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
In 2007 the MOD published its policy on the management of radioactive waste arising from the defence nuclear programmes.
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
"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
It’s interesting to note from a recent PA report on the visit of Defence Minister Andrew Robathan. He said that “the Ministry of Defence does not deny liability” and went on to say “But I don't think you would expect us to accept liability before we know exactly what the situation is.”
Video report from STV
This is surprising since the MOD has known about the contamination since 1990 and even produced its own risk assessments; surely enough time has passed and information gained to establish the responsibility for the contamination based on reasonable probability.
The reference to “industrial sites and ship-breaking” and the “need for further investigations”, seems like an attempt to further muddy the waters and play for even more time.
The reference to “earth movement which of course has of course disturbed a great deal of stuff” suggests that buried radium residues may have been disturbed and brought to the surface with a consequent increase in risk.
It seems that MODs continuing failure to accept that in all probability that the MOD is responsible for the contamination of Dalgety bay is very likely to lead to SEPA designating Dalgety Bay as radioactively contaminated land.
It’s also interesting to see how MODs miss-handling of the radium contamination at Dalgety Bay, and in particular the failure to apologise or accept liability for the contamination may well have played a significant part in shaping people’s views about the options for managing the decommissioned nuclear submarines stored on the Firth of Forth at nearby Rosyth Dockyard.
Link to press report
Link to press report concerning Devonport and Dalgety Bay
Dalgety Bay provides a classic example of the miss-management of an environmental issue causing reputational damage across all business areas.
The situation has moved from one concerning essentially scientific and objective decisions to a much more difficult situation primarily driven by ethical and political considerations. This is especially true in the current political environment where the SNP is seeking success in the up-coming referendum on independence.
31/1/12 (UKPA) reports
More tests due on bay radioactivity
Further investigations are needed at a beach where radioactive particles were found before anyone should take full responsibility, Defence Minister Andrew Robathan has said.
The Tory MP visited Fife to hand over a draft plan for further action to the Scottish Environment Protection Agency and to see the contaminated area for himself.
It comes after "significant" sources of radiation were discovered at Dalgety Bay on the Firth of Forth coast.
The contamination is thought to stem from residue of radium-coated instrument panels used on military aircraft which were incinerated and land-filled in the area at the end of the Second World War. The area faces the threat of being designated Radioactive Contaminated Land for public protection.
During a short visit to nearby Rosyth, Mr Robathan said the Ministry of Defence does not deny liability and questioned whether a clear-up of the site is needed.
"There was of course a Royal Naval air station here. It closed 53 years ago," he added. "Who knows who's liable. We're not denying liability but I think we need to be quite clear how this contamination has come about.
"For instance, there has been industrial sites. I understand there has been a ship-breaking yard just down the way. There's been earth movement which of course has of course disturbed a great deal of stuff. There's been housing estates built.
"We don't say that we are not in any way willing to help. We are willing to help. But I don't think you would expect us to accept liability before we know exactly what the situation is.
"We are therefore looking at this and we are willing to co-operate with the environment protection agency and others to find exactly what the situation is and then we can determine who is responsible for clearing it up, if there is a need to clear it up."
Last week former prime minister Gordon Brown, MP for Kirkcaldy and Cowdenbeath, called for urgent action to clean up the site. He has previously urged the MoD to "accept responsibility"
