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 For published documents, the electronic copy on the ONR website remains the most current publicly available version and copying or printing renders this document uncontrolled. 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 Office for Nuclear Regulation Page i Report ONR-COP-PAR-16-012 TRIM Ref: 2015/121450 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. Office for Nuclear Regulation Page ii Report ONR-COP-PAR-16-012 TRIM Ref: 2015/121450 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.