Milcon Research and Consulting

NAO report Managing change in the Defence workforce impact on skills

2012-02-09T00:39:00.000-08:00

National Audit Office report Managing change in the Defence workforce published today points out the Minsitry of Defence is under pressure to make rapid financial savings, is significantly reducing the size of its workforce, by over 54,000 personnel. A report today by the National Audit Office has found that these reductions are happening in advance of the Department’s fully understanding how it will operate with significantly fewer staff.

With regard to skills the report says

“The significant reduction in headcount creates a risk that current skills gaps will worsen. There is a significant risk that current skills shortages will worsen particularly as at least 16,000 personnel, 30 per cent of the reduction required, is predicted to occur through natural wastage, a process over which the Department has less control than redundancy.”

The recent statement by SEPA on the plans submitted by MOD for the remediation of the beach at Dalgety Bay may indicate that MOD has inadequate specialist skills to manage issues such as radioactive contamination.

"We consider that the plan, as it stands, lacks sufficient detail and have requested more information on a number of areas which include:

timescales for implementation of each stage of the plan;
more detail relating to the proposed investigation work;
investigation plans for Crowhill and Ross Plantation;
investigation of remediation options."

It has been previously pointed out that there are significant nuclear safety skills shortages. It will be interesting to see in this year’s report by the Defence Nuclear Environment Safety Board if the situation has changed

Ministerial Visit to Dalgety Bay

2012-02-01T04:12:00.000-08:00

It’s interesting to note from a recent PA report on the visit of Defence Minister Andrew Robathan. He said that “the Ministry of Defence does not deny liability” and went on to say “But I don't think you would expect us to accept liability before we know exactly what the situation is.”

Video report from STV

This is surprising since the MOD has known about the contamination since 1990 and even produced its own risk assessments; surely enough time has passed and information gained to establish the responsibility for the contamination based on reasonable probability.

The reference to “industrial sites and ship-breaking” and the “need for further investigations”, seems like an attempt to further muddy the waters and play for even more time.
The reference to “earth movement which of course has of course disturbed a great deal of stuff” suggests that buried radium residues may have been disturbed and brought to the surface with a consequent increase in risk.

It seems that MODs continuing failure to accept that in all probability that the MOD is responsible for the contamination of Dalgety bay is very likely to lead to SEPA designating Dalgety Bay as radioactively contaminated land.

It’s also interesting to see how MODs miss-handling of the radium contamination at Dalgety Bay, and in particular the failure to apologise or accept liability for the contamination may well have played a significant part in shaping people’s views about the options for managing the decommissioned nuclear submarines stored on the Firth of Forth at nearby Rosyth Dockyard.

Link to press report

Link to press report concerning Devonport and Dalgety Bay

Dalgety Bay provides a classic example of the miss-management of an environmental issue causing reputational damage across all business areas.

The situation has moved from one concerning essentially scientific and objective decisions to a much more difficult situation primarily driven by ethical and political considerations. This is especially true in the current political environment where the SNP is seeking success in the up-coming referendum on independence.

31/1/12 (UKPA) reports

More tests due on bay radioactivity

Further investigations are needed at a beach where radioactive particles were found before anyone should take full responsibility, Defence Minister Andrew Robathan has said.

The Tory MP visited Fife to hand over a draft plan for further action to the Scottish Environment Protection Agency and to see the contaminated area for himself.

It comes after "significant" sources of radiation were discovered at Dalgety Bay on the Firth of Forth coast.

The contamination is thought to stem from residue of radium-coated instrument panels used on military aircraft which were incinerated and land-filled in the area at the end of the Second World War. The area faces the threat of being designated Radioactive Contaminated Land for public protection.

During a short visit to nearby Rosyth, Mr Robathan said the Ministry of Defence does not deny liability and questioned whether a clear-up of the site is needed.

"There was of course a Royal Naval air station here. It closed 53 years ago," he added. "Who knows who's liable. We're not denying liability but I think we need to be quite clear how this contamination has come about.

"For instance, there has been industrial sites. I understand there has been a ship-breaking yard just down the way. There's been earth movement which of course has of course disturbed a great deal of stuff. There's been housing estates built.

"We don't say that we are not in any way willing to help. We are willing to help. But I don't think you would expect us to accept liability before we know exactly what the situation is.

"We are therefore looking at this and we are willing to co-operate with the environment protection agency and others to find exactly what the situation is and then we can determine who is responsible for clearing it up, if there is a need to clear it up."
Last week former prime minister Gordon Brown, MP for Kirkcaldy and Cowdenbeath, called for urgent action to clean up the site. He has previously urged the MoD to "accept responsibility"

Dalgety Bay on-shore Radium Contamination

2012-01-18T01:57:00.000-08:00

Recent press reports about Dalgety bay featuring interviews with Gordon Brown speaking about the ”new” discovery of particles of radioactive onshore at Crowhill wood should not ellicit any surprise, it appears that Gordon Brown is playing catch-up.

Links to recent press reports

It’s clear from a report that MOD commissioned Enviros to produce in 2009 that the possibility of onshore contamination was an issue. The report describes on-shore contamination including investigations of domestic properties and gardens built over the former RNAS/RAF Donibristle salvage area in the 1960s. This and associated reports were released by Defence Estates in response to a FOI request made 2010.

Extract from the Enviros report describing areas surveyed inshore from the beach

Link to full report

“Investigation Works Undertaken

8. As a result of the data from the first Phase Two LQA and in particular the findings relating to Property D in Zone 2A, a further phase of investigations were undertaken. The site works involved both radiological walkover surveys and intrusive investigation, the areas investigated are summarised below (Zone designation used in original Phase Two LQA are shown in brackets):

Dalgety Bay Sailing Club Boat Park (Zone 1): Radiological walkover survey of northern area where access was previously not possible;
Property A in Zone 2A and Properties H & I in Zone 4B: Radiological walkover survey and random soil sampling from two properties in Zone 4B.
Radiological walkover survey and random soil sampling from one property in Zone 2A which had not allowed access during the original Phase Two LQA.
Former Salvage Section (Zone 2A): 1m by 1m gridded radiological walkover surveys and soil sampling in the garden areas of six properties. Where radium-226 and elevated count rates were identified removal of disseminated contamination and point sources was undertaken where possible.
Internal Monitoring: Count and dose rate surveys covering accessible areas of the ground floor of six properties on the former Salvage Section and the sailing club house. A similar property outside the impacted area was also surveyed to provide a typical background for the developments which could be used as a comparison.”

Link to full report

Reference:

DALGETY BAY LAND QUALITY ASSESSMENT PHASE 2B: INTRUSIVE INVESTIGATION AND INTERVENTION LAND QUALITY ASSESSMENT REPORT – FINAL V1 DEFENCE ESTATES, PROJECT NO: 12920, TECHNICAL REPORT, November 2009, by Enviros Consulting.

The failing regime for managing contaminated land.

2012-01-16T01:23:00.000-08:00

RNAS/RAF Pulham provides a typical example of a site potentially contaminated with Radium

The Government recently introduced a new regime for the management of contaminated land to protect both man and the environment. Recent FOIs have been asked, to try to establish the extent of the hazards and risk arsing from historic contamination due to use of radium as a luminising agent by the Ministry of Defence. This issue was also subject to a detailed review by the Governments Radioactive Waste management Advisory committee (RWMAC).

The recent concerns about this legacy of radium contamination and the potential risk to the public and environment has been highlighted by the discovery that the beach at Dalgety Bay is far more extensively contaminated than previously thought and the MODs extreme reluctance to admit liability. The MOD has also released a list of some of the sites where radium contamination is an issue.

What has become clear that MOD has little if any records about radium contamination for those parts of the defence estate disposed of between the end of the Second World War and the 1980s. What records that do exist are mainly clearance certificates which were concerned about unexploded ordnance and explosives and not with other contaminates such as Radium, heavy metals, asbestos, chemical weaopns or organic solvents.

In response to an FOI it is clear With introduction of the contaminated land regime that the MOD policy is :-

“The site was despised of in the early 1960s and predates the MOD Land Quality Assessment programme. The MOD there only holds the enclosed 1969 Clearance Certificate that might be relevant to your request.

I am advised that former sites such as this fall within the statutory responsibility of the Local authority to inspect the land in its area and identify any contaminated land. It is therefore suggested that any evidence of contamination you have should be brought to the attention of the Local Authority “

This effectively shuffles off any responsibility to identify contaminated land that the MOD once owned or controlled to the Local Authorities. Local Authorities are very unlikely to hold any information about these sites and therefore are unlikely to have the means to identify whether or not such land is contaminated.

It is clear that with the need to find cost savings MOD has lost the capability to assist local authorities in identifying contaminated defence land. MOD may have transferred information that would have helped to the National Archive or the information may have been lost or destroyed.

I asked the Local Authority “Could you please provide me with information about the nature and extent of radium contamination at RNAS/RAF Pulham in Norfolk Lat 52° 24.690'N long 1° 14.011'E”

“The historic past use by the Ministry of Defence (MOD) of part of the site many years ago for aircraft breaking raises the possibility of radium 226 contamination. The nature and extent of any possible contamination is being considered but formal investigations which require detailed planning have yet to be instigated. The Council is actively working with the Environment Agency, Health Protection Agency, MOD and others within the legal framework from government to clarify what action is appropriate to investigate the possibility of contamination.”

The Wikipedia entry for RNAS/RAF Pulham says “During World War II, Pulham Air Station was used as an aircraft salvage yard for the East of England, with several huge dumps of scrapped aircraft. The resultant contamination of the land is visible even today. The RAF used Pulham for storage and Maintenance Unit work until closure in 1958.” This activity appears to very similar to that at RNAS Donnibristle which may have lead to the contamination of Dalgety Bay with Radium.

