WCSSG response to NDA Strategy III – working group discussion outputs

The following sections give a record of outputs from the facilitated feedback discussions on Strategy III. These form the basis of the WCSSG’s formal response.

Contents:

Risk and Hazard Reduction and Waste Management……………………………….01

Spent Fuel Management and Nuclear Materials………………………….………….04

Critical Enablers……………………………………..…………………………………...06

Environmental Health……………………………………………………………………10

Low Level Waste Repository …………………………………………………………..11

Risk and Hazard Reduction and Waste Management working group

25 November 2015

Overview comments

  • How will you keep momentum going, to make progress?
  • How do we make nuclear waste safer, sooner?
  • Keep the public informed, and put numbers into the strategy.
  • How successful was previous strategy, including LLWR?
  • Put numbers into the Strategy. Ten years on, we still don't have dates, times and numbers.
  • What is “waste”, and when is it an asset?
  • Removal of intolerable risk must always be the national priority.
  • What is the plan for a unified infrastructure?
  • We appreciate that this is a national strategy and that NDA must act on a broad front, but its focus must be on its biggest hazard, and reducing that risk.

Strategy section 3 – Site Decommissioning and Remediation

3. 1 Decommissioning

  • LP&S are high-risk priority, and NDA must ensure Sellafield’s focus in this area is not distracted.
  • The Strategy is silent on the quantification of risk, so it is less able to make a compelling case to Government for funding. It needs to be clear (e.g. SEDs) where the greatest risk is, how big it is and why that needs to be such a priority. Priorities must be ranked.
  • Defuelling from reactors does not remove risk, it simply moves the risk to Sellafield.Don't focus on Magnox Generation sites at the cost of reducing risk. Risk must be the first priority, and if there is anything left over it can go elsewhere.Nothing should happen at the expense of intolerable risk.
  • The Strategy needs to beware decisions made now that set up intolerable risk in the future.
  • It is not clear how the Strategy addresses MoD waste on the Sellafield site.
  • NDA needs to show how the Strategy builds on the successes of the last period, e.g. LLWR, and learns from failures.

3.2 Land Quality Management

  • Sellafield land will remain contaminated, so the Strategy cannot define an end-state.Future land strategy needs to be realistic, and based on data (e.g. half-life) – e.g. will we ever achieve unrestricted, free access at Sellafield? It will need a safety case to manage contamination impact, and how land must be used.
  • A more credible end-state will mean money is better spent, because we will have a better plan to get there.
  • The strategy must avoid diverting money from high-risk to “nice to haves”, such as simple site end states.
  • Consider in-situ disposal by creating licensed sites where the waste is located, rather than removing waste just to bury it elsewhere, particularly if “free access” end-state means using taxpayer money just to move risk.
  • The waste strategy on land use is incoherent. For example, spoil (very low level waste) is removed for new-build and put into landfill, and yet LLWR will need tons of profiling material to go on top of the repository. To avoid duplication, cost and local impact, the strategy needs to promote better liaison and co-ordinate infrastructure between SLCs.
  • The Strategy needs to consider opportunities (such as this) for waste to become an asset.
  • Need better future use of trains, e.g. taking spoil to Drigg.

Strategy section 6 – Integrated Waste Management

6.1 Radioactive Waste

  • Digging 1.5km underground will mean the excavation fills with water. We have two mountains that are solid, with few faults and little water, which could provide geological cover with lagoons to the side.Where is the mining skill and expertise in the Strategy? Where in the Strategy is the search for alternative solutions?
  • The Strategy has an all-or-nothing approach in terms of LLWR or GDF. What about the vast amounts of waste for which there are opportunities to act sooner than the GDF?
  • The draft strategy assumes a length of time for above-surface storage, and we don't think that timescale is credible. Therefore, the waste packaging strategy is not credible.
  • There is no evidence of a GDF repository being available in the next few decades, so any waste forms produced now (to stabilise legacy waste) must themselves be stable for centuries in surface or sub-surface storage.
  • There is very little mention of R&D in the draft Strategy. There are hundreds of as-yet unknowns at Sellafield, but that is no reason not to invest in R&D on waste, particularly given the lead time needed for waste planning.
  • The Strategy refers to the levels of waste, but explains only two. Also, it should reflect all categories of waste, not just the three top-line or summary levels.
  • The best way to store plutonium is to use it. If we start processing those fuel rods now, the money can go back to the taxpayer.
  • The current draft doesn't take into account the other operations likely to come to Sellafield, e.g. spent fuel from new-builds. This needs attention given time-lags involved.

6.1.2 Solid LLW

  • The draft strategy is too weak on encouraging / promoting recycle and reuse of VLLW, particularly in the supply chain. It needs to promote the benefits that will accrue for the local area. Again, it needs to fully challenge where waste can be considered an asset.

