The waters of the Clyde – Forth – Tay Estuaries and Many Other Offshore Areas are contaminated after many years of illegal dumping of Toxic Waste by the MOD and others – And they ain’t done yet – The legacy our children will inherit





Archive files have revealed dumping sites.



13 July 2016: Shocking extent of radioactive waste dumped in Scottish seas

Documents have emerged which show more than 75,000 luminised dials coated with radium were tipped into the Tay Estuary after the Second World War.

Archive files from the 1950s also reveal how radioactive waste from a Dundee plant was secretly dropped into the waters below the Forth Bridge, less than a mile from a radium-contaminated beach at Dalgety Bay in Fife.

The archive files also show other dump sites around Scotland and how waste and sludge from nuclear submarines based at Rosyth Dockyard was regularly being deposited in the Firth of Forth during the 1960s.

Documents at the National Records of Scotland show the now-defunct electronics firm Ferranti Ltd dumped scrap from its Dundee radio valve manufacturing plant in the Firth of Forth at North Queensferry every three or four months between 1954 and 1956 without permission.

Minutes from a Government meeting in 1957 show how national chief chemical inspector Eric Birse concluded Ferranti “had simply decided on their own that it would be a good place for dumping”.

During a visit to the plant in October 1956, the Radiological Protection Service told Ferranti that “the quantities involved could well present a hazard and that you should obtain approval for your dumping point and quantities to be dumped”.

The dumping spot is close to the beach in Dalgety Bay which has been closed because of radium contamination.

The beach was used to break up to 800 planes after the Second World War and the contamination there is thought to come from the instrument dials on the aircraft which had been illuminated by paint containing radium.

The Scottish Environment Protection Agency last year blamed the Ministry of Defence for the contamination, which is being released as the headland erodes.Defence chiefs have disputed its findings.

Documents at the National Records of Scotland also show how the now-defunct Dundee firm UK Time a forerunner to Timex arranged a deal with local fishermen to put 35,000 luminised dials coated with radium into drums and dump them in the Tay Estuary in 1949.

The arrangement, according to Scotland Office papers, continued for eight more years at an estimated 5,000 dials a year before dumping was switched to the UK Government’s site at Beaufort’s Dyke between Northern Ireland and Scotland.”











August 1994; Rosyth to become ‘nuclear graveyard’ says local MP Gordon Brown

The Tory government insisted that ‘storage afloat’ of Britain’s decommissioned nuclear submarines would not compromise safety, after leaked defence documents revealed proposals to moor the vessels at Rosyth naval dockyard indefinitely.

Local MP Gordon Brown, said the plans would turn Rosyth into a ‘nuclear graveyard’. The leaked proposals came as an ironic second blow for dockyard workers who were told last year that Rosyth, Fife, had lost a drawn-out battle with Devonport for the £5bn order to refit the Trident submarines.

Brown, whose Dunfermline East constituency includes Rosyth, attacked as ‘totally unacceptable’ plans to moor seven decommissioned nuclear submarines at the dockyard, while long-term policy was formulated.

Brown said the documents showed safety restrictions at the site were to be downgraded. One proposal was to set aside only £30,000 a year until 2004 for the upkeep of the submarines.

The document suggests that the body for dealing with safety questions will be moved almost 100 miles to Faslane, Strathclyde, and tugs suitable for moving the nuclear submarines are to be located 600 miles away at Devonport.

A Ministry of Defence spokesman emphasised that no decision had been made about future storage of the submarines at either Rosyth or Devonport. Four decommissioned nuclear submarines are already moored at Rosyth with another three at Devonport.

Brown said that the proposals were contained in a leaked government document marked ‘Urgent Restricted’, which he was confident was authentic.

The Government had promised to produce a consultative paper setting out its options for disposal of decommissioned submarines. But this has not yet appeared.

Brown said: ‘My fear is that they have no intention of making proposals at all, and that short- term proposals will turn into medium-term proposals, which will turn into long-term proposals.’

Decommissioned submarines have their highly radioactive nuclear fuel removed, and sent to the BNFL site at Sellafield. The reactor itself is less radioactive and is left in place within the hull.

