Category Archives: Current Consultations

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
project.
 
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.
 

MoD’s Consultation Events

Plymouth
Plymouth Guildhall –
Sat 12 to Wed 16 Nov 2011
Public Exhibitions will run from 11am to 7pm.
The exception is Remembrance Sunday where the exhibition will start at 11.05am.
Workshops are on Sat, Sun & Mon starting: 11.30, 13.00, 15.00, 16.30, 18.00

Fife
Carnegie Conference Centre, Dunfermline –
Sat 19 to Wed 23 Nov 2011
Public Exhibition from 11am to 7pm each day
Workshops are on Sat, Sun & Mon starting: 11.30, 13.00, 15.00, 16.30, 18.00
Rosyth Civil Service Club –
Tue 13 December 2011
Public Exhibition from 11am to 5pm.
Workshops are on Sat, Sun & Mon starting 11:30, 13.00, 15.00

Saltash
St Mellion Hotel, St Mellion –
Sat 3 to Mon 5 Dec 2011
Public Exhibition from 11am to 7pm each day
Workshops are on Sat &  Sun starting: 11.30, 13.00, 15.00, 16.30, 18.00

Torpoint
Torpoint Town Hall –
Tue 6 Dec and Wed 7 Dec 2011
Public Exhibition from 11am to 7pm each day
Workshops are on Wed 7 Dec starting: 11.30, 13.00, 15.00, 16.30, 18.00

Edinburgh
Surgeons’ Hall –
Fri 9 to Mon 12 and Wed 14 Dec 2011 (no event Tue 13 Dec)
Public Exhibition from 11am to 7pm each day
Workshops are on Sat, Sun & Mon starting: 11.30, 13.00, 15.00, 16.30, 18.00



National Workshops.   

Birmingham
Tue 31 Jan 2012, 11am to 4pm
International Conference Centre, Broad Street, Birmingham, B1 2EA

Glasgow
Mon 6 Feb 2012 , 11am to 4pm
Scottish Exhibition & Conference Centre, Exhibition Way, Glasgow, Lanarkshire G3 8YW

 


To register for National Workshops or for further information please contact us via the details below.

Email:
DESSMIS-SDP@mod.uk

Phone: 030 679 83793
(messages can be left on voicemail outside working hours)

Project address:
Submarine Dismantling Project,
Ash 1b #3112,
MOD Abbey Wood
Bristol,
BS34 8JH

NSubF Briefing for the Consultation

NUCLEAR SUBMARINE FORUM (NSubF)

BRIEFING

Ministry of Defence Submarine Dismantling Project (SDP)
Consultation 2011 – 2012

1.    What is the Submarine Dismantling Project ?

The Ministry of Defence (MoD) has set up the ‘Submarine Dismantling Project’ (SDP) to find a solution to the problem of storing the Royal Navy’s redundant nuclear powered submarines, which are contaminated with radioactive waste.  The project will extend over at least sixty years and will involve:

consulting the public on the options for dealing with the submarines.

  • dismantling the submarines.
  • interim storage of radioactive waste from the submarines.
  • transfer of the radioactive waste to a proposed national disposal facility for radioactive waste when/if it is built.
  • recycling as much of the remaining materials as possible.

As part of the project, the MoD is consulting nationally on its proposals from 28 October 2011 to 17 February 2012.

2.    How will consultation on the Submarine Dismantling Project take place?

The MoD is running the third public consultation on submarine dismantling from Friday 28 October 2011 to Friday 17 February 2012.

The consultation is about choosing the least worst option for how and where to dismantle old nuclear submarines and store the resulting radioactive waste as safely as possible.

The consultation acknowledges that the public have an important interest in submarine dismantling and waste storage and have a right to have their say on the Ministry of Defence proposals.  We are being invited to give our views on the options for how to dismantle the radioactive reactor compartments from redundant nuclear powered submarines.  Through a process of elimination, the MoD has arrived at three  options for how this could be done and three options for where it could be carried out.  A decision will also be needed on where the radioactive waste  will be stored – which is likely to be the hardest decision to make – but this will be the subject of a separate future consultation.

