RWMAC report on MoD radioactive waste practices

ANNEX 5
ROSYTH

Introduction

1. Rosyth is a privatised dockyard, located on the north shore of the Firth of Forth about 10 miles from Edinburgh, which, although used to refuel and refit UK nuclear submarines since the late 1960s, has never served as an operating base for nuclear powered submarines.

2. In 1987, the dockyard was contractorised, and Babcock Thorn Ltd was awarded a contract to manage the operation of the site on a commercial basis. In July 1994, the Babcock International Group acquired Thorn EMI's shareholding in the dockyard and established Babcock Rosyth Defence Ltd (BRDL) to continue the management of the dockyard. In January 1997, the dockyard was fully privatised. The site, together with its assets, was acquired by BRDL.

3. The Government's 1993 decision to concentrate submarine dockyard activity at Devonport meant that the Vanguard refit facility, then under construction at Rosyth, was never completed. All submarine refitting and refuelling activity is due to end at Rosyth following completion of the last such operation - which began in the autumn of 2000. In contrast to Devonport, therefore, submarine work at the Rosyth dockyard is being run down, although for the present, both its facilities and workforce remain in place. Rosyth is also used to a lesser extent than Devonport for surface ship work; the latter being the UK's primary operating base. Present plans do, however, envisage that Rosyth could, in an emergency, support Devonport and Faslane on submarine work. The dockyard also retains its surface ship contracts. The privatised operator, BRDL, is actively seeking replacement business.

4. Seven nuclear submarines, which have been taken out of service, are berthed at Rosyth. These activities are subject to "external" MoD regulation by NNRP. Like all submarine radioactive wastes, ownership of these deactivated submarines continues to reside with MoD. While operational wastes produced as a result of refuelling and refitting are transferred to BRDL for management, the reactor compartments and coolant circuits, which constitute the major amounts of radioactive waste present in each boat, remain MoD's responsibility to maintain. The fate of these vessels is presently under consideration as part of the ISOLUS study.

5. The ending of regular cycles of refit and refuelling work at Rosyth means that substantial parts of the site need to be decommissioned. Provision for BRDL to oversee site decommissioning and remediation work was included in the BRDL site sale agreement. For the most part, financial responsibility for this work, and liability for the waste arisings, remains with MoD.

Radioactive waste generation

6. As at Devonport, radioactive waste in solid and liquid forms arises from maintenance, refit and decommissioning work on nuclear submarines and from the on-site treatment of submarine wastes.

7. Solid LLW, the bulk of which arises through the removal and replacement of equipment and from laboratory testing, and associated wastes such as contaminated clothing, can amount to 180 m³ per year. This is processed at the site's Active Waste Accumulation Facility (AWAF) for eventual disposal, in drummed form, to Drigg. The AWAF is a new facility, commissioned in 1998, for the storage of ILW and the processing and temporary storage of LLW.

8. The annual limit on disposal of solid LLW is 200,000 MBq of beta/gamma emitting radionuclides. Actual disposals of solid LLW have been well within these levels. A new waste sorting table and active waste monitor are being acquired in order to maximise the potential for minimising waste arisings and accurately quantifying waste streams; BRDL believes that it may be possible to reduce the number of existing drums to be consigned to Drigg by 50 per cent.

9. Solid ILW amounting to about 25 m³ a year, comes from redundant activated metal components removed from areas proximate to the submarine reactor compartments. This is stored within shielded pits in AWAF.

10. Rosyth, like Devonport, also has to deal with the ion-exchange resins, both LLW and ILW, which arise, in part, from treatment of submarine reactor primary circuit wastes. Arisings of ILW resins are about 5 m³ per annum.

11. The Resin Catch Tanks (RCTs) witnessed by RWMAC during its last visit are still being used although they have now been brought within the AWAF. As at Devonport, discovery of the presence of carbon-14 has meant that previous assumptions concerning the decay of ILW to LLW need to be revisited. Some resins are now likely to remain ILW over much longer periods than was previously foreseen. As a first step, the existing RCTs, already beyond their design life, need to be replaced. BRDL intends to identify, and then assess, the various options for implementing the longer-term storage of the ILW resins.

