Defence Nuclear Safety Regulator's annual report 2011

The Defence Nuclear safety Regulator (DNSR) have recently published their annual report for 2011 which includes a summary of nuclear and radiological safety and environmental protection performance in the Defence Nuclear Programme (DNP)

Key risks are :-

Red Risk

• Lack of adequate resource to deliver the defence nuclear programmes safely.
• Measures already in hand may be insufficient to address the present and predicted shortage of NSQEP in the Royal Navy, among MOD civilians and in defence contractors

Amber risk

• Safety Cases in the DNP are inconsistent against current good practice; integration of safety analyses for the reactor and weapon needs to be expedited
• The demonstration that the risk from DNP activities is ALARP is inconsistent and tortuous to uncover
• The number of incidents remains too high

"Para 7: At least some of the Issues described further on have their roots in a general lack of resource to address the work required to conduct activities and demonstrate their safety."

This issue has been included as a red risk for years and it appears that no progress has been made to provide the required resources and if anything the situation is getting even worse year by year. DNSR appears powerless to ensure that Ministers and management to provide the resources necessary to safely deliver the MOD nuclear programmes.  

 It appears that only a serious incident would deliver an increase in resources.   This is what happened after  the Pochin enquiry in the late 1970s  following the discovery that 12 of those working at the Aldermarston appeared to have accumulated plutonium in their lungs in excess of the level recommended by the International Commission on Radiological Protection.  It was this that lead in a large part to the establishment of MOD professional Health Physicists as a separate grade within the MOD.

"Para15: Evidence continues to build that constraints on the DNP’s industrial funding are now affecting staffing levels in Tier 1 contractors; as a result projects run behind declared timetables and important safety submissions are delayed. The trend (of decades) to outsource work from MOD to industry when there are reductions in crown servant numbers (or the inability to recruit), may be approaching a real limit as industry is equally constrained. The limit may also result from the desire to maintain “crown control” of some activities, not least because safety legislation is applied differently (or exempted)  dependant on who is conducting the work."

Highlights the policy  of “crown control” under which the MOD nuclear operations remain largely exempt from civil nuclear regulation.  In the past outsourcing the work has allowed the MOD to meet staff reduction targets but it clear that the limit of this has now been reached if not exceeded.

"A number of incidents have occurred across the programme in 2011; individually they have not been of high significance or safety/environmental detriment, but taken together, they produce concern that working conditions and culture might not prevent an incident of higher significance"

DNSR highlights a worrying trend in incidents but these may well indicate the potential for a more significant incident with wider ranging consequences and may also be indicative of a safety/management culture under stress.

It is worrying that there are problems with integration of safety analyses for the reactor and weapon.  This suggests a "stove-pipe" approach to safety  and that there is insufficient consideration of the combined risks from all the hazards on the submarine, reactor, nuclear weapon, explosive, human factors and external hazards.  The report does not provide any information about what DNSR is doing to address this important issue.

Summary

The report clearly shows that the MOD lacks  adequate resources to deliver the defence nuclear programmes safely.  As far as can be seen DNSR  has been ineffective in persuading management and Ministers to provide the necessary resource.
  
It is also notable that DNSR has not issued any enforcement notices requiring the provision of the necessary resources deliver the defence nuclear programmes safely
. 
It  is also of interesting to see in  DNSRs report,  concerns expressed  about the difficulty in establishing of DNSR’s full complement of human resources in DSEA with the potential to impact on DNSRs' ability to regulate.

The report suggests the probability of a serious incident within MOD nuclear programmes continues to increase.

BBC Radio 4 - Face the Facts Radioactive Legacy

Milcon Research and Consulting is  a key contributor to the recently broadcast  BBC programme on  radium contaminated land. The contribution from Milcon Research and Consulting was based on information in the public domain and responses to FOI requests.




BBC reports :-
"A pretty town on the Fife coast remains under threat of an unwelcome distinction. A corner of Dalgety Bay could still become the first place in Britain to be branded as radioactive contaminated land if the Ministry of Defence does not follow through on a plan to deal with radioactive particles washing up on its shore. The MOD's accused of causing the contamination in the first place: aircraft containing potentially hazardous radium were smashed up and buried after the Second World War. The MOD's investigating the scale of the problem and ways it might be put right, but has not promised a full and final clean-up of the bay. That's despite calls for it to do so from the local MP and former Prime Minister, Gordon Brown, and a recent discovery of particles far more radioactive than those previously found. Yet Face the Facts reveals how the MOD has cleaned up other sites deemed far less radioactive; how it's sold off contaminated land for development with radium undetected; how a lack of records means it does not know where similar sites might be and how a confidential government report we've seen from the 1950s warned of the danger of radium dumps being forgotten or, in the case of privately-owned land, deliberately concealed."
Presenter: John Waite
Producer: Jon Douglas

