NSubF Briefing for the Storage Site Consultation

The Ministry of Defence Submarine Dismantling Project – what it means for you

The Ministry of Defence (MoD) is currently seeking public opinions on selection of a site for the storage of radioactive waste from decommissioned nuclear powered submarines. Five sites have been shortlisted as ‘interim storage sites’ for the waste. This briefing gives further information about the proposals and tells you how you can have your say.

The Ministry of Defence submarine dismantling project will oversee the disposal of 27 Royal Navy nuclear powered submarines that will have left service by the mid 2030s. This includes 19 submarines that have already left service and are stored afloat at Rosyth and Devonport naval dockyards awaiting disposal. The highly radioactive spent reactor fuel will be removed from the submarines and stored separately at Sellafield. Other radioactively contaminated components from the submarine reactors, principally the reactor pressure vessels which surround the nuclear core and its cooling system, will be removed from the submarines at Rosyth and Devonport dockyards. The submarines will then be broken up at the dockyards and the uncontaminated parts recovered and recycled as scrap metal.

Radioactively contaminated components of the decommissioned submarines will need to be placed into interim storage while the government designs and builds a national waste repository to handle the nation’s radioactive waste. This is expected to be for a period of around 40 – 60 years. The waste requiring interim storage – principally the intact reactor pressure vessel – will be categorised as intermediate level radioactive waste.

The five shortlisted sites selected as possible interim storage sites for radioactive waste from submarines are:

• The Nuclear Decommissioning Authority site at Sellafield, Cumbria

• The Nuclear Decommissioning Authority site at Chapelcross, Dumfriesshire

• The Ministry of Defence site at the Atomic Weapons Establishment, Aldermaston

• The Ministry of Defence site at the Atomic Weapons Establishment, Burghfield

• The Capenhurst Nuclear Services site at Capenhurst, Cheshire

A first submarine will be dismantled as a pilot ‘demonstration’ at Rosyth and on current schedules this is expected to be completed by around 2019. Assuming the demonstration goes to plan, submarines will be dismantled at a rate of roughly one per year. MoD has promised that no radioactive waste will be removed from submarines until an interim storage site has been agreed and all the necessary planning approvals and permits have been issued.

Once an interim storage site has been selected, the Office for Nuclear Regulation and the Environment Agency will be the main government regulatory agencies responsible for approving the dismantling and waste storage arrangements. Normal local authority planning procedures would apply for construction of the storage facility. MoD will have to submit a planning application to the local planning authority, which would consult locally and provide an opportunity for people to object or recommend conditions before making a decision on whether to accept the application.

Once all the necessary permissions have been received, each reactor pressure vessel will be removed intact from a submarine and placed in a specially made protective storage container about the size of a portacabin. The container will then be transported by road to the interim storage site, where it will be stored and monitored in a newly built secure storage facility.

MoD is now consulting widely to gather views on the shortlisted sites and the process and criteria which will be used to compare the sites and make a final choice of storage site for the waste. Local residents in the vicinity of the shortlisted sites are entitled – and encouraged – to give their views on the proposals.

What is intermediate level radioactive waste?

Intermediate level radioactive waste (ILW) from submarine reactors is material which has been in close proximity to the highly enriched uranium fuel which powers the reactor. As well as generating energy, the fuel also generates radioactive ‘fission products’ which are absorbed by the surrounding materials. Once the spent fuel has been removed from the reactor, these materials will require disposal as ILW. Unlike spent reactor fuel, ILW does not generate heat but it contains many of the radioactive elements found in higher activity wastes and its radioactive content is such that shielding is necessary to protect people from the radiation it produces. The radionuclides in ILW from nuclear reactors are long-lived, and therefore the waste must be kept isolated over a long period to protect humans and the environment from its impacts. The government plans to build a geological repository deep underground to hold the UK’s high and intermediate level radioactive wastes, but as yet plans for the repository are at an early stage and it will not open until 2040 at the earliest. Until then, waste from nuclear reactors, including submarine reactors, must be held in interim storage at secure sites.

