submarine dismantling project consultation document

8/3/2019 Submarine Dismantling Project consultation document

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Submarine Dismantling Project (SDP)

ConsultationDocument28th October 2011


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Consultation EventsPlymouth Plymouth Guildhall

Sat 12 to Wed 16 Nov 2011Public Exhibition rom 11am to 7pm each day

Workshops are on Sat, Sun & Mon starting: 11.30, 13.00, 15.00, 16.30, 18.00

Fie Carnegie Conerence Centre, DunermlineSat 19 to Wed 23 Nov 2011Public Exhibition rom 11am to 7pm each day


Saltash St Mellion Hotel, St MellionSat 3 to Mon 5 Dec 2011Public Exhibition rom 11am to 7pm each day

Workshops are on Sat & Sun starting: 11.30, 13.00, 15.00, 16.30, 18.00

Torpoint Torpoint Town HallTue 6 Dec and Wed 7 Dec 2011Public Exhibition rom 11am to 7pm each day

Workshops are on Wed 7 Dec starting: 11.30, 13.00, 15.00, 16.30, 18.00

Edinburgh Surgeons HallFri 9 to Mon 12 and Wed 14 Dec 2011 (no event Tue 13 Dec)Public Exhibition rom 11am to 7pm each day


Consultation starts: Fri 28 Oct 2011

Local events:

National workshops (please register to attend):

Closing date or responses: Fri 17 Feb 2012

Birmingham International Conerence Centre, Broad Street, Birmingham, B1 2EATue 31 Jan 2012, 11am to 4pm

Glasgow Scottish Exhibition & Conerence Centre, Exhibition Way, Glasgow,Lanarkshire G3 8YW

Mon 6 Feb 2012 , 11am to 4pm



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GUIDANCE FOR CONSULTEES

Contact Details

For all consultation enquiries, registration ornational and local workshops or to request inhard copy or alternative ormats contact:

Submarine Dismantling ConsultationAsh 1b #3112MOD Abbey WoodBristolBS34 8JH

Email: [email protected]: 030 679 83793

All o the documents produced or thisconsultation and urther background inormationis available on our website at:

www.mod.uk/submarinedismantling

You can submit your response to the publicconsultation by email, online or by reepost:

Rosyth

Devonport

FREEPOST RSKJ-KRAH-YZRJSubmarine Dismantling ProjectC/o Green Issues Communications Ltd30-31 Friar StreetReadingRG1 1DX

Glasgow

Birmingham

Please contact us i you have specic requirementsor this document in alternative ormats


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Peter Lu MPMinister or Deence EquipmentSupport and Technology

I was ortunate to visit Rosyth Royal Dockyard recently,where I was able to tour the ormer HMS Resolution,one o 17 nuclear submarines that have let service withthe Royal Navy and are in afoat storage at Rosyth and

at Devonport Royal Dockyard. Resolution was the UKsrst submarine to be armed with nuclear weapons, andprovided the oundation o our nuclear deterrent rom1969 until 1994, when she was taken out o service.

To see Resolution in the water at Rosyth, and to descendinto her decks and compartments, was to visit a remnanto the Cold War era, but one that retains its relevanceto the modern world. While we look towards the uture,towards new generations o nuclear submarines, such asthe Astute Class and the successor to the Vanguard Class,we must not orget the past and the present, and we musttake action to dispose o our older nuclear submarines.This includes those submarines, such as Resolution, thatcarried nuclear weapons, and those, such as the RoyalNavys rst nuclear submarine, HMS Dreadnought, thatcarried conventional weapons.

I have seen or mysel the excellent condition in whichthese submarines are maintained, which is a testament tothe commitment and the engineering skills o the workersthat built and continue to maintain them. However itis neither sustainable nor practical to maintain themindenitely. We should not leave the problem o disposalor uture generations. The aim o the Submarine

Dismantling Project (SDP) is to deliver a solution orthe disposal o our nuclear submarines, up to andincluding the Vanguard class, when they leave service.It is imperative that this solution is sae, secure andenvironmentally responsible, and that it delivers value ortaxpayers money.

The purpose o this public consultation is to seek yourviews on what this solution might be. The MOD hascarried out detailed analysis and investigated a wide

range o options, and we have used this inormation toreach our view on what we think the solution might looklike. But the solution has not yet been decided upon,and public consultation will play a vital role in helping us

make that decision. One area that we have ocused on inparticular is the potential or harm to the environment, sowe have also published our environmental assessmento submarine dismantling, to allow comment on thisimportant area that many people will understandably beconcerned about.This Consultation Document is the cornerstone o the SDPpublic consultation, and is intended to provide you withinormation in as clear and open a manner as possible,to help you to understand the project and to reach a viewon our proposals. I you are interested in reading moreabout the project, there is a wealth o additional materialavailable in a variety o ormats, rom straightorwardbackground inormation to detailed technical inormation.We are also holding various events where you will have theopportunity to ask questions and to talk to people rom theMOD about your views or concerns.

We are keen to hear your views, so I encourage you to takesome time to read this document, to attend an SDP eventi you can, and to submit your comments using one o themechanisms listed later in this document. It is by gettingthe views o as wide a range o people as possible that wewill reach the right decisions or communities, or deenceand or the uture.

FOREWORD

We should not leave theproblem o disposal or

uture generations


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PREFACE


This Document

The Submarine Dismantling Consultation seeks yourviews on the Ministry o Deences (MODs) proposals

or dismantling the UKs redundant deuelled nuclear-powered submarines and its assessment o anyenvironmental eects it will have.This Consultation Document is at the heart o thisprocess. When read in its entirety, it is intended toprovide the inormation you need to orm your viewsand to respond to the consultation questions. Thereis a eedback orm at the back o this document oryou to use to respond to the questions and to give usyour views about the project. Ater the consultationhas been completed we will publish a report that

summarises the eedback we have received.This document describes our proposals or takingorward the Submarine Dismantling Project (SDP), therationale behind those proposals and our assessmento the environmental eects that will result. Nodecisions will be taken on these proposals until wehave considered all the eedback we receive. Onlythen will the MOD reach its nal conclusions. Asa result, the decisions we make about submarinedismantling may be dierent to the proposals set outin this document.

Other Sources o Inormation

The Non-Technical Summary o the EnvironmentalReport, which has been published alongside thisdocument, summarises the ndings o our StrategicEnvironmental Assessment (SEA). It includes urtherquestions that invite your views on the approach it hastaken and on its ndings.

I you would like urther inormation about the SDP,this is available on our website and at our consultation

events. There are also signposts throughout thisdocument to urther inormation on particularsubjects.

There are dierent levels o inormation availabledepending on your interests: rom Factsheets orthose who want to nd out more about the key topics,through to the detailed studies that have helped us toanalyse the options. The diagram opposite outlinesthe documents that are available.


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Diagramillustratingtheinformationavailableaccordingtothelevel

oftechnical

detailcovered-fromLevel1(this

document)toLevel5(technicalstudies).

PublicConsultationDocumentationHierarchy

Level1 Level2 Level3 Level4 Level5

Consultation

Documentincl.

FeedbackForm

DataReportandOtherStudies

Factsheet9:

International

Perspectives

Factshe

et8:

Regula

tion

Factsheet7:

Managing

Radioactive

Waste

Factshe

et6:

Initial

Disman

tling

Factsheet5:

Environmental

Issues

Factshe

et4:

Radioact

ivity&

Health

Factsheet3:

Transport

Factsheet2:

Decis

ion

Process

Factsheet1:

Historyof

Project

Operat

ional

Analy

sis

Supporting

Paper

SEA

Non-Technical

Summary

SEA

Environmental

Report

Investment

Appraisal

Operat

ional

Effectiveness

Report

Other

Contributory

FactorsReport


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CONTENTS


SUMMARY OF CONSULTATION EVENTS

GUIDANCE FOR CONSULTEES

FOREWORD

PREFACE

1 INTRODUCTION 9

2 SCOPE OF THIS CONSULTATION 11

3 BACKGROUND TO NUCLEAR SUBMARINES,RADIOACTIVE WASTE AND REGULATION

13

4 THE SUBMARINE DISMANTLING PROJECT 18

5 SUBMARINE DISMANTLING ACTIVITIES ANDFACILITIES

22

6 CONSIDERING THE OPTIONS 30

7 OUR CURRENT ASSESSMENT 39

8 OUR PROPOSALS FOR CONSULTATION 46

9 NEXT STEPS 50

10 SUMMARY 52A GLOSSARY 56

B OTHER SOURCES OF INFORMATION 58

C THE SEVEN CONSULTATION CRITERIA 59

D QUESTIONS & FEEDBACK FORM 60


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INTRODUCTION

1


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IntroductionThis chapter describes the context o this Consultationprocess.

1.1. What is this consultation about?

1.1.1. This public consultation seeks your views onthe Ministry o Deences (MODs) proposalsor dismantling deuelled nuclear-poweredsubmarines and or saely managing theradioactive waste that this generates.

