SUBMARINE DISMANTLING PROJECT ENVIRONMENTAL STATEMENT NON-TECHNICAL SUMMARY

SUBMARINE DISMANTLING PROJECT
ENVIRONMENTAL STATEMENT
NON-TECHNICAL SUMMARY
In Support of the Application to Dismantle Seven Nuclear Reactors
within Laid-Up Submarines at Rosyth Dockyard
Babcock Marine and Technology
Nuclear Safety Department
Rosyth Dockyard
KY11 2YD
DOCUMENT NO. 1401001
Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
TABLE OF CONTENTS
1.0 INTRODUCTION
4 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 Submarine Dismantling Project (SDP)
The Applicant
Environmental Impact Assessment
Need for the Project
Initial Dismantling at Rosyth Dockyard
Alternatives to the Proposed Project
Consultation and Scoping
Rosyth Dockyard
Planning Policy Context
4 4 4 5 5 6 6 6 6 2.0 THE ENVIRONMENTAL ASSESSMENT
7 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 2.9 2.10 2.11 2.12 2.13 Radiological Discharges
Air Quality and Climate
Flora and Fauna (Ecology)
Landscape and Visual Amenity
Material Assets including Cultural Heritage
Population, Socio-Economics and Health and Wellbeing
Soil, Geology, Hydrogeology and Land Contamination
Water Quality and Resources
Noise, Vibration and Nuisance
Traffic and Transport
Waste Management and Sustainability
Land Use and Materials
Interaction of the Project with other Development
7 7 8 8 8 9 9 10 11 11 11 12 12 3.0 ACTIVITIES WITHIN THE WIDER SDP
13 3.1 The Interim ILW Store
3.2 Final Dismantling at Ship Recycling Facility
13 13 4.0 COMMENTS
14 JANUARY 2014
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
ABBREVIATIONS
Abbreviation
ALARA
BPM
CFC
EA
EIA
EIADR
EMP
ES
GDF
HGV
ID
IHM
ILW
LLW
LLWR
LUSM
MOD
NTB
NTS
ONR
PST
RC
RICT
RPV
RRDL
SAC
SEA
SEPA
SPA
SRF
SSSI
JANUARY 2014
Definition
As Low As Reasonably Achievable
Best Practicable Means
Chlorofluorocarbon compounds
Environment Agency
Environmental Impact Assessment
Nuclear Reactors (EIA for Decommissioning) Regulations 1999 as amended in 2006
Environmental Management Plan
Environmental Statement
Geological Disposal Facility
Heavy Goods Vehicle
Initial Dismantling
Inventory of Hazardous Materials
Intermediate Level (Radioactive Waste
Low Level(Radioactive) Waste
Low Level Waste Repository
Laid-Up Submarine
Ministry of Defence
Non Tidal Basin
Non-Technical Summary
Office for Nuclear Regulation
Primary Shield Tank
Reactor Compartment
Rosyth International Container Terminal
Reactor Pressure Vessel
Rosyth Royal Dockyard Ltd
Special Area of Conservation
Strategic Environmental Assessment
Scottish Environment protection Agency
Special Protected Area
Ship Recycling Facility
Special Site of Scientific Interest
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
1.0 INTRODUCTION
1.1 Submarine Dismantling Project (SDP)
This Non-Technical Summary (NTS)
provides a summary of the Environmental
Statement (ES) for the Initial Dismantling
(ID) of the seven out-of-service defueled
submarines at Rosyth Dockyard in Fife,
Scotland.
ID forms a part of the Ministry of Defence
(MOD) wider SDP that encompasses the
provision of facilities, personnel and
processes to dismantle twenty-seven
defuelled nuclear powered submarines of
past and current in-service classes. Its
stated aim is to ensure that the
implementation of any solution is safe,
environmentally responsible, secure, costeffective and inspires public confidence.
(Radioactive) Waste (ILW) and the entire
RPV will be stored for an interim period
