Astute " teething troubles"

The Guardian recently revealed problems with the  Astute nuclear submarine, which is coming to the end of three years of sea trials.

In the subsequent article in the Guardian Rear Admiral Lister is quoted as saying

"it would be wrong for the military to claim the difficulties were just "stuff and nonsense and teething troubles",but he also  said it would also be wrong for critics to write off what is the navy's most technically advanced boat."

I think the truth lies between these two positions

Rear Admiral Lister is also quoted as saying that  "he had identified three sorts of problems with the Astute:

• flaws in design that only became apparent when testing started;
• equipment that broke down too easily;
• and some problems relating to poor construction at the shipyard.""

What the Guardian article does not explain are the root causes that lead to these problems. It would be most interesting to know to what extent continuous organisational change together with  budget cuts within the MOD played a part; on this both the Guardian and the MOD are silent.

Non SQEP staff in SQEP Posts

On the 23rd of October MOD was requested to provide information about suitably qualified and experienced (SQEP)  personnel  who provide key support to safe delivery  MOD nuclear Programmes. 


The number of non-MOD personnel filling SQEP posts within MOD nuclear programmes, by year for the past 5 calendar years

The number of non-MOD personnel filling SQEP posts within MOD Nuclear programmes who are non-SQEP, by year for the past 5 calendar years

The number of MOD personnel filling SQEP posts within MOD Nuclear programmes who are non-SQEP, by year for the past 5 calendar years 

Number of SQEP posts within MOD Nuclear programmes where concessions have been granted to allow non-SQEP personnel to occupy the post, by year for the past 5 calendar years

Two months after the request  the  MOD is unable to provide the information requested and has yet again provided a holding reply saying they may respond by 21 of January. The law requires the MOD to provide the information requested or an explanation as to why it cannot be provided within 20 working days of the request.

It's surprising that MOD cannot provide the information about SQEP  posts as the lack of SQEP personnel are a key risk to the safety of nuclear programmes, highlighted for years by the Defence Nuclear Safety Regulator in their annual reports.

It also appears that the MOD  do not know how many concessions have been granted to allow non SQEP  personnel to occupy SQEP posts.   It is clear from a letter written by John Day the MOD's  2nd PUS to the union Prospect, that contractors have been used to fill some SQEP posts  and in at least one instance a contractor has been  removed from a SQEP post because they were not qualified and/or competent  to occupy the post.  It's of interest that the MOD was asked for the letter on  28th of August 2012 but only provided  the letter 5th of December 2012 yet again well in excess of the 20 working days required by the FOI Act.

" the first person supplied by the contractor was sub-standard"

"The root cause of this initial under performance was, at least in part due to an inadequate statement of requirement being provided by the MOD initially and the Submarine OC accepts the need to improve how it specifies and manages the performance of contractors"

This letter demonstrates that MOD has insufficient experienced staff to act as an intelligent customer for contractor services  used to safely deliver its nuclear programmes
.
This may in part explain the reluctance of the MOD to provide information about  the number of unqualified staff occupying SQEP posts with defence nuclear programmes.

In view of the recent articles in the Guardian News paper its interesting to consider to what extent has the inability of MOD to find properly qualified and experienced  people  contributed to the problems with the Astute nuclear submarine reported  by the Guardian. It is also interesting to consider what action the Health and Safety Executive might take under the Health and Safety at Work Act against the MOD for failing to provide a safe system of work.

It is now clear that the MOD does not know how many unqualified  people occupy SQEP posts which are key to the safe the safe delivery of MOD's nuclear programmes.

References

Earlier post - SQEP

DNESB Reports

Submarine safety letters in the Guardian Newspaper

On 16 November in response to the recent reports in the Guardian newspaper  Rear Admiral SR Lister wrote a letter to the Guardian


"Astute sea trials will rectify problems

As the Royal Navy officer responsible for the delivery of the Astute submarine programme, I must respond to your claims about the performance and potential safety of HMS Astute (Report, 16 November). All those involved in the delivery of our submarines have a duty to the submariners that serve on them to ensure that we provide a safe environment in which to live and work. As a submariner myself, I am acutely aware of the need to meet the exacting safety standards we demand and we are committed to meeting them both for HMS Astute and for the remaining submarines in the class.

