Strong Resistance to Rosyth being used for Nuclear Storage – The Courier 2 Feb 2012

Local consultation finds strong resistance to Rosyth being used for nuclear storage

Rosyth has said an overwhelming no to nuclear waste from redundant submarines being stored locally.
Rosyth dockyard

The majority of people living in communities surrounding the dockyard who have taken part in a Fife Council consultation exercise — dubbed the Rosyth Referendum — have rejected the idea.

With the Ministry of Defence’s nationwide consultation exercise on what happens to Britain’s fleet of decommissioned submarines drawing to a close in a matter of weeks, Fife Council decided to hold a local survey.

Local SNP councillor Douglas Chapman told The Courier: ”We have taken account of extensive local views and opinions on this issue and we are currently agreeing a council position which would recommend that these submarines and all their nuclear waste be moved out of Rosyth permanently.

”The report as currently presented by council officers will be subject to amendment from the administration and that position, I believe, will respect the views of those who replied to the Fife Council survey on the matter.

”While our final position is not yet finalised, there is a clear view locally that people are uncomfortable with the nuclear waste stored on site and with the prospect of more nuclear waste being stored there long term.

”They’ve been in our backyard for long enough and it’s time to utilise the part of the dockyard the subs use for more sustainable, commercial activity that would create many more jobs.

”Weighing heavily on our mind is the dreadful state of affairs that has been allowed to happen at Dalgety Bay and if the MoD and the British Government have not taken that issue seriously enough, you can imagine why people around Rosyth would want this nuclear legacy removed as soon as practically possible.”

Over 7,000 questionnaires were distributed to every household in Rosyth, North Queensferry, Limekilns and Charlestown. The survey was also available online.

Fife Council was pleased to see a high response rate with nearly 1,000 replying, with a ”breadth and detail of comments” showing local interest and knowledge. See full article

Debate on Scrapping of N-Subs -Plymouth Herald Monday, January 23, 2012

Debate on Scrapping of N-Subs

CAMPAIGNERS are holding a meeting to give people a last chance to have their say on the dismantling of nuclear submarines.

Groups including the Campaign Against Nuclear Storage and Radiation and the Green Party want people to speak out on the Ministry of Defence’s plans on Wednesday.

The MoD has held an extensive consultation over the last two months on how the Navy should dispose of an ageing fleet of nuclear submarines. The plans are to store intermediate waste in Devonport or Scotland and the deadline for submitting a response is February 17.

Organisers of the meeting in the city centre are calling the issue ‘the most important decision affecting the people of Plymouth in five generations’.

Ian Avent, of CANSAR, said Plymouth could effectively become a ‘nuclear scrapyard’.

He added: “What impact will this have on a city with aspirations as a world city of tourism?”

The groups, also including the Nuclear Submarine Forum and Transition Plymouth, want waste dispersed at several sites, including Scotland.

The meeting is being held at 171 Armada Way, opposite the Armada Centre, from 7pm on Wednesday. Help will be given with consultation forms.  article

Nuclear sub dismantling discussed at Dunfermline event – BBC News 19th Nov 2011

Nuclear sub dismantling discussed at Dunfermline event

The fate of seven nuclear submarines berthed at the Rosyth dockyard in Fife is being discussed at the first in a series of consultation events.

The Ministry of Defence (MoD) has said it will run out of room to store its old nuclear submarines in 2020.

It is seeking public opinion on how and where the submarines should be broken up, and what should happen to the radioactive material on board.

The first public meeting is being held in Dunfermline.

Rosyth in Fife and Devonport in Plymouth are the two preferred sites being considered as locations for removing the radioactive material from the vessels.

Seven nuclear submarines have been stored at Rosyth since the 1990s.

Ten more are berthed at Devonport, with others due to come out of active service in the future.

Fife Council said it would be asking local residents their opinion before it submitted its views.

The MoD has other events planned for Scotland before the consultation ends in February.

BBC Scotland’s Cameron Buttle was given special access to the submarines   See Video

Plans to dismantle N-subs at yard explained in workshops – Saltash People 8th Dec 2011

Plans to dismantle N-subs at yard explained in workshops
THE public in Torpoint have been able to speak their minds and learn about controversial plans to cut up ageing nuclear submarines.
A public consultation event took place at Torpoint Town Hall concerning a nuclear dismantling project in Devonport.

The event continued yesterday with special workshops beginning at 11.30am, 1pm, 3pm, 4.30pm and 6pm.

