Ministry of Defence JSP 518 Regulation of the Naval Nuclear Propulsion Programme Part 1: Directive JSP 518 Part 1 (V4.1 Jul 14) Foreword by Director Defence Safety & Environment Authority The Secretary of State for Defence (SofS) through his Health, Safety & Environmental Protection (HS&EP) Policy Statement requires each Top Level Budget Holder or Trading Fund Agency Chief Executive to be the Senior Duty Holder for the safety of defence activities conducted in his/her area of responsibility in addition to his/her wider HS&EP responsibilities. They are required to set down and implement HS&EP management arrangements for activities in their area of responsibility. The policy statement also requires there to be organisational separation between those who conduct defence activities and those who provide regulation, so that the latter are independent whilst being part of the Department. As Director Defence Safety & Environmental Authority (DSEA), I am responsible for providing defence regulatory regimes for HS&EP in the Land, Maritime, Nuclear and Ordnance domains where there are exemptions, derogations or dis-applications from legislation or where UK legislation does not apply. The regulations set out in this JSP are mandatory and full compliance is required. It is the responsibility of commanders and line managers at all levels to ensure that personnel, including contractors, involved in the management, supervision and conduct of defence activities are fully aware of their responsibilities. The Defence Nuclear Safety Regulator (DNSR-Head) is empowered to develop and promulgate the regulatory regime for the Defence Nuclear Programme and enforce these regulations. J C S Baker Director Defence Safety & Environment Authority Defence Authority for Health Safety & Environmental Protection July 2014 Foreword by Head, Defence Nuclear Safety Regulator The Defence Nuclear Programme (DNP) comprising the Naval Nuclear Propulsion Programme (NNPP) and the Nuclear Weapon Programme (NWP) of the Ministry of Defence is a fundamental component of the UK’s defence posture and has been so for many years. Those involved in these programmes, including contractors’ staff, have a duty of care to their workforces, the public and the environment. Nuclear and radiological safety and environmental protection are important, not only because of legal and moral responsibilities, but also because their effective management safeguards defence capability. DNSR has produced this Joint Services Publication (JSP 518) for the Regulation of the NNPP and JSP 538 for the NWP. Together they define and promulgate the nuclear regulatory regime (Part 1 - Policy, Requirements, Processes and Part 2 - Guidance) for the DNP. Those responsible for implementing these programmes are to comply with the requirements, and DNSR is tasked with regulating in accordance with this policy. Cdre Mike Robinson Head, Defence Nuclear Safety Regulator, DNSR Hd July 2014 i JSP 518 Part 1 (V4.1 Jul 14) Preface How to use this JSP 1. JSP 518 is intended as the primary source documentation describing independent Defence safety regulation of the Naval Nuclear Propulsion Programme. It is designed to be used by staff responsible for both the regulation of activities delivered by Duty Holders and the staff of the Duty Holders within the Defence Nuclear Programme. This JSP contains the policy and direction on nuclear safety regulation and guidance on the processes involved and best practice to apply. This JSP will be reviewed at least annually. 2. The JSP is structured in two parts: a. Part 1 - Directive, which provides the direction that must be followed in accordance with Statute, or Policy mandated by Defence or on Defence by Central Government. b. Part 2 - Guidance, which provides the guidance and best practice that will assist the user to comply with the Directive(s) detailed in Part 1. Related JSPs / Title: JSP 538 - Regulation of the Nuclear Weapon Programme JSP 471 - Defence Nuclear Emergency Response JSP 815 - Defence Health, Safety and Environmental Protection Coherence with other Defence Authority Policy and Guidance 3. Where applicable, this document contains links to other relevant JSPs, some of which may be published by different Defence Authorities. Where particular dependencies exist, these other Defence Authorities have been consulted in the formulation of the policy and guidance detailed in this publication. Training 4. Details of relevant training applicable to the DNP including safety regulation are identified in individual post specifications and/or terms of reference and the associated training plans developed against the Nuclear Competence Framework, published by the Head of the nuclear profession. Further Advice and Feedback- Contacts 5. The owner of this JSP is DSEA-DNSR. For further information on any aspect of this guide, or questions not answered within the subsequent sections, or to provide feedback on the content, contact: Job Title/E-mail: DNSR Nuclear Propulsion Regulator ([email protected]) Project focus: Nuclear Propulsion Regulation Phone: 03067932389 ii JSP 518 Part 1 (V4.1 Jul 14) Contents Preface...................................................................................................................... ii Contents................................................................................................................... iii 1 Introduction.................................................................................. 1 Structure, Purpose and Scope of the JSP............................................................ 1 Background and Outline Legal Framework for MOD Regulation of the............ 2 Naval Nuclear Propulsion Programme (NNPP) The Objectives of MOD Regulation of the NNPP................................................. 3 Authority and Delegations..................................................................................... 4 Regulation and Authorisation............................................................................... 4 The Defence Regulator.......................................................................................... 5 Figure 1 – Schematic of the Structure of JSP 518 and Regulatory Policy........ 2 Figure 2 – Diagrammatic Representation of NNPP Through-Life Responsibilities...... 10 2 Requirements.............................................................................. 11 Legislation.............................................................................................................. 11 Policy of the Secretary of State for Defence....................................................... 11 Nuclear & Radiological Safety and Environmental Protection MOD Regulatory Requirements.... 11 Security-Informed Nuclear Safety in the Defence Nuclear Programme (SINS). 14 Annex A: Legislation............................................................................................. 15 Annex B: MOD Authorisation Conditions........................................................... 23 Annex C: MOD Further Authorisation Conditions............................................. 62 Annex D: Special Nuclear Material Requirements............................................. 67 3 Regulatory Process and Activities............................................ 71 Introduction............................................................................................................ 71 Defence Safety & Environment Management Organisation................................ 71 Defence Nuclear Safety Regulator......................................................................... 71 Summary of Regulatory Activities......................................................................... 73 Authorisation........................................................................................................... 