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:
1, 4 – 6,14 - 15, 26 – 28 July 2005
10 – 11, 22 – 26, 31 August 2005
1 – 2, 12 – 16, 19 – 23, 28 – 30 September 2005
Other members of HSE-NII, including specialist inspectors also visited the Devonport licensed site during the period. The HSE-NII Superintending Inspector responsible for inspecting Naval Bases and Dockyards visited the site to attend routine regulatory meetings and also lead the inspection of the Devonport Licensed Site re-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) 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).
Following the Level 1 emergency exercise at Devonport in June 2005 we requested the licensee to address the important learning points and to re-demonstrate, through a further emergency exercise, the casualty rescue arrangements. In response the licensee completed a review of the areas requiring improvement and put in place a programme of training exercises with a focus on casualty rescue. We witnessed the repeat emergency exercise on 15 September 2005 and concluded the licensee had provided an adequate re-demonstration
The undocking of HMS Talent following a long overhaul period with refuel (LOP(R)) was successfully completed in early July and the licensee commenced a programme of outage work to confirm the continued validity of the 14 dock safety case for further submarine overhaul and refuel work. The regulatory expectations for the dock outage period were agreed in advance and our inspections focused on the examination, maintenance, inspection and testing (EMIT) activities with a focus on the dock structures and the dock cranes. We were also looking for a number of the Devonport Staged Improvement Plan (SIP) expectations to be delivered during the dock outage. In this respect the licensee progressed with the demolition of the Central Management Office structure and made good progress with the installation of core boronation equipment which will be used prior to all future submarine defuel/refuel operations.
We concluded that the licensee had satisfactorily completed the required routine compliance work (EMIT etc) for 14 dock and had addressed the small number of reported non conformances and emergent issues. We were satisfied with the progress made against the identified Devonport SIP improvements which support the safety case for the docking of HMS Triumph (T7) and commencement of the LOP(R) process. On the basis of these conclusions we provided our agreement to the docking of HMS Triumph (T7) in 14 dock.
We continued to monitor 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 to ensure worker radiation dose levels are properly controlled and reduced to ALARP. A number of joint inspections with the Environment Agency inspector were completed with a focus on completion of inactive commissioning work, maintenance, operator training and operating procedures. The licensee is currently addressing the findings from these joint inspections which we require to be satisfactorily addressed prior to permissioning active use of the facility.
We have received the licensees safety justification for the HMS Victorious refuelling operations. We are currently completing inspection and assessment work which will inform our decision on the release of the formal regulatory holdpoint which is in place to permission the commencement of the refuelling activity
Following our team inspection earlier in the year to review the Licensee’s compliance with the Ionising Radiations Regulations (IRR’s) we have requested an action plan to address the areas for improvement.
The site inspector attended the Local Liaison Committee meeting on 14 July 2005 and made a presentation covering HSE’s work during the last two periods.
The HSE-NII site inspector attended the Environment Agency’s Review of Safety meeting with DRDL on 17 September 2005. This is an example of how the regulatory community at Devonport is working together to improve our impact and effectiveness through the joined up regulation of health & safety.
During the course of our routine business on site, incidents/possible problems arise or are brought to HSE-NII inspector’s attention. These are followed up as considered appropriate and during this period we have reviewed a number of incident reports. The following matter has also been progressed which was in part raised as a result of our investigation into previously reported incidents:
Within our last quarterly report we noted that a number of safety indicators for the 9 Dock PCD facility suggested the plant and its operating regime was currently falling short of the required levels of performance. Although our judgement concluded there was currently little or no impact on nuclear/radiological safety we were concerned the situation could deteriorate if action wasn’t taken.
We have followed up this matter through targeted reactive inspection work and the licensee has presented a recovery plan. We were encouraged that the licensee is addressing the issues generically across the site through a structured health and safety improvement plan with clearly defined outcomes. We are satisfied that the licensee is treating the matter seriously and we will continue to work closely with colleagues from the other regulatory organisations to ensure the necessary improvements are delivered.
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:
No formal enforcement notices have been issued during the period covered by this report.