12. Liquid LLW comes from submarine primary coolant, decontamination processes, laundry facilities and the radiochemical laboratory. Some wastes are treated at the Effluent Treatment Plant (ETP), where, after filtration, passage through ion exchange resins, sampling and analysis, the resulting liquid is discharged to the Forth estuary. Laundry wastes are routed through a testing laboratory and associated holding tank before discharge. There is a time window for such discharge - within one to four hours after high tide. This practice was the subject of a SEPA enforcement notice requiring six specific improvements on the part of BRDL, which have now been implemented. There are specified limits of 5,000 and 40,000 MBq per annum respectively for the discharge of cobalt-60 and tritium. Actual discharges in recent years have been well within these limits. The critical group dose from liquid discharges is estimated to be 0.004 microsieverts per year.

13. Ventilation monitoring has shown that there are virtually no gaseous discharges from the site.

Site regulation

14. As at Devonport, Rosyth Dockyard is subject to full civilian regulation under NIA65 and RSA63. The NIA65 site license is not held by BRDL but resides in Rosyth Royal Dockyard Limited. NNRP Authorisation of the dockyard was granted in 1999.

15. Under RSA93, BRDL are authorised to:

- discharge radioactive gases to the atmosphere;

- discharge liquid LLW to the Forth estuary;

- dispose of solid LLW and VLLW to Drigg.

Because of the problem with detection of carbon-14 in the wastes, no disposals of LLW to Drigg have actually taken place since the beginning of 1999.

Radioactive waste management policy and strategic planning

16. Policy for radioactive waste management is set out in an instruction, issued company-wide and regularly updated, with which all employees are required to adhere. The scope of the instruction is clearly defined - covering the full range of waste-producing activities carried out by BRDL and the subsequent management operations applied to those wastes. Overall responsibilities, located at a senior level, for providing waste management functions, and for ensuring that they are discharged in a safe manner, are also clearly defined. The latter responsibility falls to the Health Physics Department. A named Radiation Protection Adviser (RPA) is responsible for ensuring that company policy is pursued, health and safety law is observed, and the requirements of RSA93 for waste management are followed. The RPA acts as the first point of contact with SEPA.

17. The policy is predicated on waste minimisation, early removal of material posing a radiation hazard, establishment of work practices designed to ensure that exposures, and potential exposures, are ALARP, and application of BPM in use of waste management technology, including authorised disposal routes.

18. However, BRDL's forward radioactive waste management plans appeared to RWMAC to be less well formulated and documented. During the visit, RWMAC posed the question of BRDL's site waste plan. The company's response was that this was executed by means of returns made to the UK National Radioactive Waste Inventory - the document that defines the volume of current and anticipated civil and defence radioactive waste streams. The Committee believes that while the Inventory is a detailed and reliable instrument of national strategy, it does not substitute for planning at site level. Its focus is on national facilities, such as Drigg, and issues common to all nuclear licensed sites, such as ILW packaging, not on site-specific waste management requirements. As will be clear from Annex 2.4, RWMAC has strong doubts about the efficacy of MoD's arrangements for compiling the defence wastes inventory and ensuring that returns made to the UK Inventory are comprehensive.

Spent fuel

19. There have, as at Devonport, been problems with the containers used for the rail transport of spent fuel to Sellafield. These difficulties have only recently been resolved. In brief :

- in 1991, regulatory approval was withdrawn for use of Used Core Transport Packages (UCTP);

- the NTL3M type container was used on a stop-gap basis;

- approval has now been given for the use of the Used Fuel Flask (UFF).

20. Despite these difficulties, BRDL was able to decant the spent fuel from the site pond. This, and approval of the UFF, should mean that BRDL will now be able to deal easily with the remaining spent fuel at Rosyth. This comprises the fuel from HMS Swiftsure still held in two UCTP flasks on the dockside - which will now have to be transferred to the new UFF flasks for transfer to Sellafield when a suitable opportunity arises. The fuel from HMS Renown, which is due to be decommissioned, has already been sent to Sellafield (March 2001) as has that from HMS Sceptre, HMS Spartan, and HMS Revenge.

