to everyone who may be affected by a radiation emergency, where a radiation emergency is defined in the UK as an emergency with the potential for an accrued dose of 5 mSv or more in the year following the emergency (or other relatively low dose criteria). This is a far lower dose threshold and is in the range of stochastic effects only. d) The ‘5 mSv in the year following the emergency’ criteria, relating to the definition of a ‘…reasonably foreseeable radiation emergency’ in UK legislation (REPPIR), is based on European EURATOM Basic Safety Standards (reference 7) and is broadly supported by Public Health England (PHE) (reference 30), which recommends that significant countermeasures '….should be offset by a correspondingly significant level of anticipated dose averted (ie. at least 10 mSv in the first year). Less disruptive or resource intensive measures could be considered for averting lower levels of dose.' e) Both the IAEA guidance and ONR’s revised Principles for Determination of the REPPIR off-site emergency planning area (and Related Guidance) (references 10 and 2) indicate that areas should take account of a range of factors (e.g. geographical factors and electoral boundaries etc). This aspect of international guidance is reflected in ONR’s principles for the determination of REPPIR off-site emergency planning areas. f) UK radiological emergency planning arrangements are complemented by arrangements available under the Civil Contingencies Act (2004) (CCA) (reference 23), and the developing concept of extendibility (i.e. the concept of planning for emergencies beyond those that are reasonably foreseeable, with the possibility of outline planning to implement dose reduction measures beyond the REPPIR off-site emergency planning area in the highly improbable event of a more severe emergency). UK guidance recommends that off-site plans prepared under REPPIR should include a framework for such scalability. I am aware that the existing BAESM Off-Site Emergency Plan contains voluntary arrangements that are supplementary to the REPPIR off-site emergency planning area, and which reflect a tiered approach to off-site emergency planning that has analogies with the IAEA concepts and principle of extendibility as described above. CCC has informed me of its intention to retain these voluntary additional arrangements in the context of the re-determination of the REPPIR off-site emergency planning area in this report. ONR is not the enforcing authority for CCA and has no legal powers in relation to ‘extendibility’. In summary, whilst UK legislation (in the form of REPPIR) does not seek to adopt the prescriptive aspects of GS-G-2.1 and noting its limited relevance given the legislative approach taken in the UK, it is of interest that the area determined within this report falls within the range advised for reactors based on international good practice.

5.6 Benefits and Dis-benefits of Dose Reduction Measures (including Countermeasures) ONR Technical Assessment Guide (TAG) (reference 2) indicates that. “Countermeasures can, in some circumstances, convey risks as well as benefits to the individuals to whom they may be applied. ONR considers that the REPPIR

