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 also from the Internet at www.hse.gov.uk/nuclear/index.htm. The Site Inspector 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 any questions raised there by members. Any other person wishing to inquire about matters covered by this report should contact the HSE’s, Nuclear Safety Directorate on 0151-951-4382.
Nuclear Safety 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 Deputy Chief Inspector responsible for regulating Nuclear Submarine Facilities and Naval Bases visited the site to discuss the sale of the dockyard.
The HSE-NII Superintending Inspector responsible for inspecting Naval Bases and Dockyards visited the site to attend routine regulatory meetings, discussions on the sale of the dockyard and the demonstration emergency exercise.
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) 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).
DRDL submitted a letter of application for the approval under LC11 of a revised Emergency Plan. The plan has been updated to take into account the completion of the new forward command post (FCP) in the Submarine Refit Complex (SRC) and a name change to an organisation that responds in an emergency (Devon Fire and Rescue Service is now Devon and Somerset Fire and Rescue Service). Our inspection concluded that DRDL’s revised Emergency Plan was adequate, representing an improvement in the overall position at Devonport for emergency arrangements. Approval of the revised plan was granted with effect from midnight on 5 th June 2007.
On the evening of 6 th June, the Devonport Site Accident Demonstration Exercise was carried out. The principal objectives of the exercise were to demonstrate casualty response and accountability following an evacuation (including locating missing persons), to demonstrate the use of the new FCP and to test the out of hours response to a Devonport Site Accident. The exercise was witnessed by a joint NII-DNSR team who considered DRDL’s response at the incident site, in the FCP, at shelter stations and in the Devonport Accident Control Centre. Whilst some learning points were evident we considered that there had been a satisfactory demonstration of the arrangements.
A meeting was held with DRDL to plan a series of project meetings to address the assessment of the programme of periodic review of safety submissions. It is expected that monthly meetings will initially be needed with DRDL to plan and organise the regulatory assessment of the submissions. This assessment will be co-ordinated with DNSR to optimise resources
DRDL’s plans for the next two submarine Revalidation and Assisted Maintenance Periods (RAMPs) now show an intention to continue to use 10 Dock for such activities until the end of 2008. This strategy will allow the removal of the 80Te refuelling crane in SRC to proceed in 2008, once HMS Triumph’s refit has been completed, and will bring about a significant nuclear safety improvement to the facility. As a result of this change in docking programme, DRDL produced a modification request to the 10 Dock safety case to allow a second mobile crane to be used to assist the RAMP. HSE-NII and DNSR have sought improvements to the safety justification for this work and carried out a readiness inspection to check the preparedness of DRDL for this work and for use of the dock following other improvement works. We considered that the crane operations had been properly planned and gained confidence that they would be properly controlled and supervised. We also considered that preparatory works for the next docking had been properly completed.
At the end of 2006, we issued a Specification requiring that DRDL should not store radioactive resins in the Modified Magnox Flasks (MMF), or Resin Catch Tanks (RCT) after 31st March 2008. The Specification was intended to help secure acceptable progress towards dealing with this legacy waste issue. We have been disappointed that progress has been held-up by concerns raised during the Periodic Review of Safety for the MODIX plant and by the Licensee’s underestimation of the amount of design work needed for the facility to empty the RCTs. These delays do not yet challenge the completion of the work required to meet the Specification but we will continue to monitor progress .
We undertook an inspection in conjunction with the Environment Agency in the SRC area. This was in part to gain intelligence in advance of a Joint inspection on Waste Management planned for later in the year. In general, our findings were satisfactory although a number of minor matters were raised with DRDL.
During our inspections we have noted that radioactive waste accumulated around the site has been moved through the processing facility and is now stored awaiting disposal. However DRDL has expressed concern that the financial arrangements currently in place are delaying disposal. We intend to follow this matter up in the near future.
We have been discussing the removal of the ion exchange resins held on site. The site have proposed to use a facility to be built at Winfrith, Dorset to process the material prior to storage at the Low Level Waste Repository at Drigg, Cumbria. There are similar wastes at other sites around the UK and we have been encouraging the dialogue between the sites to ensure that the best practical disposal option for the UK is agreed.
