ENVIRONMENTAL PROTECTION (Non Radiological)

DML has an Environmental Management System (EMS) as part of the company's overall Business Management System. This continues to be developed in line with the international standard ISO 14001 and is in the process of review to reflect recent changes in this standard. It enables the company to evaluate the environmental risks associated with its work in a structured way. This includes:

A training programme for managers in environmental risk assessment was initiated and a number of written assessments completed. This programme will continue to be developed during 2006 with more training undertaken and a bank of assessments built up. This will help guide the Company in its endeavours to minimise negative environmental impact.

New Developments

As a result of changes to legislation, a new Permit was issued by the EA to cover the activities carried out in DML's cleaning bays. As is normal with such Permits, an improvement schedule was included. All of the requirements of this schedule were completed to the required timetable.

Also as a result of legislative change, work began to enable the transfer to a new-style EA Permit from the old EA Authorisation for our boilerhouse activities. This process will be completed by the end of March 2006.

No Tri Butyl Tin Oxide (TBTO) antifouling paints were used in 2005; neither were any existing TBTO coatings removed from vessels in refit. It is still DML's intention to surrender its Authorisation to carry out this work as soon as the remaining RN vessels with TBTO coatings either have these coatings removed or are disposed of.

A programme has been established for 2006 through which managers will be trained to undertake environmental audits. This resource will be used to review and assess all processes that have a significant potential to damage the environment and ensure that appropriate controls are in place to prevent environmental harm. This reinforces DML's commitment to preserve and protect the sensitive ecology in which it operates.

Environmental Monitoring

DML holds two Process Authorisations issued by the Environment Agency under the Integrated Pollution Control (IPC) Regime, and one Permit under the newer Integrated Pollution Prevention and Control (IPPC) Regulations. Routine environmental monitoring of each of the processes concerned is carried out to ensure compliance with the Authorisation/Permit conditions. In 2005 DML continued to comply with all the targets set in these Authorisations/Permit. Details are given below - see 'Environment Agency Authorisations, Permits & Licences'

Unplanned Events

There was only one complaint/enquiry on environmental matters received from the local community during 2005. This involved noise overnight; the source was traced to an RFA vessel moored in the Hamoaze. The Ministry of Defence was informed and the problem resolved.

There were three instances of significant quantities of oil release to the Hamoaze reported during 2005. None of these were found to be attributable to DML controlled activities. One of these, however, resulted in the identification of shortfalls in the clean-up and storage of waste oil on 1 Wharf. These shortfalls have since been rectified to the satisfaction of the Environment Agency.

Environment Agency Authorisations & Licences

The Environmental Protection (Prescribed Processes and Substances) Regulations 1991 specify the processes that are considered to be potentially the most polluting. Such processes require an Authorisation issued by the Environment Agency (EA) before they can be carried out.

DML operates three such processes:

Each Authorisation/Permit specifies materials/chemicals, releases of which must be measured each year and declared to the EA.

The table below shows the permitted and actual releases of the most significant of these substances over the last 3 years.

It should be noted that whilst all of the releases are within the permitted levels, those from the boilerhouses are within by a significant margin. This is because:

DML also hold 4 licences permitting the abstraction of water from the Hamoaze for use in fire mains, for cooling purposes etc. During 2005:

All water abstracted is returned to the Hamoaze in an uncontaminated state.

Other Initiatives

In addition to the various environmental protection measures required of DML by legislation and 'good practice' the company is keen to implement other initiatives that protect the environment or promote its protection.

Recent examples are:

· energy usage reduction schemes
· improved disposal arrangements for batteries
· paper recycling
· cardboard recycling
· wood recycling
· new initiatives for the recycling of soft drink cans and bottles
· training of staff in environmental protection