Appendix C: Survey material pertinent to the conclusions of chapter 3
Letter to local authority emergency planners
Dear colleague,
Local Authority Emergency Planning and nuclear weapons
As you may know the Scottish Government recently set up a Working Group entitled Scotland Without Nuclear Weapons. I am part of a subgroup which is considering 'the adequacy of the current licensing and regulatory framework that exists in relation to HM Naval Base Clyde in relation to environmental, planning and transport issues'. For details of the full remit and the membership of the Working Group see the attached document.
We are keen to investigate the current situation regarding the transport of nuclear weapons through Scottish Local Authority areas. Your Authority is listed in the MoD's Local Authority and Emergency Services Information guidelines as one through which nuclear weapons convoys pass.
I would be very grateful if you could answer the following questions for us:
- how many nuclear weapons convoys have travelled through your local authority in, say, the last 5 years ? Have you had prior warning when convoys have passed through ? Would prior warning have helped you plan better for these transits ? Have there been any issues of concern for you during these transits ?
- when did you last participate or lead an exercise simulating an emergency with a nuclear weapons convoy ? Did this exercise raise any particular concerns for you ?
- is the legislative framework covering nuclear weapons convoys sufficiently clear ? If not, what areas need to be clarified ?
- How do you think that nuclear weapons transits are covered by the Radiation (Emergency Preparedness and Public Information) Regulations 2001 ( REPPIR) ? Do you have sufficient risk information on weapons accidents from the MoD to scope the relevance of these regulations ? What action have you taken under these regulations ?
- ho you think the LAESI guideline provide you with sufficient guidance on dealing with nuclear convoy emergencies ?
- do you think that you have been sufficiently involved in planning for nuclear weapons convoy emergencies ? Do you think that the threat of terrorism has been properly included in the current preparations ?
- we think the 'worst-case' emergency included in the LAESI guidelines is of a tanker fire engulfing a weapons transported and allowing a limited release of radio-activity but no nuclear explosion, do you concur ? Are you aware of any independent assessment of this risk ? Are you content that this is indeed the worst case that you should make plans for ?
We would be grateful to have comments on any other issues which you think might be relevant to the remit we are investigating and for any documentation which you think we might find of interest.
I would be grateful if you could respond to this request by mid-October, preferably in electronic format and returned to this e-mail address. Please indicate if you wish your submission to be in confidence or if you are happy for it to be published. All submissions will be made available to all members of the working group in due course.
Thank you very much for your help, I look forward to hearing from you.
Yours sincerely,
Dr Richard Dixon,
Director of WWF Scotland and member of the Working Group on Scotland with Nuclear Weapons
Scottish Government Working Group on a Scotland Without Nuclear Weapons
Remit
1. In the event of a decision to remove nuclear weapons from HM Naval Base Clyde, to examine the economic impact and to identify options for the development of alternative employment opportunities.
2. To explore the various international opinions that exist on the legality of nuclear weapons so far as relevant to matters within the devolved competence of the Scottish Government.
3. To explore the implications of seeking observer status at the Non-Proliferation Treaty Group and advise the Scottish Government on that process.
4. To consider the adequacy of the current licensing and regulatory framework that exists in relation to HM Naval Base Clyde in relation to environmental, planning and transport issues.
5. To identify good practice elsewhere in the world in developing peace and reconciliation and consider how Scotland might contribute to this work.
6. To report to Ministers with advice, within the context of their devolved responsibilities, on a regular basis.
Membership
http://www.scotland.gov.uk/Topics/People/swnw-working-group/membership
Survey of Local Authority Emergency Planning: collated results
Responses from 19 local authorities:
Angus Council
Argyll and Bute Council
Clackmannanshire Council
Dumfries and Galloway Council
Dundee City Council
East Ayrshire Council
Falkirk Council
Midlothian Council
North Ayrshire Council
Orkney Islands Council
Perth and Kinross Council
South Lanarkshire Council
Stirling Council
West Dunbartonshire Council
West Lothian Council
A single response from Grampian Emergency Response Unit covers Aberdeen City, Aberdeenshire and Moray Councils.
One authority not listed above responded but asked for its response to be considered in confidence. This response is included in the numbers quoted below but not in the quotations on the following pages.
Q1 Convoys: not one of them said they had any prior knowledge of nuclear convoys in their region
Q2 Training: seven said they had attended training sessions but not since 2005 or even earlier except Dumfries and Galloway which is regularly invited to attend sessions at Helensburgh led by MoD, and North Ayrshire at Hunterston
Q3 Legislative framework: only three said the legislation was clear for local authorities
Q4 Nuclear weapon transits and REPPIR legislation: disagreement as to what is included in REPPIR and what should be in the public domain and confusion about what the legislation says
Q5 LAESI guidelines provide sufficient guidance on dealing with nuclear convoy emergencies: seven thought it was sufficient
Q6 Sufficiently involved in planning for nuclear weapons convoy emergencies and has threat of terrorism been properly included in the current preparations: none of those who responded had ever been involved in the planning but considered the threat of terrorism to be a security issue and not an emergency planning one
Q7 Worst-case scenario and independent risk assessment of it: four agreed with the assessment of the worst-case scenario and five were unaware of any independent assessment of this risk.