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off-site emergency planning area (formerly DEPZ) should consider an appropriate balance between the benefits of dose aversion and the potential dis-benefits associated with implementing immediate countermeasures in a radiation emergency across too wide an area.” ONR acknowledges that there are benefits and dis-benefits associated with an increase or decrease in the size of the REPPIR off-site emergency planning area. These were identified and considered as follows. A smaller (e.g. reduced) area offers some benefits in that emergency responders would be able to focus their efforts on delivering dose reduction measures (including countermeasures) in a more concentrated manner across a smaller geographical area. Conversely, a far larger area (e.g. that includes the most or all of Barrow-in-Furness within the REPPIR off-site emergency planning area) may dilute emergency resources and also may result in the application of countermeasures (which may convey some risk in their own right) across more people than may be necessary. Notwithstanding this, ONR notes that REPPIR allows the local authority the flexibility to determine (in consultation with others) exactly what countermeasures and dose restriction measures should be planned for in a proportionate and targeted manner. REPPIR does not require that identical measures be applied to everyone within the REPPIR off-site emergency planning area, and allows the targeting of specific dose reduction measures to specific sub- populations within the area. As described in section 5.3 and conclusion 5 above, a key conclusion is that it would be neither sensible, justifiable, nor appropriate, from the perspective of assuring the effectiveness of the emergency plan, for the REPPIR off-site emergency planning area and prior information area to incorporate the entire conurbation of Barrow-in-Furness. Equally, I also conclude that the REPPIR off-site emergency planning area should include at least a part of Barrow-in- Furness (section 5.2, conclusion 4). Therefore, a balance of these considerations is needed in determining the emergency planning area. To allow a judgement to be made as to the extent of the emergency planning area that would ensure the appropriate balance of benefits and dis-benefits of counter measures, I considered the protection challenge presented by the current off-site area defined by two 2 km bisecting circles, centred on WDQ and RDB, but extended to include the entirety of Walney Island (appendix A, map 5). This would bisect the , Parkside, and wards and would not reflect the CCC preference to use physical and electoral ward boundaries for emergency planning purposes. However, a radial 2 km distance was used because it covers the extant REPPIR off-site emergency planning area and so demographic data was readily available to inform judgements of the benefits and dis-benefits of extending the REPPIR off-site emergency planning area beyond 1 km. The estimated demographic data provided by CCC (appendix B) for a 2 km radial area, including Walney Island, is summarised below: - a permanent population of 35,109 - transient populations arising from tourism and retail activities within Barrow-in-Furness and its environs . - 17,445 households and at least 1822 commercial properties; and - that there are vulnerable groups within or close to this area (i.e. 7 homes, 12 children centres, and 16 schools). This has the potential benefit of protecting a larger population, and that the current population and responders are familiar with the existing emergency arrangements. However, as the doses arising from the reference accident are dominated by gamma shine, potential doses reduce significantly with distance (e.g. doses at 2 km are <15% of those at

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700 m). Taken in the context of the large increase of population to be protected as distance increases, the increased risks associated with the implementation of countermeasures to a larger population, and the attendant increased risk of impacting on the effectiveness of the emergency arrangements, the retention of the current area would not, in my opinion, serve the best interest of public safety. I note that extension beyond 1 km would also compromise the important benefits (communications and traffic management) afforded by the clear physical demarcation of the Furness/ Cumbria Coast railway line and the electoral ward boundaries. Whilst some may argue that an extension to the REPPIR off-site emergency planning area could have unwarranted cost implications, REPPIR provides sufficient flexibility such that a targeted and proportionate plan can be produced. Whilst ONR notes potential cost implications, this is judged not to be a material factor in this determination. On balance, my opinion, noting the conclusions of the RoA/ HIREs and taking these benefits and dis-benefits into account, is that it would not be proportionate to increase the REPPIR off-site emergency planning area (for reasonably foreseeable radiation emergencies) from around 1 km to 2 km from WDQ and RDB to include a larger part of Barrow-in-Furness. In addition, any safety benefits would be outweighed by the risks of implementing countermeasures to a larger population along with the potential compromise of the effectiveness of the emergency arrangements. ONR is also aware that CCC intends to retain voluntary extendibility arrangements, which include flexibility to protect a wider community than required by REPPIR (reference 22). This is welcomed in the interests of securing further protection and confidence in public safety. Noting conclusion 4 (i.e. that the area should extend to at least 1 km, include at least part of Barrow-in-Furness, and the whole of Walney Island) and 5 (i.e. that it should be defined using a physical and electoral ward bounded area which does not include the whole of town of Barrow-in-Furness), my regulatory judgement is that the benefits of extending the emergency planning area to 2 km on the Barrow side are outweighed by the dis-benefits. Therefore, a REPPIR off-site emergency planning area based on 1 km with extension to (including Walney Island would achieve an appropriate balance between public protection, the risks from the implementation of countermeasures, and retaining an effective emergency planning area for public communications and traffic management .

As discussed earlier, the extent of the REPPIR off-site emergency planning area on the Barrow-in-Furness side of the WDQ and RDB, should be defined using a physical feature and electoral ward bounded area which does not include the whole of the town of Barrow-in-Furness.

Conclusion 7 : Taking into account the potential benefits and dis-benefits of the application of emergency dose reduction measures, it is judged on balance that a REPPIR off-site emergency planning area based on approximately 1 km with extension (including Walney Island) achieves an appropriate balance between public protection, the risks from the implementation of countermeasures and retaining an effective off-site emergency planning area.

