Dalgety Bay the Music Video

An interesting example of how issues involving radioaactivity enter popular culture and have the potential to go viral.

It should noted that its radium not plutonium at Dalgety Bay. But I sure that this detail will be lost for most people watching the video. What will remain is a lasting albeit wrong association of Dalgety Bay with Plutonium.

MOD provides no evidence that MOD follows best practice for the management of contaminated land

This FOI was submitted to the MOD following concerns raised about poor record keeping by the MOD relating to contaminated land and the MOD saying that it had in place a “robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment”


“I note from a recent BBC news report into radioactive contamination concerns at RAF Kinloss MOD is quoted as saying "The MoD is committed to assessing land quality across the entire defence estate. This robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment.”

"I note that MOD is a member of “Safegrounds” which has produced best practice guidance for the management of radioactive contaminated land.

Could you please provide me with the audit and compliance reports that demonstrate that the MOD meets this “ industry best practice”

Also you could please provide me with me with the audit and compliance reports that demonstrate that the MOD meets “SAFEGROUNDS Good practice guidance for land quality records management for nuclear-licensed and defence sites””

The MOD replied

“I can confirm that the MOD holds no information that falls within the scope of your request. I am advised that there are no requirements for the MOD to have audit and compliance reports in relation to the management of radioactive contaminated land.”  

“There is no requirement for the MOD to follow the Safegrounds guidance for land quality records management, therefore no audit and compliance reports exist”

Full reply.

The reply clearly shows that the MOD can provide no evidence to support it's statement saying that the MOD meets “best practice” and this by implication means there are no audit or compliance systems to demonstrate that it is meeting its own policy and standards for managing radioactive contaminated land let alone discharge its legal duty of care to protect man and the environment.

It is also interesting to note the MOD in JSP375 Volume 4 the MOD Safety Health and Environment Audit manual lays down the requirement for audits to provide assurance that health safety and environmental standards are being met. The reply to the FOI suggests that this requirement in so far as the management of contaminated land and “best practice” is concerned that the MOD is ignoring its own requirements for audit and assurance.

Refrences

Safegrounds Good Practice  Guidance  for the Management of Contaminated land on Nuclear-licensed and Defence Sites; version 2

Safegounds Good Practcie Guidance for Land Quality Records Management for Nuclear-licensed and Defence Sites

MOD contaminated land and the demise of stakeholder engagement

This video features a MOD contractor talking about the cleanup of the Atomic Weapons Establishment site in suburban Cardiff. The cleanup took place some years ago. The contractor explains how stakeholders were engaged and kept informed about the project. 

Presentation slides

 It interesting to compare this with the more recent situations at sites such as Dalgety Bay  etc which have been typified by a lack of constructive stakeholder engagement and an un-willingness to address and accept liability for historic contamination.

  

I suspect a driver for more positive behaviours is the need to for MOD to realise as much money as possible for sites that are being sold for redevelopment as opposed to alienated sites which are viewed as liabilities.

The need to find resource savings has means that far less money is available for to remediate polluted sites let alone stakeholder engagement.

Staff cuts cause breach of statutory duty

I recently requested the Defence Nuclear and Environmental Safety Board (DNESB) annual reports for 2011 and 2010


MOD Response


“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. ”


This response provides a damming example of how resource cuts are causing the MOD to breach its statutory duties in relation to the Freedom of Information Act to provide the information requested with 20 working days.


I suspect that the “subject matter expert” referred to in the response are specialist staff who because of their years of experience and qualifications cost more to employ than non-specialist staff. Consequently specialist staff have been offered early retirement, enabling the MOD to meet cost and staff reduction targets.


The loss of such staff reflects a dumbing down of MODs’ technical expertise, the loss of the ability to act as an “intelligent customer” for its contractors services and the ability to be properly accountable to Parliament, the public for complex technical issues such as nuclear safety.

MOD - Nuclear Liabilities Management Strategy

In 2007 the MOD published its policy on the management of radioactive waste arising from the defence nuclear programmes.

• Policy
• Annex to the policy paper
• Flyer

Four years later In 2011 the MOD published “Nuclear Liabilities Management Strategy “  the strategy was meant to explain how the policy outcomes set out in the policy paper were to be delivered, who was responsible for their delivery,  when these would be delivered,  and to identify costs and how/when the costs would be met.


