Health and Safety
Executive / Commission
Nuclear
LLC reports
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. These reports are distributed quarterly and are available from the Internet at:
http://www.hse.gov.uk/nuclear/llc/index.htm
The Site Inspector of HM Nuclear Installations Inspectorate attends LLC meetings and will be happy to respond to any questions raised there by members. Any other person wishing to enquire about matters covered by this report may contact HSE’s Knowledge Centre on 0151 951 4382.
The Nuclear Installations Inspectorate (HSE-NII) site inspectors made visits to Devonport on the following dates during this quarter:
Other members of HSE, including specialist inspectors also visited the Devonport licensed site during the period.
The HSE-NII Superintending Inspector responsible for inspecting Naval Bases and Dockyards visited the site to attend routine regulatory meetings and the demonstration emergency exercise.
Specialist Inspectors completed inspections in relation to:
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 (EA).
Inspections are undertaken for the purposes of monitoring compliance with the conditions attached by HSE-NII to the nuclear site licence, together with other relevant statutory provisions of the Health and Safety at Work etc. Act (1974).
Following an inspection in 2005 we have been progressing the closure of the inspection findings. DRDL’s OEF process continues to develop and we are pleased with the way in which it has been made easier to report events across the Devonport Site and the initiatives taken to make staff aware of and to encourage their use of the system. While the majority of the events reported are of low or no nuclear safety significance, it is important that they are used to learn and to make improvements. We will continue to encourage the further development of the OEF system to ensure the information that is reported is used to best effect to improve safety. We have recently asked DRDL to compare its OEF process against the recently published relevant good practice in the IAEA safety standard NS-G-2.11.
We carried out a team inspection with DNSR, of DRDL’s arrangements that ensure its staff are suitably qualified and experienced and that for specific safety critical roles it has a robust process to duly authorise staff. While we found that DRDL were generally compliant and that the licensee has made important improvements in the development of its corporate arrangements, we identified a few areas where we considered further improvements should be made. We found that further improvement is needed in its training database in the identification of data inconsistencies to correct errors and data omissions. We have also asked DRDL to ensure that independent checks are included in the process for the appointment of DAPs. We also considered that DRDL’s plan to roll out its Systematic Approach to Training (SAT) to be under-resourced and its implementation taking too long. We have asked DRDL to review the situation and provide us with an action plan so that we can progress the substantial completion of these items by the end of 2006.
As part of an HSE-NII wide review of the nuclear industry’s compliance with LC 23 and 24 we carried out an inspection of DRDL’s Operating Rules and Operating Instructions in the SRC and 9/10 Dock. We found that, while there are some good practices, DRDL’s approach is different from the relevant good practice international standard. DRDL is to update its internal guidance on the derivation of Operating Rules over the next few months and we will be advising the licensee on how to achieve consistency with the relevant good practice international standard IAEA NS-G-2.2 to meet our expectations. We have also asked that DRDL review its current Operating Rules and Identified Operating Instructions as part of an ongoing safety case update process and to move towards a positive demonstration of Operating Rule compliance. We have written to DRDL to seek an improvement plan to meet these expectations.
The control and accountancy of materials and equipment during refuelling is essential to ensure the future through life safe operation of the reactor. DRDL provided an excellent open presentation to HSE-NII, DNSR and British Energy (BE) on its arrangements for Loose Article Control (LAC). BE hope to apply some of the good practices observed at Devonport to the refuelling activities planned for Sizewell B nuclear power station in autumn 2006. DRDL will participate in a reciprocal inspection at Sizewell B that will be arranged to maximise the learning opportunities.
The training arrangements, both for LAC and for the refuelling process in general, appeared to meet relevant good practice. We were impressed with the 26 weeks training that is provided using the Reactor Access House (RAH) over the mock-up core to dry-run the refuelling procedures and the way that the MOD’s Central Plant Control Authority (CPCA) independently vets and approves the DRDL refuellers to underpin the DRDL in-house approval arrangements.
The Devonport demonstration emergency exercise was held on the 25th of May. DNSR participated in the inspection team. While DRDL’s performance showed a marked improvement from last year in the areas of casualty handing and team response, problems with the automated staff accountancy system “Continuum” presented considerable challenges during the exercise. We also found scope for improvement in contamination control and use of barriers at the Forward Control Point.
Despite the challenges presented by Continuum we concluded that there had been a satisfactory demonstration of the arrangements. We have asked DRDL to address the issues with the “Continuum” system and to provide a recovery plan. Until such time that the recovery plan is complete we will expect DRDL to utilise its manual back-up accountancy system, which we witnessed to be adequately demonstrated on the day of the exercise.
Following the earlier (December 2005) inspection of QA arrangements DRDL have addressed a number of the issues, including licence condition compliance credits from audits. Action tracking of regulatory issues was also inspected and NII/DRDL are exploring ways of improving the process for identifying issues. We will monitor progress and undertake a follow up inspection in this area later in July.
