Rosyth Royal Dockyard Limited - variation application

We received an application from the Rosyth Royal Dockyard Limited (RRDL), on 18 March 2023 for a variation to permit EAS/P/1173595/VN02.

RRDL have submitted a number of documents in support of their application. The documents include the application form, as submitted by the applicant, along with a technical supporting document. These documents are listed below.

• RRDL variation EASR permit modular application forms sections 1-5.
• RRDL variation application supporting document (ref 2301005).

Rosyth Royal Dockyard Limited (RRDL) are undertaking the dismantling of seven redundant nuclear submarines that are stored safely afloat in the non-tidal basin at Rosyth Business Park with their fuel removed before storage. This constitutes part of the UK wide Submarine Dismantling Project (SDP) which aims to fully dismantle the UKs nuclear submarine fleet which is now out of service.  

The SDP is a staged project with RRDL having completed Stage 1 successfully and safely on four of the submarines at Rosyth Business Park so far. Stage 1 of the SDP involved the removal of Low Level Radioactive Waste (LLW) from the submarines. 

In order for Stage 1 to commence RRDL had to apply to SEPA for a new Authorisation under the Radioactive Substances Act (1993) (RSA 1993). This was granted by SEPA in 2016 and RRDL commenced dismantling activities that year. The Authorisation allowed the removal of LLW and permitted gaseous and liquid discharges to specific permitted limits. Historic data has shown that RRDL has operated below the permitted limits in each Authorisation held.

With the introduction of new legislation on 1 September 2018, known as the Environmental Authorisations (Scotland) Regulations 2018 (EASR), the original RSA 93 authorisation was superseded and a new disposal permit (EAS/P/1173595/VN01) came into effect. There were no changes to the permitted limits.  

The SDP has now reached the point where RRDL are planning Stage 2 which involves the removal of Intermediate Level Radioactive Waste (ILW). This is primarily the Reactor Pressure Vessel (RPV) associated with each submarine.

To allow RRDL to receive and manage the ILW from the submarines the RRDL permit needs to be varied by SEPA. This will allow RRDL to remove all the remaining radioactive waste (including ILW) from the submarines in preparation for them to be fully dismantled and structural steel and non-active components either reused or recycled, where practicable.

To accommodate this, a new facility is being built by RRDL at 2 Dock on Rosyth Business Park within the nuclear licensed site. The new facility requires the installation of an active ventilation system. RRDL are, therefore applying for a new authorised radioactive gaseous waste discharge point. 

RRDL have undertaken a review of the current facilities on the site and the levels of radioactive aqueous and gaseous discharges at this time and projected to the future due to the operations associated with Stage 2 of the SDP.

Based on this review RRDL have identified that an increase to the current radioactive aqueous and gaseous discharge limits is also required. RRDL have determined the new limits they are applying for using actual data or the best information currently available. RRDL claim that the new limits will allow the site to continue flexibly with SDPs proposed activities without a need for a further application in the future.

The proposed limits have been modelled and assessed to determine whether there would be any environmental impact. The models were used to assess the radiological dose to the public, to non-human species as well as the transboundary dose to the nearest country outside the UK. All the results were well below the public dose limit of 1000 µSvy^-1 and the screening value of 10 µSvy^-1 for the protection of non-human species.