How to have your say

Detailed documents outlining the MoD proposals, together with details of consultation arrangements and events are on the Ministry of Defence website here . The Ministry of Defence is organising a series of exhibitions and workshops locally to consult people about its proposals, provide information, and take feedback on the following dates:

Aldermaston Monday 17 November 2014: AWE Recreational Society, West Gate, AWE Aldermaston Saturday 22 November 2014 and 23 January 2015: Tadley Community Centre, Newchurch Road, Tadley

Burghfield Tuesday 18 November: Burghfield Common Village Hall Thursday 20 November 2014 and Thursday 22 January 2015: Community Sports Association, James Lane, Burghfield

Capenhurst Tuesday 9 December 2014, Wednesday 10 December 2014, and Tuesday 20 January 2015: Macdonald Craxton Wood Hotel Thursday 11 December 2014: Capenhurst Village Hall

Chapelcross Friday 28 November 2014, Saturday 29 November 2014, and Thursday 16 January 2014: Victoria Halls Complex, Annan

Sellafield Wednesday 17 December 2014 and Wednesday 28 January 2015: Civic Hall and Masonic Centre, Cleator Moor Thursday 18 December 2014 and Tuesday 27 January 2015: The Beacon Museum, Whitehaven

National events:

Tuesday 6 January 2015: International Convention Centre, Birmingham

Thursday 8 January 2015: Scottish Exhibition and Conference Centre, Glasgow

Pre-booking is required for attendance at workshops. To arrange this, and for more information about consultation events, please call 0118 983 9474 or email sdp@instinctif.com

Public consultation will begin on 14 November 2014 and end on 20 February 2015. You can send your views to: DESSMIS-SDP@mod.uk or Submarine Dismantling Project, Mail Point 4119, MOD Abbey Wood, Bristol, BS34 8JH.

Some questions to ask

• Would storage of radioactive waste from submarines result in an increase in the area of the nuclear licensed site at candidate sites?

• What level of disruption and inconvenience would take place when radioactive waste from submarines is transported to the storage site, and how often would this take place?

• What will happen to waste from submarines that the Royal Navy plans to build in future which are not included under the terms of the submarine dismantling programme? Will it also be stored at the same interim storage site?

• Under current plans, when is it expected that radioactive waste from nuclear powered submarines will be moved from the interim storage site to a permanent resting place in a national radioactive waste repository? How great is the risk that the interim storage site will by default become a permanent storage site if the national repository is not built?

• What will be the total volume of the waste required to be stored, what will be the total radioactive content of the waste, and how long will it remain active?

• What risks has MoD identified identified as resulting from the interim storage proposals, and what steps will be taken to mitigate these risks?

What we think

The Nuclear Submarine Forum supports the MoD submarine dismantling project and considers it right that MoD are acting now to deal with the legacy of radioactive waste from nuclear-powered submarines. The issue cannot be ignored and will not go away, and it is our responsibility to deal with the problem, however unwelcome it is.

We are pleased that MoD is seeking the views of the public before making a decision on an interim storage site for radioactive waste from decommissioned nuclear powered submarines.

Ultimately the decision on an interim storage site for radioactive waste from submarines should be made on technical grounds, at the site where safety and security are shown to be greatest and environmental impacts lowest.

There should be no overall increase in risk to the public at the interim storage site as a result of radioactive waste from submarines. As far as possible, measures should be taken to reduce the risks from other operations commensurately, and / or accelerate decommissioning work on the site.

A decision to store radioactive waste from submarines for an interim period a particular site does not mean that the site can automatically be used a storage site for other radioactive wastes from other sources, and MoD and the site operator must give specific guarantees on this point.

Although government policy for the long term management of higher level radioactive wastes is to place them underground in a geological repository, this policy is not based around proven technology and we are not yet convinced that it is the best option. Questions remain about the feasibility of an underground repository and there is a risk that interim storage arrangements for radioactive waste will be extended indefinitely.

There must be effective arrangements for monitoring the impacts of radioactive wastes stored at the selected site, including opportunities for oversight and scrutiny by local communities. Current arrangements at some of the shortlisted sites are not adequate and openness and transparency must be dramatically improved before any decision is made to store wastes from submarines at them.

Radioactive wastes from submarines are an unwelcome legacy resulting from unwise decisions made in the past. We have not yet identified a method for managing these wastes and under such circumstances it is irresponsible to continue producing them. MoD should not construct any more nuclear-powered submarines until this issue has been resolved.