1.1.2. The Royal Navys submarines have a service lieo around 25 years. Currently, when a submarineleaves service it is stored afoat and regularly

maintained to preserve it in a sae condition.There are a total o 17 submarines currently beingstored in this way in the UK, the oldest o which,the ormer HMS Dreadnought, let service30 years ago.

1.1.3. All the Royal Navys submarines are powered bynuclear energy because it allows them to carry outmilitary operations over thousands o miles whileremaining submerged, helping them tostay undetected.

1.1.4. As a responsible nuclear operator, the MOD takes

its duty seriously to manage the submarines, bothduring and ater their service lives. Identiying asae, environmentally responsible, secure and costeective solution to dismantle these submarines,ater they have let service and been deuelled, isthe aim o the Submarine DismantlingProject (SDP).

1.1.5. We will use the eedback we receive during theconsultation period to help inorm our analysiso the various options that are available. Thisconsultation has been timed to ensure it takes

place when there is the opportunity or your viewsto infuence the MODs uture decisions.

1.1.6. Submarine dismantling, like any work involvingradioactive material, will be closely regulated bya number o independent bodies, including theOce or Nuclear Regulation and the EnvironmentAgency (EA) / Scottish Environment ProtectionAgency (SEPA), to ensure it is conducted in a sae


and environmentally responsible way. We mustalso obtain approval rom local planning authoritiesor the dismantling acilities that will be neededbeore any dismantling can start.Applications or planning and regulatory approvalcan only be made ater the MOD has madedecisions about what acilities will be needed andwhere they will be located.

1.1.7. This Consultation Document and the associatedset o Factsheets aim to help you to understandmore about submarine dismantling, to give youthe inormation you need to orm your views.Questions are posed throughout this document,the answers to which will help us to understandyour thoughts on particular subjects. These are

repeated at the end.

INTRODUCTION


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SCOPE OF THISCONSULTATION

2


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practices or managing much o the waste that willbe produced.

2.3.2. The MOD has established processes or disposingo ex-Royal Navy ships using existing ship

recycling acilities. Once the radioactive materialhas been removed rom a submarine, it is ourintention to dispose o the hull at an existing shiprecycling acility in the UK that has the necessaryenvironmental licence.

2.3.3. We are not, thereore, consulting on these routineactivities, although their environmental impactsare considered within the SEA. In some casesthese activities may be subject to consultation at alater stage as part o applications or planning orregulatory approvals.

2.4. How are we consulting?

2.4.1. The ormal consultation period began on 28October 2011 and will close on 17 February 2012.There are a number o ways or you to get involved:

Online: All the inormation that has been publishedas part o this consultation is available online atwww.mod.uk/submarinedismantlingwhere you can also submit your eedback.

By post: I you wish to request paper copieso the documents, or submit your eedbackby FREEPOST, contact details are on the insideront cover.

Local events: Events are being held in and aroundDevonport and Rosyth, where the candidate sitesor initial dismantling are located. Members othe MOD project team will be available to answerquestions and discuss any concerns you may have.Workshops will also be held during these eventsat which you can talk in a group with others anddiscuss issues in detail. Details o these events are

on the inside ront cover.

National workshops: Two larger workshops, whereissues can be discussed in detail, are being heldone in Birmingham and one in Glasgow. Whilethey are open to everyone, these workshopsare designed or those who have a strategic orspecialist interest in the project, or examplerepresentatives o special interest groups, localauthorities, industry, statutory bodies and othergovernment departments. Details o these events,and contact details to register, are on the inside

ront cover.

SCOPE OF THIS CONSULTATION

IntroductionThis chapter describes the questions on which we areconsulting, the ways in which you can get involved in theconsultation and the inormation that is available.

2.1 Why are we consulting?

2.1.1. We recognise that there is keen public interestin how and where we dismantle our nuclearsubmarines and that the public should havecondence in the solution that is chosen. This iswhy we are seeking your views on our proposalsthrough this public consultation. Consultation onour assessment o the environmental eects osubmarine dismantling is also an important parto the ormal process o Strategic EnvironmentalAssessment (SEA) that we are carrying out. This

is the third round o public consultation that hasbeen conducted on dismantling submarines (moreinormation about the previous consultations isavailable in the document SDP - Our Approach toPublic and Stakeholder Engagement), which can beound on our website.

2.2. What are we asking you?

2.2.1. This consultation seeks your views on the three keydecisions that need to be made about submarinedismantling:

How the radioactive material is removedrom the submarines;

Where we carry out the removal o theradioactive material rom the submarines;and

Which type o site is used to store theradioactive waste that is awaiting disposal.

2.2.2. There are a number o potential answers to each othese questions. No decisions will be taken untilater we have considered the responses to thispublic consultation.

2.2.3. We are also seeking your views on our assessmento the environmental eects o submarinedismantling as set out in the EnvironmentalReport.

2.3. What we are notconsulting on

2.3.1. Much o the work involved in submarinedismantling is similar to work that is alreadycarried out routinely during submarinemaintenance activities, and there are established


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BACKGROUND TONUCLEAR SUBMARINES,RADIOACTIVE WASTE ANDREGULATION3


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IntroductionThis chapter briefy describes how submarines workand explains where radioactive materials come rom in a

submarine. It explains dierent types o radioactive wasteand how they are managed. It also introduces the role othe independent regulatory bodies in providing assurancethat activities involving radiation are conducted saely.

3.1. About nuclear submarines

3.1.1. In the past, the UKs submarines were poweredby diesel uel which charged their batteries. Thisrequired them to surace regularly or air. Today,

3.1.2. There are two types o nuclear-poweredsubmarine; one carries nuclear weaponsand one does not.

Fleetsubmarinesaredesignedto counter enemy submarines andsurace ships, conduct surveillanceand intelligence-gathering tasks andother covert operations. They do notcarry nuclear weapons.

Ballisticmissilesubmarinescarrylong-range missiles with nuclearwarheads that provide the UKsstrategic nuclear deterrent.

3.1.3. The nuclear energy that powers thesubmarine is created by a nuclearreactor (using a type o reactor calleda Pressurised Water Reactor). Thenuclear uel is contained in a robustmetal chamber called a Reactor PressureVessel (RPV). The RPV is housed withina Reactor Compartment (RC), which is arobust metal enclosure that is designed toprevent radiation rom escaping, protectingthe crew inside the submarine and theenvironment outside. The RC is,in eect, the central section othe submarine (as illustrated inFigure 1 (below)).

BACKGROUND TO NUCLEAR SUBMARINES,RADIOACTIVE WASTE AND REGULATION


A nuclear submarine is onethat is powered by nuclearenergy; not all nuclear

submarines carry nuclearweapons.

Figure 1: Illustration o aTraalgar Class Submarine.Crown copyright (courtesyo Navy News]

all Royal Navy submarines are powered by energyrom nuclear reactors. Nuclear reactors producetheir power without air and do not need to suracerequently, meaning they can operate underwateror thousands o miles. This is a huge advantage toa submarine, whose primary purpose is to operateundetected beneath the surace o the sea.

ReactorCompartment


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Figureto scale

Figureto scale

A Reactor Compartment during thebuilding o a submarine.

When a submarine leavesservice all weapons areremoved beore they arestored aoat.

Royal Navy Submarines displace between5,000 tonnes (o water) or the Traalgar Class

and 16,000 tonnes or the Vanguard Class.

An RPV is typically 2.5 3 metres indiameter, 4 metres high and weighsbetween 50 and 80 tonnes.

An RC is typically 10 metres in diameter, 9metres long and weighs around 700 tonnes.

RPV inside RC

A Reactor Pressure Vessel

Figure toscale

Figure 2: Scaled illustrations o Reactor Compartmentand Reactor Pressure Vessel


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SDP will dismantleonly deuelled nuclear

submarines

3.2. What is radioactive waste?

3.2.1. Radioactive materials must be careully managedto minimise the hazard they pose to people andthe environment. The radioactive materials in anuclear-powered submarine include the nuclearuel itsel and some components that have becomeradioactive through the operation o the reactor.

3.2.2. Ater submarines leave service the nuclear uelis removed and taken or storage at the nationalacility in Sellaeld, Cumbria - this is not part othe SDP but is an existing activity that has takenplace at Devonport Dockyard or many years andwill continue in the uture.

3.2.3. Almost all the remaining radioactivity in thedeuelled submarine is inside the steel o theRPV itsel. The majority o this is within solidmetal so there is very little potential or spreadingradioactive contamination (as may be the case withgases or liquids).

3.2.4. Once dismantling begins, these components willbe classed as radioactive waste. The radioactivewaste that will result rom submarine dismantling

is categorised into two levels, depending onthe amount o radioactivity it contains and eachcategory is managed in dierent ways:

Low Level Waste (LLW)LLW includes items such as ventilation ducting,drains, pipework, protective clothing andequipment that has come into contact withradioactive material. Facilities or the disposalo LLW already exist, such as the LLW Repositoryin Cumbria.

