Response to Gibraltar Goverment approval for submarine repair

The Gibraltar Government has said that it is not opposed to the repair of HMS Tireless in a statement issued on 14 Sep. Meanwhile there has been substantial opposition to the proposal in Andalusia. The Andalusian Parliament has agreed to oppose the repair and is investigating legal action to stop it. Between 6,000 and 10,000 people took part in a demonstration against HMS Tireless in La Linea on 14 Sep. The Mayors of towns in the area are organising protests in each town next Thursday.

The MoD have said they will make a statement today (15 Sep) in which they are expected to announce when work will start.

Local groups in Gibraltar who are opposing the repair will also be considering what action they will take next.

There are a number of weaknesses in the case presented by the Gibraltar Government and their reassurances should not be taken at face value:

(1) With regard to para 5.1, the length of time since the reactor was shut down is a significant factor, up until the point at which the reactor is started up again. After the reactor is started up there is a substantial increase in the fission products which could be released in an accident. After it has been started up the submarine will remain in Gibraltar for days, probably weeks, while the reactor and crew are tested. This is also the period when an accident is most likely to occur.

(2) With regard to para 5.2, the normal length of a visit to a Z berth is less than a week. The submarine captain, Mike Walliker has told the Spanish press that HMS Tireless is likely to remain in Gibraltar until the end of the year. On this basis it will have been in Gibraltar for over 7 months. Even if the daily risk was 15 per cent of normal, the total risk of the whole visit would be four times greater than for a recreational visit.

(3) With regard to para 5.3, there is a significant risk that coolant will be spilt during the repair. The MoD admitted in a reply to Norman Baker MP in 1998 that submarine reactor coolant had been spilt on 40 occasions between 1980 and 1998 at Faslane, Devonport and Rosyth. On one of thess instances, at Faslane in 1987, almost a cubic metre of coolant was released.

(4) With regard to para 5.5, the report appears to underestimate the substantial risks involved in the final stages of the operation. According "Reactor Accident Course Notes" from the old Greenwich Naval College: "The possibility, though very remote, of a nuclear accident occurring is greatest at X berths since at these berths initial criticality, power range testing of nuclear plant are carried out as well as FAST CRUISE operation for crew training." After the repair is carried out on HMS Tireless these three stages, which are considered the most dangerous, would be carried out:

(a) The reactor would be started up, after being shut down for 6 months and after the repair.

(b) Power range testing involves tests carried on reactor performance with the reactor running, this is the most hazardous stage.

(c) FAST CRUISE is an exercise where the submarine remains at the berth but the crew carry out a series of drills, including simulating emergencies, pretending that they are at sea. The idea is that any failures in individual or team performance of the crew would be identified before the submarine sails. This means that there is a higher risk of something going wrong during FAST CRUISE than at sea. On HMS Tireless the exercise is likely to last for three days.

(5) With regard to para 5.6, the Gibraltar Public Safety Scheme (GIBPUBSAFE) does not provide the protection for children which is required under the guidelines for Iodine Prophylaxis produced by the World Health Organisation, which recommend that Potassium Iodate Tablets should be immediately available to children when the radiation dose to the thyroid is one third of the figure in GIBPUBSAFE. Also GIBPUBSAFE is not an X berth safety scheme, GIBPUBSAFE says that no nuclear repair would be carried out at a Z berth. As para (4) above shows the intention is to carry out on HMS Tireless those hazardous operations which distinguish between a Z and X berth.

(6) The safety assessment should take into account the likelihood of further repairs being carried out in future. The if this repair goes ahead then Gibraltar has effectively been made into an X berth. In the past the MoD have stated clearly that they would not repair a nuclear submarine in Gibraltar. So their recent promises statements that they would not repair one again in future are hollow. The Royal Navy continue to deploy nuclear submarines in the Mediterranean. A reactor defect has resulted in two Swiftsure class submarines being withdrawn from service. There is a significant chance that there will in future be another reactor problem on a British submarine in the Mediterranean.

 

Statement by the Government of Gibraltar relating to the Ministry of Defence’s proposal to carry out repairs to HMS Tireless in Gibraltar.