Local Authority Emergency Planning and nuclear weapons
Q1: How many nuclear weapons convoys have travelled through your local authority in, say, the last 5 years? Have you had prior warning when convoys have passed through? Would prior warning have helped you plan better for these transits? Have there been any issues of concern for you during these transits? |
Argyll & Bute | - No notice given of any - MOD says info is secret!
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Midlothian | - Not aware of any; police will have this info if it exists
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W Dunbartonshire | - Never been informed of any convoys; however many have actually travelled to Coulport over the past 5 years. Only aware of one if there is a CND protest - a concern in itself
- Regulation 17 of the Radiation (Emergency Preparedness and Public Information) Regulations 2001 ( REPPIR) - useful to be informed or involved to allow timely implementation of those procedures should the need arise.
- Another concern is that LAESI indicates that "the immediate hazard area i.e. within the 600-metre evacuation cordon the major hazard is from the conventional effects of the accident, in particular from the potential for a conventional explosion and MoD would advise that this area should be evacuated in order to provide protection" The usual convoy route passes through an urbanized area which would mean that a significant number of people would require to be evacuated from this 600 metre cordon which would in turn cause problems authority in finding appropriate emergency accommodation for them.
- Requirement of LAs to maintain procedures under Reg 17 of REPPIR means it would be useful to be informed or involved to allow timely implementation of those procedures should need arise
|
Stirling | - No info received on convoys from MOD or police
- Our response to any incident would be via our generic major emergency management procedures and therefore prior warning would not assist planning however it would allow us to put certain aspects of our response 'on standby'. I have no issues of concern.
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N Ayrshire | - Not informed - but wouldn't be concerned if there were
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Clacks | - No such convoys; could be a possible diversionary route in the event of problems on the main convoy routes
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E Ayrshire | - Very few if any dealings with convoys in 12 yrs
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Falkirk | - No significant issues of note or concern
- Over the years, there have been no significant issues of note or concern arising from such practice. Falkirk Council is fully aware of the " Local Authority and Emergency Services Information " arrangements and has confidence in our partners within the Central Scotland Strategic Coordinating Group and our individual and collective emergency planning arrangements.
|
Grampian EPU | - Not aware of any; not been informed; no involvement in any exercises nor looked closely at the legislative framework
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Perth & Kinross | |
S Lanarkshire | - We are unable to answer this question as we have no information in relation to nuclear convoys passing through the council area and have had no incidents or issues that have given us cause for concern
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Orkney Islands | - No convoys ever come through the islands and no knowledge of submarines passing through
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Angus | - I have no idea if any convoys have passed through - I'm sure that police colleagues would have this info - but I guess it identifies a gap as I have no knowledge either way if in fact any convoys have passed through
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West Lothian | - LAs not advised of convoys passing through their area
- Prior warning - good to know but wouldn't have considered that the level of risk required any special arrangements to be put in place
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Dumfries and Galloway | - This is not something that the Local Authority is concerned with - security for nuclear convoy is the remit of central government (reserved to Westminster) and the security forces - it is a matter of national security. If an incident occurred and if we were requested to support the response we would employ generic emergency response - this response would be informed by the LAESI guidelines. Our arrangements are generic - we would deal with consequences (with advice from a Scientific and Technical Advice Cell) and not the causation.
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Dundee | - I have been in post for almost 3 years and have had no involvement with nuclear weapons in transit through Dundee
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Q2: When did you last participate or lead an exercise simulating an emergency with a nuclear weapons convoy? Did this exercise raise any particular concerns for you? |
Argyll & Bute | - Never participated - assume such things organised by MOD
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Midlothian | - Not participated during last 5 yrs
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W Dunbartonshire | - The CPO last participated in a nuclear weapon convoy exercise as part of a course attended at RAF Brampton in February 1999
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Stirling | - The last exercise I participated in was four years ago at Faslane / Coulport. I have been involved in other events related to nuclear issues though not specifically a weapons convoy.
- I was reassured concerning the safety of the convoys and concerning the support available in the unlikely event that an accident should occur
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N Ayrshire | - Hunterston Nuclear Power Station & Decommissioning Site is in N Ayrshire and robust plans are in place with regular training being carried out to deal with any nuclear accident.
