- SCANS Objectives
- The nuclear release Scenario
- Exercise Failures
The pressure for submarines to use Southampton docks appears to be a political rather than a practical one. Legal advice to the Solent Coalition Against Nuclear Ships (SCANS) is that there are grounds to object to the public being put at an unnecessary risk and that the power of the Nuclear Installations Inspectorate (NII) needs examination. The “Sotonsafe” Nuclear Accident Plan, code-named “Foxwater06” was exercised on 22nd February in preparation for British submarines to enter the Docks. A persistent lack of openness surrounds most of the Nuclear Accident Exercise, with SCANS Observers excluded from the table-top Exercise. We monitored the Exercise as best we could externally, pointing to things that were not done and noting that the Exercise was inflexible and could not adapt to key variables such as the actual wind direction. This report also refers to information provided to the post Exercise meeting on 7th March. The accident scenario unaccountably remains secret but it was for a Category 3 accident, not for the most serious Category 6 failure.
In the event of a nuclear release, only limited protection from radiation can be offered to the public. The distribution of Potassiun Iodate Tablets (PITS) to prevent thyroid cancer was not tested adequately and the use of the media as the primary public warning system proved unreliable. Contradictory advise to the public to take shelter and evacuate; lack of road or sea traffic management; lack of basic anti-contamination precautions and minimising the likelihood of people self-referring for radiation checks all gave cause for concern. Advice to parents to leave their children and not collect them from school was not tested; nor were child-care professionals informed. The Exercise failed to test any part of the Plan on the ground in Hythe. The high cost of the Exercise is considered disproportional to the gain.
Despite its many failures, the Nuclear Installations Inspectors passed the Plan as ‘fit for purpose’. While it may meet naval requirements, this Exercise did not meet the needs of the public. However, since the regulatory role of the NII relating to operational boats is questionable, it does not appear that any endorsement is valid.
1.1. Southampton does not have a local nuclear risk at present and submarines have not used the so-called ‘Z Berth’ at 38/39 Berth in the Western Docks, since 2000. Prior to that, it had rarely been used. The Ministry of Defence (MoD) proposal to bring submarines powered by nuclear reactors into the City Centre again would create a new risk. Southampton City Council (SCC) has consistently requested that nuclear submarines are kept out of the docks. The request was refused and consequently the so-called “Sotonsafe” Nuclear Accident Plan, code-named “Foxwater06” was exercised on 22nd February.
1.2. Submarines use Z and X Berths at naval dockyards but Z Berths at commercial ports such as Cardiff, Hull and Tilbury were closed in the 1980s and 90s. Swansea Council successfully resisted one opening in its docks and the Liverpool berth is in abeyance. Southampton was the last commercial port in the UK to accept nuclear submarines in 2000.
1.3. Naval dockyards at nearby Portsmouth and further south, at Devonport provide ample safe anchorage at Z Berths when submarines are not operational. There is no need for Southampton to be used now any more than it has been during the past six years. The pressure for submarines to use Southampton docks appears to be a political rather than a practical one.
1.4. British nuclear submarines can enter the Docks only after the Plan has been exercised, but armed only with conventional weapons. Foreign nuclear powered and nuclear-armed submarines can do so regardless of a safety plan, dependant only on the invitation of the Secretary of State for Defence.
1.5. SCANS agrees with SCC that in the event of a nuclear release, only limited protection from radiation can be offered to the public; introducing a risk where currently there is none is a backward step. It is accepted that the Navy takes all reasonable safety precautions, and that a Category 6 accident has not occurred. But the submarine fleet is aging and reactor accidents have occurred when loss of coolant water has resulted in reactors overheating. Normally, the precautionary principle governs risk assessment, but in this case it is ignored.
1.6. In common with other major population concentrations, Southampton’s real security needs relate to matters such as climate change, bird flu, social and environmental justice and terrorism. The nearby Fawley oil terminal and industrial sites pose a permanent hazard.
1.7. The cost of the Exercise is estimated by SCC at £1million and is disproportionate to any gain. The opportunity cost should be looked at in terms of benefit rather than risk to the City.
1.8. Negotiations took place during 2005 between SCANS and SCC (acting for the Planning Liaison Committee) to secure Observer status for SCANS representatives and to request an independent Observer at the table-top Exercise. The Committee refused, but SCANS monitored the Exercise as best it could externally at Southbrook Rise, Dock Gate 4, Woolston, Weston, Hythe and Waterside.
