BAE SYSTEMS Marine Limited, Devonshire Dock Complex, Barrow-in-Furness: Local Liaison Committee

Quarterly report for 1 January 2009 to 31 March 2009

Inspections
Routine Matters
Non Routine Matters
Regulatory Activity

Foreword

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 website.

Site Inspectors of HM Nuclear Installations Inspectorate usually attend LLC meetings and will respond to questions raised there by members of the LLC.

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Inspections

The Nuclear Installations Inspectorate (NII) Site Inspector made inspections on the following dates during the quarter:

13th to 15th and 26th to 29th January
9th, 19th and 24th to 26th February
25th and 31st March

NII's Deputy Chief Inspector for Defence Sites attended the site on 24th February 2009.

NII's Superintending Inspector for the Naval Nuclear Propulsion Programme Inspection Unit attended the site on 19th and 24th February 2009.
Other NII specialist inspectors visited the site on 26th to 29th January, 17th and 24th to 26th February and 2nd to 4th and 31st March.

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Routine matters

Inspections are undertaken at site as part of the process for monitoring compliance with:

the conditions attached by HSE/NII to the nuclear site licence;
the Health and Safety at Work etc Act (HSWA) 1974; and
regulations made under the HSWA for example the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999.

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:

Radiological protection
Incidents on the Site
Staff training, qualifications and experience.
Emergency preparedness
Plant construction and/or commissioning
Examination, Maintenance, Inspection and Testing.
Management of operations including control and supervision
Radioactive waste management
Decommissioning
Organisational Changes.
Quality Assurance and records.
Meeting Safety Reps

In general the arrangements made and implemented by BAE SYSTEMS Marine Ltd (BAESM) 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.

The principal focus of inspections at Barrow during the first part of 2009 has been to determine BAESM's readiness in terms of plant, people and process for Power Range Testing (PRT) on HMS Astute, the first Astute Class submarine. PRT is the final stage of commissioning the reactor systems, including the lead up to the first criticality and subsequent full power operations. Together with the Defence Nuclear Safety Regulator (DNSR), a series of inspections have been carried out which included reviewing the site's performance against a range of licence and authorisation conditions and close-out of issues raised during our safety case assessment process. A key part of the inspections has been building confidence in the site's own arrangements for determining their own readiness and for ensuring that the commissioning operations will be carried out such that the potential hazards are properly managed and controlled. Having gained the necessary assurance, we anticipate issuing a Licence Instrument in the near future to allow PRT to proceed.

Regular updates have been received on progress towards improving the site's learning from experience systems. Significant progress has been evident over recent months with the key elements of a working system now in place. We will be looking in the coming months to ensure that these improvements become embedded and are sustained so that the nuclear safety and business benefits can be realised.

NII and DNSR assessed the site Emergency Exercise INDIGO 08 in November 2008. Whilst the exercise overall was considered to be a satisfactory demonstration of the site's emergency arrangements, we required the site to re-demonstrate some elements of their plan. This was done in the first quarter of 2009, to the satisfaction of both regulators.

We carried out a team inspection of Examination, Inspection, Maintenance and Testing (EIMT) inspection with DNSR, looking at both site and reactor plant maintenance arrangements and practices. In preparation for the inspection, the BAESM's internal regulator had undertaken a detailed investigation. We were encouraged by the process for maintenance verification that has been developed and is being rolled out. We recommended that BAE consider the benefits that may be delivered from the appointment of an overall Maintenance Authority Role, to provide a degree of coordination, and policy guidance in the EIMT field. As a related issue, we advised that BAE consider the establishment of a maintenance forum to assist with coordination and coherency in respect of the dissemination of best practice in EMIT across the site. Both NII and DNSR considered that our inspection complemented and was consistent with the findings of the internal regulator's inspections, providing a level of assurance in the functioning of the internal regulator.

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Non-routine matters

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 completed an independent investigation following an incident related to site radiography. As a result of this and the site's own investigation, improvements have been made to strengthen arrangements for handover of areas from production to radiography.

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Regulatory activity

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. No LI or enforcement notices were issued to the licensee during the quarter

Changes To HSE's Nuclear Directorate

In early 2008 the Government initiated a review into the UK's nuclear safety regulatory regime, led by Dr Tim Stone. The recommendations and the UK's Government response were published at the end of January 2009. One of the major recommendations is the decision by Government to establish the Health and Safety Executive's (HSE) Nuclear Directorate (ND) as a Statutory Corporation under the auspices of the HSE.

The creation of this new, autonomous body, (which will continue to incorporate the Office for Civil Nuclear Security and the UK Safeguards Office) will facilitate a more sustainable approach to regulating nuclear safety and security within a rapidly changing global nuclear environment and recruitment of high calibre of staff within a hardening market place for highly specialised skills.

The restructuring will not change the substance or standards of regulation or compromise the independence of the nuclear regulatory body, and will not affect the decisions it takes or the international obligations the Government requires it to meet.

Enabling work continues for the initial scoping and planning of the work-streams and programmes necessary for the Statutory Corporation to come into being from April 2010. This project has required the temporary enhancement of ND's senior management capability in order to deliver existing regulatory work and to create the Statutory Corporation.