Report ONR-COP-PAR-16-012 TRIM Ref: 2015/121450

Determination of the Off-Site Emergency Planning and Prior Information Areas for the Devonport Royal Dockyard and Her Majesty’s Naval Base Devonport:

Radiation (Emergency Preparedness and Public Information) Regulations 2001

Project Assessment Report ONR-COP-PAR-16-012 Revision 0 11 November 2016

Office for Nuclear Regulation Report ONR-COP-PAR-16-012 TRIM Ref: 2015/121450

© Office for Nuclear Regulation, 2016 If you wish to reuse this information visit www.onr.org.uk/copyright for details. Published 11/16

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Office for Nuclear Regulation Report ONR-COP-PAR-16-012 TRIM Ref: 2015/121450

EXECUTIVE SUMMARY

Determination of the Off-site Emergency Planning and Prior Information Areas for the Devonport Royal Dockyard and Her Majesty’s Naval Base Devonport: Radiation (Emergency Preparedness and Public Information) Regulations 2001

The Office for Nuclear Regulation (ONR) is responsible for regulating the GB nuclear industry in order to protect the health and safety of employees and the public against risks of harm arising from ionising radiations. ONR is the regulatory authority for Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) on nuclear licensed sites, Ministry of Defence (MOD) authorised nuclear sites and nuclear warship sites. ONR’s responsibilities include a legal duty, where it is concluded that there is a potential for a reasonably foreseeable radiation emergency (as defined in REPPIR), to determine an off-site emergency planning area (ie the area within which, in ONR’s opinion, any member of the public is likely to be affected by such an emergency). In these cases, there is also a legal duty, under the same Regulations, for ONR to determine an area within which prior information is to be distributed to the public. A radiation emergency is defined in REPPIR as a reasonably foreseeable event where a person off-site is likely to receive a radiation dose in excess of the thresholds in REPPIR (typically an effective dose in excess of 5 mSv) in the 12 months following. It therefore constitutes an important component of the UK’s overall emergency response framework. This ONR Project Assessment Report (PAR) describes and explains the basis for its re-determination, in accordance with REPPIR, of the off-site emergency planning area and the area within which prior information is to be distributed around the Devonport Royal Dockyard (DRD) and Her Majesty’s Naval Base Devonport (HMNB(D)), and relevant berths in Plymouth Sound. In relation to these areas, the lead local authority, in this case Plymouth City Council (PCC) is required to prepare an 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. PCC prepares the Devonport off-site emergency plan in consultation with other local authorities who are affected by the emergency planning area. The plan will reflect the potential need to implement appropriate protection measures such as sheltering and evacuation and administering stable iodine in order to reduce radiation doses to members of the public within all or parts of each area. REPPIR requires operators who carry out work involving quantities of radioactive materials at or beyond those specified by REPPIR, in this case Devonport Royal Dockyard Ltd (DRDL) and HMNB(D), to undertake Hazard Identifications and Risk Evaluations (HIRE) in relation to their work with ionising radiations. 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 (eg 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 within three years of the last assessment, whichever is the shorter. The off-site local authority emergency planning and prior information areas for Devonport, as provided for in REPPIR regulations 9(1) and 16(1), were first determined in 2002 - a short while after REPPIR came into force in 2001. The existing area is set at “not less than 1.5 km from any defined nuclear warship berth or mooring” and has been translated into the current Devonport off-site emergency plan as circular areas of radius 2.0 km centred on 5 Basin within the main Devonport site and the buoys in Plymouth Sound. The operator has declared under regulation 5(1) that the risks identified in the Naval Reactor Plant generic assessment have not changed, taking into account a re-evaluation of additional risks presented by on-site hazards which are deemed not to change the basis for emergency planning. However in order to provide further improvements in protection of the public, a

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change to decisions about the populations to be included within the emergency planning area(s) is needed as a result of the application of ONR’s revised principles for the determination of such areas. ONR’s re-determination of the REPPIR off-site emergency planning area and the REPPIR prior information area for the Devonport site located in Plymouth, Devon, and the relevant berths in Plymouth Sound has been undertaken in accordance with ONR’s regulatory processes, guidance associated with REPPIR itself, and the relevant ONR Technical Assessment Guide (TAG). In particular, the TAG includes ONR’s determination principles (issued in December 2013 and published in 2014) 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 Japan in 2011 and the need to review the scope of off-site emergency planning. They also reflect ONR’s commitment to seek high standards of nuclear safety at nuclear installations, and its continual efforts to seek improvements in/for measures to secure public safety and to the consistency and transparency of its decision making. ONR’s determination process requires that:  Technical assessment be undertaken, by ONR, of DRDL and HMNB(D) submissions of RoA.  In accordance with the relevant ONR TAG, ONR also gives appropriate consideration to practical and strategic factors relating to the planning and potential implementation of a credible 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 authorities (in this case PCC the duty holder within REPPIR as regards the off-site plan, along with Cornwall Council, South Hams District Council and Devon County Council) and considers, amongst other factors, local population (including vulnerable groups) and geographical considerations. This informs ONR’s determination so as to define more practical emergency planning and prior public information areas than would be the case from purely technical considerations.

The outcome of ONR’s technical assessments concludes that areas of radius of at least 1.5 km from any defined nuclear warship berth or mooring should continue to be used as the foundation for defining the extent of the need for local authority off-site emergency planning under regulation 9(1) of REPPIR. ONR’s regulatory 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 to be appropriate in the interests of public safety. As a consequence, the ultimate determination of the REPPIR off-site emergency planning area represents ONR’s regulatory judgement, and is not formed solely on the basis of technical considerations or criteria. The outcome of ONR’s review, taking into account the relevant practical and strategic considerations relating specifically to Devonport, is that both the REPPIR off-site emergency planning area and the REPPIR prior information areas for the Devonport site and the relevant berths in Plymouth Sound have been re-defined to be the enhanced areas shown within the red lines on maps 1, 2 and 3 contained in annex B to this report. Changes to the off-site emergency planning area (from the previously determined radial distance of 1.5 km from each berth) reflect 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 recommendations of this report are that ONR write to:  Plymouth City Council, being the lead responsible local authority to advise them that the REPPIR off-site emergency planning areas have been determined as the areas within the red lines on maps 1, 2 and 3 in annex B. This information should be copied to Cornwall Council, South Hams District Council and Devon County Council as additional responsible local authorities. It should also be copied to Her Majesty’s Naval Base Commander (Devonport) and Devonport Royal Dockyard Ltd acting as the duty holders for the Devonport site and Her Majesty’s Naval Base Commander (Devonport) as the duty holder for the associated Plymouth Sound berths.  Plymouth City Council, being the lead responsible local authority confirming the need to update, as required, its detailed off-site emergency plan to adequately cover the areas defined in annex B.  Her Majesty’s Naval Base Commander (Devonport) and Devonport Royal Dockyard Ltd acting as duty holders for the Devonport site and Her Majesty’s Naval Base Commander (Devonport) acting as duty holder for the associated Plymouth Sound berths confirming the requirement to ensure the appropriate provision of prior information to the public within the areas defined in annex B. This should also be copied to Plymouth City Council, Cornwall Council, South Hams District Council and Devon County Council.  The Defence Nuclear Safety Regulator, Queens Harbour Master, Maritime & Coastguard Agency, Environment Agency, Food Standards Agency and Department for Business, Energy & Industrial Strategy, to inform them of the revised REPPIR off-site emergency planning and prior information areas.

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LIST OF ABBREVIATIONS & DEFINITIONS

ACPO Association of Chief Police Officers ALARP As low as reasonably practicable Berth Includes all relevant berths, moorings and anchorages BSS Berth Safety Statements CCA Civil Contingencies Act (2004) CC Cornwall City Council CNS Civil Nuclear Security (ONR) DCC Devon County Council DEPZ Detailed Emergency Planning Zone DNSR Defence Nuclear Safety Regulator DRD Devonport Royal Dockyard DRDL Devonport Royal Dockyard Limited EA Environment Agency FEPA Food and Environment Protection Act 1985 FSA Food Standards Agency HIRE Hazard Identification and Risk Evaluation HMNB(D) Her Majesty’s Naval Base Devonport HSE The Health and Safety Executive HSL The Health and Safety Laboratory IAEA The International Atomic Energy Agency MCA Maritime & Coastguard Agency MHWM Mean High Water Mark MLWM Mean Low Water Mark MOD Ministry of Defence NCHQ Navy Command Headquarters NDA Nuclear Decommissioning Authority NEPLG Nuclear Emergency Planning Liaison Group NIA Nuclear Installations Act 1965 NII Nuclear Installations Inspectorate (now ONR) NRP Naval Reactor Plant ONR Office for Nuclear Regulation PAZ Precautionary Action Zone PCC Plymouth City Council PHE Public Health England QHM Queens Harbour Master REPPIR Radiation (Emergency Preparedness and Public Information) Regulations 2001 RGP Relevant Good Practice RNAD Royal Naval Armaments Depot RoA Report of Assessment SAP Safety Assessment Principle(s) SHDC South Hams District Council TAG Technical Assessment Guide (ONR) UPZ Urgent Protective Action Planning Zone

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TABLE OF CONTENTS

1 REGULATORY CONTEXT ...... 1 2 BACKGROUND ...... 3 2.1 REPPIR ...... 3 2.2 Devonport Site ...... 3 2.3 Timeline of MOD HIRE / RoA Submissions ...... 5 3 SCOPE ...... 6 4 METHODOLOGY ...... 7 4.1 ONR’s process for determining a REPPIR off-site emergency planning area ...... 7 4.2 Basis of Assessment ...... 8 4.3 Standards and Criteria ...... 8 5 ASSESSMENT OF TECHNICAL SUBMISSIONS ...... 10 5.1 HMNB (Devonport) Report of Assessment ...... 10 5.2 DRDL Report of Assessment ...... 10 5.3 ONR Technical Assessment ...... 11 5.4 Conclusions of Technical Assessments ...... 11 6 ASSESSMENT OF PRACTICAL AND STRATEGIC CONSIDERATIONS FOR THE DETERMINATION OF THE REPPIR OFF-SITE EMERGENCY PLANNING AND PRIOR INFORMATION AREAS ...... 12 6.1 Local Geographic, Population and Practical Implementation Factors ...... 13 6.2 Credibility and Confidence in the Extent of the REPPIR Off-site Emergency Planning Area ...... 15 6.3 Avoidance of Bisection of Local Communities ...... 17 6.4 Inclusion of Immediately Adjacent Vulnerable Groups ...... 17 6.5 International Good Practice ...... 19 6.6 Consideration of Benefits and Dis-benefits of Dose Reduction Measures (including Countermeasures) ...... 21 6.7 Other site specific factors of which ONR is aware ...... 22 7 CONCLUSIONS ...... 24 8 RECOMMENDATIONS ...... 26 9 REFERENCES ...... 27 ANNEX A – RELEVENT INFORMATION AND SIGNIFICANT FEATURES ...... 29 ANNEX B – DETERMINATION MAPS ...... 35 ANNEX C – PLYMOUTH OVERVIEW MAPS ...... 38