5.7 Other site specific factors of which ONR is aware ONR’s Technical Assessment Guide (TAG) (reference 2) indicates that: “ONR will also consider, in determining REPPIR off-site emergency planning areas (formerly DEPZs), any additional site-specific factors that it considers relevant on a case-by-case basis.” One such factor that has been considered relates to the potential developments at the Barrow licensed site with regard to the construction and Power Range Testing of the successor to the

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Vanguard Class of submarine. The construction and development of new facilities might affect the extent of the Barrow REPPIR off-site emergency planning area. However, the commissioning of the first of the successor class is not expected before 2026, and so in the absence of a RoA to cover the change, ONR is unable to take account of any proposed developments of the Barrow site . REPPIR requires neither that an RoA exist for potential developments for the successor class design at this stage, nor allows for it to be taken into account in a speculative manner. However, REPPIR does require that a review (and re-determination if appropriate) of the REPPIR off-site emergency planning area be undertaken where a material change occurs in the work with ionising radiation (regulation 5(1)). Furthermore, REPPIR places a legal obligation on the operator to submit a RoA to ONR at least 12 months before the commencement of work with ionising radiation, REPPR regulation 6(1) . The radiological hazards and risks associated with the testing of a new reactor design at Barrow would therefore need to be considered and off-site emergency planning arrangements put in place by CCC to ensure adequate protection of the workforce and public. These issues have been raised with CCC, the dutyholder for the off-site emergency plan. ONR also notes that CCC is involved in planning processes relating to some aspects of the development of the Barrow licensed site.

Conclusion 8 : Whilst REPPIR would require a review and re-determination (if appropriate) of the REPPIR off-site emergency planning area prior to operation of any new nuclear reactors at Barrow, it does not permit this to be taken into account at the time of this determination (i.e. speculatively).

6 CONCLUSIONS AND RECOMMENDATIONS This report sets out ONRs considerations in determining revised REPPIR off-site emergency planning and prior information areas for the Barrow GB nuclear site and nuclear warship site. It takes due account of the findings of the BAESM and MOD RoAs/ HIREs and of ONR’s recently revised principles and guidance. The process of determination of a REPPIR off-site emergency planning area requires regulatory judgement to balance a broad range of technical, practical, and strategic factors (which may, of themselves, require that judgements, estimations, and assumptions be made).

6.1 Conclusions The conclusions of this report are that: • ONR is satisfied from the technical submissions made by BAESM and MOD that the reactor cores at the WDQ and RDB will contain significantly fewer fission products than an Astute core at the end of a Representative Patrol Cycle. It is therefore reasonable to account for the reduction in hazard and risk presented at Barrow compared to a MOD operational berth. For both the WDQ and the RDB, a value of 690 m is accepted as the distance from the centre of the reasonably foreseeable radiation emergency to the 5 mSv contour; • The REPPIR off-site emergency planning area boundary should be defined, so far as is sensible, by the use of physical, geographical and electoral ward boundaries (to assist Cumbria County Council in the preparation and implementation of off-site emergency plans); • The extent of the REPPIR emergency planning area, as regards the watercourses, should be defined using a combination of established ABP jurisdiction lines across the Walney and Scarf channels, and where sensible, geographical and electoral ward boundaries;