To fnd out more, see theFactsheet: Radioactivity andHealth

Factsheet://


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Intermediate Level Waste (ILW)Typically, ILW comes mainly rom nuclear powerplants. It has radioactivity levels exceeding theupper boundaries or LLW. ILW on the deuelledsubmarines comes mainly rom components thatwere close to the uel. There is no disposal routecurrently available or ILW so it must be storeduntil it can be disposed o in the UKs proposedGeological Disposal Facility (GDF)

( see section 3.3).

3.2.5. In addition to the two types o radioactive wastethat will be generated by submarine dismantling,there is an additional category o High Level Waste(HLW), which generates signicant heat and hasto be cooled continuously. The SDP will generateno HLW.

3.3. Geological disposal o ILW

3.3.1. The UK plans to develop a Geological Disposal

Facility (GDF) or the disposal o ILW and HLW, byaround 2040, but a site has not yet been identied.Geological disposal involves isolating the wastedeep inside a suitable type o rock to ensure that noharmul quantities o radioactivity ever reach thesurace environment.

3.3.2. The UK Governments policy1 or geologicaldisposal o these wastes was developed ollowing athorough review by the Committee on RadioactiveWaste Management (CoRWM) and is set out in theManaging Radioactive Waste Saely (MRWS) WhitePaper2. The Nuclear Decommissioning Authority(NDA) is responsible or implementing geologicaldisposal on behal o the Department or Energyand Climate Change (DECC). The MOD, DECC andthe NDA have been working together to ensure thatthe plans or the GDF take into account the need toinclude radioactive waste rom submarines.

3.3.3. Until the proposed GDF becomes available, allILW must be stored in purpose-built interimstores that ensure it is managed saely. It isthis interim storage solution which the SDPmust establish or the storage o the ILW rom

dismantled submarines.

3.4. How are nuclear activities regulated?

3.4.1. All nuclear and radiological work in the UK isclosely regulated and is undertaken by licensedor authorised operators, whether it is carried outin the public or private sector. The independentbodies that regulate nuclear activities ensurethat saety remains a top priority, and saety isparamount in all the MODs nuclear activities.

3.4.2. Government Departments, regulators and siteoperators all work together to ensure thatstringent standards o saety are set and thenachieved. Radiation doses are strictly controlled orboth workers and members o the public, and therisk o accidents occurring is careully assessedand reduced to an absolute minimum.

3.4.3. The MOD is responsible or the sae managemento all its nuclear activities but it does not operate inisolation. Equivalent standards o regulation apply

to both MOD and industry.

3.4.4. The regulators which authorise and monitornuclear activities to ensure they comply with thesestandards and principles include:

OfceforNuclearRegulation(ONR)anagency o the Health and Saety Executive

EnvironmentAgency(EA)/ScottishEnvironment Protection Agency (SEPA)

DepartmentofTransport(DfT)(forthetransport o radioactive materials)3

DefenceNuclearSafetyRegulator(DNSR)

3.4.5. Submarine dismantling plans will be assessedor saety and ully controlled at every step o theprocess. The plans will be ully examined andendorsed by these bodies beore any work begins;the implementation will then be monitored toensure that it is carried out saely and eectively.

For more inormation aboutthe regulators and how theyapply to SDP see the Factsheet:Regulation

Factsheet://

1

Scottish Government policy or ILW diers rom the policy in England and Wales and is or long-termmanagement in near-surace, near-site acilities. It is not, however, applicable to waste arising romdecommissioning o out-o-service nuclear submarines.2http://mrws.decc.gov.uk3DTs Radioactive Materials Transport Team is currently in the process o being merged into ONR.


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THE SUBMARINEDISMANTLING PROJECT

4



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THE SUBMARINE DISMANTLING PROJECT

submarines by 2020, by which time a dismantlingsolution needs to be in place or the MOD will haveto invest in creating more berthing space4.

4.1.4. Submarine dismantling is an established activityin other countries, including France, the USA and

Russia. These countries have proven that saelydismantling submarines is practicable, paving theway or the UK to uphold its policy commitmenttoundertakedecommissioninganddisposalactivitiesassoonasreasonablypracticable5.

4.2. What materials and waste will result romdismantling and where will it go?

4.2.1. A variety o materials and waste result romsubmarine dismantling; these include steels andother metals, hazardous waste (such as asbestos),

a wide variety o non-hazardous waste andradioactive waste. The radioactive waste includesLow Level Waste (LLW) (such as contaminatedpipework) and Intermediate Level Waste (ILW)which is in the orm o steel that has becomeradioactive in the Reactor Pressure Vessel (RPV).Figure 3, let, shows the approximate amount oeach material or waste resulting rom dismantlinga Traalgar Class submarine.

For more inormation onsubmarine dismantling in othercountries see the Factsheet:International Perspectives

Factsheet://

IntroductionThis chapter introduces: why we need to dismantlesubmarines; what materials and waste will result andwhere they will go; the requirements and the scope o theSDP; and the benets and impacts o the project.

4.1. Why do we need to dismantle thesubmarines?

4.1.1. The MOD takes its duty to manage the legacy oout-o-service submarines seriously. We believethat developing a solution now, rather than leavinguture generations to do so, is the responsiblecourse o action.

4.1.2. Ater they have let service, submarines arecurrently stored afoat at Devonport and

Rosyth Dockyards where they undergo regularmaintenance to keep them in a sae condition.While this has proved to be an acceptablearrangement or over 30 years, the cost to thetax-payer o maintaining them saely is risingsignicantly as they age and as more submarinesleave service.

4.1.3. A total o 17 submarines are currently stored inthis way, which is steadily increasing over time.We expect to reach our capacity to store urther

90%Steel and other recyclablematerials (3834 tonnes)

5% Non-Radioactive HazardousMaterials (190 tonnes)

4% LLW (176 tonnes)1% ILW (50 tonnes)

Figure 3: Estimated Material Quantities or a dismantled TraalgarClass submarine (total dead weight 4250 tonnes).

4

Seven out-o-service submarines are stored at Rosyth Dockyard and 10 are at Devonport Dockyard.All submarines leaving service in uture will be stored at Devonport awaiting dismantling; no urthersubmarines will be stored at Rosyth.5The Decommissioning o the UK Nuclear Industrys Facilities Amendment to Command 2919, DTIPaper, September 2004.


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4.2.2. In approaching the dismantling o submarines,the MOD will apply the principles o the wastemanagement hierarchy shown in Figure 4 below.

4.2.3. Components and materials that are re-useableon other submarines are removed in preparingthe submarines or afoat storage. Up to 90%(by weight) o the materials rom the dismantledsubmarine will be recyclable, notably the highquality structural steel that makes up the hull.Established and approved disposal routes alreadyexist or hazardous and non-hazardous wastesthat are not recyclable. Similarly, we will useestablished disposal routes or LLW in accordancewith the UKs LLW Strategy6.

4.2.4. Crucially, it is only ILW that does not have anestablished disposal route and thereore mustbe stored until the proposed Geological DisposalFacility (GDF) is available.

INCREASINGPREFERENCE

4.3. Project objectives

4.3.1. The MOD established the SDP to dismantle27 deuelled submarines, including all the 17currently stored afoat and a urther 10 yet to leaveservice (up to and including the Vanguard Class).Dismantling o the new Astute Class, currentlybeing brought into service, and the next planned

class o submarine (known as Successor) willbe subject to uture decisions and are not withinthe scope o the SDP. Nevertheless, the proposedsolution is required where possible, to retain thefexibility to extend acilities in the uture should adecision be taken to accommodate urther classes.

4.3.2. The project was established in 20007 ollowing astudy by the MOD, which concluded that the ILWrom the submarines should be stored on land.It is a long-term project, extending or 60 years,rom the development o a solution to the eventualdecommissioning and disposing o acilities built

or submarine dismantling when they are no longerrequired. Figure 5 illustrates the timeline o theproject and highlights past and uture milestones.

6UK Strategy or the Management o Solid Low Level Radioactive Waste rom the Nuclear Industry available at: www.nda.gov.uk/7The project was ormerly called Interim Storage o Laid Up Submarines (ISOLUS).It was renamed the Submarine Dismantling Project in 2009 to better refect its objectives.8MOD Nuclear Liabilities Management Strategy 2011, available at www.mod.uk/

The estimated amountof ILW from all 27submarines is less than0.2% by volume of the UKstotal inventory of ILW.