In addition, the Submarine Dismantling Project raises many issues associated with nuclear submarines and their impact on people and the environment which relate to the problems now facing the Ministry of Defence. The consultation gives us an opportunity to have our say on these matters.

Local consultation workshops will take place in the Plymouth and Rosyth areas to seek the views of the public at the sites the Ministry of Defence has identified as potential dismantling sites (Devonport and Rosyth dockyards), with two all-day National Workshops taking place in Birmingham and Glasgow.  Views on the project should also be sent in writing to the Ministry of Defence.

There is a great deal of information about the Submarine Dismantling Project to be read and downloaded on the Ministry of Defence website at:
Submarine Dismantling Project – About

Consultation documents are available from:

Tel:    030 679 83793
Email: DESSMIS-SDP@mod.uk
Post: Submarine Dismantling Project
Ash 1b #3112
MOD Abbey Wood
Bristol
BS34 8JH

3.     What does the Ministry of Defence  hope to gain from the consultation?

The Ministry of Defence’s key objective is to gain ‘public acceptability’ for a place and a method for dismantling the Royal Navy’s redundant nuclear powered submarines.

Public acceptance for the proposals will be essential in allowing the project to go ahead without being derailed by local opposition, and in ensuring that the communities where submarine dismantling takes place will receive maximum benefit and minimum disadvantage from the project.

4.     What does the Nuclear Submarine Forum (NSubF) hope to gain from the consultation?

The Nuclear Submarine Forum 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 (see ‘Our View’ below).

5.      How has the Nuclear Submarine Forum been involved in  the Submarine Dismantling Project?

The Nuclear Submarine Forum was established in 2000 when the Ministry of Defence announced that it was commencing work on the Submarine Dismantling Project (then known as Project Isolus).  Our aim was to influence the project and inform organisations and local groups of its progress. We had no idea that we would still be at it eleven years later!  We have read hundreds of documents, been to dozens of meetings and many times wondered if we were using our time wisely.  However, our close involvement with the Ministry of Defence has given us an insight into how the Royal Navy and civil servants think and work. Through being represented on various MoD advisory groups, NSubF members have used the opportunity to take our views on nuclear disarmament, nuclear waste and nuclear risk, right into the heart of one of the most secretive of government institutions.

While much of the eleven year delay in reaching the public consultation stage of the Submarine Dismantling Project is the result of Ministry of Defence bureaucracy, the slow progress is also partly the result of the refusal of  NSubF representatives and other independent advisors to compromise on issues of principle. Mutual respect has developed in the project’s Advisory Group between a wide range of people involved in the Submarine Dismantling Project: activists, nuclear professionals, regulators, academics and MoD civil servants – all from very different backgrounds.  We do not agree on many fundamental issues but  we all agree on the aim to  decommission out of service nuclear submarines and eliminate the risks they pose as soon as possible.

6.    Has the Ministry of Defence secrecy influenced the project?

The MoD considers detailed information on submarine reactor and turbine transmission design to be secret.  Although there is no reason to suppose that the Ministry will not adopt the best technical and safety procedures when dismantling submarines, the unnecessary secrecy surrounding outdated technology and past operational details means that the openness and transparency of consultation on submarine dismantling is compromised.  Despite this, we consider that the matter is sufficiently important to remain engaged with the consultation process.

7.    What form is radioactive waste from old nuclear submarines in now?

There is radioactive waste inside the Royal Navy’s out-of-service nuclear powered submarines which are afloat in storage at Devonport and Rosyth dockyards.  Although the spent reactor fuel has been removed from most of these submarines, the reactor compartments contain considerable quantities of radioactivity.  The time has come to remove the waste into safe, dry conditions rather then leave it in the submarines indefinitely as their condition deteriorates over time.

