Memorandum submitted by the Nuclear Decommissioning Authority (NPS 20)
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.
2.1 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
2.2 We are responsible for and legally own
the 19 former UK Atomic Energy Authority and BNFL sites in
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.
2.4 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
· Nuclear materials:
Developing sustainable solutions to deal with the
· 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.
2.5 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.
2.6 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 £5.1bn from Government grant-in-aid and £3.3bn 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:
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
"make recommendations to Allerdale Borough Council,
Copeland Borough Council and
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
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.
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;
· 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
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.
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
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
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
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 £4.7bn was spent in the supply chain which included £1.3bn 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.
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.
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.
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.
6.1 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.
[i] 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.
[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.