For more information see theFactsheet: History of Project

Factsheet://

Figure 4: Waste Management Hierarchy

4.3.3. The project contributes to the delivery o the MODswider Nuclear Liabilities Management Strategy8.Its objectives have been set out ormally by theMOD, in a way that can be monitored and measuredto ensure they are met as eectively as possible.In summary, the SDP is required to dismantle 27nuclear submarines: Inasafe,secureandsustainablemanner;

Costeffectively;

By2050;

Withoutexceedingthecurrentsubmarinestorage capacity;

UpholdingMODsreputationasaresponsiblenuclear operator;

StoringILWuntiladisposalrouteisavailable;

Disposingofallotherradioactive,hazardousand non-hazardous waste in accordance withlegislation; and

Minimisingimpactuponmilitarycapability.

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4.3.4. In the long-term, the major benet o dismantlingsubmarines is to remove a legacy that wouldotherwise be a burden to uture generations anda growing nancial liability to the taxpayer. Thedecision-making process that we are ollowing isintended to maximise these benets.

4.3.5. We accept, however, that there will beenvironmental impacts associated with submarine

dismantling. Some o these will be temporary innature (such as the nuisance or disruption causedby construction work or new acilities) whileothers may endure or the lie o the project (suchas the use o land or storage acilities or routinepermitted discharges rom dismantling activities).The objective or the MOD is to minimise theseimpacts as best we can.

4.3.6. For the purpose o developing the requirementsand criteria o the project, the MOD hascategorised the higher level benets and impacts

in terms o:

Environmentalandsafetyachievinglongterm environmental benets, such as dealingwith the stored submarines, while minimisingthe environmental and saety impacts.

Publiccondencethepublicviewofsubmarine dismantling activities andoutcomes and the MODs reputation as aresponsible nuclear operator.

Figure 5: Key past and uture milestones o the Submarine Dismantling Project. (Not to scale)

What are your views on theoverall objectives or dismantlingsubmarines that have letservice?

Q1

Socio-economicbenetsforandimpactson local communities, such as sustainingjobs in the long-term but potentially causingdisturbance through construction in theshort-term.

Operationsbenetsforandimpactsondeence capability and operations, such asavailability o berthing space or docks orsubmarine maintenance.

Legislationandpolicycompliancewith legislation and implementation ogovernment policy.

1998ConceptPhase

Commenced

2000Project

Established& Front EndConsultation

(1st Consultation)

2012Submarine

DismantlingConsultation

(3rd Consultation)

Decision PointILW

Storage Site

BeginDismantling

2040Earliest

Availability OfGDF

(Planning Date)

2003 CIOP(2nd consultation)

Decision PointDismantling Sites,

Methodology &ILW Storage

Option Demonstrator

2020 BerthingCapacity For

Afloat StorageReached


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SUBMARINEDISMANTLING ACTIVITIESAND FACILITIES5



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SUBMARINE DISMANTLING ACTIVITIES AND FACILITIES

For more inormation see theFactsheet: Initial Dismantling

Factsheet://

IntroductionThis chapter introduces the dierent activities andacilities that will be required to dismantle submarines

and any implications they may have or people, or or theenvironment, in normal operation. It also gives exampleso the saety measures that will be used to saeguardagainst an accident or other harmul event duringdismantling.

The activities involved in dismantling a submarine areillustrated in Figure 6 (overlea).

5.1. Removing the radioactive materials romthe submarines (Initial Dismantling)

5.1.1. The rst activity known as initial dismantling,is to remove the radioactive materials rom thesubmarine. While almost all these materialsare conned to the Reactor Compartment (RC),the whole submarine will be checked and anycontaminated materials will be removed. There arethree options or removal o radioactive materials.These are explained in the next chapter but, in eachoption, the intended result is that the submarine iscleared o radioactivity (to below regulatory limits)so that the hull can be sent or ship recycling (see5.7). The resulting Low Level Waste (LLW) will bedisposed o to an existing licensed acility (see 5.4)

and the Intermediate Level Waste (ILW) will need tobe suitably packaged ready or interim storage.

5.1.2. Most o the acilities needed or initial dismantlingcan already be ound at a nuclear licenseddockyard. These include docks, cranes, litingequipment and buildings that will support thesubmarine while it is out o the water during workto remove and contain the radioactive materialsinside. We estimate that it will take about 12months to dismantle a submarine but there maybe opportunities to do it more quickly i this were

shown to be easible and cost eective.

5.1.3. Any negative environmental eects arisingrom SDP work will be identied and limited.Dismantling work is unlikely to increase radioactiveor non-radioactive discharges into the environmentabove the current permitted levels; any proposalto do so would require new permissions to begranted by the Environment Agency or ScottishEnvironment Protection Agency. Cutting thesubmarine hulls is not expected to raise the overall

5.1.4. Any eects on the environment will largely be aresult o the construction that is required to extendexisting acilities or build new ones. As with anyindustrial development, these may include noiseand vibration rom building works, waste romconstruction or demolition, dust and umes, andan increase in lorry movements. Since most othe acilities are already in place, the need orconstruction will be limited and thereore so willthe environmental eects.

5.2. Size-reduction o the

Reactor Pressure Vessel5.2.1. Size-reduction is the process o cutting radioactive

waste up into smaller pieces so that it can bepackaged into boxes or disposal. Size-reduction isan established process in the civil nuclear industry.It is routinely used in the decommissioning onuclear power plants including Reactor PressureVessel (RPV) components.

5.2.2. The ILW contained in the RPV will eventually bedisposed o in the proposed Geological DisposalFacility (GDF). Current plans or this acility

suggest that the RPV is too big to be disposedo whole and will have to be size-reduced andpackaged in approved containers. This couldbe done beore it is put into interim storage oraterwards (just beore it is sent or disposal).Importantly, the design o the proposed GDF isnot yet nalised and, i plans change, it may bepossible to dispose o the RPV whole, withoutsize-reduction.

noise levels at the dockyards signicantly. Positiveeects include sustaining existing skilled jobsin the dockyard or dockyards and resolution o alegacy issue which MOD has been exploring orsome time.


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5.2.3. The acilities required or size-reduction wouldinclude a building in which the RPV could becut saely into smaller pieces and packagedor storage. Cutting the RPV exposes the moreradioactive material inside, so this building wouldrequire remote handling (where the worker doesnot come into contact with the materials) and

shielded areas where cutting work could be donewhile protecting workers rom exposure. Thisbuilding would also require decontaminationacilities to remove radioactivity rom the suraceso items that had become contaminated by thecutting process. There will also be some LLWcreated during the size-reduction o RPVs and thiswill be saely disposed o (see section 5.4).

5.2.4. Any environmental eects will mainly beassociated with construction, so the range oenvironmental eects will be similar to those or

initial dismantling, described above. Unlike initialdismantling though, the acilities needed or size-reduction do not currently exist at the dockyards,so new acilities would need to be built.

5.3. Storing ILW that is awaiting disposal

5.3.1. The ILW resulting rom initial dismantling must bestored until the proposed GDF is ready to acceptit or disposal. The current planning date or theproposed GDF to begin receiving waste is 2040 but,as it will receive waste rom a number o othersources, it may be many more years beore it isready to receive ILW rom SDP. Storage acilitieswill thereore be designed to saely and securelyhold waste or up to 100 years, to protect againstany changes to the GDF timescales, in line withCoRWMs recommendations (see section 3.3).

InitialDismantling

ShipRecycling

EstablishedDisposal

Routes or

HazardousWaste

RecycleMaterial DISMANTLING

PROCESS


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5.3.2. One or more buildings would be needed to storeILW and these would have to provide the requiredlevel o shielding, containment, security andprotection. The design o the acilities will dependon the container in which the ILW is being stored.There are a number o existing and planned ILWstorage acilities in the UK that may be suitable,

but it may be necessary or preerable to developnew ILW storage acilities or SDP (see section 6.5).

5.3.3. The environmental eects o storing ILW aredirectly associated with the construction o theacility, as described in section 5.1.4, and theamount o land lost to the building itsel. The scaleo the eects depends on the size o the acility,which in turn is dictated by the size o the ILWcontainer. Once the ILW is saely stored, it will bepassively sae, meaning that the operators o the

store can keep a watchul eye to ensure that theradiation is contained. The only additional wastecreated will be domestic reuse (rom guarding thesite) and rom routine building maintenance.

GeologicalDisposalFacility

IntermediateLevel Waste

Interim Storageor Intermediate

Level Waste

Low Level Waste

& Very Low LevelWaste

EstablishedDisposal Routes

Figure 6: Dismantling Process

For urther inormation aboutILW storage, see the Factsheet:Managing Radioactive Waste

Factsheet://


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5.4. Disposing o Low Level Waste

5.4.1. The LLW resulting rom dismantling must bedisposed o at a licensed acility such as the LowLevel Waste Repository in Cumbria. Disposal oLLW is already carried out routinely by the nuclearindustry in the UK in accordance with the UK LLWStrategy. Prior to disposal, ollowing the principleso the waste management hierarchy (Figure 4),

LLW may be treated to enable materials that havebeen decontaminated to be recycled, thereoreminimising the volume o waste that must bedisposed o. Established, licensed commercialservices are available or the treatment o LLWprior to disposal; these are already used in themanagement o LLW generated duringthe maintenance o submarines while theyare in service.

