Daily Express reports
"Launched in 1984 “HMS Tired”, as she has been dubbed, was due to be decommissioned from the fleet this year but her service was extended for another four years due to the delay in the rollout of the new Astute class submarines
A Royal Navy spokesman said: “HMS Tireless returned to Devonport Naval Base last week for repair following a small coolant leak that was contained within the sealed reactor compartment. There is no risk to the public, the environment or the crew.”
Whilst this may be true, the leak may be indicative of an ageing boat reaching the end of its life.
The decision to extend its service calls in to question to what extent the granting of the extension of service is at the price of an increased risk to safety.
This incident shows that the problems encountered with commissioning the Astute submarines are having a knock on effect on nuclear safety of the older submarines that were due to have been decommissioned.
This blog has already reported the MODs failure to identify the root causes of the problems with HMS Astute. It will interesting to see if the MOD publishes any information about the causes of the leak of coolant within the reactor compartment of HMS Tireless.
It is worth considering to what extent other submarines of the same class and age as HMS Tireless might now be prone to the same sort of leak or indeed a more serious leak that might endanger the submarine.
It should be remembered that this is not the first time HMS Tireless has suffered collant leaks, in May 2000, Tireless developed a serious leak in the nuclear reactor primary cooling circuit. The nuclear propulsion system was shut down and using backup diesel power Tireless made way to Gibraltar. The damage was found to be more extensive than first thought, and the boat remained at Gibraltar, creating diplomatic tensions between Spain and Britain, until she left on 7 May 2001, nearly a year later following extensive repairs During that year, all Trafalgar-class submarines were inspected for similar problems
More recent report
I noted this response from the Environment Agency about a FOI asking
"to see copies of the letters of agreement from the Environment Agency and predecessor to the Ministry of Defence for the atmospheric discharges of depleted uranium from VJ Battery at Eskmeals Firing Range, Cumbria."
The response from the EA dated 8/2/13
Thank you for your e-mail dated 8 January 2013 regarding atmospheric
discharges at Eskmeals Firing Range.
We have made a detailed and thorough search of all the files we hold regarding the Eskmeals site, this includes records we hold on site and we have also recalled the older records in off-site secure storage and assessed these. We can find no record of letters of agreement between MOD and the Environment Agency, or its predecessors, on aerial emissions from the VJ Battery at the Eskmeals site. The majority of our regulation at that site relates to permitting and regulation of solid waste disposal or on the use of radioactive sources for testing purposes. We wouldn’t have considered the firing of military weapons for test purposes from the VJ battery as a disposal of radioactive waste and therefore not subject to our regulatory arrangements with MOD."
The response is surprising in that it refers to discharge in the context of disposing of radioactive waste rather than a discharge to the environment.
" We wouldn’t have considered the firing of military weapons for test purposes from the VJ battery as a disposal of radioactive waste".
The reply also talks in terms of "regulation" the EA has no powers to regulate since the Radioactive Substances Act is diss-applied from the MOD.
A previous post goes into the detail of the relationship between the EA and 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 EA when discharging substantial quantities of radioactive substances into the environment."
The reply from the EA shows that they have abdicated their responsibility to protect man and the environment so far as exercising proper oversight of the discharge of depleted uranium to the environment from the firing of DU at Eskmeals is concerned.
This extract from the JSP 815 clearly shows how the MOD is clearly in the driving seat so far as the regulation, oversight of radioactive substances and control of information are concerned.
ANNEX N (APPENDIX 1) RADIOACTIVE MATERIALS ANNEX (TO THE MEMORANDUM OF UNDERSTANDING BETWEEN THE ENVIRONMENT AGENCY AND THE MINISTRY OF DEFENCE)
para 27
The Agency will consult the Ministry on any request under the Freedom of Information Act 2000 (FOIA), or the Environmental Information Regulations 2004 (EIR), for the release of any classified (see MoU) or sensitive information (including paper and electronic documents) originating from the Ministry. Unless information has been provided by the Ministry on the specific understanding that it will be published, the Agency will first consult the Ministry to ensure that all factors relevant to an assessment of the balance of public interest are understood and taken fully into account.
28 Classified or sensitive information shall be managed in accordance with the Agency’s Security Management Procedure and the Official Secrets Act. In order to minimise the requirement for the Agency to reply directly to FOIA/EIR requests involving classified or sensitive nuclear programme information, the Agency will be provided, where practical, with access to classified and sensitive information on a Ministry site rather than retain the information itself.
Footnote page 2: 6 For radioactive substances activities covered by this Annex, the Agency has no legal powers to enforce compliance.
In response to a FOI request the MOD has admitted the MOD has not carried any analysis of the root causes that that lead to problems on the Astute class submarines and that this was at least in part due to the collective loss of experience.
This raises serious questions as to the safety of the MODs' nuclear submarine programme, the effectiveness of the MOD management systems and in particular the effectiveness of the MOD's internal Nuclear Regulator and the Defence Nuclear Safety Committee; it may only be luck that a serious incident has not yet happened.
This situation would certainly not be allowed to develop in the civil sector which is subject to independent regulation by the Office of Nuclear Regulation.
.
Original FOI request 29 December 2012
Reply from the MOD dated 4th February 2013
"Request for Information under the Freedom of Information (FOI) Act 2000
Further to my letter of 28 January 2013, I am writing to provide a substantive response to your request for the following information:
The Guardian recently revealed problems with the Astute nuclear submarine, which is
coming to the end of three years of sea trials.
Rear Admiral Lister is quoted as saying that "he had identified three sorts of problems with the Astute:
a: flaws in design that only became apparent when testing started;
b: equipment that broke down too easily;
c: and some problems relating to poor construction at the shipyard.""
Could you please provide me with information about the root causes of these problems.
I can confirm that the MOD does not hold any information within the scope of your request. This is because no analysis of problems on the Astute class submarines, nor any of the other lessons learning processes undertaken on the Astute programme, have categorised problems in the exact terms you describe in your request. In his interview with the Guardian, Rear Admiral Lister was providing an engineer’s assessment of the generic problems experienced during the early phase of the Astute build programme, and not seeking to quote the formal lessons learning work that has taken place.
Outside the scope of the FOI Act I should like to add that the most significant factor in the problems that have occurred in the Astute programme is the collective loss of experience of designing and building nuclear submarines owing to the long gap between the construction of the last of the Vanguard class (HMS Vengeance) and the start of the construction of HMS Astute."
The MOD needs to accept liability for the contamination at Dalgety Bay so that the contamination can properly identified, managed and dealt with; claims by those who suffered blight etc can be addressed. The MOD needs to implement the principles of environmental justice in its policies and decision making.
MODs reluctance to accept liability may be influenced by the precedent that might be set for the hundreds of other contaminated sites the MOD sold off since WW2, such as RAF Pulham in Norfolk
Dunfermline Press reports :-
GORDON BROWN has asked the head of the Scottish Environmental Protection Agency (SEPA) to make an early decision on who is responsible for the radiation leaks at Dalgety Bay. He said this was now essential if the remedial action plan to clean up the Bay area was to go ahead and be funded. It was time, he said, to name who was guilty for the leaks so further delays in cleaning up could be avoided.
He has written to SEPA after a letter to Dalgety Bay Community Council from the Ministry of Defence. In it the Ministry says it cannot agree to fund the clean-up until SEPA makes a decision as to who is responsible for the damage at the Bay's foreshore.
In his letter Mr Brown says the delays have to be brought to an end and he wants clean-up work to begin next May. Mr Brown, who has already met the Defence Secretary and held a Parliamentary debate on the issues, told SEPA, "It is clear that we will not make progress on the remediation plan until a decision is made about responsibility for the contamination and in that context I am writing to ask when you will make a determination on this issue.
"As we understand it there has yet to be conclusive evidence suggesting that other parties than the Ministry of Defence may be responsible for the dumping of radiation materials. "The MOD say they will only fund the clean-up if they are held to be liable by you and I hope you can
tell me when we can come to a conclusion on this matter.
"The people of Dalgety Bay have been very patient. We cannot continue with the prevarication and passing of the buck on who is responsible.
"A decision should be made as quickly as possible to protect the May 2013 timetable for the start of the clean-up."
My personal view has always been; that the evidence proves that the MOD was the probable source of the radium contamination and that by denying liability MOD has and continues to waste large amounts taxpayers payers money over the period of 20 or more years since the contamination was discovered.
It is also very convenient that the papers relating to the sale of Dalgety Bay which may have provided key evidence about liability cannot be found.
"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."
Its notable that the MOD is looking find a sites to break apart the decommissioned nuclear
submarines including Roysth a few miles west of Dalgety Bay
NIS report
"MoD has published a Request for Information in the Defence Contracts Bulletin and the Official Journal of the European Union seeking responses from private owners of nuclear licensed sites in the UK that may, subject to a comprehensive and publicly transparent site selection process, be able to meet its intermediate level waste storage requirements.
Babcock Marine, owners of the Rosyth and Devonport dockyards which are being considered as candidate sites for dismantling of the redundant submarines"
In view of the way in which the MOD has handled the contamination of the beach and foreshore at Dalgety Bay, it will be interesting to see to what extent there is public and political support in
Scotland for the dismantling work to take place at Rosyth.
From an ethical point of view the choice of Rosyth could be seen the MOD taking advantage of an economically disadvantaged community by holding out the chance of some short term work in exchange for taking on the legacy of the nuclear submarine programme. Dalgety Bay provides an example of the consequences of a legacy left by past defence activities.