Who we are

The Nuclear Submarine Forum (NSubF) is a network of 16 independent local groups from all parts of the United Kingdom with an interest in the Ministry of Defence’s nuclear powered submarine programme. Representatives of the Forum sit on the Advisory Group for the MoD’s Submarine Dismantling Project. NSubF wants to inform people about the Submarine Dismantling Project consultation to encourage members of the public to comment on the MoD proposals and also make clear that the human and environmental costs of the Navy’s nuclear powered submarine programme, which result in the need to dismantle submarines and generate radioactive waste, are unacceptable.

Nuclear Submarine Forum


Consultation on ILW Storage sites announced

The MOD has confirmed the shortlist of sites for storage of ILW from RN nuclear submarines. The five sites are: the Atomic Weapons Establishment sites at Aldermaston and Burghfield in Berkshire, both owned by the MOD and run by AWE Plc; Sellafield in Cumbria and Chapelcross in Dumfriesshire, both owned by the NDA and Capenhurst in Cheshire, run by Capenhurst Nuclear Services.
The MOD completed a period of pre-engagement with local authorities, elected representatives and established site stakeholder groups around each of the shortlisted sites. This provided these groups with an early opportunity to understand and comment on the criteria that should be considered during the main assessment of shortlisted sites. It is also helping to shape plans for the formal public consultation that will be carried out before any decisions are made.
The assessment process considers:
1. Whole life costs for each site.
2. Operational effectiveness of the site.
3. A Strategic Environmental Assessment (SEA).
4. The project schedule proposed by the site owner.
5. Other contributory factors such as anticipated public opinion, policy and planning
in each area.
The MOD’s analysis has not presented any grounds for discounting any of the sites at this stage. This final shortlist will be taken forward as the basis for detailed assessment including public consultation, which will be carried out locally around each
candidate site, as well as nationally.
The public consultation, which will seek views on the shortlisted sites and consult on the SEA Environment Report, will begin on 14th November 2014 and end on 20th February 2015. This will take the form of public meetings and engagement alongside a wealth of information being put into the public domain to aid stakeholder’s understanding of the
Venues for SDP Public Consultation exhibitions
Aldermaston: 17 November:  AWE Recreational Society, West Gate, Plantation Road, Aldermaston RG7 4PR.
22 November; 23 January:  Tadley Community Centre, Newchurch Road, Tadley RG26 4HN.
Internal workforce briefing: 31 October 2014
Burghfield:  18th November:  Village Hall, Recreation Road, Burghfield Common, Reading RG7 3EN
20th November; 22nd January:  Community Sports Association, James Lane, Burghfield, Reading RG30 3RS.
Internal workforce briefing: 30 October 2014
Chapelcross:  28 & 29 November 2014; 16 January 2015 (note change): Victoria Halls Complex, Downie’s Wynd, Annan DG12 6EE.
Capenhurst: 9 and 10 December; 20 January:  Macdonald Craxton Wood Hotel, Parkgate Road, Ledsham, Chester CH66 9PB. 11 December: The Village Hall, Capenhurst Lane, Capenhurst, Chester CH1 6HE.
Internal workforce briefings: 2 & 3 December 2014
Sellafield: 17 December; 28 January:  Cleator Moor Civic Hall and Masonic Centre, The Square, Cleator Moor CA25 5AU. 18 December; 27 January: The Beacon Museum, West Strand, Whitehaven CA28 7LY.
National Events
Birmingham:  6 January 2015: The ICC Birmingham, Broad Street, Birmingham B1 2EA.
Glasgow:  8 January 2015: Scottish Exhibition and Conference Centre, Exhibition Way, Glasgow G3 8YW.

Submarine Waste Storage Sites – Shortlist announced

The MOD has published the provisional shortlist of sites for the interim storage of Intermediate Level radioactive Waste that will be removed from the 27 nuclear powered submarines that have left service with the Royal Navy or are due to, including those in afloat storage at Devonport and Rosyth dockyards.

