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:
12 - 16 January
9 - 12 February
25 February
2 March
15 - 18 March
23 March
A total of 9 NII Inspectors visited site during the quarter, spending a total of 41 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).
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).
NII has continued to monitor implementation of the new maintenance regime (Licence Condition 28). NII is monitoring DRDL's progress in closing out a number of issues raised during inspections in October and November 2003.
Nii continues to monitor DRDL's progress to improve its event reporting system, which is part of the arrangements made under Licence Condition 7.
DRDL has provided NII with an acceptable programme for Periodic Safety Reviews, which it will have to carry out in accordance with Licence Condition 15.
2.2 Compliance with the Ionising Radiation Regulations
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. Recently NII sent observers to technical discussion groups, formed by MoD and DRDL to consider options for various safety improvements.
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 two incidents more formally.
The first involved a spillage of ~150 litres of potentially contaminated water to the diesel room bilge on Trafalgar in 10 Dock when a team comprising the Dockside Test Organisation and Ship Staff were filling the port loop, using the low pressure coolant make-up pumps, in accordance with the extant nuclear procedure. However the procedure did not call for the pump bypass valves to be shut after they had stopped and relied on the operator to recognise the system was in an abnormal line up. A local management investigation was undertaken which concluded that the water was make up water and not primary circuit water, and the operators acted in accordance with the extant procedures. However the procedures need to be revised to provide more explicit instructions to return systems to their normal line up as soon as practicable after completing the task for which they are moved. Although the leakage did not involve active liquors it did result in the generation of unnecessary wastes and the site inspector wrote to DRDL noting that he considered there had been a breach of LC 34(1) and reminded DRDL of its responsibilities to avoid future occurrences.
The second involved a leak of ~9 litres/day of seawater into Drain Tank Room 006 at the lowest level in the PCD building in 9 Dock. There appears to be no immediate safety concern. Discussions between DRDL and the construction contractor over this and other contractual problems are underway and in the meantime DRDL appears to be managing the situation. Financial provision has been made to complete the leak repair.
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:
x Issued Licence Instrument number 11 on 26 March 2004 giving
agreement to the commencement of inactive commissioning of the PCD
system on 9 Dock.
x Issued Licence Instrument number 12 on 26 March 2004 giving
agreement to cutting of the Main Seal Membrane on HMS Talent in 14
Dock to allow DRDL to commence the defuel/refuel operations.
No enforcement notices have been issued during the quarter.
A number of inconsistencies were identified between a sample of buildings with respect to the appointment of building controllers and maintenance of the fire safety registers. This was raised with the Fire Safety Officer and followed up by letter. A meeting was subsequently held with the Director of Health & Safety to discuss the actions DRDL proposed to remedy the deficiencies. DRDL agreed to report progress at the review meeting planned for April 2004.
Four 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, primarily relating to the MoD's arrangements for responding to nuclear and radiological emergencies. and the Staged Improvement Programme (SIP).
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 first All-Agency Planning meeting for the Short Sermon 04 Emergency Exercise, planned for 24 to 25 November 2004 was attended on 21 January 2004. MoD and Plymouth City Council jointly chaired the meeting with MoD leading on discussions on the first day, the emergency phase and PCC leading on discussions on the second day, covering the remediation phase. The meeting was well attended by the major stakeholders. NII regulatory involvement will be to provide staff to act as players and also to support MoD's CNNRP during the assessment on site. NII will take the lead for off-site assessment. NII will attend future planning meetings.
None during the quarter
No formal enforcement notices were issued by HM NII during this quarter.
Published on the HSE web site 16 June 2004