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 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:
A total of 24 NII Inspectors visited site during the quarter, including HM Chief Inspector of Nuclear Installations, a Deputy Chief Inspector and a number of Superintending Inspectors (see sections 2.6 and 2.7), spending a total of 69 days on site. In addition the HSE's Deputy Director General visited the site on 18/19 August. Some of the 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 NII has continued to monitor implementation of the new maintenance regime (Licence Condition 28), following an enforcement notice served in 2002, in preparation for joint inspections with inspectors from MoD's NNRP to be undertaken in October and November 2003.
A joint inspection was undertaken with an inspector from NNRP into control and supervision of mobile cranes (LC26) on 9 Dock and 10 Dock. The conclusion was that there was evidence of both good practice and areas for improvement, such as direct supervision by DRDL of contractors during lifting operations and completion of the relevant operational documentation. A letter was sent encouraging DRDL to implement cross fertilisation of good practice across the site.
DRDL was informed last quarter that despite the improvements it had made over the last two years, the arrangements for compliance with LC7 (relating to the recording, reporting and investigation of incidents) still fell short of the standards expected and NII was expecting to see significant progress by the end of 2003. In response on 17 September 2003 DRDL introduced new arrangements for reporting of events. Initial indications are that there appears to have been a significant improvement in event reporting and NII has advised DRDL of the need to maintain momentum with the revised arrangements.
Other Licence Conditions which have been inspected during the quarter in accordance with NII's Integrated Enforcement Strategy include licence condition 10 (relating to training), 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), 22 (relating to modifications on existing plant), 23 (the requirement to have an adequate safety case and associated operating rules), 24 (the requirement to carry out safety related activities in accordance with written instructions). The findings were generally considered adequate but areas for improvement were identified, such as a programme for periodic safety reviews and an improved system of records associated with modification proposals, which were communicated to the licensee for action.
A planned inspection relating to the progress with the recommendations from the IRRs team inspection in March 2003 was carried out during the quarter. DRDL has made good progress and all of the recommendations have been completed.
NII's has continued to inspect and assess facilities associated with the refitting of Vanguard-class submarines. This includes ensuring that issues identified during the first use of the plant, such as the Refuelling Access House crane are addressed by the time that the next Vanguard Class submarine arrives in 2004, as well as monitoring the setting to work and commissioning of the Primary Circuit Decontamination facility equipment which was not necessary for the refit of HMS Vanguard but will be required for future dockings.
NII continues to work with MoD and the licensee to ensure that a programme of safety improvements, known as the Devonport Staged Improvement Programme, (SIP), is developed such that these can be implemented in the most effective way and introduced at the earliest opportunity bearing in mind the operational needs of the Navy. This programme includes improvements to the Submarine Refit Complex (SRC) refuelling crane prior to its demolition in around 2008, the design and construction of new low-level refuelling equipment and general seismic withstand improvements for the SRC, and improvements to 10 Dock.
Mr J McCracken, HSE's Deputy Director General, visited the Devonport licensed site on 18/19 August. He appeared to be satisfied and interested in what he saw. The main thrust of his comments was that he thought more emphasis needed to be placed upon safety awareness.
Mr L Williams, HM Chief Inspector of Nuclear Installations, visited site on 11 September 2003. Discussions were held with senior DRDL and MoD staff and a meeting was held with a number of safety representatives. Mr Williams noted the improvements in safety that had been achieved over recent years and that NII is seeking to ensure all stakeholders maintain this process of improving safety by working together to deliver the Staged Improvement Programme. He suggested that there was scope for DRDL to improve safety culture.
A familiarisation visit was made to DRDL by NII's Inspection Co-ordination Group (ICG), comprising Superintending Inspectors who lead various site inspection units, in order to inform its current considerations on benchmarking, proportionality and consistency of inspection practices and procedures. The informative and useful visit succeeded in its general objective of better informing ICG on some of the complex issues relating to regulation and enforcement in the MoD and particularly the Devonport environment.
NII inspectors investigated three incidents during the quarter. One related to overdue pre-operational maintenance on the MODIX plant. Some weekly and monthly maintenance had been missed after contractors left site. Interim arrangements were put in place by DRDL when this was discovered and NII has confirmed that maintenance had been completed and job plans are in the process of being transferred onto the maintenance work-scheduling database.
The second related to an event on 14 Dock when the wrong software had been installed on a nuclear crane. This was potentially a site-wide software management problem and DRDL has modified its arrangements to control software changes. NII will re-visit this aspect in 6 months to check that progress is being maintained.
The third incident related to a snagged load involving the 14 Dock 9Te dockside crane. No personnel were harmed and no equipment was damaged. The Plant Manager took the 14 Dock cranes out of service until an investigation had been carried out and slingers, crane co-ordinators and crane drivers had been briefed to ensure that they fully understood both the health & safety and safety case issues. The restriction on lifting operations was lifted the following day.
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 notices have been issued during the quarter.
On 15 September two members of DRDL staff were scalded during commissioning tests on the new Steam Generating and Delivery System. Commissioning of the steam barge is suspended pending conclusion of the DRDL investigation. HSE's FOD office in Plymouth is following up the investigation and awaits the final report from DRDL.
On-site transport is an ongoing theme on the Licensed Site and Naval Base and improvements are continually being made.
Last year 2 workers from TRY Accord, a main DRDL contractor, were excavating a concrete floor within the Heavy Turnery Factory in preparation for a new reinforced concrete base for the installation of new plant. The work was being carried out within a wood framed tented enclosure using a petrol driven road saw without make up air and direct connection from the exhaust to outside. This is contrary to the Code of Practice for Confined Spaces. On 22 September 2003 Plymouth Crown Court imposed a £150,000 fine on TRY Accord. TRY Accord is appealing against this sentence. HSE did not prosecute DRDL as the investigation discovered it had acted reasonably in this matter.
Five NII inspectors visited HM Naval Base during this quarter, including HM Chief Inspector of Nuclear Installations, spending a total of five days on the base. A number of meetings were held with MoD personnel during the quarter, primarily relating to the MoD's arrangements for responding to nuclear and radiological emergencies.
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.
A planned inspection relating to the progress with the recommendations from the IRRs team inspection in March 2003 was carried out during the quarter. The Naval Base has made good progress and approximately half of the recommendations have been completed.
Mr L Williams, HM Chief Inspector of Nuclear Installations, visited the Naval Base on 12 September 2003. Discussions were held with senior MoD staff covering nuclear and radiological safety issues affecting the Naval Base including the Warship Support Modernisation Initiative (WSMI), which appears to have been successful and is now considered normal business. This was followed by visits to HMS Courageous and the combined Devonport Accident Control Centre (DACC), which is now fully operational. Mr Williams congratulated the Naval Base for working closely with DRDL to provide the DACC, which compares well with the best in the civil sector.
No specific inspections relating to this topic were carried out during the period.
None during the quarter.
No formal enforcement notices were issued by HM NII during this quarter.
Published on the HSE web site 4 December 2003