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
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:
11 - 13, 14, 25 - 29 April 2005
12 - 13, 18 - 19, 23 - 24, 31 May 2005
1 - 3, 6 - 10, 13 - 15, 23, 29 - 30 June 2005
Other members of HSE-NII, including specialist inspectors also visited the Devonport site during the period.
The HM Chief Inspector of Nuclear Installations made a routine visit to the site in May, during which DRDL provided an overview of managing nuclear safety across the site. The Chief inspector also met the DRDL safety representatives and inspected some of the facilities.
The HSE-NII Superintending Inspector responsible for inspecting Naval Bases and Dockyards visited the site in June and lead the inspection of the Devonport Licensed Site demonstration emergency exercise.
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), the Department for Transport (DfT) and the Environment Agency (EA). Additionally inspectors from HSE’s Field Operations Directorate (FOD) visited the site.
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).
Licensed Site Demonstration Emergency Exercise (Licence Condition 11)
The Devonport Licensed Site demonstration emergency exercise was held on 15th June 2005. These HSE-NII witnessed demonstration emergency exercises are carried out annually at each licensed site and are in addition to the Licensee’s own training exercises. The emergency exercise scenarios are developed from a matrix that ensures all aspects of the Licensee’s emergency arrangements are exercised and inspected on a regular basis. The scenario is agreed with the HSE-NII site inspector in advance of the exercise.
On this occasion HSE-NII concluded that there were a number of good features demonstrated for example the operation of the Devonport Accident Control Centre (DACC). However, as with all such exercises there are lessons to be learned and the main one on this occasion was in relation to the management of casualty rescue. The time taken for some of the incident response teams to access the facility was excessive which resulted in an inappropriate delay to dealing with a casualty. The Licensee has been requested to address the important learning points and to redemonstrate to HSE-NII the arrangements for providing effective casualty rescue.
A team inspection was completed to review DRDL’s compliance with the Ionising Radiations Regulations (IRR’s). Inspectors from HSE-NII and NNRP completed the inspections and we concluded the licensees arrangements were generally satisfactory. The areas for improvement identified from the inspection were communicated to the licensee and we are monitoring progress towards closing out these matters.
Devonport Staged Improvement Programme (SIP)
HSE-NII’s Chief Inspector visited Devonport in May and as part of his programme inspected the nuclear facilities viewing completed improvements and work in progress. The delivery of the Devonport Staged Improvement Programme (SIP), to bring about the required improvements in nuclear safety, was confirmed to be a high priority within HSE-NII’s intervention strategy. It was noted the process for implementing further improvements through the D154 Phase 3 project and other project arrangements is currently being reworked by DRDL and the MoD. The Chief Inspector emphasised the need to ensure the agreed facility improvements are delivered in line with the established SIP process and not unduly delayed.
9 Dock Primary Circuit Decontamination (PCD) Facility
We are monitoring the licensees progress towards completing the commissioning of the Primary Circuit Decontamination (PCD) facility which will be used to clean the HMS Victorious reactor primary circuit prior to the commencement of refuelling operations. The application of the PCD process is important to ensure worker radiation dose levels are properly controlled and reduced to ALARP. The inactive and active commissioning of new nuclear facilities is an important process towards demonstrating that a facility can be safely taken into full operation.
HSE-NII leads on the inspection of conventional safety with support from inspectors in the HSE Field Operations Directorate (FOD) based in Plymouth. We have liased on a number of reported conventional safety incidents during the period. One of these incidents resulted in a preliminary visit to the site by the HSE-FOD inspector. None of the incidents were found the meet HSE’s criteria for further investigation.
During the course of routine business on site, incidents/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:
Used Fuel Flask (UFF) Consignment
HSE-NII and Department for Transport (DfT) inspectors completed a joint investigation in relation to two reported incidents associated with recent fuel flask consignments from Devonport to Sellafield. Although the incident was reported by DRDL our investigation also focused on MoD as the consigner of the flask off the site. The incidents were related to the flask consignment documentation and maintenance. Our investigation concluded the shortfalls were of minor nuclear safety significance and we identified a number of areas for improvement within DRDL’s maintenance arrangements for UFF’s and the management of the MoD/DRDL consignment interface. We are continuing to monitor the issues arising from this incident to ensure improvements are made to both MoD’s and DRDL’s arrangements to prevent a reoccurrence.
9 Dock PCD Inactive Commissioning Pipework System Leaks
We have noted from our inspections that a number of safety indicators for the PCD facility suggest the plant and its operating regime currently falls short of the required levels of performance. In response to our observation HSE-NII, NNRP and Environment Agency inspectors completed joint investigations into a number of reported incidents associated with the commissioning of the new PCD facility. The reported incidents involved the leakage of trace active water from pipework systems.
Although these incidents resulted in little or no nuclear/radiological hazard we believe they could be of concern in relation to the future full operational use of the facility and we have written to the licensee seeking the necessary improvements. We are satisfied that the licensee is treating these matters seriously and will continue to work closely with EA and NNRP inspectors to ensure the necessary improvements are in place prior to release of a regulatory holdpoint for full operational use of the PCD facility.
As part of its regulation under the nuclear site licence HSE-NII issues formal regulatory documents, which include Consents, Approvals, Acknowledgements, Specifications and Notifications.
None were issued during the period covered by this report.
No formal enforcement notices have been issued during the period covered by this report.