However the strategy is very much a narrative document describing sources of wastes and options for management.  It is notable that the Strategy is very much focused on the submarine programme.   


There is no mention of decommissioning Aldermaston; the strategy states “End Point AWE will continue to support the DNP for the foreseeable future.”  The MOD is blind to the need to anticipate change and in any case at some point in the future buildings and facilities at AWE will need to be decommissioned and replaced as they age.


The MOD policy required that the strategy would be produced in consultation with stakeholders including NGOs. As far as can be determined no NGOs were consulted. This is in contrast to the national strategy produced by the NDA where the NDA actively engaged with external stakeholders including local communities and NGOs.


The strategy says “The MOD will consider public engagement on a case by case basis taking account of Government policy and environmental and planning law” The policy says 
“the MOD remains confident that in conjunction with stakeholders (OGDs and NGOs), it is able to deliver the policy set out above” 


The expectation was that MOD in developing the strategy will meet the requirement of its stated policy to involve NGOs. However it is now clear from the strategy MOD will only do the minimum required by law 


“6.3 Funding
P134 Expenditure on managing the MOD’s
nuclear liabilities will be appropriately prioritised
within the Defence budget. Funding for strategy
development and implementation is not reliant
on income from the realisation of assets’ values.”


The strategy fails in that it provides no indication of costs or how funding is to be provided against the ongoing programme of resource cuts and savings targets 

In 2007 Hansard reported  decommisioning liabilities of over £ 9 billion

19 Jan 2007 : Column 1365W—continued

"Nuclear Liabilities

Chris Huhne: To ask the Secretary of State for Defence whether his Department’s nuclear liabilities have been quantified; and how they are funded. [116180]

Des Browne: The Department’s nuclear liabilities are set out in the Department’s Annual Report and Accounts, the most recent version being those for 2005-06 (HC1394) published on 14 July 2006; a copy of which is available in the Library of the House. The estimate of the MOD’s nuclear liabilities (page 220) is £9,753,827,000"

The lack of any costs in the strategy suggest that MOD might be trying to hide an increase in decommmsssioning costs





“6.2 People, Skills and Capability
P133 Available Suitably Qualified and
Experienced Personnel (SQEP) are essential to
the MOD and its industrial partners and supply
chain to deliver successful liability management,
and decommissioning and disposal projects. The
MOD’s SQEP initiatives support the development
and implementation of this Strategy.”


The DNEB have for years pointed out that levels of SQEP staffing are below that required for the safe delivery of the nuclear programme. The ever increasing need to cut costs and the priority being given to delivery of operational capability rather than backend decommissioning  suggest this is a significant area of weakness in the delivery the policy outcomes for managing nuclear liabilities


“6.5 Information and Knowledge
Management


P136 The MOD recognises the long programme
timescales associated with implementation of
this strategy; the MOD’s system of information
and knowledge management is essential for
the effective retention of information and for
maintaining continuity between projects.”


Recent revelations have shown MODs unable to retain information and records over the medium let alone the long term.


Conclusion


The Nuclear Liabilities Management Strategy lacks substance and detail and appears to be little more than an exercise in window dressing, particularly when compared to the strategy produced for the civil sector by the NDA.


Reference:


NDA paper "Non NDA Liability Management Strategy March 2011" includes reference to the Ministry of Defence

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

This is the MOD response to a recent FOI request concerning radioactive waste


"Thank you for your email of 4 May 2012 requesting release of the minutes of the central MOD Committee concerned with Radioactive Waste Management for the period 1975 to 1985. Your request is being treated as a request under the Freedom  of Information Act 2000.  

We are writing to advise you that following a search of our paper and electronic records, the information you requested is not held by the Ministry of Defence for the period you have requested."


The response points out in the clearest terms that MOD has failed to ensure the retention of key information for the period  1975 to 1985 about the way in which radioactive waste has been managed and disposed of. It may also mean that key information about policy and standards may have been lost including records relating to MODs involvement with NIREX.


Reference  JSP 392 Vol 1 Chp 7 Jan 2008 MOD Radioactive Waste Working Group