The Ministry of Defence (MoD) asked local people their opinions as it considered where to dismantle decommissioned subs in the future.

The project could be based either at Devonport Dockyard or at Rosyth in Scotland.

At the weekend the MoD’s Submarine Dismantling team returned to the region to stage public exhibitions in Saltash.

Last month a similar five-day consultation event at the Guildhall attracted about 400 people and organisers said a real cross-section of people visited with a diverse range of views – mainly about the safety of the work.

Military chiefs earmark Devonport as the “more reasonable proposition” for the work in their consultation document.

The document states that the ‘proposed option’ is to undertake initial dismantling at both Devonport and Rosyth.

But it adds that the option to use Rosyth Dockyard only is the “least attractive” in terms of cost. An assessment of all three dismantling site options will be revisited in light of public consultation responses.

see video

Nuclear submarine dismantling at Devonport and Fife sites recommended BBC News 28 Oct 2012

Nuclear submarine dismantling at Devonport and Fife sites recommended

A Trident submarine Seven disused submarines are stored at Rosyth dockyard and 10 at Devonport

The Ministry of Defence has revealed it wants to dismantle nuclear submarines stored at Devonport in Plymouth and Rosyth in Fife at both sites.

Ten decommissioned submarines are currently stored at Devonport and seven at Rosyth – 10 remain in service.

The MoD said its preferred option was to “undertake initial dismantling at both Devonport and Rosyth”.

However a consultation document issued earlier said dismantling at Rosyth was the “least attractive option”.

The document for the Submarine Dismantling Project said this would involve transporting 20 submarines to Scotland.
‘Responsible operator’

“Dismantling at Devonport only, on the other hand, remains a more reasonable proposition,” the report said.

On its website the MoD said the work would include removing all radioactive material, mainly metalwork, which had become radioactive during use.  see article

Consultation Now Closed

and associated groups and individuals have made their own contributions. Many comments will have been recorded during the consultation events and the MOD is now tasked with collating all this and producing a report. NSubF is pressing for the draft report to be seen and commented on, at least by the Advisory Group, before publication. The Main Gate decision will be in 2013.

NSubF Submission

NUCLEAR SUBMARINE FORUM (NSubF)

Response to the MOD SDP Consultation on Dismantling Nuclear Submarines

Question 1

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.

Question 2

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.

Question 3

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

a.    Defuelling

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.

Question 4

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.

Question 5

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.

Question 6

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.

Question 7

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

Question 8
.
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.

Question 9

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.

Question 10

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.

Environmental Questions

Question 11

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

Question 12

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.

Questions 13

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.

Question 14

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.

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

Consultation announced in House of Commons

Submarine Dismantling Project

The Parliamentary Under-Secretary of State for Defence (Peter Luff): The Ministry of Defence will tomorrow— 8 October 2011—start a period of public consultation on the options for dismantling nuclear-powered submarines that have left service with the Royal Navy, including those that are in afloat storage at Devonport and Rosyth dockyards.

27 Oct 2011 : Column 17WS

Submarines in afloat storage are maintained safely, in a similar way to operational submarines. As they age, however, and as further submarines leave service, the cost to the taxpayer of maintaining them is rising significantly, and space to store them is running out.

This consultation will seek the public’s views on the proposals that have been developed by the MOD’s Submarine Dismantling Project (SDP) for dismantling and disposing of the submarines in a safe, secure and environmentally responsible way. It will seek views on the three key decisions that need to be made about submarine dismantling:

How the radioactive material is removed from the submarines;

Where we carry out the removal of the radioactive material from the submarines; and

Which type of site is used to store the radioactive waste that is awaiting disposal.

The consultation will run for 16 weeks, from 28 October 2011 until 17 February 2012. This period has been extended from the 12-week minimum to account for the Christmas holidays and in recognition of the interest in the project.

A series of events, including exhibitions and workshops, will be held in and around the Devonport and Rosyth areas, where the candidate sites for the removal of the radioactive waste from the submarines are located. National workshops will also be held in accessible locations in England and Scotland.

Consultation events will be advertised in the local press and on the project website, www.mod.uk/submarinedismantling, where all relevant documentation, including extensive supporting information, will also be published. All the responses received during the consultation process will be considered by the MOD during its further analysis of the options before final decisions are made around 2013. Only then will planning applications for activities on specific sites be made.

Details of the MOD’s proposals and of the plans for public consultation are included in the SDP consultation document, copies of which will be placed in the Library of the House.

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