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.
The Nuclear Installations Inspectorate (HSE-NII) site inspectors made visits to Devonport on the following dates during this quarter:
13 - 16 July 2004
21 - 22 July 2004
17 - 19 August 2004
8 - 10 September 2004
14 - 17 September 2004
20 & 23 September 2004
Other members of the HSE-NII, including specialist inspectors visited
the Devonport site during the period. A Deputy Chief Inspector and
Superintending Inspector attended a meeting to discuss the Devonport
Staged Improvement Programme (SIP) and Specialist Inspectors
completed inspections in relation to:
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-NII 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 as required by Licence Condition 28. The licensee has made further improvements to the arrangements for ensuring adequate levels of maintenance are completed and is working towards applying for HSE-NII's Approval of the maintenance policy. An Approval is used by HSE-NII to freeze the licensees arrangements such that changes cannot be made without further consideration by the Inspectorate.
No specific inspections have been completed during this period.
HSE-NII has continued to inspect and assess facilities associated with the long overhaul and refuelling process of Vanguard class submarines. This has included the preparations for commissioning the Primary Circuit Decontamination (PCD) facility which will be required for future dockings to reduce worker radiation doses to acceptable levels. We have encouraged the licensee to develop a decision criteria matrix in order that following PCD use the adequacy of decontamination process can be judged and worker radiation dose reduction demonstrated to be ALARP. We have introduced a regulatory holdpoint to ensure the required standards of worker radiological protection will be in place for the period of the overhaul work.
We have also monitored the licensees project to develop a plant system to boronate the reactor core for the next Trafalgar class submarine long overhaul period (refuel). The overhaul process is due to commence in mid 2005 and the provision of boronation to the core will bring about a further improvement to nuclear safety and compliance with internationally accepted standards. We have made it a requirement to have the system in place prior to granting permission for lifting a regulatory holdpoint.
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Discussions were held with Naval Base and DRDL personnel in relation to delivery of the Devonport Staged Improvement Programme. HSE-NII is working closely with the Naval Base and DRDL to ensure the required improvements, to bring some of the nuclear facilities at Devonport up to modern nuclear safety standards, are delivered within agreed timescales. The improvements are primarily focused on the Submarine Refit Complex that currently deals with S & T class boats. The overall upgrade is expected to be delivered via the D154 Phase 3 project within the period 2005-2008 and the first stage of the process was agreed at a senior tri-partite meeting between MoD, DRDL, HSE-NII on 9 September 2004. HSE-NII is pressing for early delivery of the improvement programme.
As required by Licence Condition 11 the licensee sought HSE-NII
Approval for a number of proposed changes to the site emergency plan.
During discussions with the licensee it was revealed that some of the
changes had been implemented in advance of the licensee receiving the
necessary Approval of the inspectorate. We reviewed the specific
circumstances to this breach of the site licence and given we were
aware of the proposed changes and judged them acceptable, we
concluded that formal regulatory action wasn't necessary. We have
formally requested the licensee to complete a full investigation into
the license condition breach and we will ensure recommendations for
improvement to prevent a reoccurrence are fully implemented.
In order to obtain evidence as to the adequacy of the revised
emergency arrangements we requested the licensee to complete an
actual demonstration exercise to test the specific change to use a
new Shelter Station. The demonstration emergency exercise was carried
out on 23 September 2004 and included the evacuation of 400 staff
from the Submarine Refit Complex. We judged the exercise to be an
adequate demonstration of the changes made to shelter stations and
have since provided our Approval of the revised site emergency
plan.
The HSE-NII Nominated Site Inspector attended the Local Liaison Committee meeting on 16 July 2004.
Following the publication of our report on the quinquennial review of the decommissioning strategy for the Devonport Royal Dockyard Ltd (DRDL) nuclear licensed site, we requested the licensee to put in place an action plan for dealing with the key findings. We have now agreed the action plan which shows the matters raised in our report will be addressed by end 2005. Updates on the licensees' progress will be made to the LLC in future quarterly reports.
The HSE-NII Site Inspector held a routine meeting with site safety representatives. There was good level of support for the meeting with the safety representatives raising a number of topics for discussion including:
During the course of routine business on site, events/possible problems arise or are brought to HSE-NII inspector's attention. These are followed up as considered appropriate at the time. During this period HSE-NII inspectors have investigated the following incidents:
Following the derailment of a rail tug unit in May 2004 we have continued to follow up the licensees recovery process to re-validate the design basis operational safety case for new and irradiated fuel movements using the on site rail system. Stage 1 & 2 allowing movement of fuel from 14 dock into the Low-level Refuelling Facility (LLRF) have been completed to our satisfaction and further moves of irradiated fuel have been completed safely. We will continue to monitor the recovery process through to satisfactory completion of the final stage which is required to confirm an acceptable safety case is in place for the totality of the rail system making up the nuclear transfer route on the licenced site. We are also working with the Naval Nuclear Regulatory Panel to ensure the rail system on the naval base to the interface with the national network is maintained to acceptable standards for nuclear freight movements.
As part of its regulation under the nuclear site licence HSE-NII issues formal regulatory documents, which include Consents, Approvals, Acknowledgements, Specifications and Notifications.
The following regulatory documentation was issued during the quarter:
(i) Approval Number 3 was issued to Devonport Royal Dockyard Limited providing the Health & Safety Executives approval for the document entitled 'SITE LICENCE ARRANGEMENT NO 11 & AUTHORISATION CONDITION COMPLIANCE STATEMENT NO 11 EMERGENCY ARRANGEMENTS', and referenced 'SLA/ACCS 11 ISSUE 13'.
No formal enforcement notices have been issued during the quarter.
HSE-NII continues lead on the inspection of conventional safety with support from inspectors in the HSE Field Operations Directorate based in Plymouth.
HSE-NII site inspectors and specialist inspectors visited HM Naval Base on a number of occasions during this period. 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.
HSE-NII inspectors attended two stakeholder planning meetings in relation to the forthcoming Emergency Exercise Short Sermon 04. The exercise will test the Naval Base's DEVNUSAFE on site emergency plan and the DEVPUBSAFE off site emergency plan which is owned by Plymouth City Council. The Grade A exercise will take place in November and participation up to national level is required to demonstrate both the immediate response and later remediation phases that would be necessary for dealing with a significant nuclear incident.
HSE-NII has requested the Naval Base and DRDL to produce a detailed strategy for dealing with laid up submarines at Devonport prior to the commencement of decommissioning. At present HSE-NII is satisfied the laid up submarines are stored safely at Devonport but has requested further detail and justification of the position in relation to ongoing maintenance requirements, essential staffing levels and the defuelling operations. The strategy is important to inform such matters as the timing of maintenance work on the laid up submarines in relation to the operational programme for the docks and needs to reflect the plans for delivery of the facility improvements through the Staged Improvement Programme. The Naval Base and DRDL have agreed to make the strategy available in early 2005.
No formal enforcement notices were issued by HSE-NII during the period.
Published on the HSE web site 23 August 2004