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 web site 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.
L20 7HS
The Nuclear Installations Inspectorate (NII) Site Inspector made inspections on the following dates during the quarter:
NII’s Superintending Inspector for the Naval Nuclear Propulsion Programme Inspection Unit attended the site on 11th May 2009.
Other NII specialist inspectors visited the site on 1st, 2nd and 21st to 23rd April, 7th, 19th, 20th and 21st May and 10th, 23rd, 24th and 25th June.
Inspections are undertaken at site 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 inspections at the Devonshire Dock Complex covered:
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 reporting period has continued to be to gain assurance of BAESM’s readiness in terms of plant, people and process to carry out 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 earlier operational readiness inspections. Although NII anticipated issuing the necessary Licence Instrument at the end of the last reporting period, delays to the Boat 1 programme and emergent issues (such as the fire on the bridge fin on 18th April, see below) have meant that this permission to proceed has not been granted whilst we monitored BAESM’s recovery actions and extra measures to ensure that PRT can be carried out safely. Having gained the further assurance we sought, we anticipate issuing a Licence Instrument in the near future to allow PRT to proceed.
BAESM conducted an in-depth investigation to establish the root causes of the Bridge Fin fire on HMS Astute. The interim report suggested that control of work issues may be a contributing factor. This was a particular concern to both the Licensee and Regulators, as we needed to gain assurance that work is adequately controlled in the approach to and during PRT. BAESM’s internal regulator instigated a reactive audit to “provide assurance and objective evidence that sufficient checks and balances are in place to demonstrate that Control of Work arrangements are robust and consistently applied leading into Power Range Test Activities.” NII sampled the audit process and drew confidence that it was examining and questioning relevant staff, processes and procedures. We were able to gain assurance that appropriate control of work processes are in place, and that team leaders and managers were taking clear steps to strengthen some of the key barriers that ensure work is properly controlled.
The site is required to have arrangements for control of organisational change. We have inspected these arrangements against NII’s published guidance and identified shortfalls. We will be working with the site to get an agreed way forwards to improving the arrangements.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. There were 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. 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.
The Government has put forward proposals to change the status of HSE's Nuclear Directorate (ND) to that of a Statutory Corporation under the auspices of the HSE. This is intended to enable ND, as the independent nuclear regulator of safety and security, to better meet the challenges of a changing nuclear industry over the coming years. The changes are to provide the nuclear regulator with greater flexibility and increase the accountability, transparency and openness of nuclear regulation. The Government are proposing that the statutory changes needed to bring this about will be made by a Legislative Reform Order (LRO).
This builds on the outcome of the Government initiated review of the UK's nuclear regulatory regime, led by Dr Tim Stone. The Summary Recommendations and the Government’s response were published at the end of January 2009 (available on HSE’s website: http://www.hse.gov.uk/nuclear/stonereview.htm).
A public consultation, run by DWP and DECC, on the LRO was launched on June 30th for a 12 week period, which gives the opportunity for stakeholders to comment on the proposals.
For access to this consultation please see http://decc.gov.uk/en/content/cms/consultations/hse_restruct/hse_restruct.aspx.
These new arrangements 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.
Subject to the outcome of the consultation and Parliamentary approval, and if the Parliamentary timetable permits, the aim is to bring the new body into being during 2010.
An internal change programme is currently operating within ND to ensure that the ND is ready to operate as a statutory corporation from spring 2010.
This programme does not in anyway compromise the current regulatory activities of ND.
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The licensing of nuclear
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ONR Corporate plan 2011-2015