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TABLES Table 1: Population data for wider Plymouth Area ...... 29

Table 2: North Yard Population Data ...... 30

Table 3: North Yard Significant Features ...... 31

Table 4: Plymouth Sound North Population Data ...... 32

Table 5: Plymouth Sound South Population Data ...... 33

Table 6: Plymouth Sound Significant Features ...... 34

MAPS Map 1: Map of Devonport REPPIR off-site emergency planning and prior information area 2016 – North Yard ...... 35

Map 2: Map of Devonport REPPIR off-site emergency planning and prior information area 2016 – Plymouth Sound North ...... 36

Map 3: Map of Devonport REPPIR off-site emergency planning and prior information area 2016 – Plymouth Sound South ...... 37

Map 4: Plymouth wider area map indicating distances from approximate centre of all relevant berths for the Devonport site and for Plymouth Sound ...... 38

Map 5: Plymouth wider area showing REPPIR off-site emergency planning areas ...... 39

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1 REGULATORY CONTEXT

The UK Energy Act (reference 1) requires the Office for Nuclear Regulation (ONR) to do whatever it considers appropriate for the purposes of protecting persons against risks of harm arising from ionising radiations from GB nuclear sites, including through:

 securing the health, safety and welfare of persons at work on GB nuclear sites; and  protecting persons, other than persons at work on GB nuclear sites, against risks to health or safety arising out of or in connection with the activities of persons at work on GB nuclear sites.

ONR does this by providing efficient and effective regulation of the nuclear industry, holding it to account on behalf of the public, and, in particular, ensuring that appropriate arrangements are put in place to deal with a nuclear emergency.

The Devonport site includes both Her Majesty’s Naval Base (Devonport) (HMNB(D)), which is a Ministry of Defence (MOD) nuclear site and Devonport Royal Dockyard (DRD) which is a civil nuclear site.

MOD nuclear sites and facilities are Crown exempt from licensing requirements under the Nuclear Installations Act 1965 (NIA) (reference 2). These sites are referred to as authorised sites and nuclear warship sites (referred to by the MOD as operational berths and anchorages).

The NIA additionally explicitly exempts a reactor ‘comprised in a means of transport’ from its requirements For example submarines are not licenced by ONR under the NIA.

The MOD internal regulator, the Defence Nuclear Safety Regulator (DNSR), authorises and regulates the authorised sites through the use of authorisation conditions, which are closely aligned to the ONR licence conditions for civil nuclear sites. Similar conditions are placed on operational berths.

The MOD is not however exempt from the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) (reference 3), and ONR are the enforcing authority for REPPIR on their authorised sites and nuclear warship sites (reference 4).

The MOD / ONR General Agreement and Letter of Understanding (references 5 and 6) describe the overall regulatory working relationship between the MOD and ONR. DNSR works closely with ONR in a process of joint regulation of relevant areas to minimise the impact on operators and ensure, so far as is practicable, that they are not subject to differing requirements or processes. ONR looks to DNSR as the “Competent Authority” in respect of Naval Reactor Plant (NRP) design and DNSR provides ONR with any clarification it requires on hazards arising therefrom.

In relation to REPPIR, DNSR acts as the Competent Authority in providing assurance to ONR that the detailed Naval Nuclear Propulsion Programme design information contained within the MOD REPPIR Hazard Identification and Risk Evaluation (HIRE) is valid and has been used appropriately.

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ONR’s responsibilities include a legal duty, where it is concluded that there is a potential for a reasonably foreseeable radiation emergency (as defined in REPPIR (reference 3)), to determine an off-site emergency planning area. This is the area within which, in ONR’s opinion, any member of the public is likely to be affected by such radiation emergencies.1 In these cases, there is also a legal duty under the same regulations, for ONR to determine an area within which prior information is to be distributed to the public.2 A radiation emergency is defined in REPPIR as any event where a person off-site is likely to receive a radiation dose in excess of the thresholds in REPPIR (typically an effective dose in excess of 5 milliSieverts (mSv)) in the 12 months following. It therefore constitutes an important component of the UK’s overall emergency response framework.

This report sets out the outcome and justification for ONR’s determination of the revised off-site emergency planning and prior information areas for DRD and HMNB(D), and the relevant berths in Plymouth Sound, in accordance with the requirements of REPPIR regulations 9(1) and 16(1) respectively (reference 3).

ONR is of the opinion that the extent of areas for local authority detailed off-site planning and for the provision of prior information by the operator should be the same. This is a reflection of the fact that 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.

1 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’ under regulation 9 rather than to ‘detailed emergency planning zone’ or ‘DEPZ’. 2 This is sometimes, and has historically been, referred to as the Public Information Zone (PIZ) under regulation 16, but for the same reason as given above is not used in this report. This report refers to the ‘REPPIR prior information area’.

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2 BACKGROUND

2.1 REPPIR

The UK nuclear regulatory system requires that every licensee (ie nuclear site licence holder) and authorisee (ie a MOD Nuclear site authorisation holder) demonstrate to the regulator that it fully understands the hazards and risks associated with its operations and controls them appropriately. The regulator assesses the safety and security of the design and operation of nuclear plant to ensure that licensees / authorisees provisions are robust, and that any risks are reduced so far as is reasonably practicable.

In relation to emergency planning, REPPIR requires operators, in this case Devonport Royal Dockyard Ltd (DRDL) and HMNB(D), to undertake an assessment (Hazard Identification and Risk Evaluation (HIRE)) of their work with ionising radiation which is sufficient to demonstrate that; all hazards arising from their work with the potential to cause a radiation accident have been identified and the nature and magnitude of the risks to employees and other persons arising from those hazards have been evaluated;. Where the assessment shows that a risk exists from an identifiable radiation accident, the operator shall take all reasonably practicable steps to prevent any such accident and limit the consequences of any such accident which does occur. REPPIR regulation 6 requires that operators submit a Report of the Assessment (RoA) of their HIRE to ONR and resubmit following any material change, and at least every three years of the last assessment, make a further assessment or if there has been no change of circumstance which would affect the last RoA sign a declaration to that effect and send it to ONR.

Where it is reasonably foreseeable that a radiation emergency (as defined in REPPIR) could arise, REPPIR requires ONR to determine 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)) to members of the public without them having to request it and also make that information publicly available. The plan shall be prepared in respect of such area as in the opinion of ONR any member of the public is likely to be affected by such radiation emergencies.

The off-site emergency plan, in cases where one is required, should include urgent countermeasures in order to reduce radiation doses to members of the public, such as sheltering, evacuation, administering stable iodine tablets (in the case of operating nuclear reactors), and other protection measures that are relevant, reasonably practicable, and proportionate to the radiological risk.3

Following ONR’s determination, the lead local authority, in this case Plymouth City Council (PCC), in co-operation with (other affected councils) Cornwall Council (CC) South Hams District Council (SHDC) and Devon County Council (DCC), is required to prepare an adequate off-site emergency plan in line with REPPIR regulation 9(1). In so doing, the local authorities have a legal obligation, under regulation 9(12), to consult a range of persons (including the operator, the emergency services, the relevant health authority, and such other persons, bodies and authorities and members of the public as they consider appropriate). This plan must then be reviewed, revised where necessary, and tested at least every three years.

2.2 DEVONPORT SITE

The 3 sq km (740 acres) and 5.6 km (3.5 miles) of water frontage of the Devonport site are located within the city of Plymouth, near the border of Devon and Cornwall. It is also situated on the Hamoaze, a reach of water stretching from Saltash to the Narrows, on the east bank of the river Tamar. The River Tamar is used extensively by a range of military, commercial and

3 It is noted that the emergency arrangements in the current Devonport Off-site Emergency Plan places emphasis on sheltering along with the administration of stable iodine.

Office for Nuclear Regulation Page 3 of 38 Report ONR-COP-PAR-16-012 TRIM Ref: 2015/121450 leisure craft. The site is the operating and maintenance centre for the Commodore Devonport Flotilla and as such provides support, maintenance, repair and refitting capabilities for surface ships and submarines including facilities for berthing, docking, engineering, repair and maintenance. The overall site is currently split between the DRD and HMNB(D). HMNB(D) contains the nuclear authorised site and the Devonport Royal Dockyard, operated by DRDL, contains the nuclear licensed site. It carries out major refitting and refuelling of nuclear powered submarines.

The regulatory authority for nuclear safety on the HMNB(D) nuclear authorised site is the Defence Nuclear Safety Regulator (DNSR). The regulatory authority for nuclear safety on the nuclear licensed site (operated by DRDL) is ONR. In addition ONR is the regulatory authority for conventional health and safety for both sites. This does not affect the requirement, under REPPIR, for ONR to determine areas within which, in its opinion, persons (including any member of the public) are likely to be affected by a reasonably foreseeable radiation emergency.

There has been a Naval Dockyard on the site since 1691. The dockyard was formally named Devonport Dockyard in 1824. Nuclear submarines have operated on the site since the early 1970s and there has been nuclear licensed site since 1987, located in the North Yard area of the site.

The stretch of water, on which Devonport is located, has sufficient depth and tidal effects to enable a variety of surface vessels and submarines to enter the dockyard, but is adequately sheltered from potentially extreme sea conditions by the large headland encompassing Rame Head, the 19th century Plymouth Sound breakwater and the natural shape of the coast line.

