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:
www.hse.gov.uk/nuclear/llc/index.htm
Site Inspectors of HM Nuclear Installations Inspectorate attend the LLC meetings and will be happy to respond to any questions raised there or subsequently 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.
Site Inspectors from the Health & Safety Executives Nuclear Installations Inspectorate (HSE-NII) made visits to Devonport Royal Dockyard on the following dates during this quarter:
10, 11, 12, 13, 27, 28 January 2005
7, 8, 21, 22, 23, 24 February 2005
7, 8, 9, 16, 17, 21, 22, 23, 24 March 2005
Other members of the HSE-NII, including specialist inspectors also visited the site during the period. A Deputy Chief Inspector of Nuclear Installations made a site visit in March for the purpose of the annual Level 1 meeting with the DRDL Chief Executive and other Senior Management.
Some of the inspections were carried out with inspectors from the Ministry of Defence internal regulatory organisation, the Naval Nuclear Regulatory Panel (NNRP), and the Environment Agency (EA).
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).
2.1 Compliance with Conditions attached to the Nuclear Site Licence
2.1.1 Operating Experience Feedback (OEF) & Incidents on the Site (Licence Condition 7) Team Inspection
The inspection found that DRDL’s arrangements for dealing with incidents and learning from OEF continue to improve but were less mature than some licensees. We identified a number of recommendations to encourage further improvement to the arrangements and application of OEF across the licensed site. An action plan to respond to the recommendations was requested from the licensee and will be followed up by the NII site inspection team.
2.1.2 Accumulation & Disposal of Radioactive Waste (Licence Condition 32 & Licence Condition 33).
Quinquennial Review of DRDL’s Strategy for Decommissioning (May 2004).
During the period we completed a joint team inspection, with inspectors from NNRP and EA, to examine DRDL’s arrangements for the management of radioactive waste. We also reviewed progress towards addressing the issues identified from HSE/NII’s Quinquennial Review (May 2004) of DRDL’s strategy for decommissioning. We completed follow up inspections in relation to radioactive ion exchange resin wastes that are currently stored on the site to allow for radioactive decay and treatment before their disposal as low level waste to the Drigg disposal site. We are pressing DRDL to maintain it’s programme for decanting such wastes from the Modified Magnox Flask temporary storage arrangements into modern standard Resin Storage Vessels. We are also encouraging the licensee to complete optioneering work to establish a secure management strategy and optimum timescales for treatment of radioactive ion exchange resins into a form suitable for disposal at Drigg. We are continuing to monitor these matters and will provide further updates in future LLC reports.
No specific inspections have been completed during this period. An IRR’s inspection is planned for Quarter 2 in 2005.
2.3 Inspection of Major Project work
2.3.1 15 Dock – HMS Splendid
HSE/NII agreement to the docking of HMS Splendid in 15 dock was granted for the completion of essential maintenance work and to enable further demanning of the submarine to be put in place. The DRDL safety justification for the docking put in place a further criticality safeguard through core boronation in addition to the fitting of control rod locking devices and restricting operations of the 80 te crane over the 15 dock area. The reactor core had achieved thermal roll over meaning that residual decay heat is removed passively by natural heat loss. As such HSE/NII was satisfied with the core cooling safety justification.
HMS Splendid has been decommissioned from the Royal Navy’s submarine fleet and is at Devonport awaiting defuelling. The defuelling activity is planned to commence when further improvements to the fuel handling facilities, as part of the staged improvement programme (SIP), have been completed.
2.3.2 9 Dock - Commencement of HMS Victorious LOP(R)
HSE/NII agreements to the docking and dockdown of HMS Victorious were granted to enable the Long Overhaul Period with Refuel LOP(R) to commence. Inspections on site and the assessment of safety case documentation were completed by HSE/NII inspectors to inform the permissioning process for both holdpoints. We were satisfied that the licensee had demonstrated an adequate state of readiness.
2.3.3 Staged Improvement Programme (SIP)
Further high level discussions in relation to the scope of the SIP involving HSE/NII’s Chief Inspector took place during the period. The project strategy to deliver the required improvements is currently under review within MoD and HSE/NII is pressing for early resolution of the outstanding matters to ensure there is no undue delay to the agreed programme.
The improvements are primarily focused on the Submarine Refit Complex that deals with S & T Class boats. The overall upgrade is expected to be delivered within the period 2005–2008.
HSE/NII’s immediate focus is delivery of the agreed near term facility improvements, including:
The above work is being closely monitored by HSE/NII and expected to be in place to support the safety justification for the refit and refuel of HMS Triumph which is due to commence later this year.
2.4 Compliance with Radiation (Emergency Preparedness and Public Information) Regulations 2001, (REPPIR)
The DRDL review of it’s arrangements made to comply with REPPIR was received in line with the 5 year review requirement. HSE/NII is completing an assessment of the review documentation.
2.5 Conventional Health and Safety
HSE-NII leads on the inspection of conventional health & safety with support from inspectors in the HSE Field Operations Directorate (FOD) based in Plymouth. No specific conventional health & safety inspections were completed during the period
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. There were no formal investigations during this period.
4.1 Regulation
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:
4.2 Enforcement
No formal enforcement notices have been issued during the quarter.
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 dealing with redundant submarines at Devonport 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. An IRR’s inspection is planned for Q2 2005.
2.2 Compliance with Radiation (Emergency Preparedness and Public Information) Regulations 2001, (REPPIR)
The MoD review of it’s arrangements made to comply with REPPIR was received in line with the 5 year review requirement. HSE/NII is completing an assessment of the review documentation.
HSE/NII inspectors together with other key stakeholders attended a MoD lead workshop to discuss the strategy for dealing with redundant nuclear submarines at Devonport. The workshop was held in response to HSE/NII’s request for information to inform the future regulatory strategy and decisions relating to facility improvements and docking operational programmes. The workshop covered a broad range of topics associated with managing the safe storage of redundant submarines from their arrival at Devonport through to defuelling and longer term storage (ISOLUS Project). HSE-NII is satisfied that the redundant submarines at Devonport are stored safely.
4.1 Enforcement
No formal enforcement notices were issued by HSE-NII during the period.