NUCLEAR SUBMARINE FORUM (NSubF)
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
Post: Submarine Dismantling Project
Ash 1b #3112
MOD Abbey Wood
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.
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.
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