74 Intervention Strategies and Plans......................................................................... 74 Inspections.............................................................................................................. 75 Permissioning......................................................................................................... 76 Emergency Response Demonstration.................................................................. 77 Events (Incidents and Emergencies).................................................................... 78 Enforcement............................................................................................................ 80 DNSR Reports......................................................................................................... 82 Annex A: Specific Responsibilities from DNSR’S Letter of Delegation........... 83 Annex B: Regulatory Processes for Operational Berths................................... 85 Annex C: Regulatory Agreement to Criticality of Naval Reactor Plant............ 86 Glossary.................................................................................................................. 87 Abbreviations......................................................................................................... 96 iii-iv JSP 518 Part 1 (V4.1 Jul 14) Chapter 1 Introduction Structure, Purpose and Scope of the JSP 1. This JSP defines and promulgates the policy, requirements and guidance for nuclear and radiological safety and environmental protection management of Naval Nuclear Propulsion Programme (NNPP) activities. 2. The JSP is divided into two parts: Part 1, consisting of Chapters 1, 2 & 3, states regulatory requirements and Part 2 contains regulatory guidance. In the context of the ‘Hierarchy of Environment and Safety Publications’ set out in JSP 815 ‘Defence Environment and Safety Management’, Part 1 of this JSP is at ‘Level 2’, and Part 2 is at ‘Level 3’. 3. Where possible, detailed material in this JSP is presented in Annexes linked to the relevant text in the Chapters. 4. Chapter 1 gives the background to the MOD’s internal, non-prescriptive, goal-setting regulation of defence nuclear activities and the basis for that regulation. It explains briefly the objectives of MOD regulation, including the provision of assurance to senior levels of the Department. 5. Chapter 1 explains how and why regulation is based upon the Authorisation of operators to conduct defence nuclear activities during the life cycle of Naval Reactor Plant (NRP) which have an impact on nuclear and radiological safety. It explains why this Authorisation mirrors the licensing approach of the statutory regulator (Office for Nuclear Regulation, ONR). 6. Chapter 2 sets down the regulatory requirements for the Authorisation of operators for specific roles in the life cycle of the NRP. These are principally the Authorisation Conditions (AC), which mirror Licence Conditions (LC) applied by the statutory regulator. There are additional Defence Nuclear Safety Regulator (DNSR) requirements arising directly from the mobile nature of the NRP and the wider remit of DNSR. These are presented as Further Authorisation Conditions (FAC). 7. The AC are generally presented in phrases such as “the Authorisee shall make and implement arrangements for…” Such arrangements then form part of the Authorisee’s Compliance Statements against the AC (ACCS) against which they can be inspected. 8. Chapter 3 outlines the regulatory processes which DNSR uses to set requirements, agree Authorisees’ arrangements to meet those requirements, and monitor Authorisees’ adherence to those arrangements. This supports DNSR’s objectives to seek and provide assurance and permission activities. 9. Part 2 contains guidance to Authorisees, Accreditee, Duty Holders and DNSR staff. 10. Part 2 also provides guidance to DNSR staff to inform regulatory judgements when deciding whether to permission activities. This is principally done through the adoption of HSE Safety Assessment Principles (SAP) which, subject to occasional interpretation provided, DNSR considers are not inimical to the NNPP. 11. Subsidiary Guidance to Regulators is provided by the ONR in the form of Technical Assessment Guides (TAG). DNSR contributes to and adopts the ONR Safety Assessment Principles and Technical Assessment Guides, however where these documents do not address specific issues associated with the NWP and DNP then specific NWR Safety Assessment Principles (NWR SAP), Interpretation of SAP for NNP Application, and DNSR Technical Assessment Guides (DNSR TAG) are developed and published. 12. The structure of this document is shown diagrammatically in Figure 1. [Figure 1 – Schematic of the Structure of JSP 518 and Regulatory Policy: Part 1 (Level 2 JSP): Chapter 1 Introduction; Chapter 2 Requirements (Legislation, AC, FAC, SNMR); Chapter 3 Regulatory Processes and Activities. Part 2 (Level 3 JSP): Chapter 1 Authorisee and Duty Holder Guidance; Chapter 2 Guidance for DNSR Staff (HSE SAP with interpretation for use in the NNPP, Standard Statements, DNSR TAG).] Background and Outline Legal Framework for MOD Regulation of the Naval Nuclear Propulsion Programme 13. The Secretary of State (SofS) for Defence’s Policy Statement on Health, Safety and Environmental Protection (HS&EP) matters in Defence requires that: a. We minimise work related fatalities, injuries, ill-health and adverse effects on the environment, and we reduce health and safety risks so that they are as low as reasonably practicable (ALARP). b. Within the United Kingdom (UK) we comply with all applicable HS&EP legislation. c. Overseas we apply our UK arrangements where reasonably practicable and, in addition, respond to host nations’ relevant HS&EP expectations. d. Where Defence has exemptions, derogations or disapplications from HS&EP legislation, we maintain Departmental arrangements that produce outcomes that are, so far as reasonably practicable, at least as good as those required by UK legislation. 14. The fundamental requirement for regulation by DNSR of the DNP, and specifically the NNPP for JSP 518, derives from the fact that it is a defence programme performing operations and activities both in the UK and overseas with potential nuclear and radiological consequences, albeit with very low probability of occurrence, which have exemptions from particular UK legislation. 15. The primary national legislation under which nuclear sites are regulated is the Energy Act 2013 (TEA), the Health and Safety at Work etc. Act 1974 (HSWA), and the 1965 and 1969 Nuclear Installations Act (NIA). Part 3 of TEA, which covers nuclear regulation, came into force on 1st April 2014, and formally established the Office for Nuclear Regulation (ONR) as an independent regulatory body. ONR is the enforcing authority for TEA, HSWA and NIA for GB nuclear sites. Certain sections of the NIA are relevant statutory provisions of TEA, including NIA Section 1, under which ONR licenses operators of nuclear sites. This includes contractor-managed defence nuclear sites, but excludes sites under Crown control. 16. Relevant subsidiary legislation, from which the MOD is not exempt, comprises the Ionising Radiation Regulations, 1999, (IRR), and the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR). ONR regulates all MOD nuclear sites, both contractor operated and those under Crown control, and Nuclear Powered Warships (NPW) within UK territorial waters against this legislation. 