The Nuclear Free Local Authorities (NFLA) submits today its official response to the Ministry of Defence’s (MoD) consultation on shortlisted sites for storing intermediate level radioactive waste from as many as 27 nuclear powered submarines. (1)
For well over a decade, the NFLA has actively engaged with the Ministry of Defence’s Submarine Dismantling Project. This project has been overseeing the process that will see redundant nuclear submarines dismantled at the Rosyth dockyard in Fife and the Devonport dockyard in Plymouth. (2)
This is the second consultation on the process. The first, held in 2011, looked at the options for removing radioactive waste from the submarines. In its response to the 2011 Consultation the NFLA argued that, although the MoD claimed both worker doses and planned discharges of radioactivity were predicted to “remain within currently permitted limits”, it was clear that the two Reactor Pressure Vessel (RPV) Removal options failed to meet the ALARA (As Low as Reasonably Achievable) principle.
The NFLA concluded that, by applying a series of environmental principles to the problem of what to do with decommissioned submarines, the option of storing the intact reactor compartments above ground at the sites where the submarines are currently either stored afloat or defueled appeared to be the best option.
However, the MoD announced its decision to go ahead with its favoured option of removing the RPVs and storing them intact prior to disposal in March 2013. The MoD also decided that initial dismantling should take place at both Rosyth and Devonport.
This secondary consultation considers where the RPVs that are removed from each submarine will be stored. Five sites have been shortlisted for storage of the intermediate level waste (ILW) from each RPV – they are Chapelcross in Dumfries & Galloway, Sellafield in Cumbria, Capenhurst in Cheshire and Aldermaston and Burghfield in Berkshire.
In its submission to the MoD, NFLA makes the following core points:
- Firstly, as with civil nuclear waste, NFLA recognise that the operation of nuclear submarines in the past has generated nuclear waste which is going to have to be dealt with whether we like it or not. However, the building and operation of new nuclear submarines which will generate new nuclear waste raises completely different political and ethical issues. NFLA opposes the development of new nuclear powered submarines generating new nuclear wastes.
- Secondly, the programme for the interim storage of RPVs and also the generation of new waste by new Astute Class submarines depends on the UK Government‟s search for a deep underground radioactive waste repository, and the construction of such a ‘Geological Disposal Facility’ proceeding to an established schedule. The predicted lifespan of the interim store also depends on the Geological Disposal Facility (GDF) being able to accept MoD radioactive waste relatively early on in its predicted life. In the NFLA’s view, the MoD’s programme makes assumptions about the capacity of a GDF which may prove to be too optimistic. As such, it is the NFLA view that stores should be designed to last at least 150 years or more.
- In a Scottish context the fact that Scotland’s Environment Minister, Richard Lochhead, has written to the UK’s Under Secretary for Defence, Philip Dunne, saying that waste from dismantling submarines “should not be stored in Scotland” raises to the NFLA important issues of democratic accountability.
Other points the NFLA make include:
- The MoD should rule out building any stores with spare capacity. Any planning permission granted for a store should be contingent on that store only being used for storage of RPVs from the initial 27 decommissioned submarines.
- Chapelcross should be ruled out on the grounds that it does not have the support of the Scottish Government and that RPV storage is likely to delay final site clearance.
- The MoD says there should be no need to monitor for radiation outside the store. Nevertheless the NFLA view is that a programme of monitoring should be undertaken.
- With an interim store expected to be in place for 100 years, and in the view of the NFLA to be at least 150 years, the MoD needs to consider climate change scenarios and the flooding risk to each site.
NFLA welcomes the MoD’s strong commitment to consultation within this process. This is in marked contrast with MoD‟s involvement with other projects – such as the difficult process to bring the MoD to the negotiating table to develop a remediation plan for the Dalgety Bay site in Fife, its lack of effective engagement over the Trident nuclear weapons programme or the transportation of nuclear weapons convoys across the UK. MoD should use the positive feedback it has received from this process to inform stakeholder consultation on all aspects of its nuclear policy.
NFLA Chair Councillor Mark Hackett said:
I welcome the Ministry of Defence‟s more open consultation process for the storing of interim level radioactive waste from dismantled submarines, which is in marked contrast to its lack of substantial stakeholder engagement in other parts of its nuclear policy. In its response NFLA advocates that the MoD seek not to build new nuclear submarines and create more waste, and reconsider its optimistic scenarios over the development of a deep underground waste repository as the final location for radioactive waste from dismantled submarines. The MoD needs to remain open and transparent as it moves to shortlisting down to a single site, and it has to keep local authorities and the affected local communities fully engaged with this process.”
For more information please contact Sean Morris, NFLA Secretary on 0161 234 3244 or Pete Roche, NFLA Scotland Policy Advisor on 0131 444 1445.
Notes for editors:
(1) The NFLA Radioactive Waste Policy Briefing is attached with this briefing and it will be placed on the NFLA website.
(2) MOD consultation on submarine dismantling waste storage: https://www.gov.uk/government/consultations/submarine-dismantling-project-site-for-the-interim-storage-of-intermediate-level-radioactive-waste