RWMAC report on MoD radioactive waste practices

ANNEX 6
FASLANE AND COULPORT

History

1. Her Majesty's Naval Base Clyde at Faslane is an operational base situated on the Gareloch, some 25 miles north-west of Glasgow, provides maintenance and support services for two of the three UK nuclear submarine squadrons. It differs from Devonport and Rosyth in two important respects. First, Faslane is purely a submarine operational base, and although limited nuclear repair work can be authorised there, there is no dockyard facility analogous to Devonport or Rosyth and refitting and refuelling is not carried out. Second, the site is wholly owned and operated by MoD.

2. In the months following RWMAC's visit to Faslane in February 2000, there were media reports that MoD had invited DRDL and BRDL, together with a third company, to submit proposals to manage Faslane. If implemented, such a development would, as at Devonport and Rosyth, require the application of full civil regulation to the site, with the exception of the submarine reactors themselves. No mention was made of the contractorisation proposal during the visit, however.

Site regulation

3. As MoD owned and operated sites, NIA65 and RSA93 do not apply either to Faslane itself or to the nearby Royal Navy Armaments Depot (RNAD) Coulport site which, inter alia, undertakes the loading and unloading of submarine armaments, including nuclear warheads. NNRP regulates Faslane, and also NNPP aspects of work at Coulport; Authorisation under the new arrangements was granted in 1999. Nuclear weapons aspects of Coulport work, including use of tritium, do not fall under NNRP regulation but are reported via MoD's arrangements for Radiation Protection (the CESO system described in Annex 2.1). Radioactive waste storage and disposal are, for both sites, regulated by SEPA under the pseudo-RSA93 arrangements.

Radioactive waste generation

4. Faslane deals with radioactive wastes arising from the operation at sea and the maintenance ashore of submarine nuclear propulsion systems. The current wastes consist exclusively of solid LLW and VLLW and liquid LLW. While ILW has, in the past, been generated at the site, RWMAC is not aware of any intention to carry out at work in the future which would generate ILW arisings. There is no submarine spent fuel. Coulport also produces solid LLW, and, in addition, both tritium-contaminated desiccants and liquid scintillant wastes contaminated with low levels of radionuclides. Some airborne radioactive wastes from nuclear weapons handling are discharged to the atmosphere at Coulport.

5. Faslane's procedures for minimising solid waste appear to be very effective. In particular, 80 per cent of submarine waste arisings is disposed of as domestic waste (see below). The remaining 20 per cent, roughly divided between LLW and VLLW, is, like onshore LLW, compacted and placed in 200 litre drums. Overall, these arisings are relatively small - only two drums were filled in 1999. This low rate of production means that drums have been stored on site for several years in order to ensure that the ISO containers employed for transporting solid wastes to Sellafield, which can take 60 drums, are used to capacity.

6. Interim storage at Faslane is limited to a designated Barrel Storage Area. Following supercompaction at Sellafield's WAMAC facility, the compacted drums ("pucks") are consigned for disposal to Drigg. It should be noted that no disposals were made to Drigg in 1999 on account of the carbon-14 problem. Decay storage is also employed and, once activity is at a level to which regulation no longer applies, much of Faslane's solid waste can disposed of as inactive ordinary domestic refuse.

7. Radioactively contaminated resins (in the form of sludges), produced by ion-exchange treatment of submarine low level liquid effluents, are cemented into drums and also consigned to Drigg. Since the resins used in this treatment, which takes place in the Radioactive Effluent Disposal Facility (REDF), can last up to five years, the rate and volume of waste arisings are also limited.

8. After treatment, Faslane's liquid LLW is discharged, via the REDF pipeline, into the waters of the Gareloch.

9. Solid LLW is stored at Coulport pending its disposal, via Faslane, to Drigg. This includes both wastes produced by cleaning and handling processes and desiccant (which is used in the packing of nuclear warheads for their transport from AWE to Coulport). There are also liquid scintillants, the normal disposal route for which is incineration. At the time of the visit, RNAD had applied to SEPA for a Letter of Agreement to transfer the liquid scintillants for disposal by commercial incineration. This element of the overall application was, however, withdrawn when the incinerator operator indicated that it would not accept the waste for burning. The revised permission allowing disposal of solid LLW to Drigg was granted in December 2000.

Waste treatment operations

10. Solid LLW removed from submarines is double-bagged, labelled, given a unique number (in order to provide an audit trail) and accepted into the Active Processing Facility (APF). The radionuclide content and activity of the waste is measured in the APF and its disposal route identified.

11. Liquid LLW from the submarines, which is to be treated in the REDF, is first pumped off the boats. Unlike the operational berths at Devonport, where effluent can be pumped to some shore facilities, the location of the REDF relative to the berths means that the wastes cannot be transferred directly. Currently, two different methods are used. The effluent is piped (via armour-plated hoses) either into Portable Effluent Tanks (PET tanks) mounted on lorries brought to the quay side for onward movement to the REDF, or into the Primary Effluent Barge which is moved to the REDF by sea. On arrival, the effluent is discharged into REDF receipt tanks. It is never held over in the PET tanks or on the barge.

