4TH December 2000

Solent Coalition Against Nuclear Ships (SCANS)
c/o 44 Carlton Road Southampton SO15 2HP  Tel: 023 8063680

Chief Executive
Ships Support Agency
MoD
Room 102, B Block
Foxhill
Bath BA1 5AB
 
Dear Chief Executive

Proposals for the Storage of Nuclear Powered Submarines Withdrawn from Service

On behalf of the SCANS Steering Group, I enclose a response to the MoD invitation to comment on the Storage of Nuclear Powered Submarines withdrawn from Service after decommissioning, in advance of the MoD study to look at the problem.

Our interest in the subject relates to the future of nuclear powered submarine policy. We consider that these submarines should not have access to Southampton Docks because in the event of a reactor accident or leak of coolant water, lives in Southampton could be put at risk.

Please keep SCANS informed of any further stages of consultation and any developments related to the decommissioning of submarines.

Yours faithfully

John Vetterlein
for SCANS Steering Group
Solent Coalition Against Nuclear Ships (SCANS)
c/o 44 Carlton Road Southampton SO15 2HP  Tel: 023 8063680

SUBMISSION TO THE MINISTRY OF DEFENCE    4TH December 2000
from the SCANS Steering Group

STORAGE OF NUCLEAR WASTE
FROM DECOMMISIONED NUCLEAR POWERED SUBMARINES

Problems associated with long-term storage of nuclear waste have not been solved anywhere in the world. Therefore it is not likely that the storage of waste from nuclear submarines will be without difficulty in the near, medium and long-term future.

This submission is from a community group that came together in 1998 solely to address the risks associated with nuclear submarine reactors coming into port, and particularly into the civilian docks at Southampton. Our concerns centre on the health risks to the local, regional and wider population in the event of a release of radiation into the environment from an accident or a damaged submarine reactor.

The decommissioning of old nuclear powered submarines raise similar concerns; priority must be given to the safety of local people and workers.

The storage of RN nuclear submarine radioactive waste poses similar problems to those for civilian nuclear waste. Where large items are to be stored, the same stringent conditions are needed as for packaged waste.

This submission will address the following assumptions:

1. that the risk of a release of radiation to the environment during the process of decommissioning a nuclear reactor is real and acknowledged by the Ministry of Defence;

2. that the risk of a release of radiation to the environment during the whole time the waste is stored  is real and acknowledged by the Ministry of Defence;

3. that the volume of waste to be stored will increase as each submarine is decommissioned;

4. that public health, now and in the future, must be the factor governing decisions on the best practical options;

5. that the best practical options will be adopted for:
deciding whether or not to reduce the size of component parts for storage;
deciding the degree of packaging needed for large items;
deciding the location of storage sites;

6. that if any difficulties arise during the process of decommissioning, the Ministry of Defence will notify all respondents to their study and consultation, to explain the problem;

7. that the Ministry of Defence expects to modify its views as a result of the consultation process.

1. The risk of a release of radiation to the environment during the process of decommissioning a nuclear reactor is real and acknowledged by the Ministry of Defence.

Recommendations:

1.1 improved safety precautions are developed
1.2 safety preparations are made to cover every eventuality, however remote
1.3 safety response training is given to emergency services and to local people
1.4 sufficient advance warning of predictable days of greater risk to be given to emergency services and the public to enable necessary precautions to be taken

2. The risk of a release of radiation to the environment during the whole time the waste is stored is real and acknowledged by the Ministry of Defence.

Recommendations:

2.1 all waste should be packaged to withstand fire, water or any other detriment
2.2 all waste should be inspected and monitored appropriately
2.3 all waste should be stored above ground and retrievable for repackaging in the future
2.4 storage sites need to be well known in the locality, not only to the storage industry and the regulators but to local authorities at every level and generally to the public

3. The volume of waste to be stored will increase as each submarine is decommissioned.

Recommendations:

3.1 public confidence in the MoD strategy for storing waste is an essential element of safe storage
3.2 if one site is insufficient for the entire programme, an overall plan of storage sites with capacity to store all waste from decommissioned submarines should be in place before any one site becomes operational
3.3 this plan must be finite
3.4 it is in the public interest to stop producing more nuclear waste
3.5 no new submarine reactors should be built
3.6 reactors under construction should not be fuelled
3.7 reactors ready fuelled but not yet in service, should become part of the waste programme