17. Regulations governing the transport of radioactive material are based on standards developed by the International Atomic Energy Agency (IAEA). In the DNP, the transport of radioactive materials is regulated by DNSR. 18. The DNP is the beneficiary of a unique relationship with the United States of America which is formalised by the UK/US 1958 Agreement on the Uses of Atomic Energy for Mutual Defence Purposes and the 1963 Polaris Sales Agreement as amended for Trident. The nuclear reactor technology transferred under the 1958 agreement is used in the UK only for NPW propulsion. The Objectives of MOD Regulation of the NNPP 19. The primary objective of defence regulation of the NNPP is to assure that the SofS’s HS&EP policy is implemented whilst taking into account the mobility of the naval reactor plant. 20. Compared to a statutory nuclear regulator, DNSR has an additional factor to consider when judging the acceptability of the standards of nuclear safety and environmental protection achieved in the NNPP. This is to balance the potentially competing demands of nuclear safety and available submarine capability (including Continuous at Sea Deterrence (CASD)). This can be a factor in judgements on As Low As Reasonably Practicable (ALARP) arguments. DNSR’s regulatory stance will take account of this factor. 21. There have been occasions where factors relating to defence strategy (or ‘military imperative’) have formed part of a Duty Holder’s ALARP argument. Whilst DNSR has the discretion to take factors relating to strategic imperatives into account in decisions on permissioning, these cases are expected to be exceptional, and DNSR’s fundamental expectation is for a robust ALARP case to be made without recourse to such arguments. 22. A secondary objective of Defence regulation is to provide assurance to SofS that nuclear safety in the NNPP is, as far as is reasonably practicable, at least as good as that required by statute. 23. To achieve these objectives the MOD has appointed a Head of Defence Nuclear Safety Regulator (DNSR-Hd) and staff, collectively titled DNSR. Under DNSR-Hd, Nuclear Weapon Regulation is managed by the Nuclear Weapon Regulator and Deputy Head, DNSR-NWR, and Nuclear Propulsion Regulation is managed by the Nuclear Propulsion Regulator DNSR-NPR. Authority and Delegations 24. The SofS’s Policy Statement on HS&EP and JSP 815 makes clear that it is the responsibility of those charged with conducting defence activities to carry them out safely in accordance with the law and MOD requirements. It applies across Defence, both to activities conducted directly by MOD employees (which includes the Armed Forces) and those conducted by contractors. 25. The SofS for Defence formally delegates, via the Permanent Under Secretary (PUS), responsibility for conducting defence activities safely through the management structure of the MOD, and he separately charges PUS with oversight of the Department’s safety and environment management arrangements and the responsibility for Defence regulation of them. In respect of nuclear and radiological safety in the DNP, PUS requires the Director, Defence Safety and Environment Authority (D DSEA) to appoint (and be line manager for) the Regulator. This is DNSR-Hd, who is provided with a letter of delegation giving him authority, inter alia and in extremis, to require operations to cease within the DNP. This authority is further delegated to the DNSR-Nuclear Propulsion Regulator (DNSR-NPR) who reports to DNSR-Hd. The DNSR Deputy Head (DNSR-DepHd) also reports to DNSR-Hd. 26. D DSEA chairs the Defence Nuclear Regulation Stakeholder Committee (DNRSC), the senior regulatory forum considering nuclear and radiological safety in the DNP. D DSEA is a member of the Defence Environment and Safety Committee (DESC) which, as the senior Departmental committee for HS&EP chaired by PUS, provides both advice to PUS and support to SofS in the implementation of the Department’s safety and environmental protection strategy, objectives and targets. Regulation and Authorisation 27. Defence regulation follows from the empowerment of DNSR by letter of delegation from the appropriate authority (paragraph 25 above). It is in the interest of both the regulator and regulated (and above all in the interest of safety) that both work to agreed arrangements so that their interactions may be understood and harmonised. 28. A system of Authorisation has been determined as fundamental to DNP safety management arrangements. Authorisation is a system analogous to licensing under the NIA. The requirements are defined in 36 AC which are as far as possible identical to the 36 LC applied under statute to operators of nuclear installations. As required by DNSR’s regulatory responsibilities, 4 Further Authorisation Conditions (FAC) address issues unique to the DNP (e.g. the mobility of submarine and weapon). 29. The AC and FAC are applied to an operator responsible for managing the risk presented to the workforce, the public and the environment by the nuclear assets and activities under his managerial control and who is in day-to-day control of operations. In the NNPP, operators need the support of an Authorisee responsible for through-life safety to discharge their responsibilities for nuclear safety. 30. DNSR-Hd formally Authorises a NNPP operator designated as Authorisee, for particular activities associated with the NNPP, at the 1* post-holder level through the issue of an Authorisation Certificate. Authorisees are required to develop and maintain robust safety management systems consistent with the AC and additional requirements set out in Chapter 2 of this JSP. 31. One of the functions of the Naval Reactor Plant Authorisee (NRPA) is to act as the Approving Authority (AA) with responsibility for safety of the NRP across life cycle boundaries, and delivery of a Design Authority (DA) function for the plant; this is shown diagrammatically by the colour coding in Figure 2. 32. The responsibilities of the AA are outlined in the NRPA Certificate of Authorisation. Given the mobile nature of the NRP and the different organisations with responsibility at different phases of the plant’s life, these responsibilities are crucial for the delivery of adequate standards of safety. Therefore the AA is regulated with the same formality as those with direct responsibility for day-to-day safety on account of the contribution they make to NNPP safety. While the responsibility for the safe operation of the NRP rests with the Authorisee, DNSR expects that there is a formal relationship between all Authorisees and the AA and that the AA provides clear, authoritative and coherent advice and guidance to Authorisees. 33. The transport of radioactive material between sites is regulated in a slightly different manner, and is based on the internationally agreed approach defined in the IAEA Safety Standard ‘Regulations for the Safe Transport of Radioactive Material’. See Chapter 2 paras 11-14. The Defence Regulator Purpose, Vision and Mission 34. DNSR’s vision is “Nuclear capability which is demonstrably safe and available to meet Defence needs” and the purpose is described in the mission statement “To regulate the nuclear hazards of the Defence Nuclear Programme, as a trusted independent regulator in Defence”. DNSR regulates through the CADMID life cycle which in the NNPP covers all life cycle phases of UK NRP, associated Special Nuclear Materials and Research and Development (R&D) in support of naval nuclear reactors. DNSR-DepHd/NPR also contributes to the development of the safety objectives for the R&D programme. 