They are:
  • Atomic Weapons Establishment Aldermaston in Berkshire owned by MOD, run by AWE plc
  • Atomic Weapons Establishment Burghfield in Berkshire owned by MOD, run by AWE plc
  • Sellafield in west Cumbria, owned by the Nuclear Decommissioning Authority
  • Chapelcross in Dumfriesshire, owned by the Nuclear Decommissioning Authority
  • Capenhurst in Cheshire, which is run by Capenhurst Nuclear Services
The MOD will now enter a period of pre-engagement with local authorities,  elected representatives and established site stakeholder groups.  This will provide an early opportunity to understand and comment on the criteria that should be considered during the main assessment of shortlisted sites.  It will also help to shape the formal public consultation that will be carried out before any decisions are made.
Following this period of pre-engagement a final shortlist of sites will be published in summer 2014. These will then be taken forward as the basis for public consultation, which will be carried out locally, around each candidate site, and nationally.  The MOD’s plan is for the public consultation to begin towards the end of this year and end early next year.
Further information on SDP and a copy of the proposed Criteria and Screening Report, which contains the provisional shortlist, can be found  here
The webpage also contains a copy of the Strategic Environmental Assessment (SEA) Scoping Report, which sets out the scope and level of detail of the information to be  included in the SDP’s SEA update.

Any stakeholder groups who want to be involved in the pre engagement process (25th March and 9th April) can contact:

Instinctif Partners,
4th Floor, Dukesbridge Chambers,
1 Duke Street,
Tel: 0118 983 9455
Email: Harry.Hudson(at)instinctif.com

AWE among possible nuclear submarine waste dump sites 18 Nov 2013

AWE Aldermaston and Burghfield could be among the locations the Government is casting its eye over as possible sites for waste from the nuclear submarine dismantling project.

The issue came to light at a recent meeting of the full Tadley Town Council, at which AWE local liaison committee member Mike Broad (Ind, Tadley East) said that at a recent meeting held at AWE

Burghfield, it was reiterated that the MoD was still investigating which one of a multitude of its licensed nuclear sites could be used to store nuclear waste.

read more

Office of Nuclear Regulation Consultation on Rosyth Submarine Dismantling

An application and accompanying Environmental Statement, seeking consent to undertake initial dismantling of the seven laid-up submarines at Rosyth Dockyard, has now been submitted to the Office of Nuclear Regulation (ONR) by Babcock Marine and Technology, Rosyth.  The document can be viewed on ONR’s website here
The Office of Nuclear Regulation (ONR) are one of the regulators for the Submarine Dismantling Project.

Interim Store Site Selection Update

It is anticipated that there will be a ministerial announcement of the short-list of five potential storage sites in mid February.
Two national pre-engagement workshops are planned towards the end of March at the earliest, for stakeholders of the five short-listed sites, to agree the criteria needed for the public consultation .
Following this a full public consultation will be carried out at both local and national levels.

Ministers decide on submarine dismantling: Rosyth and Devonport selected as dismantling sites.

Ministers have made the ‘Main Gate’ decision on the next steps to be taken in the Ministry of Defence (MoD) programme for addressing the legacy of the Royal Navy’s fleet of redundant nuclear powered submarines, announcing that submarine dismantling will take place at the Rosyth and Devonport naval dockyards and outlining the approach which will be used to select an interim storage site for radioactive waste from the submarines.

In its response to last year’s submarine dismantling consultation programme (online at http://bit.ly/WPqS5c), MoD has said that, as the first step in the dismantling programme, one of the ageing submarines currently in storage at Rosyth dockyard will be dismantled as a ‘demonstration’ pilot – although this work will not commence for several years yet.  During the demonstration the reactor pressure vessel from the submarine – the largest radioactively contaminated component in the reactor compartment – will be removed and stored whole. 

MoD has agreed to undertake further consultation in 2014 on selection of a site for storage of intermediate level radioactive waste generated from the submarine dismantling process.  On the basis of the results from public consultation, alongside recent legal advice, all existing nuclear sites in the UK, including those owned by MoD, the Nuclear Decommissioning Authority, and industry, will be considered as candidate locations for storage of the waste.  The government eventually intends to place waste from submarines in an underground radioactive waste repository alongside civil stocks of radioactive waste.

If the Rosyth demonstration is successful, MoD will then undertake dismantling of all remaining out-of-service submarines at both Rosyth and Devonport dockyards.  The Ministry has promised that no intermediate level radioactive waste will be removed from the submarines – including the demonstration pilot – until a solution and location for its storage has been agreed.

