Nuclear Waste fact sheet

What is defined as nuclear waste?

Nuclear waste is a form of radioactive waste that originates as a by-product of nuclear reactors and critical operations. Nuclear waste is potentially hazardous to people and the environment. Nuclear operations conducted by BAE Systems are managed to minimise the generation of waste. The generation, management and disposal of radioactive waste is robustly regulated by Government agencies.

How does BAE Systems use nuclear materials?

The submarines that we manufacture for the Royal Navy are powered by nuclear energy. Unlike engines using conventional fuels such as diesel, a nuclear reactor can operate for twenty or thirty years without refuelling. Our submarines can produce their own oxygen and drinking water, so they do not need to resurface during a patrol and can stay underwater for very long periods of time. BAE Systems builds submarines at our Barrow-in-Furness site in the UK.
 
Before the Navy will accept delivery of a submarine, we must demonstrate that all systems are functioning as intended. Prior to the submarine leaving Barrow, the nuclear reactor and safety systems are thoroughly tested and operated for the first time, which may result in very small volumes of very low hazard nuclear waste. All potential radioactive waste is assessed and managed at a dedicated facility at the Barrow site. Our operations with nuclear materials at Barrow are extremely low risk for employees, the people using our products, the general public, and the environment. 

Who is responsible for nuclear waste at BAE Systems?

The UK Ministry of Defence (MoD) owns the nuclear fuel used in submarines built by BAE Systems. The UK MoD is also ultimately responsible for any radioactive waste generated. At our Barrow Shipyard, BAE Systems Submarines manages radioactive waste on behalf of the UK MoD and holds a Radioactive Substances Permit issued by the Environment Agency. The permit specifies the requirement to adopt the best available techniques to manage waste, and specifies limits on quantities and types of waste that can be generated, and disposal routes that can be used. Compliance with the Permit is reported to the Environment Agency and the UK MoD.
 
The BAE Systems Managing Director of the Submarines business delegates authority to the Chair of the Test and Commissioning Organisation, which controls all activities that operate the nuclear reactor and generate waste. The Chair of the Test and Commissioning Organisation is responsible for ensuring that minimum radioactive waste is generated. Our Barrow Shipyard has modern waste treatment facilities to handle and dispose of any radioactive waste. The Waste Treatment Facilities Manager is responsible for ensuring that all waste is disposed of in accordance with conditions and limits specified in our permit, and the Senior Engineering Manager (Independent Nuclear Assurance (INA)) is responsible for the implementation of a safety management audit and inspection regime that demonstrates compliance with the limitations and conditions attached to the permit.

Does BAE Systems comply with regulation?

Nuclear operations, including managing nuclear materials and radioactive waste, are controlled through a rigorous and comprehensive legal framework in the United Kingdom, by a number of regulatory authorities. The Office for Nuclear Regulation (ONR) grants Nuclear Site Licences; without this our business cannot conduct nuclear operations. The Defence Nuclear Safety Regulator (DNSR) issues a similar Certificate of Authorisation; this permits the submarine to be operated in the Shipyard. The Environment Agency (EA) issues Radioactive Substances (RSR) Permits, which enables us to generate and dispose of radioactive waste. The RSR Permit includes strict controls and limits to ensure that all waste disposal has a minimal impact on the environment and local population.
 
BAE Systems has a series of Compliance Principles Matrices that define the policy and arrangements the Company has in place to comply with the 36 Licence Conditions/Authorisation Conditions associated with the operation of its Nuclear Licensed site.
 
These Compliance Principles Matrices cover all aspects of the management of the Nuclear Licensed site and adherence to these policies provides the management structure required to comply with all Regulatory requirements placed on the Company including the requirements of the Permit. BAE Systems has an approved Business Management System (BMS) that manages all quality documents and procedures, in accordance with BS EN ISO 9001:2015.  The BMS covers the making, retention and disposal of the records required to demonstrate the efficient operation of the Safety Management System and hence the Company’s compliance with condition 1.1.1 of EPR Permit.

How does BAE Systems manage nuclear waste?

