Memorandum submitted by the Nuclear Decommissioning
Authority
1.1 This submission to the House of Commons
Energy and Climate Change Select Committee is from the Nuclear
Decommissioning Authority (NDA), a non-departmental public body
established in 2005 by the Energy Act 2004.
1.2 We provide a brief summary of our work and the
reasons why we support the analysis in the draft National Policy
Statement (NPS) for Nuclear Power Generation. Key conclusions
are as follows:
— We support the analysis in the draft
NPS for Nuclear Power Generation that there are suitable ways
of dealing with higher activity radioactive waste.
— We believe that good progress is being
made and we are confident that with appropriate long term funding,
arrangements can be provided for the management of higher activity
legacy wastes, as well as those that will arise from a programme
of nuclear new build.
— No new issues arise that challenge our
ability to dispose of the wastes and spent fuel expected to result
from the operation of the two proposed new reactor designs. As
set out in the Managing Radioactive Waste Safely (MRWS) White
Paper there is a suitably flexible and robust process in place
to deal with radioactive waste issues.
— The development of UK Government policy
on nuclear new build presents opportunities for benefits from
synergies between legacy and new build activities to be realised.
2. INTRODUCTION
2.1 The Nuclear Decommissioning Authority (NDA)
is a non-departmental public body which was established by the
Energy Act 2004 and became operational in April 2005. Our sponsoring
department is the Department for Energy and Climate Change and
for some aspects of our functions in Scotland we are also responsible
to the Scottish Ministers. We remain accountable to the UK Parliament
for our operations through the Secretary of State.
2.2 We are responsible for and legally own the 19
former UK Atomic Energy Authority and BNFL sites in Great Britain.
As a strategic authority we set the overall approach and through
working with others, we focus on the objectives set out in our
Business Plan.[i] We are working closely with our stakeholders
to produce our second Strategy document which we will consult
on later this year, prior to its publication by the end of March
2011.
2.3 We were established in order to deliver
the Government's commitment to dealing effectively with the nuclear
legacy and are responsible for driving substantial change to improve
delivery and cost efficiency in a large and complex industry.
Our mission is to:
Deliver safe, sustainable and publicly acceptable
solutions to the challenge of nuclear clean up and waste management.
This means never compromising on safety or security, taking full
account of our social and environmental responsibilities, always
seeking value for money with the taxpayer and actively engaging
with stakeholders.
2.4 In summary, our job is to decommission the
nuclear facilities that the country has created over the past
fifty years or so, and to develop a waste management infrastructure
to reduce the risks to this and future generations. In carrying
out this vital and complex task, safety, security, environmental
responsibility and value for taxpayer's money are our top priorities.
2.5 In practice, our core activities fall into
five primary work streams:
— Site restoration:
Characterising, retrieving and making passively safe
highly radioactive and hazardous material; decommissioning and
cleaning-up redundant nuclear facilities across the civil nuclear
estate. Our Annual Report and Accounts 2008-09[ii] provides more
details.
— Spent fuel management:
Transporting, storing and, in some cases, reprocessing
spent fuel from the UK's first and second generations of nuclear
power stations (Magnox and British Energy's fleet) and, in doing
so, safeguarding approximately 20% of the UK's electricity supply.
— Nuclear materials:
Developing sustainable solutions to deal with the
UK's stockpile of plutonium and uranium resulting from the fuel
cycle. We have worked with our stakeholders to develop a range
of potential strategies to manage the UK civil stockpiles of these
materials [iii] to support the development of Government policy
in this area.
— Integrated waste management:
Packaging, storing and ultimately disposing of low,
intermediate and high level radioactive waste including development
of the geological disposal facility (GDF). This is also a key
enabler for nuclear new build and together with other potential
synergies is discussed later in this paper.
— Business optimisation:
Maximising the value of assets under our control
in order to contribute to meeting the costs of the NDA programme.
Without in any way compromising safety, the NDA continues to control
costs, drive efficiency and deliver value for taxpayers' money.
In the first four years of operation the NDA has made cumulative
efficiency savings of £625 million, with £5.9 billion
of income secured from our commercial assets.