I would never allow an unsafe platform to proceed to sea and the purpose of the extensive sea trials HMS Astute is undertaking is to test the submarine in a progressive manner, proving that the design is safe, that it has been manufactured correctly and that she is able to operate safely and effectively. This process reflects the nature of HMS Astute as both a prototype and an operational vessel. We have always known that it would be necessary to identify and rectify problems during sea trials and this is what we have done. All the issues noted in the story have either already been addressed or are being addressed. In particular, while we do not comment on nuclear propulsion issues, or the speed of our submarines, I can assure you that, once HMS Astute deploys operationally, we do not expect there to be any constraints on her ability to carry out her full combat role for the Royal Navy.

I invite the Guardian to spend time on HMS Astute with me to see at first hand the professionalism of the crew, the confidence they have in their boat and the rigour with which sea trials are carried out and problems addressed.

Rear admiral SR Lister
Director submarines, Ministry of Defence"

I was concerned that whilst the letter suggested that the problems reported were those normally expected to be encountered in a newly commissioned class of boat. I thought it was worth highlighting the shortcomings  in the resources and expertise needed to ensure the delivery of  the nuclear safety of the UK nuclear submarine fleet and the need for the independent regulation of nuclear safety. 

Letter of reply to Rear admiral SR Lister published in the Guardian 19 November

" Submarine safety

I read with interest the letter from Rear Admiral SR Lister, director submarines, Ministry of Defence, on the problems with the Astute submarine reported in this paper (17 November). As a former head of radiation protection policy at the MoD, I must say that public confidence would be greatly enhanced if the regulation of nuclear safety for the submarine fleet was transferred from the MoD's internal nuclear safety regulator to the Office for Nuclear Regulation, part of the Health and Safety Executive. It is also worth pointing out that the 2010-11 annual report of the Defence Nuclear and Environment Safety Board clearly shows how the MoD has failed to allocate sufficient resources to nuclear safety, in particular the lack of progress on recruiting and retaining experienced and qualified staff. The report clearly shows that ministers continue to ignore the MoD's internal nuclear regulator in the allocation of resources to support the safety of the naval nuclear propulsion programme.

Fred Dawson  Director, Milcon Research"


Reference

MOD  DNESB annual reports

Loss of specialist capabilities needed to support the nuclear propulsion programme

Guardian reports  - HMS Astute: quality control the key to restoring hunter-killer sub's reputation.  Union fears MoD has lost too many specialists amid acute sensitivity over £10bn programme

"This is what has alarmed union leaders, such as Prospect's Steve Jary, who fears the MoD has lost so many civilian specialists that it no longer has the ability to keep a proper eye on QA issues"

"The MoD is no longer able to supervise the construction of submarines effectively."

Regularly readers of this blog will recall a recent post about the loss of specialist capabilities needed to support the nuclear propulsion programme. The MOD was asked through a FOI request to provide information about loss of specialist capabilities needed to support the nuclear propulsion programme and to explore what the Union Prospect was doing to resolve the issue.

So far the MOD have failed to provide the information requested
Update on FOI request 23 November

What is becoming clear is the MOD may now reliant on contractors and granting  concessions so that less skilled and experienced personnel can be placed in SQEP posts within the MOD's nuclear progarmmes.  It is likely that this situation contributed at least in part to the problems reported in the Guardian Newspaper.

The 2010-11 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 and retaining suitably experienced and qualified staff.

The 2010-11 DNESB  report clearly  shows that MOD Ministers continue to ignore MODs internal nuclear Regulator and demonstrates the need for full civil regulation by the Office for Nuclear Regulation

Other posts on this blog about  previous DNESB reports have highlighted lack of staff and resources as a significant risk to the safety of MOD's nuclear programmes. If the Guardian newspaper reports are correct the consequences of this are now all too  clear .

There's something wrong with our submarines

The Guardian newspaper reports serious concerns about the safety of the newly commissioned Astute class nuclear submarines. Including

• Flooding during a routine dive that led to Astute performing an emergency surfacing.
• Corrosion even though the boat is essentially new.
• Concern over the instruments monitoring the nuclear reactor because the wrong type of lead was used.

