An application by the MoD to overhaul waste disposal from the Faslane and Coulport nuclear bases near Helensburgh suggests that radioactive discharges could rise sharply as more submarines are stationed there.
The liquid waste comes from the reactors that drive the Royal Navy’s submarines and from the processing of Trident nuclear warheads. It will be discharged from Faslane into the Gareloch nearby via a proposed new pipeline.
Increased pollution has been condemned by local authorities as “reckless and unacceptable” because it could contaminate wildlife and local communities with radioactivity. The MoD’s plan has also been criticised as “unwelcome” by a former environmental regulator.
According to the MoD, however, the proposed discharges were within permissible limits, and it was proposing to reduce those limits. “Nuclear safety is our top priority,” it said.
Faslane is currently the home port for four nuclear-powered Vanguard submarines armed with Trident missiles. It also hosts an ageing nuclear-powered Trafalgar submarine and three new nuclear-powered Astute submarines.
There are four more Astute submarines due to come to the Clyde – though they have been delayed – as well as another old Trafalgar submarine. In the 2030s the UK government also wants to station a fleet of new Dreadnought submarines armed with upgraded Trident missiles there.
In May 2019 the Clyde bases naval commander, Donald Doull, applied to the Scottish Government’s regulator, the Scottish Environment Protection Agency (Sepa), for renewed “approval to dispose of radioactive waste”. Ageing waste management facilities were being replaced with a new “Nuclear Support Hub” at Faslane, he said.
Solid and liquid waste from neighbouring Coulport, where Trident warheads are stored and processed, would be transported to the Faslane hub for treatment, along with wastes from submarine reactors. The resulting liquid radioactive wastes would be discharged “at a point approximately one kilometre north of the current discharge point” in the Gareloch, Doull stated.
He pointed out that proposed annual limits for discharges were being reduced “where practical”. Predicted radiation doses for the most exposed people were “significantly below” the recommended safety limit and there would be “no radiological hazard for any member of the public”, he said.
What Doull didn’t say, however, was that the amounts of radioactivity scheduled to be dumped into the Gareloch are due to rise – in some cases dramatically.
A table on page 34 of the Clyde bases’ detailed 76-page application listed the radioactive wastes expected to be discharged every year from the new Faslane hub. “Activity levels in treated liquid effluent discharged to the Gareloch have been estimated based on the maximum anticipated radionuclide levels,” the application said.
Future annual discharges of cobalt-60 – one of the main radioactive wastes from submarine reactors – were given as 23.4 million units of radioactivity, known as becquerels. This is 52 times higher than the average annual discharges of cobalt-60 over the last six years – 0.45 million becquerels.
Future annual discharges of tritium, a radioactive waste from reactors and bombs, were listed as 175,000 megabecquerels. This is 30 times higher than discharges in 2018 and 13 times higher than average annual discharges between 2013 and 2018.
The consultation document published by Sepa implicitly accepted that there could be increases in radioactive waste discharges, but did not quantify them. “Although there are plans to increase the numbers of submarines at Faslane this does not represent any change to the nature of the radioactive waste arising, although it may have an impact on the quantity of waste produced,” Sepa said.
The 50-strong group of Nuclear-Free Local Authorities (NFLA) – it includes West Dunbartonshire, where it was agreed by the former Labour administration on Dumbarton District Council – has objected to the rising discharges. “If permitted by Sepa, they would result in increased radioactive contamination of the entire Gareloch, including its flora and fauna, and would result in increased radiation doses to people living in the vicinity of the loch,” it said.
NFLA Scotland convener, Glasgow SNP councillor Feargal Dalton, urged Sepa to scrutinise the MoD application carefully. “NFLA is particularly concerned about the considerable uncertainties in modelling doses and an under-appreciation of the effects of tritium,” he said.
“There are effective alternatives to nuclear powered submarines, as pioneered by the likes of Japan, and the Ministry of Defence should make a serious attempt to look at them.”
NFLA has been backed by Kimo International, which brings together 70 coastal local authorities from across Europe. “Kimo is alarmed about the significant environmental impact of increased radioactive contamination,” said the group’s spokesperson, Arabelle Bentley.
“Kimo believes that the substantial increase in radioactive waste discharged without due diligence or mitigating actions would be both reckless and unacceptable.”
The envisaged discharges from Faslane have also been criticised by Professor Campbell Gemmell, a former chief executive of Sepa and government advisor. “As a citizen it seems to me that any increase in radioactive and general effluent loading is unwelcome and would take us in the wrong direction,” he told The Ferret.
“We want to see a lowering of radioactivity in the environment and in effluent wherever possible and given the base’s record of compliance as well as the history of accidental releases, serious scrutiny and oversight is certainly merited.”
Dr Ian Fairlie, a radiation expert who used to advise the UK government, described the proposed increases as worrying. “I do not think that the MoD has done enough work on estimating the increases in the levels of tritium and cobalt-60 in the flora and fauna of the Gareloch,” he said.
“Would Sepa staff be prepared to live near a loch with such huge annual discharges of radioactivity? I doubt it, and consider that the MoD’s proposed discharges should be disallowed.”
The Scottish Campaign for Nuclear Disarmament accused the MoD of failing to investigate or eliminate the nuclear wastes left by submarines. “Increases in radioactive discharges at Faslane are unacceptable,” said campaign chair, Lynn Jamieson.
“There is no safe dose of radiation for a pregnant mother or an infant. The local harms caused by weapon systems make a nonsense of defence.”
The former SNP MP and anti-nuclear activist, Dr Paul Monaghan, said: “Everyone living in Scotland should be alarmed and concerned by the Ministry of Defence proposal to dispose of liquid radioactive waste by pumping it directly into the sea from Faslane.”
The Ministry of Defence did not directly address the proposed increases in cobalt-60 and tritium discharges. “Nuclear safety is our top priority at Her Majesty’s Naval Base Clyde and will always remain so,” an MoD spokesperson said.
“The previous limits in the extant letters of agreement between the MoD and Sepa were set over ten years ago. Since then reactor technology and practices have advanced meaning that, even with more nuclear vessels, we expect less radioactive waste.”
The MoD added that the Clyde bases operated under “stringent safety standards” imposed by its internal watchdog, the Defence Nuclear Safety Regulator. Its annual reports were released for ten years under freedom of information law, but have been kept secret for national security reasons since 2015.
The Scottish Environment Protection Agency’s radioactive unit substances manager, Paul Dale, confirmed that an application had been received from the MoD and a public consultation launched. “Current and proposed site discharge levels fall within agreed limits,” he said.
“Sepa’s public consultation is open until 13 March and we welcome all responses, including those from NFLA and Kimo. All responses will be reviewed in detail to ensure we continue to safeguard the environment and human health.”