2.6 We have a number of other areas of activity
which we describe as critical enablers in the delivery of our
mission:
— through competition introducing international
companies to the UK nuclear decommissioning supply chain to improve
performance and bring innovation;
— investing in nuclear skills and R&D;
— learning from and sharing international
best practice with other nuclear countries; and
— working with communities to address the
socio-economic impacts of the decommissioning programme.
2.7 In order to deliver this programme of work
our spending requirements during the current Comprehensive Spending
Round (CSR07) period amounted to £8.4 billion. This comprised
approximately £5.1 billion from Government grant-in-aid and
£3.3 billion from commercial income.
3. HIGHER ACTIVITY
RADIOACTIVE WASTE
MANAGEMENT
3.1 As mentioned above, integrated waste management
is one of our core activities and is also a key enabler for nuclear
new build. In the draft NPS for Nuclear Power Generation the UK
Government has set out the reasons why it believes a suitable
site for geological disposal can be identified, why this is technically
achievable, and why acceptable interim storage arrangements will
be available. We support this position for the following reasons:
Suitable site
3.2 The UK Government and the devolved administrations
for Wales and Northern Ireland (Government) set out a framework
to implement the geological disposal policy in the Managing Radioactive
Waste Safely (MRWS) White Paper[iv] published in June 2008.This
sets out the framework for the implementation of geological disposal,
including a flexible site selection process based on voluntarism
and partnership. Experience around the world in developing geological
disposal facilities demonstrates that this approach is likely
to be the most successful way to develop a safe, secure, and environmentally
acceptable facility that secures public confidence.
3.3 The MRWS White Paper sets out a step-by-step
site selection process. The various stages are as follows:
— Stage 1: Expression of interest, corresponding
to the period up to the point where a community decides to open
up without commitment discussions with Government.
— Stage 2: Initial screening out of unsuitable
areas.
— Stage 3: Community consideration leading
to Decision to Participate.
— Stage 4: Desk-based studies in participating
areas.
— Stage 5: Surface investigations to identify
a preferred site.
— Stage 6: Underground operations.
3.4 Three formal "expressions of interest"
relating to the Copeland and Allerdale districts of Cumbria have
already been received by the Government. A West Cumbria MRWS Partnership
has been established as an advisory body which aims to:
"make recommendations to Allerdale Borough
Council, Copeland Borough Council and Cumbria County Council on
whether they should participate or not in the geological disposal
facility siting process, without commitment to eventually host
a facility".
3.5 We welcome this progress and participate
as an observer at their meetings.
3.6 At this stage of the process we are developing
a generic disposal system safety case. This will be published
in the autumn of 2010 explaining why we think our proposals will
meet the rigorous safety requirements set by the regulators. There
will be further opportunities to improve the proposals with continued
engagement with the regulators and by input from other interested
groups including potential local communities.
3.7 The programme for developing a facility
needs to be flexible and able to incorporate both technical site
investigations and ongoing interactions between the project and
the host community. This may mean accommodating longer discussion
periods and more research to address regulatory and stakeholders'
concerns. Nevertheless, there is a need to maintain momentum in
taking forward this important programme to ensure the safe and
secure long-term management of higher activity radioactive waste
in the UK. This will require long term stable and secure funding
for the programme.
3.8 As set out in the MRWS White Paper, one
of the requirements will be for Government to provide a benefits
package to a host community. Construction and operation of a geological
disposal facility will be a multi-billion pound project that will
provide skilled employment for hundreds of people over many decades.
It will contribute greatly to the local economy and wider socio-economic
framework. There could be spin-off industry benefits, infrastructure
benefits, benefits to local educational or academic resources,
and positive impacts on local service industries that support
the facility and its workforce. It is also likely to involve major
investments in local transport facilities and other infrastructure,
which would remain after the facility had been closed. In addition
there may be other benefits which may be commensurate with developing
the social and economic wellbeing of a community that has decided
to fulfil such an essential service to the nation.
Technically achievable
3.9 Government policy for long term management
of higher activity wastes is geological disposal coupled with
safe and secure interim storage and ongoing research and development
to support its optimised implementation. This was arrived at following
extensive public consultation and is consistent with the approach
adopted by the majority of other countries facing similar challenges.