12. The REDF treatment consists of passing the effluent through ion-exchange columns to enable its discharge to sea. The contaminated resins, mentioned earlier, are a by-product of this process. The treated effluent is monitored by Faslane staff before discharge. DRPS, SEPA and MAFF also monitor the effluent for purposes of internally and externally applied controls.

13. The Committee noted, at the time of its visit to Faslane in October 1994, that the PET tanks posed an ongoing, if very small, risk of spillage. Since that time, a new design has been introduced. The new Mark 4 PET tanks have built in bunds to contain any possible spillage. Other technical improvements, for example, once-only use of Gore-tex gaskets, and employment only of civilian SQEP (suitably qualified and experienced personnel) designated operators, has, in RWMAC's view, further reduced the possibility of spillages occurring. There have been no spillages in the last seven years.

14. It was clear that the barge represents the preferred method for transferring the effluent to the REDF among the crews of Devonport-based submarines visiting Faslane. This is because these vessels normally use Devonport's installed pipe system. However, there appeared to be a feeling among Faslane personnel that the barge was only fully under control when berthed to take on or discharge the effluent. On the other hand, the PET tanks have to be moved by lorry through heavily "populated" parts of the base. These concerns will not be removed by the new facility since some means of moving the effluent over relatively long distances will still be necessary. Although present barge operations do not appear to pose any significant risk, the vessel is old and its tanks are single-skinned. In public confidence terms alone, it would be worth replacing the existing barge with a more modern, double-hulled, vessel.

15. It was accepted by HM Naval Base Clyde management, at the time of the October 1994 visit, that the design of the REDF was not commensurate with modern standards. The facility has, however, continued to operate and during the February 2000 visit, RWMAC formed a good impression of the quality of management and operation of the REDF. Assay of the waste stream is undertaken both before and after ion-exchange and based on mid-stream samples. Management of the holding tanks (and associated buffer tanks) is designed to obviate the need for emergency discharges. Record keeping was demonstrated to be meticulous. Nevertheless, the REDF remains, in principle, a less than optimal operation. There are, for example, no bunds at the point of discharge of the effluent into the holding tanks.

16. The previous RWMAC report³ described Faslane's overall radioactive waste management procedures as "complex and somewhat bureaucratic", although the Committee's view was that, in all likelihood, this derived primarily from considerations of nuclear security, rather than waste management per se. The Committee found that the standards of radioactive waste management observed at Faslane were comparable to those of the civil nuclear industry.

Radioactive waste management policy

17. The Director Naval Base Clyde (DNBC), of Commodore rank, is responsible for the safe and efficient running of Faslane and Coulport, including site radioactive waste management. These requirements are reflected in the DNBC Business Plan, which is cascaded down through the business plans, which are, in turn, the "property" of site management staff at various levels. A clearly ordered and defined site management structure was evident which includes separate quality "ensurance" and "assurance" units lying outside the main day-to-day site operation management chains. These arrangements are designed to provide for a strong emphasis on individual task ownership and responsibility for delivery. The base has a dedicated RPA.

Public communications

18. There is a Local Liaison Committee. Monitoring information, including marine environmental surveys, is placed in the public domain. Public focus on radioactive waste management at the base might well sharpen if, as seems likely, the successor treatment plant to the REDF is eventually subject to a planning inquiry.

RWMAC's main observations

19. In RWMAC's view, Faslane's present, or imminent, arrangements for handling submarine solid wastes provide for clear ownership of the wastes to be identified and for a good audit trail, relating to their subsequent treatment and disposal, to be established. The treatment processes undertaken in the APF appear to be carried out effectively. In particular, all waste streams treated in the facility are well characterised.

20. The Committee's view is that Faslane deals with its solid wastes in a generally effective way. Its one reservation concerns the amount of VLLW, albeit small, which is consigned to Drigg mixed up with LLW. Improved waste segregation procedures, carried out in the APF, might be considered. The Committee also notes that there are no formal instructions dealing with on-board minimisation of submarine solid wastes. These might also be considered.

21. RWMAC would also have liked to have seen more progress made in line with MoD's intention to put a replacement ion exchange facility in place by 2003, when the safety case for the REDF expires. Although a design has been produced, which incorporates ultra-filtration as well as ion-exchange, neither planning nor pseudo-RSA93 applications (to the development control authority and to SEPA respectively) had been made at the time of the visit. RWMAC therefore urges MoD to press ahead with development of the new facility. In the Committee's view, it offers the prospect of adoption of improved standards of waste management (inter alia, by bringing treatment of solid and liquid wastes together under the same roof) and safety (since the new facility will be located in a less populous part of the base).

22. The generic problem of carbon-14 contamination of naval nuclear propulsion wastes has probably not seriously affected Faslane - simply because of the limited volume of its waste arisings. As the main body of this report makes clear, BNFL had, by the end of 2000, received complete characterisation information on Faslane wastes.

23. At Coulport, there is a large backlog of liquid scintillant waste. MoD needs to identify, and secure SEPA permission to use, an incinerator for burning these wastes. This should be attended to as soon as possible. The first step, however, should be for Coulport to acquire additional scintillant counting equipment in order to quantify the amount of radioactivity in the backlog of waste as a precursor to its disposal.