The MoD said that once the highly radioactive fuel was removed, decommissioned submarines ‘present no hazard to residents near the dockyards or to the workforce. Safety is paramount’.

Brown said: ‘We will not allow the Rosyth area to be frozen by nuclear dumping or becoming a nuclear graveyard. The Government proposals cannot be allowed to go ahead.’

Update:  at 2016 the decommissioned submarines remain dumped at Rosyth








August 2004; Rosyth Royal Dockyard Ltd’s strategy for decommissioning the Rosyth nuclear licensed site

The Rosyth Dockyard in Fife, Scotland comprises a nuclear licensed site and a non-licensed site, both of which contain facilities used to support the refitting and maintenance of nuclear powered submarines.

Rosyth Royal Dockyard Ltd (RRD) is the owner of the facilities on both of these sites and is responsible for decommissioning of these facilities, including management of the resulting waste. RRD is the holder of the nuclear site licence.

Ownership of the waste rests with the Ministry of Defence (MoD), which bears the cost of decommissioning and waste management.









October 2008; Just where the hell are we with nuclear submarine dismantling and disposal

In the UK there are around 27 nuclear submarines awaiting decommissioning, de-fuelling and dismantling. Political decisions surrounding the disposal of nuclear compartments, radioactive wastes and spent fuel are proving to be a major headache for successive governments due to outstanding quantification and preventative measures required to resolve, to the satisfaction of the public risks associated with long-term water storage of the boats, radioactive and chemical contamination, spent fuel and waste management, and handling and recycling reactor compartments.

It is anticipated the works will take around 300 years to complete.








September 2009; Babcock to Buy UK Govt.’s Commercial Decommissioning Arm for £50 Million

Babcock International last week agreed to buy the full commercial arm of the UK Atomic Energy Authority (UKAEA)—a UK government body that provides nuclear decommissioning, waste management, and new nuclear build support services—for £50 million.

The sale follows the government’s announcement in March this year that the UK Atomic Energy Authority was seeking a buyer for UKAEA Ltd.

Its decision to withdraw from the clean-up side of its nuclear sector marked a departure from policies to keep decommissioning and waste management services state-owned.

“The sale of the business will help to reinforce the UK’s strong heritage in the nuclear industry and provide a platform for the further development of skills in this important marketplace,” the government said in a press release on Friday.

“The new ownership structure will help give UKAEA Limited greater commercial focus on its operations, allowing it to capitalise on its core skills, strong track record and brand and I am confident that it will continue its growth in the UK and internationally under Babcock International’s ownership,” said Business Secretary Peter Mandelson.








November 2009; Deep Sea Burial off Barra – Final disposal of nuclear waste

Inexpert work and inexperienced operatives are more likely to cause accidents and take wrong decisions on the hoof. Deficiencies in these areas would aggravate any environmental risk arising from such activity.

For evidence of the phenomenon we are identifying here, one has only to look at the hicksville that was Doonreay in its pomp – chucking nuclear waste down a rock cleft. This is the real issue for watchfulness into the future.

At the moment, nuclear waste goes into containers and his held secure in a number of open sites in Scotland. But this is a holding operation, albeit a mid-term, (2040) holding operation.

According to the experts, we are at least 30 years away from having a secure deep-burial final location for such waste.

Unable to neutralise radioactive material, the existing primitive risk ridden solution is all there is, operating at little more than best guesstimates of the time-frames within which the material can be assumed to remain secure.

Deep-burial will involve drilling 1,000 metres down into rock shown by geological surveys to offer stability, then inserting nuclear waste in secure jacket containers and sealing up the facility.

It is obvious how many points of potential failure exist in such a proposed procedure. We know that Scotland’s seabed south of the archipelago of the Isle of Barra has shown the sort of geological reassurance the MoD is looking for. And we know that the imperial mindset will always look to dispose of risk in what are perceived as the colonies.