The Devonport site is relatively flat, but there is significant variation in elevation beyond its boundary to the east side of the Hamoaze, peaking at 70 metres within the City of Plymouth. It is similar on the opposite side of the Hamoaze, to the west in Torpoint when the land rises rapidly inland to an elevation of approximately 50 metres, and to the north is Saltash where the elevation reaches approximately 70 metres.

To the south of Devonport and the City of Plymouth is Plymouth Sound which, beyond the breakwater, opens into the English Channel. The east and west of Plymouth Sound is largely enclosed by steep slopes and cliffs rising to an elevation of over 100 metres. In the north of Plymouth Sound is Drake Island (approx. 400 x 100 metres) on which is disused military barracks and fortifications.

Further west of the Devonport site the area is mainly rural and further north and east the land is mainly pastoral.

Previous Devonport REPPIR submissions and determination

The previous REPPIR off-site emergency planning area and prior information area was determined in 2009, as a circular area of not less than 1.5 km from any defined nuclear warship berth or mooring. Devonport has over a dozen such berths, the majority of which are located in the North Yard area of the Devonport site. The remainder are located to the south in Plymouth Sound. The Devonport off-site emergency plan (reference 7) describes an area of radius centred on the centre of 5 basin within the Devonport site that encompasses the minimum area for all the dock based berths. In addition it describes radius areas around buoys in Plymouth Sound.

The Report of Assessment (RoA) for HMNB(D) identifies a number of berths used by operational nuclear submarines. Some of these are ‘X’ berths (which allow repair, maintenance and ammunitioning) and are located where the Devonport site North Yard fronts on to the Hamoaze. The remainder are ‘Z’ berths which are located in Plymouth Sound and where no nuclear related work is permitted without prior justification and Regulatory approval.

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The HMNB(D) RoA also considers the berthing of laid up submarines, which do not use either X or Z berths and are berthed in 3 basin of the Devonport site.

The RoA for DRD identifies a similar number of berths to the HMNB(D) RoA, all of which are X berths and are located within the North Yard area of the Devonport site.

2.3 TIMELINE OF MOD HIRE / ROA SUBMISSIONS

In February 2008 the MOD submitted HIREs and associated RoA’s (through DNSR) (reference 8) covering operations at the following sites:

 HMNB(D) (including Plymouth Sound berths);  HMNB Clyde (comprising Coulport and Faslane) – not considered in this report; and  UK Operational Berths (Portsmouth, Southampton, Portland, B4 Anchorage, Loch Goil, Broadford Bay and Loch Ewe) – not considered in this report.

A separate RoA submission was received from DRDL, also in February 2008.

ONR (then the Nuclear Installations Inspectorate (NII)) and DNSR put in place a regulatory strategy to assess the HIREs and RoA’s, with DNSR providing the detailed technical assessment. NII completed the regulatory assessment requirements of REPPIR with a joint regulatory position statement being issued in April 2009 (reference 9).

NII determined that the area within which members of the public are likely to be affected by a reasonably foreseeable radiation emergency extended to a distance of 1.5 km from the berth in any direction (reference 10).

In 2011 the MOD REPPIR submissions (through DNSR) (reference 11) were supported by significantly updated Berth Safety Statements (BSS) (reference 12) that considered site specific hazards. The 2011 submission constituted no change declarations (reference 11) for the Operational Berths, supported by revised BSS for:

 HMNB(D) (including Plymouth Sound berths);  HMNB Clyde (including Coulport); and  UK Operational Berths (Portsmouth, Southampton, Portland, B4 Anchorage, Loch Goil, Loch Ewe and Ramsden Dock Basin).

A declaration that the “hazard identification and risk evaluation for the Devonport Royal Dockyard site remains valid” was received from DRDL in February 2011 (reference 13)

The MOD REPPIR submission (through DNSR) in January 2014 (reference 14) was again a declaration of no change in circumstances. The totality of the MOD submissions comprised of individual submissions from each Naval Base and Navy Command Headquarters (NCHQ)), which covered the following:

 HMNB Devonport (including Plymouth Sound berths);  HMNB Clyde - Faslane Site ,Coulport Site and Loch Goil Operational Berth; and  UK Operational Berths (Portsmouth, Southampton, Portland, Ramsden Dock Basin, Loch Goil, and Loch Ewe).

A declaration that the “hazard identification and risk evaluation for the Devonport Royal Dockyard site remains valid” was received from DRDL in February 2014 (reference 15).

DNSR, as the competent authority on the NRP, confirmed its support of the no change submissions in 2011 and 2014 (references 11 & 14).

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3 SCOPE

The assessment described in this report 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 Devonport site and associated Plymouth Sound berths. It takes due account of the findings of the RoA and has been undertaken in accordance with the guidance on REPPIR (reference 16) and the relevant ONR supporting Technical Assessment Guide (TAG) (reference 17), which incorporates ONR’s principles for determination of REPPIR areas, and related guidance.

ONR’s principles recognise the learning that has emerged from global events such as occurred at Fukushima, and the subsequent need to review the scope of off-site emergency planning. They also reflect ONR’s commitment to regulating high standards of nuclear safety at nuclear installations, and its continual efforts to seek improvements to standards and to the consistency and transparency of its decision-making.

Provisions for the implementation of food restrictions are not relevant to the process of determining the REPPIR off-site emergency planning area on the basis that they are provided separately (Food and Environment Protection Act 1985 (FEPA)) and are under the legal jurisdiction of the Food Standards Agency (FSA). These provisions are therefore addressed by separate legislation other than REPPIR, may be exercised in a broader range of circumstances (for example not restricted to a radiological event), and are subject to existing planned implementation arrangements made by the FSA. They are therefore outside the scope of this report.

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4 METHODOLOGY

4.1 ONR’S PROCESS FOR DETERMINING A REPPIR OFF-SITE EMERGENCY PLANNING AREA

This process requires that ONR:

A. Conduct an initial independent technical assessment of the information provided by the operator in their HIRE / RoA and reasonably require under regulation 6 (5), a detailed assessment of any further particulars set out in schedule 6; and B. Where the potential for a REPPIR defined reasonably foreseeable radiation emergency exists, establish and consider any other relevant practical and strategic factors relating to the planning and practical implementation of measures to restrict public exposure so far as reasonably practicable (eg urgent countermeasures) for those persons who are likely to be affected by a radiation emergency.

Step A requires ONR to assess the operator’s identification and characterisation of the likelihood, nature and magnitude of the radiation related risks that may result for a radiation accident. ONR also assess the operator’s assessment of whether there is the potential for a radiation emergency to occur that is reasonably foreseeable. If this potential exists ONR will then consider the likely extent of any area within which the dose criteria contained within Schedule 1 of REPPIR may be met or exceeded. This indicates the minimum distance for further consideration in Step B, and is usually presented in the operator’s assessment reports as a circle with a specified radius from the site.

Step B applies additional pragmatic, population (including vulnerable groups), geographic and practical factors to the ONR determination and requires dialogue with the relevant local authority. The nature of these factors is set out in detail in the relevant ONR TAG (reference 17). Whilst the determined REPPIR off-site emergency planning area, as a result of considering these additional factors, need not be circular, it cannot be smaller than that arising from the technical assessment under Step A.

ONR’s principles relating to practical and strategic considerations (reference 17) emphasise that, in the undertaking of the determination, it is important to ensure that a balance is achieved between the assessment of the technical submissions provided by the operator, and such additional practical and strategic considerations that, in ONR’s opinion, are judged necessary in the interests of providing 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 (reference 17) indicate should be considered are summarised as follows:

 local, population and practical implementation;  avoidance of bisection of local communities where sensible to do so;  inclusion of immediately adjacent groups of vulnerable people;  the need for the REPPIR off-site emergency planning area to provide for an adequate and credible emergency plan, 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 (eg dilution of resources (for example police, fire and ambulance) and potential dis-benefits associated with immediate/urgent countermeasures);  relevant international good practices; and

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 other relevant site specific factors of which ONR are aware.

The starting point for the off-site emergency planning area is based on the most significant reasonably foreseeable event (referred to in ONR’s TAG, reference 17, as the ‘reference accident’, and described in guidance as an event which is less than likely but realistically possible). Such an accident could be caused, for example, by possible plant and equipment failures, breakdown of administrative arrangements, and potential unauthorised behaviours of employees or the public.

For radiation emergencies that are judged not to be reasonably foreseeable (eg the likelihood of which is so remote that detailed emergency planning against their consequences is not justified), the guidance associated with REPPIR recommends, 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.

Although the local authority off-site emergency plans include many measures to reduce radiation doses to members of the public, the most commonly referenced off‐site urgent countermeasures available in the early stages of a nuclear emergency 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 urgent countermeasures can convey a risk of harm to individuals to whom they are applied. For example, 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 evacuation (reference 18). Within a REPPIR off-site emergency planning area determined by ONR, the local authority may plan for some countermeasures to be applied immediately or urgently across at least a part of the area and it is important that the area within which they may be applied is targeted and proportionate in order to ensure that overall risks to those affected are reduced so far as is reasonably practicable. These decisions are a matter for the local authority in statutory consultation (REPPIR regulation 9(12)) with relevant organisations and persons.

4.2 BASIS OF ASSESSMENT

The REPPIR off-site emergency planning area must, as a minimum, include all of the area around the site within which any person 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). When assessing the extent of exposure, REPPIR requires that operators assess the potential doses to members of the public from all exposure routes and, for this purpose, must disregard any health protection countermeasures that may be implemented by the local authority, emergency services, or the exposed persons themselves, during the first 24 hours immediately following the event.

HMNB(D) and DRDL have prepared their RoA’s, which form the basis of ‘Step A’ (see section 4.1) of the assessment and determination described in this report.

4.3 STANDARDS AND CRITERIA

4.3.1 ACTS, REGULATIONS AND GUIDANCE

The relevant standards and criteria considered within this assessment are those contained within REPPIR (reference 3) and its associated guidance (reference 16). REPPIR are regulations created 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 (European Atomic Energy Committee) - Basic Safety Standards for the Protection of the Health of Workers and Members of the Public against the Dangers from Ionising Radiation (reference 19).

