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, 19, 27 October 2005
1, 8 – 9, 14 – 18, 21 - 22 November 2005
5 – 7, 12 – 16 December 2005
Other members of HSE, including specialist inspectors also visited the Devonport licensed site during the period.
HSE’s Director of Resources and Planning visited Devonport during the period. The visit was part of a series of visits to help HSE Board Members gain a better appreciation of the sites regulated by HSE and to build on key stakeholder relationships.
The Defence Division Deputy Chief Inspector made a routine visit to the Devonport Licensed Site and Naval Base during the period for discussions with senior management. A site visit was also completed focusing on Staged Improvement Programme projects including the Central Management Office demolition, the installation of the core boronation facility for HMS Triumph and the provision of a new SRC Forward Command Post.
The HSE-ND Superintending Inspector responsible for inspecting Naval Bases and Dockyards visited the site to attend routine regulatory meetings and also lead the annual review meeting.
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).
We completed a compliance inspection of the Licensee’s LC 6 (Documents/ Records) and LC 17 (QA) arrangements which also included a review of the close-out process for plant modifications under LC 22. In summary we found there was a clear focus on quality within DRDL through application of a well designed Business Management System that meets the requirements of national and international standards. The control of documentation has continued to develop with good progress made in dealing with legacy records. The inspection identified a number of areas for improvement and we have requested the licensee to submit an action plan to address them.
The annual review meeting took place during the period and was preceded by a site visit which focused on the general plant condition and progress with the Staged Improvement Programme (SIP) projects. The meeting discussed and agreed the regulatory strategy and priorities for the next 12 month period and beyond. In order to bring about closer co-operation and joined up regulation we invited representatives from both the Environment Agency and the Naval Nuclear Regulatory Panel as observers. The feedback to this initiative was positive and in the future we are considering having formal joint regulator review meetings with the licensee.
The purpose of the 9 dock Primary Circuit Decontamination (PCD) facility is to decontaminate the reactor primary circuit to ensure worker radiation dose levels are properly controlled and reduced to ALARP. During the period further inspections were completed with the Environment Agency relating to the commissioning of the facility. We were satisfied with the licensee’s responses and following the issue of our agreement to the commencement of PCD active commissioning, two process cycles were applied to the HMS Victorious reactor primary circuit. The decontamination process was successful and a reduction in average doserate (including steam generators) by a factor of approximately 7 was achieved (average doserate reduced from 178 to 26 micro Sv/hr). The dose reduction was in line with expectations and gives a working environment with lower average doserates than was achieved for the previous LOP(R) on HMS Vanguard.
We have received the licensee’s 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 that is in place to permission the commencement of the refuelling activity.
A radiological protection specialist inspector completed inspections relating to DRDL’s proposal to change their Approved Dosimetry Service (ADS) to BIL Solutions Ltd and to start using versions of the Electronic Personal Dosimeter as the legal dosimeter.
HSE’s inspection focused on:
The inspections didn’t identify any significant issues and it is expected the proposed changes to dosimetry arrangements will take place early in 2006.
Following our team inspection earlier in the year to review the Licensee’s compliance with the Ionising Radiations Regulations (IRR’s) we are progressing the satisfactory close out of recommendations for improvement through the agreed action plan.
The site inspection team met with the site safety representatives. The issues discussed included:
We have followed up the radwaste management team inspection findings against the schedule of agreed actions. We are satisfied that progress is being made and a number of actions have been cleared. The Licensee has updated the Site Inspector on progress made against the HSE/NII quinquennial review of decommissioning proposals. Some progress has been made in establishing a decommissioning programme. In particular the Licensee has indicated progress in developing a process to encapsulate and dispose of some waste resins held on site.
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 which were categorised of low safety significance. We are satisfied that the licensee is using the operational experience feedback process to identify areas for improvement and the learning process is helping to prevent repeat events.
We have also followed up the licensee’s implementation of the site structured Health and Safety Improvement Plan which was put in place in response to a number of control of work related events earlier in the year. We are generally satisfied with the progress to date and continue to monitor the outcomes closely, investigating as necessary any relevant events that may arise. However some recently reported minor incidents may indicate the need for the Licensee to revisit its improvement plan to improve the areas dealing with control of work. We have written to the licensee regarding this matter.
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) Licence Instrument Number 507 was issued to Devonport Royal Dockyard Limited on 2 November 2005 providing the Health & Safety Executives Agreement to the commencement of Active Commissioning of the 9 Dock Primary Circuit Decontamination (PCD) Facility.
No formal enforcement notices have been issued during the period covered by this report.
HSE-NII site inspectors and specialist inspectors visited HM Naval Base Devonport on the following dates during this quarter:
19, 27 October 2005
1, 9 November 2005
14 December 2005
A number of meetings were held with MoD personnel, primarily relating to the MoD’s arrangements for dealing with redundant nuclear submarines at Devonport and emergency arrangements.
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.
Following our team inspection earlier in the year to review the Licensee’s compliance with the Ionising Radiations Regulations (IRR’s) we are progressing the satisfactory close out of recommendations for improvement through the agreed action plan.
A Naval Base Nuclear Reactor Accident Redemonstration Emergency Exercise took place on 19 October 2005 and was witnessed by a joint HSE-NII and NNRP team. The overall exercise objective was to demonstrate a revised plan for dealing with medical aspects of a reactor accident following the identification of shortfalls in this area at Short Sermon 04. In conclusion we judged that the Naval Base had provided an adequate redemonstration of their emergency arrangements in relation to REPPIR expectations and in particular the medical shortfalls identified from Short Sermon 04.
Planning discussions took place in relation to the annual Kismet emergency exercise which is programmed to take place in early 2006.
HSE-NII has continued to monitor the MoD’s progress towards implementation of the strategy for dealing with laid up submarines at Devonport prior to the commencement of decommissioning. We attend the monthly steering committee meetings and progress to date is satisfactory. HSE-NII is satisfied that the redundant submarines currently at Devonport are stored safely.
No formal enforcement notices were issued by HSE-NII during the period.