Site decommissioning

21. Site decommissioning and remediation work is to be overseen by BRDL under a turnkey project designated RD83.

22. At present, RD83 envisages the eventual removal of nuclear equipment from two out of the three submarine docks. Facilities designed for refitting and refuelling will also be decommissioned. However, any facilities necessary for Rosyth to carry out its submarine servicing "overload" functions would be retained. AWAF, the purpose-built ILW store, will also be retained. On the face of it, AWAF will, therefore, be under-utilised unless new work comes to Rosyth.

23. The decommissioning project is being planned in two stages. Stage 1 consists of radiological surveys, examination of contamination boundaries, development of specialist decontamination techniques, and development of the competitive tendering exercise for the subsequent stage. Stage 2 consists of managing the decommissioning and decontamination work itself.

24. Key elements of the clean-up work are to cover the 2 and 3 dock refuelling facilities, the health physics building and its laundry, the refuelling equipment shop, the radiochemistry laboratory, the low active discharge line and the on-site VLLW waste disposal facility (closed in 1978).

25. BRDL intends to take account of the experience of the decommissioning of the Jason reactor site at the Greenwich Royal Naval College. There is a significant amount of survey material available for the Rosyth site, so BRDL believe that they are "not starting with a completely blank sheet". However, company staff also believe that they will need to look at many areas in more detail, for example, the depth of ground contamination. Work is, in effect, only just beginning.

The BRDL proposal for HMS Renown

26. Against the background of the ISOLUS project and loss of nuclear submarine refit work to DRDL Devonport, BRDL has made an unsolicited proposal to MoD for post-decommissioning work on HMS Renown, the decommissioned vessel awaiting de-fuelling at Rosyth. The BRDL proposal consists, in essence, of cutting out the boat's Reactor Pressure Vessel (RPV) and Primary Shield Tank (PST), their dismantling and subsequent long-term storage of those components classified as ILW in AWAF. The non-contaminated hull and fittings would be available for scrap.

27. The reason given by BRDL for the initiative is that the company is looking to find a continuing use for its workforce skills and site facilities. Although not explicitly stated, it seems likely that BRDL is also looking to win at least some of the main ISOLUS submarine post-decommissioning work - logically, for the remaining defuelled and decommissioned boats at Rosyth. In this context, RWMAC believes that acceptance of the proposal would inevitably have important implications for the main ISOLUS programme.

28. The Renown project by itself would generate about 50 or so jobs (compared with the loss of 1,400 jobs that would eventually occur following the removal of refitting work). The proposal appears to have a fairly narrow window of opportunity around the timing of the planned defuel docking of Renown, scheduled for spring 2001. This work is to be followed by an aircraft carrier contract. Therefore, if the proposal does not go forward on time, Renown's docking will have to follow the normal lay-up programme for defuelled submarines, allowing her to be defuelled and decommissioned with the six other submarines at Rosyth. In other words, the BRDL proposal will fall.

29. BRDL states that the 7,900 tonne (t) submarine can be taken down by conventional physical dismantling to the 150t RPV/PST. The RPV/PST could then be reduced to 20t of more active radioactive waste (ILW) if further dismantling took place. This was said not to require the development of entirely new technology. BRDL believes that there will be no significant worker dose implications from early dismantling. At most, this could amount to a collective dose of 0.173 manSv, or about 3.5 millisieverts per worker (assuming a workforce of 50). The length of the work, including placing the RPV/PSV components into AWAF, is estimated at nine months from the time the necessary regulatory approvals are secured.

Public relations

30. A Rosyth Local Liaison Committee meets every six months. According to BRDL, there are no local pressure groups and the company believes that relations with the local community are good. Community representatives have visited AWAF and have been informed that it may be used for the long-term storage of ILW. The nearby local authorities employ an independent radiological protection adviser to verify critical group estimates.