4. Public health, now and in the future, must be the factor governing the decision on the best practical option.

Recommendations:
4.1 while storage of submarine waste is inevitable, the factors governing decision-making are variable, and these variables need to be prioritised in favour of public health
4.2 economic factors cannot take priority above safety
4.3 the cost of safe decommissioning and storage must be met by switching resources from production of future submarine waste
4.4 adding to existing nuclear waste is unacceptable in the interests of public health

5. The best practical option will be adopted for:

(i)   deciding whether or not to reduce the size of component parts for storage;
(ii)  deciding the degree of packaging needed for large items;
(iii) deciding the location of storage sites;

Recommendations:

(i)
5.1 no technical interference with contaminated structures should be carried out that would produce air born particulate radiation
5.2 compacting of waste must be done on site to avoid transport of waste
5.3 liquid waste must be stored and not dispersed
5.4 contaminated plant and tools must be added to the waste store on completion
(ii)
5.4 large items must be packaged appropriately
(iii)
5.5 storage sites need to be at the site of decommissioning to avoid the risks from road transport of waste
5.6 communities around existing decommissioning facilities cannot be expected to shoulder an unreasonable burden of long-term waste stores
5.7 new decommissioning sites on or adjacent to existing nuclear contaminated sites with port access will have to be fully equipped for the task of decommissioning and the tools added to the waste store on completion
5.8 storage sites need to be decided in co-operation with local people

6. If any difficulties arise during the process of decommissioning, the Ministry of Defence will notify all respondents to their study and consultation, explaining the problem.

Recommendations:

6.1 because respondents to the study are taking part in good faith, and understand that although the task is not easy it must be achieved as soon as practically possible, they need to be kept informed once the storage programme is under way

6.2 difficulties that may arise will affect people near to sites and as their advocates, respondents will need a continuing role in making recommendations to decision makers

7. The Ministry of Defence expects to modify its views as a result of the consultation process
7.1 respondents need to be confident they are not wasting their time and that the MoD has a genuine interest in achieving a safe, manageable and publicly tolerable solution
7.2 the MoD need to take fully into account the recommendations of respondents, and modify its views accordingly
7.3  public interest groups and expert Non Governmental Organisations support communities, the environment and a sustainable future, but are regrettably compromised by the legacy of nuclear waste from a time when government decisions were made behind closed doors
7.4 public co-operation in solving the problem of submarine waste cannot be achieved if production of more waste continues
7.5 production of nuclear powered submarines must cease for many reasons, not least the refusal of people to store the waste in their back yard unless they see an end in sight.

END.

to the
Ministry of Defence

Study on Storage of Decommissioned Nuclear Powered Submarines

December 2000
1. PRELIMINARY POINTS

1.1 NAG shares the following Policy on Nuclear Waste Storage1 with other Non-Governmental Organisations:

1. There should be no dumping or disposal of nuclear waste.
2. The polluter should seek responsible and acceptable solutions to storage.
3. At present, nuclear waste including spent fuel, should be stored in a fail-safe condition above ground, on site at nuclear facilities where it is produced.
4. Stored waste should be constantly monitored and retrieved if necessary and repackaged.
5. Production of waste by nuclear power generation and reprocessing should cease. In addition, NAG would add that production of waste through production of nuclear weapons and submarine reactors should cease.

1.2 Principles of safe storage of nuclear waste

The Principles of safe storage of nuclear waste have yet to be agreed by DETR and the Ministry of Health, the Ministries responsible for the impacts on the environment and human health. The Ministry of Defence is not able to make decisions in advance of the acceptance of these principles. In any event, we submit that submarine waste is as unsuitable as any other nuclear waste to be buried and forgotten. It must be conditioned and stored in a retrievable form above ground where it can be monitored for a hundred years or until it has decayed to a safe level.

