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. These reports are distributed quarterly and are available from the Internet at:
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 - 7 October
13 - 17 October
27 - 29 October
7 November
10 - 14 November
20 November
8 - 12 December
A total of 11 NII Inspectors visited site during the quarter,
spending a total of 58 days on site. Some of the inspections were
carried out with inspectors from the Ministry of Defence internal
regulatory organisation, the Naval Nuclear Regulatory Panel
(NNRP).
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 by DRDL to the Inspectorate in October. The exercise centred around a reactor accident in 5 Basin and was the first time that the new arrangements, whereby DRDL provide the Emergency Controller in the case of all emergencies arising on its site, had been witnessed by NII. The exercise was successfully managed by the combined DRDL/MoD team and paves the way for greater integration of the emergency arrangements in the future.
NII has continued to monitor implementation of the new maintenance regime (Licence Condition 28), following an enforcement notice served in 2002. Joint inspections with inspectors from MoD's NNRP were undertaken in October and November 2003. These showed that whilst significant progress had been made, there were still some areas where further work is necessary to ensure consistency across the site. A number of recommendations were made which DRDL has accepted and produced a programme for resolution, which we will monitor.
Initial indications are that DRDL's new arrangements for reporting of events under LC 7 are a significant improvement on the old system with many more events being reported. This is not to say there are more events occurring now than before, but that events of lower safety significance are being captured by the system, before they become a challenge to the protection systems. NII is continuing to encourage DRDL to maintain momentum with the revised arrangements, in particular to learn and disseminate lessons from events more quickly and widely, to avoid repeat events.
The 6 monthly review meeting was held on 16 October. The most significant issue arising was that DRDL was required to supply NII with an acceptable programme for Periodic Safety Reviews, which it will have to carry out in accordance with Licence Condition 15.
No specific inspections relating to this topic were carried out during the period.
NII has continued to inspect and assess facilities associated with the refitting of Vanguard-class submarines. This includes:
NII continues to work with MoD and DRDL 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 given 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, general seismic withstand improvements for the SRC and improvements to 10 Dock.
The Local Liaison Committee was attended on 20 November 2003. No questions were raised in relation to the work of the Inspectorate.
A routine meeting was held with safety representatives on 9 December 2003. A number of issues were raised which were discussed later with site management. A further meeting is scheduled for summer 2004.
During the course of routine business on site, events/possible problems arise or are brought to NII inspector's attention. These are followed up as considered appropriate at the time. During this quarter NII inspectors investigated three incidents more formally. These involved fires during hot work on submarines in 9 Dock, 10 Dock and 14 Dock. (Fires can pose a significant threat to the safety of a submarine in dock.) DRDL had conducted its own investigation and concluded that because of the location of the fires towards the front of the submarines there were no nuclear or radiological safety implications. However DRDL had made a number of recommendations for future improvements including more rapid dissemination of information from previous events, training of fire sentries and improvements in control of work and local risk assessment.
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.
HSE's Offshore Safety Division Diving Unit was notified of a dangerous occurrence during which a tugboat was brought alongside a naval vessel, whilst civilian diving operations were underway. This is now the subject of HSE inquiries
Over the past few months there has been much greater use of signs around the site highlighting the importance of safety.
Four NII inspectors visited HM Naval Base during this quarter, primarily in support of the emergency exercise on 11 November and also on a number of other occasions, spending a total of four 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 and the Staged Improvement Process.
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.
The MoD annual demonstration exercise was witnessed by a joint NII/NNRP inspection team. This exercise was unique for MoD in that it took place in "silent hours" (2000 hours), did not involve a reactor accident and was only the second exercise whereby a representative of the organisation responsible for the geographic area where the accident occurs takes control. In this case the accident was on MoD land and therefore MoD provided the Emergency Controller. His support team was largely DRDL employees. Overall it was considered that the situation would have been handled adequately on the day but significant deficiencies were noted with respect to the operation of the Forward Command Post and the casualty rescue team. DRDL are required, jointly with MoD, to evaluate the reasons for this and to put in place a plan to resolve the problems.
The Local Liaison Committee was attended on 20 November 2003. No questions were raised in relation to the work of the Inspectorate.
None during the quarter.
No formal enforcement notices were issued by HM NII during this quarter.