at an existing nuclear site1. When the
Geological
Disposal
Facility
(GDF)
becomes available, the RPV will be size
reduced and the packaged waste sent for
final disposal. The disposal of the whole
RPV to the GDF is being explored as an
Opportunity.
Amongst other regulatory requirements,
consent is required from the Office for
Nuclear Regulation (ONR) prior to
dismantling any nuclear reactor.
1.2 The Applicant
The applicant for this consent is Rosyth
Royal Dockyard Ltd (RRDL), the nuclear
site licensee and a subsidiary of Babcock
International Group PLC.
Rosyth Dockyard has been used for the
refit,
repair
and
maintenance
of
operational nuclear submarines from the
1960s until 2003. As each LUSM Rosyth
boat reached the end of its operational life,
it was defueled and laid up in the Non
Tidal Basin (NTB).
RRDL holds Authorisation from the
Scottish Environment Protection Agency
(SEPA) under the Radioactive Substances
Act 1993 for the management of
radioactive waste arising from or produced
at the Authorised Premises.
Whilst almost all radioactive material is
confined to the Reactor Compartment
(RC), each submarine will be fully
surveyed and any such materials removed
to below regulatory limits.
Each submarine will be returned to the
MOD for transportation to a commercial
UK Ship Recycling Facility (SRF) for the
dismantling to be completed.
Low Level (Radioactive) Waste (LLW) will
be transferred to existing licensed facilities
for waste treatment and recycling, where
possible, or to disposal to the Low Level
Waste Repository (LLWR)
The Reactor Pressure Vessel (RPV) is
characterised as Intermediate Level
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1.3 Environmental Impact Assessment
An Environmental Impact Assessment
(EIA) is required under the Nuclear Reactors
(Environmental Impact Assessment for
Decommissioning) Regulations 1999 as
amended in 2006 (hereafter referred to as
EIADR) in order to identify the potential
effects of the Project.
This Non Technical Summary of the
Environmental Statement (ES) details the
key findings of the EIA process.
1
Selection of the interim storage site is subject to
consultation.
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
primarily within the RC. This first
submarine will then be returned to
afloat storage. Stage 1 will be coincident with the routine docking
and maintenance of each laid-up
submarine.
1.4 Need for the Project
The MOD believes that developing a
solution now for managing the legacy of
out of service submarines, is the
responsible thing to do, rather than leaving
it for future generations.
Submarines are currently stored afloat at
Devonport Royal Dockyard, as well as at
Rosyth and the cost of maintaining them is
increasing as they age. Each submarine
will have been out-of-service for more than
20 years when ID is commenced and the
radioactivity will have decreased.
1.5 Initial Dismantling at Rosyth
Dockyard
After considerable consultation, the MOD
has selected, subject to successful
demonstration and regulatory approvals,
that radioactive waste will be removed
from submarines in-situ, at both Rosyth
and
Devonport
Dockyards.
Nuclear
Licensed
The Submarine Dismantling Consultation
made clear to MOD that identifying a site
and achieving planning consent for an ILW
store would require an extended time
period. As a result, this has led to the joint
MOD/Babcock development of a staged
approach to ID. The two stages are
defined as follows:

