Select Committee on Trade and Industry Appendices to the Minutes of Evidence


APPENDIX 5

Letter and Memorandum by UKAEA

MANAGING THE NUCLEAR LEGACY—A STRATEGY FOR ACTION

 sWhen UKAEA appeared before the Committee on 9 July the Chairman invited us to submit in writing any additional evidence we might wish to give.

 sI would like to add just three points:

    — sThe Chairman commented that the primary aim of the proposals was "to discharge the nuclear legacy". He asked what we understood by this. We agree that "liabilities" or "legacy" management is both cryptic and negative. UKAEA has itself decided that its role is to "Restore the Environment". We believe the LMA's role will be to do for the UK's publicly funded civil nuclear sites as a whole what UKAEA has been doing for its sites: to restore the sites for alternative use as far as practicable. The LMA's title may need to be revised if this positive message is to be conveyed succinctly.

    — sWe were asked whether NIREX should be made independent of the nuclear industry. There are a number of options for NIREX which are being considered by DEFRA's consultation exercise on managing radioactive waste safely. Our view on the essential functions of NIREX which must be retained in future arrangements is best set out in our submission to DEFRA of 12 March 2002. Relevant extracts are attached. The main points are that:

      — sThe sooner long-term waste management policy can be clarified the better. Policy development for the long-term management of radioactive waste should be separated from the nuclear industry and from implementation of this policy.

      — sDecommissioning and waste management are part of an integrated process which should be considered as a whole.

      — sThe formation of the LMA therefore introduces the potential for rationalisation and simplification in the governance of radioactive waste management. The key roles of NIREX must be preserved in future arrangements but not necessarily in a separate, specialist organisation.

    — sWe provided evidence on the trend in our liabilities estimate since UKAEA became focused on environmental restoration. For clarity, the run of figures undiscounted in 2001-02 prices is shown in the following table. These figures exclude the liabilities managed by BNFL on its sites, and included in its figures, for which UKAEA has a financial responsibility:
19951996 19971998 199920002001 2002
£ billion7.927.63 7.477.357.55 7.447.527.46

  The financial legacy was being eliminated gradually until the Dounreay Safety Audit in 1998. This led to a reassessment of the work required to meet modern regulatory standards. Since then the higher costs for future work which are now expected have offset the further progress made in eliminating the legacy.

  If you need any more information or would like to discuss this note please do not hesitate to contact me.

Dr John McKeown

Chief Executive

16 July 2002

UKAEA Response to the DEFRA Consultation Document "Managing Radioactive Waste Safely"

KEY EXTRACTS RELEVANT TO THE FUTURE OF NIREX

  The main points of principle underlying this response are:

    —  UKAEA's mission is to restore the environment of our sites in a safe and secure manner, ensuring that restoration is environmentally responsible, provides value for money for the taxpayer and is publicly acceptable. This restoration includes the decommissioning and removal of all redundant facilities and the conditioning of wastes generated from this process to produce passively safe waste packages for long-term storage and eventual disposal in accordance with Government policy. In determining the long-term strategy for the management of solid radioactive waste it must be recognised that the strategy for decommissioning and waste management must be coherent and consistent to allow the process to be implemented efficiently, safely and cost effectively.

    —  UKAEA recognises the need to separate the policy development for the long-term management of radioactive waste from the implementation of this policy. UKAEA believes that a separate consultation unit should be set up within or by DEFRA to oversee the consultation process. The unit should include experts with knowledge and experience in consultation techniques, nuclear waste management issues and long-term waste management options. The Consultation Unit would become a new "policy unit" on completion of the consultation process. This Policy Unit would specify the criteria and standards, which must be met in delivering the waste management option agreed from the consultation process.

    —  UKAEA believes that there is scope for rationalisation and simplification in the governance of radioactive waste management. The Liabilities Management Authority should become responsible for optimising waste management throughout its life cycle from decommissioning to final long-term storage or disposal. The specification of waste packaging requirements and the approval of a specific waste packaging proposal (through the issuing of a letter of comfort) could also be part of the role of a future LMA; in any event these roles should not require a separate specialist organisation.

  More detailed points follow.

  UKAEA has considered the structure of the industry and advisory bodies both during and following the consultation process and believes that:

      1.  Policy development should be independent of the nuclear industry and separated from the implementation of policy.

      2.  Governance in relation to radioactive waste management should be simple with as few institutions and interfaces as possible.

  The UKAEA view is summarised in the following diagram and text.


  For the consultation period, a dedicated, full-time body—a "consultation unit"—should be set up within or by DEFRA to oversee the consultation process. The current advisory role of RWMAC would be absorbed into the consultation unit which would manage the responses to the consultation process, identify gaps in knowledge and commission research work to address these gaps. The unit should include experts with knowledge and experience in consultation techniques, nuclear waste management issues and long-term waste management options. The Consultation Unit should be independent of the nuclear industry and funded directly from Government to ensure public support in the consultation process.

  UKAEA believes the new Liabilities Management Authority could also have a role to play. The scope and structure of the LMA has yet to be defined, but UKAEA believes that it could usefully contribute to implementing Government waste management as well as decommissioning policy. Decomissioning is but one part of waste management and the LMA should become responsible for optimising waste management throughout its life cycle from decommissioning to final long-term storage or disposal. This also minimises interfaces and simplifies relationships.

  The LMA could also define, in consultation with the regulators, waste packaging specifications for long-term storage of ILW and HLW. The LMA could advise the licensed Operating Companies (OpCos), responsible to the LMA for delivering the work programmes, on the timing of waste packaging and the specifications this packaging must meet (ie waste container dimensions, performance targets, and fissile limits). The LMA could also commission any necessary generic research in support of these packaging responsibilities.

  The approval of any specific waste packaging proposal and the issuing of a "Letter of Comfort" could also be part of the role of the LMA. The OpCo tasked with packaging the waste would make a packaging case to the LMA defining how they proposed to meet the packaging specifications.

  Whatever the ultimate arrangements they should be directed towards simplifying organisational interfaces which might otherwise be complicated by the addition of the LMA and DEFRA consultation process. It must as a minimum eliminate duplication.

  "Para 6.25—Your views are invited on the need for an independent body to advise the Government and the Devolved Administrations on information needs and research requirements, and whether any of the organisations or models above would be able to provide the independent and authoritative advice and/or the research management we require. You are also invited, if you wish, to outline alternative arrangements for discharging these roles."

  The response to para 6.10 has outlined UKAEA's proposed structure for the industry during the consultation process. Following consultation this structure would require very little amendment to provide continued independent advice to the Government and Devolved Administrations.


  A new "policy unit" would replace the consultation unit. This could be the Nuclear Waste Management Commission as defined in the consultation document. This Policy Unit would specify criteria and standards the LMA and the OpCos must meet in delivering the option from the consultation process. This body should be independent of the nuclear industry and consist of experts with knowledge and experience in areas relevant to the option chosen from the consultation process. The Policy Unit could be funded either directly from Government or by a levy on the nuclear industry.

  The Policy Unit would specify the research that should be undertaken to support the development of the long-term waste management option. It would also peer review research work and provide advice to Government on the strategy for the long-term management of radioactive waste.

  The LMA would be tasked with delivering the option resulting from the consultation process and would contract with an OpCo or OpCos to deliver this option. The LMA would undertake generic work to support the development of the option; the OpCo(s) would also have to undertake specific research work to support its delivery.

  The role of waste package specification and packaging approval, as defined in the response to para 6.10, would continue following the consultation process, although it might need to be reviewed in the light of the chosen option for the long-term management of radioactive waste.


 
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