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 (NII) attends LLC meetings and will respond to any questions raised there by members. Any other person wishing to inquire about matters covered by this report may contact HSE’s Knowledge Centre on 0151 - 951 - 4382.
Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
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 Superintending Inspector responsible for regulating Naval Bases and Dockyards visited the site to attend routine regulatory meetings.
The HSE-NII Deputy Chief Inspector (Defence Installations) 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 Defence Nuclear Safety Regulator (DNSR).
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).
In connection with the recently investigated contamination events (see 3.1.1 below) DRDL has responded positively, setting out a recovery plan to put in place improvements to its safe systems of work. While several changes will address immediate improvements e.g. simplification of the way in which work is controlled by reducing the number of procedures, we are pleased that DRDL has recognised that there are wider issues that need to be tackled. To maximise the engagement of all levels of staff in the process, DRDL management has agreed to involve safety representatives and members of the industrial workforce in developing the revisions to the way work is controlled. HSE-NII sees this participatory and inclusive approach as essential in gaining the confidence and commitment of all those involved. HSE-NII is supportive of DRDL’s approach and sees the work as an important element to enable DRDL to meet its safety performance targets.
DRDL has provided a recovery plan to address the problems that were encountered with the “Continuum” electronic staff accountancy system during the demonstration emergency exercise in May. DRDL has established that there are a number of areas where the “Continuum” system could be improved. Some of these relate to component reliability while others relate to simplification of the volume of data that “Continuum” processes. DRDL is currently evaluating the findings to determine the best way to make the improvements to the staff accountancy process. HSE-NII will continue to review progress of the situation with DRDL, with early completion of the project identified as a priority regulatory objective.
We welcome the development that DRDL is to start decommissioning the redundant core pond facility and is continuing to remove legacy waste from the Submarine Refit Complex (SRC) for processing and long term storage off site. DRDL’s plan to make use of the 80Te refuelling crane to facilitate this work is supported as it simplifies the heavy lifts that are needed. Our main reservation is that some of this work should have been started earlier and it would appear not all of it will be complete before the refuelling crane is taken out of service. This will therefore require development of an alternative lifting technique and we have requested DRDL to provide details of its plans for these activities.
A meeting was held with the DRDL team responsible for the delivery of the Future Nuclear Facilities project (i.e. the provision of a low level de-fuelling facility in SRC, removal of the 80 Te refuelling crane and modern standard Fleet Time Docking Facility) to establish working level contacts between DRDL and HSE-NII. Meetings will be held on a monthly basis as we anticipate that DRDL will quickly mobilise contractors. HSE-NII will shortly identify project hold points to regulate the project. We expect to receive Preliminary Safety Cases from DRDL, for the safe removal of the 80Te refuelling crane and for the new de-fuelling facilities before the end of 2006. This project is important, as it will provide the new facilities to de-fuel redundant submarines and a modern standard facility for the fleet time docking of submarines.
Following the removal of the Central Management Offices (CMO) building in Submarine Refit Complex DRDL has been renewing rock anchors that locate the dock structures into the ground. In 5 Basin our civil engineering inspector has conducted a number of inspections of the installation of the rock anchors and is content that the work is being carried out to a high standard, to ensure that a satisfactory factor of safety is retained.
Following our team inspection in 2005 to review the licensee’s compliance with the Ionising Radiation Regulations (IRR) we are progressing the close out of recommendations for improvement through the agreed action plan. While the licensee’s progress in completing most actions is satisfactory, response to some actions has been slow.
The HSE-NII Devonport nominated site inspector participated in HSE-FOD’s Working at Height Seminar in July at Devonport.
During the course of our routine business on site, incidents/possible problems arise or are brought to HSE-NII inspector’s attention. During this period we concluded our follow-up of the contamination events in 9 dock previously reported in the Q2 LLC report and initiated an investigation into an event in the Low Level Refuelling Facility (LLRF) that was reported to HSE-NII in July.
In July (Q2 LLC report) it was reported that preliminary inquiries were carried out by HSE-NII to obtained detailed information associated with two separate, but related events where two fitters and a health physics monitor had been contaminated. It should be noted that the results from whole body monitoring indicated that the doses received in these events were very small and did not warrant immediate enforcement action. However, we expect high standards of nuclear safety performance to be maintained and our inquiries revealed shortfalls in DRDL’s safe system of work arrangements with regard to the way in which risk assessments are completed in relation to the work being carried out.