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• Noting the proximity of Barrow-in-Furness and Walney Island, a REPPIR off-site emergency planning area of less than 1 km from the WDQ (and RDB) would not provide for a credible or effective plan to secure the protection of the public, or restriction of exposures so far as is reasonably practicable in the event of a reasonably foreseeable radiation emergency. Consequently, the REPPIR off-site emergency planning area should extend to at least 1 km, to include part of Barrow-in-Furness, and given its risk of isolation, the entirety of Walney Island; • The extent of the REPPIR off-site emergency planning area on the Barrow-in-Furness side of the WDQ and RDB, should be defined using a physical and electoral ward bounded area which does not include the whole of Barrow-in-Furness; • The adoption of a REPPIR off-site emergency planning area that includes part of Barrow-in-Furness based on a minimum 1 km distance from the WDQ and RDB and with extension to follow the course of the Furness/Cumbria Coast railway line and adjacent ward boundaries on the Barrow-in-Furness side would not need further modification to incorporate adjacent vulnerable groups; and. • Taking into account the benefits and dis-benefits of the application of emergency dose reduction measures, it is judged on balance that a REPPIR off-site emergency planning area based on approximately 1 km with extension (including Walney Island) achieves an appropriate balance between public protection, the risks from the implementation of countermeasures and retaining an effective off-site emergency planning area; • Whilst REPPIR would require a review and re-determination (if appropriate) of the REPPIR off-site emergency planning area prior to operation of any new nuclear reactors at Barrow, it does not permit this to be taken into account at the time of this determination (i.e. speculatively). Consequently, for off-site emergency planning purposes, to accord with these conclusions, and in order to ensure appropriate conservatism as regards the protection of the public in the unlikely event of a reasonably foreseeable radiation emergency, it is my conclusion that the REPPIR off-site emergency planning area (and the area within which prior information must be distributed in accordance with REPPIR regulation 16(1)) be defined as the area around the combined sites bounded by the red line on the map at appendix C. This area is generally described as: A land area defined by the boundary of the Furness/ Cumbria Coast railway property and adjacent electoral ward boundaries extending by up to approximately 2 km from the WDQ and RDB on the Barrow side and to the east of the sites by up to approximately 6 km to include the whole of Walney Island; a water area extending along the Walney and Scarf channels to established ABP jurisdiction lines and bounded by the shoreline. However, it is important to emphasise that the change in the REPPIR off-site emergency planning area recommended by this report does not mean that ONR has identified a greater risk for those living near to the WDQ and RDB sites. In fact, and as is made clear in the main body of the report, ONR is satisfied that the risk has reduced compared to previous estimates. The changes reflect the combination of the improved (and lower) risk estimates for the specific activities at Barrow in comparison to an operational submarine (which was the historic assumption), along with the application of practical and strategic factors. The enhanced REPPIR off-site emergency planning area (i.e. fewer people occupying the revised planning area although it covers a significantly larger land area) is the result of the application of ONR’s revised principles for the determination of such areas, which recognise the learning that has emerged from global events such as occurred at Fukushima and the resultant need to review the scope of off-site emergency planning. This is consistent with ONR’s insistence that high standards of nuclear safety and security at nuclear installations are maintained at all times, and reflects our commitment to implementing improvements where appropriate and proportionate to do so.

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6.2 Recommendations As a result of the conclusions of this report, my recommendations are as follows: Recommendation 1: That ONR write to CCC, BAESM (WDQ) and the MOD (RDB) to advise that the REPPIR off-site emergency planning area has been determined as the area within the red line on the map at appendix C. Recommendation 2: That ONR write to CCC confirming the need to update, as required, its off-site emergency plan to adequately cover the area defined in recommendation 1. Recommendation 3: That ONR write to BAESM (WDQ) and MOD (RDB) confirming the requirement to ensure the appropriate provision of prior information to the public within the area referred to in recommendation 1. This information should also be copied to CCC. Recommendation 4: ONR should notify the Defence Safety Nuclear Regulator (DNSR) of the revised REPPIR off-site emergency planning areas.