35. In discharging his duties, DNSR-Hd: a. owns and maintains regulatory policy; b. gains assurance about safety and environmental protection by inspection and permissioning of activities, inspection of arrangements, review of safety justifications and assessment of emergency response exercises; c. provides information about safety and environmental protection by reports, including an annual report to PUS, about DNSR’s activities and conclusions; d. assures the SofS for Defence about nuclear safety and environmental protection in the DNP. Relationship with Other Regulators 36. DNSR liaises and works closely with other Defence Regulators grouped within DSEA with common interests. Principally these are the Defence Maritime Regulator (DMR) and the Defence Ordnance Munitions and Explosives Safety Regulator (DOSR). One aim is to align regulatory policy and processes and assessment effort for efficiency and to minimise impact on operators. However, the minimisation of risk of operation of platforms where multiple hazards are present is a more significant long term aim, facilitated by the formation of the DSEA. 37. The principal interface which DNSR has with any other regulator is with ONR. The MOD/HSE Agreement describes the overall working relationships 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-DepHd/NPR as the “Competent Authority” in respect of Naval Reactor Plant design and DNSR-DepHd/NPR provides ONR with any clarification it requires on hazards arising therefrom. ONR will not seek to influence naval reactor design. A ‘Letter of Understanding’ (LoU) between DNSR and ONR captures the working relationship. 38. ONR has its regulatory duties defined through statute while DNSR duties are founded on MOD policy partly in response to exemptions from statute and SofS’s wider responsibilities. ONR’s legal responsibilities require it to regulate compliance with regulations subordinate to HSWA from which there are no MOD exemptions. These include the Ionising Radiations Regulations (IRR) and the Radiation (Emergencies Preparedness & Public Information) Regulations. ONR does not regulate compliance with the Nuclear Installations Act (NIA) when MOD is in control. Authorisation covers the range of activities that are licensed, but also activities where exemptions apply. 39. The nuclear safety Duty Holder for submarines varies with life cycle phase. Authorisation seeks adequate arrangements to safeguard through-life nuclear safety and preserve design intent across the interfaces between the various Duty Holders in the NNPP. That apart, the aims, processes and techniques of Authorisation are akin to licensing. 40. Regulation of the DNP is most effectively achieved by DNSR and ONR operating a system that ensures complete and seamless oversight of all DNP activities. In some cases joint regulation occurs but generally ONR and DNSR gain assurance from the other’s activities. The DNSR/ONR relationship is formally monitored through routine bipartite meetings to monitor adherence to the spirit of the LoU. 41. The ONR process of regulation and enforcement against LC is mirrored by the DNSR process of Authorisation against AC. If an activity is both Licensed and Authorised, the same compliance statements should satisfy both regulators where the LC and AC are identical. Similarly the process of regulatory inspection of Licensee/Authorisee and the assessment of its safety documentation may be undertaken jointly by ONR and DNSR to ensure a common regulatory response and approach. 42. DNSR’s responsibility for the regulation of some radioactive discharges means that it also has interfaces with environmental regulators, the Environment Agency (EA) in England and the Scottish Environment Protection Agency (SEPA) in Scotland. DNSR is the sole regulator for: a. liquid and gaseous radioactive discharges while at sea; b. gaseous radioactive discharges while the NPW is alongside. 43. In keeping with SoS’s policy declaration of equivalence with civil standards where reasonably practicable, DNSR regulates these discharges in keeping with the principles applied by the environmental regulators, and agrees appropriate levels with the EA/SEPA. 44. The safety management arrangements for liquid discharges alongside NNPP sites and berths are regulated by ONR, with DNSR assistance, under the auspices of the IRR, and any subsequent environmental discharges are regulated directly by the appropriate environmental agencies. The respective regulatory responsibilities may be summarised as follows: a. Radioactive discharges from defence-related Licensed sites and MOD Authorised sites: (1) the discharges are regulated by EA/SEPA. (NB The discharges may include radioactive material originating on-board NPWs and transferred ashore for processing); (2) EA/SEPA also regulate the associated radioactive waste management arrangements from an environmental protection perspective; (3) For Authorised sites, DNSR regulates the associated radioactive waste management arrangements from a nuclear safety perspective; (4) ONR regulates the associated radioactive waste management arrangements from a health and safety perspective in line with ONR guidance and Joint Guidance shared by EA, SEPA and ONR. b. Radioactive discharges from NPWs directly to the environment: (1) the discharges (comprising gaseous discharges alongside and liquid and gaseous discharges at sea) and the associated radioactive waste management arrangements from both environmental protection and nuclear safety perspectives are regulated by DNSR; (2) in keeping with SofS’s policy commitment so far as reasonably practicable to operate to standards equivalent to those applied by the civil regulators, this DNSR regulation is in accordance with the regulatory principles adopted by EA/SEPA and DNSR liaises closely with the civil regulators on their application; (3) ONR regulates the associated radioactive waste management arrangements from a health and safety perspective, principally in accordance with IRR99 requirements. 45. The relationship between DNSR and EA/SEPA is one of interfaces; there is not the same overlap of responsibilities as with ONR. It should be noted that: a. the environmental regulators operate a more prescriptive regime based on limits than the nuclear safety regulators, though legally, the ALARP requirement applies to environmental discharges as well as nuclear safety; b. NNPP discharges, both from shore establishments and from NPWs, are very small in absolute and relative (to nuclear industry generally) terms. 46. DNSR is the Competent Authority for transport packages in the DNP and interfaces as necessary with ONR’s Radioactive Materials Transport Team, the Department for Transport (DfT), and other government departments. Regulatory Requirements 47. DNSR owns, sets and maintains regulatory requirements for the management of nuclear and radiological safety and environmental protection in the NNPP. Part 1, Chapter 2 of this JSP sets out the requirements and Part 2 includes related guidance. Regulatory Processes 48. The principal processes which DNSR employs to achieve regulation are similar to those employed by the statutory nuclear regulator such as: a. Authorisation – equivalent to licensing; b. Inspections; c. Assessment (of arrangements, safety documentation etc.); d. Permissioning (of activities with implications for present and future nuclear safety). 49. DNSR Inspections to verify Authorisee and Duty Holder adherence to ACCS are the principal activity of the DNSR Inspectors. Assessments are carried out on a sampling basis taking account of (for example): a. the level of nuclear hazard presented by the issue to be assessed; b. the level and independence of assessment effected by the Authorisee’s Internal Safety Authority and made available to DNSR. 50. Regulatory control over activities deemed to have a significant nuclear safety implication is effected by imposing regulatory hold-points. Progression beyond these points, be they project stages, continued plant operation, or maintenance activities (for example) then requires DNSR permission; permissioning is then the DNSR process to apply leverage to Authorisees and Duty Holders. Mature Authorisees with strong internal safety management which impose their own hold-points will be subject to fewer, or combined, regulatory hold-points. 