The NFLA agrees with most of the major issues identified by an ‘Investigation into Nuclear Submarine Defueling and Dismantling’ by the National Audit Office (NAO). The report highlights some of the key issues facing the Ministry of Defence (MOD) in operating an effective framework to safely dispose of and recycle the twenty out of service submarines residing in Devonport and Rosyth dockyards. (1)
The MOD has failed to dispose of any of the 20 submarines retired since 1980; 9 of which still contain irradiated fuel. Some of the submarines have spent longer inactive than in service. After the previous report by the NAO, ‘The Defence Nuclear Enterprise: a landscape review’, which criticized the lack of berthing space at the Devonport dockyard, the MOD committed to having its first submarine disposed of by 2023. The NAO maintain that in order to achieve this deadline serious work and investment must be undertaken. The NFLA fully supports this view.
The report focuses on the five stages of the disposal process:
- ‘Laying up’ (preparation for long term storage)
- Long term storage
- Defueling
- Dismantling
- Recycling.
In the NAO’s assessment on the capability of the MOD to execute these various phases, not one element of the process is currently able to be completed. The defueling and dismantling of the submarines are particularly concerning to the NFLA, as the MOD has not defueled a submarine since 2004, when the ONR deemed their defueling facilities unsafe. Regarding dismantling, the MOD has only managed to remove low-level waste (LLW) and still has not had approved a method of removing the intermediate level waste (ILW). To the NFLA, this is just not good enough.
This delay to the proper framework for disposal being established has also been extremely costly to the UK Government. According to the report the 11 year delay has cost around an extra £100 million. The prospect of further safe storage and maintenance of these vessels will bring further costs, the report estimates it costs £12 million a year just to maintain the 9 submarines in Devonport. The MOD has already spent over half a billion on just storing and maintaining its submarines and a further £7.5 billion liability has been allocated to complete the lifetime of the project.
The NFLA agrees with the report’s core recommendation that the building of new submarines should follow civil nuclear production in respect to plans to decommission and dispose of the submarines being put in place during the process of production. Though it should be said even the civil nuclear sector’s decommissioning plans are much slower than NFLA would prefer. (2)
Given that there is some suggestion that the MOD is considering new options for the management of the waste, NFLA remains concerned that this urgent radioactive waste problem is still not being overcome and may not be resolved until at least the mid-2020’s. That is a dismal result and highlights the ongoing weaknesses in the defence nuclear programme. NFLA also opposes Trident replacement, a programme that will eventually add more submarines and more long-term costs to this overly expensive legacy programme, at a time when the MOD’s budget is under critical stress.
NFLA Steering Committee Chair, Councillor David Blackburn said:
“The NAO’s report brings to light the dismal failings of the MOD in dealing with its nuclear submarine radioactive waste legacy. It beggars belief that after almost 40 years a solution to this issue has not been found, with costs to the project increasing year by year. NFLA urges the MOD to study carefully the NAO recommendations and act accordingly. The people of Rosyth and Devonport deserve much better than this. NFLA urges ministers to get a full grip on these nuclear legacy issues.”
Ends – for more information please contact Sean Morris, NFLA Secretary, on 00 44 (0)161 234 3244.
Notes for editors:
(1) NAO 3rd April 2019
https://www.nao.org.uk/report/investigation-into-submarine-defueling-and-dismantling/
(2) The length of time to decommission submarines tallies with the decommissioning plans to the Magnox Reactors civil nuclear programme:
| Magnox reactor | Ceased Generation | Expected to enter Care & Maintenance | Time spent preparing for C&M |
| Berkeley | 1989 | 2023 | 34 years |
| Bradwell | 2002 | 2018 | 16 years |
| Chapelcross | 2004 | 2025 | 21 years |
| Dungeness A | 2006 | 2025 | 19 years |
| Hinkley Point A | 1999 | 2027 | 28 years |
| Hunterston A | 1990 | 2024 | 34 years |
| Oldbury | 2012 | 2027 | 15 years |
| Sizewell A | 2006 | 2027 | 21 years |
| Trawsfynydd | 1991 | 2029 | 38 years |
| Wylfa | 2015 | 2026 | 11 years |