Conclusion

The lack of information to identify whether or radium contamination is present means that only a very expensive physical survey will provide an answer.

The lesson to be learnt is that it is important to retain knowledge and information over long periods of time if you wish to answer questions of liability and risk.

MOD policy on contaminated land and alienated sites

2011-12-05T00:57:00.001-08:00

In response to a FOI request about how MOD responded to the recommendations contained in the 2000 report by RWMAC “RWMAC's Advice to Ministers on The Ministry of Defence's Arrangements for Dealing with Radioactively Contaminated Land“. It is clear from the response to action 12 that the MOD has no intention of identifying what contamination exists on land that it has disposed of prior to the LQA programme such as Dalgety Bay.

It is also clear from the response to action 12 of the RWMAC report that MOD believes this responsibility lies with Local Authorities. Local Authorities hold few if any records that would assist them in identifying contamination on former MOD sites let alone the financial resources to support such activity.

I believe it is important for the safety of the environment and the public, that risks from defence related pollutants are identified and if necessary remediated. Examples of such pollutants are :-

radioactive substances such as radium,
chemical weapon residues such as mustard gas,
asbestos,
organic solvents,
explosives and ammunition
toxic heavy metals such as mercury, lead and cadmium

I also believe that it is the MODs’ responsibility to identify where there is a legacy of pollution from defence activities and where identified as the polluter, MOD should pay to for any clean up rather that pushing off the responsibility onto poorly resourced local authorities and council tax payers and Regulators

RWMAC ACTION PLAN page 3

Action 12
“MOD should give thought to the feasibility of compiling information on disposals of land predating the LQA programme, where radioactive contamination might have been involved.”

MOD response

“The introduction of EPA 1990 Part 2A places the responsibility for inspecting land with the local authority to identify land contamination.”

MOD admits that it has no clear idea of what the risk is to people from the radium contamination at Dalgety Bay

2011-12-04T12:16:00.001-08:00

In press report inthe Sunday Herald MOD is quoted as saying

"New radioactive sources have been found at Dalgety Bay and we take thisvery seriously. However, it is not yet clear what the level of risk is."

This statement clearly shows that despite all the surveys MOD admits that ithas no clear idea of what the risk is to people from the radium contaminationat Dalgety Bay

Maralinga a lasting legacy of British nuclear weapons tests in Australia

2011-11-11T09:18:00.001-08:00

The Sydney Morning Herald reports

“Ten years after the all-clear, Maralinga is still toxic

More than a decade after the Howardgovernment hailed the clean-up of Maralinga as completed, the government iscontinuing to support remediation at the former British nuclear weapons testsite.

Confidential files released underfreedom-of-information laws show Canberra officials have at times been mainlyconcerned with ''perceptions'' of radioactive contamination while rejecting arequest by the Maralinga Tjarutja Aboriginal community for a site near theMaralinga village to be cleared of high levels of contamination. Files releasedby the Department of Resources, Energy and Tourism show erosion of the massiveTaranaki burial trench north of Maralinga, described by officials as ''a largeradioactive waste repository'', has required significant remediation. Otherburial pits have been subject to subsidence and erosion, exposingasbestos-contaminated debris.

While the documents indicate ''noradiological contamination of groundwater'' has been detected, the governmenthas been obliged, under its 2009 agreement with Maralinga Tjarutja for thehandback of the test site, to initiate further work.

The Taranaki trench was used to buryradioactive debris and soil, mainly from numerous ''minor trials'' - Britishnuclear weapons safety and development experiments - that between 1956 and 1963caused the heaviest radioactive contamination.

A brief prepared in April for theMinister for Resources and Energy, Martin Ferguson, questioned the capacity ofthe Maralinga Tjarutja to manage the site.

The files show the government declinedrequests by the Maralinga Tjarutja to clean up the trials site closest to thevillage.

The ''Kuli'' site, east of theairstrip, was used to conduct 262 trials, which dispersed 7.4 tonnes of uraniuminto the environment.

While a partial clean-up in 1998removed some larger uranium fragments, reports released under freedom of informationshow surveys in late 2001 and early 2002 found the spread of fragments was muchgreater than assessed.

The contamination was not assessed as aradiological hazard but the uranium toxicity prompted consultations on aclean-up of the site, and the Maralinga Tjarutja expressed concern about a riskto children playing on the ground.

Federal officials were more concernedthat adults could wrongly interpret the yellow uranium fragments as meaning thesite was radioactively contaminated, ''which could create an image issue''.

Alan Parkinson, a retired nuclearengineer and whistleblower who questioned the management of the clean-up,yesterday said the remediation had only been partial and ''the remarkable thingreally, is how little [radioactive material] we buried''.”

It should be noted that the testsresulted in contamination not just due to uranium but also plutonium and beryllium

Maralinga - Background Information

British nuclear tests at Maralinga occurred between 1955 and 1963 at the Maralinga site, part of the WoomeraProhibited Area, in South Australia. A total of seven major nuclear tests wereperformed, with approximate yields ranging from 1 to 27 kilotons of TNTequivalent. The site was also used for hundreds of minor trials, many of whichwere intended to investigate the effects of fire or non-nuclear explosions onatomic weapons.

Thesite was contaminated with radioactivematerials and an initial cleanupwas attempted in 1967. The McClelland RoyalCommission, an examination of the effects of the tests, deliveredits report in 1985, and found that significant radiation hazards still existedat many of the Maralinga test areas. It recommended another cleanup, which wascompleted in 2000 at a cost of $108 million. Debate continued over the safetyof the site and the long-term health effects on the traditional Aboriginal owners of the land andformer personnel. In 1994, the Australian Government paid compensationamounting to $13.5 million to the local Maralinga Tjarutja people.

Continues .......

Dalgety Bay and COMARE

2011-11-11T01:52:00.001-08:00

It is interesting to note that Dalgety Bay is included in the current work
programme of the Committee on Medical Effects of Radiation in the Environment;
but in response to a FOI request COMARE said :-

"I can confirm that COMARE has not provided any advice to SEPA or MOD on
Dalgety Bay."

This begs a question as to what is the work is COMARE doing in relation to
Dalgety Bay and for whom?

Parliamentary Question - Radium Contaminated Land on the Defence Estate

2011-11-03T03:19:00.000-07:00

A Parliamentary Question to MOD Ministers provides a good example of how MPs are fobbed off with a standard line such as “the information is not held centrally and could be provided only at disproportionate cost”.

Delving into the past it becomes clear that this might not in fact be the case and that in 2000 the Radioactive Waste Management Committee (RWMAC) mentioned in their report Advice to Ministers on “The Ministry of Defence's Arrangements for Dealing with Radioactively Contaminated Land” that the “Ministry indicated that it was in the process of developing such a database.”

It would seem that such a database provides a central repository of information requested by the MP.

From Hansard

“26 Oct 2011 : Column 261W
Radioactive Waste
Mr Weir: To ask the Secretary of State for Defence at which locations his Department has records of the burial of radium fragments. [75757]

Mr Robathan: The Ministry of Defence (MOD) takes a proactive approach to the assessment of land quality across the estate and to the management of the risks to human health and the environment. This includes radium 226 associated predominantly with the historical maintenance and disposal of luminised instruments especially during and after the second world war and which are present to some degree at many current and former MOD sites.

Where radium-226 contamination has been identified the potential risks are managed at site level. Such contamination on MOD sites is present in a relatively non-mobile form, with there being little to no leaching to soils and limited solubility in groundwater. As such, it is believed that radium and for that matter radiological contamination on MOD sites poses a relatively low risk to human health and the wider environment.

While the MOD has information on those sites which have been subject to land quality assessment, the information is not held centrally and could be provided only at disproportionate cost.”

Extract from the recommendations in RWMAC's Advice to Ministers on The Ministry of Defence's Arrangements for Dealing with Radioactively Contaminated Land

"MoD should ensure, possibly in conjunction with other Government departments, that existing records of characterisation and remediation of its past and present landholdings are not lost"

"MoD should be as clear as is reasonably possible about its contaminated land holdings, and should set up a database for this purpose (drawing on LQA findings and on previous site investigation records, including desk studies and other land quality data). At the time of finalising this report (June 2000), the Ministry indicated that it was in the process of developing such a database;"

More detailed information from the RWMAC report relating to record keeping

Dalgety Bay - an example of the internet empowering citizens

2011-10-18T01:45:00.000-07:00

The recent revelations in the media concerning the radioactive contamination of the beach at Dalgety Bay may just provide the impetus to get something done to finally clear of the beach of contamination and to call the polluter to account.
MIlcon Research and Consulting played a key role in supporting the media through analysis of publically available information particularly documents published by SEPA on their website.
The example of Dalgety Bay demonstrates that public bodies can be now held to account by the empowerment of citizens through the use of the internet. Websites such as the “What do they Know” facilitate the use of both the FOI and EIR regulations by the citizen and ensure that information provided is publicly available.

Nuclear Liabilities Management Strategy

2011-10-14T01:23:00.000-07:00

MOD despite a statement in its own policy that NGOs must be involved in the development of the “Nuclear Liabilities Management Strategy”; MOD has confirmed through a response to an FOI request that no NGOs were involved or consulted.

This again demonstrates MOD lack of commitment to its own policies; and the continuing use of the discredited “announce and defend” approach to stakeholder engagement.
In view of the lack of stakeholder involvement in the “Nuclear Liabilities Management Strategy”, it will be interesting to see how many opportunities this will open for judicial challenge relating decisions taken to implement the strategy with all the cost and delays associated with such challenges. In particular the requirement for strategic environmental assessments of policies plans etc and the associated duty to involve stakeholders.

It is interesting to contrast this to enlightened way in which the NDA went about developing their strategy, involving stakeholders through its development.