As Earl Beatty said at the Battle of Jutland in the First World War  "There seems to be something wrong with our bloody ships today!"

Links to the Guardian Reports

• Slow, leaky, rusty: Britain's £10bn submarine beset by design flaws,  Royal Navy's HMS Astute 'has a V8 engine with a Morris Minor gearbox'
• Britain's nuclear hunter-killer submarines were doomed from the start, The flawed thinking and design behind the fleet at the heart of Britain's navy is now coming to the fore.

If these reports are in any way correct, its seems the MOD's internal Nuclear Safety Regulator has been asleep at the wheel, making an overwhelming  case for external regulation by the Office of Nuclear Regulation.  It would not be surprising if budget cuts and cost savings also  played a significant part in this very sorry situation. The question is, to what extent these defects put the submarine, its crew and the public at risk.

It interesting to see that the problems reported by the Guardian do not seem to feature in the annual report of the Defence Nuclear Safety Regulator for 2011

Video of DU firings at Eskmeals

In response to a FOI request the Ministry of Defense has released a video of the DU firings carried out at Eskmeals on the Cumbria coast.

The video shows how during the early years of the firing programme significant quantities of  DU were released to atmosphere and how in the later years of the firing programme efforts were made to reduce the discharge of DU to atmosphere



Related Posts

• DU firings at Eskmeals "As Low As Reasonably Practical"? 
• Unregulated discharge of Depleted Uranium to the Environment
• Depleted Uranium measurements Eskmeals West Cumbria

Dalgety Bay the MOD is unable to locate records about the sale of radioactively contaminated land and the local Community Council appeals to the public for their help.

"Dalgety Bay & Hillend Community Council

See the item of 3 October for details of what has prompted this reply
The Chairman writes: A reply from Moray Estates indicates that "They being professionally advised, could equally assume that had clear and accurate information been passed over relating to the exact nature and content of the salvage area in question then, it would be unlikely the Estate would have completed the purchase".

On this reply PLEASE NOTE THAT IF ANYBODY IN THE LOCAL AREA HAS KNOWLEDGE OF ANY OPERATIONS PARTICULARY IN RESPECT OF DONIBRISTLE AIRFIELD ON INCINERATION, DUMPING OF MATERIAL OR OTHER WORKS IN RELATION TO THE FORESHORE IN DALGETY BAY DURING THE 1950'S AND 1960'S, PLEASE CONTACT THE CHAIRMAN cmcphail.oceanwheels@btinternet.com or tel  01383 823750. 

YOU MAY HAVE IMPORTANT INFORMATION WE CAN SEND TO THE MOD AND SEPA."

Letter from MOD to Colin McPhail MBE leader of Hillend Community Council

Dear Mr McPhail,

DALGETY BAY FORESHORE RADIATION

Thank you for your letter of the 6 August 2012. I can confirm that a copy was forwarded to the Rt Hon Andrew Robathan, whilst he was still the Minister for Defence Pensions, Welfare and Veterans, as you requested. Please accept my apologies for the delay in confirming this and for replying to your letter.

As you will be aware we are now in the process of finalising arrangements to commence Stage 2 of the Investigation Plan and hope to have everything agreed ready to start in October. This will include engaging with residents, and I would like to thank you for your offer of assistance. I understand that my officials have already been in touch in this regard.

With regard to the sale of the former RNAS Donibristle, it is unfortunate that  we have not been able to establish the exact details of the documentation which was provided as part of the sale. We cannot therefore, comment on whether or not the information in question was passed across. What is certain is that we would have complied with the practice and legal requirements of the day. Given the fact that the salvage section was still present at the time of sale, combined with the breadth of the proposal put forward by the Moray Estates Development Company in respect of the site, it would seem fair to assume that they had a detailed knowledge of the site before committing to its purchase.

Returning to the Investigation Plan, we remain committed to delivering the investigation in order to assist SEPA to determine the nature and extent of the problem and what needs to be done to ensure the protection of the local community.

Again, please accept my apologies for the delay in responding.

