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:
19 - 21 April
4 - 6 May
17 - 21 May
14 - 18 June
22 and 23 June
29 and 30 June
A total of 13 NII Inspectors and two inspectors from HM Railways
Inspectorate visited site during the quarter, spending a total of 76
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). In addition,
an HSE Solicitor and her assistant visited site for a familiarisation
visit on 20 April.
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) and DRDL's progress to improve its event reporting system, which is part of the arrangements made under Licence Condition 7.
An NII team supported by NNRP personnel witnessed the DRDL annual level 1 demonstration emergency exercise in May. Overall it was judged that DRDL would have coped with the scenario and appeared to show that improvements to the arrangements in respect of casualty recovery have been made since the previous exercise held in October 2003.
Arrangements for the production of safety cases are required by Licence Condition 14. An NII team supported by NNRP personnel, carried out an in-depth inspection into compliance with this condition. On the whole the process was judged to require some improvement, a fact previously recognised by DRDL and being undertaken. NII has now written to DRDL requesting an action plan to address outstanding issues.
Two inspectors carried out an in-depth inspection into software management to assess progress made by DRDL following an event that occurred in 2003. Good progress was found to have been made so far but the process is not yet complete. A further inspection will be made in about 6 months.
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 including the preparations for commissioning of the Primary Circuit Decontamination (PCD) facility equipment, which was not necessary for the refit of HMS Vanguard but will be required for future dockings to reduce radiation doses to workers.
The technical discussion groups, formed by MoD and DRDL to consider options for various safety improvements on which NII has had specialist observers, have now completed their deliberations. It is intended that the output of these groups, which is currently being distilled, will be agreed at the tri-partite MoD, DRDL, NII steering group in September.
HSE has published a report on its quinquennial review of the
decommissioning strategy for the Devonport Royal Dockyard Ltd (DRDL)
nuclear licensed site. The review was completed in consultation with
the Environment Agency and is concerned with the licensee's
strategy for decommissioning of the nuclear licensed site.
The key findings from the review were:
3.1 Incident investigations
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 of these incidents more formally.
At around 1800 hours on 14 June, DRDL was transferring well-cooled, used submarine reactor fuel from 14 Dock to the Low Level Refuelling Facility (LLRF) when the RTU became partially derailed. Such fuel transfers are carried out at very low "walking" speed and therefore the operator had time to press the emergency stop button and bring the train to a halt before the Low Level Transfer Trolley (LLTT) carrying the fuel had chance to become derailed.
The NII site inspector was on-site at the time and examined the scene of the event, assisted the following day by two inspectors from HSE's Railway Inspectorate.
It was agreed with DRDL that a three-phase approach would be taken to regain full use of the NTR with each phase being agreed by the NII and the NNRP in advance. Firstly railway specialists would examine the track and rail vehicles and advise the licensee on initial repairs/modifications to be undertaken. Following this the LLTT would be moved to complete its journey to the LLRF. Then, further examinations/measurements would be undertaken to determine what would be needed to complete the fuel movements necessary for the submarine in 14 Dock. Following this, a review would take place of the entire NTR system to ensure that any necessary repairs or modifications had been carried out and a satisfactory maintenance regime was in place prior to unrestricted use being permitted.
At the time of writing, the NII and the NNRP have agreed to the commencement of phases 1 and 2. Phase 1 has been successfully completed and phase 2 is in progress.
The refuelling and refitting process for nuclear submarines includes a period when reactor recommissioning operations take place. During the early stages of the recommissioning operations for HMS Vanguard an event occurred when the operators were filling the reactor circuit with cooling water. This event, which was looked into by the NII site inspector, had resulted in excess cooling water entering the reactor cooling circuit. The reactor was shutdown at the time of the event and there were no cooling or containment issues. We are satisfied that DRDL has completed a full investigation into the event and has made appropriate recommendations for improvements to plant configuration control processes and procedures. We will be further monitoring the licensee's response to ensure that learning points are fully implemented.
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 issued no regulatory documents.
No formal enforcement notices have been issued during the quarter.
A rising trend in the accident statistics on the site seen last year is being addressed by DRDL with the result that this trend has now reversed with a steady decline in reportable accidents since February.
Five NII inspectors visited HM Naval Base during this quarter, spending a total of 4 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.
No specific inspections relating to this topic were undertaken during the period but meetings associated with compliance with these regulations were held.
None during the quarter
No formal enforcement notices were issued by HM NII during this quarter.
Published on the HSE web site 23 August 2004