NUCLEAR SUBMARINE FORUM (NSubF)
Response to the MOD SDP Consultation on Dismantling Nuclear Submarines
1. Overall view of Objectives for Submarine Dismantling
The Nuclear Submarine Forum welcomes the Ministry of Defence consultation on this controversial and sensitive matter. We see the need for a mature and informed debate over what to do with unwanted radioactive redundant submarines. The country has been left with this unwelcome legacy as the result of unwise decisions made in the past, but it is our generation's responsibility to deal with the problem. We cannot ignore it and leave it for our children and grandchildren to deal with.
2. 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 significant compensations provided to help offset the new burden of SDP.
3. NSubF ‘s view is that the Submarine Dismantling Project will only be by 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 in preparation for dismantling. Timely decommissioning of the submarine fleet means that there will be less spent fuel produced, making it easier and safer to handle the High Level radioactive Waste (HLW) at defuelling. Further, the amount of HLW to store forever will be reduced.
4. Submarines are old cold-war technology that no longer addresses 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 or operate them.
5. How to remove the radioactive materials
How submarines are dismantled is governed by the storage method proposed. We start from the assumption that there is no such thing as ‘disposal’ of nuclear waste, only choices in how and where it will be stored forever. The government‘s proposed deep Geological ‘Disposal’ Facility would merely store the waste out of sight and dangerously, out of mind, with the hope that no geological changes will occur to expose it in the future. All that can be said is that we do not know the future. Consequently, NSubF favours a method of removal that will enable ILW to be stored where it will not be forgotten and where there is a system of monitoring, retrieval, repackaging and transparent accountability by its custodians.
6. We accept the MOD intention that RN submarine waste will eventually go to a NDA store of some kind. Meanwhile, the interim storage should be on MOD land on the basis that the ‘operators pays’.
7. Much will be learned about the reality of the varying risks of exposure to the workforce during the demonstrator stage. This needs to be made public.
8. Where to do the dismantling
Transporting radioactive materials in any form and in the form of submarines in particular, is to be avoided to reduce the risk of an accident involving a radioactive release. Consequently, we favour submarines currently laid up in Rosyth being dismantled at that site and those laid up in Devonport to be dismantled on site. By the time the remaining ten operational submarines are due for SDP dismantling, both the defuelling and dismantling equipment will need up-dating and probably replacing. The interim years should be used to explore the establishment of a new dismantling and defuelling site. The prospect of improving the risk factors for the Plymouth community would offer some relief from the current situation. We are aware that many people in Plymouth do not want any dismantling to be done at Devonport, and NSubF agrees with that in relation to dismantling of the fleet still at sea. However, in the interests of maritime safety, we reluctantly support the duel site option for existing laid-up submarines
To defuel submarines stored afloat in Plymouth is a high-risk operation, and in the event of an accident during the process, there is the possibility of catastrophic contamination of the immediate area within the dockyard, the neighbouring community, the city of Plymouth and the area downwind of the event for 50 miles and counting. The MOD has sought to avoid SDP responsibility for this defuelling of decommissioned submarines by leaving them within the DNS Regulators responsibility as naval vessels. Whereas this protocol seeks to avoid some laid-up submarines inclusion in the openness and transparency of the Public Consultation, in reality, defuelling cannot be ignored since it has a direct bearing on both the dismantling of the laid-up submarines, and of those still in service. The rationale for DNSR responsibility for operational boats and ONR for that of all SDP boats is overwhelming and would add confidence to the SDP process.
b. Safety regime for defuelling operations in Plymouth
Crucially, defuelling should not be done under a cloak of secrecy. The dates of operations should be announced, local school children taken on educational 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 to prevent thyroid cancer. This priority of safety above political and financial considerations is ONR rather than DNSR thinking. Transparency and Openness would be established as the new regime born out of the Consultation. The risk of public opposition to defuelling cannot be weighed against the real safety gain in terms of citizen survival if an accident led to a radiation release. This demonstrable benefit is what SDP can offer to the community of Plymouth.
9. Reduction in Discharges
Any community that accepts a new risk, whether from the dismantling process or from waste storage, should be entitled to see the reduction of an equivalent risk from existing practises. It is unreasonable to expect people to accept an increased MOD operations burden involving nuclear materials. A new process will impose a new stress on communities, which demands recognition and a positive response. A real reduction of discharges should be scheduled during the lifetime of SDP. It is a hard balancing act to consider, but the requirement of a reduced ‘radiological burden’ is a reasonable response, and one that is within the power of the MOD to fulfil.
10. For example, if a coastal MOD location is considered for a SDP waste store, then non-essential submarine visits to that port should cease. If an inland MOD site such as AWE Aldermaston is considered, then a reduction in operational waste equal to that of the SDP waste should be made. Or, in the case of Devonport, routine submarine servicing should cease when any SDP discharges occur. At Faslane, a reduction in operational submarine activity might be an acceptable recompense for taking on some of the Rosyth or Devonport SDP tasks.
11. MOD recognition of how the burden of SDP will impact on communities has led to this Public Consultation. Given the amount of waste to store, it would not be unreasonable to have at least two sites, reducing the burden on any one location. Both RC and RVP/Packaged waste could be accommodated by this storage method.