8.    How much waste is there?

The Submarine Dismantling Project is dealing with 27 nuclear powered submarines,  11 of which are in service and 16 of which have been decommissioned and are awaiting dismantling.  Nine are stored afloat at Devonport dockyard and  seven at Rosyth dockyard.  Five of the redundant submarines in storage at Devonport still contain nuclear fuel. These will be de-fuelled and the spent fuel, which qualifies as high level radioactive waste will be removed to the Sellafield nuclear waste reprocessing plant before the submarines are dismantled.

After the fuel has been removed, each submarine hulk contains around 50 tonnes of intermediate level radioactive waste.  The total mass of radioactive waste generated from one submarine has been calculated as 47 tonnes.  If the radioactive waste from all 27 of the Navy’s submarines were packaged it would fill  216 standard ‘Nirex’ waste boxes, which have a volume of three cubic metres.  Around 108 of these boxes would contain intermediate level radioactive waste.  Nirex boxes are currently used to transport radioactive waste. They have been designed and tested to withstand fire and a drop from height onto a solid surface.

9.    What about the Navy’s new submarines?

The Submarine Dismantling Project commenced before work had begun on building the Navy’s new ‘Astute’ class submarines.  Nuclear Submarine Forum argued that it was irresponsible and unethical to build new submarines before a solution had been found for how to deal with the radioactive waste they would generate.  As a result, the Submarine Dismantling Project’s terms of reference only relate to disposal of the 27 submarines which entered service before HMS Astute.   However, knowledge gained in dismantling the earlier submarines will be relevant to dismantling the Astute class in 40 –50 years time.  Further consultation will be required when the time comes in order to gain public acceptance for plans for dismantling of Astute class submarines.   This has been a hard-won concession from  the MoD as NSubF members were not prepared to remain on the SDP Advisory Group if Astute class submarines were included in the scope of the project.

10.     Where will the radioactive waste be stored?

Storage options will depend on the way in which the submarines are dismantled, and the actual size of radioactive waste which results. The interim plan is store the intermediate level waste until at least 2060, by when it is hoped that a proposed national storage facility for radioactive waste will have opened.   The location of the interim waste store has yet to be determined and will be the subject of a separate consultation. MoD will keep responsibility for the waste unless and until it is handed over to the Nuclear Decommissioning Authority. 

Low-level radioactive waste generated during submarine dismantling will be sent to the existing national low level waste repository in Cumbria. No radioactive waste from the dismantling process will be classified as ‘very low level’ (waste which is exempt from special disposal and can be sent to landfill sites with the approval of the Environment Agency).

11.    What are the dismantling options?

The Reactor Compartment can be left as a whole slice of hull, providing a ready-made safety shield for the de-fuelled reactor pressure vessel and pipe-work. The height of a hull slice is about that of 2 double-decker buses.

The Reactor Pressure Vessel can be removed from the reactor compartment and stored in an extra large ‘Nirex’ protected container, with the rest of the compartment cut up and stored in standard-size three cubic metre Nirex packaged waste boxes.

The reactor pressure vessel can be cut up as well as the pipework and also stored in standard-sized Nirex boxes. The estimated number of boxes of  intermediate level radioactive waste resulting from this option is expected to fill 3.6 standard (three cubic metre) boxes per submarine.

12.    What are the waste storage issues?

If all 27 submarine reactor compartments are used as containers (as is the case in the USA, Russia and France), they will require a very large storage area. At some stage in the future they will need to be size-reduced, packaged and stored because the continuing nuclear decay will outlive the life of the hull. 

The actual volume of intermediate level radioactive waste which will need to be stored is related to how much actual cutting up is done during the dismantling process.  The more the  submarine is cut up, the smaller the packages of waste; the less it is cut up, the less is the risk of radiation exposure to workers and the environment – but large hull slices would remain as waste.  If intermediate level waste is cut up and packaged there is a greater range of options for moving it to storage sites away from the dismantling site. The store footprint would be expected to be in the region of 500 – 600 m2.

