Office for Nuclear Regulation
An agency of HSE

Devonport Royal Dockyard Ltd., Devonport Royal Dockyard and HM Naval Base Devonport

Quarterly report for 1 October to 31 December 2010

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

Devonport Royal Dockyard Limited

Inspections

The Nuclear Installations Inspectorate Site Inspectors visited Devonport on the following dates during the quarter:

  • 11th to 15th October
  • 9th to 12th and 23rd to 26th November
  • 8th to 9th and 14th to 16th December

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

  • 11th – 15th October
  • 19th to 20th October
  • 9th – 11th November

The Superintending Inspector for Naval Nuclear Propulsion Plant Inspection visited the site on the following dates during the quarter:

  • 11th to 14th October

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.

[Back to top]

Routine matters

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

  • 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 routine inspections at DRDL covered:

  • Operating Rules and instructions
  • Control and supervision of operations
  • Accumulation of radioactive waste
  • Safety cases
  • Safety culture improvement
  • Emergency arrangements including REPPIR
  • Plant modifications
  • Quality assurance
  • Incidents on site
  • Periodic review of safety
  • Control of organisational change
  • Examination, Inspection, Maintenance and Testing
  • Staff training, qualifications and experience

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, HSE/NII has monitored a project to improve safety in the Submarine Refit Complex (SRC). This project, known as ‘Future Nuclear Facilities’, 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.

In December we were informed by DRDL that it wished to review the design of the crane for the RAH and that this was likely to delay an expected request to start manufacture of the RAH, which had been scheduled to start in 2011.  As a result, HSE/NII’s formal assessment of the Pre-Construction Safety Report (PCSR) for the RAH has been put on hold.

Plant modifications

HSE/NII, in conjunction with DNSR, continue to engage with DRDL in relation to a modification proposal to the 9 Dock Plant Safety Case for loads dropped from the dockside cranes.  DRDL has also notified HSE/NII of a high category plant modification which has been indentified in relation to the connection of gas supply rigs to the Nuclear Steam Raising Plant in 9 Dock.  HSE/NII is working in conjunction with DNSR on the assessment of this submission.  HSE/NII agreement to the implementation of the modifications is required to allow the refit to proceed to the next stage.  Requests for agreement are expected before the end of the quarter.

Isolation procedures and control of work

HSE/NII continues to monitor the implementation of an electronic system to control the isolation of systems on board the submarine (known as the Rip Out / Tag Out system).  This provides a safe system of work to ensure the safety of personnel working on systems with electrical or mechanical stored energy. As reported in the last LLC report, an inspection was planned for this period to review the company arrangements for IT development.  The inspection found the arrangements to be in general accordance with standards for the quality assurance of software system development.  A number of further measures were also identified that could enhance the quality of the Rip Out / Tag Out system and DRDL has agreed to implement these.

Periodic review of safety (PRS)

The programme for PRS is considered to be making adequate progress with the generation of improvement plans which are now being implemented. The revised PRS procedures have been issued and the remaining “issues identification” meetings are scheduled for completion in 2011.  However, the PRS programme continues to be of high regulatory interest and will continue to receive attention by HSE/NII in collaboration with DNSR (in relation to the authorised site interfaces) through scheduled quarterly regulator interface meetings.

Emergency arrangements

Emergency exercise “Short Sermon 2010” took place on 12th October 2010. This was a major test exercise to demonstrate both the on-site and off-site arrangements as required by the Site Licence and REPPIR.  A Joint team from HSE/NII and DNSR inspected and assessed the demonstration of on-site nuclear emergency arrangements at Devonport together with the support given by the site to implementation of the off-site plan. A separate HSE/NII team also took part in the exercise as players, both on and off-site.  This demonstration was the first formal demonstration exercise to be undertaken by the site following the development of joint arrangements between DRDL and HM Naval Base Devonport.

Given the extent to which the arrangements had needed amendment to distil two sets of arrangements into a single structure, it was remarkable how well the demonstration was completed. The exercise scenario was realistic and enabled a positive demonstration of those features of the arrangements agreed with the regulators as objectives during the exercise planning discussions. Following the exercise debrief the emergency planning team was congratulated on its achievement.

