NIS Update: July 2012


Staff shortages and spending cuts remain key concerns in managing the safety of  Ministry of Defence (MoD) nuclear weapons and nuclear powered submarine programmes, according to the annual report of the Defence Nuclear Safety Regulator (DNSR).

The report, signed by the head of DNSR, Commodore David Langbridge, who is responsible for regulating the nuclear and radiological safety of the MoD's nuclear programmes, warns that there is a "lack of adequate resource to deliver the defence nuclear programmes safely". The problem is intensifying and requires "significant action".

Echoing concerns from reports in previous years, Langbridge advises that: “The two most significant Issues raised in this report continue themes from recent Defence Nuclear Environment and Safety Board (DNESB) reports.  These are that inadequacy of resources, both money and staff complement, and the difficulties in maintaining a sustainable cadre of suitably competent staff (Royal Navy, MOD civilians and in industry partners) are the principal threats to safety in the DNP [defence nuclear programme] in the medium term”.

The lack of finance and staff resources has been given a 'red' rating in the report, meaning that "significant action might be necessary within a year".  Shortages of submarine reactor engineers at certain ranks are a particular problem, and 29% of civilian posts within MoD requiring nuclear competence “have a high vulnerability”.  Plans to cut MoD staff by a quarter by 2014-15 "provide a difficult backdrop" to addressing this issue.

The report identifies six further problem areas, rated as 'amber' or 'green' because they require less urgent action.  These include a lack of funding for decommissioning redundant submarines and approaches to demonstrating plant safety which are “inconsistent and tortuous to uncover”.  

Difficulties in controlling the quality of work is also highlighted as a concern.  "The number of incidents remains too high," Langbridge wrote. "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."

Together, the threats "pose the risk 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."

Commodore Langbridge also highlights worries about plans to transfer DNSR's functions into a new Defence Safety and Environment Authority (DSEA) within MoD, questioning whether adequate resources will be provided.  “I do have concerns about the establishment of DNSR’s full human resources in DSEA (the basis of the transfer)”, he warns.  “In-year funding has been transferred for only those posts occupied at the time”.


Seventy four fires have broken out on the Royal Navy's nuclear-armed submarines over the past 25 years according to figures published by the Ministry of Defence.

The fires were among a total of 266 fires which broke out on all British nuclear powered submarines over the period, according to an answer from Peter Luff, Minister for Defence Equipment, Support, and Technology given to a Parliamentary Question from Scottish National Party defence spokesman Angus Robertson.

Mr Luff's answer reveals that, on average, a fire has broken out on a submarine every 40 days since 1987, or more than ten times every year.

Of the 266 fires recorded over the period, 243 were classed as "small", such as "a minor electrical fault creating smoke", and were “dealt with quickly and effectively using minimal onboard resources”.  Twenty more were rated as "medium" fires, "such as a failure of mechanical equipment creating smoke and flame, requiring use of significant onboard resources".

Three further fires took place while the submarines involved were docked at naval bases, requiring both ship and external resources to bring them under control.  One of these took place on a ballistic missile submarine capable of carrying nuclear weapons.  The bases involved are not identified, but are likely to have been either Faslane on the Clyde or Devonport in Plymouth.

Information on whether ballistic missile submarines were armed with nuclear weapons when the fires occurred was “not held in the format requested”, Mr Luff said.


Senior policy and defence officials and technical staff from the five Nuclear Non-Proliferation Treaty (NPT) nuclear weapon states – China, France, Russia, the UK and the USA (collectively known as the 'P5') – met in Washington from 27 to 29 June 2012 to discuss the implementation of actions agreed at the 2010 NPT Review Conference.

The Washington meeting was the third conference held by the P5 and follows similar meetings in London in 2009 and in Paris in 2011.

Subjects discussed at previous P5 meetings include transparency, mutual confidence building, and disarmament verification. In Washington, the P5 continued their discussion of how to report on activities they are taking to meet their disarmament commitments, and shared views on objectives for the next round of broader NPT meetings.

A work plan was agreed for a working group led by China which will develop a glossary of definitions for key nuclear terms to increase P5 mutual understanding and help facilitate further discussions on nuclear matters.  The conference also heard presentations about the UK-Norway Initiative on disarmament verification and lessons learned from implementation of New START Treaty.

The P5 also shared their views on how to handle potential instances when treaty members decide to leave the NPT regime and discussed how NPT members could respond collectively and individually to a notification of withdrawal, agreeing that states remain responsible under international law for violations of the Treaty committed prior to withdrawal.

The five nations also discussed ways to boost negotiations on a treaty to ban the production of fissile material for use in nuclear weapons, which have stalled in the Conference on Disarmament, and considered how to encourage a favourable international forum this year on establishing a Weapons of Mass Destruction Free Zone in the Middle East.


The latest report published by the British American Security Council's (BASIC) Trident Commission gives an analysis of the options for Anglo-French nuclear cooperation from Bruno Tertrais of France's Fondation pour la Recherche Stratégique.

The paper, 'Entente Nucleaire', draws lessons from past attempts at nuclear cooperation between London and Paris, evaluates present arrangements, and gauges the prospects for increased cooperation over future years.

Tertrais describes the many attempts by the two countries to cooperate on military nuclear matters over the past fifty years. All failed, though London and Paris came close to jointly developing a common air-launched cruise missile in the early 1990s.

Tertrais concludes that nuclear cooperation between the UK and France will only be viable when political conditions are ripe and timelines and requirements for each country converge.  The formal US-UK nuclear relationship has been and can be a serious impediment to such cooperation.