51. DNSR Inspectors maintain a routine relationship with operators and Duty Holders based on protocols between DNSR and the relevant manager(s). DNSR-DepHd/NPR produces a programme level intervention strategy for each regulated area from which DNSR Inspectors produce an intervention strategy and plans for each Authorisee. These include inspection and assessment programmes covering all activities to gain the necessary assurance for permissioning of activities (where this form of regulatory leverage is applied). These programmes cover: a. inspection of activities and arrangements – inspectors may wish to see how procedures are applied in practice and to verify compliance with regulatory requirements (e.g. AC); b. review of nuclear safety justifications (guided by SAP) - to enable activities to be permissioned; c. assessment of emergency response exercises – to examine the effectiveness of emergency arrangements in a dynamic environment. 52. In the event of an accident in the NNPP, DNSR-Hd becomes Head of the Safety Cell within the HQ Nuclear Emergency Response Organisation in London. 53. Part 1, Chapter 3 of this JSP sets out the related processes in more detail and Part 2 provides common guidance. Regulatory Expectations 54. This JSP sets out requirements and guidance against which to judge the acceptability of all activities within the NNPP with respect to nuclear and radiological safety and environmental protection. It requires each Authorisee to provide and maintain written justifications addressing the safety of activities conducted with NRP within their area of the NNPP, and the AA to provide and maintain intrinsic safety justifications for NRP. DNSR expects safety justifications to be developed, to be comprehensive in scope, to be of a standard equivalent to industry good practice, and to provide a depth of analysis appropriate to the risks. In accordance with HSWA, DNSR expects it to be clearly demonstrated that the risks to health from any DNP activity have been reduced so far as is reasonably practicable. The purpose of the DNP, the nature of defence operations and equipment and the potential that (for example) nuclear and maritime safety priorities may be different, are recognised to be factored into such demonstrations. 55. DNSR does not seek to be prescriptive about the construction of management arrangements or safety justifications provided their coverage is fit for purpose. Comprehensive written Compliance Statements are expected to be produced and maintained to justify Authorisation or Accreditation (e.g. as Duty Holder or DA) status. DNSR may exercise discretion in determining the acceptability of activities within the NNPP with respect to nuclear and radiological safety and environmental protection. 56. DNSR endorses the long-standing Defence position (which mirrors that of the statutory regulator) that Authorisees, with the support of the Department, should maintain a comprehensive capability to respond to NNPP emergencies, even where assessments may show that such emergencies are highly unlikely. This approach takes account of the societal concerns associated with a nuclear emergency within the NNPP. Authorisees must maintain a nuclear emergency response capability and periodically demonstrate its adequacy. 57. DNSR places considerable emphasis on seeking assurance that Authorisees, the AA and Duty Holders have a robust internal challenge capability. DNSR expects the provision of a proportionate internal regulator and/or assurance function with appropriate skills and resources, which undertakes meaningful compliance inspections. [Figure 2 – Diagrammatic Representation of NNPP Through-Life Responsibilities: Mapping through Shore Support Facility Life Cycle (Concept & Feasibility PSR, Design PCSR, Manufacture & Construction PCMSR, Commission POSR, In Service, Decom) and Submarine Build / Operational Support / Refit / Decommissioning phases under Naval Reactor Plant Approving Authority, Site Licensees, and Site Authorisees.] Chapter 2 Requirements Legislation 1. The law of the United Kingdom applies to the Defence Nuclear Programme (DNP) and is to be complied with; it is the Duty Holder’s responsibility to determine applicable legal requirements. Principal legislation relating to nuclear and radiological safety (indicating exemptions, disapplications or derogations relating to the Defence Nuclear Programme) is listed in Annex A. A fundamental feature of UK law (as required by the Health and Safety at Work etc Act 1974 (HSWA)) is that risk to the workforce and the public is to be reduced So Far As Is Reasonably Practicable (SFAIRP also expressed as “As Low As Reasonably Practicable” ALARP). Policy of the Secretary of State for Defence 2. The Secretary of State (SofS) for Defence’s Policy Statement on Health, Safety and Environmental Protection (HS&EP) matters in Defence requires that: a. We minimise work related fatalities, injuries, ill-health and adverse effects on the environment, and we reduce health and safety risks so that they are as low as reasonably practicable (ALARP). b. Within the United Kingdom (UK) we comply with all applicable HS&EP legislation. c. Overseas we apply our UK arrangements where reasonably practicable and, in addition, respond to host nations’ relevant HS&EP expectations. d. Where Defence has exemptions, derogations or disapplications from HS&EP legislation, we maintain Departmental arrangements that produce outcomes that are, so far as reasonably practicable, at least as good as those required by UK legislation. 3. In the policy statement SofS requires the Permanent Under Secretary to ensure that responsibility for health, safety and environmental protection aligns with the mandates of top-level budget (TLB) holders to manage defence activities in their delegated areas. TLB holders with responsibilities for delivery of the DNP are Fleet Commander (for Navy Command) and Chief of Defence Materiel (for Defence Equipment and Support (DE&S)). In DE&S at senior level the responsible managers are Chief of Materiel (Fleet) and Director Submarines. TLB holders are further identified as Senior Duty Holders to provide specific accountability on the management of risk to life from activities in their area of responsibility, appointing Operating and Delivery Duty Holders as appropriate. 4. JSP 815 requires that those responsible for defence capability development including the expected future commanding officers or managers are to address HS&EP factors from the earliest stages. Thus a Duty Holder, Authorisee or Accreditee within the DNP is to engage as appropriate with DNSR as early as possible noting that the DNSR view may be sought during the investment scrutiny process. Nuclear and Radiological Safety and Environmental Protection MOD Regulatory Requirements Introduction 5. The Nuclear Installations Act 1965 is the principal legislation governing the use of a site for nuclear activities. Under the Act, before conducting nuclear activities, the operator of a site must be granted a licence by the Office for Nuclear Regulation (ONR); this is subject to management arrangements being made to satisfy 36 Licence Conditions (LC). A similar process, called Authorisation, is applied in the DNP where an otherwise licensable activity is exempt. In addition to nuclear activities on a site, this has to accommodate the mobility of the nuclear powered (and armed) warships whilst operated at sea (which includes operational berths) and the transport of nuclear weapons between sites. It is also to include the discharge of radioactive materials to the environment where this is exempted. An Authorisation Certificate is provided defining the scope of activities Authorised. Both licensing and Authorisation are non-prescriptive, permissioning regulatory regimes suitable for high hazard activities. Authorisation 6. Authorisation Conditions (AC) for the DNP are stated in Annex B; these mirror LC. Specific attributes of the DNP (e.g. the organisational structures and the mobility