The procedures that would apply should the MoD wish to use deep-burial procedures for nuclear waste in a marine location in Scottish waters require the permission of the Crown Estate, (not devolved to the Scottish parliament) which owns and generates revenue from the UK’s seabed out to the 12-mile limit.

Since there is little doubt that the current Scottish Government would not be minded to offer such permission Westminster may introduce changes in the law so that they would not need to seek consent from the Scottish Government, through Marine Scotland, under the Food and Environment Protection Act (FEPA) to dump such waste in this way.

Such solutions are untested, short-term responses to a very profound problem. They will do nothing other than get the stuff out of sight and, in political terms, out of mind.

We would be – literally and irresponsibly – burying time-bombs. The Scottish nation should be ever watchful and stand ready to resist the introduction of a policy to locate deep burial sites for nuclear waste disposal on Scotland’s land or marine territory.








October 2011; Submarine Dismantling Project

Following public consultation, the Ministry of Defence decided that initial dismantling of the submarines will take place at both Devonport and Rosyth Dockyards and that the Reactor Pressure Vessel from each submarine will be removed and stored whole.

Further public consultation, on the selection of a site for the interim storage of Intermediate Level radioactive waste from the submarines, is planned to be carried out in 2014.








August 2012; MoD planned to dump old nuclear submarines in sea

A secret MoD briefing found in the UK National Archives reveals the ministry’s “technical preference” was to dispose of the radioactive hulks at sea without dismantling them. Dumping in this way, however, would raise “many environmental and other issues”, it said.

Since Britain’s first nuclear submarine, HMS Dreadnought, was taken out of service 30 years ago,(still to be found in dock at Rosyth) the MoD has been trying to work out how to get rid of its reactor. Over the decades it has been joined at Rosyth by six other retired nuclear submarines.

Since 2000 the MoD has conducted a series of prolonged public consultations on what to do with all the submarines’ radioactive remains. The latest in the last year suggested that the reactor pressure vessels should be removed from the submarines at Rosyth and Devonport.

But what would then happen to them is still unclear. The MoD says it wants to work with the Government’s Nuclear Decommissioning Authority on whether to build a new waste store, or to use current or planned stores at nuclear power station sites, like the one at Hunterston, Ayrshire.

The briefing unearthed from the UK National Archives by nuclear researcher Brian Burnell shows that the MoD has not always been so indecisive. Marked “confidential” on every page, it was prepared for Dr Dov Zakheim, a senior US defence official, ahead of a meeting in London, and sent in August 1981 by Newman Beaumont, an MoD section head.

How to get rid of defunct nuclear submarines was a “major issue”, the briefing warned. “Disposal by cutting up and burial on land in the UK or long-term laying up at UK berths are not favoured due to practical, financial and environmental reasons.” It continued: “The MoD technical preference is for dumping the whole defuelled submarine at sea, which is considered to be the cleanest, safest and most practical solution.” Defining the submarine as low-level radioactive waste, the briefing concluded, “should mean that there is no strictly legal bar to its disposal at sea but this raises many environmental and other issues”. The MoD dumped thousands of tonnes of radioactive waste in the English Channel and the northeast Atlantic from 1946 to 1983. In 1993 the MoD agreed to an indefinite ban on dumping radioactive waste at sea.









March 2013; Rosyth: No to a nuclear dump.

It was announced in March 2013 that Rosyth will be one of two sites in the UK (along with Devonport ) where decommissioned nuclear-powered submarines will be dismantled. Radioactive waste will be removed from the boats at the site, but no plan is yet in place for what to do with this dangerous material.

This kind of activity carries the risk of radioactive leaks contaminating the local environment, with possible adverse health and safety effects on the local community.

It is therefore particularly worrying that this is set to take place in Rosyth, which is very close to Edinburgh the capital city of Scotland with a population of around a half a million people.

The base, which is situated alongside housing estates, does not have a good safety record, with various accidents in the past possibly causing radioactive substances to leak into the Forth.

The Ministry of Defence (MoD) announced a new Submarine Dismantling Project (SDP) policy in March 2013, following a public consultation. There are 27 submarines which are nearing the end of their shelf life and need to be decommissioned.