The end of the Cold War has made UK-French cooperation easier as the countries' nuclear policies and postures have become largely similar. The 2010 Lancaster House Treaty and the Teutates warhead research project were “true historical milestones in the nuclear cooperation between the two countries”, made possible following “two decades of in-depth dialogue on nuclear matters”.  Differences remain however: London has a different conception of independence from that of Paris, with the UK deterrent assigned to NATO and doctrine and technology always in sync with that of the USA.

According to Tertrais, 2014 will be a significant window of opportunity for future UK-French nuclear choices. This is because, soon afterwards, both countries will have taken major decisions regarding the future of their respective forces and some avenues of potential cooperation might then become closed.


The Ministry of Defence has published a Post Consultation Report outlining the results of its recent Submarine Dismantling Consultation.  The consultation process, which took place between October 2011 and February 2012, sought views from the public and Ministry of Defence stakeholders on strategic options for dismantling the Royal Navy's redundant nuclear powered submarines.  Over 1,200 people took part in consultation events and over 400 written responses to the consultation were received by the Ministry of Defence

The report indicates that most respondents supported the aim of dismantling out-of-service submarines as soon as practicable.  Safety, public confidence and socio-economic issues were high among concerns expressed about locations for submarine dismantling and storage of waste.

There was significant concern among some residents at the candidate dismantling sites (Devonport and Rosyth) about carrying out dismantling in a heavily populated area.  The question of where the radioactive waste generated by dismantling is to be stored was also a significant issue for many respondents, and there was widespread agreement that further consultation would be required on this issue.

MoD intends to publish a further report explaining how the consultation responses have been taken into account in decision making for the Submarine Dismantling Project once key decisions have been made sometime in 2013.  Further public engagement has been promised to consider potential sites for the interim storage of radioactive waste generated as a result of submarine dismantling.


The Department for Energy and Climate Change (DECC) has published the government's response to the report by Dr Mike Weightman, head of the Office for Nuclear Regulation, on  lessons learnt from the Fukushima accident for UK nuclear industry, setting out the work DECC has done and intends to do to implement Dr Weightman's recommendations.

DECC reports that it has set about learning lessons for UK public contingency planning by carrying out a review of the Japanese response to the March 2011 earthquake and tsunami which led to the Fukushima emergency.  DECC's Nuclear Emergency Planning Liaison Group (NEPLG) has conducted a review of the UK’s national nuclear emergency arrangements in light of Japan's experience of dealing with a prolonged crisis.

The Department has been developing the tools and capability to be able to respond quickly to any incident at a nuclear site anywhere in the world, in response to Weightman's  recommendation that the nuclear industry should, with others, review how it estimates and provides information on radioactive releases to the environment.  DECC has also participated in initiatives set up by the International Atomic Energy Authority, European Union, and other international fora to discuss nuclear safety following the Fukushima crisis.

The Energy Bill, currently passing through Parliament, contains provisions to create the Office for Nuclear Regulation (ONR) as an independent statutory corporation with an obligation to be open and transparent about its decision-making.  The DECC report highlights the measures being taken to hold ONR accountable to Parliament and gives an assurance that official ONR documents will be widely published.

News from the Atomic Weapons Establishment


The Atomic Weapons Establishment (AWE) has applied to the Environment Agency to vary radioactive waste discharge permits for its Aldermaston and Burghfield sites.  The company has asked for a variation to the Aldermaston waste disposal permit in order to take advantage of changes in UK radioactive waste policy which now allows greater flexibility for operators to choose where their radioactive wastes are taken for treatment or disposal.  A similar variation was completed for AWE Burghfield last year.

AWE has also asked for a variation to the waste disposal permit for Burghfield to allow discharge of water contaminated with trace quantities of radioactive material from the on-site sewage treatment works into the Burghfield Brook.  The need to permit this discharge has come from recent changes in the regulations that have lowered the threshold for when effluents are considered to be radioactive.

The Environment Agency has taken the view that both applications are minor because they are either administrative or, in the case of the Burghfield application, very small in terms of the quantity and radioactivity of the proposed discharge.  No public consultation exercise for the proposed changes is planned.

The Environment Agency has undertaken a survey into the habits of local communities living around AWE sites to help in assessing radiation exposure pathways.  The survey took place in autumn 2011, but the surveyors were unable to find enough local residents to interview in certain areas around Aldermaston, resulting in a delay in publication.  Information from a previous survey in 2002 has instead been used to supplement data collected during the 2011 survey.  

Early indications from the survey suggest that whilst radiation exposures from AWE activities remain about the same, there have been some changes in pathways for exposure resulting from changes in farming practices in the area and closure of the Pangbourne Pipeline in 2005.  Alterations to some aspects of the monitoring programme for radiation in locally produced food may be required to reflect these changes.

The survey report is expected to be published in July 2012 and results from the monitoring programme are reported annually in the UK Radioactivity in Food and the Environment (RIFE) report which is published jointly by a number of government agencies.


Discharges of nitrogen oxides from combustion processes at the Atomic Weapons Establishment have exceeded the limit permitted by the Environment Agency by a small margin (190 mg per cubic metre measured against a limit of 180 mg per cubic metre).  The plant generating the emissions was taken off-line while AWE conducted investigations into the event.  The Environment Agency has since written to AWE with advice and guidance about how they could bring their operations back into compliance and informed AWE that the company should consider whether they need to apply to vary their current permit to allow higher emissions of nitrogen oxides in order to operate the plant.


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