APPENDIX 2
Memorandum by the British Nuclear Energy
Society
1. INTRODUCTION
(a) As the leading learned society on nuclear
energy in the UK, BNES welcomes the opportunity to comment to
the Trade and Industry Committee's enquiry into the Nuclear Decommissioning
Authority. The setting up of this Authority is highly significant
for the majority of BNES members and consequently we have proactively
taken part in the consultation exercises, both written and at
workshops undertaken by DTI/LMU in the setting up of the NDA and
also on the plans of the NDA for which we have submitted comments
as recently as 11 February 2005.
(b) We are conscious that NDA does not formally
take over its responsibility until 1 April 2005 but has been busy
developing its organisation and plans in advance of that date.
(c) For the future, we hope to continue
a constructive dialogue with NDA both by continuing to comment
on their plans and to make use of our position as an independent
learned society to include NDA in our networking activities.
2. BRITISH NUCLEAR
ENERGY SOCIETY
(BNES)
(d) The British Nuclear Energy Society is
a registered charity and was founded in 1962 by its Trustees who
represent most of the major engineering and scientific professional
institutions in the United Kingdom that include members interested
in nuclear energy.
(e) The vision of the BNES is to be the
leading "Learned Society" for Nuclear Energy,
in its totality, and to lead and facilitate a clearer understanding
of the subject. The BNES functions almost completely by the contributions
of volunteers who provide their experience and dedication to fulfil
its objectives, which are:
— To provide information to members,
UK and worldwide, on Nuclear Energy issues.
— To provide opportunities for members
to meet and debate issues locally, nationally and internationally.
— To provide opportunities for members
to publish and present papers.
— To promote increased public understanding
of the issues surrounding the use of Nuclear Energy and support
the public education activities of the Industry.
— To promote Nuclear Energy specific
training in the United Kingdom.
(f) Our membership is consequently drawn
from sections of society interested in this topic, the nuclear
industry, the contracting industry, academia, retired and other
persons. A very significant portion of our membership is engaged
in activities associated with nuclear clean-up.
(g) The BNES Young Generation Network consists
of our younger members and has demonstrated rapid growth in the
last two years. BNES sees the support and development of these
younger members as key to the future of the nuclear energy scene
in the UK and you will understand why the focus of our response
below includes "skills" whilst at the same
time stressing the need to draw upon the extensive industry experience
upon which our society has been able to draw since its formation
in 1962.
3. NUCLEAR LIFE
CYCLE/HISTORY
(h) The formation of the NDA is perhaps
the most important development in the nuclear scene in the UK
since the outset of the programme in the late 1940s. Never the
less decommissioning and the vitally important associated subject
of waste management is not new and organisations in the UK have
been actively pursuing these areas of activity, especially decommissioning,
since the publication of the White Paper on Radioactive Waste
Management in July 1982. It is fair to say that decommissioning,
after a slow start, has gathered pace but the resolution of a
waste route for intermediate level waste has stalled and BNES
is concerned that little progress has been made since the Royal
Commission on Environmental Pollution in 1976.
(i) Decommissioning is part and parcel of
the back end of a process that includes fuel enrichment, fuel
fabrication, reprocessing, construction, operation and maintenance
of nuclear power plant and facilities, operational waste management
and finally decommissioning and site remediation. These activities
are dominated by the civil nuclear industry yet a parallel and
similar set of activities proceeds in the defence sector. Also
new nuclear development continues in the UK in both sectors with
work by UKAEA and Rolls-Royce whilst BNFL is engaged in development
programmes for the next generation of more efficient and integrally
safe reactors. These new projects need to consider decommissioning
and lessons must be learnt from past experience in an area where
UK has been a world leader. There are also issues associated with
future funding for fission R+D as BNFL's remit changes on NDA
formation. Without Government commitment to R+D on future systems,
the UK will cease to contribute to this important international
endeavour.
(j) We have a highly integrated industry
with many common skills needed to cover the diversity of operations
involved but also a recognition that the technologies needed for
decommissioning in many cases require to meet different safety,
programme and cost criteria than would be required for an operational
nuclear plant. It is important that these skills are maintained
(k) The challenge the NDA must meet is to
ensure the proper balance between the existing skills set and
experience and the need for acceleration and better project and
cost management of decommissioning. BNES perceives significant
risks if the nuclear industry were to be come polarised in to
new build/operations and decommissioning factions. BNES is ideally
placed to understand this as our membership covers the entire
nuclear life cycle.
4. SET UP
OF NDA
(l) The comments you have requested are
required at a very early date, in fact before the NDA takes over
responsibility. Yet it is good policy to review the NDA performance
from the outset, as early mistakes should not be allowed to blossom.
We are encouraged by this interest of the Select Committee.
(m) The LMU have set about their task of
establishing the NDA in a highly constructive and consultative
way. However, this period has been one of great uncertainty for
the industry and our members, with high expectations of the reorganisation
requiring a balance of patience by those wanting to get on with
decommissioning. BNES has endeavoured to focus its efforts in
to the issues of skills, technologies and organisation of the
nuclear industry coupled with our belief that new nuclear build
is an unavoidable and desirable need for the UK to meet future
energy and environmental challenges.
5. ISSUES FOR
THE NDA OF
CONCERN TO
BNES
(n) Foundation stones for a strong nuclear
industry include:
— commercial relationships.
As a learned society it is not within our remit
to comment on commercial issues but to recognise their importance
and no further comment is made. Our comments at this stage are
therefore as below and, in the absence of a track record for the
NDA, are really issues that we hope they will address.