Main RWMAC observations

Waste storage and carbon-14

31. The AWAF building, opened in 1998, has made impressive new provision for the storage of ILW, and the processing and temporary storage of LLW, on the Rosyth site. Because the store was originally predicated on the basis of an ongoing role for Rosyth in submarine maintenance and refitting, the site has more than adequate future storage provision already built in. It is important to remember that AWAF was built to serve the specific needs of Rosyth; in both concept and design terms, it differs markedly from the D151 store at Devonport.

32. Currently, part of AWAF is used as a temporary store for large numbers of drums containing LLW as a consequence of the embargo on disposals to Drigg. RWMAC was told that DERA-RPS, together with Rolls Royce, were investigating the problem from the reactor design end (i.e., estimating the likely volume of carbon-14 production per reactor core). Investigations at the "radioactive waste end" have so far focussed on analysis of coolant and resin wastes rather than solids, although BRDL is reviewing the contents of the stored drums using a new active waste monitor and the results have been used to estimate the amount of carbon-14 in historic disposals to Drigg. The role of BRDL was described by its managers as one which "verified" the DERA-RPS and Rolls Royce findings. The more general state of disposals of MoD carbon-14 contaminated LLW to Drigg is discussed further in section 6, paragraphs 57-59 of the main report.

33. AWAF houses the LLW and ILW resins derived, in part, from decontamination treatment of submarine reactor primary circuits. The RCT containers witnessed by RWMAC during its last visit are still being used. A permanent solution is needed for these resins since some will remain as ILW over long periods. As a first step, the existing RCTs, already beyond their design life, need to be replaced (or possibly refurbished). BRDL is to consider the possible options. It needs to be emphasised, however, that because of the concentrations of carbon-14 in some of the resins, decanting into new or refurbished containers cannot be regarded as the permanent answer. To achieve this, a long-term arrangement which does not depend on keeping mobile wastes in free-standing containers needs to be determined.

34. For the LLW resins, the point at which the MODIX chelates can be removed needs to be established (since these are not acceptable at Drigg) as does the timescale for their conditioning (probably by cementation) required before disposal. BRDL appears to have rejected early conditioning of some of the resins on grounds of both ALARP and financial economy.

35. For solid LLW, RWMAC welcomes the introduction of the sorting table which will help to ascertain the potential for compacting both present and future wastes and contribute to the objective of reducing the number of existing LLW drums by 50 per cent. This would be a useful step since it would achieve savings in Drigg disposals - once they resume. This assessment does, however, seem to cast some doubt on the adequacy of the site waste minimisation and estimation procedures that have been pursued at Rosyth in the past.

Wider management implications

36. Despite some advances, therefore, RWMAC was unable to conclude that there was clear planning for the long-term management of the site's wastes. Overall, the Committee would like to see evidence of more thought being given to the longer-term management of Rosyth's wastes, with consideration of how the chelate and carbon-14 problems fold-in. This will also need to take account of site decommissioning and remediation, which is beginning to be addressed through the RD83 decommissioning project.

37. Nor did RWMAC feel that all the relevant issues are being considered together as a whole. A factor which may, or may not, be associated with this is the extent of available storage in the AWAF and, as a consequence, the absence of pressure to solve the problem. Clearly, however, the prospect of long-term on-site storage of ILW would have to be considered side by side with public expectations for the Rosyth site, given that its submarine operations, and also of the employment supply associated with them, are to diminish in the future.

38. For this reason, RWMAC believes that BRDL and MoD need to put further thought into a comprehensive, forward-looking radioactive waste management plan for the Rosyth site. This should include a resin management plan and take due account of the carbon-14 problem. With the failure of the UK's ILW repository programme, the Committee does not believe that there is a sound case for delaying treatment of resins, but rather there needs to be moves towards passive storage taking due account of developing NII and SEPA thinking.