6.2 Liquid and Gaseous Discharges

  • NDA should challenge OSPAR, irrespective of previously-agreed targets, if it believes it to be the right thing to do – to extend reprocessing rather than leave unprocessed fuel. Again, this is an example of where data is needed, to support the argument, or to justify not making the argument. With data, the NDA can better show its teeth.
  • Is the strategy innovative enough? For example, are there economic opportunities for non-radioactive waste, such as processing asbestos into gravel (to reduce risk on site and to make money from other businesses)?
  • Do not dilute the strategy with appeasing words. For example, “unnecessary introduction of radioactivity into the environment” is not “undesirable”, it is “illegal”.

Spent Fuel Management and Nuclear Materials working group

27 November 2015

Overview comments

  • It feels like spent exotics are foisted upon us, and this creates community issues.
  • Good that there is continuity in the strategy.
  • The disposal of fuel from the decommissioning of submarines gives us grave concern; we have no say on MoD fuel.
  • Want an overall strategy with community benefits, linked to the whole nuclear industry (not just NDA).
  • Strategy is very clear and readable.
  • An overall question re the name NDA – given that Sellafield's mission / expertise is changing beyond decommissioning.

Strategy section 4 – Spent Fuels

  • Beyond the end of reprocessing, how is fuel going to be managed, and who owns it (especially overseas fuel)?
  • Strategy contains little on what we intend to do with exotics; the state it will be left in; how it will be stored. (Similar issue as for submarine fuel.)
  • What will happen to Dounreay fuel if Scotland becomes independent?
  • The reprocessing timetable is driven by time rather than by need.
  • Ownership of / treatment of / plans for submarine fuel needs to be much clearer.
  • Need to think more about how these particular issues fit into the totality – strategy needs to make clearer the whole jigsaw picture, even when parts of that jigsaw sit elsewhere, e.g. MoD.
  • Strategy seems to assume that we will put plutonium into a GDF; councils are not happy with that.
  • Are we open to reprocessing as a safer / greater value solution than GDF?
  • Differentiating between different types of spent fuel is not that important but calling out and managing the differences between NDA and MoD fuels is important.
  • What will happen to new-build fuel / plutonium? Is this NDA’s responsibility? Will it be, in 10 or 20 years’ time?

Strategy section 5 – Nuclear Materials

  • We have a substantial stockpile of a useable commodity. The strategy contains no mention of the cost to government of holding this commodity...and the balance of cogs between long-term storage and disposal. Share the maths with us – what are the data, how that has shaped decisions, is the strategy right? Explore options.
  • As a group, we urge NDA to complete its review of plutonium urgently, to give clarity on our direction of travel.
  • Whether we use or re-use, there are potentially different end states. The strategy needs to justify the community risk and the cost of the plutonium stockpile. Sellafield's risk profile is increased by this holding, particularly in the current security climate.
  • An objective of the strategy must be to increase national confidence in our capability at Sellafield, given its impact on new-build.
  • Strategy 3 is less explicitly about the use of plutonium than it was in 2011. It needs to make the MOX fuel position clearer, and include all the other options (already in public domain) that are in consideration.
  • Will GDF material be retrievable or not, and what influence will NDA have over that decision?
  • The strategy requires a statement on exotics: we have other residual exotics (e.g. from prototype reactors), which are currently stored and will be reviewed and reprioritised as other fuels are cleared.

Critical Enablers working group

6 & 27 August 2015

Strategy section 7 – Critical Enablers

General

  • The Energy Act mandates the NDA to progress the clean-up and decommissioning mission. Securing the appropriate resources and therefore the delivery of the enablers/capability to deliver that mission is similarly mandated by statute. NDA Strategy should be clear on what NDA will do to meet all of those responsibilities.
  • Is the importance of the NDA mission and its delivery to the overarching Government/DECC energy and nuclear policy adequately captured – mission success is crucial to maintain nuclear reputation and credibility, future nuclear generation phases will require waste management and spent fuel management support services.
  • NDA must plan for a changing environment and reflect this in its Strategy; where change is already happening that is outside of the direct control of the NDA, the Strategy must be more specific than previously on how the NDA will manage/interact with that change and ensure its mission is not prejudiced.
  • New-build sites adjacent to existing NDA sites – what is NDA’s strategic approach around engagement and alignment with new build?
  • Future nuclear generation phases will require waste management and spent fuel management support services.
  • The NDA estate is diverse both in location and impact. Where that impact is significant in dominating local economies, should the NDA have specific regional strategies that cut across both mission delivery and enablers i.e. driving economic growth in areas where significant opportunities arise as opposed to managing economic decline?

