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 Clyde Local Liaison Committee (LLC) and covers activities associated with the regulation of nuclear safety at H M Naval Base Clyde. These reports are distributed quarterly and are also available on HSE’s web site 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. Any other person wishing to enquire about matters covered by this report may contact the HSE’s Nuclear Directorate on 0151-951-3484/3290.
Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
The majority of sites inspected by HM Nuclear Installations Inspectorate (NII) a part of the Health and Safety Executive are licensed by HSE/NII under the Nuclear Installations Act 1965 (as amended). HM Naval Base Clyde is not a licensed site although it operates under Authorisation from the Ministry of Defence (MoD) Defence Nuclear Safety Regulator (DNSR). The site comprises the Faslane and Coulport facilities and is regulated by HSE/NII through other legislation as noted below. This report summarises the inspection and regulatory activities associated with HM Naval Base Clyde which are coordinated with inspections by DNSR. The focus for HM Naval Base Clyde is safe and timely servicing of the UK’s Nuclear submarine fleet. This is being progressed through provision of facilities on the site which are being upgraded to meet the continued operational requirements of the Base.
The Nuclear Installations Inspectorate Site Inspector made inspection visits to the sites on the following dates during the quarter: -
Inspections on site are undertaken are taken as part of monitoring compliance with:
This entails monitoring operator’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 operators are required to make and implement adequate arrangements in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation. In this period a number of inspections of HM Naval Base Clyde, and the Operational Berths at Loch Goil and B4 anchorage were undertaken jointly with DNSR and covered:
A meeting was held to discuss progress on improvements to the site’s nuclear accident response. This followed from our request for an improved response from the Naval Base as noted as being required in the Site Inspector’s report for 2007, quarter 4. The Naval Base’s progress in meeting completion dates provided by the Base’s improvement programme was inspected. The inspection concluded that while good progress had been made, the Naval Base should revisit the programme ensuring it is adequately resourced to meet the stated completion dates.
Where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from the Naval Base, and the site inspector 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.
Operators are required to have arrangements to respond to non-routine matters and events. NII Inspectors judge the adequacy of the operator’s response including actions taken to implement any necessary improvements.
As reported to the LLC (2007 - Q1) HSE/NII are monitoring the Naval Base’s progress towards implementing improvements to the control of work and behavioural safety performance. A further inspection was undertaken by HSE/NII following information received from one of the site Safety Representatives. The inspection covered:
Following information obtained by HSE/NII before and during the inspection, HSE/NII has written to the Naval Base asking the Naval Base to review its system in a number of areas, in particular for event reporting and management oversight.
Under Health and Safety legislation NII Site Inspectors, and other HSE Inspectors, may issue enforcement (Crown) notices to secure improvements to safety.
No enforcement (Crown) notices were issued during the quarter
Submissions under REPPIR for Faslane, Coulport, Loch Goil and B4 Anchorage have been received by HSE/NII. These suggest likelihood of an Nuclear event involving a submarine is less than in previous submissions. HSE/NII is currently examining the common assessment on which the Clyde (Coulport and Faslane), Loch Goil and B4 Anchorage submissions are based. This examination is likely to be complete in July 2008. Following this HSE/NII is required by REPPIR to make a determination of the Detailed Emergency Planning Zone (DEPZ) for each of the four locations. This determination is programmed to be issued in the autumn of 2008. Until a revised determination has been issued, the Clyde sites and Local Authority have been advised to base their plans on the current DEPZ determination.