Office for Nuclear Regulation

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HM Naval Base Clyde

Quarterly report for 1 July 2011 to 30 September 2011


This report is issued as part of the Office for Nuclear Regulations (ONR) commitment to make information about inspection and regulatory activities relating to HM Naval Base Clyde available to the public. Reports are distributed quarterly to members of the Clyde Local Liaison Committee and are also available on the ONR website.

Site inspectors from ONR usually attend the Clyde Local Liaison Committee and will respond to any questions raised there by the members of the group. Any other person wishing to inquire about matters covered by this report should contact the ONR.

Post: Office for Nuclear Regulation
Redgrave Court
Merton Road
L20 7HS

HM Naval Base Clyde Inspections

The majority of sites inspected by ONR are licensed by HSE 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 ONR through other legislation as noted below. This report summarises the inspection and regulatory activities associated with HM Naval Base Clyde which are co-ordinated with inspections by DNSR.

ONR Site Inspectors made inspection visits to the Faslane and Coulport sites on the following dates during the quarter:

The Superintending Inspector for Naval Nuclear Propulsion Programme (NNPP) Inspection also visited the site on the following dates during the quarter:
15-16 September 2011

Routine matters

Inspections on site are undertaken are taken as part of monitoring compliance with:

  1. The Health and Safety at Work etc Act (HSWA) 1974 and
  2. Regulations made under the HSWA for example the Ionising Radiations Regulations1999 (IRR99), the Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR) and the Management of Health and Safety at Work Regulations 1999 (MHSW99)

The ONR Site Inspector, along with colleagues from DNSR, attended both Emergency Exercises; Bowline 11 and Evening Star 11.

Exercise Bowline 11 was the annual demonstration of HMNB Clydes emergency response to a nuclear weapon accident at Coulport. A number of command and control aspects of the exercise were not considered to have been adequately demonstrated and a re-demonstration of this phase is planned for Oct 11.

Exercise Evening Star 11 was the annual demonstration of HMNB Clydes emergency response to a Submarine nuclear accident at Faslane. This was deemed to be an adequate demonstration of the emergency arrangements at Faslane.

The Superintending Inspector for NNPP Inspection and the Site Inspector attended the Level 2 Regulatory Interface Forum, which is an annual meeting of senior base personnel and nuclear regulators (ONR, DNSR and SEPA). The aims of the meeting were to discuss HMNB Clydes Safety Strategy and 10 year programme, to receive updates on key nuclear safety implicated projects and for regulators to inform the site of developments within their organisations. Many of the same personnel also discussed HMNB Clyde Annual Review of Safety (ARoS).

The ARoS is a review by the Base on the successes and challenges over the previous year with a look forward to how progress is built on moving into the next year. The site had carried out a review of nuclear safety-significant topics, including organisational change, nuclear safety event reports and Operational Experience Feedback, safety cases, emergency arrangements, radiation protection, safety culture, conventional health and safety, maintenance, weapons safety, safety performance indicators and the Assurance Department Intervention Strategy. Progress and challenges in each of these areas was discussed. Captain Base Safety reported that the process of carrying out the review had been valuable. All the regulators considered that the outcomes were balanced and properly representative of the sites safety performance. The review will assist both the site and the regulators in developing their intervention strategies for next year.

Non-routine matters

Operators are required to have arrangements to respond to non-routine matters and events. ONR Inspectors judge the adequacy of the operators response including actions taken to implement any necessary improvements.

There were no items of particular note during the current reporting period.

Regulatory activity

Under Health and Safety legislation ONR 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.

News from ONR

ONR Board

The full ONR Board came into effect on 25 July and comprises of nine members: Nick Baldwin as the Chair, four non-executive members (Steve Bundred, John Crackett, Paul Kenny and Kevin Myers) and four executive members (Kevin Allars, Paul Brown, John Seddon and Mike Weightman).

Three Board meetings were held during this reporting period. Further information about the Board and minutes of the meetings can be found under the Board pages of the ONR website.

Moving towards a programme management organisation

Under the remit of ONR's transformational change programme, work is now underway to establish programme management principles within ONR. This way of working is closely aligned to industry and government programme management best practice and will enable ONR to meet increasing demands. This transformational change will: re-organise ONR's current organisational structure into four delivery-focussed and integrated programmes (Civil Nuclear Reactors, Defence, Sellafield, Decommissioning, Fuel and Waste); establish a corporate programme office to co-ordinate and consolidate information across the programmes, ensuring consistency in operations, and, recruit programme managers to support each of the programmes.

This approach supports the proposed establishment of ONR as a statutory corporation, signalling the ongoing commitment to securing an appropriately resourced and responsive regulator for the future.

ONR public consultation

From 19 Sept 12 Dec a 12-week public consultation is running to clarify ONR's interpretation of bulk quantities relating to radioactive matter. The nuclear site-licensing regime currently applies to a set of defined activities, which includes the storage of bulk quantities of radioactive matter. However, there is no clear definition of what constitutes bulk quantities of radioactive matter, storage of which would need to be licensed.

ONR corporate publications

ONR's first corporate plan for 2011-2015 and quarterly report have been published on the ONR website. The plan provides an insight into ONR's strategic intentions over the next five years and how these will be resourced. The quarterly report reflects the key themes and developments in each of ONR's regulatory programmes and explains the ongoing changes at ONR, as it progresses towards becoming an independent statutory corporation.

Also published on the website in September was the 2011 Nuclear Research Index (safety operating reactors). Traditionally the scope of the NRI is limited to operating nuclear reactors. Research work is done in other nuclear areas, but is coordinated separately. Therefore the scope of the 2011 NRI relates solely to the requirements for nuclear safety research relevant to operating nuclear reactors. ONR is planning to undertake a review to identify the overall requirements for nuclear safety research, including whether it should be extended to cover all areas of nuclear safety research.

Stress tests

The European Council requested a review of safety at European nuclear power plants. The European Commission supported by the European Nuclear Safety Regulatory Group (ENSREG), produced criteria and a plan for this review, now known as the ' EC stress test'. Participating nations agreed to provide progress reports by 15 September and full reports in December. The UK report compiled and delivered by ONR has been published online.

Fukushima report

Secretary of State for Energy and Climate Change, Chris Huhne, requested a report from chief nuclear inspector Mike Weightman on lessons for the UK nuclear industry from the Japanese incident. The report will be delivered to DECC in the autumn and made public. An interim report was published in May, concluding that there was no reason to curtail nuclear plant operations in the UK. ONR has written to community groups around nuclear sites in the UK to establish levels in interest in ONR conducting a series of regional public briefings.

Site licence application for Hinkley Point C received

ONR received an application from NNB Generation Company on 29 July for a nuclear site licence, relating to its proposed development of a new nuclear power station in Hinkley Point. It is anticipated that ONR will spend around 18 months assessing NNB Generation Company's suitability, capability and competence to install, operate and decommission a nuclear facility. If licensed, the company will be subject to statutory obligations and regulation by ONR.

Nuclear Safety Directive and amended licence conditions

Amendments have been made licence condition 17 and 36 to allow the obligations of the Nuclear Safety Directive (NSD) 2009/71/Euratom, to be fully implemented in relation to Great Britain. In light of this, ONR's licence condition handbook has been updated and is available via the ONR website.

Updated 2012-01-13