FOI request
“Request for Information under the Freedom of Information (FOI) Act 2000
Thank you for your email of 16 September 2011, via www.whatdotheyknow.com, in which you ask:

Can you please tell me if NGOs were consulted in the development of the recently
published MOD Nuclear Liabilities Management Strategy” and if so which NGOs were involved in the consultation. If NGOs were not involved in the consultation on the MOD “ Nuclear Liabilities Management Strategy” why were they not involved despite the commitment in the MOD “MINISTRY OF DEFENCE POLICY FOR DECOMMISSIONING AND THE DISPOSAL OF RADIOACTIVE WASTE AND RESIDUAL NUCLEAR MATERIAL ARISING FROM THE NUCLEAR PROGRAMME” That they should be involved .

This is considered to be a request for information under the FOI Act. Section 1 of the Freedom of Information Act gives an applicant the right to access recorded information held by public authorities at the time the request is made and doesnot require public authorities to answer questions, provide explanations or give opinions, unless this is recorded information held. I can confirm that the Ministry of Defence holds no recorded information that would provide an answer to the questions you have asked in your request.”

MINISTRY OF DEFENCE POLICY FOR DECOMMISSIONING AND THE DISPOSAL OF RADIOACTIVE WASTE AND RESIDUAL NUCLEAR MATERIAL ARISING FROM THE NUCLEAR PROGRAMME

MOD Nuclear Liabilities Management Strategy

Radium contamination of Dalgety Bay in Scotland

2011-10-10T06:19:00.000-07:00

Since the discovery of radium contamination on the beach at Dalgety Bay in Scotland in the early 1990s there appears little evidence that the problem has been properly addressed and the source of the contamination removed preventing the re-population of the beach with highly radioactive fragments of radium. SEPA in their recently published report concluded that :-

“Work undertaken by Defence Estates has confirmed the typical number, size and
activities of point sources at Dalgety Bay. It has also shown that the beach area
continues to re-populate with high activity point sources once cleared and that it is
estimated that over a year these will number about 100 in total. Thus there remains a
hazard to the public at Dalgety Bay from these point sources, and the total number of
radioactive sources at Dalgety Bay remains unknown.

Based on the results of solubility testing, indicative committed effective doses could
range up to 128 mSv for a 3 month old infant, with the majority of the dose being from radium daughters. However, the 2010 work has indicated that the solubility of these sources may be greater than previously expected (25% rather than up to 15%). Doses could also be greater if the relatively small number of samples subjected for leaching was not representative of the population as a whole. Overall our 2006, 2009 and this 2011 report have shown that several of the sources recovered from Dalgety Bay could give committed effective doses in excess of the relevant value for some age groups, prescribed in the Statutory Guidance issued to SEPA by the Scottish Government for Radioactive Contaminated Land.

Direct measurements of point sources to determine potential skin doses have been
undertaken. The results have been reported separately which indicate that it is unlikely the dose rate from the Dalgety Bay sources could exceed the relevant criteria specified in the guidance issued to SEPA by the Scottish Government for Radioactive Contaminated Land.

The potential committed effective doses from Dalgety Bay point sources remain
significant. The primary pathway of concern is via ingestion and as any potential effects (e.g. cancer) may take many years to be expressed and be unlikely to be easily attributable to an exposure from a visit to Dalgety Bay.

The locations and suitability of the current signage, as an optimal intervention measure, should be reviewed. Given the numbers of people using the beach there is also a need for an ongoing monitoring and recovery programme to reduce the hazard present on the beach. In the longer term, as radium has a half life of 1600 years, a programme of work to determine the primary source of the contamination at Dalgety Bay beach and isolate it from the environment may be the only manner in which the level of contamination can be reduced to a negligible level where no further interventions are needed. Given the potential costs involved of developing any robust risk assessment this approach to isolate the contamination from the environment may be the most cost effective approach to mitigating the contamination in the long term.

The absence of any programme to isolate the radioactive contamination at source will mean that sources which pose a significant hazard to health will continue to be present on the beach at Dalgety Bay. It is concluded that a programme to identify the primary source or sources is needed to reduce the number and hazard of these sources to the public using the beach at Dalgety Bay. “

A point to note is that a recent Press report indicates that material from the beach has been used in children’s sandpits; I do not believe that the risk assessments took account of this possibility.

The Committee on the Medical Effects of Radiation (COMARE) has been tasked to provide advice on the health effects of radium exposure at Dalgety Bay, but has yet to publish its findings.

“Dalgety Bay
The appearance of radium particles at Dalgety Bay first came on the committee’s work programme back in 1990. The discovery of much smaller particles recently has seen this item reappear for further consideration. A site visit by members of the Dounreay Working Group was carried out on 13th May 2008. The committee is continuing to liaise with the MoD and SEPA on this matter. The committee will also be kept aware of other similar contaminated sites as and when issues arise.”

Background information about the historic use of radium by the Ministry of Defence and the problems this created with regard to contaminated land can be found in a report by RWMAC dating back to 2000.

Most recent Press articles as of October 2011

I find it most surprising that after 20 years the beach still remains contaminated and a significant risk to those who use it; that SEPA, has so far failed to make the “polluter pay” to clean this contamination up and make the beach safe for unrestricted use. The present publicity relates to the beach little has been said about the potential contamination inshore from the beach.

In response to the press reports the MoD insisted that it took safety very seriously. “We have yet to see the latest findings from SEPA,” said a ministry spokeswoman. “Should significant risks present themselves then SEPA has the necessary statutory powers to address these.”

This shows how the MOD is doing its best to wash its' hands of this issue and leaving it to others to clean up, so much for MOD saying it takes safety seriously

Site update

2011-10-10T01:30:00.000-07:00

Links to the Milcon Research and Consulting pages on Facebook and to the FOI requests on the "What do they know" website have been added to this Blog.

These can be found on right side of this page under the list of external links.

Staff cuts on submarines impact on nuclear safety

2011-10-04T01:23:00.000-07:00

Telegraph reports

Submariners sacked at sea despite MoD promise

“A fifth of submarine medics serving on boardTrident nuclear deterrent and hunter killer submarines have been axed,including one who cared for the wounded on the HMS Astute after a crewman wenton the rampage. It is understood that several sailors were told they werelosing their jobs while conducting covert operations after their captainsreceived a signal at sea from the Ministry of Defence”

“MedicalAssistants (Submariners), known as MASMs, play a key role as they have to giveboth primary and secondary care to personnel on board when the boats are manymiles from land. They also provide the main radiation checksand radiological safety on the Navy’s 11 nuclear powered submarines.”

“Their role is so important that if there areless than two on a Vanguard nuclear deterrent boat it cannot sail.”

“We were told that the Submarine Service wasprotected from cuts but now medics have fallen into the bracket which isabsurd,” one submariner told The Daily Telegraph. “Submarine medics are soughtafter but we a losing almost a quarter of our quota of available medics.”.

“It is understood that between 15 and 25 out of100 deployable medics have been sacked. The medics receive two years intensivetraining, including NHS placements, and train intensively on dealing withradiological illness and exposure. On special missions a doctor will join themon board.”

If true this indicates how safety is againbeing trumped by the urgent need to find cost savings. I also suspect that noassessment of the impact of these cuts on safety has been carried out, asrequired by para 45 of Chapter 3 of JSP 815 “Management of OrganisationalChange”. The MOD failed duty to respond to a FOI request on this issue datingback to July, despite a legal duty to do so within 20 working days.

Below is an extract from a course prospectus that gives a goodindication of Medical Assistants (Submariners) and the theirradiation protection duties.

I.A.W City and Guilds Radiation Safety Practice Scheme Handbook 7410
Biological Aspects of Ionising Radiation
Radiation Protection
Radiation Detection and Measurement
Structure of Matter and Radioactivity
Dosimetry
Storage and Transport of radioactive material
Accidents and Incidents.
Industrial uses of radioactive material
Regulation and Guidance
Environmental Control

ThisGuardian report on the 2010 DNESB annual report gives an indication of how theMOD is using the cuts in the number posts as a means of reducing the number ofvacant SQEP posts which gives the appearance of an improvement in the situation.

SQEP staffing has been raised as a significant risk for anumber of years in both the DESB and DNESB annual reports. See para 16 of the2010 DNESB report.

So the statement “A Royal Navy spokesman said: "Therewill be no shortage of medical personnel on our submarines. Redundancies areonly being made in surplus areas." Thisseems very strange when set against the 2010 DESB and DNESB reports leavingopen the question as to what is the true position!!

The cuts also demonstrate how little notice Ministers takeof reports from the MODs main nuclear and safety committees and the DefenceNuclear Safety Regulator.

Defence Nuclear Environment and Safety Board report 2010

2011-08-26T00:07:00.000-07:00

The 2010 Defence Nuclear Environment and Safety Board report has been published.

The DNESB 2010 assurance report again shows that the ever continuing reduction in resources is putting the safety of MOD staff and the public at increasing and indeed unacceptable risk.

The DNESB assurance reports clearly show the inability of the Defence Nuclear Safety Regulator to influence decisions by Ministers and the Defence Board to ensure the provision of adequate resources for the delivery of nuclear safety within the MOD. This also demonstrates the need for a Nuclear Regulator independent of the MOD with proper powers of regulation and enforcement.

The 2010 DNESB and earlier reports clearly demonstrate how the MOD has failed to allocated sufficient resources to nuclear safety in particular the lack of progress on recruiting suitably experienced and qualified staff, the commitment to produce a decommissioning strategy supported with the necessary funding.

Office of Nuclear Regulation and the Health & Safety Executive (ONR/HSE) effective regulators of Government ?

2011-07-06T08:40:00.000-07:00

In a recent FOI the HSE was asked; could you please tell me what action ONR/HSE is taking under Health and safety legislation to ensure that standards of safety are maintained in light of MODs’ own admission that safety performance has been and continues to be compromised as a consequence of ever reducing resources.” The full text of the request is given at Annex A.