After an initial trial of the radioactive waste removal process at Rosyth, the submarines will be dismantled both there and in Devonport. Submarines will be de-fuelled before the dismantling process begins. De-fuelling facilities at Devonport are currently being upgraded with funds from the MoD’s Future Nuclear Facilities programme. De-fuelling is the most dangerous operation of the entire decommissioning process.

Radioactive Reactor Pressure Vessels (each the size of two double-decker buses and weighing around 750 tonnes) will be removed from the nuclear-powered submarines at both Devonport and Rosyth Dockyards and stored intact, prior to disposal in a planned – but as yet non-existent – Geological Disposal Facility.

The MoD is yet to find a location for storing intermediate level radioactive waste. Concerns have been raised that if a suitable site is not found, Rosyth could find itself being used as a ‘temporary’ solution.

The MoD has indicated that no submarines will be dismantled until a storage site has been agreed. It remains to be seen, however, if they will maintain this position if no progress is made in locating a site, especially as a significant delay in the dismantling process would have an adverse economic effect. The next step is for the government to seek regulatory approval for the initial dismantling at Rosyth.

Local people are increasingly anxious at the possibility of increased radioactive contamination of their environment. In the recent government consultation on the submarine dismantling project, many of the responses from the community complained that it was ‘inappropriate’ to use an urban location for dismantling, due to the risk of an accident.











July 2013; MoD can’t be trusted in Rosyth either says Brown after Bay radiation row

Gordon Brown, in parliament said, “if the MoD cannot be trusted to deal with radiation contamination at Dalgety Bay, how can they be trusted with the work of dismantling and breaking up of submarines at Rosyth?” MOD assurances about the safety of Rosyth’s nuclear submarines won’t be believed after their denials in Dalgety Bay.

The MoD, which has conceded responsibility for the contamination of Dalgety Bay has refused to pay for the clean-up of the polluted beach.











December 2013; MoD to be held to account as more than 1000 radiation particles discovered at Dalgety Bay

Gordon Brown MP is to complain that action promised in Dalgety Bay by the MoD by May this year has still not happened. He will reveal the recommendations of health experts that work to clean up the bay should be carried out as soon as possible – and not be subject to further delays.

Dalgety Bay is the first area in the whole of the UK to have a polluter ‘named and shamed’ in this way – and under the legislation which saw the MoD named as the responsible party, it is at risk of being named the only radiation-contaminated area in the UK, blighting the houses and local amenities.

Waste from Dalgety Bay is being stored in the special waste facility at Rosyth but there can be no agreement to long-term storage of nuclear waste from decommissioned submarines at the site as long as local fears about safety along the coast at Dalgety are not properly addressed.








A town meeting of Dalgety Bay community has been called by the Community Council. This will see the community vote on the Ministry of Defence’s plan to clean up radiation from the beach. The pollution resulted from the dumping 800 wartime planes with radiated dials and other hazardous equipment, and subsequent coastal erosion that has brought the pollution to the surface.

The people of Dalgety Bay have won their long campaign to guarantee that the beach area covered in radiation particles would be the subject of an extensive clean up. The work will include removing many of the radiation particles and engineering work will be carried out to build a wall to entomb the remaining materials, preventing them coming to the surface as a result of coastal erosion.









December 2013; Fears over Rosyth nuclear submarine waste

Scotland has been chosen for the pilot project to break up some of Britain’s old nuclear submarines, prompting fears it could become a dumping ground for radioactive waste.

Ministry of Defence (MoD) officials will test the removal of reactors in Rosyth, but politicians and anti-nuclear campaigners have hit out at the plans, fearing nuclear waste will be dumped in the area. A total of 27 submarines are to be dismantled at UK naval bases, with one at Rosyth the first to be cut up.

The Fife yard has been home to the old vessels for years, but concerns have been raised that the site could become a toxic dump after the MoD ordered the “demonstration of the radioactive waste removal process”.

However, the pilot will not go ahead until a storage facility for the waste is identified and further consultation is undertaken, expected to start next year.