12. Consultation Comparisons
The options offered on dismantling are well documented. However, they do not include sufficient data on the known radiological inventory in each boat. Where the inventory is not known, reasons should be given. It is accepted that a final figure may change during the assessment and first stage of dismantling.
The options on where the process is to be done, is reasonably presented with sufficient information given.
Storage Options are not explored sufficiently to enable people to make an informed judgment.
13. A limited number of advantages and disadvantages of the options have been well captured but there are omissions, either as a matter of policy or in reluctance to go into too much detail at this stage. These can be remedied by an enthusiastic pro-consultee response to the suggestions received from the Consultation and transparent scrutiny of the Consultation results and MOD response.
14. The significant facts overlooked in the Consultation Information are reported above. They are listed here in summary:
- i. full information of the reactor inventory for each submarine
- ii. the phasing out of the nuclear powered submarine programme
- iii. the demonstrator stage will probably inform a change in options
- iv. defuelling, since it has a direct bearing on both the dismantling of the laid-up submarines and those at sea
- v. the status of fuelled laid-up submarines
- vi. resolving the contradictions over Regulation between ONR and DNSR
- vii. the inadequacy of the lists of ‘benefits’ of SDP to a community. A real reduction in discharges and operational risks as a benefit for accepting SDP should have been offered up front
- viii. waste storage at more than one site
- ix. compensation: environmental, radioactive and financial
15. a. NSubF considers that the views of people in the communities around the candidate sites who are most affected by SDP, as expressed in the Consultation responses, should influence the final option chosen for how the submarines are dismantled.
b. Rosyth and Devonport should be the dismantling sites so long as the conditions of radiation benefit are met.
c. Waste should not be stored at the dismantling sites on the grounds that their local communities are currently carrying an MOD nuclear risk burden. They will be bearing the further one of SDP dismantling, and should not be expected to suffer a third burden. The number of sites chosen need not be limited to one.
16. Post Consultation Process
The MOD team responsible for the Consultation should be given adequate debriefing, post consultation training and time off before being expected to draw conclusions and write the Consultation Report.
17. No objection, suggestion or concern expressed in the consultation responses should be disregarded or dismissed as outside the SDP brief, unless not doing so would compromise safety. In all other cases, MOD has a responsibility to respond positively in a transparent and open way.
18. Publication of MOD responses to the Consultation may have to be done in two stages, enabling comment from participants or at least from the Advisory Panel before the final report is published.
19 Representatives of Local Authorities, Community Groups and NGOs affected by the MOD decisions will need to be included in any further scrutiny panel.
20. Assessment of the Consultation
The key decisions we have outlined here benefit from the knowledge gained by NSubF members from attending the ISOLUS Advisory Group and SDP Advisory Group. We have found the response to requests for information adequate, but we are conscious that technical experts have been unable to access the information they require from which to advise us on matters beyond our knowledge.
21. The Consultation met five of the seven Code of Practice criteria, but did not meet requirement three to provide information on the cost or meaningful benefits of SDP. We cannot assess its compliance with requirement six, to analyse responses carefully and provide clear feedback, until a later date when that process is complete.
22. The SEA has captured the environmental effects of SDP that the MOD requires, but not those required by the public. The main damaging effects of SDP are the defuelling of laid-up submarines and the production of increasing amounts of High Level nuclear waste by not recalling operational submarines from sea. The SEA was a missed opportunity to challenge the policy of perpetuating environmental damage caused by submarines
23. The SEA has explained most of the environmental issues of SDP. But it does not go far enough into the rationale and justification for damage caused by submarines. Environmental protection seeks to preserve and restore the environment, not merely mitigate the effects of man on the environment to a ‘best practicable’ level, whilst endorsing the cause of the detriment. The ‘best possible’ methods must be adopted to repair the damage caused, to manage potential damage anticipated and to prevent continuing damage in an effort to restore safety for people and the environment. Acknowledgment is needed that nuclear submarines are not good for the marine and land environment, and not good for health and welfare.
24. The environmental information is based on technical data relating to the radioactive inventory of each submarine reactor that is unpublished. It is therefore impossible for technical experts to analyse the risk to the public of a radioactive release in the event of an accident.
25. The risk relating to defuelling is not addressed, nor the cumulative effects of the risk from defuelling, operational discharges and SDP discharges.
26. The environmental monitoring described is adequate, but will need due diligence by MOD SEA practitioners over a long period. Details of training, retraining and research into changing best practice by MOD SEA staff would give public confidence that monitoring develops rather than stagnates.
27. NSubF welcomes the listing of Compensation as a requirement for MOD response to the damaging effects of SDP where it is not able to avoid them. Such compensation needs to be adequate, open and transparent. It needs to address environmental compensation, reduction in nuclear risk, and financial compensation to communities and individuals for the burden of SDP and particularly when any failures occur.
28. The SEA Recommendations are well done, so far as they go. But the elephant in the dockyard remains defuelling. The opportunity to address this issue arises as a result of Public Consultation and should be taken now.
29. Public safety and prevention of environmental damage are the watchwords for the SEA, the SDP and for the government. It is to be hoped that priority will be give by all three departments to rowing back on the mistakes of the past and preparing for a safer and nuclear free future.