The ONR/HSE have so far failed to provide an answer to this FOI request.

The fact that the Strategic Defence and Security Review ( SDSR ) is a politically driven process within Government and that the ONR/HSE is part of the Government albeit at arms length might explain the HSEs’ reluctance to take action against the MOD whereas the HSE is far more proactive when it comes to the safety failures of commercial operators.

It is also notable that MODs own requirements for the prior assessment of the impacts of organisational changes set down in JSP 815 “Management of Organisational Change” by MODs ( Annex B) own admission have been largely ignored.

It is clear that the political agenda driving the SDSR and the need to save money are trumping the health and safety of MOD employees and the public.

It is also clear that the ONR/HSE is failing to act as an effective Regulator and in doing so is complicit in putting the safety of MOD employees and the public at unacceptable risk.

Annex A

“MOD have just published annual report on Safety, Environmental Protection and Sustainable Development for 2010

As can been seen in the extract below from the DESB 2010 report it appears that the lessons from the Haddon Cave Review and report have been ignored; in that, decisions were taken in the SDSR/Defence Reform Review without a proper consideration of their impact on safety generally and nuclear safety in particular

Link to Haddon cave Report

"43. SDSR/Defence Reform. The Strategic Defence and Security Review did not, formally, assess the major implications for the safety of the department and there has been insufficient time to properly assess the impact of the SDSR options taken before decisions were made. Therefore the full impact of these decisions might not be known for a number of years. That said, the major issues raised by the Front Line Commands regarding wider PR11 options were discussed at a DESB in January 2011, although timescales prevented a full assessment.

44. It is unclear what impact the Defence Reform Review will have on safety. However the need to reduce costs and the severe reduction in personnel numbers will undoubtedly place a severe strain on safety systems. The department must ensure that mitigation plans are in place to maintain the appropriate standards. SSD&C is in close discussions with the Reform Review team as to how any outcome will impact on some of the wider aspects work and Defence safety as a whole."

The part of the report about Defence Nuclear Environment Safety Board (DNESB) clearly indicates that the ability of MOD's internal Regulator DNSR to do its job is being compromised by the lack resources to quote from the report "further aggravated by constraints on regulatory capacity"

"11. The DNESB Chairman reports that an acceptable standard of nuclear and radiological safety and environmental protection has been maintained in the operation and delivery of the Defence nuclear programmes. Individually, none of the DNESB's 8 issues reflect an immediate safety or environmental concern; but together they represent a potential compromise to compliance or the demonstrability of compliance and, taken together, they present a risk that it will become increasingly difficult to maintain that the Defence nuclear programmes are being managed with due regard for the protection of the workforce, the public and the environment. The principal threats to safety in the Defence nuclear programmes in the medium term are the adequacy of resources, both money and staff complement, and the maintenance of a sustainable cadre of suitably competent staff (RN, MOD civilians and in industry partners). Confidence in making the Substantial Assurance judgement is reduced from 2009 due to the adverse trend in resources (which I expect will become yet more painful), further aggravated by constraints on regulatory capacity.

12. Duty Holders have maintained Continuous at Sea Deterrence (despite increasing pressures on manpower and some equipment fragility) and have safely delivered the required military capability from the Submarine Arm despite reduced platform availability; HMS ASTUTE has become the first new SSN in the fleet since 1991.

13. The main risks/issues are:

a. Lack of adequate resource to deliver the Defence nuclear programmes safely.

b. Measures already in hand may be insufficient to address the present and predicted shortage of Nuclear SQEP in the RN among MOD civilians and Defence contractors.

c. The frequency and significance of incidents remain too high as a result of poor control of work."

Could you please tell me what action ONR/HSE is taking under Health and safety legislation to ensure that standards of safety are maintained in light of MODs’ own admission that safety performance has been and continues to be compromised as a consequence of ever reducing resources.”

Annex B

Defence Environment and Safety Management JSP 815 CHAPTER 3ORGANISATION “MANAGEMENT OF ORGANISATIONAL CHANGE

45. Without adequate planning and analysis, change may result in
the inadvertent erosion of the emphasis on high standards of
environment and safety performance. This may manifest itself in the
loss of established formal and informal environment and safety
processes, loss of critical safety culture, knowledge and
expertise, or lack of sufficient personnel to safely operate and
maintain a process with consequent increased likelihood of
accidents and incidents.

46. Duty holder organisations shall, prior to any significant
changes, conduct an environment and safety assessment to baseline
the existing arrangements for critical environment and safety
activities; analyse the impact and justify the proposed changes.
The rigour of the assessment shall be proportionate to the
significance of the change. Where appropriate and proportionate,
the organisation should seek the views of the relevant FSBs or
discipline leads.

47. It shall be the responsibility of the individual or team
proposing the initiative to implement and complete the assessment
prior to making any changes. Outcomes of assessments shall be
included in any submissions seeking endorsement to continue with
the implementation phase. Once implemented, the impact of the
changes shall be reviewed after an appropriate period.”

MOD response to the ONR interim report Japan - reactor accident

2011-06-24T02:20:00.000-07:00

On the 18 May 2011 the Chief Nuclear Inspector published an interim 'lessonslearnt' report early analysis of Japanese accident which made 26 recommendations for UK.

MOD was asked in FOIs about whether or not it made a submission to Dr Weightman `s interim report and how the MOD was responding to the reports' recommendations. The responses to the FOI requests are given below :-

"our correspondence dated 25 May 2011 has been considered to be a request for information in accordance with the Freedom of Information Act 2000. You requested the following information:

"Please could you tell me

a: if MOD made a submission to Dr M Weightman of the ONR in
relation his interim report 'lessons learnt' report "Early analysis of Japanese accident makes 26 recommendations for UK"

b: If a submission was made, please could you provide me with a
copy of the submission"

I am writing to advise you that following a search of our paper and electronic records, I have established that the information you requested is not held by the Ministry of Defence because we did not provide a submission to Dr Weightman of the ONR."

When specifically asked about how MOD was responding to the recommendation 4 of the ONR interim report

"Request for Information – Release of Information under the Freedom of Information Act "Thank you for your request of 18 May 2011 relating to the publication of the Office for Nuclear Regulation (ONR) interim report, in which you ask: Please could you tell me what specific actions the MOD will be taking to implement recommendation 4 of ONR interim report "Japanese earthquake and tsunami: Implications for the UK Nuclear Industry": "Both the UK nuclear industry and ONR should consider ways of enhancing the drive to ensure more open, transparent and trusted communications, and relationships, with the public and other stakeholders."

This enquiry is being treated as a request for information under the terms of the FOI Act. I can confirm that the Department does not hold any information that falls within the scope of your request.""

The MODs' response to these FOI requests provides yet more examples of the MOD failing to engage and learn lessons with a view to improving safety of the nuclear weapon and propulsion programmes.

MOD annual report on Safety, Environmental Protection

2011-06-10T00:23:00.000-07:00

MOD has published its annual report on Safety, Environmental Protection andSustainable Development for 2010

As can been seen in the extract below from the DESB 2010 report it appears that
the lessons from the Haddon Cave Review and report have been ignored; in that,
decisions were taken in the SDSR/Defence Reform Review without a proper
consideration of their impact on safety generally and nuclear safety in
particular

"43. SDSR/Defence Reform. The Strategic Defence and Security Review did not,
formally, assess the major implications for the safety of the department and
there has been insufficient time to properly assess the impact of the SDSR
options taken before decisions were made. Therefore the full impact of these
decisions might not be known for a number of years. That said, the major issues
raised by the Front Line Commands regarding wider PR11 options were discussed at
a DESB in January 2011, although timescales prevented a full assessment.

44. It is unclear what impact the Defence Reform Review will have on safety.
However the need to reduce costs and the severe reduction in personnel numbers
will undoubtedly place a severe strain on safety systems. The department must
ensure that mitigation plans are in place to maintain the appropriate standards.
SSD&C is in close discussions with the Reform Review team as to how any outcome
will impact on some of the wider aspects work and Defence safety as a whole."

The part of the report about Defence Nuclear Environment Safety Board (DNESB)
clearly indicates that the ability of MOD's internal Regulator DNSR to do its
job is being compromised by the lack resources to quote from the report "further
aggravated by constraints on regulatory capacity"

"11. The DNESB Chairman reports that an acceptable standard of nuclear and
radiological safety and environmental protection has been maintained in the
operation and delivery of the Defence nuclear programmes. Individually, none of
the DNESB's 8 issues reflect an immediate safety or environmental concern; but
together they represent a potential compromise to compliance or the
demonstrability of compliance and, taken together, they present a risk that it
will become increasingly difficult to maintain that the Defence nuclear
programmes are being managed with due regard for the protection of the
workforce, the public and the environment. The principal threats to safety in
the Defence nuclear programmes in the medium term are the adequacy of resources,
both money and staff complement, and the maintenance of a sustainable cadre of
suitably competent staff (RN, MOD civilians and in industry partners).
Confidence in making the Substantial Assurance judgement is reduced from 2009
due to the adverse trend in resources (which I expect will become yet more
painful), further aggravated by constraints on regulatory capacity.
12. Duty Holders have maintained Continuous at Sea Deterrence (despite
increasing pressures on manpower and some equipment fragility) and have safely
delivered the required military capability from the Submarine Arm despite
reduced platform availability; HMS ASTUTE has become the first new SSN in the
fleet since 1991. 13. The main risks/issues are:

a. Lack of adequate resource to deliver the Defence nuclear programmes safely.

b. Measures already in hand may be insufficient to address the present and
predicted shortage of Nuclear SQEP in the RN among MOD civilians and Defence
contractors.

c. The frequency and significance of incidents remain too high as a result of
poor control of work."