39. The Committee accepts that there are a number of uncertainties that would need to be built into such a plan, and thus, its formulation is not something that can be achieved tomorrow. But this is still a problem that needs to be addressed to an early timescale - particularly now that major nuclear elements of the site's work are being significantly reduced in scale, as this could potentially lead to eventual loss of appropriate knowledge and expertise.

Spent fuel

40. Few significant difficulties are any longer apparent with regard to the management of spent fuel at Rosyth and RWMAC believes that BRDL should be commended for effective management of the problem under taxing circumstances. It is noted, however, that spent fuel stored in the UCTP redundant fuel transport containers has now remained on the dockside for an extended period.

Decommissioning

41. In the discussion that took place during the visit, there appeared to be a certain lack of clarity about the ownership of some decommissioning wastes between MoD and the company, although this was something that the Ships Support Agency and BRDL believed would ultimately be resolved based on the cut-off point in the 1997 sale agreement (since this defines the extent of the site's post-privatisation liabilities).

42. There was also an acknowledgement that the estimates of decommissioning waste arisings, identified for the purpose of feeding into the UK Radioactive Waste Inventory, were at best somewhat broad, and probably also incomplete and understated.

43. RWMAC therefore believes that a substantial amount of work will be needed as part of RD83 to achieve full characterisation of the site. An important issue could prove to be what, if anything, is to be done with the main submarine basin.

44. Lastly, there was the indication that AWAF is seen as a facility that will have a role in the long-term storage of some Rosyth decommissioning wastes. Given the implications of the ILW operational wastes present on the site, this would not appear to represent a significant issue, but it would obviously be helpful if the facts, once established, could be clearly set out for the benefit of the local community.

ISOLUS and the Renown proposal

45. The ISOLUS programme as a whole may present opportunities for BRDL. The Company has existing facilities, including the capacity offered by AWAF (now that production of the waste streams for which it was designed will end in 2001), an experienced workforce, and effective local liaison mechanisms.

46. For the present, however, RWMAC is clear that MoD should not agree to the BRDL proposal for Renown going ahead. The Committee's reason for taking this view is the risk that it would compromise the ISOLUS study. This advice has already been provided to MoD in the form of a response to the public consultation undertaken by NNRP on the Renown proposal. The Committee's response, sent on 12 February 2001, is set out in full in the following pages.

ANNEX 5A
HMS RENOWN DISMANTLING PROPOSAL (ENVIRONMENTAL STATEMENT) : TEXT OF THE RWMAC RESPONSE TO NNRP

Opening summary statement

This document sets out the Radioactive Waste Management Advisory Committee's (RWMAC's) comments on BRDL's Environmental Statement (ES) for the Renown Dismantling Proposal upon which the Naval Nuclear Regulatory Panel (NNRP) has invited comments.

RWMAC's view, explained more fully in what follows in this response, is that the ES itself is generally satisfactory and indicates that there will be no significant impact on the environment provided the work is suitably managed. However, the Committee also wishes to draw to the attention of MoD generally, of which NNRP is only a part, that it believes that acceptance of the Renown proposal at this stage would be incompatible with, and could have potentially damaging effects upon, the Ministry's ISOLUS programme for dealing with its decommissioned nuclear submarines more generally.

Background

The Radioactive Waste Management Advisory Committee (RWMAC) notes that Babcock Rosyth Dockyard Limited (BRDL) has made an unsolicited proposal to the Ministry of Defence (MoD) for the dismantling of HMS Renown, a nuclear powered submarine berthed at Rosyth dockyard, on the Firth of Forth, in Scotland.

The dismantling proposal includes the long term storage of parts of Renown's nuclear reactor in a facility located within the Rosyth dockyard - which is owned and operated by BRDL. The proposal can be seen as an alternative to the traditional MoD policy of "afloat storage" of the hulls of nuclear submarines for which the Navy has no further use.

Afloat storage already applies to 10 submarine hulls which are moored under a MoD care and maintenance regime at the Rosyth and Devonport naval bases. It takes place following the removal of nuclear fuel from the submarine, draining of the primary coolant circuit and associated pipework, and further physical processes to prepare the hull for a long period afloat.