The Navy will eventually have to manage waste from 27 submarines which have been in service since HMS Dreadnought, the UK’s first nuclear powered submarine entered service in 1963.  Seven redundant submarines are currently in store afloat at Rosyth dockyard, with 11 more at Devonport dockyard and the remainder still in service.  Commissioning of new Astute and ‘Successor’ class submarines would add to this total although they are not included in this project.

Consultation on options for dismantling the submarines took place over the winter of 2012-3, with more than 1,200 people attending consultation events and over 400 written responses received in response to MoD proposals on how and where radioactive waste should be removed from redundant submarines, the type of site which might be suitable for storage of the waste, and environmental impacts resulting from the process.  According to Philip Dunne, Minister of State for Defence Equipment, Support, and Technology, comments received in response to the consultation “provided valuable input to the MoD’s options analysis, which has changed and matured significantly as a result”. 

Jane Tallents of the Nuclear Submarine Forum said:   “The Ministry of Defence’s submarine dismantling project is slowly moving in the right direction, but there is still much to do before we are in a position to deal safely with the radioactive legacy of the Navy’s nuclear submarines.

“Communities and local councils close to the Rosyth and Devonport have said loudly and clearly that the dockyards are not suitable sites for the storage of radioactive waste from submarine dismantling.  We will be watching MoD closely to ensure they stick to their promise that no radioactive waste will be removed from submarines until a storage solution has been agreed.

We are having to deal with this problem as a result of unwise decisions made in the past, yet the government seems intent on repeating these mistakes by pressing ahead to build new nuclear powered submarines without having a clear idea how or where radioactive wastes from these submarines will be managed in he long term.

The next steps in the submarine dismantling programme, especially selection of sites for storage of the radioactive waste generated by dismantling, must be taken with the full understanding and consent of communities which will be affected.  MoD must be open and transparent about its plans and must consult fully at every stage.

The Nuclear Submarine Forum will continue to represent voices of communities affected by the submarine dismantling programme and will insist that the Ministry of Defence takes an ethical approach to dealing with this unwelcome legacy.

For more information please contact Jane Tallents of the Nuclear Submarine Forum on tp2000 [at] gn.apc.org

Notes for editors:

1.    The Nuclear Submarine Forum is a network of 16 local groups from all parts of the United Kingdom, which are stakeholders in the Ministry of Defence’s nuclear powered submarine programme.  Representatives of the Forum sit on the Advisory Group for the Ministry of Defence’s Submarine Dismantling Project.  For more information please see http://www.nuclearsubwaste.net/

2.    More information about the Submarine Dismantling Project, the consultation process, and the options chosen by Ministers can be found on the Ministry of Defence website at: https://www.gov.uk/government/consultations/consultation-on-the-submarine-dismantling-project

End Refuelling. Letter from NSubF to Plymouth Herald Feb 8 2012

End refuelling

TO CLARIFY my quote in the report on the Submarine Dismantling Project (The Herald, January 26), I think the issue of defuelling submarines in the Dockyard should be included in the Public Consultation.

Six of the 10 boats awaiting dismantling still have spent fuel in their reactors. In my view, this effectively means that Plymouth is hosting a Ministry of Defence authorised but unlicensed High Level Radioactive Waste store in the centre of the city. Currently, people have no say about the defuelling process.

To get spent fuel out of Plymouth as quickly and as safely as possible, there are two options. Either it is removed from decommissioned submarines and taken to the purpose-built store at Sellafield, as soon as the new crane to lift it is approved, (delayed now until 2014). Or people lobby for a new defuelling facility to be built elsewhere, but which might take many years to complete, even if somewhere is found to take it.

Crucially, I believe defuelling should not be done under a cloak of secrecy. The dates of the operation should be announced, local schoolchildren taken on day trips, and adults offered the chance to evacuate the area.

This would leave the emergency services available to attend to the needs of vulnerable people in the event of an accident, when people would have to take shelter and take potassium iodate tablets in a bid to to prevent thyroid cancer.

Compared to defuelling, dismantling a submarine reactor compartment is many categories of risk lower, as is hosting a SDP waste store. If the MoD wants Plymouth to carry the dismantling burden, it should pay for it by abandoning high-risk operations.

The key to this is an end to refuelling and perpetuation the problem.


Nuclear Submarine Forum

The Nuclear Submarine Forum (NSubF) is a network of NGO’s, groups and individuals who have an interest in the dismantling of the 27 Royal Navy nuclear powered submarines