Associated media reports

Daily Express

Observer

The Scotsman

Sunday Post

Caledonian Mercury

Rob Edwards Blog

Milcon R & C blog report on earlier DESB reports

Proposal for a MOD Independent Safety Organisation (ISO) to include the Defence Nuclear Regulator

2011-06-10T00:19:00.000-07:00

Proposal for a MOD Independent Safety Organisation (ISO) to include the Defence
Nuclear Regulator.

As can be seen from the reply to a FOI (below) there in the past there was the
post of MOD Chief Safety Officer; former MOD Chief Safety Officer's headed up
the MODs' central safety organisation independent of the duty holders/TLBS. But
the role was abolished and no longer exists. The proposal to re-establish a
Independent Safety Organisation (ISO), seems as if the ISO is the old MOD
central safety organisation reborn !!

The present central organisation Safety, Sustainable Development and Continuity
(SSDC) Division represents the remaining rump of the former central safety
organisation largely denuded of staff with professional experience and
qualifications in safety as demonstrated by the abolition of the post of MOD
Chief Safety Officer whose post holders had qualifications such as PhDs in
physical chemistry and gas explosions with extensive experience in explosives
and ordnance safety.

Implicit in the proposal for a MOD Independent Safety Organisation (ISO) is that
the Defence Nuclear Regulator will be subsumed within it. It would be far better
for public confidence that the HSE etc should regulate MOD controlled nuclear
activities rather than to perpetuate the current system of internal regulation
with its inherent lack of transparency

From the DESB 2010 report

"39. Haddon-Cave Wider Aspects Work The DESB has agreed that some of the issues
raised in the Haddon-Cave report have implications for the wider MOD. These
issues have been translated into seven workstrands, which SSD&C are
coordinating.

40. Chief among these workstrands is an examination of the current regulatory
regimes in place in the department. The examination to date has identified that
many of the existing internal frameworks do not meet the recommendations of the
Haddon-Cave report (principally that regulators should be independent). These
findings have been agreed by the DESB. Subsequently SSD&C has been tasked with
scoping options for a possible Independent Safety Organisation (ISO). This work
is currently focused on establishing the remit of an ISO with a view, if agreed,
to producing a costed organizational option by May 2011. It is hoped that the
ISO, if created, as the single safety regulator in the MOD (bar aviation), will
have a positive impact on the assurance of Departmental safety standards. It
will also be closely involved in the production of future annual assurance
reports."

Response to an FOI request asking for details of the post of MOD Chief Safety
Officer

DBR-SSDC-Safety Enquiries (MULTIUSER)

Ministry of Defence

1 February 2011

Thank you for your request under the Freedom of Information Act dated 31
December 2010 enquiry asking for details of the post of MOD Chief Safety
Officer, and enquiring after the safety qualifications for the officers who have
held the post.

There is currently no post of MOD Chief Safety Officer. There have been four
members of the senior Civil Service who have had this role (either as Chief
Safety Officer or Chief Environment and Safety Officer) written into their post
description. The titles for the posts were Director of,successively: Directorate
Defence Health and Safety (DDefH&S), Directorate Safety, Environment and Fire
Policy (DSEFPol), and Directorate of Safety and Claims (DS&C). During the last
of these, the role of CESO(MOD) was discontinued. All business areas (eg Army,
Navy, Air Command etc) of MOD do have their own CESO.

As there is no such post, there is no professional safety qualifications
associated with it. Those who held the role as part of their posts had
qualifications such as PhDs in physical chemistry and gas explosions with
extensive experience in explosives and ordnance safety

Contractorisation of nuclear weapon handling etc at RNAD Coulport

2011-06-06T03:48:00.000-07:00

Reports in the press ( ref 1 ) indicate that MOD is intending to contractorise the weapon handling work at the RNAD Coulport ( ref 2 )

The “STRATEGIC WEAPON SYSTEM ACTIVITIES FUTURE DELIVERY OPTIONS PROJECT (SWSAFDOP) – SPECIAL TEAM BRIEF No. 002/11 24 May 2011” ( ref 3 ) indicates that “MoD will remain in overall charge, with Naval Base Commander (Clyde) retaining overall responsibility for Nuclear Activities, Explosive Safety Policy, Security and Emergency Management Planning, including retention of the Incident Commander role in response to all contingency scenarios and the role of dual authorisee for the site.”

This is arrangement is dependent on MOD demonstrating that MOD exercises a sufficient degree of control of the work. Annex A ( ref 3 ) suggests that rather than exercising control the MOD role is surveillance and assurance rather than day to day control of work activities. It is therefore debateable whether MOD exercises sufficient control to be considered “in control of the work”

The proposal for the contractorisation also recalls some years ago a similar and unfortunate situation at Dounreay where it was found that the complex web of relationships for responsibility of safety made it very difficult to understand where responsibility for safety lay and can lead to hazards and risks falling into gaps between the various interfaces between site owner and the various contractors etc. This can lead to failure to address and control the hazards and risks. The potential for confusion is further demonstrated by the reference to “dual authorisee “; I am not aware of any other licensed/authorised sites where there are two authorisation/license holders.

If contractorisation goes ahead It would be far better at RNAD Coulport to follow the model MOD adopted at AWE ( 4 ) where the site is operated and controlled by a contractor, regulated by ONR and licensed under the Nuclear Installations Act.

References

1: http://www.heraldscotland.com/news/home-news/anger-as-us-arms-dealer-takes-over-running-of-scottish-nuclear-bomb-base-1.1104095 or http://tinyurl.com/3e4nowa

2: http://en.wikipedia.org/wiki/RNAD_Coulport

3: http://robedwards.typepad.com/files/mod-privatisation-plan-3.doc

4: http://en.wikipedia.org/wiki/Atomic_Weapons_Establishment

MOD Blunder on Nuclear Report

2011-04-19T00:51:00.000-07:00

MOD failure to properly redact sensitive sections of nuclear documents released in response to an FOI request puts national security at risk. See the reports in the Telegraph and BBC

The Telegraph reported “The MoD was last night examining other documents handled by the same junior official responsible for redacting the nuclear report” this report seems to suggest that management is trying to shift the blame to the most junior member of staff involved. The report also would seem to suggest that the Americans may be less than pleased.

“ Secret details of how US Navy submarine reactors were maintained”

This incident may be indicative of the impact caused by the loss of staff and experience within the MOD

Incident aboard HMS Astute - Human factors and nuclear safety

2011-04-11T00:50:00.000-07:00

The unfortunate incident aboard HMS Astute that lead to the death of an officer and another being seriously injured raises concerns about failures to identify personnel who may be unsuitable for life aboard nuclear submarines. It is notable that that the HSE draws attention to the need to consider carefully human factors in the design of the man machine interface in nuclear activities.

So far as civil nuclear activities are concerned operators can leave the site and when on site have space and access to amenities where as in a submarine operators live, cramped within a machine, 24/7 over extended periods of time.

It would seem that human factors may have played a significant part in this unfortunate incident. Bearing in mind that some submarines as well as having a nuclear reactor have on board nuclear weapons, it is clear that lessons must be learnt to ensure such incidents do not occur again, which could lead to altogether more serious outcomes.

Link to HSE information on human factors

Link to Sunday Herald article

Quote used in article

"Fred Dawson, a former senior safety official with the MoD, said that the tragic events on Astute “may reflect pressure either domestic, or at work, on crew manning submarines”.

He added: “My concern is about the failure of management to pick up on people like this, and that such people are key to the safety of nuclear systems.”

Reference

Scott D Sagan, The Limits of Safety, organisations, accidents and nuclear weapons; Princeton University Press. ISBN-10: 0691021015 ISBN-13: 978-069102101

New UK nuclear industry regulator launched which includes defence nuclear activities

2011-04-02T07:12:00.000-07:00

New UK nuclear industry regulator Office for Nuclear Regulation (ONR) launched

"ONR has been established today as an agency of the Health and Safety Executive (HSE), pending planned legislation to establish it as a statutory body. The ONR will bring together the relevant nuclear regulatory functions of HSE (through its Nuclear Directorate) and the Department for Transport.

The organisation will ensure that those authorised to carry out nuclear activities, in both the civil and defence sectors, do so in a safe way – from power stations and radioactive waste to transport of materials and submarines. ONR staff will also regulate the security of civilian nuclear installations."

The Ministry of Defence is to be commended in moving away from its own system of internal regulation to civil regulation with all the benefits that brings, particularly of transparency and independence, the authorisation of defence related nuclear activities such as nuclear submarines, their berths the ship lift at Faslane, RNAD Coulport, nuclear weapon transportation and the Vulcan reactor at Dounreay etc.

Link to the ONR statement

Review of nuclear safety in light of the situation in Japan

2011-03-18T10:43:00.000-07:00

From the HSE web site

Mike Weightman on events in Japan

"Mike Weightman^[1], chief nuclear inspector and head (director) of the Health and Safety Executive’s Nuclear Directorate^[2], the UK’s independent nuclear safety and security regulator, said:

“Since Friday, the Health and Safety Executive's Nuclear Directorate has been monitoring events in Japan closely. We have provided specialist technical advice to the UK Government and ensured there are no immediate implications for the safety of the UK nuclear facilities. This is a difficult time for Japan and we are ready to provide support as necessary. We must establish the facts, which are emerging and not yet fully known. The nuclear regulatory standards in the UK ensure our nuclear power reactors are robust against all the external hazards that may be reasonably foreseen in the UK and I agree with advice that seismic and tsunami events of such extreme magnitude as seen in Japan are not foreseeable for the UK. However, it is important that we consider the implications and learn any lessons to ensure we continue to secure the protection of people and society.