Yours sincerely,

Mark Hutchinson
Chief Operating Officer
Defence Infrastructure Organisation
DESK 9, LEVEL 5 ZONE A, MOD MAIN BUILDING , WHITEHALL, LONDON, SW1A 2HB
MOD telephone: 9621 78294
Telephone:   0207 807 8294    0207 807 8294?
Fax:   0207 218 2470    0207 218 2470
Email: DIO-COSOpspport@mod.uk
Website


The letter makes it clear that the MOD assumed that it would seem fair to assume that the Moray Estates Development Company had a detailed knowledge of the site before committing to its purchase. This is clearly an attempt to shift liability away from the MOD onto the Moray Estates Development Company.   The MOD has not given in the letter any evidence to back up this assumption. It also calls into question how many other situations there are, where the MOD has sold land  making the same assumption.



DALGETY BAY FORESHORE RADIATION  e-petition

WHAT CAN YOU DO?

You can sign our official UK Goverment e-petition, and you can join our email campaign. Please do both! Urge everyone you meet to do the same

"I respectfully ask the Ministry of Defence and Scottish Environment Protection Agency to state that remedial work on the contaminated foreshore area in Dalgety Bay will begin immediately after the investigation plan is satisfactorily completed and that those deemed responsible for the contamination will fund the work and have it completed by the end of 2013"

DU Firing programme at Eskmeals - As Low As reasonably Practical ?

Reference 1

Looking back to the UK depleted uranium firing programme and in particular the firings carried out Eskmeals on the west Cumbrian coast. It is interesting to consider to what extent these firing complied with the duty to restrict exposures to as low as level as reasonably practical (ALARP).  

The  IRR99 and the IRR85 requires employers to keep exposure to ionising radiation as low as reasonably practicable. 

VJ Battery at Eskemals in the early years was essentially a traditional open butt with the addition of a roof and extract ventilation from each side of the butt. this allowed the spray back of aerosolised DU and fragements through the open air onto a apron in front of the butt.

To quote from the reports :-

 Safety Services Organisation MOD(PE) November 1983, The distribution of Depleted Uranium releases at P&&EE Eskmeals, excluding appendices.

Report summarising the measurements taken at VJ Butt P&EE Eskmeals of Depleted Uranium in air during the period 1981 to 1982.

"The penetrator on impacting with the target produced pyrophoric fragments which rapidly disintegrate and. there is a spray back-up the range over an angle of 20 degrees  for a distance of 60 metres."

"Total activity in air measurements taken outside the butt indicate that DU is being released to the environment at levels above the DAC for a period of time after firing. It is not possible to quantify the amounts.".   DAC "Derived Air Concentration" ICRP 30

"The DU dust was found to be well within the respirable size range, dust particles of this size have very long settling times and can remain airborne  for very long periods of time and if allowed to disperse from the butt may travel many hundreds of meters."

This is the  Department of Defense Superbox DU firing facility at Aberdeen Proving Ground Maryland USA. As can be seen the facility offers almost complete containment. It includes a flight tunnel with a drop down door.  The Superbox facility is seen as an example of a facility that reduces exposures to the public and workers outside the facility to a level that is  ALARP

The conclusion is that  that in the early years of the firing programme the MOD failed to meet its legal duty to restrict exposures to as low as level as reasonably practical. It is also interesting to consider that that the VJ Battery at Eskmeals was probably very quick and cheap to build compared to the Superbox facility in the USA. 

It is now also clear that the MOD failed to seek letters of agreement from the Environment Agency for the discharge of DU to atmosphere from VJ Battery at Eskmeals. This was in breach of the MODs' own policies.

Later years of the firing programme at Eskmeals

DRPS Report "Comparison of Kirkcudbright and Eskmeals Environmental Monitoring Data with Generalised Derived Limits for Uranium" June 2002 mentions that a tunnel was added to the face of VJ Butt in order to reduce discharges of DU to the environment. This acknowledged that the original firings at VJ did not comply with the requirement to restrict exposures to as low as level as reasonably practical.

References

1: HSE Reducing risks protecting people 2001

Radiation Protection Technical Advisory Committee (RAPTAC)

In response to a FOI request the MOD has released some of the minutes of the Radiation Protection Technical Advisory Committee (RAPTAC). 

