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Submarine Dismantling Project Consultation

SEPA's Approach to Regulating Civil and Ministry of Defence Premises

SEPA regulates the disposal of radioactive waste from civil licensed nuclear sites such as power stations and research facilities. Storage of radioactive wastes on those sites is regulated by the Office for Nuclear Regulation.

A number of Scotland's licensed nuclear facilities have reached the end of their productive life and are in varying stages of decommissioning and site clean-up.  Decommissioning is an immense undertaking, with a timescale that can extend from decades to hundreds of years.  As Scotland's environmental regulator, SEPA ensures that all wastes produced during the decommissioning and clean-up of nuclear facilities do not pose a threat to the environment or human health.

At civil licensed nuclear sites, SEPA's role is to regulate those managing the decommissioning work through the Radioactive Substances Act 1993 (RSA 93) and other environmental legislation.  SEPA sets specific limitations and conditions under which radioactive substances can be disposed of. 

The Ministry of Defence (MoD) is largely exempt from the provisions of RSA 93. In cases where the MoD is exempt from such legislation, it is MoD policy to introduce standards and arrangements, where reasonably practicable, that are at least as good as those that would have applied had they not been exempt.  In practice, SEPA and the MoD have agreed that the provisions of RSA 93 will be applied by administrative arrangements. These arrangements ensure that the regulation of MoD installations is consistent with that used for equivalent civilian operators where practicable.

SEPA Involvement in SDP

The MoD has a specific programme for deciding on the most appropriate way of dismantling and disposing of submarines. It is called the Submarine Dismantling Project (SDP) and includes an Advisory Group (on which SEPA is represented) to ensure effective stakeholder involvement.

The SDP seeks to consult the public on the MoD's proposals for dismantling the UK's redundant and de-fuelled nuclear-powered submarines and its assessment of any environment effects it will have.  Submarine dismantling will be closely regulated by a number of independent bodies, including SEPA, to ensure it is conducted in a safe and environmentally responsible way.

The SDP consultation process was launched on 28^th October 2011 for a period of 16 weeks and asks stakeholders for views on the following:

• How the radioactive material is removed from the submarines;
• Where MoD carry out the removal of the radioactive material from the submarines - Rosyth and Devonport or a combination of both sites are identified as the 2 candidate sites where submarine dismantling will take place;
• Which type of site is used to store the radioactive waste that is awaiting disposal, and
• The environmental impacts of the SDP work – this information is included in a separate Strategic Environmental Assessment document.

Options for how radioactive waste is removed from submarines are:

• Separate & store the whole Reactor Compartment 'RC Separation', whole on land. 
• Remove & store the Reactor Pressure Vessel 'RPV Removal' leaving the submarine mostly intact.
• Remove & size-reduce the RPV for storage as Packaged Waste 'Packaged Waste'

Rosyth is one of the candidate sites for this work and has been chosen due to the facilities, skills and experience already available on site.  The type of site to be used for the storage of intermediate level radioactive waste is still being assessed.

SEPA will respond to both the MoD consultation document and the SEA document and the response will be posted on this website.  SEPA will attend the MoD led Consultation workshops being held in Fife, Edinburgh and Glasgow (details below).  Our "role" is to explain SEPA's regulation of Rosyth.

Supporting Information

Our Radioactivity in Food and the Environment (RIFE) report provides an in-depth assessment of radioactivity in food and the environment in the UK and the public's exposure to radiation.  The report focuses on key information that demonstrates both that food remains safe and that the public's exposure to ionising radiation is within legal limits.  The report brings together the results of radiological monitoring carried out by sites we regulate during 2010 and includes information about Rosyth.  The most recent report is RIFE 16. 

SEPA's Pollutant Release Inventory allows you to search our SPRI data for discharges on or off sites we regulate, including Rosyth.