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 or subsequently by members of the LLC. Any other person wishing to inquire about matters covered by this report should contact the HSE’s Nuclear Directorate Information Centre on 0151-951-3484.
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 HSE/NII Site Inspector made inspection visits to the site on the following dates during the quarter: -
Specialist NII Inspectors also visited the site on both of the October visits.
Inspections on site are undertaken are taken as part of monitoring compliance with:
We discussed the site’s efforts to improve safety culture and attended the Incident and Injury Free (IIF) orientation training. This focuses on setting expectations from the workforce in terms of expected behaviours and the support that they can expect from their managers. An important part is the expectation that they will challenge unsafe behaviours in others and should expect to be challenged if they are doing unsafe acts. It is also about being proactive and asking questions about potential risks and how to mitigate them and about an attitude of choosing to follow safety rules rather than having to. This was balanced by the support that can be expected from managers (especially, that they will be supported if they stop work due to a genuine safety concern). We considered the standard of delivery and the safety messages in the IIF orientation course to be very good. Provided the levels of commitment in evidence are sustained, then there should be a positive impact on behaviours on the site and hence on nuclear safety performance.
A joint NII and DNSR team assessed the demonstration emergency exercise Sheetbend 2008, which was a Level 1 (Mod Grade C) exercise based on a propulsion accident scenario at Coulport. The site’s emergency arrangements were considered to be adequately demonstrated, albeit with some improvements required in casualty handling and evacuation. It was particularly pleasing that the site’s own internal assessment team captured all the major points identified by the regulatory team and was at least as critical in identifying improvement points.
A joint NII/DNSR/SEPA inspection of radioactive waste management was carried out during the period. The Inspection Team examined closely the conclusions and recommendations of the Best Practicable Means (BPM) study which has recently been completed at HMNB Clyde. This provides a thorough and credible analysis of the present arrangements for the management of radioactive waste arising from naval nuclear propulsion programme activities at HMNB Clyde and concludes that the base is not currently employing BPM. Recommendations have been made for bringing the arrangements up to a BPM standard. The Regulators intend to monitor the implementation of these recommendations with a follow-up inspection in mid 2009.
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.
There were no items of particular note during the current reporting period.
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.