1.9. This report takes into account our observations on the ground and points to things that were not done. It also refers to information provided to the post Exercise meeting on 7th March but since most of the Exercise was secret, many important questions remain unanswered.
1.10. The ‘Sotonsafe Plan’ should be a stand-alone plan. In the event of a real release, sufficient national civilian resources may not be brought to bear on the problems since any vehicles and personnel used would risk contamination and lengthy quarantine. Military resources may also be stretched, particularly if they have to respond over a wide area beyond the immediate nuclear source.
1.11. Access to the’ Sotonsafe Plan’ on the SCC website is not easy to find unless you have the reference: http://www.southampton.gov.uk/advice/emergencies/emergency-planning/default.asp
1.12. Legal advice to SCANS is contrary to that of the Council’s legal officers. Swansea City Council successfully argued that in the event of a submarine reactor accident it could not protect its citizens and was not prepared to face litigation arising from lack of care. There are grounds to object to the public being put at an unnecessary risk.
1.13. The MoD has changed its justification for putting Southampton at risk from a submarine in the Docks from ‘recreational’ to ‘operational’. The regulatory role of the NII ends once a boat becomes operational, as safety is then subjugated to the operation. It follows that the NII does not have the power to assess the ‘Sotonsafe’ Plan nor declare it “fit for purpose”.
2. SCANS Objectives
2.1. We wanted to see if the Exercise tested the Plan thoroughly and answered questions such as ‘how will the public be evacuated on foot from shops, leisure facilities and public areas in the 2Km countermeasures zone?’ ‘Where will they go?’ Do the public know about the Plan or the Exercise? Will traffic disruption be tested and ‘will the distribution of Potassium Iodate Tablets (PITS) in time to protect people prove feasible?’
2.2. The distribution of PITS to prevent thyroid cancer to households downwind by Naval Ratings was one controversial task to be tested. This medication is to be delivered by the Navy to residents downwind of the accident, particularly to children and vulnerable groups.
2.3. We were concerned to see the level of public information available and if the Exercise would remain a mystery to the general public who it is designed to protect.
2.4. Eighteen SCANS Observers worked on a rota basis in cold conditions to monitor the Exercise participants’ activity throughout the day from 08.30 – 18.00. We were very grateful for the use of a room in St. Mary’s Church Office as our HQ and for the support of the staff there. SCANS recorded actual activity and endeavoured to gauge public opinion of the exercise.
3. The nuclear release Scenario
3.1. The release of radiation from a submarine reactor accident would be very unpredictable. The Exercise scenario unaccountably remains secret but it was for a Category 3 accident, not for the most serious Category 6 failure when a reactor might explode beyond the confines of the hull at speed. SCANS advice from the nuclear engineer expert, John Large, is that a release of radiation into the atmosphere from a damaged reactor would not necessarily happen over several hours, with plenty of warning. The Exercise should have tested the safety response to a worst case scenario when a fast release might occur under certain conditions, such as fire or impact.
3.2. Weather conditions would indicate where most, but not all the radiation might reach. It was disappointing that this Exercise did not respond to the actual East/North East wind direction on the day. If an Exercise cannot adapt to the key variable governing risk to the public, it is hard to see how the Nuclear Installations Inspectorate (NII), SCC, or the public can have confidence in the Plan. An opportunity to carry out this essential test was missed. A rehearsal to try to protect the people in Hythe and the rural Waterside hinterland downwind on 22nd February would have been possible with sufficiently flexible preparation.
3.3. The third sector for which a response should have been tested was the central area of the City. Here the plan is to evacuate shops, businesses and public buildings.
3.4. The Exercise was limited to an unrealistic 2Km range in one direction. Radiation could be expected to reach well beyond 2Km. The Food Standards Agency plan to test milk and crops up to 70Km downwind.
3.5. A concurrent event took place during the Exercise when an unexploded bomb was located on Weston Shore, the nearest land point to the Z Berth on the Southampton side of Southampton Water outside the Docks. The evacuation of 500 homes in Weston took place and a Rest Centre established at Chamberlayne Leisure Centre. Southampton Airport’s incoming flights were stopped for 2 hours. This procedure contrasted with the lack of realism and information for the public regarding the nuclear exercise, particularly in the immediate area around Ocean Village.
