Health and Safety
Executive / Commission
Nuclear
LLC reports
This report is issued as part of the Health and Safety Executive's commitment to make information about inspection and regulatory activities relating to the above site available to the public. It is for distribution to members of the Devonport Local Liaison Committee and covers activities associated with the regulation of safety at Devonport Royal Dockyard and HM Naval Base.
The Site Inspector of HM Nuclear Installations Inspectorate (part of the Health and Safety Executive’s Nuclear Directorate) attends LLC meetings and will be happy to respond to any questions raised there by members. Any other person wishing to inquire about matters covered by this report should contact the HSE’s, Nuclear Safety Directorate on 0151-951-4103.
Inspections on site were made on the following days:
2 – 3 October
7 - 11 October
28 - 31 October
4 – 8 November
11 – 14 November
27 – 28 November
2 - 6 December
16 – 18 December
A total of 15 NII Inspectors along with the FOD inspectors from the Plymouth office visited site during the quarter spending a total of 80 days on site. Joint inspections were carried out with inspectors from the Ministry of Defence internal regulatory organisation, Naval Nuclear Regulatory Panel, NNRP.
Inspections are undertaken for the purposes of monitoring compliance with the conditions attached by HSE to the nuclear site licence, together with other relevant statutory provisions of the Health and Safety at Work etc. Act (1974).
During this period, inspections have continued to be focused on activities associated with the readiness inspections of 9 Dock in anticipation of refuelling activities planned for HMS Vanguard commencing later in 2002 and early 2003, preparation for the defuelling of HMS Valiant, operations in the Submarine Refit Complex or generally for activities across the site. Particular attention has been paid to compliance by the licensee with licence condition 11, (relating to arrangements for dealing with any accident or emergency arising on the site), 21, (relating to the commissioning of plant or process which may affect safety), 23, (the requirement to have an adequate safety case and such operating rules as this calls for), 24, (the requirement to carry out safety related activities in accordance with written instructions), 26, (the control and supervision of specified activities), 27, (relating to the availability of safety mechanisms) 28, (the requirement for maintenance arrangements), 36, (the control of organisational change) in relation to the Warship Modernisation Support Initiative project. The findings were generally considered adequate but areas for improvement were identified which were communicated to the licensee for action.
One of the conditions attached to the nuclear site licence, LC11, requires that the arrangements for dealing with an accident or emergency arising on the site are rehearsed periodically. Such a rehearsal was demonstrated to the Inspectorate in October. It was the view of DRDL, and agreed by ourselves, that the Company had not adequately demonstrated the arrangements and should repeat the exercise using the same personnel before the end of January 2003.
Compliance with the Ionising Radiations Regulations, with respect to work being carried out at a number of locations around the site was inspected. Whilst this was considered to be generally adequate, a number of suggestions for improvements were made which the licensee is considering.
Much of NII’s effort at Devonport continues to be spent on the inspection and assessment of the following major project:
Commissioning of the new facilities built to permit the overhaul and refuelling of the Trident nuclear submarines, including 9 Dock, Low Level Refuelling Facility, (LLRF), the Nuclear Transfer Route, (NTR), and the shore-based cooling systems, is ongoing. The commissioning has been divided into a number of discrete stages and regulatory hold points established which prevent the licensee from proceeding from one stage to the next until the Inspectorate is content that the work can be carried out safely and that the associated risks are as low as reasonably practicable.
The Local Liaison Committee was attended on 27 November 2002. No questions were raised in relation to the work of the Inspectorate.
A routine meeting was held with safety representatives on 4 December 2002. A number of issues were raised which were discussed later with site management. A further meeting is scheduled for summer 2003.
A new site licence was signed on 25 October and came into force on 1 November 2002. This was necessary in order that a new nuclear transfer route, (NTR), for movement of submarine reactor fuel would be totally included within the boundary of the licensed site. The extra land incorporated into the licensed site for this purpose is leased from the MoD and amounts to approximately 0.22 hectares.
Two incidents occurred in 9 Dock during the reporting period. The first of these involved the movement of the Reactor Access House into position over HMS Vanguard. Insufficient of the submarine casing had been removed prior to this activity being carried out and a minor collision occurred. No significant damage was caused to either the submarine or the RAH. In the second, a few litres of slightly radioactive liquid were spilled onto the floor of 9 Dock. This was safely cleaned up and did not escape to the environment. Both incidents were investigated by NII inspectors who concluded that whilst there had been undesirable lapses in control, neither event presented a significant risk to workers or the public. It was decided that in view of the responsible approach being taken by DRDL to prevent a recurrence, no formal enforcement action should be taken on this occasion.
As part of its regulation under the nuclear site licence NII issues formal regulatory documents, which include Consents, Approvals, Acknowledgements, Specifications and Notifications.
During this quarter NII:
No enforcement action was undertaken but the progress of the licensee in discharging the Improvement Notice, relating to maintenance activities and issued earlier in the year, continues to be monitored. The indications at present suggest that the requirement to meet the 31 March 2003 completion date may now be difficult to achieve as a result of unforeseen resource problems. Discussions with DRDL and further monitoring of progress are under way.
HSE’s inspectors based in the Plymouth area office inspected the site with respect to an Improvement Notice issued earlier in 2002 as a result of deficiencies with respect to conventional health and safety. They concluded that DRDL had now met its obligations and satisfied the requirements of the Notice. HSE inspectors in Plymouth provided the following information:
DRDL selected a team, (including safety representatives), to review its existing systems for the provision of services to ships and submarines and built upon current best practices. From this exercise a number of improvements were identified, including better planning, hardware, infrastructure, briefings, audits/inspections etc. to implement and control the provision of services to vessels in a safe manner. A great deal of work was undertaken in putting these together to create a system flexible enough to be used at each of the diverse business units across the site.
Site transport safety is the subject of continuing discussions between inspectors based at HSE’s FOD office in Plymouth and the site as a planned programme of improvements is implemented.
Three NII inspectors visited HM Naval Base during this quarter spending a total of two days on the base. A number of meetings were held with MoD personnel during the quarter but no formal inspections were carried out.
MoD activities, at HM Naval Base and Devonport Royal Dockyard, are inspected under the Health and Safety at Work etc. Act (1974), the Radiation (Emergency Preparedness and Public Information) Regulations 2001, (REPPIR), and the Ionising Radiation Regulations 1999.
No specific inspections relating to this topic were carried out during the period although previous actions were followed-up and plans for a team inspection in March 2003 were discussed.
No specific inspections relating to this topic were carried out during the period although previous actions were followed-up.
The Local Liaison Committee was attended on 27 November 2002. No questions were raised in relation to the work of the Inspectorate.
None during the quarter.
No formal enforcement activities were carried out by HM Nuclear Installations Inspectorate during the period covered by this report.