of naval reactor plant and nuclear weapons) and the remit of DNSR (e.g. encompassing environmental protection and transport) require conditions in addition to those of LC. Four Further Authorisation Conditions (FAC) are stated in Annex C. 7. Authorisees are to make and implement management arrangements that satisfy the safety requirements of each relevant AC and FAC, and are to maintain a compliance statement for each Condition outlining how their arrangements meet the requirements. Authorisees are responsible for managing the risk that the nuclear assets under their control present to the workforce, the public and the environment. Authorisees are to demonstrate day-to-day control of activities for which they are responsible. If an Authorisee is to cease conducting Authorised activities, a process leading to removal of Authorisation is to be undertaken by consultation between the Authorisee and DNSR. 8. Authorisees in the DNP are detailed in Table 1: Table 1 – Authorisees in the Defence Nuclear Programme: - Construction and first commissioning of Naval Reactor Plant: MD/BAE Systems Maritime Submarines, Barrow (NNPP) - R&D, manufacture, assembly/disassembly of nuclear weapons: MD/Atomic Weapons Establishment plc (NWP) - Testing of naval reactor plant: Naval Superintendent, NRTE Vulcan (NNPP) - Logistic transport of nuclear weapons: Head of Strategic Weapons Project Team (NWP) - Naval base support and maintenance: Naval Base Commander, Clyde & Naval Base Commander, Devonport (NNPP); Naval Base Commander, Clyde (NWP) - Deep maintenance (including refuelling) of naval reactor plant: MD Submarines/Devonport Royal Dockyard Limited (NNPP) - Operations at sea and alongside operational berths outwith Authorised sites: Head of Nuclear Propulsion (NNPP); Chief Strategic Systems Executive (NWP) Design and Approval 9. The designers of Naval Reactor Plant and nuclear weapons, and those who approve them for use, are to ensure that they, and information supplied about them, are fit-for-purpose and facilitate safe conduct of activities by the Authorisees. Authorisees are to provide assurance to the approvers and designers about the conduct of activities with Naval Reactor Plant and nuclear weapons so that knowledge about their condition is maintained. 10. The Approving Authority (AA) for Naval Reactor Plant is Head of Nuclear Propulsion (NP-Hd); the scope of Authorisation encompasses NP-Hd’s role as AA. This rôle also carries the requirement to specify and manage R&D in support of maintaining safe operation of the NRP, and gaining assurance of the quality of components in the plant to support the requirements of the safety justifications. Transport of Radioactive Material Transport of Radioactive Material (RAM) between Sites 11. All Duty Holders with responsibilities associated with the transport of radioactive material between sites are to comply with legislation and except where explicitly agreed with DNSR are to: a. Comply with UK law as if no ‘defence exemption’ applied, with the exception that where legislation incorporates an edition of the IAEA Regulations for the Safe Transport of Radioactive Material which is earlier than the current edition then the current edition of the IAEA Regulations may be substituted. b. Comply with any requirements of DNSR as the DNP Competent Authority. 12. UK Duty Holders with responsibilities associated with the transport of Special Nuclear Material (SNM) in the DNP external to Licensed or Authorised sites are to comply with the ‘SNM Requirements’ (SNMR) listed in Annex D to Chapter 2 as part of their management arrangements for safety, and to comply with FAC4 of Annex C to Chapter 2. 13. Where a UK Civil Competent Authority has issued a ‘national derogation’ from the requirements of legislation (in practice usually EU legislation) for civil RAM transport then, unless DNSR explicitly advises otherwise, that derogation is deemed to apply to equivalent DNP RAM transport operations. 14. Where ONR has issued ‘a consent’ for a DNP RAM shipment to a civil site and copy of that consent is provided to DNSR then, unless DNSR explicitly advises otherwise, an equivalent DNSR consent is deemed to have been issued. On Site Transport of Radioactive Material 15. Where the transport of RAM within a site is carried out in a manner that is compliant with the requirements for off site transport, then DNSR will normally accept that process as being adequately safe without additional evidence. Where on site transport of RAM is managed in a different manner the arrangements shall provide an ALARP demonstration and shall be justified in an appropriate site safety case. Guidance 16. Guidance on interpretation of and compliance with regulatory requirements is provided in Part 2 of this JSP. Security–Informed Nuclear Safety in the Defence Nuclear Programme (SINS) 17. In the 2006 revision of the HSE Safety Assessment Principles used by both ONR and DNSR, the class of external hazards was expanded to include “malicious acts” for the first time, recognising that the consequences of such acts could harm the workforce or the public through the release of radioactive material. In the civil programmes, the safety and security regulators have worked together to amplify their expectations of Licensees’ approach. Within the DNP the intent to commence a similar process was identified in a joint DNSR/ONR letter in January 2012 to all Authorisees/Licensees in the DNP. DNSR will expect to find appropriate considerations in safety submissions which address malicious acts as part of the normal Periodic Review of Safety (AC/LC15 arrangements) for existing facilities. Similar considerations will be required in the design of new facilities, equipment and any future reactor or reactor modification programme. In addition, against the background of SINs, DNSR will continue to develop a mutually constructive relationship with the defence security organisations to provide a joined up response to the Authorisees to ensure safety and security requirements are not considered in isolation. Annex A to Chapter 2: Legislation Introduction 1. A comprehensive framework of legislation exists to ensure that the UK’s civil nuclear programme and DNP achieve acceptable standards of safety and environmental protection. 2. Activities within the DNP generally work within this legislative framework, but are subject to a number of exemptions, disapplications or derogations which take account of the purpose and objectives of the MOD (principally the available capability) and the physical environment in which the DNP operate. The following paragraphs provide an overview of the principal legislation applicable to nuclear and radiation safety and environmental protection in UK and British Overseas Territories. The general application of the legislation to DNP is described and the regulating authority is identified. Nothing in this Annex affects the responsibility of an Authorisee, Approving and Design Authority, or other Duty Holder for complying with applicable legislation. International Framework 3. Nuclear safety is the subject of international co-operation and agreement through such bodies as the International Atomic Energy Agency (IAEA), the Organisation for Economic Co-operation and Development (OECD) and the International Commission for Radiological Protection (ICRP). It is also a major element of European Union (EU) policy, and is addressed in particular within the EURATOM Treaty which imposes requirements on the way in which member states conduct activities involving nuclear and radiological hazards. 4. Although it is the UK Government’s position that the EURATOM Treaty does not apply to military activities, legislation emanating from EURATOM which is incorporated into national law under UK Acts of Parliament is applicable unless a Defence exemption is included in the legislation. 