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 also from the Internet at http://www.hse.gov.uk/nuclear/index.htm. The Site Inspector of HM Nuclear Installations Inspectorate (NII) attends LLC meetings and will be happy to respond to any questions raised there by members. Any other person wishing to inquire about matters covered by this report should contact the HSE’s Nuclear Directorate on 0151-951-4382.
Nuclear Safety Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
The Nuclear Installations Inspectorate (HSE-NII) site inspectors made visits to Devonport on the following dates during this quarter:
4, 10, 11, 23, 24 July 2007
15, 16, 28 – 31 August 2007
3, 4, 26, 27 September 2007
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.
Specialist Inspectors completed inspections in relation to:
Waste Management
Quality Assurance
Ionising Radiations Regulations
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.
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).
Meetings are now being held with DRDL on a regular basis to address the assessment of the programme of periodic review of safety submissions. We have now looked at the process DRDL is using and sampled some of the findings to see how they are being managed and resolved. From our inspections to date we have an increasing level of confidence with the process and in the progress that DRDL is making
As part of the inspections this year relating to Quality Assurance we completed a joint team inspection with DNSR/RSD Serco of the Quality Assurance arrangements with regard to the controls applied by DRDL to the Future Nuclear Facilities project and to its contractors. We found that the FNF project is appropriately resourced and does not rely on contractors for taking decisions regarding the nuclear safety implications for the project i.e. it has a good intelligent customer capability. In general while some improvements have been sought, in relation to managing updates from contractor’s planning information and clarity over the status of documents associated with the Quality Plan, we found that the project’s QA arrangements to be in-line with good practice and surveillance of its contractors on programme
A joint NII, DNSR and Environment Agency team inspection was conducted at the end of August covering the management of radioactive waste by DRDL and by HM Naval Base at Devonport. The main findings are that DRDL should develop an integrated approach to the management of radioactive waste on the site in order to demonstrate it is taking account of all the relevant factors, achieving best practice and properly optimising its future plans in line with the principles of ALARP (As Low As Reasonably Practicable) and BPEO (Best Practicable Environmental Option). We also advised that DRDL review its extant staffing levels against future requirements for post-operational clean-out (POCO), decommissioning and management of radioactive waste.
We continue to hold regular meetings with the DRDL team responsible for the delivery of the Future Nuclear Facilities project (i.e. the provision of a low level de-fuelling facility in SRC, removal of the 80 Te refuelling crane and modern standard Fleet Time Docking Facility). DRDL continue to make good progress on the project for the design of the Reactor Access House (RAH) which enables defuelling to take place. DRDL is currently planning the project programme in detail with its contractors and will inform HSE-NII in due course whether there is any scope for programme shortening, e.g. through parallel working. DRDL is currently in the final stages of tender evaluation for the proposals for the removal of the 80Te crane. It is anticipated that DRDL will shortly be in a position to inform HSE-NII on its choice of contractor and the method of removal.
At the May 2007 joint team IRR inspection there were a number of areas where improvements should be made, or where the arrangements should be reviewed or clarified; none of these relate to any legislative non-compliance or major safety concerns. Following the joint inspection in May across the Devonport site a progress meeting was held with the RPA for DRDL. DRDL indicated that about a third of our findings had been progressed to a point where it was content they had been addressed. We were content with the progress made and agreed to hold further progress meetings on a quarterly basis and to conduct compliance inspections on those items which the duty holder considered completed.
Babcock International Group PLC announced on 10 May 2007 that the company had entered into an agreement with the current owners for the acquisition of Devonport Management Limited (DML). DML currently undertakes major Nuclear Submarine overhaul and refuelling work for MoD at Devonport via its wholly owned subsidiary company Devonport Royal Dockyard Ltd (DRDL). DRDL is a site licence holder under the Nuclear Installations Act (1965) and certain prescribed activities carried out on the site are regulated by HSE-NII. The nuclear site licence places certain legal responsibilities on licensee organisations and, in particular, covers the requirement for the control of nuclear safety related matters through an appropriate body corporate with suitable leadership and management capabilities. When licensee organisational arrangements are subject to significant change, HSE-NII assesses the proposals paying particular attention to matters including the legal requirements to satisfy the site licence, leadership and management, organisational structures, intelligent customer capability, management responsibilities, nuclear safety competencies, control of work and sufficient relevant nuclear safety knowledge and experience.
HSE-NII has engaged with relevant stakeholders to ensure that any proposed changes are properly conceived and executed such that high standards of nuclear safety performance continue to be secured at Devonport Royal Dockyard. The current position is that the licensee corporate and operational management structures remain unchanged and as such the nuclear safety related activities taking place at the site remain secure through the existing arrangements as regulated and inspected by HSE-NII. Any future changes will be subjected to the site’s Management of Change process which requires that the effect on safety of any changes be assessed.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 have monitored the licensee’s response to events reported by its systems and been appraised of events it considers important. In addition, jointly with DNSR, we have been monitoring events that have challenged or weakened the effectiveness of the safe systems of work to protect worker safety. While we continue to seek improvements in this area we are planning an inspection to draw attention to an area where we consider reasonably practicable improvements should be made.
As part of its regulation under the nuclear site licence HSE-NII issues formal regulatory documents, which include Consents, Approvals, Acknowledgements, Specifications and Notifications.
None this period.
None this period.
HSE-NII site inspectors visited HM Naval Base Devonport on the following dates during this quarter:
28 – 31 August 2007
This visit was part of the joint NII/DNSR/EA site-wide inspection of compliance with licence/authorisation conditions covering the management or radioactive waste.
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.
At the May 2007 joint team IRR inspection there were a few areas where improvements should be made, or where the arrangements should be reviewed or clarified; none of these relate to any legislative non-compliance or major safety concerns. Following the joint inspection in May across the Devonport site a progress meeting was held with the RPA for HM NB Devonport. HM NB Devonport indicated that that it expected completion of some of the findings by first quarter 2008. We were content with the progress made and agreed to hold a further progress meeting in the New Year with the duty holder.
We participated in the final multi-agency planning meeting to discuss arrangements for the forthcoming Short Sermon 07 emergency exercise.
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. A number of submarines are now in storage at Devonport prior to commencement of the Defuel, De-equip and Lay-up Preparations (DDLP) process with further submarines expected to be taken out of service in the forthcoming period. To comply with Government policy, the MoD is required to de-fuel the redundant submarines, which 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 were 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. However, detailed design and safety case development is now underway and we have provided comment on the Preliminary Safety Cases from DRDL for the safe removal of the 80Te crane and for the de-fuelling facility. We understand that the contracts have now been placed for most of the main elements of the programme and that funding for the work is established. As noted in Section 2.2 of the DRDL part of this LLC report, we are engaging with DRDL on a regular basis as this important project proceeds. The most recent MoD programme suggests that the new facilities can be completed by 2012 and we are pressing for improvements to this timescale. 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.
No formal enforcement notices were issued by HSE-NII during the period.