5.4.2. The acilities required or disposing o LLW wouldinclude one or more buildings in which LLW

could be packaged in approved containers. Fromhere it would be dispatched or treatment (whereappropriate) and disposal. Such acilities wouldincorporate the required shielding, containment,security and protection. They can already be oundin nuclear licensed dockyards, although someurther development may be needed or the SDP.

5.4.3. The environmental eects o operating licensedLLW disposal acilities are outside the scopeo the SDP, but these are well understood andare eectively minimised through the licensingconditions imposed by the regulators. There are nosignicant environmental eects rom dispatchingLLW rom the dockyards or disposal; this isroutine business and is closely regulated to preventany damaging eects.

5.5. Transporting submarines

5.5.1. The submarines will be transported by sea i theyneed to be moved rom where they are storedafoat to the initial dismantling site. This will not benecessary i both Devonport Dockyard and RosythDockyard sites are used or initial dismantling.

Out-o-service submarines can be moved usinga number o methods including towing thesubmarine, towing a barge with the submarineon it or using a heavy lit ship. Submarines willbe docked or additional maintenance prior totransport to ensure they are seaworthy. Followingthe removal o the radioactive materials, it will alsobe necessary to move submarines rom the initialdismantling site(s) to the ship recycling acility.Although the modes o transport are similar,transporting submarines beore the radioactivematerials have been removed would involve

additional saety measures and regulation.

5.5.2. The acilities required or transporting submarinesinclude the docks, cranes, liting equipment andbuildings needed to maintain them and ensure theyare seaworthy.

5.5.3. A suitable dock, port or harbour is needed to loadsubmarines on to a barge or heavy lit ship, or totow them and similarly to ofoad and / or moorthem at their destination. Most o these acilities

can be ound at a nuclear licensed dockyard.

5.5.4. Transporting intact submarines between existinglicensed sites has very ew environmental eects,beyond those o the exhaust emissions o thetransport and escort ships. I, however, the RC hasbeen separated rom the submarine leaving theseparated ront and rear sections, these cannot betowed and they will have to be transported by bargeor heavy lit ship or which deep water is required.Depending on the site, this may require additionaldredging o the sea bed which could impact the

marine environment.

5.6. Transporting radioactive waste

5.6.1. Radioactive waste removed rom the submarineneeds to be transported in approved containersor disposal or or storage awaiting disposal.Depending on the size and type o container used,this could be by sea, road or rail.

5.6.2. The acilities and inrastructure required totransport waste may include docks, ports orharbours, rail-heads or access roads, dependingon the methods chosen, as well as buildings toprepare waste or dispatch or to receive waste orstorage. The acilities needed to dispatch LLW canalready be ound in a nuclear licensed dockyard.Development o new acilities may be needed todispatch ILW but this will depend on the size andtype o container and the mode o transport.

5.6.3. Radioactive waste is already transported regularlyin the UK by road, rail and sea. It is closelyregulated by a number o bodies including theDepartment or Transport and the Deence

Nuclear Saety Regulator. UK legislation sets strictrequirements or the sae transport o radioactivewaste including; the types o transport packageallowed; how much radioactivity they can contain;and how they must perorm in specied teststo prove their integrity in the unlikely event o atransport accident.

5.6.4. The mode and requency o transport neededto move ILW that has been removed rom thesubmarines will depend on a number o actors,including the method o initial dismantling adopted

and the location o the storage site.


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5.7. Ship recycling

5.7.1. Following the removal o radioactive material (theinitial dismantling activity) the submarine canbe transported to a commercial ship recyclingacility within the UK. Here the hull will be brokenup and dealt with in accordance with the wastemanagement hierarchy (Figure 4, section 4.2).The recycling acility will require the relevant

environmental permits and all materials, includinghazardous and non-hazardous materials, will bemanaged through established and approved routes.Ship recycling will be conducted in accordance withthe UK Ship Recycling Strategy (2007)9.

5.7.2. There are a number o existing ship recyclingacilities in the UK that would be suitable ordismantling submarines, once the submarine iscleared o radioactivity to below regulatory limits. Itis not our intention to develop a new ship recyclingacility or the SDP.

5.7.3. The acilities required or ship recycling includethe docks, cranes and the space needed to supportthe submarine out o the water, separate and sortthe materials and then dispatch the various non-radioactive materials or recycling or disposal.

5.7.4. The recycling o submarines will be very similarto the recycling o surace ships because thenon-radioactive materials involved are verysimilar. This includes large quantities o valuablemetals like copper, lead and steel. Like surace

To fnd out more about all aspectso transport, see the Factsheet:Transport

Factsheet://

9UK Ship Recycling Strategy, February 2007 available at www.dera.gov.uk/environment/waste/business/ship-recycling10Assessment o Plans and Programmes Regulations 2004

ships, submarines also contain some hazardousmaterials such as oils and lubricants, asbestos andheavy metals. These will be careully managed bythe ship recycling acility through approved routesand will be recycled wherever possible.

5.7.5. The MODs Disposal Services Authority (DSA),which is responsible or the sale or disposal o allmilitary equipment that is surplus to requirements,

will manage the process o contracting a shiprecycling acility on behal o the SDP. The DSAhas proven experience in managing the recyclingo Royal Navy surace ships and a proven recordo minimising waste sent to landll, consistentlyrecycling more than 95% o the material in thesurace ships that are broken up.

5.8. Assessing the environmental eects

5.8.1. One o the key objectives o the SDP is to ensure

that submarine dismantling is carried out in aresponsible way that minimises environmentalimpacts and takes advantage o opportunities toimprove the environment.

5.8.2. In order to understand the environmentaleects o each stage o submarine dismantling,some o which are described above, the MODhas commissioned a Strategic EnvironmentalAssessment (SEA). An SEA is a ormal and legally-dened process10 that looks at what the signicantenvironmental eects o a programme might be,so that these can be taken into account as the

options are developed and beore major decisionsare made.

5.8.3. The potential environmental impacts that couldoccur at all the stages o the project, includingpossible impacts on communities and health havebeen assessed as part o the SDPs SEA. Theresults o the SEA, including recommendationsor ways to avoid or minimise them, have been edinto the wider assessment o the options which issummarised in Chapter 7.

More inormation about the DSAand its experience o managingship recycling projects is availableat www.edisposals.com

Online Inormation://

5.6.5. The transport o radioactive material is closelyregulated to minimise any oreseeable saetyand environmental risks and has very ewenvironmental eects beyond those o the exhaustemissions rom transport. I the packages arelarge, moving them by road may cause some localdisruption to trac, as would be expected or anyoversized load.

5.6.6. Transporting the ILW rom the storage acility tothe proposed GDF when it is available also allsunder the scope o the SDP.


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5.8.4. An important part o the SEA is to give the publicthe opportunity to understand and comment onthe eects that the SDP may have on them or theircommunity, and to suggest any improvements. Weare seeking your views on the SEA as part o thispublic consultation. The Non-Technical Summaryand the Environmental Report itsel pose a serieso questions or your eedback. (These questionsare reproduced at the back o this document.)

5.8.5. Following public consultation, the responsesreceived on the SEA will be used, alongside allthe consultation responses, to inorm the MODsrecommendations about the way orward. Inecessary, the SEA will be updated and urtherassessments undertaken. Once the initialdismantling site(s) have been selected, detailedsite-specic environmental assessments will becarried out as required or planning andregulatory applications.

5.9. What are the possible accidents that

could happen?5.9.1. There is no risk o a nuclear reactor accident as a

result o submarine dismantling because there isno nuclear uel (ssile material) involved.Almost all o the radioactivity in the deuelledsubmarine is xed within solid metal insidethe RPV so the risk o accidental release oradioactivity is extremely small.

To fnd out more about theSEA and the results o theassessments, see the Factsheet:Environmental Issues or read theNon-Technical Summary o theEnvironmental Report and the ullreport itsel

Factsheet://

5.9.2. Beore any activities can begin, a saety case mustbe prepared to prove to the regulators that everyconceivable accident scenario has been assessedand that all reasonable measures have been putin place to prevent accidents rom occurring tominimise their impact i they do occur. This workwill take place ater the key decisions which arethe ocus o this Consultation have been made.This is because it requires detailed assessment odesigns or specic sites. These details will orm

part o planning and regulatory applications whichhave their own statutory requirements or publicconsultation. It is, however, possible to give someexamples o potential accident scenarios at thisstage. These are set out in Figure 7 right, togetherwith examples o the kinds o saety measures thatmust be in place to prevent them rom occurring,or to prevent them rom causing harm to people orthe environment i they do occur.


