Government safety watchdogs have decided that regulation of Scotland's nuclear bomb store is to remain outside the civil nuclear safety regime, even though operation of the site has been handed over from the Ministry of Defence to a consortium of private companies.
The high security Royal Naval Armaments Depot at Coulport, where the UK's nuclear warheads are stored and loaded onto Trident submarines, has until now had 'crown exemption' as a military site from the Nuclear Installations Act 1965 – the principal law governing nuclear safety at civil nuclear sites.
Management of the Coulport site was handed over to private sector managers in January 2013, but has escaped licensing under the Nuclear Installations Act because the Office for Nuclear Regulation (ONR) has concluded that the level of Ministry of Defence control of the site remains at the “absolute minimum that is acceptable” to allow the site to escape licensing under the Nuclear Installations Act - “and then only when considered within the wider construct of HMNB Clyde”.
Documents released under the Freedom of Information Act (available to download below) reveal that ONR has warned that although the contracting arrangements will allow the site to remain exempt from licensing “for the present”, the situation will be “under continuous threat from any future extension of contractor control” either at Coulport or in the Clyde naval base.
Following an inspection visit to Coulport, ONR considered that there was a “serious risk” that any further changes to management arrangements could result in a situation where crown exemption arrangements are “no longer sustainable”.
Scottish National Party MP Angus Robertson has written to the Office for Nuclear Regulation to request that management and safety arrangements at Coulport are kept under regular review, and that the Scottish Government is consulted on any future decisions relating to licensing of the site.
Regulation of the Coulport site is currently undertaken from within the Ministry of Defence itself, through the Defence Nuclear Safety Regulator (DNSR). Critics have accused DNSR of operating in a more secretive and unaccountable manner than the civil nuclear regulator, and say that, as an internal MoD department, it lacks the independence necessary to be an adequate watchdog.
In January management and operation of the Coulport site was handed over to the ABL Alliance – a private sector industrial consortium comprised of AWE plc, Babcock International, and Lockheed Martin. AWE plc operate the Atomic Weapons Establishment sites in Berkshire where Trident warheads are manufactured and maintained. Unlike Coulport, the Atomic Weapons Establishment was required to comply with civil nuclear licensing arrangements following its privatisation in the 1990s.
A report of an inspection report prepared by DNSR following an inspection at Coulport reveals that, at a September 2010 meeting personnel from HM Naval Base Clyde sought to convince regulators that the proposed new management arrangements would be sufficient to “guard against potential Licensing by ONR”.
The inspection report also shows that the decision to privatise management arrangements at Coulport was taken because outsourcing of work to contractors at the Clyde base had caused the pool of MoD resource at the base to diminish “significantly”, and as a result MoD had been unable to sustain sufficient nuclear expertise among its personnel at the base. Even under the new arrangements, the sustainability of the residual MoD organisation “may become a potential concern” to DNSR, and current gaps in the proposed structure for the new organisation “have been identified as a risk”.
ONR inspectors “will continue to monitor any changes to organisation at HMNB Clyde” and intend to revisit Coulport in August to conduct a further inspection to verify that control arrangements ensure that MoD retain command over operations at the base.
Download the documents released by the Office for Nuclear Regulation under the Freedom of Information Act here: