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”.
Wednesday, 23 June 2010
Tuesday, 25 May 2010
MOD publishes report on 2009 safety concerns
MOD published their key corporate health and safety report for 2009 which has been provided to me in response to an FOI request.
MOD have identified a number of key themes that have emerged from 2009, they are:
"• The pressure that resource constraints are placing on safety and the need to ensure that decisions with safety implications are taken at the right level.
• A continuing shortage of personnel, both those with the necessary safety qualifications and those with sufficient experience to discharge their safety responsibilities.
• Concern over the cumulative effects of change, in particular personnel moves resulting in a dilution of available experience and competence."
Nuclear safety
"A key area of concern highlighted by the report is 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. The key areas of concern for the medium term are the sufficiency of resources, both money and staff complement, and the maintenance of a suitable cadre of suitably competent staff (RN, MOD civilians and industry partners)."
Explosive safety
"The condition of the explosives estate remains a primary concern for the Board, with the potential for significant vulnerability. The consequences of an explosive incident could have a significant impact on capability, and the potential off-site (public domain) consequences could have serious implications for the Department. Risk against compliance with MOD Regulations is increasing and, if agreed, a higher level of risk (including aggregated risks) may have to be accepted on resource grounds."
Defence plan 2010-14
It is interesting to note that the section 7 of the Defence Plan 2010-14 makes no specific mention of the serious safety issues raised in the DESB 2009 report in relation to either nuclear or explosive safety. It would seem that these issues appear to have been filtered out.
MOD have identified a number of key themes that have emerged from 2009, they are:
"• The pressure that resource constraints are placing on safety and the need to ensure that decisions with safety implications are taken at the right level.
• A continuing shortage of personnel, both those with the necessary safety qualifications and those with sufficient experience to discharge their safety responsibilities.
• Concern over the cumulative effects of change, in particular personnel moves resulting in a dilution of available experience and competence."
Nuclear safety
"A key area of concern highlighted by the report is 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. The key areas of concern for the medium term are the sufficiency of resources, both money and staff complement, and the maintenance of a suitable cadre of suitably competent staff (RN, MOD civilians and industry partners)."
Explosive safety
"The condition of the explosives estate remains a primary concern for the Board, with the potential for significant vulnerability. The consequences of an explosive incident could have a significant impact on capability, and the potential off-site (public domain) consequences could have serious implications for the Department. Risk against compliance with MOD Regulations is increasing and, if agreed, a higher level of risk (including aggregated risks) may have to be accepted on resource grounds."
Defence plan 2010-14
It is interesting to note that the section 7 of the Defence Plan 2010-14 makes no specific mention of the serious safety issues raised in the DESB 2009 report in relation to either nuclear or explosive safety. It would seem that these issues appear to have been filtered out.
Sunday, 16 May 2010
Sunday Herald report “Revealed: the catalogue of chronic safety blunders at Scotland’s nuclear navy bases
Sunday Herald report “Revealed: the catalogue of chronic safety blunders at Scotland’s nuclear navy bases”
“The Ministry of Defence is struggling to deal with hundreds of safety blunders, pollution leaks and environmental lapses at nuclear weapons bases on the Firth of Clyde. Official reports obtained by the Sunday Herald reveal that Faslane and Coulport have been plagued by nuclear accidents, radioactive contamination and fires over the last two years. Worryingly, there have been unspecified “shortfalls” in the safe management of nuclear bombs. And rules meant to protect people against asbestos and even Legionnaires’ disease have been frequently broken. The Government’s safety watchdogs have also warned that unless millions of pounds are invested in replacing the ageing radioactive waste plant at Faslane, it will no longer be safe in four years’ time. That will add to the multi-billion pound bill for keeping nuclear weapons in Scotland, critics say.”
Full story at
http://tinyurl.com/2wnw3ue and http://tinyurl.com/2w2q5pc
If accurate this article raises a number of questions. Firstly, shortfalls in radioactive waste management were highlighted as long ago as 2001 by RWMAC in their independent review of MOD radioactive waste management practices; it seems that very little has been done to implement their recommendations. It also seems that another independent review of MOD radioactive waste management practices is long overdue.
http://tinyurl.com/33f2bdp
The sorts of safety and environment failings highlighted in the article may indicate weaknesses in the safety culture on sites associated with the naval nuclear programme. It is interesting to compare these with those highlighted in the reports into the explosion and fire at Texas City Oil refinery USA and to what extent cultural and organisational similarities exist between BP and the MOD.
http://tinyurl.com/pe2qan
http://www.hse.gov.uk/leadership/bakerreport.pdf
It is also worth considering to what extent improvements in safety and environmental performance might be delivered if the Naval Nuclear programme and facilities were subject to civil regulation under the NIA and RSA rather than the current system of internal regulation. There may be significant cost savings for tax payer and MOD since there would no longer be a need to fund the system of internal Regulation; the urgent need to find savings within Government budgets would seem to encourage this.
The case for civil regulation was put by RWMAC in their 2001 report, recommending that:-
“Irrespective of MoD's assurance and, where necessary, its own regulatory arrangements, RWMAC believes that, as an overriding general principle, the benefits of civil regulation in helping to maintain operational standards, and in promoting assurance and transparency, are not in doubt. Thus, there should be a presumption that civil regulation should, as far as is reasonably practicable, be applied to MoD nuclear and radioactive waste management activities. Where there is a case for not doing so, this should be clearly set down and justified”
And further recommend that:-
“Subject only to real security considerations, the principles of openness and transparency should be taken as far as is reasonably practicable to help promote public confidence in the safety of MoD's nuclear and radioactive waste management operations”.
“The Ministry of Defence is struggling to deal with hundreds of safety blunders, pollution leaks and environmental lapses at nuclear weapons bases on the Firth of Clyde. Official reports obtained by the Sunday Herald reveal that Faslane and Coulport have been plagued by nuclear accidents, radioactive contamination and fires over the last two years. Worryingly, there have been unspecified “shortfalls” in the safe management of nuclear bombs. And rules meant to protect people against asbestos and even Legionnaires’ disease have been frequently broken. The Government’s safety watchdogs have also warned that unless millions of pounds are invested in replacing the ageing radioactive waste plant at Faslane, it will no longer be safe in four years’ time. That will add to the multi-billion pound bill for keeping nuclear weapons in Scotland, critics say.”
Full story at
http://tinyurl.com/2wnw3ue and http://tinyurl.com/2w2q5pc
If accurate this article raises a number of questions. Firstly, shortfalls in radioactive waste management were highlighted as long ago as 2001 by RWMAC in their independent review of MOD radioactive waste management practices; it seems that very little has been done to implement their recommendations. It also seems that another independent review of MOD radioactive waste management practices is long overdue.
http://tinyurl.com/33f2bdp
The sorts of safety and environment failings highlighted in the article may indicate weaknesses in the safety culture on sites associated with the naval nuclear programme. It is interesting to compare these with those highlighted in the reports into the explosion and fire at Texas City Oil refinery USA and to what extent cultural and organisational similarities exist between BP and the MOD.
http://tinyurl.com/pe2qan
http://www.hse.gov.uk/leadership/bakerreport.pdf
It is also worth considering to what extent improvements in safety and environmental performance might be delivered if the Naval Nuclear programme and facilities were subject to civil regulation under the NIA and RSA rather than the current system of internal regulation. There may be significant cost savings for tax payer and MOD since there would no longer be a need to fund the system of internal Regulation; the urgent need to find savings within Government budgets would seem to encourage this.
The case for civil regulation was put by RWMAC in their 2001 report, recommending that:-
“Irrespective of MoD's assurance and, where necessary, its own regulatory arrangements, RWMAC believes that, as an overriding general principle, the benefits of civil regulation in helping to maintain operational standards, and in promoting assurance and transparency, are not in doubt. Thus, there should be a presumption that civil regulation should, as far as is reasonably practicable, be applied to MoD nuclear and radioactive waste management activities. Where there is a case for not doing so, this should be clearly set down and justified”
And further recommend that:-
“Subject only to real security considerations, the principles of openness and transparency should be taken as far as is reasonably practicable to help promote public confidence in the safety of MoD's nuclear and radioactive waste management operations”.
Friday, 2 April 2010
MoD's internal regulator condemned military's plans as 'flawed, inaccurate and outdated'
This Guardian article “MoD's internal regulator condemned military's plans as 'flawed, inaccurate and outdated' with interest.
http://www.guardian.co.uk/uk/2010/mar/31/nuclear-subs-dnsr
I make the following observations. The situation reported in the Guardian may reflect on a lack of resources and in particular the impact successive budget cuts and the difficulty in retaining suitable qualified professional staff. As long ago as 2003 The MOD recognised this problem in the “DEFENCE ENVIRONMENT AND SAFETY REPORT 2003-2004”
http://tinyurl.com/yjuhyhz
“Risk 5. NUCLEAR SKILLS SHORTAGE: Effect: Insufficient qualified and experienced personnel to support the Defence Nuclear Programmes. Likelihood: Medium, Impact: Inability to sustain aspects of the Defence nuclear outputs. Risk Category: Personnel, Reputation, Operational”
It seems the short-comings highlighted in the DNSR Review might in part be due to these shortages of staff and resources identified in the DESB report. The shortages of skilled professional staff are likely to increase as the civil nuclear programme begins to accelerate drawing skilled staff away from the Defence sector
The recent budgetary situation in MOD has received coverage in the press and there will be significant cuts in the near future which may serve to cause even greater difficulties in funding and staffing.
It seems sensible therefore for MOD to move to a system of civil regulation which would engender far greater public confidence in the safety of its naval nuclear operations. MOD has recognised this; in the licensing of the Atomic weapon Establishments under the Nuclear Installations Act and as a matter of policy in the “ANNUAL REPORT TO THE DEFENCE ENVIRONMENT AND SAFETY BOARD 2000/01”
http://tinyurl.com/yfr44jy
“MOD accepts that, where it is practicable, demonstrating openness and transparency and building confidence will best be achieved by compliance with the civil regulatory regime and the Department has agreed to consider further moves in that direction.”
It is interesting to note that the “ANNUAL REPORT ON SAFETY, HEALTH AND ENVIRONMENTAL PROTECTION IN MOD 2004/5” was much shorter than previous reports and failed to include any reference to nuclear safety; and so far as I can determine from the MOD website that no further annual report to the DESB has been published.
http://tinyurl.com/yzxsye9
Perhaps the time has come to consider the affordability of MOD nuclear programmes and whether they can be resourced to conform to civil safety standards.
http://www.guardian.co.uk/uk/2010/mar/31/nuclear-subs-dnsr
I make the following observations. The situation reported in the Guardian may reflect on a lack of resources and in particular the impact successive budget cuts and the difficulty in retaining suitable qualified professional staff. As long ago as 2003 The MOD recognised this problem in the “DEFENCE ENVIRONMENT AND SAFETY REPORT 2003-2004”
http://tinyurl.com/yjuhyhz
“Risk 5. NUCLEAR SKILLS SHORTAGE: Effect: Insufficient qualified and experienced personnel to support the Defence Nuclear Programmes. Likelihood: Medium, Impact: Inability to sustain aspects of the Defence nuclear outputs. Risk Category: Personnel, Reputation, Operational”
It seems the short-comings highlighted in the DNSR Review might in part be due to these shortages of staff and resources identified in the DESB report. The shortages of skilled professional staff are likely to increase as the civil nuclear programme begins to accelerate drawing skilled staff away from the Defence sector
The recent budgetary situation in MOD has received coverage in the press and there will be significant cuts in the near future which may serve to cause even greater difficulties in funding and staffing.
It seems sensible therefore for MOD to move to a system of civil regulation which would engender far greater public confidence in the safety of its naval nuclear operations. MOD has recognised this; in the licensing of the Atomic weapon Establishments under the Nuclear Installations Act and as a matter of policy in the “ANNUAL REPORT TO THE DEFENCE ENVIRONMENT AND SAFETY BOARD 2000/01”
http://tinyurl.com/yfr44jy
“MOD accepts that, where it is practicable, demonstrating openness and transparency and building confidence will best be achieved by compliance with the civil regulatory regime and the Department has agreed to consider further moves in that direction.”
It is interesting to note that the “ANNUAL REPORT ON SAFETY, HEALTH AND ENVIRONMENTAL PROTECTION IN MOD 2004/5” was much shorter than previous reports and failed to include any reference to nuclear safety; and so far as I can determine from the MOD website that no further annual report to the DESB has been published.
http://tinyurl.com/yzxsye9
Perhaps the time has come to consider the affordability of MOD nuclear programmes and whether they can be resourced to conform to civil safety standards.
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