We had discussions with DRDL on the plans for decommissioning redundant plant and equipment on the site. While the site plans are at an early stage HSE-NII noted the general direction was satisfactory and that discussions were taking place with the MoD to ensure sufficient funding was in place to enable the plan for the next 5 years to be driven forward. We also discussed and agreed with DRDL the timetable for submissions for Quinquennial review of decommissioning plans
We have been holding regular meetings 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). DRDL continue to make good progress on the project for the design of the Reactor Access House (RAH) which enables defuelling to take place. DRDL is currently planning the project programme in detail with its contractors and will inform HSE-NII in due course whether there is any scope for programme shortening, e.g. through parallel working. DRDL is currently in the tender evaluation phase for the proposals for the removal of the 80Te crane. It is anticipated that DRDL will shortly be in a position to inform HSE-NII on its choice of contractor and the method of removal.
The Ionising Radiations Regulations (IRRs) provide a framework for ensuring that exposure to ionising radiation arising from work activities is kept as low as reasonably practicable and does not exceed dose limits for individuals. This is an area where HSE-NII carries out specific inspections to look in detail at compliance with these Regulations. During May, a joint NII-DNSR inspection was completed across the Devonport site covering the activities of DRDL and the Naval Base. The inspection included co-operation between employers, designation of areas, arrangements for control of radioactive substances, prior risk assessment and restriction of exposure, respiratory protective equipment (RPE), maintenance and examination and radiography.
W e concluded that all areas inspected were in compliance with IRR99 and there were a number of good points in all the areas inspected. In particular, the good co‑operation between DRDL and the Naval Base was a recurring theme throughout the inspection. The single site-wide dosimetry system is a powerful tool for managing and reducing radiation exposure and the functionality of the system is being well used. We also considered the arrangements for control of radiography to be good, noting that this is an area where constant vigilance is required because of the nature of the hazard provided by the radiography sources.
There were a number of areas where improvements should be made, or where the arrangements should be reviewed or clarified; none of these relate to any legislative non-compliance or major safety concerns. In particular, the current arrangements at C2 barriers need to be reviewed as there is potential for smaller items to by-pass the monitoring systems. We considered that the policy for the posting of Local Rules and its implementation should be reviewed as there is inconsistent application at present. There is also a need to review radioactive source holdings. DRDL recognise this need and are planning improvements, which we intend to review during a planned inspection in August.
DRDL has continued to build on the developments in response to our two improvement notices and has co-located the three teams covering safety culture, control of work and excellence in operation. These teams will also address DRDL’s input to HSE-NII’s Safety Performance Indicators initiative. This is a corporate project that seeks to persuade Licensees to develop measures to monitor and review their safety performance.
It was notable that the excellence in operation team has started by tackling a long-standing issue with regard to the condition of workshops facilities/practices through an investment programme and streamlining of working practice (10 Dock is the lead). While this is recognisably a business led effort, the improvements being made are to modernise workshops, which in turn will have benefits for the health and safety of the workforce and help create a working environment that will support the improvement in behaviours being sought by DRDL. It is intended that we will co-ordinate our programme of safety walks in the dock areas to support the excellence in operation team’s initiative.
Babcock International Group PLC announced on 10 May 2007 that the company had entered into an agreement with the current owners for the acquisition of Devonport Management Limited (DML). DML currently undertakes major Nuclear Submarine overhaul and refuelling work for MoD at Devonport via its wholly owned subsidiary company Devonport Royal Dockyard Ltd (DRDL). DRDL is a site licence holder under the Nuclear Installations Act (1965) and certain prescribed activities carried out on the site are regulated by HSE-NII. The nuclear site licence places certain legal responsibilities on licensee organisations and, in particular, covers the requirement for the control of nuclear safety related matters through an appropriate body corporate with suitable leadership and management capabilities. When licensee organisational arrangements are subject to significant change, HSE-NII assesses the proposals paying particular attention to matters including the legal requirements to satisfy the site licence, leadership and management, organisational structures, intelligent customer capability, management responsibilities, nuclear safety competencies, control of work and sufficient relevant nuclear safety knowledge and experience.
HSE-NII has engaged with relevant stakeholders to ensure that any proposed changes are properly conceived and executed such that high standards of nuclear safety performance continue to be secured at Devonport Royal Dockyard. The current position is that the licensee corporate and operational management structures remain unchanged and as such the nuclear safety related activities taking place at the site remain secure through the existing arrangements as regulated and inspected by HSE-NII. Any future changes will be subjected to the site’s Management of Change process which requires that the effect on safety of any changes be assessed.