Stage 1, will involve the docking of
the submarine and removal of LLW
JANUARY 2014

Stage 2, will involve the docking of
the submarine for removal of the
RPV and Primary Shield Tank
(PST).
Certification
of
the
submarine as free of radioactive
material to below regulatory limits
will be completed. The submarine
will then be made ready for
handover to the MOD and possibly
a further time afloat, before
consignment for final dismantling at
a UK SRF. Stage 2 will only
commence when the ILW interim
storage solution is agreed.
This first ‘demonstration’ submarine will be
dismantled at Rosyth using the same
processes intended for the remaining
submarines. The project will then pause to
assess the lessons that need to be
learned for the remaining submarines and
to improve the understanding of cost,
before contracts are placed for the
dismantling of the remaining submarines
or for the development of any longer term
facilities.
This demonstration will also refine and
confirm the rigorous safety and security
procedures which will be followed in the
design and operation of the dismantling
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
facilities and processes, and validate
radiological dose and discharge projections.
1.6 Alternatives to the Proposed
Project
The MOD conducted Public Consultation
during 2011-2012 on nine options with
a number of variants, developed from
combinations of the following:

Technical Approaches to the ID of
submarines.

ID Site(s).

Generic ILW Storage Site(s) for
ILW arising from initial dismantling.
‘cradle to grave’. These phases are the
MOD’s responsibility and they were not
included in the EIA process. The reader is
referred to the SEA where these matters
are discussed in greater detail.
1.8 Rosyth Dockyard
Rosyth Dockyard is situated at Rosyth
near Dunfermline, Fife, Scotland. It is on
the north bank of the environmentally and
commercially important estuary of the
River Forth, about 2 km west of the Forth
Road Bridge and the M90.
The MOD also undertook a Strategic
Environmental Assessment (SEA). This
was to identify the potential environmental
effects of the proposals, so that they could
be considered and minimised while the
options were being developed and major
decisions made.
The Decision was made in March 2013 to
proceed with the ID as described above
and conduct further assessment and
public consultation with regard to the siting
of the Interim ILW store.
1.7 Consultation and Scoping
The MOD together with Babcock has
undertaken stakeholder engagement and
briefings since the announcement with the
Rosyth Local Liaison Committee and the
SDP Advisory Group Meeting that was
open to the public.
In February 2013, the MOD asked the
ONR to provide an informal opinion on the
proposed format and content of an
application for EIADR Consent to
undertake the ID of the seven nuclear
submarines at Rosyth Dockyard. The ES
follows that format and content and takes
into consideration the comments of the
ONR, SEPA and the Environment Agency
(EA).
The laid up submarines can be seen within
the NTB in this aerial photograph of the
Dockyard.
1.9 Planning Policy Context
The Rosyth Waterfront that includes the
working areas of Rosyth Dockyard, is an
‘Established Employment Area’ under the
Dunfermline and West Fife Local Plan.
It is considered that the dismantling of
submarines is a compatible port related
activity that is in compliance with the
policies within the adopted local plan. The
temporary storage of nuclear waste is a
by-product of this activity and, under the
circumstances; it can be considered that
this is also a port related activity. Thus
no planning application is likely to be
necessary for the SDP ID at Rosyth
Dockyard.
Phases of the SDP other than ID are
considered within the ES and its
appendices but at a high level to inform
the reader of the entirety of the SDP from
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
2.0 THE ENVIRONMENTAL
ASSESSMENT
discharges throughout the design and
operation of the Project.
2.1 Radiological Discharges
The impact on radioactive discharges of
undertaking ID is judged as negligible as
there is no change in radioactive
discharge limits to the environment in the
medium-term life of the project at Rosyth
Dockyard.
Babcock is contracted by the MoD to
maintain the laid up nuclear powered
submarines at Rosyth Dockyard.
Monitoring of levels of radiation and
radioactivity in the environment both inside
and outside of the Dockyard, is carried out
by Rosyth Dockyard, the MOD and SEPA.
It is reported that:
There is potential for long term
improvement as radioactive discharge
limits are likely to be reduced after the
submarines are dismantled.
In 2011, authorised gaseous discharges
from Rosyth were below the Level of
Detection. Liquid wastes are discharged
via pipeline to the Forth Estuary and in all
cases the activities in the liquid discharged
were below authorised limits.
2.2 Air Quality and Climate
The disposals of wastes arising from ID at
Rosyth will not be covered by the existing
waste disposal authorisation and RRDL is
applying for a new Authorisation to
dispose of these radioactive wastes and
continue
management
of
legacy
radioactive wastes. In due course a
Variation or new Authorisation will be
applied for the Stage 2 activities.
Fuels
will
necessarily
be
used
continuously throughout the project but
emissions are judged to have negligible
effect on air quality and potential for global
warming. Mitigation is by forward planning
and good management.
Calculations have shown that liquid and
gaseous radiological arisings from ID, both
for Stages 1 and 2, can be managed
within the existing Rosyth Dockyard
discharge limits. Existing limits for
radioactive aqueous discharges to the
Forth Estuary and radioactive gaseous
discharges to the environment will be
unchanged during ID. There are no limits
for discharge of solid wastes and these will
be increased, with as much as possible
going for treatment and recycling.
The potential dose rates to the general
public remain unchanged.
SEPA require that exposures of the public to
ionising radiation are As Low as Reasonably
Achievable (ALARA). The mitigation of Best
