The Nuclear Free Local Authorities (NFLA) and KIMO International submits today a joint response to a Scottish Environmental Protection Agency (SEPA) consultation considering a Ministry of Defence (MoD) application to vary radioactive discharges at the Faslane and Coulport naval site on the Clyde Estuary, particularly affecting the Gare Loch. (1)
The MoD has submitted an application to SEPA for the disposal of radioactive waste at Her Majesty’s Naval Base (HMNB) Clyde, Coulport and Faslane. The application covers discharges from a new effluent treatment facility at Faslane and seeks to update existing arrangements. The SEPA consultation ends on the 6th March 2020.
The MoD is building a Nuclear Support Hub (NSH) at Faslane which will centralise the existing radioactive waste handling facilities and radiochemistry laboratories. The NSH is situated in a new location within the Faslane site, with a new effluent discharge point into the middle of the Gare Loch. This is one of the reasons that a new site agreement is needed.
The Faslane naval base supports the operation of nuclear submarines, some of which are armed with Trident nuclear weapons. The number of nuclear submarines which operate from Faslane is scheduled to increase. This will be the main reason why, despite the application being for lower absolute limits for liquid radioactive discharges into the Gare Loch, actual discharges are expected to increase, some by very large amounts. NFLA and KIMO International strongly objects to these increased radioactive discharges which, if permitted by SEPA, would result in increased radioactive contamination of the entire Gare Loch, including its flora and fauna, and would result in increased radiation doses to people living in the vicinity of the Loch.
The MoD is exempt from the provisions of the Environmental Authorisations (Scotland) Regulations 2018 (EASR). However, MoD policy states that: “Where Defence has exemptions, derogations or dis-applications from Health and Safety and Environmental Protection (HS&EP) legislation, we maintain Departmental arrangements that produce outcomes that are, so far as reasonably practicable, at least as good as those required by UK legislation.”
In the view of NFLA and KIMO International, there is no good reason for these exemptions, derogations and dis-applications from HS&EP legislation. These should apply to the MOD as they do to all employers. This is particularly the case for all civilian contractors.
NFLA and KIMO also note that the application says: “It should be noted that although there are plans to increase the numbers of submarines at Faslane this does not represent any change to the nature of the radioactive waste arising although it may have an impact on the quantity of waste produced.” In other words, the amount of radioactive wastes will be substantially increased.
The core conclusions of NFLA and KIMO to this application include:
- The MoD’s application involves expected increases in discharges of tritium by as much as 30-fold and discharges of cobalt-60 by almost 50-fold.
- Whilst the individual and collective doses estimated by the MoD and FSA are relatively small, there are considerable uncertainties involved with the modelling especially with regard to tritium.
- Doses attributed to tritium should be multiplied by around 20 in order to use a precautionary approach.
- UK Government policy is that unnecessarily introducing radioactivity into the environment is undesirable, even at levels where doses to humans and other species are purportedly low and, on the basis of current knowledge, are unlikely to cause harm.
- The Clean Technology choice for powering submarines would not involve using a nuclear reactor. Non-nuclear air-independent propulsion (AIP) submarines offer particular advantages over nuclear submarines. NFLA recommend MoD pursue such an option.
NFLA Scotland Convener, Councillor Feargal Dalton said:
“The NFLA is strongly concerned that this MOD application will see an increase in radioactive waste into the Gare Loch. It objects to such changes. NFLA is particularly concerned about the considerable uncertainties in modelling doses and an under-appreciation of the effects of tritium. There are effective alternatives to nuclear powered submarines, as pioneered by the likes of Japan, and the Ministry of Defence should make a serious attempt to look at them. With the OSPAR Commission strongly encouraging ‘close to zero’ discharges into the marine environment, NFLA is concerned at an application which sees significant increases of tritium and cobalt into the Gare Loch area. We call on SEPA to scrutinise this application carefully and take full account of our concerns.””
Arabelle Bentley for KIMO International added:
“KIMO is alarmed about the significant environmental impact of increased radioactive contamination and the consequent harm both to ecosystems and to people residing in the Loch Gare area. Their safeguarding is of paramount importance and KIMO believes that the substantial increase in radioactive waste discharged without due diligence or mitigating actions would be both reckless and unacceptable. KIMO joins with NFLA in urging the MoD to work to find alternative solutions that do not pose a threat to the environment or to human health.”
Ends – for more information please contact Sean Morris, NFLA Secretary, on 00 44 (0)161 234 3244.
Notes for Editors:
(1) NFLA Radioactive Waste Policy Briefing 81 on Radioactive Waste Disposal from HMNB Clyde, February 2020 is attached with this media release.