7.2 Research and Development

  • The Strategy makes no reference to ethical standards in the development of science and technology; what is the NDA’s approach in considering ethical issues both in overall strategy and research outputs; i.e. do we take into consideration the Nuffield/Oxford/Cambridge secondary science curriculum?
  • The NDA should have a role in setting and monitoring the application of ethical standards in the R&D it commissions, and act as an exemplar for the industry.
  • Can the NDA increase the amount of direct research undertaken by its own estate (especially at Sellafield) and maximise the R&D’s access to the on-site challenges, in an effort to both maintain existing capability and sweat other assets and programmes already invested in?
  • R&D business planning must be focused on delivering acceleration of the mission and provide value for the taxpayer – not science for science’s sake.

7.3 People (including skills and capability)

  • The NDA’s Strategy is silent on its approach to the application of the minimum wage and zero hours contracts throughout its estate and the supply chain. The NDA should set standards for SLCs to follow, and ensure they reflect those in procurement activities and that ethical considerations are referenced in our STEM activity.
  • The skills strategy must make it plain that its aim is to attract, develop and then retain the skilled workforce required to deliver the mission.
  • The approach could focus on examining the next ten-year skills profile and develop activities and demand plans from SLCs that meet the ‘attract, develop and retain’ concept and also give a strong lead on the development/reskilling of the current workforce – an overall approach to ‘grow your own’.
  • NDA should have the lead role in pulling together the various SLC and supply chain plans into a cohesive approach – ensure sites not competing for the same workforce.
  • STEM activity should be aimed at both primary and secondary pupils and be focused on supporting HR as opposed to socio-economic/corporate responsibility drivers.
  • NDA should have the ability, and Government endorsement, to work with education, skills and training providers to establish curricula that help tackle the skills challenge.
  • NDA should encourage the use of its own workforce as ambassadors in STEM and other outreach activity, supporting time to undertake these activities;its current workforce should be its advocates, ambassadors and an extension of its recruitment approach.
  • Why is the Strategy silent on NDA’s tactical approach; where can this be found if it does exist and where is it referenced?
  • NDA to ensure SLCs appropriate qualifications to the task in hand, don’t over-recruit, as then people move on quickly causing gaps in mainstream activity i.e. blue collar support; also why does everyone need O-level equivalents, even if they area wagon driver or work in the laundry?
  • In Cumbria, training infrastructure is reaching capacity; where is the Strategy to ensure sufficient additional facilities are in place at the right time?
  • More broadly, NDA should, directly or through its SLCs, support schemes to get people into work – employment brokerage, assisted travel etc.

7.4 Asset Management

  • Robust asset management must be delivered as opposed to being seen as a nice to have – it will secure value for money in a strategic context.
  • Asset care and investment to maintain high standards must be seen as a priority in allocating resources.
  • This can be secured by an approach that ensures consistent and continual investment as opposed to just building on a policy of sustaining values.
  • NDA should adopt asset definition as per ISO 5001.
  • NDA should adopt best practice ethical management as owners, landlords and neighbours of valuable public assets.

7.6 Supply Chain Development

  • Energy Act gives NDA the responsibility to maintain and develop a robust and successful supply chain, linked to new missions and economic sustainability; what is the NDA’s strategy relevant to supporting supply chain development than just its own mission?
  • What are the barriers, either in statute or in procurement terms, that hamper better supply chain support, and how does NDA seek to remove them?
  • Completely endorse the principle that NDA and SLCs should set the standard for the new build players in supply chain engagement – indeed the NDA estate may have some catching up to do.
  • NDA should set the high standards for supply chain engagement and procurement, and demand application by its SLCs and their supply chains – if you want to do business with nuclear these are your responsibilities. The days of relying on SLCs need to be updated – NDA is the statutory authority.

7.8 Socio-economics

  • NDA mission has changed since 2005, and the regional context is different; one fit doesn’t suit all. Regional strategies need developing, particularly in a long-game community like Cumbria.
  • Those strategies must also link into regional economic growth policies if both the community and industry is to benefit.
  • Activity must link to negative impacts of a community dominated by a nuclear employer; more work is needed on the nuclear have-nots to broaden local people taking advantage of opportunities.
  • Lots of investment that is not nuclear-driven per se can support the NDA mission – quality of life and place, quality education and health services, better public transport links and, where appropriate, using nuclear skills to attract diverse investment and different jobs.
  • We have a lot in Cumbria, sweat it and build from it – a position of strength.
  • In Cumbria, socio-economic investment should support the sustainability of the industry and its expertise, and NDA has a key role in advocating to Government the essential services and opportunities the Cumbria community provides. These should attract targeted investment from Government and Europe.

7.9 Public and stakeholder engagement