Keep calm and carry on: Immunity from integration for Blighty’s Armed Forces?

The Ministry of Defence (MOD) controls in excess of 250 miles of coastline in the United Kingdom, spread across some 48 coastal sites, making them a key stakeholder in the Coastal Zone Management equation. Since WWI the MOD has acted with relative immunity regarding its use of the coast; Countless chemical and conventional munitions have been dumped in coastal waters with airfields and dockyards growing regardless of existing land uses. Any integration regarding the use of these sites has remained almost solely at the discretion of the MOD. Here, Devonport Dockyard is used as a case study to address the extent of the MOD’s immunity in comparison to other stakeholders.

Devonport, located on the eastern bank of the River Tamar, is the largest naval base in Western Europe, encompassing 6km of waterfront. It is the only facility operated by the MOD that is capable of repairing and refuelling Britain’s nuclear fleet of submarines (HSE, 2004). Devonport overhauls the reactor coolant of these subs, exchanging radioactive water for fresh water. This aqueous radioactive waste is discharged directly to the R.Tamar or the dockyard sewers, a means of disposal authorised on an individual basis by the Environment Agency (EA). It is fair to say that this level of immunity would not be awarded to any other stakeholder in the coastal zone, where this form of pollution would be totally unacceptable.

sub_devonport
A submarine docked at Devonport Dockyard, Plymouth.

In 2002, Devonport successfully applied for permission to discharge 500% more radioactive effluent into the R.Tamar, citing the new generation of nuclear submarines as the reason behind the increase. The EA was satisfied that the new limits would not pose a significant environmental impact and would provide better regulatory control. This authorisation was granted despite the fact that the MoD has not been hugely successful in maintaining high standards with regard to its duty when discarding such waste. Devonport has been responsible for countless nuclear spills in recent years that have all gone unpunished and have even at times been unreported. In 2008, 280 litres of contaminated coolant was spilt into the R.Tamar (Daily Telegraph, 2008).

Following this authorisation, the MOD’s immunity from normal procedures was further ratified when the European Commission sought to take the UK Government to court for breaking conditions of the Euratom Treaty 1957; A European policy on the disposal of nuclear waste (Daily Telgraph, 2008). The UK Government retorted with the argument that Euratom does not apply to sovereign military installations. The European Commission stated that the authorisation was granted “without taking account of Euratom Treaty provisions and legislation regarding the protection of the health of workers and the general public.”

These revised annual limits also only amount to only 1% of the limit deemed hazardous to health. This exemption, however, has not come without restrictions and targets; there is a strict chain of reporting on the new limits and Devonport’s management on an annual basis (EA, 2001a). Furthermore, the Environment Agency has stressed that it is committed to an overall progressive reduction in radioactive discharges and discharge limits in coming years (EA, 2001b).

The other big player in coastal nuclear waste disposal is the energy industry. Nuclear power stations discard aqueous radioactive waste in much the same way, so why should military installations be exempt when looking at management and integration of the coastal zone? Surely people living next to an MOD site should be afforded the same protection as those near a power station?

It is fair to say that the MoD is afforded this immunity because the nation needs to be protected before it can be managed and protected. It seems therefore that the MOD is exempt from Marine Planning and Regulatory policies, in an approach not dissimilar to the cost-benefit analysis. The costs of potential small doses of radiation are outweighed by the benefit of a nuclear capability and deterrent.  Or at least, the benefit outweighs the cost for the decision makers, can the same be said for the local population?

References:

Environment Agency (2001a) ‘Summary Document on the proposed decision by the Environment Agency on the Application by Devonport Royal Dockyard Limited to dispose of radioactive wastes from Devonport Royal Dockyard’,
Environment Agency (2001b) ‘Proposed Decision Document on the application made by Devonport Royal Dockyard Ltd to dispose of Radioactive Wastes from Devonport Royal Dockyard’
Health and Safety Executive (2004) ‘Devonport Royal Dockyard Ltd’s strategy for the decommissioning of the Devonport Nuclear Licensed Site: A Review by HM Nuclear Installations Inspectorate’, Merseyside, England.

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