REGULATORS - Nuclear Safety

DML must ensure that its practices and procedures comply with an extensive range of legal and contractual requirements to ensure that the risks and any impact on people and the environment are minimised.

Two bodies regulate the nuclear part of DML's business. As the nuclear work is predominantly for the Royal Navy, the Ministry of Defence (MoD) retains a regulatory role in addition to the civil regulator, the Nuclear Installations Inspectorate (NII). Both regulators require DML to have comprehensive arrangements to operate safely and they regularly carry out rigorous inspections.

Civil Regulator

The NII is the Nuclear Safety Directorate of the Health and Safety Executive. It licences the part of DML's site at Devonport Royal Dockyard where nuclear operations take place. This is known as the Nuclear Licensed Site. As part of the Nuclear Site Licence, and in common with all nuclear installations, it imposes 36 separate conditions under which the licence is operated.

The NII nominates inspectors to visit the site on a regular basis. Its primary role is to ensure that the site is being operated in accordance with the licence and the conditions attached to it. It also ensures that all nuclear facilities are sufficiently robust to meet the demanding standards required for nuclear work. Dedicated site inspectors are supported by a number of assessors who closely scrutinise the company's arrangements and proposals.

MoD Regulator

The MoD regulator, the Defence Nuclear Safety Regulator (DNSR), authorises DML to carry out nuclear activities on both the Nuclear Licensed Site and on adjacent waters. Whilst this Authorisation closely mirrors the Nuclear Site Licence it is concerned more with submarine plant and the infrastructure required to support it. DNSR works closely with the NII in carrying out assessments and inspections of the Licensed Site and of MoD Authorised activities.

Nuclear and Radiological Assurance

In order to strengthen the Company's arrangements for gaining assurance of compliance with the conditions of the Nuclear Site Licence and the supporting regulations, a Nuclear Assurance Group was created in October 2006 under a Senior Manager within the Nuclear Safety & Quality Directorate.  This group provides a powerful focus for all aspects of nuclear and radiological compliance and a consistent interface with each of the Regulatory organisations.

Improvement Notices delivered by the Nuclear Installations Inspectorate in 2006

During 2006, a number of incidents occurred that indicated that some aspects of the company’s control of radiological work, in particular risk assessments, were weak.  A further incident involving a crane later in the year, whilst having no nuclear or radiological implications, indicated weaknesses in arrangements for training.  DML took both issues very seriously and commenced substantial remedial programmes.  The Nuclear Installations Inspectorate determined that a formal approach was necessary and placed two Improvement Notices requiring corrective action by December 2006 and April 2007 respectively.  In each case, remedial programmes have extended significantly beyond the scope of the Improvement Notices as the company seeks well developed and permanent solutions. 

In 2006, the NII also placed a Specification on DML to modify the storage arrangements for some radioactive resins by March 2008. The improvements sought on Risk Assessments were completed by December 2006, to the satisfaction of the NII.