The dismantling of HMS Renown by BRDL would be subject to two areas of primary legislation and associated regulation :

- the Nuclear Installations Act 1965 (NIA65) under which the Nuclear Installations Inspectorate (NII) regulates operations within the licensed site at Rosyth Dockyard.

- the Radioactive Substances Act 1993 (RSA93) under which the Scottish Environment Protection Agency (SEPA) regulates the disposal, including discharges to the environment, of waste from premises in Scotland.

RWMAC understands that BRDL will require regulatory consents from both NII and SEPA before it could begin the proposed dismantling work.

The dismantling work of a nuclear reactor would, normally, also be subject to the Nuclear Reactor (Environmental Impact Assessment for Decommissioning) Regulations 1999, (NR(EIA)99, applications under which are decided by the Health and Safety Executive (HSE). These Regulations do not apply to projects serving UK national defence purposes. In view, however, of MoD policy that such exempt activities should be subject to standards and arrangements which are "so far as is reasonably practicable, at least as good as those required by the legislation", arrangements have been made for the application to be assessed and decided by NNRP. Although NNRP is part of the Navy, it acts as an independent regulator within MoD for elements of the nuclear submarine propulsion programme to which the civil legislation does not apply. In this role, NNRP has to decide whether or not it should give approval to BRDL's proposal. It is for other parts of MoD to decide whether the company should be awarded a contract for the work.

Application of the NR(EIA)99 regulations implies that BRDL should submit an ES identifying, describing, and assessing the environmental effects of the project. The effects cover human beings, fauna and flora, all aspects of the natural environment, and material assets and the cultural heritage, all of which are specified in a Schedule to the Regulations. NR(EIA)99 also requires specified parties to be consulted on the application.

Under the special arrangements described above, BRDL has voluntarily submitted an Environmental Statement (ES) in support of its application. NNRP has invited the statutory consultees identified in the Regulations to comment on the ES. It has also asked RWMAC to comment as a discretionary consultee. NNRP has said that it will take views on the ES, received as part of the public consultation, into account in deciding whether or not to give consent to the Renown proposal.

It is a matter of public knowledge that RWMAC is currently carrying out a study on MoD's radioactive waste management practices ("defence wastes"). A key area of defence wastes management, MoD's "ISOLUS" study on the long-term management of nuclear submarines (see section below), overlaps with consideration of the BRDL proposal. RWMAC welcomes being given the opportunity by NNRP to comment on BRDL's ES submission but, in so doing, has also contemplated the Renown proposal in the wider ISOLUS programme context.

The MoD "ISOLUS" programme

In the past¹, RWMAC has criticised MoD for having no policy for the long-term management of defuelled and decommissioned nuclear submarines. In 1998, MoD announced a study aimed at deciding and implementing future policy for managing the hulls, and particularly the Reactor Pressure Vessels (RPVs), of such submarines. This exercise is known as the ISOLUS study, standing for "Interim Storage of Laid-Up Submarines." In essence, ISOLUS aims to secure a consistent approach to the overall management of all existing redundant submarine hulls, as well as the future need to deal with present in-service submarines.

Four options were considered during the first stage of the study - continued afloat storage, and three alternative land storage options. The latter comprised land storage of the intact reactor compartment; dismantling the reactor compartment into its major components for storage as unpackaged waste; and further dismantling of the major components for storage as packaged waste. No assumptions were made about the sites at which storage, whether afloat or on land, would take place. At some point, the site, or sites, would be subject to a selection process.

The first stage of the study concluded that, while afloat storage remains an entirely safe way of storing decommissioned submarines, land storage was the best solution for the longer-term. Accordingly, in order to progress the option, MoD invited expressions of interest from industry for commercial solutions for land storage. It would ultimately be for those with an interest to indicate precisely how they would address the problem, with land storage of intact reactor compartments taken as a benchmark for comparison. Some 15-20 companies expressed an interest in participating in this work during the course of 2000.

