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 May 2008 the Inspectorate undertook a team inspection with DNSR to examine the site arrangements for following through the causes of incidents and the learning points derived from site investigations. The inspection concluded that the DRDL arrangements met the requirement of the site licence with respect to incident reporting and that it has made considerable progress since the previous operational experience feedback inspection undertaken during March 2005. Some recommendations for improvement were made and will be followed through during the course of routine inspections.
During the financial year 2007/8 HSE/NII was in discussion with DRDL about its programme for decommissioning redundant facilities and equipment on the site. As a result DRDL produced a 5 year decommissioning programme. DRDL has not been able to implement this programme in full although a programme for this year is in place. As a result HSE/NII has written to DRDL pointing out that in the absence of decommissioning it will be necessary to maintain the facilities and equipment in a safe state. The issue was also raised at a meeting to discuss cross site safety matters. DRDL has reiterated its commitment to decommissioning and undertaken to provide appropriate safety justification for those items in the programme that are awaiting decommissioning. This matter will be followed up through routine quarterly inspections.
DRDL is required to have adequate arrangements for handling nuclear emergencies on site through the conditions of the site licence. Similarly, the Naval Base is required under the Radiation Emergency Preparedness and Public Information Regulations (REPPIR) to have an operator’s plan for handling nuclear emergencies on the non licensed part of the Devonport site. HSE/NII is the enforcing authority for both regulations. Devonport has been moving towards matched arrangements for both Naval Base and Licenced Site and a joint demonstration exercise was held in June.
The exercise was well organised with a scenario that presented a suitable challenge to the emergency arrangements. However, on this occasion we considered this to be only just an adequate demonstration of the site’s emergency arrangements. As with all such exercises there were lessons to be learned, the main ones being in relation to access control, deployment of the Fire and Rescue Services and casualty recovery. In respect of the key issues above, HSE/NII and DNSR agreed to take the opportunity of future internal exercises to show how the learning points have been addressed including any re-work of relevant arrangements.
The recently appointed NII Superintending Inspector held discussions with members of the DRDL Senior Management Team and visited the site nuclear facilities for familiarisation purposes on 23rd and 24th June 2008. He also led the team during the annual demonstration exercise on 25th June 2008.
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:
As reported last quarter, 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), now renamed Babcock Marine (Devonport) (BM(D)). BM(D) 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 the Licencee’s 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.
During the quarter HSE/NII continued to discuss 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. However, we considered that there was a requirement for the DRDL board to become more familiar with the requirements of the site licence and to introduce some performance indicators related to the Board’s governance on nuclear matters. HSE/NII is cooperating with DRDL to meet these requirements and expect to issue a Licence Instrument in response to the DRDL application during the next quarter.
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.
No Licence Instruments were issued during the period.
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:
the Health and Safety at Work etc. Act (HSWA) 1974;
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.
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. An enabling activity for the new facilities is the safe removal of the 80Te crane. DRDL have submitted their safety case for its removal and HSE is content with the proposed methodology. 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.
HSE-NII has held a series of meetings to discuss arrangements for the joint Naval Base and DRDL demonstration emergency exercise. The results of the demonstration exercise are reported against the DRDL section of this report.
The recently appointed NII Superintending Inspector held discussions with Senior Naval Base personnel on 23 and 24 June 2008.
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.