Health and Safety
Executive / Commission
Nuclear
LLC reports
A. DEVONPORT ROYAL DOCKYARD
LIMITED
Inspections
Routine Matters
Non Routine Matters
Regulatory and Enforcement
Activity
B. MINISTRY OF
DEFENCE
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:
7-11 AprilA total of 9 NII Inspectors visited site during the quarter spending a total of 53 days on site. Some of the 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 been focused on activities associated with the completion of work by the licensee in relation to the enforcement notice served in 2002 in respect of maintenance (Licence Condition 28). The licensee was required to develop maintenance schedules that accurately reflect the plant safety cases and work instructions to ensure that the maintenance is carried out appropriately. This has now been accomplished and NII has lifted the enforcement notice. NII will continue to monitor implementation of the new maintenance regime over the coming months and a joint inspection with inspectors from MoD's NNRP will be undertaken in October.
A joint inspection was undertaken with an inspector from the Environment Agency which covered requirements of licence conditions LC12 (requirement to have suitably qualified and experienced persons), LC25, (requirement to make and keep appropriate operational records), LC32, (accumulation of radioactive waste), and LC34, (leakage and escape of radioactive waste), as well as those of the Radioactive Substances Act 1993. The conclusion of the inspection was that generally the licensee was working within the requirements of the legislation although there were a number of areas where improvements could be made. These included a requirement to reduce the production of solid radioactive waste by removal of packaging materials before items are taken into controlled areas and ensuring that record sheets are signed off in accordance with written procedures.
The NII believes that an important part of the process of managing a nuclear site safely is the way in which the licensee learns from loss of control events and prevents recurrences or more significant events occurring in future. DRDL has been informed that despite the improvements it has made over the last two years, the arrangements for compliance with LC7 (relating to the recording, reporting and investigation of incidents) still fall short of the standards expected and NII is expecting to see significant progress by the end of 2003.
No planned inspections relating to the IRRs have been carried out during the quarter.
NII's has continued to inspect and assess facilities associated with the refitting of Vanguard-class submarines.
Following a successful refuelling campaign for HMS Vanguard and the removal from site of the spent fuel, NII is now turning its attention to ensuring that issues identified during the first use of the plant are addressed by the time that the next Vanguard Class submarine arrives in 2004. In addition NII is monitoring the commissioning of equipment that was not necessary for the refit of HMS Vanguard but will be required for future dockings, such as the Primary Circuit Decontamination, facility.
NII has been working with MoD and the licensee to ensure that a programme of safety improvements is developed (known as the Devonport Staged Improvement Programme, (SIP)) 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 original refuelling crane at the Submarine Refit Complex, (SRC), 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.
NII inspectors investigated two incidents during the quarter. One related to faults arising with the electronic dosimetry instrumentation used on site. NII pressed the licensee to achieve a rapid repair programme for this equipment and this was accomplished.
The second related to an event on HMS Vanguard where a small number of workers were exposed to airborne contamination. It was subsequently determined that the radiation levels were insignificant and posed no risk to health. The licensee is proposing to take steps to prevent a recurrence by reviewing engineering procedures and the design of glove-boxes, by rationalisation of paperwork systems, by improved training of personnel and by better control and maintenance of vacuum cleaning equipment.
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-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 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.
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 associated with the IRRs were carried out during the quarter although previous actions were followed up.
No specific inspections relating to this topic were carried out during the period although previous actions were followed-up.
MoD was given strong advice to better control access to radwaste storage areas on the tidal berths which are confined spaces. Improved systems of control are now in place.
No formal enforcement notices were issued by HM NII during this quarter.
Published on the HSE web site 3 October 2003