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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 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.

Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS

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Devonport Royal Dockyard Limited

Inspections

The Nuclear Installations Inspectorate Site Inspector(s) visited Devonport on the following dates during the quarter:

• 20th to 23rd and 26th to 31st January
• 23rd to 26th February
• 17th to 19th and 23rd to 25th March

Specialist inspectors carried out inspection on the following dates during the quarter:

• 26th to 28th January
• 4th, 5th and 17 to 19th March

The Superintending Inspector visited the site on the following dates during the quarter:

• 21st, 27th and 28th January

The Deputy Chief Inspector visited the site on the following date during the quarter:

• 21st January

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.

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.

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Routine Matters

Inspections at Devonport Royal Dockyard Ltd are undertaken as part of the process for monitoring compliance with:

1. conditions attached by HSE/NII to the nuclear site licence;
   
2. the Health and Safety at Work etc. Act (HSWA) 1974 and;
   
3. 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 routine inspections at DRDL covered:

• Reporting of site incidents
• Control of isolations
• Training
• Operating Rules and instructions
• Nuclear Safety Committee
• Emergency arrangements
• Commissioning
• Organisational Change
• Control and supervision of operations
• Periodic review of safety
• Management arrangements
• Warning signs
• Leakage and Escape of Radioactive Material
• Modification or experiment on existing plant

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.

Site Developments and Future Nuclear Facilities

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. Specialist assessors have completed their initial assessment of the submission and NII has engaged with DRDL in dialogue that will inform the inspectorate's decision to permit routine dockings in the SRC. The NII has recently issued DRDL with a Licence Instrument that permits HMS Superb to enter 14 dock so that it may be prepared for berthing in 3 basin.

Emergency Arrangements

In HSE/NII's report for April to June 2008, HSE/NII noted that 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 had been addressed including any re-work of relevant arrangements. During the quarter HSE/NII witnessed a shift exercise of the site emergency arrangements and were satisfied that this demonstrated that the identified learning points had been addressed.

9 Dock Safety Case

Last quarter DRDL submitted its operational safety case for undertaking submarine refuelling and refurbishment work in 9-Dock. This safety case had been enhanced with experience gained during work on previous submarines. In October 2008, HSE/NII acknowledged receipt of the safety case and agreed to preliminary work proceeding. Regulatory assessment of the safety case is now progressing and 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 early in April 2009.

Site Safety Culture

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, the SCIT has been revitalised with the appointment of a new team leader and the introduction of other new personnel. The site has launched its new safety campaign under the banner title ‘QUEST' and published its safety vision and desired behaviours in a small booklet. The Inspectorate welcomes the site's commitment to continued improvement in the site safety culture.

Senior Level Visits

The HSE/NII Deputy Chief Inspector and Superintending Inspector visited the site on 21st January 2009. During their visit, they met with senior members of site management. At the meeting, DRDL and the Inspectorate formally reviewed the site safety performance since Deputy Chief Inspector's previous visit and discussed the future direction of DRDL's nuclear business.

The Superintending Inspector also his visited the site on 27th and 28th January 2009. He had discussions with DRDL senior management and visited 9-Dock and the SRC.

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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 response including actions taken to implement any necessary improvements. Matters of particular note considered during the current period include:

Management of Organisational Change

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.

DRDL put forward three proposals to reduce its workforce. The Inspectorate received and discussed these proposals with DRDL and with a number of DRDL Safety Representatives. The Inspectorate has agreed with DRDL that there will be measures of performance on the implementation of the proposals. These indicators will be monitored by DRDL and the Inspectorate. As reported in the last quarter, the Inspectorate has also undertaken an on-site Inspection of DRDL's arrangements and has agreed with DRDL that the site baseline safety organisation will be reviewed to take account of regulatory expectations.  

Incident Investigations

As reported previously, HSE/NII was 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 and has met with DRDL to ensure lessons learned are applied to the Licensed Site.

DRDL has advised HSE/NII that during work in the reactor compartment of a nuclear submarine in 5 basin, two workers were slightly contaminated both internally and externally. The external contamination was discovered at one the Installed Personnel Monitors (IPM) that are used to routinely monitor all persons after work in radiation controlled areas. Internal contamination was subsequently detected using whole body monitoring facilities on the site. HSE/NII inspectors attended site to discuss the incident with key personnel. The level of contamination is significantly below the limits at which the employer is obliged to notify the regulator. HSE/NII is satisfied that the health physics systems used by the site to detect the contamination and the actions taken by the health physics personnel immediately following the incident were appropriate. DRDL continues to investigate the circumstances that led to the contamination and is taking action to prevent a similar incident.

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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 take; these are collectively termed Licence Instruments (LI). In addition, Inspectors may issue enforcements notices to secure improvements in safety.

The following Licence Instrument was issued during the quarter:

LI

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Acknowledgement

Acknowledgement of NED-MNC-240-9595 Interim Safety Justification (ISJ) for Dockings in the SRC Solely for the Purpose of Docking HMS Superb in 14 Dock with Decay Heat At or Below 6Kw. In Order to Complete Preparations for Its Fuelled Long Term Berthing (LTB) Under Licencee's Arrangements.

No enforcement action was taken at DRDL during this period.

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HM Naval Base Devonport

Inspections

The Nuclear Installations Inspectorate Site Inspector(s) made an inspection to HM Naval Base Devonport on the following date during the quarter:

• 20th and 21st January 2009.
• 17th March 2009.

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Routine Matters

MoD activities, at HM Naval Base and Devonport Royal Dockyard, are inspected as part of the process of monitoring compliance with:

1. the Health and Safety at Work etc. Act (HSWA) 1974;
   
2. regulations made under HSWA for example the Radiation Emergency Preparedness and Public Information Regulations 2001, (REPPIR), and the Ionising Radiation Regulations (IRR) 1999.

Redundant Submarines

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.

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.

Nuclear Accident Response Organisation (NARO)

HSE/NII has held meetings to discuss arrangements aligning Naval Base and DRDL  emergency responses.

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Non-routine Matters

The NII Deputy Chief inspector and Superintending Inspector visited the Naval Base on 21st January 2009. During their visit they had discussions with Senior Naval Base Personnel.

The Naval Base has continued to keep HSE/NII informed on the investigation of the spillage to the Hamoaze in respect of its application to the DRDL Licensed Site.

HSE (NII and Field Operations Directorate) attended a safety coordination meeting with the senior Site Safety Representatives and both the DRDL and Naval Base Safety Directors. The meeting is held regularly to discuss progress on safety matters on the site.

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Regulatory activities

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.

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