END-OF-LIFE PREPARATION FOR SUBMARINES
5. MINISTRY OF DEFENCE IMPLEMENTATION
5.1 APPLICABILITY
The applicability of the Convention requirements to the Ministry of Defence (MOD) vessels is currently yet to be determined.
Whilst draft Article 3 of the proposed Convention provides an exemption for government owned ships including any warships, the same article requires the adoption of appropriate measures (not impairing operations or operational capabilities of such vessels) to be taken to ensure that such vessels act in a manner consistent, so far as is reasonable and practice, with the proposed Convention.
Notwithstanding this, DEFRA’s UK Ship Recycling Strategy and the MOD Environmental Policy Statement and Guiding Principles [4] commit the MOD to comply with all legislation which extends to the UK (including legislation giving effect to the UK’s international obligations).
For submarines, this commitment is further reinforced by the Navy Management Plan [5] which states that the Navy Board intends that positive actions will be taken to
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©2008: The Royal Institution of Naval Architects ensure the continued improvement of current practices
and adherence to both national and international legislation. Legislative compliance is to be verified through routine inspections and audits.
5.2 POLICY, PRACTICE & INTERFACES It is anticipated that the proposed IMO Convention and UK Government Strategy would be implemented within the MOD through a number of existing policy commitments as detailed below:
5.2(a) Joint Service Publications (JSPs)
The relevant JSPs providing the authoritative set of high level policies or guidelines with pan-MOD application are:
x JSP 815 (Defence Environment & Safety) - describing in high level corporate system for the management of environmental protection and safety [9];
x JSP 418 (Sustainable Development and Environment Manual) - providing a framework for the protection of the environment in the MOD, having regard for globally accepted general principles of environmental protection and sustainable development [10];
x JSP 430 (Ship Safety Management) – Provision of high level guidance primarily in ship safety issues [11].
These high level policies mandate the application of Project Oriented Environmental Management System (POEMS) as described below.
5.2(b) Project Oriented Environmental Management System (POEMS)
POEMS [6] is an Environmental Management System (EMS) mandated on, and designed to assist, the MOD’s Defence Equipment & Support (DE&S) organisation (as well as their contractors, suppliers and advisers) in the through life management of environmental performance and environmental liabilities of equipment, platforms and services.
It provides a useful framework and structure upon which a systematic, documented and auditable system for discharging and managing the proposed IMO requirements can be developed. Figure 1 (Appendix I) provides a suggested outline of how such a system may be established to simultaneously meet both proposed IMO and POEMS requirements.
5.2(c) Sustainability Appraisal
Sustainability Appraisal (SA) [7] is a process to ensure
that sustainable development considerations and policy requirements are integrated into all plans, programmes and policies that have the potential to affect the environment, society and/or the economy particularly on, over or around areas owned, occupied or used by the MOD, its agencies or partners.
Applied in this context, SA can assist in the identification of other statutory assessments and enable appropriate environmental, social and economic mitigation to be identified and managed through the MOD or site-based (recycling facility) EMS.
5.2(d) Sustainable Procurement
Sustainable Procurement is a process through which the MOD aims to acquire goods, services, works and utilities in a sustainable manner through the consideration of the through-life social, environmental and economic costs.
The MOD is currently in the process of developing its Sustainable Procurement Strategy and its interface with end-of-life vessel recycling is yet to be clarified.
5.3 SUBMARINES & IMPLICATIONS
The key high level requirements for new, in-service and end-of-life submarines are considered in Figure 2.
Figure 2 – Key Requirements for Submarines
Other potential implications for submarines of the proposed Convention are discussed below.
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©2008: The Royal Institution of Naval Architects 5.3(a) Recycling Facilities and Options
Given the security sensitivity surrounding submarines, it is sound to assume that all end-of-life nuclear powered submarines will be recycled and disposed in the UK.
Assuming that no vessel components are to be exported for recycling and disposal, the requirements embodied in the Basel Convention and the implementing Waste Shipment Regulations are unlikely to apply.
However, given the lack of recycling facilities in the UK, disposal (and laid-up storage) options and available sites are limited. It should be noted that it is not the intention of this paper to include issues relating to the decommissioning of the Reactor Compartment (RC).
These are currently being addressed by a specific MOD project (ISOLUS).
5.3(b) Design for the Environment
Despite its apparent focus on the disposal activities, the new IMO Convention is also intended to drive changes in the design and construction of future vessels through the adoption some of the heuristic Design for Environment principles (outlined in Table 2 in order to minimise environmental impacts during in-service operation and to facilitate the ease of reuse, recycling and material recovery of end-of-life vessels.
With the over-riding priority placed on design and construction to ensure crew safety and operational integrity, the bulk of the submarine will continue to be constructed with robustness of build and maintenance as a design criteria rather than ease of dismantling and recycling.