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7 REFERENCES

1 A guide to the Radiation (Emergency Preparedness and Public Information) Regulations 2001. L126. 2002. http://www.gov.uk/pubns/priced/l126.pdf. 2 The technical assessment of REPPIR submissions and the determination of detailed emergency planning zones, ONR NS-TAST-GD-082 Revision 2 2013. www.onr.org.uk/depz- onr-principles. 3 ONR-EPR-CR-14-50 Barrow REPPIR Dose Calculations and Responsibilities During Transit. 2014. 4 Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations. 5 Koichi Tanigawa et al. Loss of life after evacuation: lessons learned from the Fukushima accident: Lancet: Volume 379 Issue 9819 889-891, 10 March 2012. http://www.thelancet.com/journals/lancet/article/PIIS0140-6736(12)60384-5/fulltext 6 Health & Safety Executive, Nuclear Directorate, Assessment Report, Assessment of MOD Generic Plant HIRE and Site Specific Reports of Assessment. 2008. 7 Council Directive 96/29 Euratom of 13 May 1996 laying down basic safety standards for the protection of the health of workers and the general public against the dangers arising from ionising radiation. Official Journal of the European Communities (1996) 39, No L159, 1-114 IBSN 0 11 915263 0 8 Safety Assessment Principles for Nuclear Facilities, 2014 Edition, Revision 0. AM.1 Accident management and emergency preparedness. 9 IAEA Safety Standards Series (General Safety Requirements) No GS-R-2 dated November 2002. Preparedness and Response for a Nuclear or Radiological Emergency. ISBN 92-0-116702-4. http://www-pub.iaea.org/MTCD/publications/PDF/Pub1133_scr.pdf 10 IAEA Safety Standards – Safety Guide No GS-G-2.1 2007. Arrangements for Preparedness for a Nuclear or Radiological Emergency. ISBN 92–0–109306 3. http://www-pub.iaea.org/mtcd/publications/pdf/pub1265_web.pdf 11 BAE Systems (2011), eDMS 1677246, REPPIR Submission 2011, Report of Assessment. 2011. 12 BAE Systems (2011), eDMS 1677242, REPPIR Submission 2011, Hazard Identification and Risk Evaluation. 2011. 13 MOD, SMP 104/02/02/20, Report of Assessment of the Hazard Identification & Risk Evaluation, Ramsden Dock Basin, No 3 & 4 Berth, Barrow in Furness, Issue 1. 14 ONR-DEF-AR-12-049 ONR Assessment of the 2011 REPPIR HIRE Submissions for the Port of Barrow from BAESM Systems Marine Ltd and the Ministry of Defence. 2013.

15 Poyry Energy limited (2007), 200435.117/r01, Naval Reactor Plant Hazard Identification and Risk Evaluation, Ministry of Defence, REPPIR 2008 Submission, Issue 2, October 2007. 16 BAESM Barrow Berths DEPZ Discussions. Email to ONR dated 29 May 2014. 17 Barrow DEPZ Determination - Cumbria County Council Response to ONR’s Preliminary Discussion & Questions. Email dated 19 February 2014. 18 Correspondence between Cumbria County Council and ONR, 4 April 2014. Response to Office of Nuclear Regulation Regarding Queries around the Proposed DEPZ for BAE Systems, Barrow in Furness. 19 BAE Systems Maritime Submarines, Off-Site Emergency Plan – Proposed Change to Detailed Emergency Panning Zone (DEPZ), September 2013. 20 DEPZ & BAE - CCC Response to ONR Queries. Email dated 4 August 2014). 21 Barrow REPPIR Off-site Emergency Planning Area Determination - MCA Responsibilities and Control of Maritime Access Provisions. Email MCA to ONR dated 17 October 2014.

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22 BAE DEPZ – CCC Response to ONR Queries. Email dated 17 August 2014). 23 Civil Contingencies Act (2004): Chapter 36, 13 November 2004, Her Majesty’s Stationery Office 24 Population data provided by CCC for area within 700 m from the WDQ. (e-mail from CCC, 28 May 2014). 25 Walney Island residential population data. (e-mail, CCC, 14 April 2014). 26 Vulnerability of the population of Walney to isolation. (ONR Contact Record, CR-14-091, January 15). 27 Flooding on Walney Island during the winter of 2014. BBC News. 2014. http://www.bbc.co.uk/news/uk-england-cumbria-27022182 (Walney Island Risk of Split from Flooding) 28 Cumbria Alert Radiation Emergency information leaflet for BAE Systems Submarine Solutions and Ramsden Dock Basin, Barrow-in-Furness. 2008. www.cumbria.gov.uk. 29 CCC has advice re vulnerable groups within a 100 m wide zone of the area determined by this report. 30 PHE (formerly NRPB), NRPB advice (Volume 8. No.1. 1997, Intervention for Recovery After Accidents, para 35). 33 CCC conformation of intention to retain extendibility arrangements. (e-mail, CCC, 17 August 2014).