ISOLUS involves a commitment to carry out public consultation, the provisions of which incorporate the following : initial (i.e., non site-specific) information about the study and the possible general implications; taking public views, both before and after the process of site selection begins; drawing on the views of experts who can be seen to be capable of representing the public interest; and, using briefings and the Internet, to provide regularly updated information on the progress of the project. There is also intended to be dialogue with both the public and other stakeholders.

RWMAC's view of the BRDL Environmental Statement

RWMAC notes that the required scope and coverage of the ES is set out in the Schedule attached to the NR(EIA)99 regulations.

In RWMAC's view, the ES appears to adequately address the requirements of the NR(EIA)99 schedule.

The Committee believes that, subject to the maintenance of good working practices:

- the proposal appears to be technically feasible and basically consistent with major submarine decommissioning and lay-up work, in which BRDL already has a great deal of experience;

- existing BRDL plant is to be used; no new development is needed. Any work required over and above normal submarine decommissioning and lay-up procedures, which appears to amount to the dismantling of metal structures, in order to remove the RPV, is conventional engineering work for which BRDL has the expertise and which has no significant impact on the environment;

- the need for BRDL to manage radioactive wastes, including discharges, as a result of the proposed Renown work does not appear to have any significant adverse effect on the environment.

RWMAC notes that the proposal would be subject to BRDL making satisfactory safety cases for the dismantling processes and storage of the resulting wastes. These would be judged against conformance to safety principles and criteria laid down by the NII under the provisions of NIA65.

The Committee notes that there will only be minor airborne discharges from the cutting out and dismantling of the submarine's reactor compartment. The Committee sees no reason to question this assessment.

RWMAC also notes that the need for additional discharges of liquid radioactive waste is estimated to lead only to extremely low additional radiation doses to members of the critical group of much less than one microsievert per year.

However, the Committee notes that proposals for the disposal of radioactive waste, including aerial and liquid discharges, will need to be considered and authorised by the Scottish Environment Protection Agency (SEPA) under the provisions of RSA93.

Additionally, RWMAC notes that the possibility of accidental spillage of radioactive effluent is specifically considered and addressed in the ES. In light of the information provided, it seems most unlikely that an accidental release would occur and, even if it did, that its effects could not be suitably mitigated.

Given that any radioactive releases, either aerial or liquid, would be so low, it is difficult to see that there can be any significant radiological impact on the environment from the proposed process. This needs to be confirmed, however, by the regulatory scrutiny required of NII and SEPA.

There is, however, one aspect that may need to be given some further thought in the consideration of the proposals under NIA65, and RSA93 and also, potentially, by NNRP. The potential utilisation of the Rosyth ILW store has, so far as RWMAC is aware, not yet been fully evaluated in the context of any longer-term radioactive waste management and site decommissioning and clean-up planning for the Rosyth site. As the Committee's forthcoming report on defence wastes is likely to make clear, this assessment needs to include the implications for long-term on-site storage of wastes contaminated with carbon-14, a long-lived radionuclide recently (1998) identified as a significant waste stream produced by submarine reactors. Space within the store would also be taken up by any wastes arising from Renown and also, potentially, any other submarines that might ultimately be dismantled for land storage at the site. If so, this could eventually lead to additional radioactive waste storage facilities being needed on the site.

RWMAC's view of the BRDL Renown proposal in the context of the wider ISOLUS programme

It is easy to understand why BRDL submitted the Renown proposal. As a result of a MoD decision in 1993, no submarine refitting work will, after 2001, be carried out at Rosyth. Unless replacement work can be found, BRDL will have a surplus workforce, including expertise and experience built up over many years of submarine support operations, and surplus facilities, including a new, purpose-built, ILW store. It is natural that the company should seek further contracts at an early a stage as possible. Equally, in RWMAC's opinion, any view of the Renown proposal must be placed in the wider context of the ISOLUS programme.