Nevertheless, other Design for Environment principles are being proactively adopted. For instance, the elimination/ substitution of prohibited hazardous materials and the minimisation of restricted materials are not new requirements in the construction or refit of submarines but rather, they are ongoing processes (e.g.
BR1326 process by which new materials are introduced into submarines require an assessment by the Institute of Naval Medicine) driven primarily by the need to reduce the occupational exposure risk of crew to potentially hazardous materials.
Design for Environment Heuristic Rules Waste &
Energy Reduction
x Design of energy and water efficient equipment;
x Reduction of waste by-
products in manufacturing, use, and maintenance;
x Elimination of unnecessary manufacturing steps;
x Incorporation of TQM and JIT philosophies.
Material Selection &
Management
Design for Recycling x Keep design simple;
x Aim for dematerialisation;
x Keep different types of materials to a minimum;
x Use of materials that are compatible with each other;
x Use of recycled materials as starting compounds;
x Label parts;
x Pay close attention to recyclability;
x Re-use/recycle packaging and other peripheral requirements;
x Examine components that may be used upon
failure/disassembly;
x Consider ease of decontamination.
Design for disassembly x Avoid mixing materials that
would be difficult to separate;
x Use modular design;
x Use moulded-in instructions to illustrate disassembly points;
x Design for ease of assembly, separation, handling and cleaning;
x Apply tight tolerance principles to reduce need for fasteners (and thereby avoiding the need for special
disassembly tools);
x Look into the possibility of applying reversible disassembly methods.
Management of Hazardous Materials
x Where possible, avoid secondary finishes, hazardous materials and heavy metals;
x Introduce non-hazardous solvents and cleaning materials.
Product Enhancement
x Incorporation of as many functions as possible into any single part;
x Design secondary/ multiple uses for a product/equipment;
x Design for long operational life;
x Keep design simple and timeless.
Table 2 – Design for Environment: Heuristic Rules
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©2008: The Royal Institution of Naval Architects Additionally, the use of numerous Commercial-Off-The-
Shelf (COTS) equipment on board submarines is beneficial in that new/replacement COTS components would have already largely been manufactured to eliminate/reduce such substances in compliance with the EU Directives and Regulations such as the EU Restriction of the use of certain Hazardous Substances (ROHS) in Electrical Electronic Equipment. Such COTS equipment would have benefited from Design for Environment principles inherent in their manufacture.
5.3(c) Waste Minimisation of Operationally-Generated Waste
Given obvious space constraints, submarines benefit from a distinct advantage in that waste minimisation is a design consideration from the outset. Waste minimisation initiatives include the reduction of packaging and increasing automation (reducing reliance on manpower), thereby reducing waste generation during operations.
5.3(d) Environmental Contingency Planning
Contingency measures and systems focussing on the safety of the crew are already well established. There may be a need to review contingency planning to assess the adequacy of current measures and systems in mitigating environmental damage.
5.3(e) End-of-Life Preparatory Works
In accordance with new IMO Guidelines, such preparatory works include pre-cleaning, decontamination, gas removal, decommissioning of systems required for obtaining the IMO’s ‘International Ready to Recycle Certificate’. It is anticipated that current decommissioning and Defuel, De-Equip & Lay Up Preparation (DDLP) processes (and corresponding assurance systems) encompassing the following phases depicted in Figure 3, are likely to be sufficiently comprehensive (although this needs to be further verified). Consequently, the new IMO requirements are likely to largely represent the formalisation and translating of current provisions and assurance processes in an IMO acceptable format.
Other implications on submarines may be raised by the Maritime Environmental Working Group (MEWG), a sub-group of the Ship Safety Board, formed with the aim of looking into maritime environmental compliance challenges.
Submarine Post Commission Phases
- Time Lines
Decommissioning (Leaves Operational
Service)
Complement Reduction (Fuelled Berthing)
Long-term Berthing (Fuelled Berthing)
Defuel, De-Equip &
Lay Up Preparation (Defuelled Berthing)
Afloat Lay-Up (Defuelled
Berthing)
Survey & Docking Periods (SADP)
Afloat Lay-Up (Defuelled
Berthing)
Final Disposal under Project
ISOLUS
Figure 3 – Time Lines for Submarine Post Commission Phases
6. CONCLUSIONS
The requirements of the proposed IMO Convention on the Safe & Environmentally Sound Recycling of Ships are likely to apply to and affect all new, in-service and end-of-life submarines.
However, the nature of submarines/submarine operations are such that design and operational constraints already take into account many pertinent issues such as reduction of potentially hazardous substances, exercise of extensive controls over decommissioning etc. Consequently, the (new) requirements are likely to largely entail the formalisation of existing arrangements, processes, and assurance & approval systems within an IMO-approved framework.
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Notwithstanding this, the MOD has a significant ability to further contribute towards sustainable development goals through, for instance, driving design enhancement and in exercising influence over through-life procurement decisions.