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 Local Liaison Committee and covers activities associated with the regulation of safety at the Devonshire Dock Complex, Barrow-in-Furness. These reports are distributed quarterly and are also available on the HSE’s web site at http://www.hse.gov.uk/nuclear/llc/index.htm. Site Inspectors of HM Nuclear Installations Inspectorate usually attend LLC meetings and will respond to questions raised there by members of the LLC. Any other person wishing to enquire about matters covered by this report may 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 (NII) Site Inspector made inspections on the following dates during the quarter:
18th April 2008
22nd to 24th April 2008
6th May 2008
19th to 21st May 2008
5th June 2008
10th to 12th June 2008
NII’s Superintending Inspector for the Naval Nuclear Propulsion Programme attended the site on 6th May 2008. Other NII inspectors attended site on 23rd April and 19th to 21st May 2008.
Inspections are undertaken at site as part of the process for monitoring compliance with:
(i) the conditions attached by HSE/NII to the nuclear site licence;
(ii) the Health and Safety at Work etc Act (HSWA) 1974; and
(iii) regulations made under the HSWA for example the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999.
This entails monitoring licensee’s actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and any other matters which may affect safety. The licensees/operators are required to make and implement adequate arrangements under the conditions attached to the licence in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation. In this period inspections at the Devonshire Dock Complex covered:
In general the arrangements made and implemented by BAE SYSTEMS Marine Ltd in response to safety requirements were deemed to be adequate in the areas inspected. However, where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from the licensee, and the site inspector will monitor progress during future visits. Where necessary, formal regulatory enforcement action will be taken to ensure that appropriate remedial measures are implemented to reasonably practicable timescales.
An inspection was completed to establish the adequacy of BAE SYSTEMS Marine Ltd’s arrangements under Licence Condition 17 (Quality Assurance), and to benchmark the arrangements against the requirements of the relevant IAEA Safety Standard. In the areas inspected it was clear that BAE SYSTEMS Marine Ltd operates adequate arrangements and these in the main satisfy the requirements of the benchmark standard. Where improvements are required, these areas had already been recognised and improvement programmes are in place that are starting to deliver.
A joint inspection was carried out with the Defence Nuclear Safety Regulator (DNSR) and inspectors from BAE’s internal regulator (Nuclear Safety Regulation Department) into the arrangements for training and competency, for the appointment of Duly Authorised Persons to control and supervise operations and for control of organisational change. The improved process that is currently being introduced to identify and manage the competencies needed for particular roles and any training gaps shows promise and NII will continue to monitor its implementation. It was also confirmed that the expected elements of a process for appointing Duly Authorised Persons are in place and are being properly managed. In addition, much progress was evident in developing a baseline organisational structure from which BAE SYSTEMS Marine Ltd can assess the potential impact on nuclear safety of any proposed organisational changes.
Discussions were held with BAE SYSTEMS Marine Ltd, Cumbria County Council, DNSR and the Ministry of Defence to discuss requirements for an off-site plan covering the Operational Berth at Ramsden Dock which is used by submarines on leaving the Barrow Docks system. This describes the management arrangements and emergency procedures for the protection of the public in the extremely unlikely event of an accident involving the nuclear reactor whilst the submarine is at Ramsden Dock. Further discussions are planned to discuss and agree the extent of testing of the integration of the arrangements at Ramsden Dock with those on the Barrow site.
At specific points in the submarine build programme, BAE SYSTEMS Marine Ltd assess their progress against specified criteria before allowing progression to the next build stage. NII monitored this review to gain confidence in BAE’s internal process. We were satisfied with the level of scrutiny and challenge and the evidence base required to allow activities to proceed to the next stage.
Licensees are required to have arrangements to respond to non-routine matters and events. NII inspectors judge the adequacy of the licensee’s/operators response including actions taken to implement any necessary improvements.
During the reporting period, there have been further emergent build quality issues. NII has monitored BAE Systems’ response to these and we are satisfied that appropriate controls have been put in place to ensure that nuclear safety is maintained.
Under Health and Safety legislation NII Site Inspectors, and other HSE Inspectors, may issue formal documents to ensure compliance with regulatory requirements. Under nuclear site licence conditions HSE/NII issues regulatory documents, which either permission an activity or requires some form of action to be taken; these are collectively termed Licence Instruments (LI). In addition inspectors may issue enforcement notices to secure improvements to safety.
No LI or enforcement notices were issued to the licensee during the quarter.