1.3  NAG 's history of considering problems of nuclear waste storage

In 1998, NAG organised a day conference entitled "Problems in Store" when we drew together representatives from the nuclear industry, NGOs, Local Authority officers and councillors, the emergency services and community groups, to look at nuclear waste storage.

We recognise the need to move beyond an adversarial approach and to press for waste reduction practices to be taken more seriously.

NAG Conference, Problems in Store.

In 1999, we made a substantial submission1 to the Environment Agency on Radioactive Discharges from the Atomic Weapons Establishment (AWE) Aldermaston and Burghfield that included the issue of nuclear waste storage. This report contains much that we wish to contribute to the present Study.
 
Safe management of solid waste: - minimising the release of radioactivity for at least 100 years for radionuclides with short half-lives – especially tritium, which presents a challenge to manage without causing significant releases.

Also in 1999, NAG called for a Public Inquiry on AWE in a paper presented to Ministers and Members of Parliament, noting that radwaste storage at AWE was integrally involved in a series of problematic radioactive processes.

The contamination  / decommissioning  / radwaste storage / rate of discharge problems are all interconnected in a way that makes it particularly difficult to prioritise public and worker health and safety.

This balance needs independent and open assessment.

In July 2000, NAG organised the 15th Low Level Radiation and Heath Conference in Reading. Papers presented by thirteen experts covered a wide range of aspects of radiation dangers and long-term radioactive waste hazards.  The conference informed our background knowledge of the current problems under discussion.

 .. for far too long we have laboured under the delusion that the problem was simple and that sceptics were simply misinformed.
    Dr. Rachel Weston. Friends of the Earth

1.4 Submarine nuclear waste

Submarine waste may seem a simple problem compared with the awesome tasks of storing large amounts of High Level Waste (HLW) from nuclear power station reactors and weapons-grade plutonium. But submarine waste has unique problems, because the size of contaminated components present a challenge for storage. The Best Possible Environmental Option (BPEO) must be taken, rather than the Best Practical Environmental Option, which suggests financial and industrial constraints. All Intermediate level waste (ILW) and Low Level Waste (LLW)) must be packaged, stored and monitored in secure purpose built facilities. Changes in the decay rate will need to be monitored long into the future.

1.5 MoD experience of handling nuclear waste

At present, waste volumes from AWE Aldermaston dominate the total volumes produced by MoD. ILW waste is stored on site and LLW is sent for storage at BNFL Drigg. The MoD record in caring safely for waste at AWE in the past has been poor but recent improvements have been made. It is to be hoped that lessons learned at AWE will transfer to the storage of submarine waste.

2.  LONG-TERM STORAGE OF SUBMARINE NUCLEAR WASTE

2.1 Submarine Decommissioning

The decision on how best to decommission submarines will depend on assessing the best possible balance between
a) the optimum size of components for safe storage
b) the health and safety of decommissioning workers
c) public health risks from gaseous and liquid discharges during decommissioning
d) the relationship between the location for decommissioning and the storage site

It is essential to make these decisions before informing Babcock Ltd what is required of them in their experiment to decommission HMS Renown. The decommissioning process should not be industry driven, but must be in response to the storage and public health requirements.
What is very clear is that before undertaking any dismantling work                         on the submarine itself we will secure all the necessary regulatory         approvals. We will also secure the approval of the Ministry of Defence.5    Babcock Rosyth Defence Ltd, (BRDL)

2.2 AWE is an Unsuitable Site for Submarine Nuclear Waste Storage

No-one wants a radwaste store on their doorstep, but we are stuck with one at AWE after fifty years of nuclear weapons production. ILW has accumulated - and continues to accumulate - on the site. It is therefore not an option to bring waste onto the AWE site from elsewhere, and any such proposal would be met by objections from NAG.

2.3 Other Unacceptable Site Options

British Naval nuclear waste must be confined to mainland Britain. There is no possible justification for considering removing waste to another shore.