This is the main Committee concerned with ionising radiation protection. The papers provide an insight in the issues of concern to MOD Officials in the late 1970s and early 1980s. 

 It is notable that the MOD have only provided 3 sets of minutes not the 10 requested.. 

 Issues of note include : 

• Nuclear test veterans 
• Retention and recruitment of Health Physicists 
•  Radiation dose limits 
• Application of the proposed Ionising Radiation Regulations to the MOD 

 Minutes 

1983 2nd meeting 
1980 1st meeting 
1979 2nd meeting 
Covering letterFOI and response 

FOI and response

Thank you for your email of 14 September 2012 requesting the following information: Could you please provide me with the following information:- 

1: Terms of reference of the Radiation Protection Advisory Committee (RAPTAC) referred to in the 12th report of the House of Commons Defence Committee Radiological Protection of Service and Civilian Personnel 
 2: date of the first meeting of RAPTAC 
 3: Agendas of the first 10 meetings 
 4: Minutes of the first 10 meetings 

We are treating your correspondence as a request for information under the Freedom of Information Act 2000. We have now completed an extensive search of archives for the information you requested and we have located the following documents.

RAPTAC 2nd Meeting 1979 – Minutes 
RAPTAC 1st Meeting 1980 – Minutes 
RAPTAC 2nd Meeting 1983 – Agenda
RAPTAC 2nd Meeting 1983 – Minutes 
RAPTAC 1st Meeting 1984 – Agenda 
RAPTAC 2nd Meeting 1984 - Agenda 

We have provided all the information that we could locate for you. These documents have been assessed under the Freedom of Information Act 2000 and personal information has been redacted under the Absolute Exemption Section 40.

Unregulated discharge of Depleted Uranium to the environment

Thank you for your enquiry dated 21 September 2012. This has been dealt with under the Freedom of Information (FOI) Act 2000.

You asked for: 

 "letters of agreement from the Environment Agency and its predecessor organisations for  the MOD to discharge of depleted uranium to the environment from Eskmeals and  letters of agreement from the Scottish Environment Protection Agency and its predecessor organisations for the MOD to discharge of depleted uranium to the environment from  Kirkcudbright." 

"I am writing to advise you that the information you requested is not held.  There is no licensing as such of the Ministry of Defence's depleted uranium firing activities. The  procedure adopted at the outset of the depleted uranium trials programme, which is still in force, is  for regulatory authorities with Health and Safety and Environmental Protection responsibilities to  be involved in the design of the safety arrangements and to visit the sites as and when they wish."

In the case of Kirkcudbright some 6,907 shells have been fired into the Solway Hansard and  there appears to be no accurate figures for the amount of DU dispersed to the environment at Eskmeals. 

JSP 392 Vol 2,  Leaflet 30  "DEPLETED URANIUM" states that there are so far as the Radioactive Substances Act 1993 (RSA93)  is concerned there are parallel arrangements, this being the case there should be letters of agreement from the environmental regulators for the discharge of depleted uranium to the environment.  The response to the FOI request shows that none were obtained  and the discharges were unregulated. 

It may be that the MOD felt that it would be pointless to seek letters of agreement form the environmental Regulators as they were unlikely to agree to the discharges and so far as the MOD were concerned it was fortunate that the RSA93 does not apply to the MOD. 

The response to this FOI request clearly shows the MOD failed to meet its own policy to seek letters of agreement from the environmental  Regulators  when discharging substantial quantities of radioactive substances into the environment.  

Extract from JSP 392 Vol 2,  Leaflet 30  "DEPLETED URANIUM" 


"3 In addition to the general requirements of the Health and Safety at Work etc Act 1974 and the 
Management of Health and Safety at Work Regulations 1999, the following specific legislation applies 
directly or is applied indirectly through parallel arrangements designed to achieve equivalent standards: 
• Ionising Radiations Regulations 1999 (IRR99) (apply directly). 
• Radioactive Substances Act 1993 (RSA93) (parallel arrangements)"



References

MOU between the MOD and Environment Agency

Loss of specialist capabilities needed to support the nuclear propulsion programme

The MOD was asked through a FOI request to provide information about loss of specialist capabilities needed to support the nuclear propulsion programme and to explore what the Union Prospect was doing to resolve the issue.