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Examples o potential accident scenarios Examples o typical saety measures

Road accident during the transport o ILW Waste may be set in concrete - absorbs radiation andkeeps it together

Package or shielded container tested and approved to stricttransport standards

Use o transport over-pack - tested and approved to stricttransport standards

Leak o small quantity o residual radioactiveliquids during removal o radioactive materialrom the RC

Liquid systems drained as part o preparing submarineor afoat storage

Containment around the RC to ensure that no liquids are lost

Fire in submarine while removing radioactivematerials rom RC

Flammable materials removed rom submarine when preparing orafoat storage

Ignition sources (e.g. electrical supplies and cutting equipment)strictly monitored and controlled

Fire detection and protection equipment installed andre drills rehearsed

Use submarine compartments to prevent spread o re and smoke

Excessive radiation dose received by workersduring size reduction o the RPV

Remote operation o equipment to keep workers at distancerom radioactivity

Shielding (radiation absorbing walls and windows to protect sta)

Strict controls on access to areas containing radioactive materialsto limit workers exposure to radiation

Terrorist attack on ILW store Site security ences and barriers

Controlled access to site and security patrols

Design criteria or store and storage containers

Container drop during movement within theILW Store

Design and test containers to prove that they can withstand dropsand impacts

Demonstrate procedures to recover a dropped container as part ostore design and commissioning

Aircrat or large vehicle crashes into ILW store Waste set in concrete

Restricted airspace around site

Crash barriers and road trac controls around site

Corrosion o ILW container during storage Designed and approved or 100 years storage

Condition monitoring, ventilation control

Figure 7: Examples o possible accident scenarios and typical saety measures


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CONSIDERING THEOPTIONS

6



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CONSIDERING THE OPTIONS

Find out more about theDecision-Making process inthe Factsheet: Decision-Making

Factsheet://

IntroductionThis chapter describes the key decisions that we need tomake to guide our approach to submarine dismantling.

It introduces the decision making-process that we areollowing, the actors and options we have considered andthe methods o analysis we have used.

6.1. The decisions we need to reach

6.1.1. O the activities explained in the previous chapter,the MOD has already established, proven andcommercially available solutions or all exceptinitial dismantling o submarines and the storageo Intermediate Level Waste (ILW) arising romit. The key decisions that need to be reached, areocused on the ollowing activities:

How we remove the radioactive material romthe submarines;

Where we remove the radioactive materialrom the submarines;

Which type o storage site is used or storingthe ILW until it can be disposed o in theproposed Geological Disposal Facility (GDF).

6.2. The decision-making process weare ollowing

6.2.1. The decision-making process we are ollowing isexplained in more detail in the document SDP Our Approach to Decision Making available on ourwebsite. To date, it has involved the ollowingbasic steps:

Identifyingtherequirementsfortheproject,the benets we are seeking to deliver and theimpacts we are seeking to avoid (these areoutlined in Chapter 4);

Identifyingtheoptionsandscreeningout

those that are impractical, uneconomicor ail to meet the projects requirements(described in sections 6.3 to 6.5);

Identifyingthefactorsthatwillenableustoassess how well the options meet the projectrequirements (described in section 6.7); and

Assessingtheoptionsagainsttheseactors in order to orm our proposals orconsultation (the methods we have used toassess the options are described in section6.9 and our current assessment o theoptions is described in Chapter 7).

6.2.2. The proposals we are making at this stage aredescribed in Chapter 8. The process that will ollowthis public consultation is described in Chapter 9.


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Remove and size-reduce the RPVor storage as Packaged WastePackaged Waste

TheRPVandotherradioactivewastewouldbe removed in the same way as above butthen immediately size-reduced and packagedinto boxes or storage. Once again the

submarine would be let otherwise intact. Nofurthercutting-uporpackagingwould

be required in uture beore the boxes aredisposed o.

6.3.2. In each case, we have accounted or the waste tobe size-reduced and packaged into boxes at somepoint beore it can be disposed o. However, we areexploring the possibility that the proposed GDFcould accept larger packages which would meanthe RPV could be disposed o without being cut up(as explained in section 5.2).

6.3.3. The main dierence between the options thereoreis the order and timing in which the size-reductionand storage activities are carried out, and the ormin which the waste is removed rom the submarineand stored while awaiting a disposal solution.

For more inormation see theFactsheet: Initial Dismantling

Factsheet://

6.3. Options or how we remove theradioactive waste rom the submarines

6.3.1. There are three possible options or removingradioactive waste rom the submarines. Low LevelWaste (LLW) is routinely removed and disposed orom submarines during service. These optionsocus on the removal o ILW:

Separate and store thewhole Reactor CompartmentRC Separation

ThewholeRCwouldbeseparatedfromtheront and rear sections o the submarineand stored whole, leaving the hull o thesubmarine in two sections.

TheRCwouldbestoredonland(thestructure o the RC itsel would provide theshielding needed while it is being stored).

TheRCisaround700tonnes(ofwhichupto50 tonnes is ILW). Due to its size it would bedicult and very expensive to move the RC,so it is assumed in this option that it wouldbe stored where it is removed (at the initialdismantling site).

TheRCwouldhavetobecutupintosmallerpieces and the ILW packaged at some point inthe uture beore it can be disposed o in theproposed GDF.

Remove and store the ReactorPressure Vessel RPV Removal

TheRPV,whichsitswithintheReactorCompartment and other radioactivematerials would be removed through a holein the hull o the submarine, leaving the RCand the rest o the submarine otherwiseintact. The hole would be closed aterwardsto make the submarine watertight again.

TheRPVwhichweighsbetween5080 tonnes and any remaining ILW (inpipework connected to the RPV or example)would then be packaged in a shieldedcontainer that is suitable or transportand storage.

AtsomepointinthefuturetheRPVwouldneed to be cut up into smaller pieces andpackaged beore it can be disposed o.


What are your views on theoptions or how the radioactivematerials could be removedrom the submarine? Do youthink any signicant optionshave been let out?

Q2


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RC Separation

RPV Removal

Packaged Waste

Figure 8: Options or how we remove the radioactive waste rom the submarines

In store until at least 2040

SIZE-REDUCTIONFACILITY

ReactorCompartment

Interim RCStorage

Packaged Wasteor Disposal



Interim ILWStorage


ReactorPressureVessel

In store untilat least 2040



Interim ILWStorage


ReactorPressureVessel In store until

at least 2040




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6.4. Options or where we remove theradioactive waste rom the submarines

6.4.1. For security reasons surrounding the design o thesubmarine and reactor, initial dismantling must becarried out in the UK. It must also take place at asite that holds a nuclear licence or this work whichmeans the sites activities will be closely regulatedby the Oce or Nuclear Regulation, to ensure the

highest saety standards are maintained.

6.4.2. We considered all sites in the UK that currentlycarry out nuclear activities against a range oscreening criteria such as accessibility by sea,available space and existing ship-handlingacilities.

6.4.3. Devonport Dockyard and Rosyth Dockyard, whereout-o-service submarines are currently stored andwhere in-service submarines are, or have been,maintained and retted, met the screening criteria.

The dockyards are owned by Babcock, the UKsexperts in submarine maintenance.

6.4.4. Both sites have past or current experienceo submarine maintenance and o nucleardecommissioning and thereore a workorce withexisting skills and experience in these areas.

6.4.5. The submarines could be dismantled at eithero these sites or at both (the dual site option).Under the dual site option, each dockyard wouldundertake the initial dismantling o the submarinesit currently stores afoat; submarines would not bemoved between sites prior to initial dismantling.Further submarines yet to leave service would bedismantled at Devonport Dockyard. No urtherdismantling would take place at Rosyth once theseven submarines currently stored there havebeen dismantled.

For more inormation aboutthe candidate site selectionprocess see the SDP SiteCriteria and Screening Paperavailable at www.mod.uk/submarinedismantling

Screening Paper://

6.5. Options or which type o site is used tostore ILW

6.5.1. We have identied sites that already undertakenuclear activities and thereore hold a license orauthorisation as potential storage options or the

ILW rom dismantled submarines. These sites areowned either by the MOD, industry or the NDA.

6.5.2. We have considered these options according totheir ownership and by location relative to theinitial dismantling site(s). This would dictatewhether or not the waste needs to be transported.

6.5.3. The NDA is in the process o exploringopportunities to share its current and plannedstorage acilities to improve value-or-money andreduce environmental impact o new store build.

Such a development in the NDAs strategy wouldbe an important consideration in any site screeningexercise. To date it has not been appropriate toconduct a screening exercise to identiy individualcandidate storage sites. This is because odierent contexts and developing strategiesaecting dierent types o site. Commercial sites,meanwhile, would need to be screened through acommercial process inviting expressions o interestrom site owners. At this stage, thereore, we areassessing the types o site that may be used andnot the specic sites themselves.

What are your views on thecandidate sites or where theradioactive waste is removed

rom the submarines? Do youthink any signicant options havebeen let out?

