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SEPA consultation on nuclear waste from Faslane and Coulport

In 2008 an internal report revealed major shortcomings in how Faslane handles its nuclear waste. [1] It followed a series of accidental discharges of radioactive coolant water into the Gareloch. Now the Ministry of Defence plans to substantially increase the amounts of nuclear waste that will be produced at Faslane and Coulport.

The Scottish Environmental Protection Agency (SEPA) have launched a consultation with proposed changes to the Letters of Agreement which cover nuclear waste from Faslane and Coulport.[2]  Responses to this consultation should be submitted by 20 September to This email address is being protected from spambots. You need JavaScript enabled to view it.   You could use this model letter.

 

Radioactive waste associated with Trident cannot be justified

SEPA should not approve any disposal of radioactive waste which does not comply with the principle of justification - “No practice involving exposure to radiation should be adopted unless it produces sufficient benefit to the exposed individuals or to society to offset the radiation detriment it causes”.[3] Trident is an indiscriminate Weapon of Mass Destruction. It is designed to use radiation to cause harm and not to benefit the lives of individuals or society. 

The consultation document quotes a 2001 court case decision that the “justification test has no application in law to activities of a military nature”.  However, in the case of nuclear waste from Trident, SEPA should not just accept the UK Government’s justification for nuclear weapons but it should take account of the view of the Scottish Parliament, which is opposed to the presence of Trident in Scotland. On 20 March 2013 the Parliament passed a resolution saying, "That the Parliament acknowledges the devastating humanitarian impacts of nuclear weapons; endorses the Secretary-General of the United Nations’s five-point plan for nuclear disarmament; calls on the UK Government to acknowledge the opposition of the Scottish Parliament to nuclear weapons and to the presence of Trident in Scotland, and further calls on the UK Government to explore options for the removal of Trident ahead of the so-called main gate decision in 2016." 

The proposed new limits include gaseous discharges of up to 20Gbq of tritium from the Trident nuclear weapons’ programme at Coulport.  Waste from Trident nuclear submarines will also form a significant proportion of the proposed discharges of solid and liquid waste from Faslane and Coulport.

SEPA should not approve any disposal of radioactive waste associated with Trident nuclear weapons or Trident nuclear submarines.

Timescale of approval and the independence referendum

The consultation is taking place 12 months before the referendum on Scottish independence.  A Yes vote would be likely to have a significant impact on the continued deployment of Trident in Scotland. SEPA should not pre-empt the referendum decision by facilitating the long-term presence of Trident in Scotland.  The new letters of agreement should only cover a limited time period, such as 2014 - 2016.

Proposed discharges assume Trident warheads are upgraded

The proposed discharge limits are based not only on the continued presence of nuclear weapons at Coulport, but also on UK government plans to upgrade these weapons.  The consultation documents say that the Coulport limits take account of the introduction of the Mk4A warhead and a new tritium reservoir.  The Mk4A warhead refurbishment programme is a substantial enhancement of the capability of the Trident nuclear warhead.  The introduction of a new design of tritium reservoir is likely to increase the reliability of the warhead.

SEPA should not approve any disposal of radioactive waste associated with upgrading Trident nuclear weapons.

Proposed increases to limits for Coulport

The proposals include substantial increases in nuclear waste limits for Coulport.  Currently the only solid waste that can be removed from the site is material contaminated with a small amount of tritium. The proposal is to increase this tritium figure by 50 times.  Other forms of solid waste and the disposal of liquid waste from Coulport will be permitted for the first time. 

These changes have been introduced because, in future, the Ministry of Defence plan to maintain and repair submarines inside the Explosives Handling Jetty at Coulport. The consultation documents say that some maintenance work will be moved from Faslane to Coulport “in order to provide for greater operational flexibility”. 

SEPA should not approve any increase in radioactive waste from Coulport in order to provide “greater operational flexibility” for Trident nuclear submarines.

Carrying out submarine maintenance at Coulport will mean that solid and liquid radioactive waste will be transported by road from Coulport to Faslane. This introduces an additional risk, of an accidental discharge during transportation.

SEPA should not approve the increase in radioactive waste from Coulport because moving work from Faslane to Coulport does not result in the Best Practicable Means of handling radioactive waste.

Projected increases in waste produced at Faslane

The quantities of solid and liquid radioactive waste produced at Faslane are projected to rise for a number of reasons.  The Ministry of Defence plans to increase the number of submarines at Faslane from 5 in 2013 to 14 in 2019. Their projections assume that there will be unplanned major repairs which will produce significant amounts of radioactive waste.  Solid waste will arise from the dismantling of the current Radioactive Effluent Disposal Facility.  In addition, a change in the threshold for Cobalt 60 will mean that more material is categorised as radioactive waste.

