Thursday, 20 January 2011

Safety Concessions at Clyde Submarine Base

Safety Concessions at Clyde Submarine Base
In response to an FOI asking for information about the number of concessions granted against nuclear safety regulations by year since 2000 at the Clyde Submarine Base. Safety concessions are situations where there is relaxation of a safety standard which agreed between the operator and the regulator. eg time allowed to reach a particular standard and mitigating measures taken to reduce hazard and/or risk.
MOD have provided the following information
“It may be helpful for me to explain that occasionally, for operational reasons, there may be a requirement to temporarily append a safety case and provide temporary suspension of associated conditions and limits of safe operations, or the authorised scope of operations at Her Majesty’s Naval Base (HMNB) Clyde. Prior to this decision the impact of such an amendment is carefully considered to ensure that any safety risk is both tolerable and as low as reasonably practicable (ALARP). On each occasion, when such an amendment is needed, HMNB Clyde will approach the Defence Nuclear Safety Regulator to consider and formally agree the amendment. Please find below a table which gives the number of amendments as agreed with the Regulator since 2000:

Year Number of amendments
2000 2
2001 0
2002 2
2003 1
2004 3
2005 2
2006 0
2007 0
2008 1
2009 3
2010 4
"
The relaxation of a safety standard which is agreed between the operator and the regulator providing the temporary suspension of associated conditions and limits of safe operations. This implies that workers/ the public and the environment are at greater risk.
Correspondence
http://www.whatdotheyknow.com/request/safety_concessions_clyde_submari#incoming-142601

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

Reference
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”.