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4.3.2 SAFETY ASSESSMENT PRINCIPLES

ONR’s Safety Assessment Principles (SAP’s) provide inspectors with a guiding framework for making consistent regulatory judgements on nuclear safety cases. Although the SAP’s are not directly relevant to the assessment of REPPIR submissions, the guidance within SAP: AM.1 - Accident management and emergency preparedness (reference 20) has been taken into account.

4.3.3 TECHNICAL ASSESSMENT GUIDES

The SAPs are supported by a suite of internal TAG’s, 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 17). This TAG incorporates ONR’s principles for determination of REPPIR off-site emergency planning areas.

4.3.4 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 16).

ONR also notes the relevance of the following International Standards and Guidance:

 The International Atomic Energy Agency (IAEA) Safety Standard Series – Preparedness and Response for a Nuclear or Radiological Emergency GSR Part 7 (reference 21).  IAEA Safety Standards – Arrangements for Preparedness for a Nuclear or Radiological Emergency GS-G-2.1 (reference 22).

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5 ASSESSMENT OF TECHNICAL SUBMISSIONS

The Devonport site includes both a nuclear licensed site (operated by DRDL) and a nuclear authorised site (an MOD site operated by HMNB(D)). This arrangement means a RoA produced by each operator in respect of their activities with ionising radiation has been submitted to ONR. As set out in section 2.3, the RoA’s, in their current issue, for both DRDL and HMNB(D) were submitted to ONR4 (then NII) in 2008. Since that time DRDL and HMNB(D) have made declarations of no change in relation to the RoA’s in 2011 and 2014 in line with the requirements of REPPIR (regulation 5).

Common to both the DRDL and HMNB(D) RoA’s is a generic HIRE carried out to evaluate the risks and hazards from the NRP fitted in each of the UK’s three main types of nuclear powered submarines (all of which may be berthed at Devonport). This generic HIRE contains classified information and as such any reference to the material it contains has been kept at a sufficiently high level in order to avoid the need to apply a similar level of classification to this document.

The reference accident common to both DRDL and HMNB(D) RoA’s is defined as a leak in the primary cooling circuit of the NRP, 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 leak is largely contained within the submarine, although a small part of the release inventory may be released to the environment.

5.1 HMNB (DEVONPORT) REPORT OF ASSESSMENT

The HMNB(D) RoA (reference 23) covers those activities with ionising radiations that are carried out under the responsibility of the MOD on the HMNB(D) site at Devonport. In its current revision it was submitted in 2008 and, as HMNB(D) assert that there have been no significant changes in activities involving ionising radiations since, declarations of no change have been made with respect to it in 2011 and 2014. It describes a number of submarine berths and supporting facilities that may give rise to a radiation accident. Review of the hazards shows that only fault scenarios associated with the NRP of berthed operational submarines could lead to a reasonably foreseeable radiation emergency as defined by REPPIR. These are defined as the reference accident described above in section 0. The most significant reasonably foreseeable radiation emergency identified indicates that a distance of 0.87 km from the relevant submarine berth should be used for emergency planning purposes.

The technical assessment of the HMNB(D) RoA is considered by the Defence Nuclear Safety Regulator (DNSR) as the relevant competent authority. They have confirmed their support of the 2008 submission and subsequent no change declarations in 2011 and 2014 (references 8, 11 & 14).

5.2 DRDL REPORT OF ASSESSMENT

DRDL’s RoA (reference 24) covers those activities with ionising radiations that take place on the licensed site at Devonport. Like the HMNB(D) it describes a number of submarine berths and supporting facilities that may give rise to a radiation accident. It also concludes that only fault scenarios associated with NRP of berthed operational submarines could lead to a reasonably foreseeable radiation emergency as defined by REPPIR. It draws from the same generic submarine HIRE as the HMNB(D) RoA and it reaches that same conclusion that the most significant reasonably foreseeable radiation emergency identified indicates that a distance of 0.87 km from the relevant submarine berth should be used for emergency planning purposes as this would be the area affected by a radiation emergency where a member of the public could receive a dose of 5 mSv.

4 The MOD REPPIR submission for HMNB(D) is sent to DNSR who forward it to ONR as described in section 2.3.

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5.3 ONR TECHNICAL ASSESSMENT

ONR (then NII) conducted a technical assessment of the generic submarine HIRE when it was submitted in 2008. Following a detailed review of the various fault scenarios it concluded that a more significant event than that proposed by the HMNB(D) and DRDL RoA’s was reasonably foreseeable and that as a result the minimum distance for emergency planning should be 1.5 km from each submarine berth. This assessment did not do an in-depth review of the site specific hazards, but made the judgement that any site specific fault scenario would be bounded by fault relating to the NRP.

A more recent ONR assessment has been conducted in 2016 which has not reassessed the conclusions of ONRs (NII) previous assessment but has focussed on whether there are any changes or additional hazards at Devonport which could add to the conclusions of the generic HIRE for the NRP. ONR’s specialist technical assessor was satisfied with DRDL’s judgement that there were no fault sequences that made a material change to the REPPIR submission and considers that the conclusions of ONR’s (NII) previous assessment remain valid.

DNSR is the regulator for security at defence sites and they have been consulted with respect to security related events at Devonport. It is their judgement that while a security event (unauthorised behaviours and malevolent acts) may initiate a nuclear emergency, it is unlikely that the amount of material released will result in consequences beyond the existing 5 mSv reference accident footprint.

It is therefore recommended that the fault sequence as determined in 2008, and previously detailed, should be considered as the site reference accident for the Devonport site and its associated Plymouth Sound berths with a predicted “5 mSv dose contour” to 1.5 km and that an area of not less than 1.5 km from each berth should be used as the basis for emergency planning.

5.4 CONCLUSIONS OF TECHNICAL ASSESSMENTS

The reference accident at the Devonport site relates to a fault scenario involving a radiation emergency at a NRP of a berthed operational submarine. This bounds all other fault scenarios on the sites. A distance of 1.5 km from the defined nuclear warship berths or moorings should continue to be the basis for off-site emergency planning.

The ONR technical assessment recommends that the determination of the REPPIR off-site emergency planning area should continue to be based on the 1.5 km distance from defined nuclear warship berths or moorings (for simplicity henceforth referred to as berths). ONR’s technical assessor agreed this distance was supported 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 (as described in section 6 below).

Conclusion 1: ONR is satisfied that the technical submissions made by HMNB(D) and DRDL demonstrate that members of the public are not likely (the legal test provided by REPPIR) to be exposed to effective doses in excess of 5 mSv (or other dose criteria defined in REPPIR Schedule 1), in the year following a reasonably foreseeable radiation emergency, beyond a radial distance of 1.5 km from any of the defined nuclear warship berths or moorings at DRD or HMNB(D).

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6 ASSESSMENT OF PRACTICAL AND STRATEGIC CONSIDERATIONS FOR THE DETERMINATION OF THE REPPIR OFF-SITE EMERGENCY PLANNING AND PRIOR INFORMATION AREAS

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 which is adequate to restrict exposures to the public, so far as is reasonably practicable, in the event of a reasonably foreseeable radiation emergency.

In accordance with ONR’s TAG (reference 17) and the principles incorporated within it, ONR must also give consideration to the practicality (in an emergency planning sense) of the REPPIR off-site emergency planning area, by considering a number of pragmatic factors considered to be relevant to deliver protection of the public.

In the course of considering these factors, ONR has consulted with PCC as the organisation responsible under REPPIR for preparation of the off-site emergency plans for Devonport and considered data in the RoA’s (references 23 and 24). In addition to PCC ONR has also consulted CC, SHDC, DCC, the Queens Harbour Master for the Port of Plymouth (QHM) and the Maritime & Coastguard Agency (MCA) as they are affected by the off-site emergency planning and prior information area determined.

The first step in this determination process was the application of the 1.5 km radial distance to each berth to provide the initial area against, and beyond which, the practical and strategic factors should be considered. The information provided in the RoA’s (references 23 and 24) details a number of berths located in the North Yard area of the Devonport site and a number of berths (which in this case are buoys / anchorages) in Plymouth Sound, several kilometres to the south. When the boundary of the 1.5 km radial distance is plotted for each berth this leads to three distinct areas, one covering the North Yard berths and two covering the Plymouth Sound berths. The boundary of these circles is considered to establish the minimum boundary that can form the off-site emergency planning area. These will henceforth be referred to as the North Yard and Plymouth Sound areas.

Due to the distance between North Yard and Plymouth Sound merging these areas to form a single off-site emergency planning area is not considered to be practical or proportionate.

It is noted that the existing Devonport off-site emergency plan (reference 7) employs separate areas for North Yard and Plymouth Sound.

Conclusion 2: Due to the distance between the North Yard and Plymouth Sound berths, a single REPPIR off-site emergency planning area is not considered to be practical or proportionate.

Initial inspection of the Plymouth Sound berths suggests a single planning area covering these berths may be appropriate. However the anchorages to the south of the Plymouth breakwater are both more than 2.0 km from the coast in any direction meaning that emergency planning for these berths is likely to be different for those to the north of the breakwater – even when consideration has been given to ONR’s practical and strategic factors. Therefore is judged that two distinct REPPIR off-site emergency planning areas should be determined for the Plymouth Sound berths: one for those north of the breakwater; and one for those to the south of the breakwater. These will henceforth be referred to the Plymouth Sound North and Plymouth Sound South areas.

Conclusion 3: Two REPPIR off site emergency planning areas have been determined for the Plymouth Sound berths. One for those north of the breakwater (Plymouth Sound North area) and one for those south of the breakwater (Plymouth Sound South area).

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To inform the application of the practical and strategic factors, which is discussed in sections 6.1 to 6.7 below, relevant information and significant features with respect to the North Yard and Plymouth Sound areas have been identified. These are detailed in annex A.

6.1 LOCAL GEOGRAPHIC, POPULATION AND PRACTICAL IMPLEMENTATION FACTORS

ONR TAG (reference 17) states 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 relation to the off-site emergency plan as provided for under REPPIR regulation 9(12).)”.