Link to the programme web site

Related Milcon R&C blog posts


Dalgety Bay


Hilsea Lines


Pulham


Chatham 


Failure to provide accurate information in response to FOI requests

Chatham an urban nuclear waste dump and a lasting legacy of the nuclear submarine programme

Background


Chatham Dockyard played a key part in the United Kingdom’s nuclear propulsion programme. Refitting and refueling of nuclear submarines was carried out at Chatham from 1970 until March 1983.  These activities gave rise to radioactive waste which had to be disposed of.  Higher activity wastes were disposed of to BNFL Sellafield in Cumbria. However some of the lower activity wastes were disposed of by local burial within the Dockyard site.  This was done with the agreement of the Regulator HMIP (reference 1) on the assumption the waste contained short lived Cobalt 60 which would decay away over a period of 20 to 30 years. In interesting note that in an answer to a PQ about radioactive waste arrangements at Chatham, there was no mention of the disposal of radioactive waste by burial at Chatham. Hansard (26 Nov 2002: Column 172W)


More about the history of refitting and nuclear work at Chatham Dockyard


Amount of waste buried


Approximately 300 cubic meters of radioactive waste was buried between 1968 and 1986 - reference 2


Risk assessment


Reference 6  to quote the MOD “The risk assessment for the disposal of radioactive waste by burial Chatham - It has not been possible to locate this information, it would have predated the approvals granted by the Department of the Environment in 1980 and has not been located in any of the files recovered”.   This is a significant failure in the MOD’s corporate memory.


Cobalt 60 and Carbon 14 


Cobalt 60 has a short half live of around 6 years, so that after about 24 years the amount of radioactivity will have fallen by approximately 93%. It was on this basis that it was considered safe to dispose of the waste by local burial.


However it came to light that nuclear waste arising from the submarine programme also contains significant amounts of Carbon 14 with a half life of 5,700 years. This issue was picked up by the Governments Independent Advisory Committee on Radioactive Waste Management (RWMAC) in their 2001 report on the Ministry of Defence radioactive waste management practices. Reference 3, 4.  DRPS estimates of carbon 14 in wastes arsing form the naval nuclear prolusion programme can be found at reference 5 paragraphs J and K.


Monitoring


Reference 7:  the attached MOD letter dated 13 October 2008 clearly shows that whilst environmental monitoring for Cobalt 60 was being carried out, it was not for Carbon14. This despite the knowledge dating back to 2001 that Carbon14 may be present.


Burial site


It is notable that the burial site remains MOD property this suggests that  the risks from the buried waste are not insignificant.  The site is walled off by a 3 metre high wall, whilst the site its self has reverted to scrub and woodland.

Google Earth view showing the dump site at Chatham out-lined in red

As can be seen from the image above the burial site the immediate area is undergoing extensive redevelopment including the water-front, a new marina and housing etc.

View of the dump site from Pier Approach Road the dump is behind the wall and appears to be heavily wooded

Conclusion

• The assumption that Cobalt 60 was only significant radionuclide present in the waste buried at Chatham was mostly likely wrong.
• The non-availability of a risk assessment or safety case for the burials a Chatham is a serious failing of corporate memory and does little to engender public confidence in the MODs ability to manage the safety of legacy issues over the medium and long term.
• In the absence of any available safety case, the MOD in conjunction with the Environment Agency needs to publish a revised safety case for the burial site to take account of the presence of Carbon 14 in the waste. The safety case should also demonstrate that the burial meets current standards and regulatory requirements to ensure both environmental and human safety. If this cannot be done to the satisfaction of stakeholders and the Regulators serious consideration must be given to remediation of the site.
• The situation at Chatham does little to improve public confidence in the Governments policy and the NDAs strategy for managing radioactively waste nationally and the MOD in particular. It remains to be seen how the MOD will respond to issues surrounding the waste dump at Chatham, but if Dalgety Bay is an indicator, the signs for speedy action are not good.

References


1: HMIP agreement to dispose of radioactive waste by burial 
2: MOD letter dated July 1987
3: RWMAC report on the MODs’ radioactive waste management practices 2001 - Carbon14 paragraphs 6.52 to 6.62
4:  MOD response to RWMAC regarding Carbon 14
5: DRPS estimates of Carbon14 in waste streams arising from the Naval Nuclear Propulsion Programme paragraphs J and K
6: Letter dated 7 August 2009 from MOD providing information on burials of radioactive waste at Chatham
7: Letter dated Medway Council dated 29 May 2009 with attached letter from MOD dated 13 October 2008

The failing regime for managing contaminated land.

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.