Letter and Memorandum by UKAEA
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
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
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
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:
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
16 July 2002
UKAEA Response to the DEFRA Consultation Document "Managing
Radioactive Waste Safely"
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
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
For the consultation period, a dedicated, full-time bodya
"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
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 6.25Your 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
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
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.