3.6. Police, SCC nor anyone else informed people evacuated from their homes about the on-going nuclear accident exercise. Withholding related information is anti-democratic and leads to distrust in future.
3.7. The role of the media as the primary public warning system is a vital element of the Plan, yet it was easily distracted by the contemporaneous event. The ITV network refused to cover the Exercise in favour of the evacuation and bomb topic. This element of the Plan cannot be relied upon.
3.8. The dilemma of how to balance the provision of public safety information with the risk of causing panic was not tested in the Exercise. An Exercise to examine this problem is necessary.
4. Exercise Failures
A list of observed failures are given in Appendix 1.
4.1. Despite a good deal of effort, the PITS distribution exercise was woefully inadequate. Naval ratings wearing SCC tabards “walked” the route of a small segment of Woolston to identify letterboxes where they would deliver PITS in the event of an accident. Addresses were checked against a list, but the real time taken to visit each household was not tested. Not all access (e.g. to flats above shops) was verified as the Safety Plan requires. As one emergency measure that is reasonably predictable in scope and detail, PITS distribution could and should have been realistically rehearsed. This part of the Exercise failed on the following grounds:
(i) the segment tested was too small from which to extrapolate
(ii) central area shops and businesses were not included
(iii) the time taken to deliver PITS was not tested
(iv) the number of residents at each address was not established
(v) flats above shops were missed
(vi) there was no interaction with the public
(vii) staff at health, police and community PITS distribution points were not involved
(viii) individual counter-indicators for this medication were not addressed
4.2. The exercise did not appear to involve any practical test of road traffic management, a crucial matter in any case of a real emergency.
4.3. Water traffic management likewise was given no practical test. In particular, the Hythe Ferry passengers and operators practised no emergency procedures, although they would be among the first civilians to be affected by an accident at the Z berth.
4.4. The Z berth itself was not secured, being open to unhindered public access throughout the exercise.
4.5. No police presence for the exercise was in evidence. Crowd control, fast passage for emergency vehicles, prohibition of entry to contaminated areas etc. was not observed.
4.6. No emergency personnel other than fire-fighters were observed to wear, carry or practise distribution of protective clothing or equipment.
4.7. Protection against environmental contamination did not appear to be tested. Although there are so many unknowns here, it could be expected that vehicles and personnel moving between contaminated and uncontaminated sites would have taken precautions not to spread irradiated particles in the Exercise. Removal of outer clothing and shoes on entering buildings would be one example of appropriate precautions that could have been tested.
4.8. The response to contaminated casualties involved only one patient presenting at the General Hospital in the Exercise. There is a danger of minimising the likelihood of people self-referring for radiation checks. It is not clear if the associated problem of contaminated ambulances being quarantined and therefore out of service was addressed. Details relating to the hospital capacity and long-term effects of coping with contaminated casualties are needed. This area of response was totally inadequate.
4.9. Concerns expressed at the public meeting by a Pre-School Playgroup Leader from Hythe made clear the failure of the Exercise to inform or engage with those with responsibility for children, the most vulnerable group at risk of thyroid cancer. Her questions about her responsibilities and the complete lack of information about PITS were an indictment of the lack of responsibility shown in this Exercise.
4.10. Advice to parents to leave their children and not collect them from school was not tested.
4.11. Management of the public taking shelter, while at the same time overseeing evacuation of public areas such as West Quay, was not practically tested. The juxtaposition of this Exercise with the discovery of a British military bomb on Weston Shore exposed this weakness. The contradictory warnings to the public are:
(i) Shelter: Go in, Stay in, Tune in
(ii) Evacuate: go outside from shops, businesses, public areas
People trying their best to carry out instructions would see and hear in the media of others being advised to take the opposite action. No account appears to have been taken of this confusion in the Exercise. In the event of an emergency this is likely to be among the most challenging tasks, for which advance practice would have been invaluable. Some would say, essential.
5.1. Southampton’s real and pressing security needs relate to matters such as climate change, risks from the Fawley oil refinery or terrorism. The unnecessary concentration on an avoidable risk is unacceptable.
5.2. A failure to test any of the Plan on the ground in the Hythe area was a mistake. Response in a rural community would encounter different problems from that of a town.
