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’s Superintending Inspector for the Naval Nuclear Propulsion Programme attended the site on 15th October, 11th and 12th November 2008.
NII’s Deputy Chief Inspector for Defence Sites attended the site on 11th and 12th November 2008.
Inspections are undertaken at site as part of the process for monitoring compliance with:
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.
HSE/NII undertook a joint Operational Readiness Inspection, with the Defence Nuclear Safety Regulator (DNSR). This examined BAESM’s readiness, in terms of people, plant and process for 2nd Hot Operations for HMS Astute. This included reviewing the site’s performance against a range of licence and authorisation conditions. Additional visits followed up the issues raised at this inspection, including discussions on control of work initiatives in the commissioning organisation, maintenance schedules and arrangements, the status of the safety cases and revalidation of elements of the primary circuit supports. Having gained the necessary assurance, HSE/NII issued a Licence Instrument Agreement to allow 2nd Hot Operations to proceed.
Regular updates were received on progress towards improving the learning from experience systems. This remained an area of regulatory concern during the reporting period, with little evident progress on delivering planned improvements. It is hoped that improvements made since December will put the improvements back on track.
Discussions were held with BAESM regarding their initiatives relating to control of work on Boat 3. We were impressed by both the knowledge and enthusiasm of those we spoke to and could also see how the ongoing initiatives to introduce lean manufacturing processes should have a positive safety benefit.
NII and DNSR assessed the site Emergency Exercise INDIGO 08. Whilst the exercise overall was considered to be a satisfactory demonstration of the site’s emergency arrangements, we require the site to re-demonstrate some elements of their plan in the next quarter.
The final inspection this quarter was the first in a series of joint NII / DNSR Operational Readiness Inspections to gather evidence for permissioning of HMS Astute Phase 7 (Power Range Testing). We looked for suitable progress in site arrangements and close out of issues already raised from our safety case assessment process. Further inspections are planned to gain the confidence needed to allow this activity to proceed.
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, HSE/NII started an independent investigation following an incident related to site radiography.
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.
On completion of a series of inspection and assessment activities related to the commissioning of the first of the Astute class submarines, NII issued LI 505, entitled Agreement to Astute Initial Active Commissioning 2nd Hot Operations on 18th December 2008.