SNP defence spokesman Angus Robertson MP said: “The Ministry of Defence’s approach to nuclear safety in Scotland clearly leaves a lot to be desired.“ Instead of experimenting with cutting up these submarines and worrying about the consequences later, the MoD needs to put a credible plan in place for what to do with the radioactive parts of these subs before it begins work.”

The Nuclear Submarine Forum, a coalition of pressure groups, has called for an end to building such vessels until a proper way of dealing with the resulting waste is found.









January 2014; Gordon Brown escapes scrutiny from BBC over Dalgety Bay scandal despite inaction when Prime Minister

Former Prime Minister Gordon Brown has escaped questions over his role in the scandal that has led to the radioactive contamination of Dalgety Bay after the MoD was formally named as the polluter.

Brown, who is the local MP, refused to act when warned about the contamination five years ago when he was UK Prime Minister. Despite this, the former Labour leader is now attempting to portray himself as a leading campaigner calling for the MoD to clean up the mess. Locals are angry amid mounting fears that the area may now be closed down to the public.

In a report on BBC Radio Scotland, the former PM faced no questions from reporter Glenn Campbell over his inaction. The BBC Scotland reporter told listeners the Labour MP was someone “who has been campaigning on this”.

The lengthy piece heard Brown say he was “shocked and dismayed” at the lack of action from the MoD. Mr Brown called on the MoD to clean up the mess and remove risky contaminated material, claiming “it’s not too expensive”.

However, as revealed by Newsnet Scotland as far back as December 2011, Gordon Brown did little to facilitate a clean-up of the area when he was Prime Minister, despite being made aware of the issue two years earlier.

In 2009 when Brown was Prime Minister, the MoD’s own scientists refused to analyse material from the site because of the risk it could give them cancer. Despite this, the MoD continued to resist pressure to pay for a clean-up of the radioactive pollution.

In 2011, the Ministry also continued to play down the possible health risks for members of the public even though official minutes from a meeting in 2009 revealed that MoD scientists had such grave concerns over the contamination that they refused to handle it.

In 2011 after losing the general election, Brown made a rare appearance in the House of Commons and bizarrely gave a speech calling for a debate on the issue, suggesting the seriousness of the situation was new.

Speaking in front of MPs, Mr Brown said: “I call this debate for one purpose and one purpose only, to persuade the Ministry of Defence of the need for urgent action in an area in my constituency where radioactive materials have been discovered.”

The naming of the MoD as the culprit follows years of investigation work carried out by the Scottish Environmental Protection Agency (SEPA). According to SEPA, the area around the bay was contaminated by radioactive material caused by the dumping of components from old World War 2 aircraft.

Concerns for the Fife beach rose after hundreds of radioactive contaminated fragments were discovered by scientists working for the Scottish Environmental Protection Agency.

Some of the material discovered was been described as being so radioactive that it would cause burns if touched. The Dalgety Bay discoveries were made after the MoD had conducted a survey of the area in September 2011, discovering only 33 radioactive fragments.

SEPA scientists carried out their own survey and discovered over four hundred contaminated fragments, some 76 times more radioactive than the previous discoveries.

In November 2011, the MoD refused to accept responsibility for the contamination, something condemned by SNP MSP for Mid Scotland and Fife Annabelle Ewing.

In December 2011, Deputy First Minister Nicola Sturgeon said the MoD’s failure to act was “entirely unacceptable”. Ms Sturgeon also revealed that the Cabinet Secretary for rural affairs and the environment Richard Lochhead had already written twice to the UK Secretary of State for defence urging the MOD to take immediate action, but had received no reply.

In 2012, Annabelle Ewing also revealed how Westminster knew of the contamination half a century ago, (Dalgety Bay is built on the old RNAS Donibristle/HMS Merlin airfield.

After the Second World War the airfield was used to break up redundant aircraft and the waste was used to reclaim land. Included in that waste was traces of radium from the luminous paint used on instrument dials) but kept the revelations secret.