5. In the framework of the Treaties establishing the European Union, EU law may take the following forms: a. EU Legislation. This is applicable and binding on all Member States: (1) Directives. (e.g. Directive 96/29/EURATOM - Basic Safety Standards Directive); (2) Regulations. (e.g. Council Regulations (Euratom) 3954/87 and 2218/89); (3) Decisions. Binding on addressees; b. EU Recommendations, Opinions – not binding. Legal Framework in the UK 6-8. Legislation provides the fundamental basis of safety practice. SofS for Defence may, in the interests of national security, by a certificate in writing, exempt certain defence activities and premises from the requirements of certain Regulations. Relevant Legislation – Health and Safety - European Communities Act 1972 (ECA) - Health and Safety at Work etc Act 1974 (HSWA): No general Crown exemption. - The Energy Act 2013 (TEA): Established ONR on 1st April 2014. - Nuclear Installations Act 1965 and 1969 (NIA): Restricts operation to licensed bodies; Crown is generally exempt under Section 9, but DNSR regulates MOD Duty Holders with equivalent provisions. - Atomic Weapons Establishment Act 1991 Amendment Order 1997 - Ionising Radiations Regulations 1999 (IRR99): Applicable to MOD; foreign visiting NPWs exempted by SofS. - Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR): Regulated by ONR; DNSR acts as Competent Authority for design info. - The Justification of Practices Involving Ionising Radiation Regulations 2004 - Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (amended 2011): Regulated by DNSR for defence nuclear material. Relevant Legislation – Environmental Protection - Environmental Permitting (England and Wales) Regulations 2010 (EPR10), and Radioactive Substances Act 1993 (RSA93) - High Activity Sealed Radioactive Sources and Orphan Sources Regulations 2005 (HASS) - Nuclear Reactor (Environmental Impact Assessment of Decommissioning) Regulations 1999, amended 2006 (NR(EIAD)R) Relevant Legislation – Visiting Forces - Visiting Forces Act 1952, IRR99 exemptions, and REPPIR exemptions. Overseas - Gibraltar (BOT) legislation: IRR 2004 and Gibraltar REPPIR 2004. Contracted Support & Intelligent Customer 36-39. MOD retains ultimate responsibility and must retain sufficient 'intelligent customer' capability to act as the 'Controlling Mind' to assert that nuclear risks are ALARP throughout the lifecycle. Annex B to Chapter 2: MOD Authorisation Conditions (AC1 - AC36) AC1 Interpretation: Definitions of key terms (Agreement, Approval, Authorised site, Authorisee, commissioning, Consent, Direction, DNSR, excepted matter, experiment, installation, modification, Notification, nuclear matter, nuclear safety committee, operations, radioactive material, safety case, Specification, etc.). AC2 Marking of the Site Boundary: Arrangements to prevent unauthorised entry, erect/maintain boundary fences. AC3 Restriction on Dealing with the Site: No conveyance, assignment, transfer, or letting of the site without DNSR consent. AC4 Restrictions on Nuclear Matter on the Site: Arrangements to control entry and storage of nuclear matter; consent required for new installations. AC5 Consignment of Nuclear Matter: No consignment off-site except to relevant sites or with DNSR consent; preservation of records for 30 years (50 years if lost/stolen). AC6 Documents, Records, Authorities and Certificates: Maintenance and 30-year preservation of safety compliance records. AC7 Incidents on the Site: Arrangements for notification, recording, investigation, and reporting of incidents. AC8 Warning Notices: Display of notices for warning signals, emergency exits, and fire/emergency actions. AC9 Instructions to Persons on the Site: Ensuring all persons on site receive adequate instruction on risks, hazards, and precautions. AC10 Training: Arrangements for suitable training of all personnel whose responsibilities affect safety. AC11 Emergency Arrangements: Adequate arrangements to respond to site accidents/emergencies, consultation with local authorities, periodic rehearsals/exercises. AC12 Duly Authorised and Other Suitably Qualified and Experienced Persons: Appointment of SQEP and DAPs; DNSR power of veto. AC13 Nuclear Safety Committee: Establishment of a senior advisory committee (minimum 7 members, at least 5 present including 1 independent) to consider safety matters. AC14 Safety Documentation: Production and assessment of safety cases justifying design, construction, commissioning, operation, and decommissioning. AC15 Periodic Review: Systematic review and reassessment of safety cases (approximately every 10 years). AC16 Site Plans, Designs and Specifications: Maintenance of updated site plans and building/plant schedules submitted to DNSR. AC17 Management Systems: Implementation of management systems and quality management arrangements giving due priority to safety. AC18 Radiological Protection: Assessment of average effective dose and notification to DNSR if specified dose levels are exceeded. AC19 Construction or Installation of New Plant: Arrangements and stage-by-stage control/hold-points for new plant construction. AC20 Modification to Design of Plant Under Construction: Categorisation and control of design modifications during construction. AC21 Commissioning: Staged inactive and active commissioning arrangements, test records, pre-operational safety cases, and DNSR consent. AC22 Modification or Experiment on Existing Plant: Safety classification, staged control, and justification of plant modifications and experiments. AC23 Operating Rules: Production of safety cases defining conditions and limits of safe operation (operating rules) and compliance oversight. AC24 Operating Instructions: Implementation of written step-by-step operating instructions derived from safety cases. AC25 Operational Records: Detailed records of plant operation, inspection, maintenance, and radioactive material/waste inventories. AC26 Control and Supervision of Operations: Ensuring safety-affecting operations are supervised by appointed SQEP. AC27 Safety Mechanisms, Devices and Circuits: Ensuring sufficient protective systems and circuits are connected and in good working order. AC28 Examination, Inspection, Maintenance and Testing (EIMT): Plant maintenance schedules, written schemes, and qualified personnel for maintenance. AC29 Duty to Carry Out Tests, Inspections and Examinations: Carrying out additional tests or examinations as specified by DNSR. AC30 Periodic Shutdown: Shutting down plant for scheduled maintenance/inspection, restart subject to DNSR consent if specified. AC31 Shutdown of Specified Operations: Compliance with DNSR directions to shut down operations; restart requires DNSR consent. AC32 Accumulation of Radioactive Waste: Minimising production/accumulation of radioactive waste and maintaining records. AC33 Disposal of Radioactive Waste: Compliance with DNSR direction for disposal in accordance with statutory/environmental authorizations. AC34 Leakage and Escape of Radioactive Material and Radioactive Waste: Control and containment to prevent leaks; leak detection and reporting. AC35 Decommissioning: Arrangements and staged programmes for safe decommissioning of plant and facilities. AC36 Organisational Capability: Maintaining adequate financial and human resources; controlling organisational changes affecting safety. Annex C to Chapter 2: MOD Further Authorisation Conditions (FAC1 - FAC4) FAC1 Duty of Co-operation: (1) The Authorisee shall make and implement adequate arrangements to co-operate with other Authorisees and maintain coherent management arrangements. (2) Co-operate with Approving Authorities / Design Authorities for naval reactor plant and/or nuclear weapons. (3) Co-operate with external/internal organisations for safety activities. (4-5) Submit arrangements to DNSR for approval. FAC2 Operational