BAE Systems Marine Ltd, Barrow Shipyards - Radioactive substances activities (RSA) permit consultation

Closed 22 Mar 2022

Opened 23 Feb 2022

Feedback updated 6 Sep 2022

We asked

We asked your views on an application to vary the radioactive substances permit for BAE Systems Marine Ltd, Barrow Shipyards.

You said

We received 2 responses in total to our public consultation. Of these responses, 1 was from an individual and 1 was from an organisation. The responses we received have been summarised in the consultation response document.

We did

We assessed the application and the consultation responses were considered as part of this assessment. We issued the permit variation on 23 August 2022. The key changes to the permit are:

  • extension of the permit boundary to include Devonshire Dock Quay
  • addition of conditions and limits for keeping and use of radioactive material and accumulation of solid and liquid radioactive waste at Devonshire Dock Quay

Published responses

View submitted responses where consent has been given to publish the response.


We have received an application from BAE Systems Marine Ltd to make changes to the existing radioactive substances activities (RSA) permit for the Barrow Shipyards site in Cumbria.  The permit controls receipt and disposal of radioactive waste and imposes conditions and limits on radioactive discharges to the environment.

The proposed changes to the permit are as follows:

  • An extension to the boundary of the permit
  • Addition of conditions and limits relating to keeping and use of radioactive material, in the form of open sources
  • Addition of conditions and limits relating to accumulation of radioactive waste.

BAE Systems Marine Ltd build, test and commission nuclear-powered submarines at the Barrow Shipyards site. Small quantities of solid, liquid and gaseous radioactive waste are produced during testing and commissioning of the submarines.  There is no proposed change to the type, volume or activity of radioactive waste to be generated, but the location at which testing and commissioning will take place will change when the new Dreadnought submarines are built. 

Within the Barrow Shipyards site there is:

  • A nuclear licensed site which covers the Devonshire Dock Complex and the Wet Dock Quay, with its associated facilities, where testing and commissioning of Astute submarines currently takes place. The current RSA permit boundary is consistent with the nuclear licensed site boundary.
  • An MoD nuclear authorised site which covers the Devonshire Dock Complex and the Devonshire Dock Quay.  New facilities are currently being developed at the Devonshire Dock Quay to enable the larger Dreadnought submarines to be tested and commissioned, as they cannot be accommodated at the Wet Dock Quay.

Devonshire Dock Quay is situated outside the current boundary of the RSA permit, so the applicant is seeking to extend the boundary of the permit to include it.     

On a nuclear licensed site the keeping and use of radioactive material plus accumulation of radioactive waste is regulated by the Office for Nuclear Regulation (ONR) and receipt and disposal of radioactive waste is permitted and regulated by the Environment Agency.  Outside a nuclear licensed site, the Environment Agency permits and regulates all these activities.  As Devonshire Dock Quay and its associated facilities are outside the nuclear licensed site, the applicant is seeking to add keeping and use of radioactive material (in the form of open sources) and accumulation of radioactive waste to the existing RSA permit.  We have standard permit conditions relating to these activities, and appropriate limits will be specified. 

Solid and liquid radioactive waste will be stored temporarily at the Devonshire Dock Quay and its associated facilities on the authorised site during testing and commissioning and will subsequently be transferred to the nuclear licensed site for disposal via existing permitted routes.  The location of gaseous discharge points specified in the permit will change but there will be no increases in radioactive discharge limits, or in estimated radiation dose to the public.

We are seeking comments on this permit application.  You can view the application and supporting documents by scrolling to the bottom of this page.

Why your views matter

We are consulting on this application to give people the opportunity to understand the proposed changes to the permit and provide us with any information they think is relevant to our decision making.

We can take account of:

  • relevant environmental regulatory requirements and technical standards
  • information on local population habits and practices and sensitive sites
  • comments on whether the right process is being used for the activity
  • the potential impact, whether the impact is acceptable and what pollution control measures or abatement may be required
  • information that we have not been made aware of in the application.

We cannot take account of:

  • anything outside the scope of the Environmental Permitting Regulations
  • whether a site should have a formal designation under Habitats Directive or other conservation legislation
  • whether the activity should be allowed or not as a matter of principle and the justification of practices involving radiation – for example, we will not consider the justification for the UK nuclear submarine programme
  • land use issues, or sustainability challenges
  • the impact of traffic travelling to and from the site
  • comments about the Government’s defence policy
  • comments about the transport of radioactive waste

What happens next

Thank you for responding to this consultation.

We will make your response publicly available (excluding personal information and financial data) on our online tool whilst the consultation is running, unless you have requested that we do not publish your response.

Following the end of the consultation we will assess all the information and responses received.  We will then produce a final decision document and this will be published alongside the permit and variation notice on this consultation’s web page in April 2022.

We will not be responding to individual comments on the application.

Thank you

Nuclear Regulation Group North


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