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S Lanarkshire | - We last participated in an event focusing on nuclear weapon convoys in the late 1990s, I am unable to provide the exact date/year
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Angus | - I have never been involved
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West Lothian | - 2004 and a number of MoD awareness sessions
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Dumfries and Galloway | - There are "live" exercises led by MoD at Helensburgh and we have been invited fairly regularly. The last exercise I attended was not a cause for concern.
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| No comment from Clacks, E Ayrshire, Falkirk, Grampian EPU, Perth & Kinross, Dundee |
Q3: Is the legislative framework covering nuclear weapons convoys sufficiently clear? If not, what areas need to be clarified |
Argyll & Bute | - It's clear for other agencies, but I don't see anything for the local authority in there; should it show what our roles and responsibilities would be in a convoy incident?
- What are my responsibilities as an EPO for the Council in such an incident?
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Midlothian | - Legislative framework seems clear
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W Dunbartonshire | - Apart from REPPIR (17) and LAESI, unaware of other appropriate information or legislation regarding weapons convoys so cannot comment.
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Stirling | - I think that the legislative framework is adequate and the roles and responsibilities are clear.
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S Lanarkshire | - I am unable to answer this question as I am unfamiliar with the legislative framework - unless this refers to REPPIR
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Angus | - This is not an area I am familiar with - so an update and or guidance would be helpful
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West Lothian | - Not clear what is the relevant legislation
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Dumfries and Galloway | - The LAESI guidance is clear and informs our planning assumptions / generic planning
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| No comment from N Ayrshire, Clacks, E Ayrshire, Falkirk, Grampian EPU, Perth & Kinross, Dundee |
Q4: How do you think that nuclear weapons transits are covered by the Radiation (Emergency Preparedness and Public Information) Regulations 2001 ( REPPIR)? Do you have sufficient risk information on weapons accidents from the MoD to scope the relevance of these regulations? What action have you taken under these regulations? |
Argyll & Bute | - To my knowledge, I don't think they are, sorry I don't have the time to read through the whole REPPIR Reg to look for a part on convoys. I understood that it was only the LAESI doc that covered this.
- I have no risk information from the MOD, other than what is in the LAESI doc and what was taught at the course many years ago.
- No action taken
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Midlothian | - REPPIR would appear to have been adequate to date. Community Risk Register has assessed the risk.
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W Dunbartonshire | - REPPIR Regulation 17 applies to ALL local authorities irrespective of the rest of REPPIR, and it relates to general duties on local authorities to have arrangements in place to provide information to the public with regard to any kind of radiation emergency (including those involving nuclear weapon convoys).
- Information on the risk of a contamination incident resulting from a convoy is contained within the REPPIR (17) draft procedures which the Authority has produced to ensure that senior officers can determine whether members of the public would benefit from taking protective measures following an incident resulting in contamination
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Stirling | - Nuclear weapons transits are not covered at all well by the REPPIR regs. There is an implication that road transport is not included in the regs.
- We do not have any risk information from the MOD other than that contained within the Community Risk Register which does not give much detail.
- Stirling has arrangements to provide information to the public should a radiation emergency arise.( These are generic arrangements under CCA not specific to nuclear incidents)
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S Lanarkshire | - As nuclear convoys are not fixed nuclear sites - and on the basis that we have no information on when or where nuclear convoys may pass through the council area - we have no specific risk assessments or plans for responding to an incident involving a nuclear convoy.
- Our generic emergency procedures would be utilised in the first instance. However, an incident of this type would immediately be classified as a national emergency and appropriate national contingency arrangements and co-ordination implemented. That being the case, we are clear on our role and responsibilities as a local authority and would respond accordingly.
- A nuclear convoy accident is not included in the national risk assessment (see Scottish Local Risk Assessment Guidance March 2008), and as such is not included in our local area risk register.
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Angus | |
West Lothian | - Not as far as I know
- N/A
- No action taken under these regulations
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Dumfries and Galloway | - In D&G we have to comply with REPPIR in for the fixed nuclear installation at Chapelcross. In general the information contained in LAESI is as adequate as the information that we would put in the public domain in relation to a nuclear power station. Again there are national security issues associated with the transportation of nuclear weapons - even if we knew about these we'd need to seek advice before putting these movements into the public domain - perhaps on the advice of the FoI commissioner
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| No comment from N Ayrshire, Clacks, E Ayrshire, Falkirk, Grampian EPU, Perth & Kinross, Dundee |
Q5: Do you think the LAESI guidelines provide you with sufficient guidance on dealing with nuclear convoy emergencies? |
Argyll & Bute | - There seems to be no guidance for local authorities.
