Health and Safety
Executive / Commission
Nuclear
LLC reports
Inspections (MOD)
Routine Matters (MOD)
Non Routine Matters (MOD)
Regulatory and Enforcement
Activity (MOD)
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 attends LLC meetings and will be happy to respond to any questions raised there by members. Any other person wishing to enquire about matters covered by this report may contact HSE's Nuclear Directorate Information Centre on 0151 951 4103.
Inspections on site were made on the following days:
6 - 10 JanuaryA total of 15 NII Inspectors visited site during the quarter spending a total of 70 days on site. Joint inspections were carried out with inspectors from the Ministry of Defence internal regulatory organisation, Naval Nuclear Regulatory Panel, NNRP and the Environment Agency.
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 9 Dock in preparation for refuelling activities planned for HMS Vanguard, preparation for the docking of HMS Talent in 14 Dock for Long Overhaul Period Refuel (LOP(R)), 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), 14 (relating to safety cases), 15 (relating to periodic review of safety cases), 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). 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. As a result of a demonstration to the Inspectorate in October 2002, which identified several areas for improvement in the on-site emergency response, DRDL offered to repeat the exercise using the same personnel on 30 January 2003. On this occasion DRDL was able to adequately demonstrate its emergency arrangements.
Compliance with the Ionising Radiations Regulations, with respect to work being carried out at a number of locations around the both the licensed site and Naval base was inspected by a team of inspectors from NII, NNRP and the EA. Whilst this was considered to be generally adequate and shows improvement since the previous inspection, a number of suggestions for improvements were made which the licensee is considering.
Much of NII's effort at Devonport continued to be spent on the inspection and assessment of the proposed new facilities associated with the refitting of Vanguard-class submarines, (TSSBN).
Commissioning of the new facilities, including 9 Dock, Low Level Refuelling Facility and the Nuclear Transfer Route, is ongoing. The commissioning of the facilities was divided into a number of discrete stages and regulatory hold points were established to prevent the licensee from proceeding from one stage to the next until the Inspectorate was content that the work could be carried out safely and that the associated risks were as low as reasonably practicable. The final regulatory hold points to allow commissioning of the facilities were released during the quarter, please see section 4.1 below.
The defuel of HMS Valiant, which was docked in 14 Dock for Dock Down and Lay-up Preparations, was successfully completed and the submarine left 14 Dock on 6 March 2003. It has been moored in 3 Basin along with other defuelled submarines.
NII has asked DRDL to produce a programme for periodic review of its plant safety cases in order to be assured that plants still comply with the original safety case; to compare against current standards for new plant, evaluate any deficiencies and implement any reasonably practicable improvements to enhance plant safety; to identify any ageing process which may limit the life of the plant and to revalidate the safety case until the next PSR, subject to the outcome of routine monitoring by the licensee and regulation by NII.
An incident occurred on HMS Talent whilst it was moored in 5 Basin when a member of the ship's crew crossed a radiography barrier and received a very small unplanned radiation dose. This was a similar incident to that which occurred on HMS Triumph in 10 Dock last year. The incident was investigated by NII and radiography was suspended whilst DRDL's investigation of the event was conducted. The investigation is complete and a number of recommendations are being progressed. 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 with respect to the individual or DRDL. However NII takes a serious view of repeat events, particularly when it involves unnecessary doses to individuals and DRDL has been warned that any further repeat radiography events may result in enforcement action being taken.
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 last year, continues to be monitored. The indications at present suggest that the requirement to meet the 31 March 2003 has been achieved. A final inspection with respect to the enforcement notice is planned for May 2003.
Onsite 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 four days on the base. A number of meetings were held with MoD personnel during the quarter and a team inspection covering IRRs was carried out, please see 2.1 below.
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.
The IRR team inspection mentioned in Part A above also covered the Naval Base. A separate list of suggestions for improvements was made which the Naval Base is considering.
No specific inspections relating to this topic were carried out during the period although previous actions were followed-up.
None during the quarter.
REGULATORY AND ENFORCEMENT ACTIVITY
No formal enforcement activities were carried out by HM Nuclear Installations Inspectorate during the period covered by this report.
Published on the HSE web site 5 August 2003