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 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 also from the Internet at http://www.hse.gov.uk/nuclear/index.htm. Site Inspectors of HM Nuclear Installations Inspectorate (part of the Health and Safety Executive’s Nuclear Directorate) attends LLC meetings and will be happy to respond to questions raised by members. Any other person wishing to inquire about matters covered by this report should contact the HSE’s, Nuclear Directorate on 0151-951-3484/3290.
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.
The HSE-NII Chief Inspector visited the site to attend routine regulatory meetings.
Specialist Inspectors completed inspections in relation to:
Construction records
Operating rules and Instructions
Some of the inspections were carried out with inspectors from the Ministry of Defence internal regulatory organisation, the Defence Nuclear Safety Regulator (DNSR) and the Environment Agency.
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 on from the inspections made by our civil engineering inspector of the installation of new rock anchors in 5 Basin we inspected the records of construction and confirmed that the records appear to be to a good standard.
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 completed the evaluation of the system and we understand DRDL will now implement improvements to the accountancy system and process. We expect these improvements to have been successfully completed in time for the demonstration emergency exercise planned for June 2007. 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 agreed to the docking of HMS Spartan in 15 Dock to allow it to complete hull integrity work in preparation for its lay-up prior to DDLP on 29 November 2006. The activity was permissioned once we were satisfied with a number of safety improvement related deliverables.
As part of the inspection made jointly with DNSR in June 2006, HSE-NII commented that DRDL’s internal guidance on the formulation of Operating Rules should be consistent with international good practice. As part of a recent review we found DRDL’s updated guidance to be much improved and our points to have been addressed.
We participated in a joint inspection, led by DNSR, of the arrangements and their implementation, for completing maintenance across the site. Overall the maintenance arrangements are well organised, robust and implemented in a consistent manner. Maintenance, release and reinstatement of systems appeared to be well managed and there is a good process for corrective actions and for records keeping. Particular strengths are the computer-based maintenance records system (MAXIMO) and the central maintenance management team. It was also pleasing that progress made since the Improvement Notice in 2003 has been sustained.
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. As reported in the Q3 LLC we had reservations that some of this work should have been started earlier and that it appeared that not all of it would be complete before the refuelling crane is taken out of service.
In order to help secure acceptable progress towards dealing with the legacy waste we completed further negotiations with DRDL and issued a specification requiring that DRDL should not store radioactive resins in the Modified Magnox Flasks (MMF), or Resin Catch Tanks (RCT) after 31 st March 2008. We will monitor DRDL’s progress towards compliance with this Specification.
We have been holding meetings with DRDL on a monthly basis with the 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). In November we received the Preliminary Safety Report (PSR) for the project and in early December DRDL gave NII and DNSR a presentation on the proposed design for the defuelling facility. 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 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 remains slow.
The HSE-NII Chief Inspector visited the HSE Plymouth office in October and participated in a routine liaison meeting with HSE staff.
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 followed up the licensee’s response to the Improvement Notice served in relation contamination events in 9 dock and progressed our investigation into an event in the Low Level Refuelling Facility (LLRF).
In July 2006 (Q2 LLC report) it was reported that preliminary inquiries were carried out by HSE-NII to obtain detailed information associated with two separate, but related events where two fitters and a health physics monitor had been contaminated. 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. While DRDL responded positively in July 2006 to the issues raised 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.
Since August 2006 regular meetings have been held with the team that DRDL formed to address the safe system of work and the Improvement Notice. In December we inspected the changes DRDL has implemented and found that DRDL has responded positively to the improvements we sought and has made significant progress. We are content that DRDL’s revised work processes for producing risk assessments, briefing workers on the risk assessments and controlling access to the radiological areas on the submarine are much improved and that the requirements of the Improvement Notice have been met. We are also confident that DRDL will now complete the improvements across other nuclear-implicated work on the licensed site. We will continue to monitor DRDL’s progress with this task over the coming months .
During Q3 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 investigations 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. While the event in itself held no danger for the public, or the workforce, the behaviour of the operators was potentially unsafe, inappropriate and not to the high nuclear safety standard performance we expect.
We concluded that enforcement action was appropriate to secure the necessary safety improvements and accordingly, an Improvement Notice was served in relation to Licence Condition 10 – Training with a closing date of 17 th April 2007. Subsequently we met with DRDL to discuss the licensee’s initial response and noted the intention to put in place a dedicated project team. We stressed the importance of forming the team that was representative of the workforce and the importance that the response provided by the team was owned and endorsed at the highest level in DRDL. We are pleased that DRDL has recognised the need to co-ordinate these further improvements with those already underway to address the earlier Improvement Notice (see 3.1.1 above). We will continue to have regular contact with DRDL as work progresses over the coming months .
We carried out an initial investigation into a low-level worker contamination event within the NEMSFAC and reviewed DRDL’s internal investigation follow-up proposals.
Our initial view is that some of the issues emerging relate to basic housekeeping, management of materials records and control of work. At this time we are looking for DRDL’s investigation to complete before deciding whether we need to instigate any further regulatory action.
As part of its regulation under the nuclear site licence HSE-NII issues formal regulatory documents, which include Consents, Approvals, Acknowledgements, Specifications and Notifications.
Licence Instrument No 511 – Agreement to the docking of HMS Spartan in 15 Dock was given on 29/11/06.
Licence Instrument No 513 - Specification on the storage of Resin Waste in MMFs and RCTs was issued on 8/12/06 with a compliance date of 31/03/08.
Improvement Notice I/2006/ND/MJM1 was served on 13 th November 2006 following our investigation into the event in LLRF (see paragraph 3.1.2). The Notice has a completion date of 17 th April 2007.
HSE-NII site inspectors visited HM Naval Base Devonport on the following dates during this quarter:
3 and 18 October 2006
1, 14 and 29 November 2006
13 December 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 and balance of investment project.
The HSE-NII Superintending Inspector responsible for regulating Naval Bases and Dockyards visited the Naval Base to attend routine regulatory meetings.
The HSE-NII Deputy Chief Inspector (Defence Installations) met with Naval Base staff at a routine regulatory meeting.
The HSE-NII Chief Inspector visited the Naval base to attend a routine regulatory meeting.
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.
Nothing to report 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. 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 development is now underway as we have now received the Preliminary Safety Cases from DRDL, for the safe removal of the 80Te crane and for the de-fuelling facility. We understand that the main contracts have now been 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.