2.4 Naval Nuclear Waste

NAG shares with others the maxim that "the polluter pays". The responsibility for Naval nuclear waste rests with the Navy and the Ministry of Defence. This responsibility does not end with a financial commitment, but extends to the detriment that is caused by nuclear waste stores and the potential hazard of a radioactive accident, either gradual or sudden. Whereas no one Naval site can be expected to burden its neighbours with an unreasonably large nuclear waste store, it is the Navy that must take and spread the burden throughout its port assets that are already radioactively contaminated. To avoid road transport of waste, decommissioning will need to be carried out at storage sites: Storage-Site-Based-Decommissioning (SSBD). Waste stores would thus be confined to Naval sites with sea access.

2.5 Financial Cost

No expense should be spared in undertaking SSBD. The Ministry of Defence faces a similarly unpalatable financial burden as does the civilian nuclear power industry. The fact that naval reactors are 'individually' afloat, does not mean that they can all be considered to belong on one or two location when it comes to decommissioning and storage, however financially and logistically convenient might be such an assumption.
Decommissioning and Storage need to be seen as a package, and solutions cannot be financially driven. Priority must be given to Health & Safety, protection of the environment and public acceptability.

2.6 Legal Matters

In the past, the MoD has sought to hide not only military secrets, but a great many other matters behind the veil of "crown immunity". In the present case there can never be public confidence in a storage regime that is cloaked in secrecy. Naval nuclear waste storage sites must be fully publicly regulated. In our view the EURATOM Treaty covers military sites to ensure proper accountability for nuclear safety. NAG regrets the MoD failure to accept this point. The matter is a subject before the court in January 2001.6

2.7 Regulation of Nuclear Waste Stores

Naval nuclear waste stores must be licensed sites under the regulation of the NII and the Environment Agency. Authorisation must be sought for nuclear storage areas on Naval sites. The granting of a licence to AWE in 1997 sets a precedent in the MoD that can be repeated. Such legislative changes as are necessary, to enable Naval storage sites to be regulated, should be set in motion as soon as possible.

2.8 The Consultation

Before taking part in the MoD Consultation, NAG will need to be assured that it is not to be a cosmetic exercise to "allay public fears". These problems are real and not imaginary. We need to be confident that we are not wasting our time. The resources, voluntary time and effort committed by NAG to taking part, have to be worthwhile and in the public interest. The public interest will not be served if the MoD merely tick the "Consulted the Public" box before doing what they intended to do in the first place. The debate must be based on evidence that is heard in public. In the recent public consultation about discharges at AWE, any official body representing public health interests has been conspicuously absent. The very least the government can do is to make sure that the perilous future of storing nuclear waste is not only as safe as possible, but is seen to be so. The POST report on public views on radioactive waste accepts that genuine concerns are well founded and have to be taken into account.7

2.9 Framework for the Decision Document

In the final decision document, we would expect to see detailed, sound reasons for MoD decisions, based on the responses to the Consultation. A successful outcome will be complete transparency of the problems and their solutions, achieved through public consensus with the MoD. The way this programme is handled will impact on the wider problem of waste storage. Ordinary people will have to live with the decisions, and they will do so more comfortably if they see that their concerns have been addressed and their warnings heeded.

1. A rational strategy for decommissioning and nuclear waste management". NGO Policy 1988 amended 1993&4.

2. Objection on behalf of the Nuclear Awareness Group. NAG Submission to the Environment Agency   Consultation on AWE Radioactive Discharge Application. Mobbs. P33 para 3.6. November1999

3. The Primacy of Public Health & Safety: The Case for a Public Inquiry on the Atomic Weapons Establishments, AWE  Aldermaston &  Burghfield. NAG. 1st December 1999

4. Present Day Considerations to Ensure Long Term Care in Radioactive Waste Management. Weston. Low Level Radiation & Health Conference July 2000

5. Babcock Rosyth Defence Ltd, (BRDL) Presentation on MoD submarine decommissioning contract. 12 May 2000

6. Judicial Review of the Environment Agency's Radioactive Discharge Authorisation to AWE. R v Environment Agency, ex parte Marchiori & NAG Ltd. High Court, London 12/13/15/January 2001

7.Radioactive Waste – Where next? Parliamentary Office of Science and Technology Committee - the Management of Nuclear Waste. Report No.106 November 1997

NAG Ltd
Nuclear Awareness
Secretary: Pam Vassie
8 Langborough Road
Wokingham
RG40 2BT