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) visited 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 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.
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 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 monitored 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. As part of updating the safety case, the inspectorate has been considering a submission from DRDL to justify routine submarine docking in the SRC docks. This justification will require DRDL to obtain a Licence Instrument from the Inspectorate before proceeding and follows from the DRDL decision not to use 10 Dock for submarine routine dockings. The inspectorate has discussed the justification and the updated operational safety case 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 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. DRDL has confirmed its commitment to decommissioning and has proposed a programme of work to justify 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. Waste management matters are followed up through routine quarterly inspections. In the last quarter the Inspectorate, while content with progress in some areas, has been disappointed in progress in others.
DRDL has submitted its operational safety case for undertaking submarine refuelling and refurbishment work in 9-Dock. This safety case has been enhanced with experience gained during work on previous submarines. HSE/NII has acknowledged receipt of the safety case and has agreed to preliminary work proceeding while assessment of the safety case is completed by a joint HSE/NII and DNSR assessment team. It is expected that, subject to the satisfactory completion of the assessment process, HSE/NII will issue an agreement to continued use of the 9-Dock facility during the forthcoming quarter.
Following interventions by HSE/NII in 2005, DRDL has been implementing improvements to the safety culture for work on the Licensed Site. This was implemented through a major initiative led by senior site personnel through a Safety Culture Improvement Team (SCIT). This initiative has coincided with a reduction in the site accident rate. In recent months, members of the SCIT have been transferred to in-line duties and the Inspectorate has been concerned that the improvement process could lose direction. DRDL has recognised the potential for this to occur and has indicated that replacement effort will be transferred into the SCIT. The Inspectorate welcomes this commitment to continued improvement in the site safety culture.
The HSE/NII Superintending Inspector visited the site on 1st October 2008. During his visit, he met with senior members of site management. At the meeting, DRDL and the Inspectorate formally reviewed the site safety performance during the previous year. The NII Assessment Superintending Inspector also attended this meeting.
The HSE/NII Chief Inspector and his assistant Inspector visited the site on 17th September 2008. They had discussions with DRDL and Naval Base senior management and visited the laid-up submarines, an operational submarine, 9-Dock and the SRC. They observed the docking of HMS Vigilant in 9-Dock, discussed the removal of the 80te crane at the SRC and discussed items of mutual interest with the Captain and crew of the operational submarine.
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:
The nuclear site licence places certain legal responsibilities on licensee organisations. 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.
DRDL has indicated that it intends to reduce its workforce and has informed the Inspectorate that as a result of the workforce reduction, there will be a number of change proposals that will require regulatory attention. The Inspectorate has received a preliminary proposal in the area of emergency arrangements and is in discussion with DRDL on that proposal. The Inspectorate has also undertaken an on-site Inspection of DRDL’s arrangements and intervened with DRDL to ensure its management of change proposals will take account of regulatory expectations.
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 has discussed the actions placed as a result of the report with DRDL. HSE/NII has therefore decided that it will take no formal regulatory action other than to follow through the satisfactory completion of the DRDL actions.
HSE/NII was also made aware of the spillage of radioactivity into the Hamoaze during operations on the Naval Base. The equipment in use and which resulted in the spillage is also used on the Licensed Site. NII has therefore monitored the progress of the Naval Base Investigation to ensure any lessons learned are applied to the Licensed Site.
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.
The following Licence Instruments were issued during the quarter:
| LI | 520 | Acknowledgment | Acknowledgement of 9 Dock Vanguard Class Submarine LOP(R) Facility Plant Safety Case NED -PSC - 290 Under Licensees Arrangements |
| LI | 521 | Agreement | Agreement to Commencement of Operations in 9 Dock for Nodes 1 to 3 Under PSC290 |
| LI | 522 | Acknowledgement | Acknowledgement Of Submitted Category A Modification/Experiment On Existing Plant |
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.
HSE/NII has held meetings to discuss arrangements aligning Naval Base and DRDL emergency responses.
As reported in the sections of the report related to DRDL, the NII Chief inspector visited the Naval Base on 17th October 2008.
HSE/NII continue to monitor the response and investigation of the spillage to the Hamoaze in respect of its application to the DRDL Licensed Site. The activity released by the spillage was significantly below the levels that would require the Naval Base to report the matter to HSE/NII. Nevertheless the Naval Base has continued to keep HSE/NII informed on the matter.
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.