Responding to reports that the MoD was still trying to get out of its obligation to clean up radiation at Dalgety Bay, Ms Ewing said: “Local residents of Dalgety Bay and Fifers from across the Kingdom have been waiting decades for this mess to be cleaned up. “A SEPA investigation last year found the MoD were solely responsible for the contamination.

Any suggestion from the MoD that this matter can be resolved via fences and warning signs is an insult to both local people and all who care about Scotland’s environment. “There can be no more excuses from the MoD – they need to fund and carry out a clean-up at Dalgety Bay immediately.”









February 2014; How Babcock plans to decommission UK nuclear submarines at Rosyth

Rosyth Royal Dockyards Ltd. (RRDL), a subsidiary of Babcock International Group, has applied for consent to begin the dismantling project in January 2016.

The UK nuclear regulator initiated a formal, three-month consultation on the project in late January (for which comments must be received by 21 April 2014.) after what it calls ‘considerable consultation’, the UK Ministry of Defence has chosen to remove radiated waste in-situ at Rosyth and Devonport Nuclear Licensed Dockyards.

But because of delays expected to develop an intermediate-level waste store for the Reactor Pressure Vessels (RPVs) of ultimately 27 decommissioned nuclear submarines, MOD and Babcock have decided to split the d&d operation into two stages. (The ILW site is now expected to be identified in 2016, and operational in 2019.)

Stage one is docking a submarine and removal of low-level waste, primarily within the reactor compartment (RC). Stage two will involve removing the reactor pressure vessel and surrounding primary shield tank.

Stage 2 will only commence when the ILW interim storage solution is agreed. The plan is to dismantle a first demonstration submarine entirely, and study the process, before contracting for dismantling the remaining units. The initial project is expected to take 12 years to complete.







February 2014; Chapelcross Group of discuss submarine plan

Chapelcross Site Stakeholder Group will meet in Annan town hall on Friday to discuss the potential for storing radioactive waste from the UK’s submarine fleet at the former nuclear power plant.

The Ministry of Defence’s Submarine Dismantling Project has shortlisted the site near Annan – whose nuclear rods were removed last year after a major de-fuelling project – along with four others across the border at Sellafield in Cumbria, Capenhurst in Cheshire and at Aldermaston and Burghfield in Berkshire.

A public consultation will take place later this year to determine which of the five sites will be ultimately chosen to store reactor components from disused submarines. The chosen site will be used as an interim storage site for the reactor components until after 2040 when the UK’s geological disposal facility is planned to come into operation.











March 2014; Statement on Hazardous incident at Vulcan Nuclear Test Establishment

The MoD has on Scottish soil, and in Scottish waters, an operational test reactor; a fleet of redundant submarines awaiting dismantling; and an operational fleet of nuclear-powered submarines, four of which are Trident armed. All significant environmental hazards.

Vulcan is the test-bed for the pressurised water reactors used in Britain’s nuclear submarines. As the Defence Secretary put it, the reactors at Vulcan are “hammered”, so that any faults will show up there rather than in an operational submarine.

In January 2012, low levels of radioactivity were detected in the cooling water of the reactor. This took place in a sealed circuit, and we were reassured by the Ministry of Defence last week that there was no detectable radiation leak from that circuit.

However, there should be no radioactivity in the cooling water, and the incident was of such significance that the reactor was shut down for much of 2012 until tests and trials could be carried out. The reactor was only restarted in November 2012 – 10 months later.

The MoD believe that the problem lay in a microscopic breach of fuel element cladding, but they do not know what caused that breach. Nevertheless, they appear to be confident that the reactor can be operated safely until decommissioning begins next year.

The Defence Secretary indicated that this incident would be rated at Level 0 on the 8-point International Nuclear Event Scale, indicating that it is a mere “Anomaly” with no safety significance. Whilst that may sound somewhat reassuring, the incident led to the significant decision to shut down the reactor as a precaution for 10 months.

During 2012, SEPA became aware of an increase in discharges of radioactive gases from the site. Those discharges, at 43% of the annual limit, were within the threshold permitted by SEPA. However, they were much higher than the previous year, when emissions were only 4% of the permitted limit.