The relevant local authorities have been consulted with regard to what features should be used to define the boundary of the area determined. The default is to use infrastructure or geographical features such as, roads, railways, rivers and streams unless it is locally convenient to use other boundaries, such as postcode or electoral ward boundaries. In this case it was agreed that the use of infrastructure and geographical features was suitable. So as to avoid unnecessary inclusion of transport routes within the area determined the boundary of the area is taken to be the inner edge of any road, railway, river or other such similar feature unless otherwise stated.

Conclusion 4: The REPPIR off-site emergency planning area boundary should be defined on land, so far as is practicable, using physical features such as roads, rivers, and streams.

Where the boundary of the defined area runs along a coast line consideration needs to be given as to what aspect of the coast is used as the defining feature. It is noted that Association of Chief Police Officers (ACPO) / MCA national agreement uses the Mean High Water Mark (MHWM) as the demarcation for co-ordination of operational response to incidents for example if the incident is on the seaward side of the MHWM the co-ordination is undertaken by the MCA; conversely if it is landward side co-ordination is with the Police. However for Devonport I consider that use of the Mean Low Water Mark (MLWM) is more appropriate for the definition of the boundary planning area where it meets the coast line as it either fully includes, or excludes, those persons who may be residing in between the MHWM and the MLWM and whose primary means of shelter or evacuation is more likely to be via land rather than sea – for example people on the beach.

Conclusion 5: At the coast the REPPIR off-site emergency planning area boundary should be defined, so far as is practicable, using the Mean Low Water Mark.

For the marine area QHM was consulted5 as to the best way to define the boundary area. QHM were of the opinion that, for simplicity of communication with vessels during an emergency, wherever possible, definition of the boundary is best described as a distance from a single point (creating a radial boundary).

Conclusion 6: The extent of the marine area should preferably be described as radii from a defined point for simplicity of communication with vessels.

5 Meeting between ONR and QHM at Devonport 25/02/15.

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6.2 CREDIBILITY AND CONFIDENCE IN THE EXTENT OF THE REPPIR OFF-SITE EMERGENCY PLANNING AREA

ONR TAG (reference 17) states 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.”

REPPIR states that the safety objective of the planning undertaken by local authorities with the REPPIR offsite 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.

Therefore, although it has been concluded (section 5.4) that the limit of the extent to which members of the public are likely to be exposed to ‘5 mSv in the year following a reasonably foreseeable radiation emergency’ is a distance of 1.5 km from any defined berth, a REPPIR off-site emergency planning area based on a contour equating to that distance must also provide a sufficient off-site planning area for the purposes of satisfying this broader REPPIR dose restriction intention, noting the proximity of any significant conurbations to the defined berths.

North Yard Area

To examine the extent of the area necessary to provide for a meaningful off-site planning area, I have first considered the off-site emergency planning challenge that would be presented by the minimum North Yard area. Information, provided by the Health and Safety Laboratories (HSL), on the population within 1.5 km (further details can be found in annex A) indicates within this areas there is/are:

 a night time residential population of approximately 32 000;  a significant transient (railway, ferry and waterborne craft) population;  41 vulnerable groups (ie 12 schools, 13 care homes, and 16 nurseries);

In this context, ONR is mindful that, whilst UK licensees and authorisees are typically conservative in their approach to nuclear safety, complex technical assessments of potential emergency situations must inevitably rely on a range of assumptions, judgements and estimates.

Whilst ONR is satisfied that the REPPIR submissions made by the licensees and authorisees demonstrate the overall risk from the site has been conservatively estimated, ONR is of the opinion that it is appropriate, where public safety is at stake, that it acts with reasonable conservatism in its own right, in the interests of confidence in securing the public safety objective of REPPIR.

As a consequence, ONR’s principles recognise that an off-site emergency planning area, which demands very little by way of an emergency plan in practice (eg it contains a very small population), 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.

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In the case of North Yard the initial 1.5 km area considered encompasses a very significant population (also noting that the current Devonport off-site emergency plan (reference 7) covers a slightly larger area) and it is not therefore necessary to extend the minimum area to “provide for a credible and effective response in the event of a reasonably foreseeable radiation emergency”.

However, it is recognised that a plan covering part of a densely populated area may also be significantly challenged in the extremely unlikely event that the area required for public protection were to extend further than that determined as it would include a large number of additional residents. REPPIR6 and Nuclear Emergency Planning Liaison Group (NEPLG) guidance state that it is good practice for the emergency plan to provide the basis for dealing with radiation emergencies that are not reasonably foreseeable through the concept of extendibility. Such an extension of the area required for public protection would fall under this concept, one which the current Devonport off-site emergency plan (reference 7) does address.

Therefore, I am of the opinion that the emergency planning area for the North Yard area does not need to be extended beyond 1.5 km from each berth for the provision of credibility and confidence in the off-site plan and will form the basis for determining the REPPIR off-site emergency planning area following consideration of the practical and strategic factors.

Plymouth Sound North Area

The Plymouth Sound North area, at a radial distance of 1.5 km from each berth, contains a night time population of less than 50, no vulnerable groups and no significant infrastructure. The temporary population within 1.5 km is likely to be limited to vessels (civil and military) at sea, tourists and golfers on land. In isolation it may be necessary to extend the area to provide the basis for a credible plan. However as the Devonport off-site emergency plan also covers (and will be continue to be required to cover) the North Yard area there is no such need. Therefore I consider that it is not necessary to extend the emergency planning area for Plymouth Sound North beyond 1.5 km from each berth for the provision of credibility and confidence in the off-site plan. 1.5 km should therefore form the basis for determining the REPPIR off-site emergency planning area following consideration of the practical and strategic factors.

Plymouth Sound South Area

The Plymouth Sound South area, at a radial distance of 1.5 km from each berth contains no permanent population or vulnerable groups. The 1.5 km radius from the northern most berth just bisects the Plymouth Sound breakwater. Temporary population is likely to be limited to vessels at sea (civil or military) or anyone visiting the breakwater. In isolation it would be necessary to extend the area to provide the basis for a credible plan. However as stated previously the Devonport off-site emergency plan also covers the North Yard area there is no such need. Therefore I consider that it is not necessary to extend the emergency planning area for Plymouth Sound South beyond 1.5 km from each berth for the provision of credibility and confidence in the off-site plan. 1.5 km should therefore form the basis for determining the REPPIR off-site emergency planning area following consideration of the practical and strategic factors.

Conclusion 7: A REPPIR off-site emergency planning area based on a minimum radial distance of 1.5 km from all berths in North Yard and Plymouth Sound (North and South) will provide for a credible and effective plan to secure the protection of the public and restriction of exposures so far as is reasonably practicable, in the event of a reasonably foreseeable radiation emergency.

6 Paragraph 138 of REPPIR.

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6.3 AVOIDANCE OF BISECTION OF LOCAL COMMUNITIES

ONR TAG (reference 17) states 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.”

North Yard Area

The minimum radial distance of 1.5 km from each berth for the North Yard area bisects Plymouth to the north and east and Torpoint to the west. Inclusion of the whole of Plymouth and Torpoint would extend the area far beyond 1.5 km and include a population in excess of 265,000. These are clearly not small communities and I consider that to include the whole of both would be excessive and unnecessary. Thus, in this case, bisection of the Plymouth and Torpoint is unavoidable.

It is possible to subdivide Plymouth by use of electoral ward boundaries (of which there are 20) or neighbourhoods7. However following inspection of these boundaries and in consultation with PCC I am of the opinion that use of such boundaries is not suitable for defining the REPPIR off-site emergency planning area. For consistency the Torpoint part (which has two electoral wards) of the emergency planning area will also not be sub divided.

The minimum North Yard area boundary also crosses a rural area (to the north of Torpoint). There are a number of small hamlets in the vicinity, but none that are bisected by the 1.5 km radial distance, however if these are bisected by extension of the area when application of the practical and strategic factors are considered then it is appropriate to include all residences in them.

Plymouth Sound North and South Areas

The minimum radial distance of 1.5 km from each berth for the Plymouth Sound areas does not bisect any local communities and therefore this factor will only need to be considered should the application of any of the other practical and strategic factors lead to a bisection of any small or local communities.

Conclusion 8: It is considered not appropriate to include the whole of the large urban areas of Plymouth and Torpoint to enable the avoidance of bisection of small or local communities. Use of community boundaries within Plymouth and Torpoint has been considered and deemed not to be appropriate for determining the emergency planning area boundary.

6.4 INCLUSION OF IMMEDIATELY ADJACENT VULNERABLE GROUPS

ONR TAG (reference 17) states that:

“ONR recognises that groups of vulnerable people (eg 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

7 The Plymouth neighbourhoods were officially adopted by Plymouth's Local Strategic Partnership ('Plymouth 2020') in January 2003 and define 43 distinctive areas within the city. Each neighbourhood has a population of approximately 5500 people (Source: An atlas of child health and its determinants at neighbourhood level within Plymouth. Public Health Development Unit November 2006).

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as those located within the zone.” (The definition of ‘vulnerable’ groups must be the definition adopted by the relevant local authority.)

North Yard Area

Data provided by HSL has shown that there are that there are 41 vulnerable groups within 1.5 km of the North Yard berths (12 schools, 13 care homes, and 16 nurseries). For consideration of this practical and strategic factor it is necessary to consider those vulnerable groups beyond 1.5 km. Here, data provided for Plymouth and Torpoint indicates that there is a regular and frequent distribution of vulnerable groups to the southeast of the 1.5 km radial distance extending well beyond 2.0 km.

Therefore, for the purposes of determining the appropriate planning area for North Yard, I consider that an immediately adjacent vulnerable group is one that is close to (and beyond) the minimum 1.5 km radial distance. I have considered the inclusion of each based on a balance of the nature of that vulnerable group, its size, its distance and the other practical strategic factors. I am of the opinion that beyond a radial distance of 2.0 km any vulnerable group should not be considered ‘immediately adjacent’ and inclusion of any group beyond this distance would only be the direct result of the application of more than one of the other practical and strategic factors.

