Defence Nuclear Safety Regulator's annual report 2011

The Defence Nuclear safety Regulator (DNSR) have recently published their annual report for 2011 which includes a summary of nuclear and radiological safety and environmental protection performance in the Defence Nuclear Programme (DNP)

Key risks are :-

Red Risk

• Lack of adequate resource to deliver the defence nuclear programmes safely.
• Measures already in hand may be insufficient to address the present and predicted shortage of NSQEP in the Royal Navy, among MOD civilians and in defence contractors

Amber risk

• Safety Cases in the DNP are inconsistent against current good practice; integration of safety analyses for the reactor and weapon needs to be expedited
• The demonstration that the risk from DNP activities is ALARP is inconsistent and tortuous to uncover
• The number of incidents remains too high

"Para 7: At least some of the Issues described further on have their roots in a general lack of resource to address the work required to conduct activities and demonstrate their safety."

This issue has been included as a red risk for years and it appears that no progress has been made to provide the required resources and if anything the situation is getting even worse year by year. DNSR appears powerless to ensure that Ministers and management to provide the resources necessary to safely deliver the MOD nuclear programmes.  

 It appears that only a serious incident would deliver an increase in resources.   This is what happened after  the Pochin enquiry in the late 1970s  following the discovery that 12 of those working at the Aldermarston appeared to have accumulated plutonium in their lungs in excess of the level recommended by the International Commission on Radiological Protection.  It was this that lead in a large part to the establishment of MOD professional Health Physicists as a separate grade within the MOD.

"Para15: Evidence continues to build that constraints on the DNP’s industrial funding are now affecting staffing levels in Tier 1 contractors; as a result projects run behind declared timetables and important safety submissions are delayed. The trend (of decades) to outsource work from MOD to industry when there are reductions in crown servant numbers (or the inability to recruit), may be approaching a real limit as industry is equally constrained. The limit may also result from the desire to maintain “crown control” of some activities, not least because safety legislation is applied differently (or exempted)  dependant on who is conducting the work."

Highlights the policy  of “crown control” under which the MOD nuclear operations remain largely exempt from civil nuclear regulation.  In the past outsourcing the work has allowed the MOD to meet staff reduction targets but it clear that the limit of this has now been reached if not exceeded.

"A number of incidents have occurred across the programme in 2011; individually they have not been of high significance or safety/environmental detriment, but taken together, they produce concern that working conditions and culture might not prevent an incident of higher significance"

DNSR highlights a worrying trend in incidents but these may well indicate the potential for a more significant incident with wider ranging consequences and may also be indicative of a safety/management culture under stress.

It is worrying that there are problems with integration of safety analyses for the reactor and weapon.  This suggests a "stove-pipe" approach to safety  and that there is insufficient consideration of the combined risks from all the hazards on the submarine, reactor, nuclear weapon, explosive, human factors and external hazards.  The report does not provide any information about what DNSR is doing to address this important issue.

Summary

The report clearly shows that the MOD lacks  adequate resources to deliver the defence nuclear programmes safely.  As far as can be seen DNSR  has been ineffective in persuading management and Ministers to provide the necessary resource.
  
It is also notable that DNSR has not issued any enforcement notices requiring the provision of the necessary resources deliver the defence nuclear programmes safely
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It  is also of interesting to see in  DNSRs report,  concerns expressed  about the difficulty in establishing of DNSR’s full complement of human resources in DSEA with the potential to impact on DNSRs' ability to regulate.

The report suggests the probability of a serious incident within MOD nuclear programmes continues to increase.