The Primary Circuit Decontamination (PCD) facility was used by DRDL to successfully reduce worker dose rates by factors of about 5 prior to the start of the refit of HMS Victorious. After finishing using PCD DRDL intend laying-up the plant until the next LOPR in 9 Dock. HSE-NII has been pressing DRDL to ensure that it puts in place an effective maintenance regime, for the lay-up period and to make improvements to its alarm management system to bring it up to a relevant good practice standard.
Following an inspection by HSE-NII in March 2006 DRDL has clarified its lift plan arrangement for the heavy lifts using the 14/15 Dock 80te crane. These plans include procedures that have helped to make clear when action must be taken by the crane driver to stop the crane, should there be a problem with communications between the banksman, directing the lift, and the crane driver. We wrote to DRDL in April expressing our satisfaction with progress and our contentment for DRDL to authorise the lifts.
Following our team inspection in 2005 to review the licensee’s compliance with the Ionising Radiation Regulations (IRR) we are progressing the close out of recommendations for improvement through the agreed action plan. The licensee’s progress to date is satisfactory.
The HSE-NII Devonport nominated site inspector held a coordination meeting with the HSE-FOD area office Plymouth to discuss inspection priorities. HSE-NII will participate in HSE-FOD’s Working at Height Seminar in July at Devonport and support HSE-FOD’s initiative with large employers to reduce accident rates over a five-year period. HSE-FOD’s plan is consistent with HSE-NII’s commitments to Government (Public Service Agreement (PSA) 2) that seek a reduction in nuclear accident precursors.
During the course of our routine business on site, incidents/possible problems arise or are brought to HSE-NII inspector’s attention. During this period we followed up the following events that had occurred in 9 and 14 Dock.
9 Dock: HSE-NII and EA jointly reviewed DRDL's investigation into an event involving a minor spillage of primary circuit liquor, due to the failure of a manometer connection that occurred on 8 March 2006. While DRDL’s investigation appeared to be thorough identifying shortfalls in its safe system of work arrangements, DRDL did not go as far as setting out how it would convert its recommendations into specific actions to address the problems found.
14 Dock: More recently HSE-NII and EA discussed EA’s findings following the completion of an investigation into a recent event in 14 Dock where a small but detectable quantity of active liquor was found on the dock bottom. HSE-NII and EA concluded that the events in 9 and 14 Dock were similar and that they appeared to indicate problems with DRDL’s safe systems of work. EA served a Site Warning to DRDL.
Preliminary inquiries were carried out by HSE-NII to establish some of the facts associated with two separate, but related events where two fitters and a health physics monitor had been contaminated. While the results from the whole body monitoring indicated that the doses received by the two persons involved in the first event were very small and did not warrant enforcement action, our inquiries revealed significant shortfalls in DRDL’s safe system of work arrangements. The results of our inquiries into the second event showed that no detectable dose had been received.
To bring these observations to DRDL’s attention HSE-NII wrote to DRDL requiring it to review the situation and to report back to NII by 14th July on what action it plans to take to address the problems found.
As part of its regulation under the nuclear site licence HSE-NII issues formal regulatory documents, which include Consents, Approvals, Acknowledgements, Specifications and Notifications.
No formal regulatory documents have been issued during the period covered by this report.
No formal enforcement notices have been issued during the period covered by this report.
HSE-NII site inspectors and specialist inspectors visited HM Naval Base Devonport on the following dates during this quarter:
A number of meetings were held with MoD personnel, primarily relating to the MoD’s arrangements for dealing with redundant nuclear submarines at Devonport, the naval nuclear propulsion programme balance of investment project and emergency arrangements.
MoD activities, at HM Naval Base and Devonport Royal Dockyard, are inspected under the Health and Safety at Work Act (1974), the Radiation Emergency Preparedness and Public Information Regulations 2001, (REPPIR), and the Ionising Radiation Regulations (IRR) 1999.
Nothing to report this period.
Nothing to report this period.
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. HMS Spartan arrived at Devonport in Q1 for storage prior to commencement of the Defuel, De-equip and Lay-up Preparations (DDLP). To comply with Government policy, the MoD is required to de-fuel the redundant submarines, that have left operational service with the Royal Navy, as soon as reasonably practicable.
As previously reported to the LLC the current DDLP facilities are coming to the end of their operational life and HSE-NII gave notice to the MoD and DRDL that no further DDLPs were to be carried out at Devonport until the installation of new facilities to bring about a low level defuelling route was complete. A number of the improvements are still to be delivered, including removal of the existing refuelling crane and installation of a new reactor access house. The most recent MoD programme suggests that the new facilities can be completed by 2012 and we are pressing for improvements to this timescale, which is currently subject to pressure on MoD budgets. 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.
We attended meetings and workshops with MoD associated with the development of a Naval Nuclear Propulsion Programme (NNPP) Staged Improvement Programme (SIP). This is a development of the successful Devonport SIP process that has and continues to be used to manage improvements to facilities at Devonport.
No formal enforcement notices were issued by HSE-NII during the period.