Q3


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6.5.4. Four types o sites have thereore been identiedand assessed as options or ILW storage:

Storageatthepointofwastegeneration

- this could include Devonport or RosythDockyards or Her Majestys Naval BaseDevonport i initial dismantling were done atDevonport Dockyard;

Storageatsitesownedbyindustry,remote

rom the point o waste generation; StorageatsitesownedbytheMOD,remote

rom the point o waste generation; and

StorageatsitesownedbytheNDA-remote

rom the point o waste generation.

6.5.5. All options, except the NDA option, assume thata new build storage acility will be required. Asbuilding more than one new storage acility orSDP would be uneconomic we have assumed, withthe exception o the NDA option, that ILW storagewould be at one site only.

6.5.6. The MOD is working jointly with NDA to assess thecosts and benets o using NDA storage acilitiesand whether or not this would be best value ormoney, compared to developing a new build acilityon a MOD or commercially owned site.

No submarines will bedismantled until a storagesolution has been agreed.Regulations are in place toenorce this commitment.

6.6. The Do Minimum option

6.6.1. Chapter 4 explained why we need to dismantlesubmarines, however, it is important that wecompare the options or dismantling submarineswith the alternative o not doing so. We callthis alternative the do minimum option whichinvolves continuing to store and maintain out-o-service submarines afoat, indenitely into theuture, and building additional berthing space asit becomes necessary. It should be stressed thatthis is not being considered as a credible optionbut as a comparator or the options that do involvedismantling submarines.

6.7. Factors we have considered

6.7.1. Making these decisions involves many complexconsiderations and it must be based rmly onevidence, taking account o all the relevant actors.Figure 9 (overlea) describes all the actors we haveconsidered to date in assessing the options. Theseactors are derived rom the objectives or theproject (see section 4.3) and, where appropriate,are aligned to the Strategic EnvironmentalAssessment (SEA).

For more inormation seethe Factsheet:Managing Radioactive Waste

Factsheet://

What are your views on theoptions or which type o site isused to store the intermediate

level waste rom submarinedismantling?Do you think any signicantoptions have been let out?

Q4


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Cost actors Whole Lie Cost: The total cost o an option throughout the lie o the project.

Policy actors Flexibility and Robustness to Opportunities and Risk: Opportunities and risks are things thatmay happen in the uture that have a positive or negative impact, respectively. How ar does anoption maximise opportunities and minimise risk?

Compliance with UK Policy and Strategy on Radioactive Waste Management: How well does anoption satisy UK Government policy?

Scope and Extent o Transport o Submarines and Radioactive Waste: How ar does an option

minimise the amount o transport that will be required?

Unauthorised Access to Classifed Materials during Dismantling, Storage and Transport: Howsecure is an option in preventing unauthorised access to classied materials throughout the lieo the project?

Compliance with UK Decommissioning Policy: How well does an option satisy UK policyobjectives on nuclear decommissioning?

Operationalactors

Impact on the Maritime Enterprise: What impact, positive or negative, will the option have onmilitary operations, support to military operations and long-term military capability?

Flexibility o Dismantling Approach to Managing Future Classes: To what extent will the optionallow the MOD, in the uture, to adapt or extend the lie o acilities to undertake dismantling o

uture classes o submarines?

Threat to Skill and Experience Set: To what extent will the option take advantage o existingskills and experience? What impact, positive or negative, will an option have on the availability oskills and experience in the uture?

Transerable Dismantling Knowledge: To what extent does an option allow us to learn romothers or share learning with others, both in the UK and overseas?

Health andSaety actors

Worker Dose: Dismantling, Storage and Transport: What cumulative radiation dose will workersbe exposed to or an option?

Non-Radiological Impact on Workers: What are the other health and saety hazards to workers,involved with an option?

Potential or an Unplanned Radiological Release during Dismantling: What is the potentialo an option resulting in workers being exposed to an unplanned release o radiation duringdismantling?

Potential or an Unplanned Radiological Release during Transport: What is the potential o anoption resulting in workers being exposed to an unplanned release o radiation during transport?

Potential or an Unplanned Radiological Release during Storage: What is the potential o anoption resulting in workers being exposed to an unplanned release o radiation during storage?

Environmentalactors

Radiological Discharges to the Public: To what extent does an option minimise the impact oradiological discharges (planned and unplanned) to the public?

Radiological Discharges to the Environment: To what extent does an option minimise the impacto radiological discharges (planned and unplanned) to the environment?

Non-Radiological Impact on the Public: What are the non-radiological impacts o an option tothe public? For example, how might an option aect the public through noise, light pollution,vibration or dust?

Non-radiological Impact on the Environment: What are the non-radiological impacts o anoption to the environment? For example, how might an option aect water quality, air quality andbiodiversity?

Impact on the Built Environment: What could be the impacts o an option on the builtenvironment? For example, how might an option aect heritage, landscape or townscape?

Impact rom the Natural Environment: What could be the impact on an option rom the NaturalEnvironment? For example, how might an option be aected by fooding, extreme weather or theeects o climate change?

Figure 9: Cost and Eectiveness Factors


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6.7.2. The actors listed in Figure 9 can all be assessedquantitatively through cost estimating, calculationor expert judgement. In addition, we have alsoidentied a number o actors, called OtherContributory Factors (OCFs), which will beimportant considerations but which cannot beassessed quantitatively and require urtherevidence. Some o this evidence will be gatheredthrough public consultation or urther stakeholder

engagement beore a qualitative assessment canbe made. The OCFs that we have identied todate are shown in Figure 10.

6.7.3. We have an understanding o some o these OCFsrom earlier consultations; or example, basedon the inormation available at the time, theConsultation on ISOLUS Outline Proposals (CIOP)11

indicated a higher level o public condencein the option o separating and storing the RC.However, there is a need to update and expandour understanding because more recent work and

our current assessment o the cost, eectivenessand environmental eects o the options may havechanged the picture.

6.7.4. Consultation responses relating to OCFs will becollated and summarised in the Post ConsultationReport. The OCFs will then be reviewed. Whereinsights can be quantied they will be incorporatedin the cost analysis, assessment o operationaleectiveness or the risk analysis as appropriateand these analyses will be updated.Any remaining actors will remain as OCFs toinorm the nal decision.

Other Contributory Factors

Public Confdence:What concerns do the public have about the MODs proposals and the decision-making process that is beingollowed? What bearing do these concerns have on an option or the process by which it is being considered?

Socio-economic Impacts:What might be the socio-economic impacts (both positive and negative) o an option?

Political and Policy Frameworks:How might established political and policy rameworks aect an option?

Implications o or or other Local Projects:How might an option aect or be aected by other local development projects? What might be the combined eects?

Impact o or on other UK Radioactive Waste Management Initiatives:How might an option aect or be aected by UK radioactive waste management initiatives? Examples o such

initiatives might be the UKs Strategy on Low Level Waste or the UKs programme or geological disposal.

Commercial Considerations:What commercial considerations might aect an option? Examples o commercial considerations might be thepotential or competition or the right o suppliers to decline to tender.

Figure 10: Other Contributory Factors

11For more inormation see the Document Archive on the SDP website.


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6.8. Integrated options

6.8.1. In order to take actors such as transport intoaccount, we have assessed integrated optionsmade up o the sensible combinations o theoptions or each o the three key decisions that weneed to reach.

6.8.2. We have assessed a total o 24 integrated options

(plus the do minimum option) such as RCseparation at Rosyth with storage at the point owaste generation or RPV removal at Devonportwith storage on a remote MOD site.

6.8.3. Storage o RCs at a site remote rom the initialdismantling site has not been assessed as anintegrated option. This is because our cost studiesound that the additional costs associated withsea transport and dockside handling o RCs wouldmake moving them to a dierent site or storageuneconomic. This integrated option will, however,

remain as a uture opportunity to be reviewed asurther detailed work helps to rene our estimates.

6.8.4. Storage o RPVs using NDA acilities has not beenassessed as an integrated option either. This isbecause the easibility o this combination hasyet to be developed through joint studies with theNDA. It remains under review, however, as anopportunity that will be developed urther shouldits easibility be proven.

6.9. Analysis methods6.9.1. A whole-lie cost model was developed to provide

estimates o the costs o each o the integratedoptions throughout the lie o the project. Thesewere then assessed in an investment appraisalwhich brings together the results o the costmodel and applies a consistent set o accountingprinciples to provide a comprehensive assessmento the nancial perormance o each.

6.9.2. For those actors that could not be assessed interms o cost, we assessed the eectiveness o

the options (i.e. how well they met the projectsrequirements) using Multi Criteria DecisionAnalysis (MCDA). The MCDA method involvedthree workshops where experts across a range orelevant subjects were asked to agree the actors,weight the importance o each actor and thenscore each integrated option against each actor.

6.9.3. The ndings o the investment appraisal and theMCDA are brought together in the OperationalAnalysis Supporting Paper (OASP) which is ourcurrent assessment o the cost eectiveness (orvalue or money) o the integrated options. TheOASP provides the basis or our proposals whichare set out in Chapter 8.