FOI Request 28 August 2012

"Request for Information under the Freedom of Information (FOI) Act 2000 

Thank you for your email of 28 August 2012 requesting the following information: 

Letters and emails between MOD Officials and the Union Prospect concerning the loss of specialist capabilities needed to support the nuclear propulsion programme and the Frame work Agreement Technical Services for the period January 2012 to June 2012. 

I am writing to advise you that we are still working to identify the information that falls within the scope of your request.  I estimate that it will take a further 20 working days to identify this information, so I will write to you again no later than 23 October 2012.  Please accept my apologies for the delay, and for not providing a response within the 20 working days set out in the FOI Act."  

• The delay in providing the information requested again points out the failure of the MOD to meet its legal duty to provide the information requested within 20 working days.
• It may also indicate that the MOD's  document and record keeping systems, even for recent correspondence are seriously flawed.
• It may be the case that the MOD does not want to release the information and wishes to hide the information for fear that it will inevitably show that the MOD is still failing to provide the required level of specialist resource to safely deliver its nuclear programmes.
• The MOD may now have become reliant on contractors and granting  concessions so that less skilled and experienced personnel can be placed in SQEP posts within the MOD's nuclear progarmmes.  

MOD Radiation Protection and Radioactive Waste Committee Papers

In response to a FOI request the MOD have released  the minutes of a number of committees concerned with radiation protection and the management of radioactive waste.

Link to FOI requesting :-

"a; the minutes,
b: agendas
c: Terms of reference

for

a: the Radiation Protection Policy Committee (RPPC)
b: the Radioactive Waste Working Group (RWWG)
c: the Radioactive Waste Information Group (RAWIG),

for the period 1990 to 2000"

The MOD provided the following information

Radioactive Waste Working Group RWWG

Terms of Reference

Minutes

7  January 1999
20 May 1999
9 September 1999
13 January 2000
7 June 20000
19 September 2000

Radiation Protection Policy Committee RPPC

Terms of Reference

a:                    b:

Minutes

17 October 1996
28 January 1998
9 June 1998

Radioactive Waste Information Group RAWIG

Terms of Reference -  not provided

Minutes

13 January 1999
18 May 2000
8 November 2000

Its notable that apart from the agendas these are the only documents provided,  the MOD said that

 " Despite an extensive search of the archives we have been unable to locate a complete set of minutes, agendas and terms of reference for the committees detailed in your request. Some of the files which may have contained the minutes, agendas and terms of reference for the committees have been destroyed."   

 It seems very surprising that the minutes of MOD central committees dealing with issues as significant as radiation safety and the management of radioactive waste and radioactively contaminated land  have been lost or destroyed. 

These remaining documents  provide a snap-shot  of the radiation protection and radioactive waste issues faced by the MOD and show how the MOD was responding. The documents  also provide a good indication of the value of the papers that have been lost.

The more cynical  may be suspect, within the MOD there is a deliberate policy of destroying  files to avoid  answering difficult questions about past activities and dodging liability.  Such a policy appears to have resulted  in  a "corporate lobotomy"  so far as knowledge of  historic activities are concerned. It also results in an inability to learn from history that would help inform decisions concerning current activities and issues.

A previous post  also drew attention the loss of files and records

Failure to ensure the preservation of the minutes of the  central MOD Committee concerned with Radioactive Waste Management for the  period 1975 to 1985.

DE&S Contractorisation a disaster in the making

DE&S provides the intelligent customer function for Defence procurement  including expertise in examining  and drawing up contracts to ensure that they offer value for money whilst delivering the required defence capability.  The proposal to contractorise DE&S  will remove this intelligent customer function and risks causing a similar but far larger problem than occurred in the education sector where budgets were devolved  to schools which lacked the necessary expertise  in understanding, drawing up and managing contracts.

The result for schools is a laptop that has a price of between £350 and £400 the school was charged £3,750. Another example is a school that had to pay nearly £500,000 to settle a lease on behalf of one school for photocopiers worth just £45,000.   It is interesting to consider what the situation will be for the taxpayer with much larger contracts in the defence sector. 