5.1 Skills
(o) It is a feature of the nuclear industry
that, whilst organisations change and come and go, the basic personnel
who make up the skills set remains as a valuable and experienced
pool supplemented on the one hand by new persons joining the industry
and losing persons through retirement. The considerable reduction
in scope for new nuclear build has led to fewer persons entering
the industry for a long-term career path. At the same time numbers
such as £48 billion liabilities (which many take to be the
cost of clean-up, which could be higher or lower depending on
the success of the NDA) are attracting many companies to the decommissioning
market and BNES have benefited in membership from this. New entrant
does not necessarily mean adequate skills and BNES has addressed
this issue by supporting our Young Generation Network to deliver
training events for its members and to establish an education
committee that will liaise with parties interested in nuclear
education in the UK whether government, industry, universities,
school or the public.
(p) What is important is that government
needs to encourage NDA to recognise that this skills management
process needs to be optimised across the full nuclear cycle in
both civil and defence sectors and is not just a function of decommissioning.
(q) NDA needs to recognise that such skills
development needs to be funded and that such funding as an investment
can only benefit the UK nuclear industry as a whole. BNES would
be concerned if contractors failed to include adequate allowances
for training because of the competitive pressures to win contracts
from NDA. NDA needs to be very open in its statements as to how
it expects to encourage and develop nuclear related skills and
avoid a free-for-all fight for limited resources across the entire
nuclear sector, both civil and defence. The current NDA Annual
Plan makes only £100K allowance for skills development against
a budget of £1.6 million for briefing ministers.
(r) The UK's civil nuclear technology base
has been seen in a period of tremendous change over the last 20
years. The R&D capability which supported the Nuclear Industry
and the National commitment to nuclear power, largely held within
the then Central Electricity Generating Board and the United Kingdom
Atomic Energy Authority through to the end of the 1980's, was
reduced significantly with the privatisation and deregulation
of the Electricity Supply Industry and the funding curtailment
of the UKAEA's mission by Government. BNFL remained the major
funder and only provider of active R&D and support facilities
of any significance in the UK with strong links into the research
active academic sector especially in the North of England. The
advent of the NDA brings significant uncertainty as to the long
term sustainability of BNFL's strategic knowledge R+D base due
to the limited nature of NDA's remit, long term projections of
declining NDA requirements, the competitive contracting framework
engendered within the NDA related supply chain and the lack (to
date) of government funding for R+D in areas other than NDA.
5.2 Technology
(s) Technology is a fundamental requirement
across all the various stages of the nuclear fuel cycle whether
it is design, construction, operation or decommissioning. It is
important for those working in the industry to recognise that
the technology is fit for purpose for the particular stage of
the process. BNES is encouraged that the advent of the NDA has
led to a renewed focus on simple, effective and proven technology
for decommissioning recognising that in many cases the design
specification for decommissioning technology is considerably different
to that required for a new operational nuclear plant.
(t) BNES believes that the work by LMU to
involve the regulators in this process was valuable and we hope
that NDA will continue down this path. As a society we participate
in and organise conferences many of international significance
where leading world specialists meet to discuss decommissioning
experience and techniques. These conferences together with the
research and development funds proposed by NDA are just two vehicles
for ensuring that adequate technologies for decommissioning are
demonstrably available in the future.
(u) Conferences have been well supported
by the nuclear industry in the past and BNES hopes that NDA will
continue to encourage its contractors to participate in such events
in the future and especially to encourage young persons to participate.
It is the coming together of the old experienced hands and the
new generation that leads to a vibrant and innovative industry.
(v) In separate comments to NDA, BNES has
questioned the value of the NDA proposed R&D programme in
proportion to the value of the liability. It may be that contractors
will undertake some R&D themselves but experience shows in
any industry that R&D expenditure requires a degree of certainty
that there will be adequate return to the business.
(w) NDA have a requirement under the Energy
Act to secure long-term skills to support the clean up mission
and have established a direct portfolio of research work to meet
this need—in the order of £10 million/pa. In the NDA
draft strategic plan NSTS (Nuclear Science and Technology Services
now Nexia Solutions Ltd) is indicated as the organisation to develop
and manage this portfolio. Although welcome, given the complexity
and expense of carrying out R+D in active facilities required,
the amount set aside is low given the challenges faced by NDA,
particularly since BNFL's successful University Research Alliances
are mainly funded from the NDA direct portfolio. This potentially
impacts the skills pipeline feeding the sector generally as well
as BNFL's R+D capability directly.
5.3 Organisation
(x) BNES recognises that the NDA is tasked
with making significant changes to the organisation of the UK
nuclear industry and the existing incumbents have put a significant
amount of effort in the last year or two into developing new ways
of working and base-line and near-term work plans. We note that
these plans, upon which we have commented to NDA separately, include
activities across the whole nuclear life cycle and are not just
limited to nuclear clean-up. BNES notes that the slow pace of
development of waste management is a risk to these plans. BNES
notes that the NDA has set a target to put up 50% of sites to
competition by 2008.
(y) BNES is concerned that:
— The competition does not lead to
conflict between price and safety.
— The competition does not lead to
the advantage of UK co-ordinated clean-up policy across all sites
being negated by specific site competitions.
— The holistic approach to nuclear
energy in the UK is not jeopardised because NDA focus is solely
on clean-up. As well as being liabilities many nuclear sites are
UK assets for which there are many possible future uses not least
potential locations for new nuclear facilities with local populations
containing experience, skills and the appreciation of the safety
needs in operating and managing such facilities.
6. CONTACTS
(z) This document has been prepared on behalf
of British Nuclear Energy Society by Michael Grave, Chairman of
BNES Cumbria Branch (which has an interest in Waste Management
and Decommissioning) in consultation with other society officers.
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