To support determination of the required emergency area planning information on vulnerable groups between radial distances of 1.5 and 2.0 km was provided by PCC and CC. ONRs intent is to be consistent with other aspects of council arrangements for vulnerable groups, therefore, as a default, it will use the relevant local authorities’ definition of what constitutes a vulnerable group when considering the extent of the planning area. It should be noted that there is Cabinet Office guidance8 on this subject with a general definition of “vulnerability” to mean; “those that are less able to help themselves in the circumstances of an emergency” and include people with mobility difficulties, mental health issues, children/elderly, hearing and visual impaired. For consistency with other ONR REPPIR determinations I have also considered the inclusion of groups who could be at risk of greater exposure (so could be considered as “vulnerable”). Examples include residents of caravans, beach huts, leisure craft, campsites or sites where members of the public may have restricted access to information or the important countermeasure of sheltering could be considerably less effective for those occupants when compared to the protection offered to those who are able to shelter in a more substantial and permanent structure. For the North Yard area this latter consideration is generally more applicable to those in the marine environment (i.e vessels, both civil and military).

Information provided by PCC, CC, SHDC and DCC confirmed the information provided by HSL, with a few minor differences. Additionally PCC had included GP surgeries on their list of vulnerable groups. Details of the HSL data supplied can be found in annex A.

Inspection of the available vulnerable group data for North Yard showed that any minor differences that exist between the different sources would have very little impact of the extent of the planning area defined. Therefore I have reviewed all the vulnerable groups identified within the 1.5 km to 2.0 km radial distance and included those which provide a net benefit in securing public protection when all practical and strategic factors are considered. An example of this is the area to the south east of North Yard (see the area determined in map 1 in annex B) where Stoke Damerel Primary School and several care homes have been included by extending the area, using convenient geographical features, to a distance not exceeding 1.8 km from the nearest berth.

8 Chapters 5 & 7 - https://www.gov.uk/government/publications/emergency-preparedness

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Conclusion 9: Vulnerable groups within a radial distance of 1.5 to 2.0 km of North Yard berths have been reviewed and the area determined will include those that result in a net benefit in securing public protection when all practical and strategic factors are considered.

Plymouth Sound North Area

The same request for vulnerable group information between 1.5 and 2.0 km radial distance was made to PCC, CC with respect to Plymouth Sound as was made for North Yard. Information was also requested from SHDC (and DCC who provide their emergency planning) as the planning area may also extend into their district. All responded that there were no vulnerable groups (by their definition) in the area requested.

Review of the Plymouth Sound area has shown that there are a number of other potential vulnerable groups that should be considered for inclusion. These include the users of caravans, holiday homes, marine vessels and Staddon Heights golf course.

As described above, in my opinion residents of caravans, holiday homes and marine vessels should be considered for inclusion.

Similarly users of a golf course may not have immediate access to shelter, plus the challenges of communication with them in the event of an incident may also render them more vulnerable.

Holiday home complexes and golf courses typically cover a large area of land. Some of their overall footprint may fall within, or be immediately adjacent to, the minimum radial distance and require inclusion. Where this is the case the whole of the footprint of that group will be included in the planning area unless there are specific reasons for partial exclusion.

Therefore I conclude that Staddon Heights golf course, the holiday residences of Cedar Park, Bovisand Park and Bovisand Lodge Estate should be included in the area determined.

Conclusion 10: Staddon Heights golf course and the holiday residences of Cedar Park, Bovisand Park and Bovid and Lodge Estate should be included in the area determined for Plymouth Sound North.

Plymouth Sound South Area

The 1.5 km radial area drawn around the northern most Plymouth Sound South berth bisects the Plymouth Sound breakwater. Although this structure and the fort immediately to the north of it do not contain any permanent population it is possible for persons to visit them (for example for survey or maintenance of those structures). Therefore I consider that the whole of the breakwater and associated fort should be included in the Plymouth Sound South area.

Conclusion 11: The Plymouth Sound breakwater and associated fort should be included in the area determined for Plymouth Sound South.

6.5 INTERNATIONAL GOOD PRACTICE

ONR TAG (reference 17) states 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 Energy Agency (IAEA) publications GSR Part 7 and GS-G-2.1

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(references 21 and 22). 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: a Precautionary Action Zone (PAZ) and an Urgent Protective Action Planning Zone (UPZ). However, due to differences in the UK legal framework, and the assessment of reasonably foreseeable radiation emergencies on a case-by-case basis, neither of these zones are 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, but also 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 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 (ie 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 in the range of stochastic (random or chance) 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 19) and is broadly supported (of the same order of magnitude) by Public Health England (PHE) (reference 25), 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 principles for determination of the REPPIR off-site emergency planning area (and related guidance) (references 21 & 17) indicate that areas should take account of a range of factors (eg 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 26), and the developing concept of extendibility (ie the concept of planning for emergencies beyond those that are reasonably foreseeable, with

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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 regulatory guidance states that off-site plans prepared under REPPIR should include a framework for such scalability. The existing Devonport off-site emergency plan (reference 7) contains voluntary arrangements that are supplementary to the REPPIR off-site emergency planning areas, 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. ONR is not the enforcing authority for CCA.

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 areas determined within this report fall within the international good practice ranges.

6.6 CONSIDERATION OF BENEFITS AND DIS-BENEFITS OF DOSE REDUCTION MEASURES (INCLUDING COUNTERMEASURES)

ONR TAG (reference 17) states 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 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.

Noting that REPPIR requires that the 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) the considerations are:

 An area of the minimum size might be beneficial as emergency responders would be able to focus their efforts on delivering timely dose reduction measures (including countermeasures) in a concentrated manner across a smaller population and geographical area.  A larger area (eg that, for instance, extended to avoid bisection of local communities or to include a vulnerable group) might be perceived as providing safety benefits to a larger population.  However, a larger area may be judged to have the potential to compromise the effectiveness and timeliness of some of the emergency arrangements.  A larger area might be perceived as requiring the application of countermeasures across more people than may be necessary (with any risks that could be presented by such measures). This notwithstanding, REPPIR provides the local authority with 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 based on but not bounded by the REPPIR off-site emergency area determined by ONR. 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.

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For the North Yard area there is a large population both within and beyond the 1.5 km minimum area. A small increase in the extent of the area could lead to a substantial increase to the number of people it contains, and includes additional significant infrastructure leading to complication of the emergency response. For this reason increases to the extent of the area beyond the 1.5 km minimum should only be affected where, in my opinion, the benefits of doing so represent a net benefit to the planning area as a whole. The expected result of this is that the average distance of the planning area boundary to the source of potential hazard will not extend much beyond the minimum recommended distance for the urban portions of the area.

Conclusion 12: Taking into account the benefits and dis-benefits of the application of emergency dose reduction measures it is judged that extension of the REPPIR off-site emergency planning area for the Devonport site North Yard area, based on the minimum 1.5 km radius from each operational submarine berth, should be kept to a minimum when considering all practical and strategic factors in order to achieve an appropriate balance between public protection, the risks from the implementation of countermeasures, and retention of an effective emergency planning area.

For the Plymouth Sound areas an increase in extent of the area would only result in the inclusion of a substantial population numbers and significant infrastructure if that increase extended beyond 5.0 km to north / northeast – for example it would include parts of Plymouth. To the south is the English Channel and the land east and west has a low population density. Thus extension of the area determined is less constrained by the concept of the dis-benefits of dose reduction measures than it is for the North Yard area. However should the Plymouth Sound areas require extension as far as the populated areas to the north then the same conclusions would apply.

A potential result of this reduced constraint to limit the extent of the area to avoid possible dis-benefits is that the resulting areas determined for Plymouth Sound (Plymouth Sound North area in particular) may appear disproportionately large in comparison with the North Yard area. This will be due to the contrasting population densities of the two areas when all of the ONR practical and strategic factors have been applied.

Conclusion 13: Extension of the REPPIR off-site emergency planning area for the Devonport Plymouth Sound areas, beyond the minimum 1.5 km radius from each berth, need only be minimised when considering the application of emergency dose reduction measures if that extension reaches as far as the urban areas to the north. This is in order to achieve an appropriate balance between public protection, the risks from the implementation of countermeasures, and retention of an effective emergency planning area.

6.7 OTHER SITE SPECIFIC FACTORS OF WHICH ONR IS AWARE

ONR TAG (reference 17) states 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.”

During the course of undertaking this work ONR has been made aware of two planning applications that may have relevance to the REPPIR off-site emergency planning area determination.

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The first relates to the development of part of the South Yard area of the Devonport main site which has been subject to the Plymouth City Deal and is likely to be redeveloped into light industrial facilities (Plymouth City Council Planning reference 14/02269/OUT). This development is outside the 1.5 km minimum radius for North Yard and it does not alter any of the considerations made with respect to the other practical and strategic factors discussed above.

The second planning application relates to the redevelopment of Fort Bovisand (South Hams District Council planning reference 58/2441/15/F), which lies on the coast to the east of Plymouth Sound and the breakwater, into residential accommodation. Fort Bovisand lies within 1.0 km of one of the Plymouth Sound buoys and as such is completely within the 1.5 km minimum radial distance which forms the basis of the emergency planning area. Therefore it will be included in the REPPIR off-site emergency planning and prior information area and does not need to be considered further.

A review of significant features within the wider Plymouth area (see map 4 in Annex C) has been carried out to see if there is anything which should be considered as part of this determination. This has included urban centres, transit hubs and other such geographical items. These are detailed in Table 3 and Table 6 in annex A. From this, I have not identified any features that require consideration beyond that already considered as part of the other practical and strategic factors.

Conclusion 14: There are no additional site specific factors of which ONR is aware that require consideration when determining the REPPIR off-site emergency planning area for Devonport.

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7 CONCLUSIONS

This report sets out the main considerations that ONR has given to determining revised REPPIR off-site emergency planning and prior information areas for the Devonport nuclear licensed and authorised sites. It takes due account of the findings of the HMNB(D) and DRDL RoA/ HIRE and of ONR’s 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).