3.10 UK Government policy for new nuclear-build requires
"requesting parties" to submit reactor designs to the
regulators' Generic Design Assessment process. As part of this
process we advise requesting parties on the disposability of radioactive
waste and spent nuclear fuel generated by new reactor designs.
This advice is based on the disposability assessment [v] against
geological disposal facility design and safety considerations.
It is an extension of the assessment methodology we use for legacy
wastes known as the Letter of Compliance process, which is subject
to regulatory scrutiny.
3.11 We have completed assessments for:
— the UK EPR proposed by EdF and AREVA
as a co-requesting party; and
— the AP1000 proposed by Westinghouse Electric
Company LLC.
3.12 We have concluded that compared with legacy
wastes and existing spent fuel, no new issues arise that challenge
the fundamental disposability of the wastes and spent fuel expected
to arise from operation of both designs of reactor. Fuel from
new reactor designs will be subject to higher burn-up than existing
UK reactors. This means extracting more energy from the same amount
of fuel with the result that the spent fuel is hotter and more
radioactive. Disposability assessments have shown that this can
be accommodated without adverse effects on the design or safety
of a geological disposal facility.
3.13 One way of addressing this hotter and more
radioactive spent fuel is to store it for a longer period of up
to 100 years. This would allow the process of radioactive decay
to render the fuel similar to that from existing reactors. However,
this is an area where further optimisation of geological disposal
designs will be explored with the requesting parties. Joint working
arrangements for this optimisation are in place between the Nuclear
Industry Association (NIA), the utilities and ourselves.
Interim storage
3.14 As previously stated, geological disposal
is the way higher activity waste will be managed in the long term.
This will be preceded by safe and secure interim storage for a
number of decades until a geological disposal facility can receive
waste.
3.15 We have published our UK wide review of waste
storage arrangements for legacy wastes.[vi] We have interim storage
facilities that are and will be safe and effective, and will remain
so for as long as is necessary, until a GDF is available for use.
3.16 New nuclear build operators will need to
provide safe and secure onsite interim storage of spent fuel and
intermediate level waste. There is extensive experience, both
in the UK and overseas, of storing such materials and hence this
should not present a significant technical challenge. We will
seek opportunities to work with potential new build operators
to consider options for the interim storage of wastes from any
new nuclear power stations.
4. CAPABILITY TO
DELIVER GEOLOGICAL
DISPOSAL
4.1 The MRWS White Paper confirmed that we are
responsible for planning and implementing geological disposal
in the United Kingdom. Accordingly, we have set up a new directorate
called the Radioactive Waste Management Directorate to develop
into an effective delivery organisation to implement a safe, sustainable
and publicly acceptable geological disposal programme. This Directorate
was formed in 2007 when the UK Government transferred the functions
formerly carried out by Nirex to the NDA. Thus the skills and
expertise that existed have been retained and further developed.
4.2 We are successfully transforming this part of
the NDA to become an organisation that will ultimately be able
to hold a nuclear site licence and disposal authorisations for
a GDF. Following a detailed review by regulators we have commenced
operations as a prospective Site Licence Company (SLC) under voluntary
regulatory scrutiny in preparation to becoming the organisation
that delivers the facility.
4.3 The competencies required to implement geological
disposal will be provided from a combination of our staff and
the external supply chain. We have identified the duties and functions
needed to undertake our current safety and environmental activities.
As part of the development of our procurement strategy we have
engaged with the supply chain.
4.4 Many other countries are developing geological
disposal facilities. We work closely with implementation organisations
around the world and we have undertaken a benchmarking exercise
with other comparable programmes to validate our work. This has
included the programme of the Swedish waste management organisation,
SKB who have recently selected a site, and also the French, Swiss
and Japanese geological disposal programmes.
4.5 SKB has undertaken an independent review[vii]
of our current programme. We are working with them and others
to identify opportunities to strengthen our programme through
the transfer of technology and knowledge.
4.6 In order to plan the financing of the geological
disposal programme and to inform Government's staged decision
making process we evaluate the potential cost of the programme.
This cost is affected by many factors, but at the current stage
of planning there are inevitable uncertainties. Therefore, we
have developed a tool, termed the Parametric Cost Model, to identify
the cost impact of different scenarios. This is used to assist
the Department of Energy and Climate Change in their development
of a fixed unit price methodology for disposal of material from
new nuclear power stations.