Chris Huhne ^[3], Secretary of State for Energy and Climate Change, has asked me to provide a report ^[4]on the implications of the unprecedented events in Japan and the lessons to be learned for the UK nuclear industry. There will be an interim report by mid May 2011 and a final report within six months. The reports will be put in the public domain and will be comprehensive, wide in scope and based on the best technical advice, consulting nationally and internationally with colleagues and organisations who, like us, have the safety and security of people and society uppermost in our minds.""

It will be interesting to see if the review extends to defence nuclear activities and if it does will the reports be made public.

MOD withholds information on how the recommendations of the Haddon Cave report are being taken forward

2011-02-18T03:26:00.000-08:00

MOD is withholding information about how the recommendations of the Haddon Cave report are being taken forward particularly in the context of nuclear safety. The information is being with held on the grounds:

“Information held by a government department or by the Welsh Assembly Government is exempt information if it relates to

(a) the formulation or development of government policy,

On this occasion we believe that the need to allow free and frank discussion between officials and ministers outweighs the public's right to information. This is because the assessment is ongoing and we would not wish to prejudice any future decisions. Once the Department has decided on a course of action a public statement will be made. “

The Haddon Cave report was published nearly two year ago in 2009, the delay in acting on the wider implications of the report particularly for nuclear safety seems to indicate that MOD has yet to make any decisions on how the recommendations are to be acted upon. If there was good news to report I am sure that MOD would be only too keen to publicise that news.

MOD nuclear decommissioning strategy, a state secret

2011-02-12T13:04:00.000-08:00

Following an internal review relating to a FOI request to the MOD to provide information about its nuclear decommissioning strategy; MOD continues to keep details of its nuclear decommissioning strategy secret and has reneged on its own policy to involve stakeholders including NGOs in the development of its decommissioning strategy preferring the old discredited “announce and defend” approach to decision making.

The MOD policy makes clear that the strategy is to be developed in consultation with stakeholders which means that the draft strategy should be a public document.

The following references in the MOD policy support this view

Para 8 K “consulting appropriate public and stakeholder groups on the options considered and the contents of the strategy”

Para 10 “Whilst in no way underestimating the task ahead the MOD remains confident that in conjunction with stakeholders (OGDs and NGOs) it is able to deliver the policy outcomes set out above”

Policy statement

Extract from the MOD’s internal review.

“MOD Decommissioning and Disposal Strategy (Section 35 and Section 22)

12. DE&S informed you that the information is being withheld in its entirety under section 35(1)(a) and explained that although there is a public interest in the development of the MOD's Decommissioning and Disposal Strategy, there is a greater public interest in MOD having the space to develop that strategy in an effective manner, including proposing and discussing new ideas, without the fear that there would be early disclosure of information before it has had an opportunity to mature. At the time of your request the consultation process was ongoing and I can confirm that this has not yet been finalised. lt is vital for MOD to be able to discuss all options in a free and frank manner and that disclosure would be detrimental to this process as participants would be less than free and frank if they were concerned that their contributions would later be subject to disclosure. Again, I can also inform you that this exemption is engaged where the information can be accurately characterised as relating to formulation or development of government policy.”

It notable that the information requested does not relate to policy but the strategy that delivers the policy outcomes referred to in “Ministry of Defence Policy for Decommissioning and Disposal of Radioactive Waste and Residual Nuclear Material arising from the Nuclear Programme.

The MOD approach is in stark contrast to the open and transparent processes which the Nuclear Decommissioning Authority (NDA) employs; involving stakeholders including NGOs in the development of their strategy. The NDA seems to have no problems discussing new ideas, or fears about the early disclosure of information before it has had an opportunity to mature.

The report on non NDA Liability Management Strategy published in March 2010 indicates MOD’s failure to address liabilities for Exotic Fuel and Higher Active Waste

To quote from the report

“MoD currently owns the largest stock of exotic fuel which is stored at Sellafield. MoD does not have a long term liability management plan for these fuels so their impact on NDA‘s exotic strategy is as yet undetermined. There is the potential that this could form part of the exotic fuels inventory and hence may influence the NDA strategy” and

“Higher Active Waste. Wastes from BE reprocessing and potentially from MoD fuel processing will require (i) long term management, (ii) appropriate conditioning for ultimate disposal, and (iii) disposal in the GDF”.

This demonstrates that MODs inability to develop a strategy for managing its nuclear liabilities is impacting negatively on the NDA and nationally on the “managing radioactively waste safely” process.

This all tends to suggest that MODs reluctance to provide information on its strategy for managing nuclear decommissioning liabilities is to avoid embarrassment about an inability to make decisions on how to manage these liabilities, failure to afford them proper priority and most of all, a lack of funds.

What no decommissioning Strategy !!!

2011-02-05T09:01:00.000-08:00

MODs' own reports acknowledge there is no funding to deliver the decommissioning strategy. However a properly funded decommissioning strategy is one of the key requirements for holding a nuclear site license in the civil sector, why should MOD be any different?

From the 2009 DNESB report

“Decommissioning & Disposal. 2005 issue 3 updated and reduced.
No Decommissioning and Disposal Strategy and no funded plan for decommissioning and disposal of submarine including adequate facilities to de-fuel them at the end of service life”

However the guidance from the HSE to inspectors on decommissioning nuclear licensed sites requires licensees’ to demonstrate that they have funding to carry out decommissioning and for state owned industry should describe their corresponding arrangements.

Extract from “NUCLEAR SAFETY DIRECTORATE GUIDANCE FOR INSPECTORS ON DECOMMISSIONING ON NUCLEAR LICENSED SITES

A2.3.14 Demonstration of Financial Provision

A2.3.14.1 Comprehensive estimates of the costs of decommissioning should be provided and linked to the activities to be carried out. All significant activities should be taken into account including corporate and general infrastructure responsibilities; radioactive waste management, storage and disposal; decontamination and dismantling works; care and maintenance; monitoring and surveillance and any other associated activities. Major cost components should be identified together with the distribution of costs with time. Any assumptions made on discount rates and the timescales over which they have been applied should be justified (see Appendix 6).

A2.3.14.2 Licensees should provide details of the arrangements for the funding of their nuclear liabilities. In the case of the privatised industry the financial provision is expected to be contained in segregated funds, kept separate from other company funds. The state owned industry should describe their corresponding arrangements. Licensees should provide a demonstration of the adequacy of the financial provision being made to implement the strategies. This should show that the strategy does not economically foreclose on earlier options for decommissioning, including an explanation of how the costs will change and the money will be provided if alternative options are chosen.”

Extract from a note by the Health & Safety Executive- Financial Implications of Licence Condition Compliance at NDA Sites:

“Financial Implications for Site Licensees
HSE clearly has an interest in whether the site license company (SLC) has reasonable expectation of access to sufficient resources to enable it to comply with all the Licence Conditions, and to have confidence that those resources will continue to be available at least for the term of the NDA contract. Confidence in the likely access to adequate and secure funding is one factor which HSE takes into account in its continuous assessment of whether an SLC is, and is likely to remain, a fit and proper body to hold the nuclear site licence (bearing in mind that if not happy with the SLC’s fitness, HSE has the power to revoke a licence at any time, and to impose suitable controls on the ex-licensee via Directions issued under the Nuclear Installations Act).”

The MOD is not subject regulation by the Nuclear Installations Act 1965 (NIA65) but subject to a system of internal regulation enforced by the Defence Nuclear Safety Regulator (DNSR); it is clear that DNSR lacks the regulatory power to ensure that the MOD decommissioning strategy is funded as would be the case on a civil site regulated by the HSE/NII.

If the MOD controlled nuclear activities were subject to regulation under the NIA65 it is worth considering if HSE would find the MOD fit and proper body to hold a nuclear site licence.

The lack of a funded decommissioning strategy provides powerful evidence of the need to apply the Nuclear Installation Act 1965 to MOD controlled nuclear activities.

Cash crisis hits MOD Nuclear Safety

2011-01-22T02:45:00.000-08:00

In response to an FOI request MOD has published the Defence Nuclear Environment Safety Board assurance reports for 2008 and 2009.

These reports highlight the very serious resource and funding problems now faced by the MOD in the delivery of the nuclear propulsion and weapon programmes safely without unacceptable risk to workers the public and the environment.

2008 DNESB report

2009 DNESB report

In 2009 The BBC reported on the Haddon cave review into the circumstances of a Nimrod aircraft crash in 2003 that results in 14 military personnel

To quote from the report

“Gen Cowan was promoted to a four-star general in September 1998 and appointed the first Chief of Defence Logistics in April 1999. He was responsible for carrying out the government's plan to unite the separate logistics support agencies for the Royal Navy, Army and RAF into a single Defence Logistics Organisation. In 2000 he announced a target of reducing costs by 20% by 2005, an aim which Mr Haddon-Cave QC said appears to have been "implemented across the board with a ruthless, if not 'Stalinistic', efficiency". In his report, Mr Haddon-Cave said Gen Cowan should have realised cutting costs could come at the expense of safety and airworthiness. Gen Cowan, who left the post in August 2002, is now retired.”

It’s clear from the 2009 DNEB report that little has changed with the exception of the even greater need for the MOD to cut costs is much greater than in the late 1990s and early 2000s. The DNESB recognised the impact of these cuts on safety in their 2009 DNSEB assurance report by acknowledging “The risk resulting from inadequate resources in the DNP has been closely monitored since it became a significant issue last year” . The DNESB highlighted the lack of adequate resource to deliver (and regulate) the defence nuclear programmes safely resourcing as the number one risk on the DNESB risk register.

Whilst the Nimrod crash lead to the unfortunate and regrettable deaths of 14 service personnel; an accident involving a nuclear weapon or a submarine reactor has a the potential to cause harm on a much greater scale because nuclear weapons are transported on public roads and submarines are berthed and serviced near or alongside centres of population.