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APPENDIX A

Map 1: Map of Barrow REPPIR off-site emergency planning areas: 2002 – 2014 (Report section 2.1) Outer circles represent REPPIR off-site emergency planning areas, inner circles are part of the Council’s detailed emergency plan for application of countermeasures.

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Map 2: Map of the Furness Peninsula (10 km radial distance from the WDQ) (Reference BAEASM RoA) (Report section 5.1)

Map 3: BAE Systems Submarine Solutions Shipyard at Barrow-in-Furness Showing licensed site and transit route to the RDB (Reference BAEASM RoA) (Report section 5.1)

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Map 4: Associated British Ports jurisdiction lines (Report section 5.1)

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Potential Barrow off -site emergency planning area and additional population areas Potential planning area Population area up to 2 km Population area up to 3 km

Map 5: Potential Barrow off-site emergency planning area and population areas extending to 2 km and 3 km (Report section 5.3)

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APPENDIX B Demographic data for the area around Barrow-in-Furness Data provided by Cumbria County Council (Reference 18)

Description 700 m (approx) 2 km + Walney 3 km + Walney Off -site emergency planning area Based on the circular area of circular area of determined by this geographical radius 2 km radius 3 km from report location around the from the WDQ the WDQ and RDB WDQ (bounds the and RDB The area within the RDB) red line on the map at

appendix C.

Permanent 1904 35109 48677 24785 Population

Transient 170 215 215 215 population(nature ** ** ** ** (0) (2) (2) (2) reserves) [tourist attractions – Dock [1] [1] [1] [1] Museum] (for note: No marina in Barrow in Furness, the only tourism figures available are for all of Barrow District which includes large tourism attractions outside the area)

Total Private 1163 17445 23475 12678 Properties

Total Commercial 582 1822 2002 1623 Properties

Vulnerable Groups***

Schools (public and 1 16 25 14 private)

Children Centres 0 12 19 10 (Play groups & childcare facilities, not including the nursery’s on school premises or Child- minders)

Care Homes & Day 0 7 (6 care 14 (13 care homes 7 (6 care homes and Centres homes and 1 and 1 day centre) 1 day centre) day centre)

Camping/Caravan 0 5 (3 caravan 5 (3 caravan sites, 5 (3 caravan sites, 1 Sites, riding school sites, 1 golf 1 golf course, 1 golf course, 1 riding and golf clubs course, 1 riding riding school) school) school)

* marinas, tourists & retail

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** Nature reserve and visitors – This includes up to 16,500 annual visitors (approx. 45 visitors per day) to the Nature Reserves and 44,149 annual visitors (approx. 170 visitors per day) to the Dock Museum. *** Cumbria County Council advice (Reference 17): “ In relation to “vulnerable groups” raised in the ONR question the response will be drawn from Cabinet Office material and based on the general definition of “vulnerability” to mean “those that are less able to help themselves in the circumstances of the emergency” and include people with mobility difficulties, mental health issues, children/elderly, hearing and the visually impaired. This will be developed to show the distinction between “premises providing facilities for vulnerable people” e.g. schools, sheltered accommodation etc which can generally be mapped and vulnerable people living in a domestic setting which are more difficult to identify and map. Reference will also be made to the impact of vulnerability at different stages of the planning and response in relation to “warning and informing” e.g. impact of visual impairment in reading material, (bearing in mind those for whom English is not their first language), hearing impaired in relation to siren etc. Finally the response will also consider identifying premises which may afford less protection e.g. caravan site, beach huts and include outdoor locations e.g. nature reserves.”

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APPENDIX C Map: ONR determination of the REPPIR off-site emergency planning area and the REPPIR prior information area around the Barrow GB nuclear site and nuclear warship site. The area defined by this map may be generally described as: A land area defined by the boundary of the Furness/ Cumbria Coast railway property and adjacent electoral ward boundaries extending by up to approximately 2 km from the WDQ and RDB on the Barrow side and to the east of the sites by up to approximately 6 km to include the whole of Walney Island; a water area extending along the Walney and Scarf channels to established ABP jurisdiction lines and bounded by the shoreline.

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