This choice of store location will in part depend on what decision is made on reducing the size of the reactor compartment. The smaller the size-reduction, the more additional waste will be produced and the greater the risks  posed to workers.  On the other hand, if the compartments are left whole a larger storage site will be required near the coast because they would be too large and heavy to transport by road.

13.    What is the proposed Geological Disposal Facility (GDF)?

In the long term future the government proposes to build an underground geological disposal facility as a respository for radioactive waste.  However, as yet there is no guarantee that a GDF will be built. The proposal to consign nuclear waste to a deep geological store is under serious challenge, particularly from Greenpeace (see http://www.greenpeace.org/international/en/campaigns/nuclear/waste/), as there are other waste management options which may be more suitable.  As an alternative policy, the Scottish Government is advocating a long term store from which radioactive waste is retrievable for examination, repackaging and re-store, enabling future generations to manage the waste using future technologies and allowing access in the event of any problems.

14.    What are the inter-generational issues?

A key ethical question for the Submarine Dismantling Project is should we leave submarine radioactive waste storage solutions for future generations to find, or do we have a responsibility to resolve the problems our generation has created?   Related to this is the issue of whether we should use the skills of the present day workforces at Devonport and Rosyth, who are familiar with these submarines, to dismantle them or delay to await further radioactive decay and reduce the radioactive dose to workers.  Regardless of what option is chosen, it will be important to ensure that full details of submarine wastes and the hazards that they pose are passed on to future generations by disseminating this knowledge widely.

OUR VIEW

Reducing future risks to zero

The Nuclear Submarine Forum welcomes the Ministry of Defence consultation on this controversial and sensitive matter, as it is essential that there is a mature and informed debate over what to do with the unwanted radioactive legacy of the Navy’s redundant submarines.  We strongly urge everyone with an interest in the project to take the opportunity to have their say during the consultation period.

We have been left with this dangerous and unwelcome legacy as the result of unwise decisions made in the past, but it is our generation’s responsibility to deal with this problem.  We cannot ignore it and leave it for our children and grandchildren to deal with.

If this project is to succeed then the communities where submarine dismantling will take place must agree to accept the work on a fully informed basis, with social benefits and compensation provided to help offset the risks involved. 

NSubF‘s view is that the Submarine Dismantling Project will only be accepted by the public if we have confidence that the UK’s nuclear powered submarine programme is being phased out.  No further vessels should  be built and those currently in service should be rapidly decommissioned, with their reactors shut down to reduce further risk and prepared for dismantling.  The less a reactor is used, the less spent fuel it produces and the easier and safer the radioactive waste is to handle.

Why ‘No New Build’

Submarines are old cold war technology that no longer address modern security threats such as cyber-attack, extremism, or the impacts of climate change .  They pose unnecessary radiological and safety risks to the crew and other workers, the public, and the environment.  Continuing with a nuclear navy will continue to put the public at risk whenever and wherever submarines are docked, serviced, decommissioned and dismantled.  Without a clear  safe storage  route for  radioactive waste from submarines, it is irresponsible to build them..

Not assets but liabilities

The Nuclear Submarine Forum would like to see at least one submarine reactor compartment  preserved whole – to act as a monument to folly.  Nuclear weapons and submarine reactors are not military assets but liabilities. Their acquisition has been a high-risk strategy which is no longer appropriate, except within an outmoded dogma. Common sense must prevail and a way forward found for a non-nuclear Navy.

Do you need help with your response?

Contact Nuclear Submarine Forum  with specific queries [di@nuclearinfo.org] or for more help, contact defence consultant Andy Oppenheimer who has offered to provide expert help at a negotiated, very reasonable fee.

Contact:

Andy Oppenheimer
www.andyoppenheimer.com
Editor, G2 Defence Intelligence & Security
Editor, Chemical & Biological Warfare
Member, International Association of Bomb Technicians and Investigators
+44 (0)77 6666 2655
+44 (0)1273 725 203 (land line)