This post has been reported in the Guardian

Link to the report on Chanel 4 News and Friday 28 January featuring coments I made during an interview with Julian Rush

Safety Concessions at Clyde Submarine Base

2011-01-20T07:45:00.000-08:00

Safety Concessions at Clyde Submarine Base

In response to an FOI asking for information about the number of concessions granted against nuclear safety regulations by year since 2000 at the Clyde Submarine Base. Safety concessions are situations where there is relaxation of a safety standard which agreed between the operator and the regulator. eg time allowed to reach a particular standard and mitigating measures taken to reduce hazard and/or risk.

MOD have provided the following information

“It may be helpful for me to explain that occasionally, for operational reasons, there may be a requirement to temporarily append a safety case and provide temporary suspension of associated conditions and limits of safe operations, or the authorised scope of operations at Her Majesty’s Naval Base (HMNB) Clyde. Prior to this decision the impact of such an amendment is carefully considered to ensure that any safety risk is both tolerable and as low as reasonably practicable (ALARP). On each occasion, when such an amendment is needed, HMNB Clyde will approach the Defence Nuclear Safety Regulator to consider and formally agree the amendment. Please find below a table which gives the number of amendments as agreed with the Regulator since 2000:

Year Number of amendments

2000 2

2001 0

2002 2

2003 1

2004 3

2005 2

2006 0

2007 0

2008 1

2009 3
2010 4

The relaxation of a safety standard which is agreed between the operator and the regulator providing the temporary suspension of associated conditions and limits of safe operations. This implies that workers/ the public and the environment are at greater risk.

Correspondence

http://www.whatdotheyknow.com/request/safety_concessions_clyde_submari#incoming-142601

Defence Nuclear Environment and Safety Board Assurance Reports for 2006 & 7

2010-12-26T11:28:00.000-08:00

In response to an FOI request MOD has published the Defence Nuclear Environment and Safety Board Assurance Reports for 2006 & 7 prepared by the Chairman of the Defence Nuclear Environment and Safety Board, which oversees nuclear and radiological safety in the naval nuclear propulsion and nuclear weapons programmes.

MOD aims to publish the reports for 2008 and 2009 by the end of January 2011.

The Defence Nuclear Environment and Safety Board Assurance Reports 2007 report

The 2007 DNESB report indicates that as of 2007 there is no funded decommissioning strategy to implement the agreed Defence Decommissioning Policy. Since 2007 there have been and will continue to be extreme pressure on MOD’s budgets and I suspect this situation may well have got considerably worse since 2007.

2007 DESB report to the Defence Board

The 2007 DESB report to the Defence Board makes no reference to the assurance report by the DNESB so it is reasonable to conclude that the DESB failed to make the Defence Board aware of the issues and concerns raised in the Defence Nuclear Environment and Safety Board Assurance Report for 2007.

There was a link within the report to “Duty Holder/FSB inputs 2007” but this is broken

Reference
Link to MOD Decommissioning and disposal policy paper

MoD bomb disposal harming Gibraltar marine life

2010-08-21T08:36:00.000-07:00

Guardian reports:-
"The Ministry of Defence is at the centre of a conservation storm after reportedly destroying marine life and threatening the habitat of endangered birds by blowing up old ordnance off the coast of Gibraltar.

Protesters say the "wanton and destructive" blasts, carried out in a designated UK-Gibraltar SCI (Site of Community Importance) left hundreds of dead fish floating on the sea's surface. "Thousands of marine animals are likely to have been killed and left to rot on the seabed," they said.

The campaigners called on military chiefs to stop the work immediately. They warned that such acts would not be tolerated by the people of Gibraltar and condemned the destruction as "the rape of Gibraltar's waters".

The controversy follows underwater detonations earlier this month when the MoD, which has a naval base and military garrison on the Rock, disposed of unexploded munitions and time-expired military ammunition.

It claimed it has permission under a 1998 agreement with the Gibraltar Ornithological and Natural History Society (GONHS) to use an area off Governor's beach, east of the Rock, to safely dispose of unwanted ordnance, including unexploded shells dredged up during construction work around the harbour.

It used "thunderflash" prior to the blasts to scare away fish, but said it was inevitable and unavoidable that some would be killed.

The GONHS told the Guardian, however, that while it had reluctantly accepted some detonations for the purposes of essential training in the 1990s, no written agreement was ever signed.

Since then the site had become part of the Southern Waters of Gibraltar SCI under the European commission habitats directive and part of the Estrecho Oriental Spanish SCI controversially declared by Spain. Any understanding reached 12 years ago would no longer apply, said the society.

The site was also important to one of the last mainland Iberian populations of the threatened western Mediterranean shag. There are fears that explosions, if carried out when the birds are fishing, could kill them.

"The MoD agreed to the UK-Gibraltar site designation and so should know that such activities would require an appropriate assessment," said Dr John Cortes, general secretary of the GONHS. "It appears also that the detonation was not an exercise, and therefore not essential training".

The Gibraltar Federation of Sea Anglers (GFSA) said the detonations took place less than 200 metres from the shore and killed valuable catch including bream and sea bass.

The explosions were so strong that one federation member, in a boat 200 metres away "felt the shockwaves". British military personnel were seen collecting the dead fish with a net.

"At a time when public opinion is behind a campaign to regulate and control fishing and protect the marine environment, British forces personnel have shown that they have no respect for or any regard for public opinion," said the federation.

Mario Ramos, former chairman of the GFSA who sits on the Angling for Change committee which is campaigning for the Gibraltarian government to introduce marine conservation legislation, said one of their members had captured it on his mobile phone and had caught over 400 dead fish floating.

"And it's not just the hundreds of fish that were floating on the surface. The fact is the sea bed is being completely demolished. Every living thing on the bottom, whether it's octopus, crabs, flat fish, shrimps, thousands of marine animals, it's all blasted.

"Gibraltar has got a very limited shoreline. The last thing we want to do is be blasting our own coastline," he said.

Such explosions were frequent in the 1980s and early 1990s. Concerns were voiced at regular meetings between the local community and the military through the "MoD Conservation Group". As a result, the MoD agreed to reduce them to an absolute minimum, and to use a maximum charge of just 2.2kg.

There was then a "marked decrease" in explosions, said Dr Cortes. "We were still not happy, and the matter did remain on our own agenda". However, the MoD then disbanded the conservation group.

There had been no explosions in recent years, he added, until the events of a few weeks ago.

The MoD said in a statement: "Given the construction work around the harbour, it is not unusual for unexploded munitions to be uncovered. These munitions must be expertly removed and safely disposed of, along with time-expired military ammunition.

"In a 1998 agreement between the Ministry of Defence and the Gibraltar Ornithology and Natural History Society, an area off Governor's beach to the east of the Rock was identified as being the safest area for these necessary explosive disposals."

A spokesman said that the MoD was in talks with the government of Gibraltar over the SCI designation. "We are aware of this [SCI] designation and are in discussion with the government. However, we only have one site designated within the waters off Gibraltar where we are able to destroy ordnance, so in order to carry out controlled explosions without unnecessarily risking lives we continue to use the area as designated by the government of Gibraltar for such use."

Radioactive waste management strategies Civil & Defence

2010-06-23T02:20:00.000-07:00

It is interesting to look at the NDA website and the NDA strategy which sets out to establish a world class programme of safe, cost-effective, accelerated and environmentally responsible decommissioning of the UK's civil nuclear legacy. I compared this with the information published by the MOD for the management of Defence related nuclear legacy on the MOD website, where I found no strategy for the management of the defence nuclear legacy; this is despite a policy statement published by MOD in 2007 and annex which sets out in detail the requirements for such a strategy. There is also a supporting policy fact sheet .

The absence of a strategy means there is no indication of how the policy outcomes are to be delivered, or when, what are the priorities, provision financial resources. It is notable that the DESB annual report 2009 to the Defence Board makes no reference to and provides no assurance on the delivery of the radioactive waste policy outcomes.

The 2009 DESB report does include an input from DNESB Chairman which mentions “that it will become increasingly difficult to maintain that the defence nuclear programmes are being managed with due regard for the protection of the workforce, the public and the environment.” but also contains no reference to the strategy for the management of the defence nuclear legacy. Despite this the DNESB Chairman reports “Substantial Assurance”.

MOD publishes report on 2009 safety concerns

2010-05-25T07:59:00.000-07:00

MOD published their key corporate health and safety report for 2009 which has been provided to me in response to an FOI request.

MOD have identified a number of key themes that have emerged from 2009, they are:

"• The pressure that resource constraints are placing on safety and the need to ensure that decisions with safety implications are taken at the right level.

• A continuing shortage of personnel, both those with the necessary safety qualifications and those with sufficient experience to discharge their safety responsibilities.

• Concern over the cumulative effects of change, in particular personnel moves resulting in a dilution of available experience and competence."

Nuclear safety
"A key area of concern highlighted by the report is that it will become increasingly difficult to maintain that the defence nuclear programmes are being managed with due regard for the protection of the workforce, the public and the environment. The key areas of concern for the medium term are the sufficiency of resources, both money and staff complement, and the maintenance of a suitable cadre of suitably competent staff (RN, MOD civilians and industry partners)."

Explosive safety
"The condition of the explosives estate remains a primary concern for the Board, with the potential for significant vulnerability. The consequences of an explosive incident could have a significant impact on capability, and the potential off-site (public domain) consequences could have serious implications for the Department. Risk against compliance with MOD Regulations is increasing and, if agreed, a higher level of risk (including aggregated risks) may have to be accepted on resource grounds."

Defence plan 2010-14
It is interesting to note that the section 7 of the Defence Plan 2010-14 makes no specific mention of the serious safety issues raised in the DESB 2009 report in relation to either nuclear or explosive safety. It would seem that these issues appear to have been filtered out.