The exercise direction functioned smoothly and was reactive to decisions being made by the exercise players. This was particularly evident when the decision to declare an off-site incident was taken (for good reason) in advance of the exercise expected time-line. While this decision resulted in early termination of some activities such as the search of the Naval Base evacuation area, the player actions were appropriate to the situation.  The conduct of the exercise players was calm, deliberate and responsive.  Each player contributed effectively to the overall exercise performance.

It was pleasing to note that the site’s self-assessment of the demonstration exercise corresponded closely where observations were made by the regulators. The site also noted other areas for improvement.

Overall this exercise represented the culmination of a very large scale change programme which has been implemented following the adoption of reference accident criteria. This work has resulted in much more effective and robust emergency arrangements, and the exercise demonstrated the operators’ ability to implement these arrangements more than adequately.

HMS Talent docking readiness inspection

HSE/NII conducted a readiness inspection in December for the planned docking of HMS Talent in January 2011.  DRDL’s new Internal Regulator had carried out extensive auditing and review activities in advance of this inspection and they had concluded that the facility was not yet ready.  Further discussions were held with facility staff which supported this view, but a realistic plan did appear to be in place to meet the proposed docking timescales.  A further inspection is planned for early January to confirm operational readiness before the docking is formally permissioned by HSE/NII.

Senior level visits 

The Superintending Inspector visited the site on 11th to 14th October. This was a formal visit arranged to inspect the annual demonstration of the site nuclear emergency response arrangements under LC11 and REPPIR.  He also had separate discussions with DRDL senior management and the Naval Base management team and visited 5 Basin.

[Back to top]

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.

In late October, HSE/NII was informed of the discovery of low levels of tritium in waste water sent for disposal from HMS Trafalgar and further low levels of tritium in tanks on board the submarine.  HMS Trafalgar was docked for lay up preparations and as part of this work, several on board tanks were emptied of their liquid arisings and the water disposed of.  A quantity of water was disposed of via the usual clean route but was subsequently found to have contained very low levels of tritium.  HSE/NII monitored DRDL’s response to this event.  Arrangements are now in place with the Environment Agency to manage these discharges (the Best Practicable Means identified as being as the route that was already being used), so, any future such discharges will follow the same route, but will be fully authorised.

[Back to top]

Regulatory Activity

Under Health and Safety legislation, HSE/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 in safety.

As stated in the last LLC report, the Executive issued an enforcement letter requesting that DRDL write to HSE detailing its recommendations and forward actions in response to the investigation into the contamination incident reported to HSE/NII on 17th May 2010.  DRDL responded to this request in November providing details of its corrective actions in response to the event.  HSE/NII intends to check that the actions have been appropriately implemented.

No Licence Instruments were issued during the period

[Back to top]

HM Naval Base Devonport

Inspections

The Nuclear Installations Inspectorate Superintending Inspector, Nominated Site Inspector and other Inspectors visited HM Naval Base Devonport on the following dates during the quarter:

  • 12th, 13th October 2010

[Back to top]

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. Some of these submarines are defuelled and others contain fuel.

Until the new defuelling 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. We are also satisfied that until such time as MoD declares its submarine decommissioning strategy, submarines can be safely stored at Devonport on an interim basis.  During the reporting period, Devonport has been named as one of the candidate sites for submarine dismantling, the other being Rosyth.  MoD are committed to carrying out public consultation before any major decisions are made. 

Emergency arrangements

Emergency exercise “Short Sermon 2010” was carried out on 12th October 2010.  This is reported in detail in the DRDL section of this report

[Back to top]

Non-routine Matters

There were no non routine matters this quarter.

Incidents

There were no incidents to report this quarter.

[Back to top]

Regulatory and Enforcement Activity

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.

Transforming HSE Nuclear Directorate

HSE’s Nuclear Directorate (ND) continues work on a programme of change entitled 'Transformation' which is intended to help ND realise its aims to become recognised as a world-class regulator. Over the coming months, ND’s focus will include improving the way it engages with all of its stakeholders, including communities around nuclear licensed sites, to explain the work that it does and the regulatory decisions it makes.

ND will keep stakeholders fully informed of changes and any decisions that are made through channels including:

If you have any comments, questions or suggestions regarding ND’s Transformation programme, please get in touch by emailing ONRenquiries@hse.gsi.gov.uk.

Directgov - Business Link

Updated 25.05.12