On further investigation into the events, we determined that improvements identified following similar events that had occurred in 2003 did not appear to have been implemented effectively. While DRDL responded positively in July to the letter written by HSE-NII with a recovery plan to make a number of improvements, we judged that an increased level of enforcement action was needed to address the shortfalls. Accordingly, an Improvement Notice was served on 16 th August 2006 to address risk assessment associated with the work that had led to the reported events. We agreed to a period of 4 months for the Licensee to deliver the necessary improvement.
During the period, DRDL reported to HSE-NII that a heavy lift of a component had been made in the Low Level Refuelling Facility (LLRF) that had apparently exceeded the declared Safe Working Load for the lifting equipment. No immediate enforcement action was necessary by HSE-NII as DRDL itself had made the equipment safe and stopped all work in the facility. Our initial investigations confirmed that while, on this occasion, there was no nuclear or radiological hazard, there appeared to have been the potential for a conventional safety hazard to the operators, should the lifting equipment have failed. The equipment is designed and used for nuclear safety-related operations and of serious concern was that a safety mechanism (interlock) should have prevented any possible overloading of the lifting equipment.
Further investigation led us to formally interview the licensee’s managers and operators of the facility. We found that the operators had overridden a safety mechanism, believing erroneously that components of the mechanism had been removed for maintenance. We also established that the design of the crane and the lifting equipment was engineered with factors of safety that exceeded the stated safe working load by a considerable margin. We therefore concluded that a failure of the lifting equipment was remote such that the actual risk to the operators was negligible. We are now in the final stages of drawing together the findings from our investigation in which we have identified several breaches of health and safety and nuclear safety law. While the event in itself held no danger for the public or the workforce, the behaviour of the operators was potentially unsafe and inappropriate. We have concluded that enforcement action is necessary and are preparing an Improvement Notice to address shortfalls identified from our investigation.
As part of its regulation under the nuclear site licence HSE-NII issues formal regulatory documents, which include Consents, Approvals, Acknowledgements, Specifications and Notifications.
No formal regulatory documents have been issued during the period covered by this report.
Improvement Notice I/2006/ND/PJH1 was served on 16 th August 2006 following our investigation into the 9 dock containment contamination events (see paragraph 3.1.1). The Notice has a completion date of 15 th December 2006.
HSE-NII site inspectors and specialist inspectors visited HM Naval Base Devonport on the following dates during this quarter:
5 and 11 July 2006
6 and 7 September 2006
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.
The HSE-NII Superintending Inspector responsible for regulating Naval Bases and Dockyards met with MoD personnel in routine regulatory meetings.
The HSE-NII Deputy Chief Inspector (Defence Installations) met with MoD personnel in routine regulatory meetings.
MoD activities, at HM Naval Base and Devonport Royal Dockyard, are inspected under the Health and Safety at Work Act (1974), the Radiation Emergency Preparedness and Public Information Regulations 2001, (REPPIR), and the Ionising Radiation Regulations (IRR) 1999.
The actions from the 2005 IRR team inspection were closed out satisfactorily during this period
Nothing to report this period.
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. HMS Spartan arrived at Devonport in Q1 for storage prior to commencement of the Defuel, De-equip and Lay-up Preparations (DDLP) and HMS Sovereign arrived in Q3. There are now three redundant submarines in storage at Devonport awaiting 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 DDLPs were to be carried out at Devonport until the installation of new facilities to bring about a low level defuelling route were 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. However, detailed design and safety case work is now underway and we expect to receive Preliminary Safety Cases from DRDL, for the safe removal of the 80Te crane and for the de-fuelling facility before the end of 2006. In addition, contracts are now being placed for the main elements of the programme. As noted in Section 2.2 of the DRDL part of this LLC report, a regulatory strategy for engaging with these projects is being developed. The most recent MoD programme suggests that the new facilities can be completed by 2012 and we are pressing for improvements to this timescale. 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.
No formal enforcement notices were issued by HSE-NII during the period.