1. The Gibraltar Government has stated that HMS Tireless should not be repaired in Gibraltar unless the Gibraltar Government, separately advised by an independent panel of experts, was satisfied that carrying out the repairs in Gibraltar pose no risk to public health or the environment Separately the MOD should overcome public concerns and anxieties over this matter.

2. The Government of Gibraltar appointed a panel of experts comprising: (1) Mr Peter Davidson a nuclear safety expert and engineer and an independent member of the Nuclear Safety Committee at Devenport, UK. (2) Mr John Large, a nuclear safety expert and engineer with considerable experience and track record of advising local Governments and environmental organisations and lobby groups. (3) Ove Arup - a leading UK firm of Consulting Engineers. (4) Mr Alan Martin, a nuclear safety and Radiation Protection expert.

3. In assessing whether the carrying out of repairs to HMS Tireless posed risk to the public or the environment, the Government brief to the panel of experts invited them to compare such risks to those which Gibraltar has habitually accepted during all historical nuclear vessel visits to Gibraltar for recreational or operational purposes.

4. The Gibraltar Government has now received the Report of its panel of experts. The panel of experts has confirmed that it has obtained a significant amount of MOD information and documents and is satisfied that this information is sufficient for its purposes. The panel is also satisfied with the quality of the MOD’s work and the underlying safety culture.

5. The panel of experts have unanimously concluded as follows:

(1) The long time since the reactor was shut down means that HMS Tireless is in a safer state than a boat visiting for recreational purposes, and will remain so throughout the repair period.

(2) The repair operations will not introduce any significant new safety risks. The panel accept as reasonable the MOD’s assessment that the daily risk rate during the repairs is just 1 5% of the recreational visit daily risk rate. The panel accept that the daily risk rate posed by HMS Tireless will not exceed and will generally be significantly lower than that from a normal recreational visit.

(3) The water to be removed from the primary circuit and other waste is of low radioactivity. The MOD has adopted good safety practice in their engineered and administrative arrangements for handling and storing it, until it leaves Gibraltar after the submarine’s departure. The panel is satisfied that this activity represents a very low safety risk.

(4) As planned by the MOD the weld repair is very likely to be successful. The remaining uncertainties have no safety significance but may result in programme delay. (This refers to a small possibility identified by the Panel that the small crack which is the source of the leak may extend beyond the weld to the pipe itself If this turns out to be the case the consequence is only delay and has no safety significance).

(5) The Panel consider that the three procedures involved - welding, weld examination and pressure testing - will provide sufficient defence in depth against a defective weld surviving undetected through to the reactor start-up, and conclude that no significant additional safety risks will arise during reactor start-up and operation prior to the departure from Gibraltar of HMS Tireless. (6) The panel considers that the Gibraltar Public Safety Scheme (Gibpubsafe) provides sufficient contingency in terms of emergency planning arrangement for the period of the repairs. The Panel concluded that the proposed repairs do not require an alteration to the Scheme.

6. In these circumstances the Gibraltar Government is not opposed to the MOD’s proposal to carry out the repairs in Gibraltar. If the MOD decide to proceed with the repairs in Gibraltar, it remains responsible for the maintenance of the highest standards of safety to ensure the health and safety of the people of Gibraltar and of our neighbouring region and our environment. It is still incumbent on MOD to ensure that any reasonable public concern and anxiety that remains is assuaged.

7. The Government of Gibraltar considers the repair of HMS Tireless in Gibraltar to be an isolated and exceptional case that creates no precedent. The Gibraltar Government is strenuously opposed to the establishment of Gibraltar as a nuclear vessel repair facility.

8. The incident of HMS Tireless has raised issues about the adequacy of current legislation in the area of public health and safety and issues with a potential to adversely affect them. The Government is to undertake a review of such legislation.

9. The Government is already carrying out, with the help of a specialist UK contractor, regular monitoring of the atmospheric and aquatic environments. These will continue on a constant basis until HMS Tireless leaves Gibraltar.

10. The Government will publish the full report of its panel of experts during the next few days. Given their obvious interest in the matter, and pursuant to the Government’s policy of cross border co-operation, the Government will send copies of the report to Campo Mayors, to the Mancomunidad de Municipios and to the Junta de Andalucia.