We now understand that this was probably due to the testing that took place following the shut-down. That is why the Defence Secretary was wrong when he told the House of Commons that there had been “no measurable change in the radiation discharge” – a publicly reported ten-fold increase is most certainly measurable and I am sure he will want to correct the record.

SEPA were first contacted by the MoD in September 2012 seeking a meeting, but with no details being divulged at that point. A SEPA officer responsible for Vulcan was then summoned to a meeting which took place on 11 December at the site.

At that meeting, SEPA were told about the incident; the tests that had been carried out; and the suspected cause. By then the incident had been classified as one with no safety or environmental impact, and the MoD instructed that the issue must be kept on a strict need to know basis.

Accordingly, neither SEPA senior managers nor the Scottish Government were informed. The UK Government’s own Office for Nuclear Regulation similarly confirmed what was said to SEPA as according to their own spokesperson, “We were required to keep the information on a need to know basis for security reasons.”

We now know that SEPA and Ministers weren’t the only victims of the UK Government’s veil of secrecy. When my own officials visited the site in February 2012 to discuss its decommissioning, there was no mention of any problem.

Let’s be clear. It was the responsibility of the MoD and the UK Government to inform the local community, this Parliament, and the Government, of the events at the test facility. No-one else. We therefore propose to use the forthcoming regulations under the Regulatory Reform Act to leave behind the Crown exemption for MoD sites.

We are fortunate that what we are discussing today is not a nuclear incident, but the failure of the UK Government to be open and transparent about an incident at Vulcan. Where we can act to restore public confidence, in shedding the Crown exemption, we will.

But the MoD’s handling of it – keeping SEPA in the dark for months, and Ministers, Parliamentarians and the public for much longer – is a major concern.

The MoD has again demonstrated a deep-seated culture of secrecy. This raises questions about what else they know but are not telling us. The MoD is in control of facilities which present a great potential hazard in Scotland and it appears that we cannot rely on them to volunteer information.








June 2014; Scottish independence: ‘Yes’ vote could scupper nuclear clean-up

At present, only the seven out-of-service submarines that are currently floating at Rosyth are scheduled to be dismantled there. However, space at Devonport is tight and it is expected that Rosyth would eventually have to take on much more of the dismantling work. There are a further 20 Nuclear submarine hulls at Devonport awaiting dismantling.

A number of engineering companies have registered their interest in dismantling and removing waste from 27 submarines in Devonport near Plymouth and Rosyth on the Firth of Forth. But they are understood to be concerned that a “Yes” vote for independence could complicate the 60-year programme of de-fuelling and breaking up the submarines.

The MoD has refused to draw up any contingency plans.

One industry insider said that delays were “absolutely” a risk, but that the Navy just “laughs off independence as something that isn’t going to happen”. The US has large decommissioning facilities, but these are nearly full to capacity. Sending vessels there would also add to the cost, said to be about £60m a submarine.





17. September 2014; Adverse effects of exposure to Low level radiation underestimated

Insufficient research of low level radiation risks, a matter of much voiced concern was addressed at a recent conference. Speaking during a panel session at the World Nuclear Association’s (WNA) 2014 Symposium, Roger Coates, vice president of the International Radiation Protection Association (IRPA), said that the nuclear industry and governments “have not been honest in presenting the risks of radiation at low levels”.

He suggested the nuclear industry should encourage its radiation protection practitioners to join the debate on presenting the risks of radiation. “If we express risks of radiation in what is defined as ‘normal’ … we will be in a more honest and better situation,” Coates said, rather confusingly. More revealingly, Willie Harris, Director of Radiation Protection at the US utility Exelon Nuclear, stated that the nuclear industry “does not have a significant amount of research in low-dose areas” in its studies and concepts, and that, in some cases, there had been a ‘mis-communication’ of radiation risks.






October 2014; Managing the use and disposal of radioactive and nuclear substances and waste

Five UK nuclear facilities have been confirmed as potential sites to store waste from decommissioned nuclear-powered submarines. A public consultation process will run from 14 November 2014 until 20 February 2015 to help determine which site is selected.

