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.
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:
NII Mechanical Engineering and Quality Assurance Specialist inspectors attended site on 2nd July. A NII Radiation Protection Specialist Inspector visited the site on 9th September.
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.
A joint inspection of the site’s arrangements for control of work was carried out with both DNSR and BAE SYSTEM Marine’s internal regulator NSRD (Nuclear Safety Regulation Department). The inspection covered the Dockyard Test Organisation (DTO), Reactor Test Group (RTG) and reactor build activities on Boat 3. A number of significant improvements in the site’s arrangements were evident since the last control of work inspection.
An inspection of Maintenance Arrangements was carried out. This included a follow up of issues identified during a previous inspection in 2007 and a sampling of maintenance tasks and associated records. Whilst minor areas for improvement were found, the arrangements were found to be adequate.
Discussions were held with BAE SYSTEMS Marine Ltd and the Environment Agency on the progress in decommissioning of the Nuclear Facilities Barge, covering waste management issues and control of the decommissioning process.
Further discussions were held with BAE SYSTEMS Marine Ltd, Cumbria County Council, DNSR and the Ministry of Defence to agree requirements for an off-site plan covering the Operational Berth at Ramsden Dock which is used by submarines on leaving the Barrow Docks system. Discussions were also held with the site about the Emergency Exercise, planned for November 2008. The discussions covered the exercise scenario and which elements of the emergency plans would be demonstrated.
A meeting was held to review progress made against the actions that arose from the IRR99 inspection in 2007. Adequate progress is being made, and a further meeting to check progress is planned for the next quarter.
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 was an event on the Nuclear Facilities Barge, where a contractor was using a tool, without following all of the BAE SYSTEMS Marine’s procedures. NII is satisfied that the Licensee took prompt action to ensure that the correct procedures are used in the future decommissioning of this facility.
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