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).
We have previously reported that we issued an Improvement Notice in November 2006 in order to secure the necessary safety improvements following an incident in the LLRF in Q3 of 2006. This Improvement Notice was served in relation to Licence Condition 10 (Training) with a closing date of 17 th April 2007. In response, DRDL formed a project team which included representatives of the workforce and co-ordinated its improvements with those already underway to address the earlier Improvement notice on Risk Assessment. We have held a number of discussions with these teams to gain confidence that the improvements proposed would satisfy our concerns. DRDL implemented their improvements to the training of those working in the LLRF before the closing date and did not seek an extension to the Notice. They are now extending these improvements to the rest of the Nuclear Submarine Business Unit. We will continue to maintain regular contact with DRDL as these improvements are rolled-out.
A regular part of our normal business on site is to carry out safety inspections with DRDL managers and workforce safety representatives.
During an inspection of work on board HMS Victorious, we identified that it was not readily apparent in a number of compartments how the fire alarm should be activated in the event of a fire. In addition, knowledge of available exit routes shown by some of those on board was poor, as was signposting of exit routes. In response, DRDL agreed to immediately halt all hot work (welding, cutting and grinding) on board and did not restart such work until measures had been put in place to address the concerns, including identifying exit routes, improving knowledge and visibility of fire alarm call points, improved signage and training for the workforce, including those who only work occasionally on board. Recognising that the same concerns applied to other submarines, DRDL took the prudent decision to extend the ban on hot work across the site until similar measures had been implemented. We considered that DRDL’s response was entirely appropriate and is a reflection of improvements in the prioritisation of safety and safety culture that have occurred recently on the site.
A safety inspection was also completed around 9 Dock and in Primary Circuit Decontamination (PCD). In PCD, there was a tolerance of problems caused by the poor ergonomic design of the building and it will be necessary to mitigate some of these before next use of the facility. In 9 Dock, there was a significant amount of clutter (probably a result of the recent purge on storage on the dock bottom) together with a tolerance of poor standards of cleanliness in work areas (particularly the workshop). DRDL quickly attended to the issues bringing about a much safer workshop environment. Safety inspections of both the SRC area and the Nuclear Utilities Building (NUB) were also completed.
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 515 – Approving DRDL’s revised emergency arrangements under LC11(3) was issued on 5 th June 2007
None this period.
HSE-NII site inspectors visited HM Naval Base Devonport on the following dates during this quarter:
This visit was part of the site-wide inspection of compliance with the Ionising Radiations Regulations (IRR) 1999 (see Section 2.1 below).
The HSE-NII Superintending Inspector responsible for regulating Naval Bases and Dockyards visited the Naval Base to discuss the sale of the dockyard.
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.
During May, a joint NII-DNSR inspection was completed across the Devonport site covering the activities of DRDL and the Naval Base. The inspection included, co-operation between employers, designation of areas, arrangements for control of radioactive substances, prior risk assessment and restriction of exposure, respiratory protective equipment (RPE), maintenance and examination and radiography. On the Naval Base, we inspected the arrangements for IRR compliance on operational submarines and on a Long Term Berthed (Fuelled) submarine.
We concluded that all areas inspected were in compliance with IRR99 and there were a number of good points in all the areas inspected. In particular, the good co‑operation between DRDL and the Naval Base was a recurring theme throughout the inspection. The single site-wide dosimetry system is a powerful tool for managing and reducing radiation exposure and the functionality of the system is being well used.
There were a number of areas where we considered that the arrangements should be reviewed or clarified. In particular, we considered that a single system should be used to manage radioactive sources and that holdings of such sources should be reviewed to establish whether they are still required. We also considered that detailed guidance should be provided in the Naval Base Radiological Protection Standing Orders on the requirements for each of two styles of Prior Risk Assessment that are used on the Naval Base.
A planning meeting was attended to discuss arrangements for the forthcoming Short Sermon 07 emergency exercise.
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. A number of submarines are now in storage at Devonport prior to commencement of the Defuel, De-equip and Lay-up Preparations (DDLP) process 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 and we have provided comment on 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.