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.
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:
The Superintending Inspector visited the site on the following dates during the quarter:
The Deputy Chief Inspector visited the site on the following date 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.
IInspections 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 implementation. 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 inspectors 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.
Over a number of years, the Inspectorate has been pressing for the removal of the 80te refuelling crane jib. In late September, DRDL completed its removal as part of a project to improve safety in the Submarine Refit Complex (SRC). This project, known as ‘Future Nuclear Facilities’ is due to be competed in 2012 and will allow defuelling of laid up submarines currently on the Devonport site together with other submarines when they are taken out of service. The project includes a replacement Reactor Access House (RAH) for removing fuel from the reactor, updated operational safety case and other safety improvements. The inspectorate has discussed these in depth with DRDL and is content with progress.
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 wrote 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 reiterated its commitment to decommissioning and has undertaken to provide appropriate safety justification for those items awaiting decommissioning. During the quarter DRDL was able to advance decommissioning and disposal for a few items within their plan and the Inspectorate has been assured that the full programme will be sanctioned in the forthcoming financial year. This matter will be followed up through routine quarterly inspections.
Following intervention by NII in 2005, DRDL has been implementing improvements in the way it controls and supervises work undertaken on the Licensed Site. As part of follow up monitoring of progress an inspection covering the development of arrangements for control of work and relevant Operational Experience Feedback issues was undertaken in 10-Dock. This was a deep/thin slice consideration of a specific group of activities being undertaken at the time. The outcome of the inspection was generally favourable with no serious issues being identified. Some minor issues for consideration were highlighted. These will be followed up with DRDL during routine inspections.
The NII Superintending Inspector visited the site on 2nd and 3rd of July 2008. During his visit he continued his familiarisation with the site and its operations. He attended a meeting on cross site safety matters where he discussed site decommissioning.
The NII Deputy Chief Inspector and Superintending Inspector visited the site on 30th September 2008. They had discussions with DRDL senior management and visited 9-Dock and the SRC where they observed the 80te crane jib on a barge in 15-dock.
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 taken to implement any necessary improvements. Matters of particular note considered during the current period include:
Purchase of DML by Babcock International Group
As reported previously, Babcock International Group PLC through its subsidiary Babcock Marine (Devonport) which wholly owns Devonport Royal Dockyard Ltd (DRDL) undertakes major Nuclear Submarine overhaul and refuelling work for MoD at Devonport. 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 the proposed changes are properly conceived and executed such that high standards of nuclear safety performance continue to be secured at Devonport Royal Dockyard. During the last 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 and addressed.
During this quarter HSE/NII concluded discussions on the 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. 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. DRDL has produced and is implementing a training programme for the DRDL Board. As part of this the NII Site Inspector made a presentation to the DRDL board highlighting its responsibilities in managing a site licence company. HSE/NII has issued a Licence Instrument agreeing to DRDL’s proposal.
Incident Investigation
HSE/NII has been following through the DRDL investigation into an incident which occurred in March 2008 where potentially radioactive steam was released to atmosphere from a portable effluent tank during operations in 9-dock. HSE/NII is satisfied that on this occasion no radioactivity was release with the steam. HSE/NII is content that the DRDL investigation has been thorough and is continuing to discuss with DRDL the actions it will take as a result of the investigation. Following the conclusions of these discussions, HSE/NII will decide, if appropriate, what regulatory action it may take.
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 (Agreement)
‘AGREEMENT TO IMPLEMENT ORGANISATIONAL CHANGE’
was issued on 6th August 2008.
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. This has been reported in the DRDL Section of this report.
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.
During the quarter and following from an event at another site, the Naval Base has discussed with the inspectorate the arrangements to manage and monitor sealed sources on board the laid up submarines. HSE/NII is satisfied that the Naval Base is well placed to discharge its responsibilities.
HSE/NII has held meetings to discuss arrangements aligning Naval Base and DRDL emergency responses.
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.