The sites, which already hold radioactive materials, are either owned by MOD, the Nuclear Decommissioning Authority (NDA) or industry. They are:

i. The MOD owned Atomic Weapons Establishment (AWE) site at Aldermaston

ii. The MOD owned Atomic Weapons Establishment (AWE) site at Burghfield

iii. Sellafield in west Cumbria, owned by the NDA.

iv. Chapelcross in Dumfriesshire, owned by the NDA.

v. Capenhurst in Cheshire, which is run by Capenhurst Nuclear Services.

Minister for Defence Equipment, Support and Technology, Philip Dunne, said: “When the submarines in the Royal Navy fleet reach the end of their lives we need to dispose of them in a way that is safe, secure and environmentally sound. This open and transparent public consultation process provides the opportunity to work closely with local communities near to potential sites to listen carefully to their views with the aim of delivering a solution that achieves these objectives. We value the views of those who have something to say about the submarine dismantling project. All of them will be considered properly as part of our decision-making process. After consultation we will publish a report on our findings and after we have selected a site, we will explain why we reached that decision”.

The submarine dismantling project will oversee the disposal of 27 Royal Navy nuclear submarines that are due to have left Naval service by the mid 2030’s and be defuelled, including 19 submarines that have already left service and are stored afloat at Rosyth and Devonport. The submarines can only be completely dismantled once reactor components, which are categorised as radioactive waste, have been removed. The initial dismantling process will support up to 60 skilled jobs.

There will be a series of exhibitions and workshops close to all 5 sites – which were previously announced on a provisional shortlist on 13 February 2014, plus 2 national workshops. The site chosen will be used for interim storage of reactor components until after 2040, when the UK Geological Disposal Facility (a deep geological site for the permanent disposal of spent fuel and nuclear waste) is complete.

The Scottish government is furious that a site north of the border, Chapelcross in Dumfriesshire, has been shortlisted as a location that could store radioactive waste removed from the submarines. When the shortlist was revealed in February, Holyrood environment minister Richard Lochhead wrote to UK Defence minister Philip Dunne demanding that the waste should not be dumped in Scotland.

Dismantling cannot start until a storage site for the 90-to-135-ton reactor pressure vessels, which hold the submarines’ nuclear cores, is agreed upon.





October 2014; SEPA’s Approach to Regulating Civil and Ministry of Defence Premises

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 public were consulted 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.







November 2014; Dounreay Prototype Fast Reactor Sodium Fire

The Prototype Fast Reactor (PFR) sodium tank farm houses four tanks that contain sodium residues from the operation of the reactor. On October 6, following operations in the PFR sodium tank farm to remove the residue sodium from a redundant tank, the tank was left overnight under surveillance. In the early hours of October 7, the Dounreay fire brigade was alerted by an alarm from the tank farm. About the same time, an operator undertaking surveillance heard banging noises and saw smoke, and also called the on-site fire brigade. The fire brigade arrived promptly and quickly extinguished the fire. The area was monitored by the fire brigade until it was deemed that there was a low probability of re-ignition. We continued to monitor the situation and the area was kept under surveillance, until the residues from the fire were cleared up.

The initial investigation confirmed the probable mechanism for the initiation of the fire and concluded radioactivity may have been released, via an unauthorised route. SEPA were informed. It also indicated that there were a number of aspects that required further investigation. The level of the investigation was increased to ensure that the full picture of the reasons for this incident were understood. The investigation thoroughly checked each aspect of the work and identified procedural non-compliances and behavioural practices that were factors in the incident, and fell short of the values and standards expected of our people. It also confirmed the release of radioactivity via an unauthorised route.

Direct action has been taken to stabilise the situation and stop work in the tank farm area. It will not be re-started until the authority is satisfied with improvements. A dedicated team led by a senior manager will be responsible for a safety improvement plan focused on learning lessons from this and other incidents and ensuring there is improvement in the way we undertake work. This improvement plan will be wide ranging and ensure the whole site recognises the improvements that must be made. chapelcross






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