In 2007 the MOD published its policy on the management of radioactive waste arising from the defence nuclear programmes.
Four years later In 2011 the MOD published “Nuclear Liabilities Management Strategy “ the strategy was meant to explain how the policy outcomes set out in the policy paper were to be delivered, who was responsible for their delivery, when these would be delivered, and to identify costs and how/when the costs would be met.
However the strategy is very much a narrative document describing sources of wastes and options for management. It is notable that the Strategy is very much focused on the submarine programme.
There is no mention of decommissioning Aldermaston; the strategy states “End Point AWE will continue to support the DNP for the foreseeable future.” The MOD is blind to the need to anticipate change and in any case at some point in the future buildings and facilities at AWE will need to be decommissioned and replaced as they age.
The MOD policy required that the strategy would be produced in consultation with stakeholders including NGOs. As far as can be determined no NGOs were consulted. This is in contrast to the national strategy produced by the NDA where the NDA actively engaged with external stakeholders including local communities and NGOs.
The strategy says “The MOD will consider public engagement on a case by case basis taking account of Government policy and environmental and planning law” The policy says
“the MOD remains confident that in conjunction with stakeholders (OGDs and NGOs), it is able to deliver the policy set out above”
The expectation was that MOD in developing the strategy will meet the requirement of its stated policy to involve NGOs. However it is now clear from the strategy MOD will only do the minimum required by law
P134 Expenditure on managing the MOD’s
nuclear liabilities will be appropriately prioritised
within the Defence budget. Funding for strategy
development and implementation is not reliant
on income from the realisation of assets’ values.”
The strategy fails in that it provides no indication of costs or how funding is to be provided against the ongoing programme of resource cuts and savings targets
In 2007 Hansard reported decommisioning liabilities of over £ 9 billion
Chris Huhne: To ask the Secretary of State for Defence whether his Department’s nuclear liabilities have been quantified; and how they are funded. Des Browne: The Department’s nuclear liabilities are set out in the Department’s Annual Report and Accounts, the most recent version being those for 2005-06 (HC1394) published on 14 July 2006; a copy of which is available in the Library of the House. The estimate of the MOD’s nuclear liabilities (page 220) is £9,753,827,000"
The lack of any costs in the strategy suggest that MOD might be trying to hide an increase in decommmsssioning costs
“6.2 People, Skills and Capability
P133 Available Suitably Qualified and
Experienced Personnel (SQEP) are essential to
the MOD and its industrial partners and supply
chain to deliver successful liability management,
and decommissioning and disposal projects. The
MOD’s SQEP initiatives support the development
and implementation of this Strategy.”
The DNEB have for years pointed out that levels of SQEP staffing are below that required for the safe delivery of the nuclear programme. The ever increasing need to cut costs and the priority being given to delivery of operational capability rather than backend decommissioning suggest this is a significant area of weakness in the delivery the policy outcomes for managing nuclear liabilities
“6.5 Information and Knowledge
P136 The MOD recognises the long programme
timescales associated with implementation of
this strategy; the MOD’s system of information
and knowledge management is essential for
the effective retention of information and for
maintaining continuity between projects.”
Recent revelations have shown MODs unable to retain information and records over the medium let alone the long term.
The Nuclear Liabilities Management Strategy lacks substance and detail and appears to be little more than an exercise in window dressing, particularly when compared to the strategy produced for the civil sector by the NDA.
NDA paper "Non NDA Liability Management Strategy March 2011" includes reference to the Ministry of Defence