Practicable Means measures will be
employed for management of solid, liquid
and gaseous radioactive wastes and
JANUARY 2014
Fife's air quality is generally good, but in
some areas there is a higher level of air
pollution, mainly arising from the volume of
traffic on the roads.
No ozone depleting substances are in use
across the Dockyard but there is a small
potential for residual coolant to be present
in tanks, throughout the submarine. The
rigid foams used as insulation may contain
chlorofluorocarbon compounds (CFCs).
Hazardous materials such as CFCs and
asbestos that may be present in older
submarines, are identified in the Inventory
of Hazardous Material (IHM or Green
Passport) that is prepared for each
submarine.
The
IHM
allows
for
identification and pre-planning, with
preparations made for collection in
containment by qualified, experienced
personnel and appropriate final disposal.
These matters will all be detailed in the
Environmental Management Plan (EMP)
to be produced for the Project.
The site, being all reclaimed land, is within
the 0.5% annual probability of flooding
from the Forth Estuary. The Project uses
existing facilities and there is no change to
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
the estuary coastal processes. There is no
increase in the risk of flooding elsewhere
or any impact on the resilience of other
areas.
There is little floral and faunal diversity
within the Dockyard and all the sites where
SDP activities will take place have hard
cover and are in current industrial use.
Sea level rise is unlikely to have an effect
within the medium term (12 years) of the
Project. However, estuarine flooding may
occur more frequently due to an increase
in storminess, with more frequent storm
surges and extreme rainfall events.
There is potential for discharges or spills
to be released to the Estuary but in
mitigation, dismantling activities will take
place within the dry dock or in a shore
based building. Furthermore, containment
will be in place for all activities where there
may be release of radiological or
hazardous material.
Activities are unlikely to be affected by
climate change but effects of severe winds
and storms will be mitigated by being
prepared and having local restrictions in
place during adverse weather conditions.
Overall, the impacts on Air Quality and
Climate were considered to be negligible
both before and after mitigation.
2.3 Flora and Fauna (Ecology)
Rosyth Dockyard is located adjacent to the
sensitive environment of the Firth of Forth
Special Protected Area (SPA) and Ramsar
Wetland of International Importance.
These are underpinned by the Firth of
Forth Site of Special Scientific Interest
(SSSI). Upstream is the Special Area of
Conservation (SAC) of the River Teith, a
tributary of the Forth.
ID activities will not affect plants and
animals, or designated nature conservation
sites. It will not affect natural systems or
fisheries. Impacts are considered to be
negligible.
2.4 Landscape and Visual Amenity
The Dockyard is adjacent to three
candidate Special Landscape Areas and
the sensitivity of the maritime landscape of
the Estuary and the Firth of Forth is high.
The submarines have been laid up at
Rosyth Dockyard for many years and the
facilities to be used are existing with no
new buildings planned. New or existing
cranes are required for ID. They will be
below the established dockyard skyline
and therefore not be out of place with
regard to existing cranes and buildings
already present on site.
Any additional lighting is likely to be
directed down into the dock and not
present a visual disturbance. This will be
addressed in the EMP.
It is judged that initial dismantling activities
will have negligible effect on landscape
and visual amenity.
Photograph of oystercatchers on the Firth of Forth
taken from the wildaboutbritain website
The MOD carried out a Habitats
Regulations Assessment as part of the
SEA and judged that at Plan level, the
effects of the Project at Rosyth Dockyard
will not have any adverse impact on the
integrity of the SAC, SPA or Ramsar Sites.
JANUARY 2014
2.5 Material Assets including Cultural
Heritage
Rosyth Dockyard contains two Grade B
listed historic buildings and the Waterfront
area has Grade A listed buildings
(Scheduled Monuments) remaining from
pre-reclamation of the Dockyard.
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
training and experience and will be of long
term benefit in the civil nuclear industry at
the end of the Project.
From a postcard owned by Bob McEwan on the
undiscoveredscotland website
It is considered that there is no likelihood
of impact on any cultural heritage site or
assets. There is low potential for finding of
artefacts in the made ground as there will
be minimal excavation required. Impacts
have therefore been assessed as
negligible.
2.6 Population, Socio-Economics and
Health and Wellbeing
The main settlements nearby are Rosyth
and Dunfermline to the north but there is
no resident population within 0.5 km of the
site in any direction.
Fife makes a significant contribution to the
Scottish economy with an annual business
turnover of £10,000m that supports around
9,000 businesses and over 160,000 jobs.
However, Fife faces significant economic
and social challenges to recover from the
global financial crisis and return to growth.
These challenges include economic and
employment growth across key sectors to
remove reliance on public sector
employment.
Babcock in 2012 supported almost 1,600
jobs at Rosyth that contributed over £100
million of Gross Value Add. 86% of the
workforce is in the two highest skill
categories compared to just 51% across
Fife as a whole and 87% of employees live
in Fife.
The Project will provide medium-term
benefit in maintaining employment for the
12 years of the Project for about 80
people. There will also be additional
benefits of employment to contracting
companies. Skills will be enhanced by
JANUARY 2014
The well-being of the community also
depends to some extent on public
confidence that the process is safely
managed and that risks really are as low
as they are said to be. Mitigating actions
will include:

Promotion of a project culture
which
values
appropriate
transparency and engagement with
the local community.

Provision of information on safety
management
and
regulatory
oversight arrangements.

Ongoing communication with (and
provision of information to) Rosyth
Local Liaison Committee.

Responding promptly to any
questions or concerns raised
directly by members of the
community or expressed in local
media.
It is considered that clearing the legacy of
the laid-up submarines with their removal
from Rosyth and much of the materials
being recycled, will be seen by the
community as a benefit and that the public
image of the site will be improved.
By removing the submarines, the project
releases important facilities for other
commercial use. This will promote
diversity and new opportunities for
economic growth and is beneficial.
The project is judged as beneficial in both
the medium and long term and of minor
significance. Its benefits are enhanced by
maintaining good communication with
stakeholders and the community.
2.7 Soil, Geology, Hydrogeology and
Land Contamination
After the seven submarines were laid up,
redundant facilities and areas were
radiologically surveyed and remediated.
An area of conventional contamination
also had remedial action undertaken.
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
Radiological
or
conventional
land
contamination could result if polluting
substances or spills were washed into the
ground.
The dock, roadways and the Active Waste
Accumulation Facility (AWAF) that will be
used in ID activities have hard standing.
Land contamination is only likely to occur
in areas of excavation and excavation will
be minimal in this project.
Potentially contaminating materials will be
identified, properly stored and disposed of
appropriately to avoid land contamination
and this will be detailed in the EMP.
It is considered that land contamination
risks to the site are minimal with proper
containment of hazardous and potentially
radioactive materials. There is no risk of
mobilising any existing land contamination.
Impacts on Soil, Geology, Hydrogeology
and Land Contamination have therefore
been judged as negligible.
2.8 Water Quality and Resources
Ensuring the water quality of the Forth
Estuary is fundamental, as it represents
both an important estuarine water
resource and an area of international
ecological significance. There are no
natural streams running through the
Dockyard.
Surface
water
run-off
from
the
impermeable areas is discharged to the
Estuary through ten consented surface
water discharges. The SEPA consented
radioactive discharge is also to the Forth
Estuary.
The potential for radioactive or chemical
spillages or discharges entering drains or
dock culverts and reaching the Estuary
has been addressed in a Hazard and
Operability study. A range of safety
measures have been put in place.
JANUARY 2014
Photograph of dolphins on the Firth of Forth by
Peter Dollive (wildaboutbritain website)
A small volume of water will be added to
the RPV in Stage 2 as shielding and then
be removed for treatment before discharge
to the Estuary. A larger volume of
potassium chromate solution will also be
removed and disposed of offsite at a
specialist facility. Both these mildly
radioactive liquids will be contained with
design and engineered safeguards in
place for management of removal and
disposal.
Only very small residual volumes of nonaqueous liquids are anticipated to be
within the submarine; these are identified
in the IHM, and managed by containment
before appropriate disposal.
There is design intent not to use any water
or other liquids in processes where there
are suitable alternatives, such as
diamond-wire cutting. This will minimise
aqueous arisings and no discharge
consent will be required.
Potential impacts are mitigated by using
dry processes wherever possible, together
with the BPM management procedures of
containment and storage.
The effects of initial dismantling on water
quality and resources are judged as
negligible as there will be no change in
water demand and no change to amounts
and quality of surface water and
groundwater flows. The quality of the Forth
Estuary will not be affected.
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
2.9 Noise, Vibration and Nuisance
Health and Safety at Work legislation
requires that where noise poses a risk to
workers health, mitigating actions must be
put in place. Similarly, the general public
and residents must be protected not only
from physical damage to health, but also
from nuisance which causes deterioration
of their quality of life.
and
all
movements
to
minimise
disturbance and congestion and to carry
out transportation of people and materials
safely and with the required security.
HGVs will not go through the residential
areas of Rosyth but go instead along the
lower road to Ferrytoll and the M90.
With planning, it is expected that there will
be minimal nuisance and disturbance.
Noise and lighting levels are monitored
routinely at Rosyth Dockyard, both inside
the
Dockyard
and
outside.
Risk
assessments including assessment of dust
are routinely undertaken as part of work
planning
Should the Port Babcock Rosyth
International Container Terminal (RICT) be
developed, it is anticipated that daily traffic
movements (two way) will rise from 20 to
900 over the first ten years of operation
that will dwarf ID movements.
It is unlikely that any activity will be noisier
or have the potential to cause more
vibration or dust than any other activity
currently undertaken at Rosyth Dockyard.
Any additional lighting that is required is
likely to be down within the dock and will
not cause nuisance to others.
Nonetheless, the impact after mitigation is
scored as minor negative as there will be
an increase in the number and frequency
of HGV and vehicle movements to and
from the site.
These matters will be detailed in the EMP
and monitoring will continue through the
life of the project.
2.11 Waste Management and
Sustainability
2.10 Traffic and Transport
Scottish waste legislation places a duty on
all persons who produce, keep or manage
waste, including Local Authorities, to apply
the waste hierarchy. This is central to the
development
of
sustainable
waste
management in Scotland and the ambition
of a zero waste society.
Some new plant and materials will be
required to carry out this Project and these
are likely to come by road. One or two
loads per week of material for recycling or
disposal will leave the site by Heavy
Goods Vehicles (HGV).
It is the intention that recycling of material