BAE Systems must demonstrate to relevant regulatory authorities that we have robust arrangements and facilities in place to manage and carry out nuclear operations safely, minimising risks to people and the environment. We must demonstrate full compliance with all Licence and Permit conditions. Our workforce is highly trained and experienced; and we have a rigorous management and assurance regime to make sure our processes, procedures and operating rules ensure the safety of our employees, the site at Barrow, the public, and the environment.
  
Our nuclear operations are independently inspected throughout the year, both by our own internal nuclear assurance team and external regulatory authorities, including the Office for Nuclear Regulation (ONR), Defence Nuclear Safety Regulator (DNSR) and the Environment Agency (EA).
 
Waste producers/owners, including defined contractor 'Responsible Persons' must ensure that the waste is managed properly, recovered or disposed of safely, does not cause harm to human health or pollution of the environment and is only transferred to someone who is authorised to receive it. Waste is any substance or object which the holder discards, or intends or is required to discard, and includes any waste that comes from:

• any commercial activity;
• construction;
• demolition; and
• industry.

 

Is it safe?

All operations undertaken at Barrow with nuclear materials are extremely low risk; in terms of the safety of our employees, the people using our products, the general public and the wider environment.

What about the risks from nuclear waste? 

The risk presented to the local population from all radioactive waste generated by the Barrow Shipyard is less than the radiation risk of a transatlantic crossing by air. BAE Systems Submarines operates the nuclear plant at the very start of its life. On completion of the testing programme, the submarine is handed over to the Navy, leaves the Barrow dock system and never returns. The low number of operating hours, and clean start of life conditions ensure only a very small quantity of very low hazard radioactive waste is generated. The regulatory authorities assessed the potential impact of this waste on the environment and the local population before operations were allowed to begin under strict conditions. These conditions, covering the type and maximum amount of waste, are included in our Radioactive Substances (RSR) Permit.  All waste is monitored against the permit conditions, and we report our performance in our Annual Report to the regulators. The business has a Permit Compliance forum, where relevant internal stakeholders meet and review all relevant permitting issues (including Radioactive Substances). Letters of Delegation are issued to business leaders responsible for Compliance with the Environmental Permit from the Management Committee.

Do you train employees on how to manage nuclear materials safely?

Ensuring our staff are well trained and suitably qualified is the key factor in ensuring that the Company operates to the highest levels of safety. We have a comprehensive programme established to ensure employees are trained to a level appropriate to their role, from basic induction training to nuclear specialist level. We regularly check that employees who handle nuclear material are up-to-date and familiar with the latest relevant procedures.
 
Radioactive waste is part of a risk management process and subject to regulatory inspection at least three times a year. Assurance is carried out on operators to ensure everything is handled properly.

Relevant Legislation/Guidance

Legislation/Guidance	Details
1965 c.57	Nuclear Installations Act 1965 (as amended)
1974 C.37	Health and Safety at Work Act (as amended) 1974
2023 C.52	The Energy Act 2023
Nuclear Site Licence 42C	Nuclear Site Licence for BAE Systems Marine Limited
EPR/UB3433DW	Barrow Shipyards Nuclear Site Permit
CEAR	Compilation of Environmental Agency Requirements, Approvals and Spcifications (dated 23/08/2022)
SI 2009 No. 1348	The Carriage of Dangerous Goods and Use of Tranportable Pressure Equipment Regulations 2009
SI 1993 No. 3031	Transfrontier Shipment of Radioactive Waste Regulations 1993
SI 2008 No. 3087	Transfrontier Shipment of Radioactive Waste and Spent Fuel Regulations 2008
SI 2016 No. 1154	environmental Pwermitting (England and Wales) Regulations (as amended) 2016
BEIS	Scope of and Exemptions from The Radioactive Substances Legislation in england, Wales and Northern Ireland - Guidance Document - 2018
dstl	Radiological Protection Services - 'Marine Environmental Radioactivity Surveys at Nuclear Submarine Berths'
ISO 17025	General requirements for the competence of testing and calibration laboratories
BS En ISO 9001:2000	Quality Management Systems

 

The information contained in this fact sheet is for PLC managed businesses and is accurate as at the date of its publication.
 
Publication date: 21/08/24