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:
A member of the Health and Safety Commission visited Devonport during the period and participated in the LLC meeting on 17th January 2007.
Other members of HSE, including specialist inspectors also visited the Devonport licensed site during the period.
The HSE-NII Superintending Inspector responsible for regulating Nuclear Submarine Facilitiesand Naval Bases 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).
A number of inspections were completed in relation to an application by DRDL for our agreement to proceed with cutting the Main Seal Membrane on HMS Triumph; this activity signifies the start of refuelling of the submarine. Our inspection included a sample of training modules, examination questionnaires, commissioning records and the observation of a training module being given. Our Agreement to the above activity was provided through the issue of a Licence Instrument on 8th February 2007.
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 issues have been satisfactorily addressed.
As part of the visit by the Health & Safety Commissioner, we carried out an inspection of the provision of cooling water for decay heat removal in 10 Dock. Adequate cooling of the reactor core is a fundamental nuclear safety requirement and the compliance inspection focussed on the operator’s familiarity with the safety case. DRDL staff demonstrated good knowledge of the level of cooling needed, the alternative supplies of water, the procedures needed to restore cooling should water supplies fail and the configuration of the supplies as needed by the safety case. A number of minor conventional safety concerns were noted whilst visiting the dock and dock bottom.
We joined an inspection led by DNSR to check that the lessons learned from the experience of refuelling HMS Victorious had been incorporated by DRDL in planning the loose article control safeguards to be implemented during the refuelling operations on HMS Triumph. We were content with the efforts that have been made by DRDL to capture the lessons from recent events and to improve procedures before starting to refuel HMS Triumph.
We completed inspections in facilities on the site that handle radioactive waste. We noted that a campaign within DRDL to address waste accumulation had been successful as there was a temporary increase in the volume of waste being handled in the waste management buildings. We noted that the NEMSFAC area appeared to be relatively free of accumulated waste. A more extensive inspection on waste management by HSE-NII, DNSR and the Environment Agency is planned for later in the year.
HSE-NII has held separate meetings with DRDL and the Trade Union safety representatives, regarding two proposed changes, firstly to merge the operational and maintenance departments and secondly rationalise shift patterns. DRDL’s arrangements under LC36 apply an integrated safety management approach that considers aspects wider than nuclear and radiological safety expected under the licence.
In reviewing the two associated changes we identified areas for improvement in relation to; recording the decisions made about how the change is categorised (in particular to nuclear safety), the accessibility for a reviewer to detailed supporting documentation for the proposed change, and the need for detail about the training plan for staff taking up new roles. DRDL have recently discussed its implementation plan with us and we concluded that there were no nuclear or radiological safety reasons to prevent the changes from proceeding. The points raised by the inspection will be picked up later in the year in the context of a follow-up inspection in relation to Training (LC10), Duly Authorised/Suitably Qualified and Experienced Personnel (LC12) and Control of Organisational Change (LC36).
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). The project is progressing well with three major contracts now in place. 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 have been 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.
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 to an event in the Low Level Refuelling Facility (LLRF) and a contamination event in NEMSFAC.
During Q3 - 2006, 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 (November 2006) in relation to Licence Condition 10 – Training with a closing date of 17th 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 a 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 to report that DRDL is co-ordinating these further improvements with those already underway to address the earlier Improvement Notice on risk assessment. Based on the progress made and the information given to us by DRDL we are confident that the improvements in progress should address the Improvement Notice on training. We will continue to maintain regular contact with DRDL as the improvement plan is extended outside the LLRF.
We carried out a follow-up to an initial investigation into a low-level worker contamination event within the NEMSFAC and reviewed DRDL’s internal investigation and follow-up proposals.
A number of areas have been identified for improvement by DRDL, including control of work, training, procedures and material control. We have considered the event in relation to the HSE Enforcement Management Model and concluded that additional enforcement action at this stage would not be warranted. This is because DRDL has committed to address the findings from the event, through extending the specific improvements identified in the two recent improvement notices, to the other related areas on the nuclear licensed site.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 514 – Agreement to the activity to commence the Main Seal Membrane (MSM) cut on HMS Triumph in 14 Dock was given on 8th February 2007.
None this period.
HSE-NII site 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 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.
In conjunction with the visit to DRDL a Health & Safety Commissioner held discussions with the Naval Base Commander and the Naval Base Safety team.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. During 2006 HMS Spartan arrived at Devonport for storage prior to commencement of the Defuel, De-equip and Lay-up Preparations (DDLP) with further submarines expected to be taken out of service in the forthcoming period. 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 contracts have now been placed for most of the main elements of the programme and that funding for the work is established. As noted in Section 2.2 of the DRDL part of this LLC report, we are engaging with DRDL on a regular basis as this important project proceeds. 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.