In summary, the conclusions of this report are that:

 ONR is satisfied that the technical submissions made by HMNB(D) and DRDL demonstrate that members of the public are not likely (the legal test provided by REPPIR) to be exposed to effective doses in excess of 5 mSv (or other dose criteria defined in REPPIR Schedule 1), in the year following a reasonably foreseeable radiation emergency, beyond a radial distance of 1.5 km from any of the defined nuclear warship berths or moorings at DRD or HMNB(D).  Due to the distance between the North Yard and Plymouth Sound berths, a single REPPIR off-site emergency planning area is not considered to be practical or proportionate.  Two REPPIR off site emergency planning areas have been determined for the Plymouth Sound berths. One for those north of the breakwater (Plymouth Sound North area) and one for those south of the breakwater (Plymouth Sound South area).  The REPPIR off-site emergency planning area boundary should be defined on land, so far as is practicable, using physical features such as roads, rivers, and streams.  At the coast the REPPIR off-site emergency planning area boundary should be defined, so far as is practicable, using the Mean Low Water Mark.  The extent of the marine area should preferably be described as radii from a defined point for simplicity of communication with vessels.  A REPPIR off-site emergency planning area based on a minimum radial distance of 1.5 km from all berths in North Yard and Plymouth Sound (North and South) will provide for a credible and effective plan to secure the protection of the public and restriction of exposures so far as is reasonably practicable, in the event of a reasonably foreseeable radiation emergency.  It is considered not appropriate to include the whole of the large urban areas of Plymouth and Torpoint to enable the avoidance of bisection of small or local communities. Use of community boundaries within Plymouth and Torpoint has been considered and deemed not to be appropriate for determining the emergency planning area boundary.  Vulnerable groups within a radial distance of 1.5 to 2.0 km of North Yard berths have been reviewed and the area determined will include those that result in a net benefit in securing public protection when all practical and strategic factors are considered.  Staddon Heights golf course and the holiday residences of Cedar Park, Bovisand Park and Bovid and Lodge Estate should be included in the area determined for Plymouth Sound North.  The Plymouth Sound breakwater and associated fort should be included in the area determined for Plymouth Sound South.

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 Taking into account the benefits and dis-benefits of the application of emergency dose reduction measures it is judged that extension of the REPPIR off-site emergency planning area for the Devonport site North Yard area, based on the minimum 1.5 km radius from each operational submarine berth, should be kept to a minimum when considering all practical and strategic factors in order to achieve an appropriate balance between public protection, the risks from the implementation of countermeasures, and retention of an effective emergency planning area.  Extension of the REPPIR off-site emergency planning area for the Devonport Plymouth Sound areas, beyond the minimum 1.5 km radius from each berth, need only be minimised when considering the application of emergency dose reduction measures if that extension reaches as far as the urban areas to the north. This is in order to achieve an appropriate balance between public protection, the risks from the implementation of countermeasures, and retention of an effective emergency planning area.  There are no additional site specific factors of which ONR is aware that require consideration when determining the REPPIR off-site emergency planning area for Devonport. Consequently, for emergency planning purposes and in order to ensure appropriate conservatism as regards the protection of the public in the unlikely event of a reasonably foreseeable radiation emergency, the REPPIR off-site emergency planning areas (and the areas within which prior information must be distributed in accordance with REPPIR regulation 16(1)) are defined as:

North Yard Area

The area described by the red line on map 1 in annex B and generally described as:

An area extending between 1.5 and 2.5 km from the centre of the Devonport site 5 basin whose boundary follows, in the main, the inner edges of roads, property boundaries and pathways on land and a radius of 2.0 km from the centre of 5 basin on the water.

Plymouth Sound North Area

On consideration of all of the practical and strategic factors I judged that extension of the radial distance around the buoys in Plymouth Sound North to 1.7 km from the minimum 1.5 km is necessary to achieve a suitable emergency planning and prior information area, overall this results in the area described by the red line on map 2 in annex B and generally described as:

A mostly marine and mainly circular area of radius 1.7 km around Delta and Echo buoys in Plymouth Sound that includes the breakwater and Drake Island and also extends onto land to include parts of Bovisand and Crownhill Bays on the eastern side.

Plymouth Sound South Area The area described on the red line on map 3 in annex B and generally described as:

The combined area based on 1.5 km circular radii around 22 and 23 anchorages in Plymouth Sound and including the Plymouth Sound breakwater and the Plymouth Sound breakwater fort.

This determination has been undertaken in response to REPPIR submissions to ONR by MOD and DRDL. ONR has considered these submissions, applied its 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.

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This is consistent with ONR’s insistence that high standards of nuclear safety at nuclear installations are maintained at all times, and reflects our commitment to implementing improvements where appropriate and proportionate to do so.

8 RECOMMENDATIONS

As a result of the conclusions of this report, the recommendations are that ONR write to:

Recommendation 1: Plymouth City Council, being the lead responsible local authority to advise them that the REPPIR off-site emergency planning areas have been determined as the areas within the red lines on maps 1, 2 and 3 in annex B. This information should be copied to Cornwall Council, South Hams District Council and Devon County Council as additional responsible local authorities. It should also be copied to Her Majesty’s Naval Base Commander (Devonport) and Devonport Royal Dockyard Ltd acting as the duty holders for the Devonport site and Her Majesty’s Naval Base Commander (Devonport) as the duty holder for the associated Plymouth Sound berths.

Recommendation 2: Plymouth City Council, being the lead responsible local authority confirming the need to update, as required, its detailed off-site emergency plan to adequately cover the areas defined in annex B.

Recommendation 3: Her Majesty’s Naval Base Commander (Devonport) and Devonport Royal Dockyard Ltd acting as duty holders for the Devonport site and Her Majesty’s Naval Base Commander (Devonport) acting as duty holder for the associated Plymouth Sound berths confirming the requirement to ensure the appropriate provision of prior information to the public within the areas defined in annex B. This should also be copied to Plymouth City Council, Cornwall Council, South Hams District Council and Devon County Council.

Recommendation 4: The Defence Nuclear Safety Regulator, Queens Harbour Master, Maritime & Coastguard Agency, Environment Agency, Food Standards Agency and Department for Business, Energy & Industrial Strategy, to inform them of the revised REPPIR off-site emergency planning and prior information areas.

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9 REFERENCES

1. Energy Act 2013, Chapter 32. Part 3, Chapter 4, ‘Function of the ONR’, paragraph 78, ‘Principal function’. Part 3, Chapter 1, ‘The ONR purposes’, paragraph 68(1). The Stationery Office. December 2013. IBN 978-0-10-543213-5 2. Nuclear Installations Act 1965 and subsequent amendments. 3. Statutory Instruments 2001 No. 2975 Radiation (Emergency Preparedness and Public Information) Regulations 2001 4. Statutory Instruments 2014 No. 469 The Energy Act 2013 (Office for Nuclear Regulation) (Consequential Amendments, Transitional Provisions and Saving) Order 2014. 5. General Agreement Between Ministry of Defence and Office for Nuclear Regulation for Regulation of the Defence Nuclear Programme. 28th January 2015. 6. Letter of Understanding between the Office for Nuclear Regulation and The Defence Nuclear Safety Regulator setting out their intentions for coherent, complete and seamless regulation of the Defence Nuclear Programme. 30th April 2015. 7. Devonport Off-site Emergency Plan, version 5.0 (Interim), September 2015 8. REPPIR – Technical Assessment of 2008 Submissions by Defence Operators DNSR/3/3/3/1. October 2008. 9. REPPIR 2008 Submission – Regulatory Assessment, 30th April 2009, HSE Reference: D3NON 70059. 10. Radiation (Emergency Preparedness and Public Information) 2001 (REPPIR) Regulation 9(1) Off-site emergency plan Operational submarine berth – HM Naval Base Devonport, Devonport Royal Dockyard. 11. Radiation (Emergency Preparedness and Public Information) 2001 (REPPIR (REPPIR) 2011 submission by defence operators. 12. UK Operational Berth Safety Statements in Support of the MOD 2011 REPPIR Submission. 13. Letter from Devonport Royal Dockyard Ltd – Radiation (Emergency Preparedness and Public Information) Regulations 6: Report of Assessment of Hazard Identification and Risk Evaluation. 25 February 2011. 14. Defence Operators 2014 REPPIR submission, DSM/Tech/REPPIR/14/01 31st January 2014. 15. Letter from Devonport Royal Dockyard Ltd - Radiation (Emergency Preparedness and Public Information) Regulations 6: Report of Assessment of Hazard Identification and Risk Evaluation. 21 February 2014. 16. A guide to the Radiation (Emergency Preparedness and Public Information) Regulations 2001. L126. 2002. http://www.gov.uk/pubns/priced/l126.pdf 17. The technical assessment of REPPIR submissions and the determination of detailed emergency planning zones, ONR NS-TAST-GD-082 Revision 2 2013. http://www.onr.org.uk/operational/tech_asst_guides/ns-tast-gd-082.pdf 18. 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 19. 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 20. ONR Safety Assessment Principles for Nuclear Facilities, 2014 Edition, Revision 0. AM.1 Accident management and emergency preparedness

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21. IAEA Safety Standards Series (General Safety Requirements) No GSR Part 7 dated November 2015. Preparedness and Response for a Nuclear or Radiological Emergency. ISBN 978–92–0–105715–0. http://www-pub.iaea.org/MTCD/Publications/PDF/P_1708_web.pdf 22. 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/Pub1265web.pdf 23. HM Naval Base Devonport. Report of Assessment of Hazard Identification and Risk Evaluation. Issue 1 – February 2008. 24. Devonport Royal Dockyard Limited. Report of Assessment to meet the requirements of Radiation (Emergency Preparedness and Public Information) Regulations, Regulation 6 and Schedule 5. Revision D – February 2008 25. PHE (formerly NRPB), NRPB advice (Volume 8. No.1. 1997, Intervention for Recovery After Accidents, para 35). 26. Civil Contingencies Act (2004): Chapter 36, 13 November 2004, Her Majesty’s Stationery Office.

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ANNEX A – RELEVENT INFORMATION AND SIGNIFICANT FEATURES

Wider Plymouth Area

Population data relating to the Plymouth and the surrounding areas is given in Table 1 with a map of these areas in annex C, map 4.