5.3. The public were mostly unaware of the exercise and were certainly given no opportunity to take part in it: publicity before and after the event was minimal. Even those with a key role in the Safety Plan (such as health workers at PITS distribution points) or those particularly vulnerable (Ocean Village residents, for example) were not alerted to the exercise on the day. Apart from questions of inadequacy in testing the Safety Plan, the persistent lack of openness undermines democracy.
5.4. The cost of the Exercise is estimated by SCC at £1million and is disproportionate to any gain.
5.5. The key issues that need to be tested or re-tested if a nuclear submarine is to have access to Southampton Docks are as follows:
(i) media cooperation
(ii) clarification of who and why different groups of the population should shelter or evacuate
(iii) time taken for actual PITS distribution
(iv) child care professionals at every level need to be consulted
(v) parents response to advice not to collect children from school
(vi) openness during the Exercise
(vii) human, environmental and financial evaluation of contamination
5.6. The shortcomings of the Exercise indicate that public protection was not really tested. Despite these failures and its lack of authority, the NII passed the Plan as ‘fit for purpose’. This is perhaps not surprising since the NII is paid for and trained by the Navy in relation to submarine safety. The request by SCANS for an independent expert observer was refused.
5.7. The undisclosed NII criteria must be set extremely low for the Plan to be designated ‘fit for purpose’ based on this limited Exercise. The unnecessary concentration on an avoidable risk is unacceptable.
SCANS recognised that SCC was required by the Radiation (Emergency Preparedness Public Information) Regulations (REPPIR) to undertake this Exercise, but it was a severely limited test. In the event of a nuclear release in Southampton, residents and businesses would find this plan woefully inadequate. The shortcomings of the Exercise indicate that sufficient public protection cannot be provided.
The NII assessment that the Plan is “fit for purpose” may meet naval requirements for a crew and its submarine, but it does not meet the needs of the public. Further, the MoD states its intention to use Southampton Docks for operational submarines. As the NII has no power to regulate operational boats, the value of the NII assessment is questionable. For this reason, it would be wise for the City Council to take independent advice and for the Navy to re-think its plans.
I SAFETY FAILURE
§ confusing and conflicting advice would have been given to the public in Weston, to both evacuate and shelter
§ no test involving a road accident during a nuclear release was observed
§ road users had no opportunity to take part in the exercise
§ Fire Service access to the Z Berth for 6 vehicles was held up for 10 minutes at dock gate 4 security checkpoint
§ no personnel were observed to wear or carry protective clothing or masks during the Exercise
§ no test of the ability to stop commercial, ferry or leisure activity on Southampton Water was observed
§ no test of the ability to ensure people took shelter was observed
§ the exercise was designed not to address the most likely scenario that radiation would spread beyond 2Km – up to 70Km according to the FSA
§ Naval personnel did not locate access to flats above Woolston shops or all doors as required
§ Naval personnel did not test how long it would take to deliver PITS
§ PITS distribution was unrealistic because the time given to simulate delivery was inadequate
§ The opportunity to test the time taken to deliver PITS should not have been missed
II CIVIL AND HUMAN RIGHTS FAILURE
§ secrecy surrounding the exercise undermines democracy
§ the public had no opportunity to take part in the exercise and were largely unaware of it
§ Health workers at PITS distribution points were unaware of the exercise
§ Ocean Village residents we spoke to had no knowledge of the exercise
§ Hythe police station, a PITS distribution point, was closed until 10.00am Station staff said they had no knowledge of the exercise or PITS
§ Hythe pier & ferry staff had no knowledge of the exercise
§ Ministry of Defence Police at Marchwood & Hythe military bases said they had no knowledge of the exercise
§ Woolston and Weston residents we spoke to had no knowledge of the exercise
III ENVIRONMENTAL FAILURE
§ only the response to immediate events was tested as the exercise was contained within the working day
§ the response to medium and long-term danger was not tested
§ no response to immediate environmental damage test was observed
§ response to devastating long-term environmental damage was not tested
§ the exercise was designed not to respond to actual weather conditions
IV SECURITY FAILURE
§ A police presence was not apparent, except at Weston in relation to a separate incident
§ the Z berth was not secured
V ECONOMIC FAILURE
§ the high cost of the exercise is disproportionate to the degree of safety and security achievable
VI LEGAL FAILURE
§ the exercise ignored international humanitarian & environmental law
that ensures that the precautionary principle prevails
SCANS Tel: +44 (0)380 554434 m: 07880 557035
e-mail: firstname.lastname@example.org web: www.nuclearinfo.org