You can fnd the detail o ouranalysis in the OperationalAnalysis Supporting Paper

Screening Paper://

What are your views aboutthe methods used to comparedismantling and storageoptions, in particular theactors considered to assesstheir suitability/eectiveness/

perormance?

Q5


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OUR CURRENTASSESSMENT

7


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OUR CURRENT ASSESSMENT

IntroductionThis chapter summarises the ndings o our currentassessment o the options. It details the advantages,disadvantages and costs o the options or the key

decisions we need to reach.

Work still remains to be done, and there are actors thatcannot be assessed until the results o this consultationare available. However, we can draw some indicationsrom the analysis to date. At this stage, no options havebeen discounted rom urther consideration (except thedo minimum).

7.1. Our assessment o the Do Minimumoption

7.1.1. To provide a comparison with the options ordismantling submarines, we have also assessedthe option o Doing Minimum - continuing to storesubmarines afoat indenitely and building moreberthing space when required.

7.1.2. This option potentially restricts Dockyard andNaval Base operations due to a lack o berthingspace. It leaves decommissioning issues to uturegenerations and, in the long-term, will not complywith UK policy on decommissioning. This is alsothe most expensive o all the options in the long-

term due to the cost o creating extra berthingspace and the rising cost o maintenance.

7.2. Our assessment o the options or how weremove the radioactive waste romthe submarines

7.2.1. As explained in Chapter 6, the three options orhow we remove the radioactive waste rom thesubmarines initial dismantling are:

SeparateandstorethewholeRC

RC Separation; RemoveandstoretheRPVRPV Removal; or

RemovetheRPVandsizereducetostoreaspackaged waste Packaged Waste.

7.2.2. Operational actors were the most signicant indistinguishing between these options; such as theeect on berthing arrangements or competitionwith other dockyard activities. Policy actors werealso signicant in separating the options in termso how well they balance dierent policy objectives.

Forexample,dismantlingassoonasreasonablypracticable,whiletakingadvantageofthebenetso radioactive decay (whereby the amount oradiation reduces over time).

7.2.3. The RC Separation option would potentially havesignicant environmental eects due to the verylarge size o the store that would be required (morethan 10 times bigger than the other options). Thiswould have a signicant visual impact and theamount o land lost to the building could haveknock on eects on drainage, habitats and otheraspects o the environment. In Devonport, theRC Separation option would also be more likelyto require dredging as submarines that have hadtheir RC removed would need to be transportedby barge or heavy lit ship (which requires deepwater in order to load the submarine by sinkingand then foating beneath it). Nevertheless,the environmental actors did not discriminatesignicantly between the eectiveness o theoptions because, in our assessment, all optionscould be designed to achieve the legally requiredenvironmental standards.

7.2.4. Both the RPV Removal and Packaged Wasteoptions perorm reasonably well on eectivenessand cost grounds; the RPV Removal optionappeared to be the best, although Packaged Waste

appears equally good i it can take advantage oNDA storage acilities.

7.2.5. The RPV Removal option takes advantage o thebenets o radioactive decay so that the sizereduction activity at the end o the storage periodmight be made simpler and less costly. It alsooers the greatest potential to take advantage ochanges in GDF entry conditions or disposal oILW (such as size, weight or radioactive inventory)which might, in the uture, allow or whole RPVs tobe disposed o without the need or size-reduction.

This would oer signicant savings in the cost odeveloping, operating and decommissioning asize-reduction acility and potential improvementsin eectiveness.

7.2.6. The RC Separation options also take advantageo the same benets o radioactive decay butappear to be less eective and more expensivethan the others. This is because RCs are bothlarge and heavy and the inrastructure requiredto handle and store 27 o them would be costlyand have negative eects on the environment (as


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described above) and operations at the dockyard(s).Although this option would be broadly compliantwith decommissioning policy it would, in ourassessment, progress decommissioning activitiesmore slowly than is reasonably practicable.

7.2.7. Health and saety actors, whilst o absoluteimportance, did not distinguish signicantlybetween the options because, in our assessment,

all three options could be designed to achieve thelegally required saety standards. There weresome dierences between estimates o radiationexposure to workers (with RC Separation being

lower than the RPV Removal and Packaged Wasteoptions) but as all estimates were very low (relativeto statutory limits and typical employer doseconstraints) they did not distinguish signicantlybetween the options.

7.2.8. Figure 11 summarises our assessment o how theadvantages, disadvantages and costs compare oreach o the options.

Figure 11: Summary comparison o technical options

Option Advantages Disadvantages Cost

RC Separation andstorage

Allows or radioactive decaybeore RPV is removed andsize-reduced

Flexible to changes in entryconditions to the proposedGDF

Experience o this approachin other countries

Additional operations andacilities to store and handleRCs

Seaworthiness o submarinehull is compromised (ortransport to ship recycling)

RCs can only be transportedby sea

Very large store ootprint(over 10 times larger thanother options) causing largestoverall environmental impacto storage acility

Generally most expensivedue to RC handling andstorage costs

Potential cost savings iRPV size-reduction provesunnecessary or simpler dueto decay

Costly size-reductionacilities and operationsdeerred until later

RPV Removal andstorage

Allows or radioactive decaybeore RPV is size-reduced

Flexible to changes in entryconditions to the proposedGDF

RPV transportable by landor sea

RPV is sel-shieldingthereore less shieldingrequired than or packagedwaste

Transport, handling andstorage less standardised thanor packaged waste

Generally comparable topackaged waste

Potential cost savings iRPV size reduction provesunnecessary or simpler dueto decay

Costly size reductionacilities and operationsdeerred until later

RPV Removal andsize-reductionor storage aspackaged waste

Stores ILW in disposableorm with no urtherprocessing required

Consistent with civiltransport, handling andstorage arrangements

Packaged wastetransportable by land or sea

Less fexible to changesin entry conditions to theproposed GDF

Less radioactive decay prior tosize reduction

Generally comparable to RPVRemoval and storage

Potential savings throughuse o NDA storage acilities

Unnecessary initialexpenditure i size-reductionnot required


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7.3. Our assessment o the options or wherewe remove the radioactive waste rom thesubmarines

7.3.1. As explained in the previous chapter, the optionsor the location o initial dismantling activities are:

DevonportDockyard;

RosythDockyard;or acombinationofbothofthe

above - dual-site.

7.3.2. Both sites already have many o the acilitiesrequired to undertake initial dismantling includingthe berths, docks, handling acilities and Low LevelWaste (LLW) processing acilities that would berequired. As a result, the scale o developmentthat would be needed is limited and no signicantenvironmental eects o initial dismantling wereidentied at either site. As Devonport Dockyard

is closer to a built up area than Rosyth Dockyardthere would be a greater chance o constructionactivities causing disturbance to local communitiesbut within the denitions o the SEA this was notidentied as a signicant eect.

7.3.3. Initial dismantling at Rosyth only, requiresmore submarines to be transported than initialdismantling at Devonport only. For storage opackaged waste or RPVs the Rosyth only optionsare less eective and cost more than the equivalentoptions or initial dismantling at Devonport, or atboth sites. For the RC Separation options, however,Devonport would rank as the best option, ollowedby Rosyth and then dual-site.

7.3.4. The dierences in eectiveness and cost betweenthe Devonport and dual-site options are small. Thecosts o duplicating some acilities and operationsat both sites are oset by the costs saved byavoiding the need to transport submarines prior toinitial dismantling.

7.3.5. Figure 12 summarises our current assessmento how the advantages, disadvantages and costs

compare or each o these options.


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Option Advantages Disadvantages Cost

DevonportDockyard

Fewer submarines (7) to betransported prior to initialdismantling compared toRosyth only option

Competition with otheroperations or space,resources and acilities

Depth o water in PlymouthSound may restrict somemethods o submarinetransport

Less expensive than Rosythonly option and comparable tothe dual-site option

Rosyth Dockyard In a less built up areareduced risk o disturbanceto local community

Currently more ree spacethan Devonport

More submarines (20) to betransported prior to initialdismantling compared toDevonport only option

Potential confict withre-development plans

Most expensive due tocosts o transporting moresubmarines and lack o othersimilar work with which toshare overheads and siterunning costs

Both Devonportand RosythDockyards dual-site

No submarines to betransported prior to initialdismantling

Rate and order o

dismantling can beoptimised to best manageliabilities at both Rosyth andDevonport

Some duplication o acilitiesand environmental eects

Less expensive than Rosythonly option and comparable toDevonport only option

Cost savings on transport o

submarines estimated to begreater than site duplicationcosts

Potential to make urthersavings by optimising rateand order o submarinedismantling to minimiseliabilities at both sites

Figure 12: Summary comparison o initial dismantling site options


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7.4. Our assessment o the options or whichtype o site we use to store ILW

7.4.1. As explained in the previous chapter, the optionsor which type o site we use or storage o ILW areas ollows:

ILWstorageatpointofwaste

submarine dismantling project consultation document

Documents