In its report on MoD defence wastes, RWMAC is likely to say that the ISOLUS study needs to be seen in the context of the Government's planned national consultation on the way forward for a policy on management of the UK's solid radioactive wastes. This wider consultation, should, the Committee believes, focus on all the options for the long-term management of solid radioactive waste, both civil and military, and on the means by which the public's views are to be sought and taken account of, rather than on specific management proposals. The Committee has already published its views on the importance of achieving widely-based scientific and societal agreement if policy on radioactive waste is to be successful^2,3. Part of this requirement is the need for decision-making to be, and to be seen to be, transparent and to avoid any suggestion that decisions have been pre-determined, i.e. made in advance of consultation.

RWMAC believes that the ISOLUS study, for reasons of the relative simplicity of the waste streams involved and the waste management practices likely to be needed, can serve as a useful model for public consultation. It is, therefore, in the national, as well as the MoD's, interests that the ISOLUS programme should proceed in a way that reflects the need for transparency in the information provided, full and unfettered public discussion of the options, and decisions which can be seen to derive from public participation in the process. Even if the eventual option for managing the submarines was to be selected more on social, employment, or economic considerations, the Committee believes it is essential, in particular, that radiological factors should be fully aired and understood by both the public and other stakeholders.

With this in mind, RWMAC believes it would be a mistake for MoD to take up the BRDL proposal at this stage in the ISOLUS study. The reasons for this are as follows. As part of ISOLUS, MoD has stated its commitment to listen to public views, take expressions of interest from industry, and then inform industry of the public view to allow it to work up detailed proposals. MoD will then evaluate these proposals in order to decide on the options, and the associated sites to be pursued. If, on the other hand, MoD was to take up the BRDL proposal, it would essentially be pre-selecting a contractor, a strategy for the work, and a site on which to initiate the programme. This would be contrary to the stated principles of the ISOLUS initiative.

A decision by MoD to go ahead with the Renown proposal, in the middle of the ISOLUS initiative, would, in particular, be to undermine the principle of public participation under which the latter is being undertaken. It would send strong signals that decisions had, indeed, been pre-determined and cast doubt on whether contractor competition, which is an element of ISOLUS, was being conducted on a fair and inclusive basis. It might also open up the possibility of a challenge to ISOLUS decisions on grounds that either the public consultation, or the tender competition, were flawed, or both. Any consequent legal ruling, for example if the Renown proposal was to be called-in and decided by Ministers, or made the subject of a public inquiry, could also prejudice the entire ISOLUS programme.

In this context, the exact timing constraints associated with the Renown proposal also need to be contemplated. RWMAC understands that the Renown proposal is constrained by a particular window of opportunity. In essence, BRDL has only a limited amount of time in which to carry out the Renown work until resources have to be switched to a surface ship refitting contract. This in turn implies that the regulatory consents under NIA65 and RSA93 will need to be secured very rapidly. In practice, it is important for the procedures associated with the granting of consents, including those for public consultation, to be undertaken in full in order to obviate the risk of legal challenge.

Hence, RWMAC's wider advice to MoD, irrespective of NNRP's consideration of BRDL's ES, is that it should be extremely wary of pursuing the Renown proposal at this point in time because of the potentially damaging effect of doing so on the wider ISOLUS programme. It is not something that RWMAC itself could support.

However, that having been said, RWMAC acknowledges that, given the expertise and experience of the company workforce and the facilities located on the site, both BRDL and Rosyth should be considered as potential candidates for ultimate delivery of whatever strategic plan for the long-term management of redundant submarines ultimately emerges from the ISOLUS process.
References

1. The Radioactive Waste Management Advisory Committee's Review of the Ministry of Defence's Radioactive Waste Management and Practices, Department of the Environment, Transport and the Regions, December 1997.

2. The Radioactive Waste Management Advisory Committee's Advice to Ministers on the Interpretation and Significance of the Results of Science Programmes into Radioactive Waste Disposal, Department of the Environment, Transport and the Regions, April 1999.

3. Twentieth Annual Report of the Radioactive Waste Management Advisory Committee (Chapter 3), Department of the Environment, Transport and the Regions, November 2000.