Table 1: Population data for wider Plymouth Area

5 km area - map 4 10 km area - map 4 Residential Population (night time) 223 107 326 086 Childcare population (No. locations) 3 667 (104) 5 794 (158) School population (No. Schools) 31 765 (81) 44 322 (118) College population (No. Colleges) 5 416 (3) 5 416 (3) Care Home population (No. Care Homes) 2 054 (87) 3 163 (123) Number of Hospitals 5 12 Railway Station annual passengers (No. of 2 712 162 (7) 2 780 844 (9) stations) No. of Ports & Ferry Terminals 8 11 No. of Bus and Coach Stations 1 1 No. of Campsites 4 15 Stadia Capacity (No. Stadia) 29 387 (3) 29 387 (3) Area (km2) 137.2 438.3 Data provided by HSL

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North Yard Area

As described in section 0, the North Yard area of the Devonport site is where maintenance on nuclear powered submarines is carried out. The site is immediately adjacent to the densely populated City of Plymouth to the east, through which passes the A38 and a major branch of the Great Western Main line (Cornish Mainline / Exeter to Plymouth Line) which passes within only a few hundred metres of the site. To the north is Royal Naval Armaments Depot (RNAD) Ernsettle, just beyond the Tamar (road) and Royal Albert (rail) bridges. On the opposite side of the Hamoaze and to the north west is the town of Saltash, to the west is the town of Torpoint and the Thanckes Oil Fuelling Depot.

North Yard specific population data, including that for the REPPIR off-site emergency planning area is provided in Table 2.

Table 2: North Yard Population Data

REPPIR off-site within 1.5 km of within 2.0 km of emergency operational operational planning and prior submarine berths submarine berths information area Residential Population - night time 32 213 54 477 39 309 Residential population – day time, term 13 806 23 846 17 124 time Residential population – day time, 18 277 31 134 22 475 non-term time Child care population (no. locations) 514 (16) 820 (23) 648 (20) School pupils (no. locations) 2 932 (12) 7 155 (20) 4 826 (17) College population (no. locations) 0 (0) 2 357 (1) 0 (0) Care home residents (no. locations) 196 (13) 500 (25) 460 (23) No. of Hospitals 0 0 0 Railway station annual passengers (no. 61 462 (5) 61 462 (5) 61 462 (5) locations) No. of Port & ferry terminal 2 2 2 No. of Bus and Coach Stations 0 0 0 No. of Campsites 0 0 0 Stadia Capacity (no. locations) 0 (0) 8 400 (1) 0 (0) Area (km2) 9.73 16.07 11.44 Data provided by HSL

North Yard specific significant feature information is provided in Table 3.

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Table 3: North Yard Significant Features

Approximate distance from North Approximate Population / Town / Feature Yard (centre of initial area) Comment Plymouth 0.3 km 258 700 Torpoint 1.2 km east 7 700 Saltash 1.9 km north east 15 500 Thanckes Oil Fuelling Depot 0.9 km east - Derriford Hospital 6.0 km north east - Plymouth Airport 6.3 km north east Closed late 2011 RNAD Ernsettle north - St Barnabus Hospital 2.5 km north west Saltash Home Park Stadium 2.5 km east Football capacity 19 500 Brickfields Stadium 1.9 km south Rugby capacity 8 500 Torpoint Ferry 2.4 million vehicle movements 1.1 km south per annum11 Cremyll Ferry Peak hourly capacity: 314 2.8 km south persons each way (no vehicles)11 Data compiled by ONR

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Plymouth Sound Areas

Plymouth Sound is a bay in the English Channel stretching from Penlee Point (Cornwall) in the southwest, approximately 6 km to Wembury Point (Devon) in the southeast and Plymouth Hoe approximately 6 km in the north. Roughly in the centre of Plymouth Sound is the Plymouth breakwater a 1600 metres long by 65 metres wide breakwater standing in approximately 11 metres of water that protects the anchored vessels to the north from the frequent storms from the south west.

The 1.5 km radial distance for the berths (which in this case are buoys) located to the north of the breakwater bisects Drake Island to the North, encompasses Bovisand Fort and bisects the Staddon Heights golf course to the east. It does not reach the Cornish coast to the west.

The 1.5 km radial distance for the berths (which in this case are anchorages) located to the south of the breakwater only bisects the breakwater. The berths are more than 2.0 km from the coast in any direction.

Plymouth Sound specific population data, including that for the REPPIR off-site emergency planning area is provided in Table 4 and Table 5.

Table 4: Plymouth Sound North Population Data

REPPIR off-site within 1.5 km of within 2.0 km of emergency planning operational submarine operational and prior information berths submarine berths area Residential Population - night 34 636 399 time* Residential population – day time, 17 294 195 term time* Residential population – day time, 20 358 234 non-term time* Child care population (no. 0 (0) 0 (0) 0 (0) locations) School pupils (no. locations) 0 (0) 0 (0) 0 (0) College population (no. locations) Care home residents (no. 0 (0) 0 (0) 0 (0) locations) No. of Hospitals 0 0 0 Railway station annual 0 (0) 0 (0) 0 (0) passengers (no. locations) No. of Port & ferry terminal 0 0 0 No. of Bus and Coach Stations 0 0 0 No. of Campsites 0 1 1 No. of Stadia Capacity (no. 1 1 1 locations) Area (km2) 8.89 15.0 11.68 Data provided by HSL *It is noted that this figure does not account for seasonal variation and that summer time population these areas may be larger.

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Table 5: Plymouth Sound South Population Data

REPPIR off-site within 1.5 km of within 2.0 km of emergency planning operational submarine operational and prior information berths submarine berths area Residential Population - night time 0 0 0 Residential population – day time, 0 0 0 term time Residential population – day time, 0 0 0 non-term time* Child care population (no. 0 (0) 0 (0) 0 (0) locations) School pupils (no. locations) 0 (0) 0 (0) 0 (0) College population (no. locations) Care home residents (no. 0 (0) 0 (0) 0 (0) locations) No. of Hospitals 0 0 0 Railway station annual 0 (0) 0 (0) 0 (0) passengers (no. locations) No. of Port & ferry terminal 0 0 0 No. of Bus and Coach Stations 0 0 0 No. of Campsites 0 0 0 No. of Stadia Capacity (no. 0 0 0 locations) Area (km2) 8.73 14.78 8.81 Data provided by HSL

Plymouth Sound specific significant feature information is provided in Table 6

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Table 6: Plymouth Sound Significant Features

The following table shows the approximate distance of various towns and other significant features from the nearest Plymouth Sound berth.

Approximate distance from Approximate Population / Town / Feature Plymouth Sound (nearest berth) Comment Plymouth 2.3 km north 258 700 Plymstock 2.2 km north east 24 100 – suburb of Plymouth Planning permission for Bovisand Fort 1.0 km east residential development Down Thomas 2.5 km east 333 Wembury 4.7 km south east 2 740 Mount Batten 2.0 km north Diving centre Heybrook Bay 2.6 km south east 472 Cremyll 2.9 km north west <1 000 Mount Edgecumbe Country Park 1.7 km east Park Kingsand 3.5 km east 647 Cawsand 3.5 km east <1 000 Millbrook / Anderton 4.6 km east 2 278 North Yard 5.2 km north Devonport site Torpoint 5.0 km north east 7 700 Breakwater and associated fort Plymouth Sound breakwater 0.5 km south not permanently inhabited Drake Island 1.4 km north Disused naval barracks and fort Staddon Heights Golf Club 1.4 km east (nearest point) Recreational Staddon Heights Golf Club (Club 2.0 km east House) Bovisand Holiday Park 1.6 km east Static Caravan park Cedar Park 1.6 km east Holiday homes / chalets Peak hourly capacity: 314 Cremyll Ferry 2.9 km north west persons each way (no vehicles)11 Cawsand to Barbican Ferry 3.5 km east Landing (Cawsand) Ferry route < 1.5 km, March to October, up to 64 passengers per Cawsand to Barbican Ferry 12 2.6 km north crossing Landing (Barbican) Ferry route < 1.5 km, Plymouth Ferry Terminal, Millbay 450 000 passengers pa13 docks (to St Malo, Santandar & 2.5 km north 250 000 tonnes cargo pa13 Rascoff)

Data compiled by ONR

11 Information from Cornwall Council and Plymouth City Council River Tamar Crossings Study, Final Report R001/rev08. July 2013 12 Information from www.cawsandferry.co.uk 13 Information from www.abports.co.uk

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ANNEX B – DETERMINATION MAPS

North Yard Area Map showing the REPPIR off-site emergency planning and prior information area for the operational nuclear submarine berths in the Devonport North Yard area, described as:

An area extending between 1.5 and 2.5 km from the centre of the Devonport site 5 basin whose boundary follows, in the main, the inner edges of roads, property boundaries and pathways on land and a radius of 2.0 km from the centre of 5 basin on the water.

Map 1: Map of Devonport REPPIR off-site emergency planning and prior information area 2016 – North Yard

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Plymouth Sound North Area Map showing the REPPIR off-site emergency planning and prior information area for the operational nuclear submarine berths (which in this case are buoys) in the Plymouth Sound North area, described as:

A mostly marine and mainly circular area of radius 1.7 km around Delta and Echo buoys in Plymouth Sound that includes the breakwater and Drake Island and also extends onto land to include parts of Bovisand and Crownhill Bays on the eastern side.

Map 2: Map of Devonport REPPIR off-site emergency planning and prior information area 2016 – Plymouth Sound North

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Plymouth Sound South Area Map showing the REPPIR off-site emergency planning and prior information area for the operational nuclear submarine berths (which in this case are anchorages) in the Plymouth Sound South area, described as:

The combined area based on 1.5 km circular radii around 22 and 23 anchorages in Plymouth Sound and including the Plymouth Sound breakwater and the Plymouth Sound breakwater fort.

Map 3: Map of Devonport REPPIR off-site emergency planning and prior information area 2016 – Plymouth Sound South

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ANNEX C – PLYMOUTH OVERVIEW MAPS

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Map 4: Plymouth wider area map indicating distances from approximate centre of all relevant berths for the Devonport site and for Plymouth Sound14

14 Note: the radial areas shown are not the REPPIR off-site emergency planning areas for Devonport, the area shown have been used to bound the population data provided in Table 1 which in turn has informed ONRs determination.

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Map 5: Plymouth wider area showing REPPIR off-site emergency planning areas15

15 This map represents an overview of the Devonport REPPIR off-site emergency planning areas. The maps shown in Annex B represent ONR’s definitive definition of the Devonport REPPIR off-site emergency planning areas.

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