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:
http://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 Knowledge Centre on 0151 951 4382.
The Nuclear Installations Inspectorate (HSE-NII) site inspectors made visits to Devonport on the following dates during this quarter:
Other members of HSE, including specialist inspectors also visited the Devonport licensed site during the period.
The HSE-NII 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. The meeting focused on providing feedback from an HSE-NII commissioned stakeholder survey on the quality of regulatory interactions.
The HSE-ND Superintending Inspector responsible for inspecting Naval Bases and Dockyards visited the site to attend routine regulatory meetings.
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 followed up on the recommendations made during the HSE-NII/NNRP control of work team inspection (2005). Some progress had been made in key areas however we noted further issues and inconsistencies with differing levels of compliance and practices adopted across site. We noted the improved nuclear facility access arrangements that have been put in place to ensure all workers, particularly contractors new to the site, are briefed on safety and quality expectations prior to commencing any work.
Our findings related to:
We will continue to progress the recommendations made following the team inspection, using enforcement action as necessary, to secure the required improvements.
A Specification was issued under LC28 (2) for DRDL to submit its maintenance policy to NII for formal Approval. This regulatory approach is consistent with that adopted by NII for other licensees. Documentation to support the issue of an Approval is being progressed.
2.2 Inspection of Major Project work
9 Dock - Reactor Access House/Refuelling Safety Case
We completed our assessment of the licensee’s safety justification for the HMS Victorious refuelling operations and concluded that the improvements implemented since the last use of the facility were in line with ALARP requirements. We also completed sampling inspection work that focused on the training of the refuelling teams and the human factors aspects of the refuelling process. The licensee satisfactorily addressed the issues categorised as essential for further operation of the facility. Further improvements to the refuelling arrangements continue to be pursued, against agreed timescales, through our normal regulatory business. A Licence Instrument Agreement was issued allowing the refuelling process to commence through release of a formal regulatory holdpoint.
14/15 Dock - Reactor Core Boronation Facility
We completed our assessment of the DRDL Plant Modification Proposal for HMS Triumph (T7) core boronation. Our assessment concluded the proposal was satisfactory and we issued a Licence Instrument Agreement allowing DRDL to implement the modification. The core boronation process took place in March 2006 and represents a significant improvement to nuclear safety and secures a consistent approach across the Devonport dock facilities for the overhaul and refuelling process. The addition of boron to the reactor coolant ensures that the reactor core exhibits a margin to criticality (Keff) in line with internationally accepted standards.
2.3 Compliance with the Ionising Radiations Regulations (IRR’s) 1999
Approved Dosimetry Service
Following our inspections and agreement, DRDL completed the change to their Approved Dosimetry Service (ADS) supplier to BIL Solutions Ltd and started using the Electronic Personal Dosimeter as the legal dosimeter. We are satisfied that the revised arrangements continue to meet the IRR legal requirements.
Team Inspection
Following our team inspection in 2005 to review the Licensee’s compliance with the Ionising Radiations Regulations (IRR’s) we are progressing the close out of recommendations for improvement through the agreed action plan. The licensee’s progress to date is satisfactory.
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.
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.
HSE-NII site inspectors and specialist inspectors visited HM Naval Base Devonport on the following dates during this quarter:
A number of meetings were held with MoD personnel, primarily relating to the MoD’s arrangements for dealing with redundant nuclear submarines at Devonport, the naval nuclear propulsion programme balance of investment project 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.
Nothing to report this period.
Emergency Arrangements Demonstration Exercise – Kismet 2006
The annual Naval Base Nuclear Reactor Accident Demonstration Emergency Exercise took place on 8 March 2006 and was witnessed by a joint HSE-NII and NNRP team. The exercise scenario was defined and agreed in advance using the emergency planning matrix which ensures key areas of the arrangements are exercised periodically. Following the exercise we judged that the Naval Base had provided an adequate demonstration of their emergency arrangements in relation to REPPIR requirements.
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.
During the period a further redundant submarine (HMS Spartan) arrived at Devonport for storage prior to commencement of the Defuel, De-equip and Lay-up Preparations (DDLP).
To comply with Government policy, the MoD is required to de-fuel the redundant submarines, that have left operational service with the Royal Navy, as soon as reasonably practicable.
As previously reported to the LLC the current DDLP facilities are coming to the end of their operational life and HSE-NII gave notice to the MoD and DRDL that no further DDLP’s were to be carried out at Devonport until the installation of new facilities to bring about a low level defuelling route was complete. A number of the improvements are still to be delivered including removal of the existing refuelling crane and installation of a new reactor access house. The most recent MoD programme suggests that the new facilities can be completed by 2012 and we are pressing for improvements to this timescale which is currently subject to pressure on MoD budgets. Until the new facilities are brought into service we are satisfied that, subject to satisfactory monitoring arrangements, the redundant submarines can be safely stored in a fuelled state at Devonport on an interim basis.
We attended meetings and workshops with MoD associated with the development of a Naval Nuclear Propulsion Programme (NNPP) Staged Improvement Programme (SIP). This is a development of the successful Devonport SIP process that has and continues to be used to manage improvements to facilities at Devonport.
No formal enforcement notices were issued by HSE-NII during the period.