It is suspected that because of contractorisation safety and environmental aspects of procurement will either be exploited by companies to increase the cost to taxpayer of defence systems or given a  low priority.

Transparency and openness  of defence procurement will be significantly reduced as the Freedom of Information Act does not apply to commercial undertakings as will accountability to Parliament.

A look back at radiation protection in the MOD's nuclear programmes

In 1990  the 12th  report of the  House of Commons Defence Committee was published. Looking at the report today provides a very interesting view of radiation protection and doses to both civilians and service personnel  working in the Defence Nuclear programmes in the late 1980s.

Link to the report.  

The report provides an insight into how the MOD was responding to the Gardner report and also touches on the need to counsel radiation workers about their exposures to radiation.  The report also discusses the no fault compensation scheme .

COMARE advice on the Gardner report

The report  mentions  the Graduate Entry Training scheme for Health Physicists  (GETS). The GET scheme  became a victim of the fragmentation of the defence nuclear sector, especially when AWE  no longer participated.  It was from this point on that the active career management  of MOD Health Physicists took a steep downhill turn. This also reflects the demise of the scientific civil service with the move away from engineering and science grades to a broad banded  grade structure,  which  includes a science and engineering skills framework.


Recruiting and retaining specialist staff

when asked "have there been difficulties in recruiting and retaining specialist staff" Surgeon Captain Harrison replied "I think there always has been, but the Ministry has responded to this by starting up a graduate entry training scheme for health physicists which has been running now some four to five years and this is brining really good first class graduates  into the service".

Over 20 years after the publication of the 12th  report of the  House of Commons Defence Committee ; the retention of specialist staff including health physicists remains  to this day a significant issue and risk to the safety of MOD's  nuclear programme, with little indication of progress in finding a solution.

Links

Counselling Scheme

MOD page on compensation scheme

Radiation Compensation Scheme

Depleted Uranium Measurements Eskmeals West Cumbria

In response to an FOI request MOD has  released two  reports on levels of Depleted Uranium ( DU) generated at the point of impact of 120mm DU kinetic energy rounds against hard targets at the Eskmeals R&D facility in West Cumbria. These reports detail measurements used to determine the time at which workers with PPE could enter the target area.

While most of the interest in DU has focused on service personnel who were exposed to DU in combat,  workers at Eskmeals were exposed day in day out for years whilst DU  firings were carried out at Eskmeals.

Report summarising the measurements taken at VJ Butt P&EE Eskmeals of Depleted Uranium in air during the period 1981 to 1982.

Safety Services Organisation MOD(PE) November 1983, The distribution of Depleted Uranium releases at P&&EE Eskmeals, excluding appendices.

Qinetiq Eskmeals

MOD in breach of undertaking to the Information Commissioner.

It is becoming clear that the MOD is in breach of duties under the Freedom of Information Act and the Undertaking given to the Information Commissioner in June 2011.

In the undertaking signed by the MOD's  Permanent Under Secretary undertook to

"take steps to ensure the appropriate resource is allocated to request handling and this resource regularly reviewed for effectiveness"

In the undertaking the Information Commissioner said

"having regard to the available evidence, considers that the Ministry of Defence needs to take steps to ensure that requests for information are dealt with appropriately. In particular he considers that the public interest statement of intent, facilitated by this Undertaking, will provide assurance that the authority has embraced the culture of openness and transparency the legislation seeks to promote"


Examples of failure of the MOD to comply with the FOI Act and the Undertaking

28 August 2012

We advised that we hoped to have a response to you by 29th August 2012. 

Unfortunately it will not be possible to make this date due to a combination of unavailability 

of subject matter expertise through leave and sickness. We hope to have a final response 

to you by 21st September 2012.

12 June 2012

“In the case of your request for the DNESB 2011 report (we have interpreted this as a

request for the Defence Nuclear Safety Regulator Annual Report 2011), as there is

information contained within the report which may need to be withheld from the document

for its release under FOIA, a public interest test is required.

Unfortunately the Public Interest Test is taking longer to carry out than anticipated at the

time; this is in part due subject matter expert unavailability. I am therefore unable to

provide you with a substantive response to the second part of your request at this time.

