MoD's internal regulator condemned military's plans as 'flawed, inaccurate and outdated'

This Guardian article “MoD's internal regulator condemned military's plans as 'flawed, inaccurate and outdated' with interest.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

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'

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

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