4.7 The Committee on Radioactive Waste Management
provides independent scrutiny and advice to Government on the
long term management of higher activity radioactive wastes. As
part of their work they scrutinise our programme and one of their
reports[viii] they welcome the progress made by Government and
the NDA in carrying forward the geological disposal implementation
programme.
5. POTENTIAL SYNERGIES
5.1 Since our establishment we have significantly
and successfully restructured the industry to deliver our legacy
decommissioning and waste management mission. The development
of UK Government policy on nuclear new build presents further
opportunities for benefits from synergies between legacy and new
build activities. These include the following:
— Supply chain
The supply chain is a critical resource to deliver
our mission. In our first four years £4.7 billion was spent
in the supply chain which included £1.3 billion in 2008-09,
of which 70% was let competitively. Our Supply Chain Development
Strategy[ix] include commitments to "explore synergies with
other nuclear clients". We continue to work with all interested
parties to enable "a safe, affordable, cost effective, innovative
and dynamic market" and recognise that many in the supply
chain are potential suppliers for new build.
— Infrastructure
There are potential synergies with regard to infrastructure
required for us to deliver our existing responsibilities and those
for a new nuclear programme. These will need to be explored in
further detail and will cover; waste packaging and conditioning,
interim storage, and transport.
— Socio-economic
As a result of our land disposal programme we have
generated over £500 million of income by selling land to
"new build" operators. Four out of the 10 sites nominated
for new nuclear power stations are on land previously owned by
NDA and are therefore adjacent to existing nuclear installations.
This has given a much more positive economic outlook for those
communities than was previously envisaged, and we will be seeking
to explore opportunities including the potential redeployment
of site staff as manpower requirements on legacy sites reduce
and new build sites increase.
— Skills
We need to ensure we have innovative technology and
an appropriately skilled workforce and supply chain to deliver
our mission. Our Skills and Capability Strategy[x], supported
by major employers, and associated Action Plan[xi] demonstrate
how we will meet this challenge. These developments will also
support a new nuclear build programme.
— Research and development
We explore opportunities to share research and development
findings with international partners. This provides good value
for money as it means we can learn from others around the world.
The skills built up by this may be useful to support new build
work.
6. CONCLUSIONS
6.1 We support the analysis in the draft NPS
for Nuclear Power Generation that there are suitable ways of dealing
with higher activity radioactive waste.
6.2 We believe that good progress is being made and
we are confident that with appropriate long term funding, arrangements
can be provided for the management of higher activity legacy wastes,
as well as those that will arise from a programme of nuclear new
build.
6.3 No new issues arise that challenge our ability
to dispose of the wastes and spent fuel expected to result from
the operation of the two proposed new reactor designs. As
set out in the MRWS White Paper there is a suitably flexible and
robust process in place to deal with radioactive waste issues.
6.4 The development of UK Government policy
on nuclear new build presents opportunities for benefits from
synergies between legacy and new build activities to be realised.
January 2010
REFERENCESi NDA,
NDA Business Plan 2009/12, 2009.
ii NDA, NDA Annual Report and Accounts 2008/2009,
2009.
iii NDA, NDA Plutonium Topic Strategy: Credible
Options Technical Analysis, 2009.
iv Defra, BERR, Welsh Assembly Government, Department
of the Environment Northern Ireland, Managing Radioactive Waste
Safely: A Framework for Implementing Geological Disposal, 2008.
v NDA, Radioactive Waste Management Directorate,
"Disposability Assessment of Solid Waste Arisings from New
Build", 2008.
vi NDA, UK Radioactive Higher Activity Waste
Storage Review, 2009.
vii SKB, SKB Peer Review of the NDA RWMD Provisional
Implementation Plan—PIP, 2009.
viii CoRWM, CoRWM Report to Government: Geological
disposal of higher activity wastes, 2009.
ix NDA, NDA Supply Chain Development Strategy,
2009.
x NDA, NDA Skills and Capability Strategy, 2008.
xi NDA, NDA Skills and Capability Action Plan,
2008.
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