The increase in liquid waste is not consistent with the September 2008 review which said that “the annual throughput (both in volume and inventory terms) will reduce over time given the improvements in the new PWR2 plant and also the reduction in size of the nuclear submarine fleet”.[4]  Two of the reasons given for increasing the projected quantities of nuclear waste in the consultation document, the increased number of submarines based at Faslane and the decommissioning of REDF, were anticipated in 2008.  It is worth noting that Devonport-based submarines have in the past made frequent visits to Faslane, during which coolant is transferred to shore. The unauthorised discharges at Faslane in 2004 and 2008 were from submarines based in Devonport.

The current letters of agreement for liquid and solid waste from Faslane were agreed in 1993 and 1995 respectively.  These permit disposals at far higher levels than have actually taken place.  The new proposals involve a reduction in permitted levels, even though the actual levels are expected to rise.  This is to be achieved by reducing the headroom between projected and permitted disposals.

Disposal of submarine waste from around the world

The current letters of agreement only cover nuclear waste generated at Faslane and Coulport.  The consultation document proposes a change whereby Faslane will receive any nuclear waste which is produced from British nuclear submarines when in foreign ports.

Radioactive waste handling practice at Faslane

There were unauthorised discharges of radioactive coolant water from submarines at Faslane in 2004, 2007 and 2008. The last of these incidents occurred during the transfer of coolant from HMS Torbay to the Primary Effluent Barge.  Following this, SEPA wrote to the Commander of Faslane, pointing out that the incident “represents a failure by the MOD to act in accordance with a number of conditions set down in our Letter of Agreement”.[5]  In September 2008 a review of waste handling practice at Faslane was carried out.  This showed that the current arrangement did not constitute Best Practicable Means.  The report identified problems with the Radioactive Effluent Disposal Facility (REDF), the Primary Effluent Barge and with the pipe work used to transfer liquid waste.  In addition to these practical problems there were serious failings arising from a lack of suitably qualified and experienced personnel.  The recurring problems were identified as signs of a failure in the safety culture at Faslane.

It is worth noting that annual reports from the Defence Nuclear Safety Regulator in recent years show that the lack of suitably qualified and experience personnel remains the most serious safety issue in the Defence nuclear programme.

The original design life of the REDF expired in 2008. The Ministry of Defence had scheduled to replace it with a new facility. This was delayed until 2010 and then, in 2008, until 2014. In recent years there have been further delays in building the replacement plant.  It is now scheduled to enter service in 2017.  The life of the existing REDF plant has, after upgrading work, been extended until 2020.  The life of the Active Processing Facility (APF), which handles solid waste, has also been extended until 2020.[6]

A report from Babcock in October 2010 noted that SEPA accepted the Life Extension programme for REDF as “Best Practicable Means”. However, Isabelle Watson of SEPA, commenting on this statement, said that “MOD was reminded in 2009 and should be reminded again that the requirement for BPM is one which is dynamic and continual. BPM requires to be kept under review to ensure that the requirement continues to be met”.[7] She also expressed concern about the risks of spillage during the transport of liquid waste to the REDF and the need for details of the new waste facility and proposed replacement Primary Effluent Barge.

While the proposed new letters of agreement would include the movement of liquid and solid waste from Coulport to Faslane there was no specific provision for this is the Safety Justification Plan to support the Life Extension of the REDF and APF until 2020.[8]

In the light of the previous problems of a poor safety culture and the specific problems with the REDF and APF, SEPA should not give an open ended Letter of Agreement for the disposal of radioactive waste while Faslane lacks appropriate facilities to handle this waste in the long term.  They should issue a more restricted temporary Letter of Agreement covering the period during which REDF and APF will be used.  This should be followed by a long term agreement only after the new waste handling facilities are fully operational.



[4] Assessment of arrangements to comply with Best Practicable Means for the handling, movement, processing, storage and disposal of radioactive waste at HMNB Clyde, Faslane. http://www.sepa.org.uk/about_us/access_to_information/access_to_information_files/faslane_and_coulport.aspx

[5] Letter from Byron Tilly (SEPA) to Commodore Hockley (Faslane), 23 May 2008.

http://www.sepa.org.uk/about_us/access_to_information/access_to_information_files/faslane_and_coulport.aspx

[6] Strategy for radioactive waste management at HMNB Clyde – REDF Life Extension, report from Babcock to the Defence Nuclear Safety Regulator, 22 October 2010.

[7] Email from Isabelle Watson (SEPA), 5 October 2011.

[8] Safety Justification Plan to support the Life Extension of the REDF and APF until 2020, HMNB Clyde, 22 March 2012.

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