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Midlothian | - LAESI guideline has been sufficient to date
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W Dunbartonshire | - Information contained in the LAESI document is sufficient for local authority purposes and is used to inform the risk assessments carried out for the Community Risk Register
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Stirling | - I think that the LAESI guidelines do provide sufficient guidance in a very clear and concise manner
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S Lanarkshire | |
Angus | - Not an area I am familiar with
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West Lothian | |
Dumfries and Galloway | - For the purposes of local Authorities - yes
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| No comment from N Ayrshire, Clacks, E Ayrshire, Falkirk, Grampian EPU, Perth & Kinross, Dundee |
Q6: Do you think that you have been sufficiently involved in planning for nuclear weapons convoy emergencies? Do you think that the threat of terrorism has been properly included in the current preparations? |
Argyll & Bute | - No
- Don't know, what are the current preparations for the threat of terrorism?
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Midlothian | - The level of our involvement is in direct correlation to the number of convoys that we have been made aware of.
- We are not party to the preparations for dealing with a terrorist threat.
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W Dunbartonshire | - This LA never has been involved in planning for convoy emergencies and cannot therefore comment if the threat of terrorism has been included.
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Stirling | - I have not been involved at all in any planning for nuclear weapons convoy emergencies however as I stated at point 2, I was reassured concerning the safety of the convoys and concerning the support available in the unlikely event that an accident should occur. The response arrangements from the MOD are I believe fit for purpose and our generic emergency response plan will dovetail with the MOD response.
- I have no knowledge as to the inclusion of the threat of terrorism in MOD preparations however I would imagine that convoys represent a 'soft target' and this should be part of preparations.
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S Lanarkshire | - We have never been involved in planning for nuclear convoy emergencies - however as stated before, we are clear on our role and responsibilities as a local authority and as a category one responder and our Contingency Planning Team are sufficiently knowledgeable in the subject area to be able to advise / guide any council response required.
- In relation to the issue of terrorism, our only comment is that one of the principles of emergency planning is that the response should focus on the effects and not the cause. In that respect the threat of terrorism in relation to nuclear convoys is not a factor for emergency planning/response but rather a factor in relation to the security of such convoys.
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Angus | |
West Lothian | - I wouldn't expect to be consulted as this is undertaken by MoD
- Unable to comment on preparations for threat of terrorism
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Dumfries and Galloway | - This is not something that the Local Authority is concerned with - security for nuclear convoy is the remit of central government (reserved to Westminster) and the security forces - it is a matter of national security
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| No comment from N Ayrshire, Clacks, E Ayrshire, Falkirk, Grampian EPU, Perth & Kinross, Dundee |
Q7: We think the 'worst-case' emergency included in the LAESI guidelines is of a tanker fire engulfing a weapons transported and allowing a limited release of radio-activity but no nuclear explosion, do you concur? Are you aware of any independent assessment of this risk? Are you content that this is indeed the worst case that you should make plans for? | |
Argyll & Bute | - Don't know enough to comment on this "worst-case emergency
- Not aware of any independent assessment of this risk
- I'm not making plans for any of this, should I be? Isn't it the MOD which has the plans. I think I would just be advised by the MOD
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Midlothian | - We have been led to believe that this is the worst case scenario and have no evidence to the contrary. If you are indicating that this is not the case I am sure that our risk assessment in the CRR would need to reflect an evidenced based increase in risk.
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W Dunbartonshire | - Would agree with the 'worst case' scenario proposed.
- A Community Risk Register is maintained by Strathclyde Emergency Co-ordinating Group.
- Any plans would reflect the requirements of IEM and the response would be to the effects of an incident rather than the cause and while it would pay heed to a worst case scenario, it would not rely upon it to dictate the level or type of response
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Stirling | - I agree with your assessment of the worst case scenario
- I am not aware of any independent assessment of this risk
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Angus | - Not aware of any assessment of this risk - additional consideration should be given to relevant SCG s in this regard
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West Lothian | - Yes
- No
- Yes, as far as I know
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Dumfries and Galloway | - See above: This is not something that the Local Authority is concerned with - security for nuclear convoy is the remit of central government (reserved to Westminster) and the security forces - it is a matter of national security
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| No comment from N Ayrshire, Clacks, E Ayrshire, Falkirk, Grampian EPU, Perth & Kinross, Dundee |
Other comments:
Angus: For those LA who do not have as much input to this specialist area - it would be helpful to be kept up to date in the event circumstances changing and for mutual aid purposes.
Dumfries and Galloway: It seems to me that you are asking the questions of the wrong organisation. The duty for local authorities is to have generic response plans in place to deal with the effects of an emergency and not the causes. We are not part of the security forces and would not expect to be informed about issues which would relate to national security. In addition other than in the very generic planning arena and potentially from the environmental health position I would not expect Local Authorities to be consulted on issues relating to nuclear or radiological matters.