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 Devonport. These reports are distributed quarterly and are also available on the HSE’s website 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 HSE’s Nuclear Directorate on 0151 951 3484/3290.
Nuclear Directorate
Health & Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
The Nuclear Installations Inspectorate Site Inspector(s) made inspections to Devonport on the following dates during the quarter:
Specialist inspectors carried out inspection on the following dates during the quarter:
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 at Devonport Royal Dockyard Ltd are undertaken 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 implementations. In this period routine inspections at DRDL covered:
In general the arrangements made and implemented by the site 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, or are being sought from the licensee, and the site inspector(s) 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.
In January 2008 NII and DNSR completed a joint team inspection of the processes controlling work on submarines in dock at Devonport. The inspection concluded that improvements made by DRDL during 2007 have been effective in improving safety awareness when conducting nuclear safety related work.
In December 2006 NII issued a specification to DRDL instructing it to cease the use of Modified Magnox Flasks (MMFs) and Resin Catch Tanks (RCTs) for the storage of resins after 31st March 2008. The Specification was issued to help secure acceptable progress towards dealing with legacy waste. An inspection was held at the end of the quarter that confirmed DRDL had met the requirements of the Specification and is now storing the resin in Resin Storage Vessels.
Licensees are required to have arrangements to respond to non-routine matters and events. NII inspectors judge the adequacy of the licensee’s response including actions take to implement any necessary improvements. Matters of particular note considered during the current period include
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 the 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. Recent interactions with DRDL senior management have taken place to offer advice from a regulatory perspective, relating experiences from similar changes of ownership and from licensee changes resulting from the establishment of the Nuclear Decommissioning Agency (NDA). During this quarter DRDL submitted a proposal under LC 36 to make changes at a senior level in the company reflecting the establishment of Babcock Marine. The proposal has been subjected to the site’s Management of Change process which requires that the effect on safety of any changes be assessed. While we are currently discussing some details of the proposal with the Company we are content that the licensee’s 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.
Four events reported on the licensee’s event reporting system were selected for follow-up with an HSE-NII radiological specialist. DRDL were found to have conducted thorough investigations that sought to determine the cause of the events and to identify reasonably practicable improvements. DRDL’s progress with the implementation of the findings from the events will be monitored on a routine basis.
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 take; these are collectively termed Licence Instruments (LI). In addition Inspectors may issue enforcements notices to secure improvements in safety.
Licence Instrument 518 – An agreement to install the pressure hull insert using the 43 Te Dockside Crane following deboronation.
No enforcement action was taken at DRDL during this period.
The Nuclear Installations Inspectorate Site Inspector(s) made an inspection to HM Naval Base Devonport on the following date during the quarter:
MoD activities, at HM Naval Base and Devonport Royal Dockyard, are inspected as part of the process of monitoring compliance with:
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, which 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. We continue to engage 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.
There are no items of particular note during the current reporting period.
Under Health and Safety legislation NII Site Inspectors, and other HSE Inspectors, may issue formal documents to ensure compliance with regulatory requirements or may issue enforcement notices to secure improvements in safety.
No enforcement action was taken at HM Naval Base Devonport during this period.