will be maximised where possible. This will
apply to both radioactive and nonradioactive materials in line with the Waste
Hierarchy, with the minimum going to
landfill, the LLWR and GDF.
The RPV in traveling by road to the interim
ILW store, will require the use of a special
road trailer complying with UK road
regulations. Such a movement will occur
seven times in total with a likely interval of
6 months to a year between movements.
Potentially 520 tonnes of radioactive waste
will be produced from the RC per
submarine. Approximately 490 tonnes will
be metallic and 30 tonnes non-metallic
material. For seven boats a total of 3640
tonnes will be produced.
There will also be workers and contractors
coming and going from the site over the 12
years of the project.
Only small amounts of non-radioactive
waste will be removed in the ID but a
quantity of materials from the RC are likely
to be characterised as not being
The impact of activities on noise, vibration
and nuisance is judged as negligible.
These matters will be detailed in the EMP
and care will be taken in planning of loads
JANUARY 2014
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
considered as radioactive2 and will be
recycled/disposed of as non-radioactive.
Very small quantities such as asbestos
containing material may be Special Waste
requiring appropriate disposal. These will
be managed according to the RRDL
environmental policies and procedures.
It is acknowledged that throughout the 12
years of the Project, there is a continual
disposal of largely radioactive waste.
However, the end result is that a legacy of
waste is correctly disposed of, with
maximised recycling, ensuring we do not
leave unnecessary burdens for future
generations.
The
most
significant
recycling
opportunities arise in the final dismantling
phase at the ship recycling yard when
more than 3500 tonnes per submarine of
readily recyclable high quality metals can
be reclaimed.
2.12 Land Use and Materials
Rosyth Dockyard was constructed about
100 years ago, with additional facilities
such as the Active Waste Accumulation
Facility (AWAF) constructed more recently.
No new buildings will be constructed for
the Project as it makes use of existing
facilities, modified to be fit for purpose.
New cranes will be required but will have
potential for re-use as will some of the
plant and tools required.
The project will not use significant
amounts of energy. It is considered the
impact on land use and materials is
negligible.
2.13 Interaction of the Project with
other Development
The Queensferry Crossing
The Queensferry Crossing is scheduled
for completion in 2016.
The associated improvement works will
aid vehicular movements to and from the
Dockyard. Windshielding on the new
bridge is claimed to protect the crossing
from the effects of wind and provide a
more reliable corridor, particularly for
HGVs.
Port Babcock Rosyth
Container Terminal
The medium term impact is judged as
minor negative in that waste is continually
being produced through the 12 years of
the Project, but after mitigation and
considering the end benefits, is judged as
minor positive.
An additional benefit is that by undertaking
this work, Rosyth Dockyard is relieved of a
legacy responsibility and the site is then
available for commercial use that is likely
to bring about further economic benefits.
2
International
The RICT scheme is for development and
delivery of an intermodal container
terminal immediately upstream of Port
Babcock Rosyth. The scheme makes use
of the deepwater access conditions and
land previously reclaimed that is currently
lying derelict.
The construction period will be about 20
months and is likely to be in development
as the Queen Elizabeth Class Carrier
builds come to a close.
Freight traffic generated by the RICT will
travel through the dockyard, with 95% of it
expected to travel from or to the Ferrytoll
Junction and the M90 or the Forth Bridge.
Where radioactivity is below regulatory limits.
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
The significant HGV traffic associated
with the RICT means that any traffic
generated by the SDP will be negligible in
comparison.
Within the Dockyard, ID may cause
infrequent, short-term and local disruption
to traffic movements as the large load of
the RPV is moved. This is considered to
be of negligible impact.
Effect on Environment of European
Economic Area States
There is seen to be no effect on the
environment of other European Economic
Area States.
3.0 ACTIVITIES WITHIN THE WIDER
SDP
Certain activities within the wider SDP are
the responsibility of the MOD and not
Rosyth Dockyard and therefore are not
assessed within the ES. Regulators other
than the ONR may have jurisdiction over
these matters.
3.1 The Interim ILW Store
This activity is the responsibility of the
MOD.
Site Selection
Existing UK nuclear licensed or authorised
sites that meet the availability criteria will
be provisionally short-listed by the MOD in
a Screening and Criteria Report.
This shortlist will then be taken forward for
more detailed comparison, informed by the
updated SEA and public consultation,
before selecting a specific site for which to
seek planning and regulatory consents.
It is expected that the selected site will be
announced in 2016.
The acceptance of the entire RPV by the
GDF is seen as an Opportunity.
Otherwise, the RPV will require to be size
reduced and packaged in industry
standard boxes before dispatch to the
GDF. This may be up to 100 years from
now.
Regulatory Responsibilities
The store will be required to be on a nuclear
licensed or authorised site. A new store will
certainly require planning permission.
Thus regulators having responsibilities at
this stage of provision and operation of the
interim store are the Environment Agency
(EA) or SEPA, ONR and the Local
Planning Authority.
Responsibility for transport to and from the
interim store of MOD radioactive material
rests with the Defence Nuclear Safety
Regulator.
3.2 Final Dismantling at Ship Recycling
Facility
The MOD remains the owner of the
submarine after completion of ID and
clearance of radioactive material (to
regulatory limits). The submarine will be
restored by Babcock with MOD oversight
to standards set by the MOD Design
Authority (Structures) for afloat storage
and onward transportation to the compliant
UK SRF.
The regulating or Competent Authority is
likely to be the EA (or SEPA in Scotland)
and will regulate the authorisation of
recycling facilities through the environmental
permitting system (or equivalent).
Approved documents/authorisations required
will be:

Document of Authorisation of the
SRF to be granted to the facility by
the competent authority, likely to
be the EA or SEPA.

Ready for Recycling Certificate and
updated IHM for the vessel, to be
obtained by the ship owner prior to
Technical Requirements for the Store
The store will be designed in accordance
with Industry Guidance and will store
RPVs from the 27 submarines.
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Submarine Dismantling Project Environmental Statement. Non Technical Summary. Doc No. 1401001
selection of the SRF. This details
the nature, location and estimated
quantity of hazardous materials
remaining after waste minimisation.


Rosyth
Library,
Parkgate
Community
Centre,
Parkgate,
Rosyth, Dunfermline, Fife, KY12
7EP.
Ship Recycling Plan to be
developed by the recycling facility
in consultation with the ship owner
before dispatch of the vessel to the
SRF. The Competent Authority is
to be informed of selection of the
SRF for recycling of the vessel.
Significant recycling opportunities arise
with high quality steels and other valuable
metals being released.
4.0 COMMENTS
If you wish to make a representation
regarding the EIADR process, this Nontechnical Summary or the Environmental
Statement, please submit comments in
writing before the expiry of the period of
thirty days starting with 16th January 2014
to the Office for Nuclear Regulation, FAO
Mr Ben Hughes, ONR, Project Officer for
International Shipments, Sources and
Environment Team, 4N.1 Redgrave Court,
Merton Road, Bootle L20 7HS, stating the
grounds
for
your
representation.
Representations can be sent by email to
[email protected].
All the documentation involved in the
EIADR process is publically available and
is readily available from a number of
sources. Documents can be obtained
from:

ONR
from
the
website,
http://www.hse.gov.uk/nuclear/eiad
r.htm

the HSE knowledge centre (Bootle)

or the HSE office local to Rosyth.
Additionally the
inspected at:

documents
can
be
the offices of the Licensee at
Rosyth Business Park, Rosyth,
Dunfermline, Fife, KY11 2YD;
JANUARY 2014
PAGE 14 OF 14