Berths: (1-4) Adequate arrangements for using operational berths outside Authorised sites (including overseas) by Nuclear Powered Warships (NPW); requires DNSR consent before use. FAC3 Radioactive Discharges: (1-7) Arrangements to minimise and control radioactive discharges to the environment, record discharge data, furnish info to DNSR, and seek DNSR consent if directed. FAC4 Transport Packages: (1-5) Ensuring radioactive material transport outside an Authorised site uses appropriate packages; CA package approval by DNSR where specified. Annex D to Chapter 2: Special Nuclear Material Requirements (SNMR 1 - 11) - SNMR1 Organisational Capability: Provide and maintain necessary personnel and resources (aligned with SSR-6 para 306, ADR 1.7.3, AC17, AC36). - SNMR2 Training: Ensure transport personnel receive appropriate training (SSR-6 paras 311-315, ADR 1.3/1.7.2.5/8.2, AC10). - SNMR3 Packaging: Obtain assurance of proper packaging for specific contents (SSR-6 paras 421-433, ADR 4.1.9, AC26, FAC4). - SNMR4 Documentation: Retain certificates of approval, handling instructions, and transport records (SSR-6 paras 546-556, ADR 5.4, CDG Regs, AC6). - SNMR5 Operating Procedures: Preparation, marking, labelling, and transport index determination (SSR-6, ADR, AC23, AC24). - SNMR6 Monitoring: Provide calibrated instruments to monitor radiation and contamination (SSR-6, ADR, AC28). - SNMR7 Consignment: Shipping documents, placarding, vehicle segregation, and Competent Authority notification (SSR-6, ADR, AC5). - SNMR8 Radiological Protection: Establish Radiation Protection Programme for transport (SSR-6 paras 301-303, ADR 1.7.2, AC18). - SNMR9 Non Compliance: Procedures to respond to, investigate, and report non-compliance (SSR-6 para 309, ADR 1.7.6, AC7). - SNMR10 Emergency Arrangements: Maintain and exercise transport emergency response arrangements (SSR-6 paras 304-305, CDG Regs, AC11). - SNMR11 Security: Prevent unauthorised access to SNM (SSR-6 para 109, ADR 1.10.1.1, AC2). Chapter 3 Regulatory Processes and Activities Introduction & Departmental Arrangements 1-3. DNSR delivers regulation where statutory regulation is exempt. D DSEA delegates authority to DNSR-Hd and chairs the Defence Nuclear Regulation Stakeholder Committee (DNRSC). Defence Nuclear Safety Regulator Organisation 4-7. DNSR-Hd delegates regulatory authority to DNSR-NPR (Naval Propulsion) and DNSR-DepHd/NWR (Nuclear Weapons), supported by Principal Inspectors and Inspectors. Consultants & Interaction with Other Regulators 8-10. Support from AMEC (RSD), DSTL, DCMT, INM. Close working relationships with ONR (via General Agreement & LoU), EA, SEPA, DMR, DOSR. Summary of Regulatory Activities 11-15. Regulatory policy development via DNRF and RPC. Six core processes: Authorisation Certificate, Intervention Strategies/Plans, Inspections, Safety Assessments/Permissioning, Emergency Response Exercises, and Event Response. Authorisation, IS/IP, and Inspections 16-29. 3-4 year Intervention Strategies (IS) and annual Intervention Plans (IP). Inspection types: Routine, Permissioning, Themed, Reactive, Large Scale, and Authorisation Inspections. Permissioning & Safety Justifications 30-36. Direct and secondary powers to permission activities via Consents, Approvals, and Agreements. Scrutiny against SAPs, TAGs, and ALARP principles. Transport & Emergency Demonstrations 37-40. Package approval as Defence CA; periodic assessment of live demonstration exercises against REPPIR and JSP 471. Events & Investigations 41-48. Reporting of incidents under AC7; investigations; adaptation during Defence Nuclear Emergency via HQ NERO (DNSR-Hd as Head of Safety Cell). Enforcement 49-57. Graduated enforcement ladder: Observations (good/bad practice, no formal response), Findings (formal response required), Safety Improvement Notices (SIN), Immediate Safety Requirements (ISR - AC31 shutdown), and arbitration/escalation. DNSR Reports 58-61. Visit Records, Quarterly Reports (provided to Local Liaison Committees), and formal DNSR Annual Report to PUS, DNEB, and DNSC. Annex A to Chapter 3: Specific Responsibilities from DNSR’s Letter of Delegation 1. Details 13 specific regulator duties (a to m): influence safety legislation; influence MoD policy; develop domain regulatory regimes; inspect and audit; issue authorisations/permissions; enforce standards; investigate incidents; issue guidance; promote safety culture; contribute to annual DSEA report; alert Director DSEA of serious issues; foster peer relationships with statutory regulators and foreign authorities. Annex B to Chapter 3: Regulatory Processes for Operational Berths 1-8. Berths outside Authorised sites are de facto temporary nuclear sites. Details regulatory oversight division (UK, Gibraltar, BOT, Foreign) across Management Arrangements, Safety Submissions, REPPIR determinations, and Emergency Arrangements. Annex C to Chapter 3: Regulatory Agreement to Criticality of Naval Reactor Plant 1-5. Requires regulatory agreement prior to NRPA issuing Authorisation to Operate (AtO). Staged regulatory approval for Power Range Testing (PRT) and fleet operation (AtO(Fleet)), plus controls over emergent issues and hold points. GLOSSARY: Definitions provided for: Accident, Accreditation, Accreditation Certificate, Accreditee, Agreement, ALARP, Approval, Approve, Approving and Design Authority, Approving and Design Authorities Conditions, Assurance, Audit, Authorisation, Authorisation Certificate, Authorisation Conditions, Authorised Site, Authorisee, Authority, Barrier, Broadly Acceptable, Cause, Commissioning, Competence, Compliance Statement, Consent, Consequence, Constraint, Decommissioning, Defence, Defence Nuclear Material, Defence Nuclear Programme (DNP), Defence Safety and Environmental Authority (DSEA), Design Authority, Design Intent, Design Organisation, Direction, Diversity, Dose, Duly Authorised Persons (DAP), Duty Holder, Effective Dose, Emergency Arrangements, Emergency Plan, Endorse, Environment, Event, External Hazard, Facility, Fissile Material, Further Authorisation Conditions, Hazard, Hold Point, Incident, Independent Nuclear Safety Assessment (INSA), Independent Peer Review (IPR), Individual Risk, Initiating Event, Inspection, Intelligent Customer, Internal Hazard, Joined-up Regulation, Licensed Site, Licensee, Management Arrangements, Modification, Naval Reactor Plant, Naval Reactor Plant Authorisee (NRPA), Normal Operation, Note, Notification, Nuclear Emergency, Nuclear Matter, Nuclear Safety, Nuclear Safety Related, Nuclear Steam Raising Plant, Nuclear Weapon (NW), Nuclear Weapon System, Operating Instructions, Operating Organisation, Operating Rules, Operational Berth, Operation(s), Periodic Review of Safety, Permissioning, Radiation Emergency, Radiation Safety, Radioactive Material, Radioactive Substance, Radioactive Waste, Reactor Accident, Redundancy, Risk, Risk Assessment, Safety Case, Safety Category, Safety Clearance Letter, Safety Criteria, Safety Principle, Safety System, Site Safety Case, Special Nuclear Material, Specification, Suitably Qualified and Experienced Persons (SQEP), Target, Transport, Unacceptable, Utility. ABBREVIATIONS: Lists over 70 acronyms including AA, AC, ADA, ADAC, AF&F, ALARP, ASND, AWE, BR, BSL, BSO, CASD, CBA, CLOSO, CSSE, DA, DAP, DBA, DfT, DMR, DNESB, DNM, DNP, DNRF, DNRSC, DNSC, DNSR, DO, DOSR, DRDL, DSTL, DSEA, EA, EAC, ECCS, EIMT, EOP, EPR, ESDA, EU, FAC, GoG, HASS, HAZID, HIRE, HMNB, HS&EP, HSE, HSWA, IAEA, ICRP, IM, INES, INSA, IoF, IP, IRR, IS, ISR, JSP, LC, LCP, LLC, LOCA, LOD, MAA, MOD, MPS, NEBUST, NBC, NIA, NNPP, NPR, NPW, NR(EIAD)R, NRP, NRPA, NRTE, NRW, NSC, NT, NW, NW ADA, NWP, NWR, NW SPSC, OB, OECD, ONR, PRS, PLEX, PRT, PSA, PSI, PUS, QA, RA, RAM, R&D, REPPIR, RPC, RPV, RSA, RSD, SAP, SEPA, SFAIRP, SFC, SI, SIN, SINS, SJ, SMDC, SNM, SNMR, SofS, SOL, SPS, SPSC, SQEP, SSC, Sv, SW PT, TAG, TEA, WH.