Sunday, 26 December 2010

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

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

Link to MOD Decommissioning and disposal policy paper

Saturday, 21 August 2010

MoD bomb disposal harming Gibraltar marine life

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."

Wednesday, 23 June 2010

Radioactive waste management strategies Civil & Defence

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”.

Tuesday, 25 May 2010

MOD publishes report on 2009 safety concerns

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, 16 May 2010

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

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 and

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.

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.

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”.

Friday, 2 April 2010

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.

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”

“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”

“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.

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.

Thursday, 25 February 2010

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.

Monday, 22 February 2010

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”

Wednesday, 3 February 2010

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.


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