I will write to you again by Wednesday 4 July, by which time I expect to be able provide

you with a final response to your request for information. ”

Planned Privatisation of the Military Equipment Agency

The Guardian recently reported

"Ministry of Defence plans to privatise the multibillion-pound agency that provides the armed forces with military equipment appear ill thought out, could endanger British troops and are potentially undemocratic, according to a report by a leading security thinktank"


Royal United Services Institute have issued a briefing paper " The Defence Materiel Strategy and the GOCO Proposal for Abbey Wood". "We also wonder if ministers are being asked to take a decision whose major implications are poorly understood. Ignorance is no substitute for forethought and objectivity: the government and the country cannot afford a wrong decision in this area. In the meantime, we wonder if those tasked with making this solution work might use the questions above as an aid to a fuller examination. This might help them to avoid the unintended, and potentially huge, negative consequences that always emerge from complex and challenging undertakings, especially where the pros and cons have not been thoroughly examined."


Some points to consider

Governance, accountability and transparency required in a democratic nation’s public business

Its open to question whether or not the FOI/EIR would apply to the GOCO. If it turns out that the FOI/EIR do not apply to the GOCO there will be a very significant reduction in openness and transparency; as stakeholders (citizens, journalists NGOs) will no longer have legal power to obtain information about the safety issues and environmental harm caused by the countries military nuclear programmes.

MOD as an intelligent customer

Since previous contractorisations of the Dockyards and AWE, D&ES have been the MOD intelligent customer for the services of the contractors running these sites.  If DE&S themselves become a contractor it appears there will be no expertise left within the MOD to act as a intelligent customer for its contractors services or to make judgements on contractor performance against contractual obligations.

Civil Regulation 

If DE&S is contractorised the Naval Bases which support the nuclear programme should be subject to civil regulation and licensed under the Nuclear Installations Act by the Office of Nuclear Regulation , DNSRs MOD internal regulators role being limited to submarines at sea. From a safety point of view this is to welcomed 

I  have recently been informed by reliable sources, " that this  won't happen. The Naval Bases are to be transferred back to Naval Command and the NBC's will be the Authorisees, where appropriate. Similarly the Intelligent Customer function will be Naval Command's".

DE&S

This organisational chart gives an indication of the scope of work carried out by DE&S that may well be contractorised. It's also  interesting to note this publicly available chart gives names, post titles, email and phone numbers including Submarines, headed by Director Submarines - RAdm Simon Lister Mil: 9352 37504, Tel: 0117 91 37504 email: DESSM-DirMA@mod.uk

Serious resource issues effecting the nuclear submarine programme

A recent report in the Telegraph highlighted serious resource issues effecting the nuclear submarine programme.  These resourcing issues have been highlighted in the Milcon Blog  for a number of years.

The Telegraph reports the MOD responding to its article by saying that the MOD

" recognises that the Royal Navy has sufficient manpower for its submarines and we are confident that this will remain the case."

This seems to be at odds with what the DNSR, MOD's internal Nuclear Safety Regulatory has highlighted resourcing as a red risk  in the DNSR's  Annual report for  2011 which states

 "These are that inadequacy of resources, both money and staff complement, and the difficulties in maintaining a sustainable cadre of suitably competent staff (Royal Navy, MOD civilians  and in industry partners) are the principal threats to safety in the DNP in the medium term"


This seems to suggest that the response from the MOD Press Office bears little relation the  situation expressed by the MOD's  own internal Regulator.  

Radium contamination confirmed at Pulham

In January I said in this blog that RAF/RNAS Pulham  provides a typical  example of a site potentially  contaminated with Radium.

It is now clear from a press report that Radium contamination from past defence activities is present on the site.

It was inquiries made  by Milcon Research and Consulting made to the Local Council that in part prompted the Council to look into the issue of Radium contamination at RAF/RNAS Pulham.

It was also clear the response MOD made to an FOI request that the MOD held no information that would help identify if Radium was present on the site.

It is also clear that there are many more sites such as Pulham where radioactive contaminates and other contaminates are present and may pose a risk to human health and the environment. But that the MOD has long since lost records that would identify such sites.