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