Sunday Herald report “Revealed: the catalogue of chronic safety blunders at Scotland’s nuclear navy bases

2010-05-16T11:38:00.000-07:00

Sunday Herald report “Revealed: the catalogue of chronic safety blunders at Scotland’s nuclear navy bases”

“The Ministry of Defence is struggling to deal with hundreds of safety blunders, pollution leaks and environmental lapses at nuclear weapons bases on the Firth of Clyde. Official reports obtained by the Sunday Herald reveal that Faslane and Coulport have been plagued by nuclear accidents, radioactive contamination and fires over the last two years. Worryingly, there have been unspecified “shortfalls” in the safe management of nuclear bombs. And rules meant to protect people against asbestos and even Legionnaires’ disease have been frequently broken. The Government’s safety watchdogs have also warned that unless millions of pounds are invested in replacing the ageing radioactive waste plant at Faslane, it will no longer be safe in four years’ time. That will add to the multi-billion pound bill for keeping nuclear weapons in Scotland, critics say.”

Full story at
http://tinyurl.com/2wnw3ue and http://tinyurl.com/2w2q5pc

If accurate this article raises a number of questions. Firstly, shortfalls in radioactive waste management were highlighted as long ago as 2001 by RWMAC in their independent review of MOD radioactive waste management practices; it seems that very little has been done to implement their recommendations. It also seems that another independent review of MOD radioactive waste management practices is long overdue.

http://tinyurl.com/33f2bdp

The sorts of safety and environment failings highlighted in the article may indicate weaknesses in the safety culture on sites associated with the naval nuclear programme. It is interesting to compare these with those highlighted in the reports into the explosion and fire at Texas City Oil refinery USA and to what extent cultural and organisational similarities exist between BP and the MOD.

http://tinyurl.com/pe2qan

http://www.hse.gov.uk/leadership/bakerreport.pdf

It is also worth considering to what extent improvements in safety and environmental performance might be delivered if the Naval Nuclear programme and facilities were subject to civil regulation under the NIA and RSA rather than the current system of internal regulation. There may be significant cost savings for tax payer and MOD since there would no longer be a need to fund the system of internal Regulation; the urgent need to find savings within Government budgets would seem to encourage this.

The case for civil regulation was put by RWMAC in their 2001 report, recommending that:-
“Irrespective of MoD's assurance and, where necessary, its own regulatory arrangements, RWMAC believes that, as an overriding general principle, the benefits of civil regulation in helping to maintain operational standards, and in promoting assurance and transparency, are not in doubt. Thus, there should be a presumption that civil regulation should, as far as is reasonably practicable, be applied to MoD nuclear and radioactive waste management activities. Where there is a case for not doing so, this should be clearly set down and justified”

And further recommend that:-

“Subject only to real security considerations, the principles of openness and transparency should be taken as far as is reasonably practicable to help promote public confidence in the safety of MoD's nuclear and radioactive waste management operations”.

MoD's internal regulator condemned military's plans as 'flawed, inaccurate and outdated'

2010-04-02T08:24:00.000-07:00

This Guardian article “MoD's internal regulator condemned military's plans as 'flawed, inaccurate and outdated' with interest.

http://www.guardian.co.uk/uk/2010/mar/31/nuclear-subs-dnsr

I make the following observations. The situation reported in the Guardian may reflect on a lack of resources and in particular the impact successive budget cuts and the difficulty in retaining suitable qualified professional staff. As long ago as 2003 The MOD recognised this problem in the “DEFENCE ENVIRONMENT AND SAFETY REPORT 2003-2004”

http://tinyurl.com/yjuhyhz

“Risk 5. NUCLEAR SKILLS SHORTAGE: Effect: Insufficient qualified and experienced personnel to support the Defence Nuclear Programmes. Likelihood: Medium, Impact: Inability to sustain aspects of the Defence nuclear outputs. Risk Category: Personnel, Reputation, Operational”

It seems the short-comings highlighted in the DNSR Review might in part be due to these shortages of staff and resources identified in the DESB report. The shortages of skilled professional staff are likely to increase as the civil nuclear programme begins to accelerate drawing skilled staff away from the Defence sector

The recent budgetary situation in MOD has received coverage in the press and there will be significant cuts in the near future which may serve to cause even greater difficulties in funding and staffing.

It seems sensible therefore for MOD to move to a system of civil regulation which would engender far greater public confidence in the safety of its naval nuclear operations. MOD has recognised this; in the licensing of the Atomic weapon Establishments under the Nuclear Installations Act and as a matter of policy in the “ANNUAL REPORT TO THE DEFENCE ENVIRONMENT AND SAFETY BOARD 2000/01”

http://tinyurl.com/yfr44jy

“MOD accepts that, where it is practicable, demonstrating openness and transparency and building confidence will best be achieved by compliance with the civil regulatory regime and the Department has agreed to consider further moves in that direction.”

It is interesting to note that the “ANNUAL REPORT ON SAFETY, HEALTH AND ENVIRONMENTAL PROTECTION IN MOD 2004/5” was much shorter than previous reports and failed to include any reference to nuclear safety; and so far as I can determine from the MOD website that no further annual report to the DESB has been published.

http://tinyurl.com/yzxsye9

Perhaps the time has come to consider the affordability of MOD nuclear programmes and whether they can be resourced to conform to civil safety standards.

Decommissioned Nuclear Submarines little progress

2010-02-25T03:02:00.000-08:00

Willie Rennie (Dunfermline & Fife West, Liberal Democrat To ask the Secretary of State for Defence

(1)what assessment his Department has made of the merits of using the site at Sellafield for the (a) submarine dismantling and (b) radioactive waste storage elements of the submarine dismantling project;

(2) what sites his Department is considering to use for the (a) submarine dismantling and (b) radioactive waste storage elements of the submarine dismantling project

Hansard source (Citation: HC Deb, 24 February 2010, c597W)

Quentin Davies (Parliamentary Under-Secretary, Ministry of Defence; Grantham & Stamford, Labour)

There are currently four regions where there are MOD or defence-related commercial sites that are likely to be considered for submarine dismantling project activities. These regions are Devon, Fife, Argyll and Bute and Berkshire. A number of briefings to elected representatives in these regions have already been carried out, including to the hon. Member, and others have been scheduled.
The project is at an early stage in the process to develop an effective public consultation and associated strategic environmental assessment. This work has included identification of existing nuclear sites, both defence and civil, that are technically capable of submarine dismantling or storing the resultant radioactive waste. At this stage, two sites have been identified that could be technically capable of carrying out dismantling activities and 12 sites have been identified that could be technically capable of carrying out waste storage. Technical capability is only one aspect and the wider suitability of sites has not yet been assessed.

Further analysis work is still required and, until the public consultation is complete, no decisions will be taken on sites for either submarine dismantling or waste storage. I am withholding details of the individual sites identified at this time, as the MOD intend to publish this information in the future as part of the planned public consultation and strategic environmental assessment.

Navy dock in danger of becoming a 'nuclear dumping ground'

2010-02-22T08:47:00.000-08:00

Guardian reports
“Navy dock in danger of becoming a 'nuclear dumping ground' Military chiefs are running out of space to store the UK's growing number of obsolete nuclear submarines, prompting fears that one of the country's busiest naval ports is set to be turned into a nuclear scrapyard."

The Isolus website states that a fourth round of consultation is due to start in 2010 and will last for at least 12 weeks.

The delays in addressing the decommissioned nuclear submarines mirror the situation on MODs general strategy for the management of nuclear waste, which it has failed to publish.

The requirement for the strategy is detailed in the in the policy published in October 2007 “Ministry of Defence Policy for Decommissioning and the Disposal of Radioactive Waste and Residual Material arising from the Nuclear Programme”

IAEA & Euratom apply to defence related radioactive materials and wastes managed by the NDA

2010-02-03T09:00:00.000-08:00

The NDA has confirmed that the IAEA safeguards regime for radioactive materials/substances and radioactive waste and also, the provisions of the Euratom Treaty and subsidiary legislation does apply to radioactive wastes and substances/materials originating from UK defence activities managed, stored or disposed by the NDA or its contractors. I must admit I was somewhat surprised at the response.

Transcript of my email to the NDA and their response

FoI Request to the NDA dated January 8 2009

Dear JH
Thank you for your reply but correct me if I am wrong, but I do not recall you replying yes or no to this question bearing in mind the reference I made UK defence activities

"So am I correct that your reply means that the IAEA safeguards regime for radioactive materials/substances and radioactive waste and also, the provisions of the Euratom Treaty and subsidiary legislation will apply to radioactive wastes and substances/materials originating from UK defence activities managed, stored or disposed by the NDA or its contractors."

Fred Dawson

Reply from NDA dated February 9 2009

Dear Mr Dawson

Sorry for the delay in responding. The answer is yes.

Regards

JH Information Access Manager

NDA, Herdus House, Westlakes Science and Technology Park, Moor Row, Cumbria, CA24 3HU
T: 01925 80 2077
W: http://www.nda.gov.uk

MoD guilty of repeated nuclear safety breaches

2009-04-27T05:05:00.000-07:00

Guardian reports:
Britain's nuclear submarine fleet has been hit by a series of serious safety breaches involving repeated leaks of radioactive waste, broken pipes and waste tanks at its home base on the Clyde, the Ministry of Defence has disclosed.

One-third of deaths in Britain’s military caused by accidents

2009-02-23T00:28:00.000-08:00

The Independent newspaper reports one-third of deaths in Britain’s military caused by accidents. The evidence is of a lasting legacy of damaged lives. It would be interesting to know if the these offical statistics were produced in accodrance with the Statistics Authority Code of Practice for Official Statistics and quality mark.