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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:

• 6th to 8th, 20th to 23rd and 28th to 30th April
• 11th to 14th and 26th to 29th May
• 8th to 12th and 22nd to 26th June

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

• 6th to 8th and 28th to 30th  April
• 27th and 29th May
• 8th to 11th, 24th and 25th June

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

• 8th April
• 23rd and 24th June

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.

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Changes to HSE’s nuclear directorate

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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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
• Duly Authorised and Suitably Qualified and Experienced Persons
• Safety Cases
• Quality Assurance
• Examination, Maintenance, Testing and Inspection

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. The inspectorate has commenced a programme of engagement with DRDL on various safety topics ahead of its formal assessment of the Pre-Construction Safety Report (PCSR) for the RAH. The assessment will ultimately inform the inspectorate’s response to DRDL’s request to commence manufacture of the RAH, which is scheduled to start in 2010.

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 follows from the DRDL decision not to use 10 Dock for submarine routine dockings. The Inspectorate will require DRDL to obtain a Licence Instrument before proceeding. Specialist assessors have completed their assessment of the submission and prepared a list of technical enquiries which have been discussed with DRDL. DRDL is responding to these enquiries and the inspectorate requires the licensee to request a licence instrument ahead of the next scheduled docking in the SRC. The final decision to issue the licence instrument will be informed by a team inspection of DRDL’s preparations for the docking.

The NII has recently issued DRDL with a Licence Instrument that permitted HMS Torbay to enter 15 dock to complete external work which required no intervention in the nuclear steam raising plant. In 14 dock, DRDL is continuing preparatory work on HMS Superb ahead of its berthing in 3 basin.

Radiation Emergency Preparedness Public Information Regulations (REPPIR)

The submarine plant operator submitted Hazard Identification and Risk Evaluation (HIRE) reports in 2002 and 2005 based on methodology used in previous legislation. Using these reports HSE-NII concluded that notwithstanding the use of old methodology, a radiation emergency, as defined by REPPIR, was reasonably foreseeable with a consequence of an airborne contamination release to a distance of 2Km. HSE-NII wrote to the Local Authority advising that they were required to prepare a detailed emergency plan to cover an area of 2km radius centred on the submarine berths.

The Regulators (HSE-NII and MoD) required the MoD duty holders to address the methodologies used in the HIRE and associated Reports of Assessment (ROA) by the next REPPIR submission date. In 2008, the HIRE submissions were very much improved in a number of respects, particularly the clarity of presentation assisted by the adoption of a ‘reference accident’ methodology, in line with the civil sector. It was therefore concluded that the HIRE constituted an appropriate submission in response to REPPIR requirements. As a result, HSE-NII has subsequently determined that the HIRE and ROA at Devonport require the Local Authority to prepare a detailed emergency plan to cover an area of not less than 1.5km centred on the submarine berths.

Emergency Arrangements

On 24th June 2009, a team of HSE-NII and DNSR inspectors observed the Level 1 demonstration emergency exercise. The purpose of the exercise was to demonstrate the adequacy of the dockyard’s emergency arrangements, as required by the Site Licence, to deal with any accident or emergency arising on the site. The exercise was also to demonstrate the adequacy of the Naval Base emergency arrangements made under the REPPIR regulations and as required by the Naval Base Authorisation.

The exercise scenario presented a very challenging test of the emergency arrangements, allowing both the Devonport Site Accident and Reactor Accident responses to be tested in one exercise. On this occasion, most of the features were demonstrated well. The Regulators highlighted the operation of the Devonport Accident Control Centre (DACC) and the Forward Control Point (FCP) to be two areas where a high level of competence was witnessed. It is of significance that the site has introduced a duty senior manager to take the lead in the FCP and this has clearly had a positive influence on the management of the site response.

As with all exercises there were lessons to be learned, the main one for this exercise was the operation of the Access Control Point. This facility is not fully equipped to handle information flow and is physically small for its purpose and therefore its operation did not match the performance level observed in the DACC and FCP. It is noted that there is an opportunity afforded by the REPPIR determination to make better use of existing facilities in revised emergency response arrangements. The Regulators are encouraging the site to take this matter forward.

The regulators noted that the DRDL/Naval Base observations were detailed, comprehensive and self-critical. They aligned well with the regulatory observations and demonstrated the site’s positive learning culture.

9 Dock Safety Case

HSE/NII has completed its targeted assessment of DRDL’s safety case for operations in 9-dock. Some issues were identified most of which were satisfactorily addressed by the licensee. Other issues, that were not significant enough to prevent the issue of a licence instrument against the safety case, are being carried forward with the licensee for resolution in the medium term. An agreement to the continued use of the 9-dock facility was issued on 17 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). The Inspectorate welcomes the site’s commitment to continued improvement in the site safety culture and has continued to monitor and encourage this site initiative.

Isolation Procedures

With the encouragement of HSE/NII, DRDL has carried out a review of its methods and procedures for the implementation of safe systems of work including the isolation of hazardous plant for intrusive maintenance. The licensee has identified areas for development and improvement, and the HSE/NII is keeping itself informed of progress to ensure that its expectations are met.

Maintenance on Site

Between 28th and 30th April NII and DNSR carried out a joint Examination, Maintenance, Inspection and Test (EMIT) themed inspection at DRDL. The inspection sampled DRDL’s EMIT processes and practices which are required to comply with the Site Licence. It was concluded that DRDL were able to demonstrate a basic level of compliance, particularly with respect to the planning the delivery of EMIT, but that there remained several areas where processes and practices should be improved. NII communicated the outcome of the inspection in a letter to the licensee, which confirmed several actions placed on DRDL by the regulators.

Management Arrangements

From 8th to 10th June a joint HSE-NII/DNSR team examined the management arrangements in place on the DRDL site against the recently issued International Atomic Energy Agency (IAEA) standard GS-R3. The team found that all the elements required by the standard were present at the Devonport site. The team noted that the site was considering updating its management arrangements and gave encouragement for this to proceed to more clearly embed the GS-R3 standard in the site’s arrangements.

Senior Level Visits

The Superintending Inspector visited the site on 8th April and 23rd/24th June. He had discussions with DRDL senior management and visited 9-Dock and the SRC. On 23rd and 24th June he led the joint HSE-NII/DNSR team in assessing the site performance at the annual demonstration exercise.

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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:

Incident Investigations - RAH Fire

On 17 June 2009 there was a fire in the air handling unit on the roof of the 9-dock reactor access house. HSE/NII received and considered initial information provided by the licensee and considered that there was no need to carry out an immediate regulatory inspection. HSE/NII has been content to allow the licensee to carry out its own investigation in co-operation with the local fire and rescue service. A follow up inspection was carried out by an HSE/NII fire specialist and a site inspector who are both content that there was no significant nuclear safety hazard and that there remains no requirement for a regulatory investigation.

There were no other significant events in the quarter.

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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	524	Agreement	Agreement to Commencement of Operations in 9 Dock under PSC290.
LI	525	Acknowledgement	Acknowledgement of NED-MNC-240-9595 Interim Safety Justification (ISJ) for Dockings in the SRC Solely for the Purpose of Docking HMS Torbay in order to complete emergent external repairs.

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:

• 8th April

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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) and Demonstration Exercise

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

The Naval Base held a joint emergency arrangements demonstration exercise with DRDL on 24th June. This has been reported in the DRDL section of this report.

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Non-routine Matters

The NII Deputy Chief inspector and Superintending Inspector visited the Naval Base on 8th April 2009. During his visit he had discussions with Senior Naval Base Personnel.

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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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